Integrity is one of the core values in which we, Ciklum, operate. The Code of Conduct is company-wide and describes how we put Ciklum values in the way we work every day. It also explains our commitments and, more importantly, expectations towards everyone. Commitments I make to you and, likewise, commitments you make to me and everyone we deal with both internally and externally.
We run our business ethically and responsibly. We are committed to complying with the highest standards of integrity. We commit to prevent corruption, fraud and anti-competitive ways of working. We are respectful and follow the laws of the land where we operate.
A document can never cover one hundred percent of every situation you may face on a day-to-day basis. The Code of Conduct is your map. It illustrates the values and provides the tools that will help you, that will guide you in making the right decisions consistently and ethically. Also, it is important to raise your hand, speak out if you become aware or suspect a violation of the Code. We introduced Ciklum “Speak Up” to help you with this notification so you may do it with one hundred percent confidentiality and privacy.
Our Code of Conduct is important, critical and imperative. We are all responsible for the reputation of Ciklum and it is an important commitment for us to make and to honor.
As a multi-national group of companies with an identifiable brand the actions of one Ciklumer 1 has the potential to impact upon the entire group. Furthermore, with the diverse range of jurisdictions in which Ciklum operates there is a wide range of laws, rules, regulations, customs and approaches to conducting business. The continued success of Ciklum depends on the actions of every Ciklumer being transparent, lawful and ethical. As such, the primary function of this Code is to provide a unified set of principles and behaviours which are designed to act as a guide to help you make the right decisions for yourself and for Ciklum.
At the same time, the Code of Conduct cannot describe every law, policy or process that may apply to us or every situation that we may face within our everyday role. As a general rule, we are responsible for understanding and complying with the laws, regulations and policies that relate to our business activities.
Detailed guidance on how to deal with important ethical and compliance issues will be described in Ciklum’s corporate policies and other relevant documents. These will be available on the MyCiklum portal. However, being aware, understanding and following the principles described in this Code will help to protect the reputation of Ciklum and Ciklumers.
This Code applies to and is mandatory to be followed by all Ciklumers. Each of us, wherever we work, must behave in accordance with these standards when dealing with fellow Ciklumers, clients, suppliers, stakeholders, governmental
authorities and competitors. We also should require our suppliers or vendors to adhere to this Code or adopt similar ethical standards.
The primary responsibility for maintaining an environment of ethical behaviour rests with Ciklumers through a demonstrated commitment to compliance with the Code of Conduct and with legal and regulatory requirements relevant to Ciklum’s business. To carry out this responsibility, Ciklumers will:
In addition to their professional responsibilities in Ciklum, Senior Management (Leadership team & Invited Members3) must maintain a workplace environment that stresses commitment to compliance with the Code of Conduct and with laws and regulations. Ciklum’s Leadership Team will:
Board of Directors
The Board of Directors4 is accountable for ensuring overall compliance with the Code of Conduct and the legal and regulatory requirements relevant to the Ciklum’s business. The Board has the overall responsibility and authority to:
The Code cannot cover every situation that we may face. We may find ourselves faced with a dilemma that we are not sure how to resolve. If in doubt, ask yourself these questions:
If the answer is ‘No’ to any of these questions, or if you are not sure, stop and seek further advice.
If you become aware or suspect a violation of this Code, we expect you to report promptly to your Line Manager / Project Manager, HR Business Partner / People Partner or Compliance Department. If you are uncomfortable making such a notification, you may do so anonymously using Ciklum SpeakUp.
There are a number of ways that you can seek advice and support, including through any of the following:
Never hesitate to ask questions, raise concerns, or seek the guidance you need. Ciklum will not tolerate any discrimination against anyone who has reported a concern in good faith.
Ciklum will investigate any report of a violation with the principles of the Code of Conduct. You must cooperate fully with any investigation, but should not investigate independently as alleged violations may involve complex legal issues, and you may risk compromising the integrity of a formal investigation.
Conduct that violates the law and/or company policies is ground for disciplinary or remedial action. In addition, failure to report a known violation of law or company policy by someone else may result in disciplinary action for Ciklumers and/or termination of employment/your relationship with Ciklum. The disciplinary action taken will be decided on a case by case basis. The action will be conducted in accordance with Ciklum’s HR procedures and corresponding legal requirements. Where laws have been violated, we will cooperate fully with the appropriate authorities.
Ciklum is a global group of companies, and our business is subject to the laws of many different countries. Each day we interact with a variety of individuals and groups including our clients, competitors, co-workers, suppliers, and sometimes government officials. We are committed to interacting with all in a respectful, ethical manner and in compliance with legal requirements. We would rather miss out on a business opportunity than compromise our integrity.
Bribery is the offering, giving, receiving or soliciting of any item of value in order to wrongfully influence someone’s actions, or to secure an improper advantage5.
Ciklum has a zero-tolerance policy toward bribery and corrupt conduct in any form. Improper inducements involving government officials, clients, suppliers, business partners, and all other counterparties are strictly prohibited. We must all act with the utmost honesty, integrity and transparency in all dealings with clients, suppliers, business partners and government officials. Ciklum does not allow Ciklumers or others to make facilitation payments on its behalf.
We are committed to complying with all anti-corruption/anti-bribery laws, everywhere in the world such as the US Foreign Corrupt Practices Act, the UK Bribery Act and EU Directives. Bribery can have very serious consequences, for the individuals involved and for Ciklum. Any third-party, agent or intermediary acting on Ciklum’s behalf is also prohibited from offering, giving or accepting bribes and improper inducements, including acts of favouritism to influence a business decision.
Ciklum policy and practice requires moderation and the use of good judgement when giving or accepting gifts or entertainment in the course of business. Extending or receiving common courtesies such as business meals in connection with legitimate business activities generally is acceptable. However, in any such dealings, Ciklumers should not request, accept, offer to give or give anything of value that would give the appearance of impropriety or suggest that the gift or entertainment was intended in any way to influence a business decision or to obtain an improper advantage.
A gift can be an item, but it also can include event tickets or the provision of services when the gift provider is not otherwise involved in the event or service (e.g. the giver provided the tickets but does not accompany the recipient to the event). Entertainment is distinguished from a gift as it typically involves meals, events or other forms of entertainment (e.g. sporting events, concerts, shows) where the provider participates in the meal, event or other form of entertainment.
Permissible gifts and entertainment include those that6 :
Gift limits and Prohibitions
Permissible gifts, entertainment and hospitality
For details, please refer to the corporate Gifts, Entertainment and Hospitality policy that will be available on the MyCiklum portal
People who are involved in criminal activity such as bribery, fraud or trafficking narcotics may attempt to launder money through apparently legitimate businesses in order to use the funds from their criminal activity and reduce suspicion7.
Ciklum will not accept or process money gained through criminal activity; we will only deal with reputable clients who are involved in legitimate business activities and whose funds are derived from legitimate sources. If you become suspicious, you should raise your concern immediately to the Compliance Department and document all steps that are taken in relation to the transaction.
Sanctions are a foreign policy tool used by Governments to restrict the ability of designated countries, individuals or entities access to particular products, services and markets8.
Ciklum has a zero tolerance approach to engaging with entities or individuals that are subject to sanctions restrictions implemented by the UN, EU, USA or other Governments as well as to those implemented by any local government at any of Ciklum’s locations. If you have any doubts about dealing with an entity which may be subject to sanctions, you should raise the question with the Compliance Department.
Generally, antitrust and competition laws prohibit any activity that may improperly reduce or inhibit competition. Most countries where Ciklum does business also have laws restricting attempts to monopolise markets or otherwise restrict or control competition.
It is CIklum’s obligation to comply with these laws where they are applicable. Because of the complexity of antitrust and competition laws, it is imperative that Ciklumers seek advice from the Compliance Department on any question regarding these issues. The penalties for violating antitrust laws and trade regulations can be extremely severe for both Ciklum and the individuals involved.
Ciklum takes its obligations under applicable data protection and privacy laws very seriously in all countries where Ciklum does business10. We all have a responsibility to safeguard the privacy, confidentiality and security of personally identifiable information and other private information of Ciklumers, clients, partners and other third parties in Ciklum’s possession. We have in place effective systems to only allow access to our personal information to those who have a valid business reason for accessing it, reducing the risk of our personal data being compromised. While creating documents in cloud environment we need to provide access only to those people, who are authorised to see it.
You should never provide the information without the individual’s permission. If in doubt you should refer your enquiry to Compliance Department.
We must help to ensure that Ciklum’s books and records, which include virtually all forms of business documentation, electronic or otherwise, accurately and fairly reflect, in reasonable detail, all transactions and dispositions of assets. It is of critical importance that Ciklum’s financial reporting, including its reports to investors and lenders, be accurate and timely. Depending on type of services they provide, Ciklumers may be called upon to give information necessary to assure that Ciklum’s financial reports are complete, fair and understandable.
Confidential information includes all non-public information that might be useful to competitors or that could be harmful to Ciklum if disclosed11.
Ciklum has a duty to its clients, suppliers and personnel to respect all information it holds about them and to protect and handle such information responsibility.
Ciklum’s legal obligations and its competitive position require that confidential information remain confidential and that we are diligent in our efforts to protect our intellectual assets. Information that is proprietary to our clients, suppliers and others should be treated as confidential and used for the purpose for which it was obtained and disclosed only as permitted between Ciklum and the other party. Confidential information should be properly and securely stored, transmitted and disposed of, and Ciklumers must be mindful of the risk of discussing confidential information in public places. This means that Ciklumers should not disclose or share information regarding internal Ciklum matters with anyone outside Ciklum, except as required in the performance of their employment duties.
It is never acceptable to discuss confidential information in a public place even if there are no classified documents in use. The security and confidentiality of the information could be compromised if someone overhears the conversation.
‘Conflict of interest’ arises where a person’s position or responsibilities within their business unit presents an opportunity for personal gain above the normal rewards of cooperation12. In other words, a conflict of interest exists when your personal interests interfere with the best interests of Ciklum. Ciklumers should attempt to avoid actual or apparent conflicts of interest.
Any personal interests (or the interests of a member of immediate family) in relation to Ciklum’s business must be disclosed to your manager and the Compliance Department immediately. Disclosure is mandatory, failing to disclose a conflict or a perceived conflict is a violation of the Code.
In situation that appears to present a conflict of interest we expect you to “refrain and report”.If it is not possible to avoid participating in the event or activity creating the conflict, promptly disclose the potential conflict to your supervisor and the Compliance Department, and avoid participating in decisions that might raise the appearance of a conflict until you receive appropriate guidance.
We are each responsible for protecting any equipment and property to which we have access to or have been entrusted to safeguard, whether that equipment belongs to Ciklum company, our clients or other third parties. We need to make sure that these assets are not compromised, lost, damaged, misused or wasted. We use these assets exclusively for Ciklum’s business purposes.
Ciklum recognises the role that social media plays in communications and society today. However, sometimes it gets difficult to make clear division between one’s private voice on social media and the role as a Ciklumer. We all need to be responsible in our engagement on social media and exercise judgement when communicating in public forums. While engaging on social media, you should:
In our relationships with each other, we strive to be open, honest, and respectful in sharing our ideas and thoughts, and in receiving input. We value the free flow of thoughts, ideas, questions and concerns. We encourage CIklumers to raise work related issues or concerns through our established processes as soon as issues or concerns arise.
Ciklum promotes a cooperative and productive work environment by supporting the cultural and ethnic diversity of its workforce. Our collective challenge is to enhance the company’s performance through valuing and understanding differences. Ciklum is committed to a policy of providing equal employment opportunity to all qualified individuals and applicants. This commitment is reflected in all aspects of our daily operations.
We do not discriminate on the basis of race, color, descent, sex, sexual orientation, gender reassignment, political views, confession or religious beliefs, nationality, ethnicity, marital or civil partnership status, family / career responsibilities, pregnancy and maternity / paternity status, age, disability or impairment, profession or occupation, veteran status, physical peculiarity or genetic information in any personnel practice, including recruitment, hiring, employment, compensation and benefits / remuneration, facilities and services, promotion, training and professional development, termination and references, discipline and grievance.
At Ciklum, we are committed to creating a safe, healthy and non-threatening work environment. We integrate sound safety and health practices within our operations and comply with applicable workplace safety and health regulations. We foster an environment where everyone feels safe and is treated with courtesy and professionalism. Any act of violence or threatening behavior or possession of weapons will not be tolerated.
Under all circumstances, all Ciklumers must take due care of their health and safety and ensure that they do not endanger others by any acts or omissions. Activities that are not conducive to a good work environment are not permitted; this includes the storage, consumption, distribution, or being under the influence of alcohol or any controlled substances other than substances as prescribed by a physician on company-owned or leased property, during working hours, while on company business, or while using company property.
Moderate alcohol use at company-sponsored events after working hours can be allowed with prior functional head or director sign off. A dedicated manager must be responsible for the event. Under no circumstance can alcohol be offered to individuals under the legal drinking age attending the event.
Ciklum strives to comply with all national, federal, state, and local laws and regulations. Respecting the responsibilities of government agencies and cooperating with them in good faith as they execute established guidelines and policies is essential.
Ciklumers shall not provide anything of value to any local, state, or national or federal elected or appointed official or government employee unless the Ciklumer’s supervisor has confirmed that the item of value complies with all laws or regulations that limit or prohibit such gifts or require the gifts to be reported.
Ciklumers are encouraged to participate in the electoral process through voting, contributing time or other appropriate means. You may not contribute funds, assets or services for, or on behalf of, Ciklum to any political candidates, political party, charity or similar organisations unless such contribution is expressly permitted by law and authorised by Ciklum.
We will make a positive social and economic contribution through our activities to the communities in which we work, and we will support, sponsor and contribute to the activities of other organisations, where they are aligned with our own business objectives, our values and will enhance the reputation of Ciklum13.
We contribute to charities and good causes through sponsorship and donations and by providing materials. We encourage our employees to give their time as volunteers to these causes. When making sponsorship commitments, charitable donations or promises of ‘in-kind’ support such as company materials or resources, prior approval is required and the activity must be recorded. All requests for sponsorship and charitable donations received must be approved by Compliance Director to ensure that they meet our sponsorship and charitable giving criteria.
Who are Ciklumers?
Ciklumers is used in this Code as the collective reference for employees (permanent or temporary, full or part time) of any Ciklum legal entity, or any of its affiliates or subsidiaries, as well as for others performing work for, or on behalf of, Ciklum.
What is bribery?
Broadly, bribery is defined as giving or receiving a financial or other advantage in connection with the “improper performance” of a position of trust, or a function that is expected to be performed impartially or in good faith.
Bribery does not have to involve cash or an actual payment exchanging hands and can take many forms such as a gift, lavish treatment during a business trip or tickets to an event. The types of bribery that take place in the commercial sector are numerous. Some simple examples are:
Ciklum’s definition of bribery also includes making “facilitation payments”. A “facilitation payment” is a payment or gift given (usually to a government official) to speed up a procedure or to encourage one to be performed. It does not include fees required to be made by law such as the payment of a filing fee for a legal document. The acceptance of a facilitation payment by a government official is an example of corrupt activity.
Ciklum defines “corrupt conduct” or “corruption” as the abuse of entrusted power for private gain.
What is money laundering and sanctions?
‘Money laundering’ is the process of hiding illegal sources of money. For example, under the UK Proceeds of Crime Act 2002 (POCA) money laundering offences are committed when a person:
This process is of critical importance, as it enables the criminal to enjoy these profits without jeopardising their source. Illegal arms sales, smuggling, and the activities of organised crime can generate huge amounts of proceeds. Embezzlement, insider trading, bribery and computer fraud schemes can also produce large profits and create the incentive to “legitimise” the ill-gotten gains through money laundering. When a criminal activity generates substantial profits, the individual or group involved must find a way to control the funds without attracting attention to the underlying activity or the persons involved. Criminals do this by disguising the sources, changing the form, or moving the funds to a place where they are less likely to attract attention.
Sanctions are a foreign policy tool used by Governments to restrict the ability of designated countries, individuals or entities access to particular products, services and markets. The jurisdictions, individuals and entities who are the target of sanctions are those who particular governments view as engaging activity which is either considered abhorrent (e.g. suppression of civil rights) or would threaten international peace and security (e.g. development of a nuclear weapon). These restrictive measures are most commonly enforced by the UN, EU and USA.
What is fair competition and anti-trust?
Generally, antitrust and competition laws prohibit any activity that may improperly reduce or inhibit competition. Most competition laws and trade regulations apply to the sale and marketing of services as well as products. It is expected that each of us compete vigorously and fairly in the conduct of business matters but always in compliance with the local and other countries’ laws.
What is personal information?
Personal information is any information that can be used, alone or in combination with other information, to identify a specific individual. It includes such information as a person’s name, address, email address, date of birth, driving licence number, financial account numbers, passport, Social Security/Tax ID number or other government identification number and other identifiers.
What is confidential and proprietary information?
Confidential information includes all non-public information that might be useful to competitors or that could be harmful to Ciklum if disclosed. Proprietary information, i.e. intellectual property, includes data such as trade secrets, patents, trademarks and copyrights, and business information, research and new product plans, objectives and strategies, records, databases, salary and benefits data, employee personal and medical information, client, employee and supplier lists and any unpublished financial or pricing information.
What is conflict of interest?
‘Conflict of interest’ arises where a person’s position or responsibilities within their business unit presents an opportunity for personal gain above the normal rewards of cooperation. A conflict of interest can arise in many situations, including:
1 Please refer to Definitions section
2 Supervisor is a Ciklumer you report to
3 Leadership Team and Invited Members is the group of Ciklum top managers that contains from C-level officers (CEO, Global CFO, COO, CTO, CDO, CHRO, CRO and VP C&C) and directors – Legal D., Compliance D., Finance D., Delivery D. and Commercial D.
4 Board of Directors of the Ciklum Group Holdings Limited Holding Company, BVI
5 For more information, please refer to Definitions and Examples sections
6 For more information, please refer to Examples section
7 For more information, please refer to Definitions and Examples sections
8 For more information, please refer to Definitions and Examples sections
9 For more information, please refer to Definitions and Examples sections
10 For more information, please refer to Definitions and Examples sections
11 For more information, please refer to Definitions and Examples sections
12 For more information, please refer to Definitions and Examples sections
13 For more information, please refer to Examples section