1 Intro­duc­tion

The primary pur­pose of the code of con­duct of the Codelab sp. Z o.o. (referred to below as Codelab) is to com­mu­nic­ate to all employ­ees and stake­hold­ers our shared eth­ic­al val­ues and busi­ness prin­ciples and, fur­ther­more, to estab­lish guidelines for our daily work. We encour­age our sup­pli­ers and busi­ness part­ners to adopt the prin­ciples of this code of conduct.

Our busi­ness activ­it­ies are based on high eth­ic­al stand­ards. We pro­mote fair com­pet­i­tion in com­pli­ance with applic­able legis­la­tion and expect our employ­ees to observe the prin­ciples of fair com­pet­i­tion in per­form­ing their work for Codelab.

Codelab com­plies with all rel­ev­ant laws and reg­u­la­tions in every coun­try in which it oper­ates. In situ­ations where legis­la­tion provides no set­tle­ment, we work on the basis of our own stand­ards and prin­ciples, val­ues and cor­por­ate cul­ture. Should leg­al reg­u­la­tions con­flict with the prin­ciples of the code of con­duct, the law will retain valid­ity. It is the respons­ib­il­ity of each and every employ­ee to be aware of applic­able legis­la­tion or to seek appro­pri­ate advice in order to ensure com­pli­ance therewith.

1 Value-based action

1.1 Human rights

Codelab pro­motes and respects the prin­ciples of the United Nations Uni­ver­sal Declar­a­tion of Human Rights, the prin­ciples of the ILO (Inter­na­tion­al Labour Organ­iz­a­tion) Declar­a­tion on Fun­da­ment­al Prin­ciples and Rights at Work, the Rio Declar­a­tion on Envir­on­ment and Devel­op­ment, and the United Nations Con­ven­tion against Cor­rup­tion. Fun­da­ment­al human rights should be ubi­quit­ous, recog­nized and respec­ted, and applied to all employ­ees – irre­spect­ive of wheth­er they are engaged on a tem­por­ary or per­man­ent basis.

1.2 Equal treat­ment and equal opportunities 

Codelab does not per­mit any form of dis­crim­in­a­tion with regard to gender, nation­al­ity, reli­gion, race, age, dis­ab­il­ity, sexu­al ori­ent­a­tion, polit­ic­al opin­ion, trades uni­on mem­ber­ship and social or eth­nic ori­gin. We treat all employ­ees and col­leagues with respect and dig­nity. We pro­mote a cul­ture of equal oppor­tun­ity and diversity, with pos­i­tion, remu­ner­a­tion and per­son­al suc­cess depend­ing on indi­vidu­al skills and per­form­ance. All employ­ees are remu­ner­ated appro­pri­ately – as a min­im­um in accord­ance with applic­able leg­al regulations.

1.3 Cor­rup­tion

The abuse of power, nepot­ism and cor­rup­tion, includ­ing offers of illi­cit pay­ment by an employ­ee or organ­isa­tion, will not be tol­er­ated. Any attempts to bribe Codelab employ­ees must be repor­ted to man­age­ment immediately.

Gifts and sim­il­ar bene­fits may be offered to or accep­ted from third parties if they are of low value and can be deemed to be the sign of hos­pit­al­ity in the course of nor­mal busi­ness practice.

1.4 Anti­trust and Com­pet­i­tion Principle

Codelab is com­mit­ted to enga­ging in fair and vig­or­ous com­pet­i­tion, in com­pli­ance with anti­trust and com­pet­i­tion laws and reg­u­la­tions. Codelab is against activ­it­ies, such as agree­ments between com­pet­it­ors that fix prices, cer­tain restrict­ive sup­ply agree­ments, or unfair use of a strong mar­ket pos­i­tion to harm com­pet­i­tion. Codelab sup­ports and upholds the prin­ciples of free and unres­tric­ted com­pet­i­tion between all play­ers at all levels of the sup­ply chain. It means that Codelab com­petes inde­pend­ently from oth­er mar­ket play­ers and does not seek to con­trol the com­mer­cial policy and prac­tices of its cus­tom­ers. Codelab does not coordin­ate its com­pet­it­ive beha­viour with oth­er com­pan­ies to try to avoid or reduce the rigours and uncer­tainty of a com­pet­it­ive mar­ket place.

This Prin­ciple applies glob­ally to all employ­ees and may apply to third parties act­ing on behalf of Codelab. Fail­ure to com­ply with anti­trust and com­pet­i­tion laws could lead to crim­in­al and civil pen­al­ties for Codelab and any per­son (includ­ing employ­ee) per­son­ally, dis­cip­line con­sequences for employ­ees, busi­ness dis­rup­tions, and harm to Codelab’s reputation.

1.5 Work­ing conditions

Codelab opposes child labour and all oth­er forms of forced labour. Codelab sup­ports the free­dom of asso­ci­ation for all employ­ees. All employ­ees are entitled to join a trades uni­on and to par­ti­cip­ate in nego­ti­ations for col­lect­ive agree­ments. Employ­ees must not be sub­jec­ted to any form of phys­ic­al pun­ish­ment and any form of phys­ic­al, sexu­al, psy­cho­lo­gic­al or verbal har­ass­ment. All employ­ees are assured a safe and healthy work­ing environment.

1.6 Inter­ac­tion with the environment

Codelab pro­motes care­ful inter­ac­tion with eco­lo­gic­al chal­lenges and con­ducts its busi­ness in a respons­ible man­ner. All employ­ees should fol­low and respect Codelab’s eco­lo­gic­al approach.

2 Iden­ti­fic­a­tion

2.1 Pro­tect­ing com­pan­ies’ assets

Pro­tect­ing the company’s tan­gible and intan­gible assets (such as intel­lec­tu­al prop­erty) is essen­tial for Codelab’s busi­ness suc­cess. All employ­ees are obliged to use assets only for legit­im­ate busi­ness pur­poses and to pro­tect them from loss and unau­thor­ized use. Codelab’s assets may not in any cir­cum­stance be used for illeg­al or improp­er purposes.

2.2 Polit­ic­al involvement

Codelab is neut­ral towards politi­cians, can­did­ates and polit­ic­al parties and does not sup­port them fin­an­cially or in any oth­er man­ner. Neither Codelab’s name nor any resources under Codelab’s con­trol may be used to pro­mote the interests of parties and politicians.

2.3 Insider dealing

Codelab expects all employ­ees to behave as required of insiders even if they are not actu­ally registered as insiders. Employ­ees must treat all inform­a­tion and secrets relat­ing to cur­rent and future busi­ness activ­ity with the utmost con­fid­en­ti­al­ity. Inform­a­tion relat­ing to Codelab’s busi­ness activ­it­ies, its cus­tom­ers and part­ners as well as to indi­vidu­al pro­jects may not be mis­used or dis­closed to third parties.

2.4 Account­ing and reporting

Codelab’s account­ing and report­ing must be per­formed in accord­ance with gen­er­ally accep­ted prin­ciples of account­ing and its account­ing records must provide a true and authen­t­ic insight into its fin­an­cial pos­i­tion. Codelab must always strive to provide open, fair, reas­on­able, prompt and com­pre­hens­ible reporting.

2.5 Respons­ib­il­ity

Codelab man­agers will ensure that the con­tent and sense of this doc­u­ment is dis­trib­uted, under­stood and observed with­in their respect­ive areas of respons­ib­il­ity. Fur­ther­more, employ­ees will be encour­aged to reveal beha­viour that might con­flict with this code of conduct.

3 Sense of purpose

3.1 Focus on success

All employ­ees work to achieve the best pos­sible solu­tions in the interests of our cus­tom­ers and busi­ness part­ners. We strive to achieve con­tinu­ous optim­iz­a­tion and act with short decision-mak­ing pro­cesses. We pro­mote cre­at­ive think­ing and work with a focus on solu­tions without los­ing sight of pro­cess safety.

3.2 Con­flicts of interest

In order to be able to con­duct busi­ness in an open and fair man­ner, all employ­ees and mem­bers of the man­age­ment board must avoid any situ­ation and any interest that might impair their judge­ment with regard to their duties towards our employ­ees, cus­tom­ers, sup­pli­ers and oth­er busi­ness partners.

4 Excel­lence

4.1 Qual­ity standards

All employ­ees apply their high level of pro­fes­sion­al com­pet­ence for the bene­fit of Codelab and its cus­tom­ers. The work of every­one is driv­en by a high stand­ard and aware­ness of quality.

4.2 Aware­ness of inform­a­tion security

All employ­ees treat the data entrus­ted to us by cus­tom­ers, part­ners and col­leagues with the utmost care.

4.3 Know­ledge management

All employ­ees share their know­ledge with each oth­er. Employ­ees sup­port one anoth­er in achiev­ing their tar­gets and sub­or­din­ate their own interests to the com­mon good.

4.4 Con­tinu­ous improvement

Codelab seeks to improve its busi­ness oper­a­tions on a con­tinu­ous basis and encour­ages all man­agers and employ­ees to par­ti­cip­ate in this process.

5 Con­clud­ing remarks

This code of con­duct applies to all busi­ness activ­it­ies of Codelab in all coun­tries. All employ­ees are bound by this code of con­duct and always strive to put it into prac­tice in their daily work.

Infringe­ments of this code of con­duct will not be tol­er­ated, wheth­er expli­citly or impli­citly. Viol­a­tions of this code of con­duct may be repor­ted anonym­ously and con­fid­en­tially to the man­age­ment of the leg­al depart­ment or via Codelab’s com­pli­ance func­tion mail­box. Any­one report­ing a viol­a­tion in good faith need not fear any form of reproach. In con­trast, fail­ure to observe this code of con­duct may lead to cor­res­pond­ing dis­cip­lin­ary action.

Our code of con­duct is reg­u­larly reviewed, com­mu­nic­ated and made avail­able centrally.