Code of Conduct

Preface

Business is not about winning or losing. Business is a creative process: it’s about building, changing and adapting continuously. Instead of focusing on the outcome, we are focusing on how we play.

The Board of Directors outline in this code the principles and practices that define our ethical standards and the way we conduct business. The definition of our standards and values is not difficult. The challenge is to live up to them even when times are rough.

We follow this code in order to foster a culture where responsible behavior, ethical standards, integrity, accountability and trust are key factors to protect our people, our reputation, our customers and our shareholder value.

Conduct

At Consulteer we are one family. We are a group of people which truly cares. Our main goal is to bring meaningful inspiration & innovation to every organization and become their most beloved partner.

The core of professionalism is ethical behavior. It distinguishes professionals from other players in the marketplace. Consulteer and all its employees demonstrate their commitment and accountability to ethical behavior on a daily basis by adhering to our code of conduct and its ethical standards.

We will become a strong and more successful enterprise when we conduct business in an honorable and responsible fashion. One enterprise that represents our three core values “all for one”, “we care” and “accountability & commitment” in every fiber.

These three core values are the base of our code. They are the foundation we stand on and help us to put our values into action.

ALL FOR ONE.

All members of our organization support each other and pledge to support our enterprise. An ecosystem where transparency, fairness and consistency are crucial to our success. Our rule is simple. We believe in the culture of us.

WE CARE.

We foster a culture which enables and encourages us to speak up when problems, risks and misconducts occur. We care, excite and always strive to challenge the status-quo. We care for what is right and not who is right. We know progress is more important than perfection. We are aware that business is change and therefore we are on the offense. All the time.

ACCOUNTABILITY & COMMITMENT.

We are an organization where every single one of us is taking responsibility for the things we do. We know that committing to our customers, co-workers and shareholders will result in meaningful solutions. We believe that “doing it” is similar to “wanting it”, but “doing it” is just way more efficient...

These values represent our organization. An organization where the element of trust is crucial to our well-being and success.

This code applies to everybody & everything

Each Consulteer employee follows the principles and standards we have defined for ourselves. It describes our relationship with our stakeholders, our competitors, as well as how we treat one another. This code is the foundation of our policies, guidelines and procedures. We also select our co-workers, clients & suppliers using these same principles.

Ignorance is not an excuse

Every employee has to complete our onboarding and training program. Part of this process is the introduction to our standards and values, as well as how to apply them on a daily basis.

All employees, organization sites and partners should act honorably and treat co-workers, clients & suppliers with courtesy and respect. Ignorance isn’t an excuse for violating this code.

Our leadership & our code

This code is fully supported by the Board of Directors, the Executive Committee and all the Consulteer locations. Every one of us needs to make sure that our business conduct and our decisions follow those standards defined in this code. We put the interests of our clients, the organization and the shareholders first.

Once a year the Board of Directors will review this code to ensure that the key developments in regard to our customers, employees and key stakeholders are reflected in it.

Conduct Framework

Our code includes three dimensions on how we interact with one another:

INSIDE VIEW

Our responsibility towards one another.

Business Information & Technology

We use our information technology securely and cautiously to maintain the highest confidence our clients award us with. Information security threats are evolving rapidly and becoming more sophisticated. We carefully store, treat and retain business information and handle it with the utmost care.

Business information may include requirements, specifications, transactional data, contracts, strategies, communication or any other information we receive from our business partners as well as co-workers. Information technology is any software or equipment used to send, store or transform images such as text, images, video, audio, data or general information.

Example: I receive an e-mail that seems to be from our accounting department. This e-mail asks me to review an attached contract. The sender e-mail looks suspicious, so I immediately inform our IT department that I may have been subject to a virus. Thanks to my fast response, no harm was done.

Communication

We communicate in a truthful, transparent and thoughtful manner. How we are perceived is heavily influenced on how we communicate. We prioritize timely, accurate, clear and open communication. This preserves Consulteer’s reputation and the reputation of its locations. Therefore, we are careful of how we communicate with one another, with our clients and other stakeholders.

Communication includes everything written and spoken, information shared at conferences, gatherings on digital (for instance social media, mails, instant messaging) or physical channels.

Conflict of Interests

All decisions we make are in Consulteer’s best interest. Conflicts of interest may affect our judgment, objectivity or loyalty. They can expose us to reputational, legal or financial risks.

Conflicts of interest arise when our personal interests interfere with those of Consulteer. Whenever we have a conflict of interest, we are transparent in disclosing our personal interest, and we remove ourselves from the decision-making process. This behavior fosters an open and fair environment.

Conflicts of interest may arise from personal relationships, financial interests or external positions or activities. These could negatively affect our individual performance or our organization’s interest.

Example: I’m in charge of hiring a new developer for our team. A distant relative applies and while she might be suitable for the position, I am biased. I disclose this information to our human resources department and take myself out of the decision-making process.

Diversity & Inclusion

A diverse and inclusive environment where everyone is treated with respect and without discrimination or harassment is our standard - nothing less.

Different talents, perspectives and backgrounds allow us to better understand our clients and to create richer and more meaningful solutions. Working together in a diverse and inclusive environment enriches the team spirit and increases productivity.

We are committed to a supportive work environment, where employees have the opportunity to reach their fullest potential. At Consulteer we are all expected to do our utmost to create a workplace culture that is free from harassment, intimidation, bias and unlawful discrimination.

We are fully committed to fair and equal treatment. We provide equal opportunities for all employees to develop their professional skills regardless of their age, race, ethnicity, nationality, gender, religion, sexual orientation, disability, medical status or any other class protected by law.

Example: A recent colleague has great ideas, but rarely chooses to share them during the team meeting. Other colleagues take center stage, and he is afraid to speak up. I know how valuable a new perspective can be, so I encourage the team to listen to him. If this does not work, I will speak to my manager.

Fraud

We conduct our business in a legitimate manner. We are honest and transparent.

Engaging in intentionally misleading, or deceitful activities constitutes as fraud. We are committed to ensure the highest standards of integrity and do not tolerate any form of fraud. Acting with the highest integrity fosters trust and builds a solid brand and reputation, while increasing customer loyalty and mutual respect.

Examples of fraud include theft of property, falsification of information, submitting dishonest timesheets and/or claims.

Example: It’s the end of the month and I’m asked to turn in my timesheet. As I forgot to track my time in the beginning of the month, I’m tempted to estimate the hours I worked. I know the recordings must reflect reality. So instead of making up the hours, I try to construct the worked time based on the emails sent throughout the day and I do inform my supervisor.

Health, Safety & Security

We keep our workplace free from anything that endangers our health, safety or security.

Vital to our well-being and team spirit is a healthy, safe and secure working environment. Our value “all for one” also encourages us to look out for one another’s health and safety. Acts that undermine or damage our community will not be tolerated.

We proactively avoid, detect and assess hazards. We follow security procedures and report accidents, injuries, unsafe practices and conditions in a timely manner. We only engage in activities that allow us to conduct our work safely, effectively, and always plan for business continuity.

Example: We opened a new office where anyone can enter our building without identification or batch. Anyone can just walk into the office without registration. As I want to keep our workplace safe, I report this instantly to my office manager.

We are a dog organization

We like any form of beings. Dogs especially.They are welcome in our offices. However, before bringing your canine companion to the office, please make sure to speak with your manager upfront about the guidelines.

Dress Code

Dress well and come to work in what makes you feel comfortable. If wearing a tie makes you happy - go for it! If you like it more casual - go for it!

Intellectual Property

Knowledge is the key to our success; we are obsessed in both the creation and protection of it.

Although we believe that the future will be about wisdom, creativity and the ability to constantly learn, knowledge is still a key part of Consulteer. We protect our expertise at all times and at any cost.

Consulteer owns all intellectual property we create during the course of our work. Some of the intellectual property we get in touch with is owned by our clients. Even after we leave the enterprise, it remains the property of Consulteer or the clients. Intellectual property includes strategy documents, requirements, software specifications, source code or transactional data.

Example: I recently had my laptop replaced. The old laptop do contain source code for several client projects. I proactively clean up the laptop before I turn it in to our IT department to protect our client’s data.

Whistleblowing

We actively speak up if actions we observe are against our code of conduct and may harm the organization's future.

We immediately report any potential violations of laws, rules, regulations, policies, professional standards and the principles laid out in this code to our manager or HR department.

Any form of retaliation against whistleblowers is unacceptable.

We expect our managers to act and report any violations of laws, rules, regulations, policies, professional standards and the code of conduct.

Example: During a recent customer visit, I noticed that one of my colleagues copied data to a USB stick. As we are usually working in the client’s environment, I think this is highly suspicious behavior. I inform my manager about the incident.

OUTSIDE VIEW

Our responsibility towards our business partners and society.

Bribery & Corruption

We conduct business in a fair manner without accepting or offering benefits intended to improperly influence the decision-making process.

We do not engage in bribery or corruption in any way. It is not only illegal, but also compromises our integrity and reputation and undermines fair market opportunities. A long-lasting relationship with business partners is based on a truthful and ethical exchange. Trust is the most powerful quality indicator for our organization.

Giving and receiving of gifts, hospitality, charity or sponsorships will never influence our decision-making process or those of our business partners. This includes bribes indirectly made through third parties.

Example: During a recent business trip to a client, I observed that the account manager gave the client a white envelope. I think this is unusual and highly suspicious behavior. I reported it to the management.

Data Protection

We handle personal data with the utmost confidentiality and use it only for legitimate and specific business purposes.

Our clients and stakeholders expect us to process and protect their personal data properly and with the greatest care. Protecting our client’s data is a vital element for our relationship with our stakeholders, and it allows us to conduct our business effectively and securely. Personal data is any information that can be used to identify someone, such as a name, address or date of birth. The same applies to confidential information of our competitors. We respect them and want to compete with them fairly. But we do not want their or a former employer’s confidential information.

Example: I recently received a dataset from one of our clients for test purposes which includes information of their whole staff with what appears to be real data including the date of birth or private address. While I understand that test data is best as close as the real-world data, I talk to the client first on ways to get a fully anonymized data set. If my client cannot provide this, I will talk to my manager to make sure we can put additional security measures into place.

Sustainability & Human Rights

We deliver products and services that do not compromise our future.

Sustainability is at the forefront of our business conduct. Taking this long-term view helps us to improve our economic efficiency, protect the environment and contributes to sustainable development of societies in the countries we are active.

Consulteer is dedicated to corporate responsibility and official member of the UN Global Compact initiative that is committed to implementing its ten principles in the areas of human rights, labor, the environment and anti-corruption. Human rights are the basic standards needed to lead one’s life with dignity.

Our respect for those principles allows us to develop a balanced approach to our decisions. We select business partners that share these same values.

The ten principles of UN Global Compact initiative include:

Human Rights

Principle 1: Business should support and respect the protection of internationally proclaimed human rights

Principle 2: Make sure that they are not complicit in human rights abuses

Labor

Principle 3: Business should uphold the freedom of association and the effective recognition of the right to collective bargaining

Principle 4: The elimination of all forms of forced and compulsory labor

Principle 5: The effective abolition of child labor

Principle 6: The elimination of discrimination in respect of employment

Environment

Principle 7: Business should support a precautionary approach to environmental challenges

Principle 8: Undertake initiative to promote greater environmental responsibility

Principle 9: Encourage the development and diffusion of environmentally friendly technologies

Anti-Corruption

Principle 10: Business should work against corruption in all its forms, including extortion and bribery.

Environment

Our responsibility towards the planet.

Environmental Compliance

We comply with all applicable legislation and sustainability commitments. We strongly believe in a lean approach to whatever we do. We care about all the resources we have and try to handle them with care and consciousness.

Offices

We rent an eco-friendly, modern offices that are size appropriate and incorporate energy efficiency measures.

We are in a very collaborative discipline, thus meeting people in person at different locations is a key element. However, we strive to reduce our carbon footprint and rent location which are state of the art in terms of energy consumption and efficiency in the cities we are located. Our offices fits the current and projected size of the next 2 years, thus reducing spare capacities.

Example: Wherever possible, we are using a “hot-desk” approach with dedicated spaces for collaboration instead of a fixed office and fixed desk allocation.

Waste & Recycling

We separate waste in all our locations and have it recycled whenever possible.

As an organization, we prevent pollution and reduce the consumption of resources through waste management strategies that promote waste minimization re-use and recycling whenever appropriate.

Example: An employee leaves the organization within the first year. His laptop was acquired less than a year ago. We will re-use it for the next employee that enters the enterprise.

Smart Resource Management

Thoughtful consumption of resources is also applicable to spending time and money. We prefer to spend our resources wisely. Plan our time and the time of others sensibly. If you are uncertain about whether you should spend money or submit an expense for reimbursement, check with your manager.

Transportation

How we move drives our main energy consumption as a consulting organization.

Part of our job is to travel to different locations to deliver our services. The mode of transportation we choose is a major driver for our energy consumption as an organization. We always strive to have the best economical/ecological ratio, to balance the travel time with the carbon footprint we incur.

Example: Some clients require our specialists to work on premises. We cover the public transportation costs in favor of reimbursement of individual transportation for employees that travel often.

Physical & Virtual Meetings

A virtual meeting may reduce our carbon footprint and allow us to work more efficiently. Nevertheless, for Consulteer personal meetings are and will always be a crucial cornerstone of its organization’s values and success. It is a way to express our appreciation towards one another. Therefore, carefully decide whether you conduct a virtual or personal meeting.

For meetings outside our work location, whenever possible and feasible, we aim for virtual meetings in order to respect our responsibility towards the planet and our resources. We support technologies that enable us to work virtually and synchronously.

Example: The monthly management meeting at one of our subsidiaries has been held in person so far. As one of the board members however needs to fly in, we changed it to a personal meeting once a quarter, while the rest of the meetings are virtual.

Conclusion

We will never be able to describe every possible scenario. If you find yourself in an unexpected situation, apply these standards to the best of your judgment, seek guidance or simply ask your manager or HR for help.

We trust you will make the right decisions for our organization and your co-workers. Never forget to put personal resentments or personal enrichment aside and always see our organization at the center of your attention. Treat any human being respectful. At any time for any reason. We trust you will make the right decision.