Code of Ethics
Purpose
This Code of Ethics (“Code”) explains the position of Cint Group AB and its subsidiaries and affiliates (the “Company,” “Cint,” or “Cint Group”) on key issues in three important areas: Anti-corruption and Ethics, Labour Standards and Human Rights, and the Environment. Other than through this Code, these are addressed more fully in Cint’s related policy statements (e.g., Anti-Bribery, Human Rights, Modern Anti-Slavery Statement (Australia), and Modern Anti-Slavery Statement (UK)), which are fully incorporated herein by reference.
To support the Code of Ethics, in particular our commitments to comply with the law and be true to our other core principles and values, on an operational level Cint has put in place policies in specific compliance areas that are of particular importance to Cint’s operations: anti-bribery, competition and trade sanctions. Cinters (defined below) are expected to be familiar with the requirements of these policies.
In line with the principles articulated in the Code of Ethics, Cint has also published a Whistleblowing Policy and Procedure for reporting certain serious misconduct at Cint. As described in more detail in the Whistleblowing Policy and Procedure, Cint has zero tolerance for retaliation against employees who, in good faith, report serious misconduct through the whistleblowing system.
It is our firm belief that following the Code of Ethics is essential to the continued success of Cint, and we thank all Cinters and Third Parties (defined below) for their efforts to uphold these standards.
Scope
The Code of Ethics applies to everyone who renders services to or on behalf of Cint, including but not limited to employees, executive officers, and members of the Board of Directors (“Cinters”). All Cinters are expected to follow this Code of Ethics. Agents, contractors, consultants, vendors, suppliers, distributors, representatives, and other business partners to and of the Company (“Third Parties”) are also expected to uphold the principles set forth in this Code. Managers have a special responsibility to establish a work environment where ethical behaviour is encouraged and rewarded. Employees should understand that every instruction that is given, or goal that is set, by their supervisor is done in the context of this Code.
Roles and responsibilities
Chief Executive Officer – The CEO is ultimately responsible for ensuring the continuous operations and compliance of the company. CEO may instruct leadership and other employees and business functions to implement and effectuate company policies. Those instructions are set out in this document.
Policy subject
Anti-corruption and Ethics
Anti-bribery
Cint refuses to accept or retain business through bribery. Cinters shall not directly or indirectly offer, promise, grant, or authorize the giving of money or anything of value to someone to unduly influence the recipient in the performance of professional duties or in order to obtain or retain an improper business advantage. Cinters shall not ask for or accept improper benefits from others in connection with the performance of their duties to Cint. Applicable anti-bribery laws, and Cint’s Anti-Bribery Policy statement(s), are to be strictly followed.
Competition
Cint and its employees endeavour to follow applicable competition law. Cinters shall not engage in discussions with competitors regarding market allocation, competitive information exchange, production and sales quotas, or bid rigging.
Trade Sanctions
Cint endeavours to comply with United Nations sanctions and applicable sanctions under the laws of the European Union, the United Kingdom, and the United States. Cinters shall not attempt to circumvent applicable trade sanctions and shall adhere to Cint’s Trade Sanctions Manual.
Conflicts of Interest
Cinters shall avoid situations in which their own personal interest, or the interest of their family members, friends, or acquaintances, affect their ability to make decisions that are in the best interest of Cint. Every business decision is to be based on the best interests of Cint, not personal interests. A “family member,” for avoidance of doubt, includes but is not limited to parents, grandparents, siblings, children, spouses (including common law spouses) and domestic partners, aunts/uncles, nieces/nephews and first cousins, including in-law or step relations of any of the foregoing.
Corporate Opportunities
If a Team Member uncovers potential opportunities for Cint, that individual shall endeavour to use the opportunity to advance Cint’s goals and interests. Cinters may not use such opportunities to advance their own interests or the interests of any family member, friend, or acquaintance.
Confidentiality
It is important that Cinters understand and know how to protect confidential information, including business secrets. Any non-public information about Cint, as well as certain information about our employees, customers, suppliers, vendors, or other business partners, that you may have or access as part of your work for Cint, whether electronic, written or verbal, are considered confidential information. Cinters shall not share non-public information with anyone other than those who have both the authorization to access it and a need to know it in order to do their jobs. Cinters are expected to take appropriate steps to protect confidential information, such as by asking companies or individuals outside of Cint to sign a confidentiality agreement before gaining access to our information and following other policies and contractual obligations. Cinters should ask their manager or the General Counsel if unsure whether information can be shared or how to share it.
Labour Standards and Human Rights
General
Cint endeavours to follow all requirements set out in applicable law or consistent with its Modern Anti-Slavery Statements and Human Rights Policy with regard to worker safety and human rights. Cint understands that its business may have an impact on human rights issues, particularly in relation to people’s working and living conditions, and endeavours to seek opportunities to understand and then mitigate any such impacts consistent with this Code, its Modern Anti-Slavery Statements and Human Rights Policy.
Privacy
Cint understands the importance of protecting individual’s right to privacy and the need to protect the confidentiality and integrity of the personal data (personal information) in its care. Cint has established a comprehensive privacy program which is built on compliance with all applicable privacy laws and regulations, most notably the General Data Protection Regulation (GDPR). Cint recognizes the rights of individuals under the applicable laws and regulations and strives to adhere to a standard which recognizes privacy rights globally. Confidential personal data is safeguarded with strong data protection and information security and regular training on privacy is provided. Personal data is disclosed to third parties only when legitimate grounds to do so have been established and appropriate measures have been taken to protect the personal data to be transferred.
Equal Opportunity and Anti-discrimination
All Cinters should be treated with dignity and respect. Cint endeavours to provide equal employment opportunities. Discrimination or harassment based on race, ethnicity, gender, physical disability, sexual orientation, religion, or any other basis made unlawful by applicable law is not tolerated.
Working Conditions
Cint endeavours to provide a healthy and safe work environment. Abuse (whether physical or verbal) and unlawful harassment are strictly prohibited.
Child Labour
Cint recognizes and honours the rights of every child to be protected from economic exploitation and from performing any work that is likely to be hazardous, to interfere with the child’s education, or to be harmful to the child’s health or physical, spiritual, moral, or social development. Cint endeavours to comply with applicable law and internationally-recognised standards regarding child labour, consistent with its Modern Anti-Slavery Statements and Human Rights Policy.
The Environment
Cint endeavours to comply with all applicable environmental laws and regulations. Environmental resources are to be used responsibly and carefully, and Cint constantly strives to conduct its business in an environmentally sustainable way, by way of, for example, improved efficiencies or investment in sustainable products, services, and technologies. Ideas from Cinters that reduce the environmental impact of Cint’s activities are supported and encouraged.
Monitoring of Compliance and Enforcement
Understanding and Complying with the Code of Ethics
It is the personal responsibility of every Cinter to understand and comply with this Code of Ethics, and of every Third Party to uphold its principles. Managers should ensure that their subordinates fully understand and comply with the standards and requirements stipulated in this Code of Ethics. Any concerns encountered in enforcement as well as comments or suggestions for improvement should be escalated in line with Cint’s standard reporting procedures, including, if appropriate, to the CEO. Reports of violations of this Code of Ethics can also be submitted through Cint’s confidential whistleblowing system, which is provided by an external partner to ensure secure reporting. This communication platform is encrypted, password protected, and can be completely anonymous. Reports can be made electronically or through a voice recording system by visiting (reporting website purposefully removed from public version of this Code).
Escalated concerns or reports regarding violations of Cint’s Code of Ethics should be made in good faith and will be handled in accordance with Cint’s policies. Any person submitting or assisting with submitting such report is protected against discrimination or retaliation for doing so.
Violation of the Code of Ethics
Cint does not tolerate any illegal or unethical acts. Anyone violating the Code of Ethics may be subject to disciplinary action, up to and including termination of employment, assignment or contract.