Code of Conduct

Version 1.0

INTRODUCTION

IT-Gravity-VO GmbH d.b.a. The Welkin Suite (hereinafter – «Company») is software development company, where numerous different people do their best and maximize their efforts in order to create excellent software for our clients. And we always will.

We clearly understand, that in order to succeed with our mission, we should be able to successfully communicate and co-exist as a team in our internal matters, as well as with our clients and contractors, ending up with communities and governments around the world. Being the management of Company, we are pleased to say, that this code of conduct was not made to change things in our company, but rather to write down what already exists.

People are more likely to make ethical choices when integrity, honesty and compliance guide our decisions-making, and we strongly believe, that this code of conduct will help you to succeed. We wanted this document to be simple, yet effective, just like our code, and looks like we did it.

I. SHORT SUMMARY

Not everyone likes reading huge documents, so long story short: here is summary of everything you need to know about this code.

What we stand for:

  • comfortable and safe workspace
  • friendly work environment
  • diversity and integrity
  • mutual respect
  • conflict solving
  • conflict solving
  • compliance with laws
  • honest partnership
  • honorable representatives
  • international cooperation
  • multiculturalism

What we are against:

  • disrespect and hostility
  • racism, sexism, harassment
  • ethnical/national discrimination
  • political/religious propaganda at work
  • conflict escalation and corporate wars
  • dangerous workspace
  • unfair competition
  • money laundering
  • financing of terrorism
  • bribery and corruption
  • illegal activities

If you would like to know more about anything of the above – feel free to study this document. If you face any problems with anything listed: there are contacts below to inform us about them.

II. TROUBLESHOOTING

Here in our Company, we believe, that every conflict and/or violation of this code can and should be resolved. But, in order to do so we should know about it. That is why we are trying to make reporting for you as easy as possible with the most possible ways. You do not need to know all the details, when you think that something is going wrong, do not hesitate to speak up. Tell us and we will take action.

Tell us via following:

Your confidentiality will be protected.

Important note: please remember, that we will review all messages we receive, even anonymous ones. We will not tolerate any retaliation and we will take action up to submission to law enforcement agency. Also keep in mind that wittingly fake reports and accusations will have serious consequences as well.

Managers of our company will:

  • discuss this code with their teams and set appropriate expectations;
  • be a good example;
  • explain that we accept only those results, which were achieved in the right way;
  • be someone, with who members of their teams can talk about these matters;
  • seriously review all incoming messages related to this code and take action.

III. DIVERSITY AND INTEGRITY

Best results are always delivered by strongest teams. No matter what are qualifications of its members, such results cannot be achieved without mutual respect and cooperation. It takes all of us working together, while cultivating an atmosphere of mutual respect, inclusion and collaboration.

Development teams often consist of different people, who may vary by their age, expertise, income, family, nationality, views and other factors. However, we value each member of the team and we take steps to create an inclusive culture that makes every employee feel welcome.

We knowingly did not stick to tightly defined ‘values’ or ‘guidelines’, because we think, that they can often come into contradiction with each other, regarding challenges and tasks we face, and thus devaluing them. Thus, we decided to stick with our ‘atmosphere’ and ‘ecosystem’, that we have created in our Company.

Even though separate teams may have their specific commons or style of communication, basic rules for them remain the same – we welcome every employee and respect each of them, no matter how different we may be.

IV. ZERO TOLERANCE

Company within its ecosystem demonstrates zero tolerance policy for the harassment and discrimination.

Harassment - behavior that demeans, humiliates or embarrasses a person, and it is characteristically identified by its unlikelihood in terms of social and moral reasonableness. In the legal sense, these are behaviors that appear to be disturbing, upsetting or threatening. Harassment can appear in forms of unwanted sexual or relationship proposals, remarks, jokes, gestures, slurs, which may appear in any kind of form, whether verbal, non-verbal or visual conducted whether inside of workplace or outside by any kind of employee regardless of their position, age, gender, etc.

Discrimination - act of making distinctions between human beings based on the groups, classes, or other categories to which they are perceived to belong, namely of race, age, caste, criminal record, height, weight, physical appearance, disability, family status, gender identity, gender expression, generation, genetic characteristics, maritalstatus, nationality, profession, race and ethnicity, religion, sex characteristics, sexual orientation, political ideology, social class, personality, as well as other categories.

Important note: behavior mentioned will not be tolerated. We wish to solve all the conflicts by negotiation and cooperation, however, once we cannot reach agreement on the situation, we may end collaboration with you. We understand, that each uprising case is unique and definitions are broad, so if you are unsure – ask your manager.

V. NO PROPAGANDA

Most of the people around the world have some kind of political or religious views and beliefs, which is duly enshrined in most constitutions in the form of freedom or right. However, following the most basics rules of business etiquette we do not think, that office is good place for politics or religion. Moreover, enforcing your views in the office may find lots of opposition with your colleagues, which will cause a lot of unnecessary stress. Company respects your rights, freedoms and views, but we kindly ask you to refrain from any form of propaganda at your workplace and we suggest you to discuss it in more appropriate places, if you have such needs.

VI. CONFLICT OF INTERESTS

Conflict of interest can arise when our personal relationships or financial interests overlap with our job responsibilities. If we don’t navigate potential conflicts of interest carefully, these situations can impact the decisions we make, erode trust within teams, and harm the Company’ reputation. Moreover, in some cases and jurisdictions it can be regarded as illegal activity and lead to criminal and/or administrative punishment. As a company we want you to tell us about any of your outside relationships, which may lead to conflict of interest.

As employees of Company we:

  • make decisions in favor of Company;
  • evaluate whether or not there is conflict of interest in decisions we make;
  • understand that conflict may exist even without our knowledge;
  • prior working with our companies we make sure, that there is no conflict of interest;
  • speak to our managers, when we doubt whether conflict exists;
  • ones conflict arises - collaborate to reduce negative impact on the company.

VII. HEALTH SAFETY

The situation the world is facing is a truly unprecedented one. The global coronavirus pandemic is affecting all of our families, our businesses and our communities. Our people’s health is our top priority and as the situation escalates, Company’s duty is to ensure our teams are safe. Therefore, we are taking every measure to protect them and meet all public authorities’ requirements.

We are monitoring in real time the COVID-19 situation and will take all appropriate actions – in line with the evolution of global and local authorities’ guidelines. We have already switched to remote work as much as possible, with estimate 95% of all our activities going without visiting of office. We are fully committed to protecting our people and clients. Ones our office will be open, we will also take all necessary safety measures for our workspaces.

Despite all the situation going around COVID-19 pandemic we inspire our employees to keep healthy lifestyle and nutrition, go in for all kinds of sports.

VIII. RELATIONSHIPS WITH CLIENTS AND SUPPLIERS

Each of our projects is important to us. Valuing our client’s trust we are ready to do our best to deliver the desired result. Company intends to provide flexible and client-oriented approach in order to deliver reliable, scalable and secure software, while keeping it on-time and on-budget. And in order to provide aforementioned quality of our services in our day-to-day work we are guided by the following:

  • Follow local privacy and data protection laws;
  • Clear and accurate privacy notices when collecting or processing personal data;
  • Protect customers’ data by building secure products and services;
  • Act within usual and common standards of industry;
  • Do not leave any kind of software backdoors, easter eggs or other malicious code;
  • Provide fair and accurate information and records about software development;
  • Keep all kinds of gifts and business hospitality within reasonable and adequate boundaries.

Like any other business we use lots of suppliers to maintain our activities, so we are cautious in terms of who we buy from and who we cooperate.

  • Do not pay kickbacks or bribes;
  • Engage with reliable suppliers;
  • Do not enter into deals with entities connected to illegal activities;
  • Open and fair cooperation;
  • Resolve conflicts by negotiation;
  • Avoid hidden terms or arrangements;
  • Hire people based on their merits and abilities

IX. ANTI-BRIBERY

Company is committed in doing business without corruption. Such approach means, that you are not required to pay or offer any kind of bribes of kickback in any form whether to government or municipal officials, clients, suppliers and our employees. You are also prohibited to solicit or accept bride or kickback.

This policy also applies to payments that our contractors make on our behalf. Do not deal with unethical representatives and report to your manager, when you will notice any signs of corruption. You will not be punished for refusing to pay or take a bribe or kickback, even if your refusal results in a loss of profits or other negative consequences of Company.

Also note, that corruption may appear not only in form of cash, as well as in for of, including, but not limited to, paying for unnecessary services, contributions to third parties, tax or other business benefits, job offers, unreasonable entertainment, goods and meals, free access to software and other intellectual property, insider information.

Also note, that corruption may appear not only in form of cash, as well as in for of, including, but not limited to, paying for unnecessary services, contributions to third parties, tax or other business benefits, job offers, unreasonable entertainment, goods and meals, free access to software and other intellectual property, insider information.

  • give or take bribes or kickbacks;
  • cooperate with suppliers, which may be subject to violation of anti-corruption laws;
  • share insider’s information, which could provide unfair advantage in stock trading or harm investors;
  • promote or encourage corruption on any levels.

X. ANTI-MONEY LAUNDERING

Anti-money laundering – is behavior of the company aimed towards avoidance of cooperation with counterparties, whose business runs for concealment of the origination and/or beneficial ownership of money, which were obtained through criminal activities by passing them through companies.

Company sets priority to work with reputable suppliers and we stay cautious with counterparties, who do not have transparent beneficial ownership structure and/or are not clear in their intentions. We are also following all necessary procedures for international Anti-money laundering regulations, when it is required, and we are open to our customers for "KYC" checks.

XI. ANTITRUST AND FAIR COMPETITION

Antitrust regulation are laws aimed towards free and fair competition between subjects of business within regional and/or goods markets. Such regulation helps to avoid unfair price practices, trust and cartel agreements, unfair business practices and any other actions, which may harm free competition and market pricing. Business practices and their fairness, which we apply in our daily job, are as important, as results, which we achieve. Healthy competition and fair business practices put our customers first by giving them access to a variety of services at fair prices. Competing fairly ensures that we meet our business objectives with our integrity intact.

Following these guidelines, Company avoids any formal or informal agreements with competitors that may limit competition, does not make agreements on bids, auctions and reductions, collect information about competitors only from appropriate resources, does not use any illegal competition practices.

XII. ANTITERRORISM AND SANCTIONS

International affairs affect our everyday lives as well as our business, because international sanctions are one of the main instruments of international pressure. As we mentioned earlier, we are cautious about who we work with, and sanctions check remains one of our instruments to keep in line with international legislation. Here we provide list of countries, with which we do not work or cooperation with which are subject to additional check by our legal team, for the possibility of safe operations with them. We also do not have any business relationship with persons and entities connected to terrorism or financing of terrorism.

‘Do not work with’ countries: Russian Crimea entities, Iran, North Korea, Cuba, Syria.

High risk countries: Afghanistan, Belarus, Burundi, CAR, Guinea, Congo, Egypt, Lebanon, Libya, Mali, Russian Federation, Somalia, Sudan, Venezuela, Yemen, Zimbabwe.

XIII. INTERNATIONALITY AND RESPECT OF HUMAN RIGHTS

Company operates around the globe with various range of counterparties. Such variety of partners requires us to act within regulations of different jurisdictions, while also acting under international regulations, local business commons and recommendations of international organizations.

We are honest and transparent in our discussions with government representatives and officials, so we respond truthfully, appropriately and promptly to government inquires and requests for information. We also comply with global trade controls, economic sanctions, which prohibit us from doing business with certain countries, governments, entities, and individuals. Ones we are not sure whether or how to act – we make double check for legal validation.

Company is committed to respecting and promoting human rights to ensure that our services plays a positive role to society. In our day-to-day activities we respect rights of each single individual, whether it is employee, client or supplier. We advocate for the rule of law, including consideration of international laws and norms, including those in form of recommendations. In case if we will face orders from our clients, which may violate or reduce human rights by violation of appropriate laws – we will discuss such orders for their modification or refrain from such work.

XIV. REPRESENTATION OF COMPANY

Our public statements and communications are honest and not misleading. What we say and we say it matters. When we are talking to public, we make full accurate and timely information about our services and products, so that our communications were not misleading. People in Company do not speak on behalf of the company unless they are authorized to do so. In case if third parties are willing to obtain any kind of information about company, it’s products or services, which you are not authorized to comment publicly – redirect all these questions to management. Aforementioned rules also apply to all of our web-sites and pages in social media.

When you speak or act out on public while being employee of Company, on public issues or in a public forum, you do that only as a single individual and you should not give appearance that you speak or act on behalf of Company, unless otherwise was previously approved or asked for by management of the company. This is particularly important with the rise of social networking media. You must always be aware that such services are increasingly being monitored by clients and colleagues.

Company encourages all employees to pursue personal interests, including active participation in their communities. However please note, that Company will not make contributions, payments or otherwise give any endorsement or support directly or indirectly to political parties or candidates, including their organizations made for political purposes. You must not make any contributions on behalf of Company.



Respect each other and follow these simple recommendations.