Code of Conduct

It is Corporatek's policy to conduct its worldwide operations in accordance with the highest business ethical considerations, to comply with the laws of the countries in which Corporatek operates and to conform to locally accepted standards of good corporate citizenship.

This policy applies to all divisions of Corporatek and to all employees regardless of function, grade or standing. References in this policy to "Corporatek" or "the Company" are meant to include references to all Divisions of the Corporatek Group.

  1. The Company's activities and operations will be carried out in strict compliance with all applicable laws and the highest professional ethics standards.
  2. Corporatek will not discriminate against any employee for any reason such as race, religion, political convictions or gender, and will treat everyone with dignity and with full respect for their private lives. This is expected also to apply to relations between members of personnel.
  3. In its relations with governmental agencies, customers and suppliers, the Company will not, directly or indirectly, engage in bribery, kick-backs, payoffs, or other corrupt business practices.
  4. The use, directly or indirectly, of Company funds for political contributions to any organization or to any candidate for public office is strictly prohibited, where such contributions are forbidden by applicable law. Where such contributions are lawful, they must be made in a fair and prudent way and must be approved by the most senior Corporatek officer in the country of operation.
  5. Corporate funds and assets must be utilized solely for lawful and proper corporate purposes. Transfer or expenditure of such funds or assets will be undertaken only if the stated purpose is in fact the actual purpose. The transfer or expenditure of such funds and assets must be authorized in writing in accordance with procedures established by Corporatek headquarters or the relevant Corporatek Division.
  6. Employees may offer tips, gratuity or hospitality of a customary amount or value for routine services or courtesies received, to which the recipient is entitled.
  7. A tip, gratuity or hospitality may be offered to a government employee only if such act is customary and is not illegal under applicable law. All such expenditures must be reported and recorded in the Company's book of accounts.
  8. In connection with their business activities, employees may receive gifts of token value or accept invitations only if such gifts or invitations have no influence on their decision making and are not illegal under any applicable law. No employee may receive from any customer, supplier or business associate of Corporatek cash, gifts or invitations with other than nominal monetary value.
  9. Employees, irrespective of their function, grade or standing, must avoid conflict of interest situations between their direct or indirect (including members of immediate family) personal interests and the interest of the Company. Typical conflict situations include providing services to or owning stock (or stock options) in business entities which are competitors, customers or suppliers of Corporatek (minor shareholdings of less than 1% in listed companies are generally not considered to be conflict of interest situations).
  10. Employees must notify their direct supervisor of any actual or potential conflict of interest situation and obtain a written ruling as to their individual case. This applies in particular to employees involved in projects with companies developing partnership or similar arrangements with Corporatek (such as "incubator" programs), who are offered stock or stock options of these companies. The direct supervisor will advise the Company's General Counsel, who in turn will consult with the President and the Director of Human Resources to provide a considered and confidential response.
  11. All Corporatek personnel shall provide client and prospective clients with true and accurate information about Corporatek's products and services. When warranted, Corporatek personnel may divulge information related to future products and services to strategically positioned clients with the proviso that said information is provided under non-disclosure agreements and without making any promises as to the dates of commercial availability of future products and services.
  12. All Corporatek personnel involved in engineering and consulting projects shall use their professional engineering seals to certify key documents.
  13. All benefits provided to Corporatek employees in addition to their standard remuneration (salary and bonus) must be awarded in full compliance with corporate guidelines and national legislation (including tax regulations) and remain in line with local practice.
  14. Corporatek will support and respect the protection of international human rights within its sphere of influence, in particular the effective elimination of all sorts of compulsory labor and child labor, and it will make this a criterion in the choice and management of its suppliers and sub-contractors.
  15. Corporatek will support a precautionary approach to environmental challenges, and, within its sphere of influence, undertake initiatives to promote greater environmental responsibility and encourage the development and diffusion of environmentally friendly technologies.
  16. Corporatek will respect the privacy of data relating to individual persons (whether employees or third parties) which it may hold or handle as part of its information processing activities.
  17. Corporatek recognizes Intellectual Property Rights as a central shareholder value in any high technology company. Corporatek takes every appropriate action to preserve and enhance its Intellectual Property and respects the Intellectual Property rights of others.
  18. All officers, executives and managers of Corporatek and its subsidiaries are responsible for the continuing enforcement of and compliance with this policy, including necessary distribution to ensure employee knowledge and compliance. Non-compliance with this policy will result in disciplinary measures.
  19. Any employees encountering difficulties in the application of this policy must consult immediately with their management.