Code of Business Ethics

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Complementing our business values, this Code of Business Ethics has been formalized outlining our commitment towards our People and third parties who work for and with us, but also to summarize important and basic rules when conducting business on Coberg’s behalf.

Our code of business ethics applies to all employees at Coberg and associated companies, everyone at every position, including our employees, shareholders, management, and partners.

RESPECT FOR OTHERS

It’s mandatory to respect everyone you interact with. Be kind, polite and understanding. You must respect others’ personal space, opinions and privacy. Any kind of violence is strictly prohibited and will result in immediate termination. You’re also not allowed to harass or victimize others.

If someone, be it customer, colleague or stakeholder, is offensive, demeaning or threatening toward you or someone you know, report them immediately to HR or your manager. You can also report rudeness and dismissiveness if they become excessive or frequent.

ANTI-BRIBERY & CORRUPTION

A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or business or personal advantage. Kickbacks are payment of any portion of a contract made to employees of another contracting party or the utilisation of other techniques, such as subcontracts, purchase orders or consulting agreements, to channel payment to public officials, political parties, party officials or political candidates, to employees of another contracting party, or their relatives or business associates.

Gifts and entertainment might be recieved and offered to strengthen business relationships, only if they are of a moderate and not excessive value. When dealing with government and public sector entities we must keep in mind that special rules may apply.

CONFIDENTIALITY

Any information concerning Coberg, its clients, suppliers, projects, products, services or its business that is not generally publicly available must be treated confidential and only used for the purpose it has been provided to us. Unauthorized disclosure of confidential information can significantly damage Coberg’s reputation and can be in violation of applicable data protection or secrecy law and our contractual obligations. Maintaining the confidentiality of the business is still in effect even after people no longer work with Coberg or it’s customers.

CONFLICT OF INTEREST

Conflict of interest may occur whenever your interest in a particular subject leads you to actions, activities or relationships that undermine our company. This includes situations like using your position’s authority for your own personal gain or exploiting company resources to support a personal money-making business. Even when you seemingly act to the company’s advantage, you may actually disadvantage it. For example, if an employee uses dubious methods to get competitor intel and raise their sales record, their action will have a positive impact on the company’s revenue, but it will put us at a legal risk and promote unhealthy business practices.
If it turns out you have created a conflict of interest for yourself, you will be terminated. If the conflict of interest was involuntary (e.g. buying stocks from a company without knowing they’re a competitor), we will take actions to rectify the situation. If you repeat the offence, you may be terminated.

LAWFULNESS

You are obliged to follow all laws which apply to our organization. Depending on your role and profession, there might be various laws you need to observe. For example, accountants have their own legal restrictions and they must be fully aware of them. When you’re preparing contracts, clauses, disclaimers or online copy that may be governed by law (such as consent forms), please ask verification from our legal advisory before finalizing anything. You must not expose, disclose or endanger information of customers, employees, stakeholders or our business. Always follow our cybersecurity policy, too.

Following laws regarding fraud, bribery, corruption and any kind of assault is a given. You are also obliged to follow laws on child labor and avoid doing business with unlawful organizations. If you’re not sure what the law is in a specific instance, don’t hesitate to ask HR or our legal counsel.

TEAMWORK

Working well with others is a virtue, rather than an obligation. You will certainly get to work autonomously and be focused on your own projects and responsibilities. But, you should also be ready to collaborate with and help others.

Be generous with your expertise and knowledge. Be open to learning and evolving. If days go by without you consulting or brainstorming with anyone, you are missing out on opportunities for excellence. Instead, work with others and don’t hesitate to ask for help when you need it.

INTEGRITY & HONESTY

First, always keep in mind our organization’s mission. We all work together to achieve specific outcomes. Your behavior should contribute to our goals, whether financial or organizational.

Be honest and transparent when you act in ways that impact other people (e.g. taking strategic decisions or deciding on layoffs). We don’t tolerate malicious, deceitful or petty conduct. Lies and cheating are huge red flags and, if you’re discovered, you may face progressive discipline or immediate termination depending on the damage you did.

Stealing from the company or other people is illegal. If you’re caught, you will face repercussions depending on the severity of your actions. For example, if you steal office supplies, you may receive a reprimand or demotion (at a minimum), while if you steal money or data (e.g. engaging in fraud or embezzlement), you will get fired and face legal consequences. The decision is at HR’s discretion on a case-by-case basis.

COMPETENCE AND ACCOUNTABILITY

We all need to put a healthy amount of effort in our work. Not just because we’re all responsible for the organization’s success, but also because slacking off affects our colleagues. Incomplete or slow working might hinder other people’s work or cause them to shoulder the burden themselves. This comes in direct conflict with our respect and integrity principles.

We also expect you to take up opportunities for learning and development, either on-the-job or via educational material or training. If you are unsure how you can achieve this, have an open discussion with your manager.

Also, take responsibility for your actions. We all make mistakes or need to make tough decisions and it’s important we own up to them. Failing to be accountable on a regular basis or in important situations (e.g. a crucial mistake in our financial records) will result in termination. If you take responsibility and come up with ways to fix your mistakes where possible, you will be in a far better position.

COMPANY REPRESENTATION

Individuals who are appointed by management or board and granted such power by applicable law or by relevant powers of attorney. People are prohibited to represent Coberg in media or social media without prior approval from the management or the partners of the firm.

Any questions about the Code of Business Ethics and its application can be emailed to: compliance@coberg.net and it will be circulated internally as needed.