Code of Business Conduct

INTRODUCTION

Our values

OGEL IT stand by the following values: Passion for quality, Work smart, Respect for people and for the planet.  Our values show what we stand for as a business and employer.

Passion for Quality

When OGEL IT opened its doors for business, we have placed the utmost importance on quality.  We pride ourselves on delivering the best customer service to our customers and extend that passion across all our services.  This dedication shapes everything we do, from growing our customer base and expanding our services through innovation.  It is why we invest in our people, technology and the continuous improvements of our organisation and operations.

Work Smart

OGEL IT pride ourselves in making the work place a simpler and easier to navigate environment by adopting smart technologies in our broad service catalogue, and managing these services with a friendly, helpful and knowledgeable team of subject experts.  Through our discovery process, we analyse our customers business function and choose only the most beneficial solutions at the best price.

Respect for People and for the Planet

We are committed to our communities and strive to consistently improve the impact we make on the planet.  This means that we respect human rights and treat the people and places around us with the greatest degree of care.  We adhere to the laws and regulations of each of our local markets.  We also draw strength from the differences between people and cultures.  The responsibility we feel for our surroundings has shaped our social and environmental practices.

What is this Code?

The Code communicates the basic principles that each of us must observe when acting for or on behalf or OGEL IT.  It explains what we are committed to and what is expected of you as an employee.  The underlying policies give further practical guidance on the various topics in the Code.

The Code and policies apply to all individuals employed by OGEL IT, regardless of the type of contract or the location of their work.  The Code and policies also apply to individuals working for OGEL IT through a third-party contract.

The Code and policies do not cover every situation that may occur, nor do they remove the need for using common sense and professional judgement.

We expect you to act as OGEL IT ambassador at all times and to be mindful of your and OGEL IT’s reputation.

OUR CODE

We respect people and the planet

Health & Safety –

We put health and safety first

People are at the heart of OGEL IT.  This means that we always put health and safety first.  We all have a duty to work safely.  Whether we are at our workplace, visiting sites, meeting with customers or travelling, we must always follow safety rules and procedures.

Make sure you know what to do if an emergency occurs at your workplace, or at any place that you visiting.  Always exercise common sense, follow the correct procedures and any incident, unsafe situation or near miss.

Human Rights –

We respect the dignity and human rights of all people

We do business with respect for peoples fundamental dignity and their human rights.  This is anchored in our values, in our policies and in the commitments we have made to international standards.

We expect you to ensure that you comply with OGEL IT’s commitments to human rights.  We encourage you, as well as our customers, suppliers and other business partners and other people affected by our activities, to speak up if you observe suspect potential human rights breaches.

You can find more guidance on the OGEL IT’s Modern Slavery & Human Trafficking Statement and our Speak Up! channel and relevant policies on the OGEL IT website.  Otherwise please contact HR on HR@ogelit.com to request further information.

Discrimination and Harassment –

We say no to discrimination and harassment

We treat people equally and fairly, based on the principle of non-discrimination.  We respect cultural and individual diversity and promote inclusiveness.  We employ, reward and promote people based on the principles of equal opportunity, without distinction according but not limited to race, colour, gender, sexual orientation, religion, national or social origin, age and disability.

A key aspect of safeguarding the personal dignity and equality of each employee is to ensure that harassment, in whatever form, does not occur. Treat your colleagues with respect and fairness, and avoid situations that may be perceived as inappropriate.  We do not tolerate physical verbal, sexual or psychological harassment, bullying, abuse or threats.  Whenever you observe or suspect discrimination or harassment in the workplace, we urge you to speak up.

You can find more guidance on the OGEL IT’s Human Rights Policy and our Speak Up! channel and relevant policies on the OGEL IT website.  Otherwise please contact HR on HR@ogelit.com to request further information.

Environment –

We strive to consistently reduce the impact we make on the planet

We believe it is our responsibility to actively reduce our impact of the environment.  As part of our Sustainable Development Goals, it is our ambition to grow our business while respecting people and the planet.  Within our entire value chain and wherever we operate, we pay specific attention to reduce our CO2 emissions and consumption of water, energy and raw materials, and to increase the use of renewable energies.  We also focus on reducing waste through recycling and reusing.

We expect you to contribute to these ambitions and we encourage you to continuously introduce, develop and improve sustainable initiatives in your daily work.  Challenge or report situations or decisions that go against OGEL IT’s Sustainable Development Goals and worsen our impact on the environment.

We conduct business with integrity and fairness

Competition –

We are committed to the principle of vigorous but fair competition

We strive to win, but we always compete in compliance with competition laws.  Our business relations with customers and suppliers, as well as occasional contracts with competitors, require careful attention to competition rules wherever we do business.  For example, situations in which we are in direct contact with a competitor, and when we indirectly exchange information with competitors through IT service associations, platforms or public media statements.    This also applies when we wish to enter into exclusive agreements with supplier and customers.  In addition, we need to make sure that we only recommend, and never impose, minimum resale prices on our customers.

In the above-mentioned situation, or in case you have any questions about competition law, please reach out to HR to discuss.  Speak up if you observe or suspect any violation of competition laws.

Bribery –

We do not allow any form of bribery, in any place, at any time

We seek to win with integrity and fairness.  It is our principle never to accept, ask for, engage in, make, offer, promise or authorise any bribes to anyone, in any place, at any time.  With bribery we mean giving or receiving anything of value to or from any person, either government officials or commercial parties, to obtain or retain business, influence decisions, or secure an improper advantage in the conduct of our business.   This also includes bribery through others, such as third parties and making facilitation payments.  Be on your guard and always follow applicable laws and appropriate policies when providing anything of value, such as gifts, entertainment, hospitality and charitable donations.  If you observe or suspect that bribery is taking place, speak up.

You can find more guidance on the OGEL IT’s Bribery Policy and our Speak Up channel and relevant policies on the OGEL IT website.  Otherwise please contact HR on HR@ogelit.com to request further information.

Gifts, Entertainment, Hospitality and Donations –

we offer and accept gifts, entertainment, hospitality and charitable donations in an appropriate and transparent manner, only occasionally and never to unduly influence business decisions. 

We work with our customers, suppliers and other business partners to grow together.  This also involves creating goodwill, fostering long-lasting business relationships and showing appreciation.  Hosting and participating in events that contribute to the enjoyment of life are central to our business.  However, gifts entertainment and hospitality should never influence, or appear to influence, the integrity of business decisions or the loyalty of the persons involved.

If you give or receive gifts, business meals, entertainment or hospitality, make sure that they are appropriate and proportionate.  Give and accept them openly and unconditionally.  Always safeguard our reputation, exercise professionalism judgement, and avoid undue pressure on the recipient.

Wherever we do business we are sensitive to social and cultural traditions, but do not make contributions to politicians or political parties.  We may provide charitable donations, but we always do so in a transparent and professional manner.

Money laundering and sanctions –

We do not facilitate money laundering or engage in business with sanctioned parties.

WE do not want our business to be used by other for the purpose of money laundering, terrorist financing or any other criminal activities.  Also we do not do business with persons, entities, governments or countries if doing so violates applicable (economic) sanctions.  In order to prevent any violation of anti-money laundering laws or sanctions, it is key for us to know our customers, suppliers and other business partners.

Make sure to comply with local laws and any reporting requirements.  Speak up if you have concerns about money laundering activities or activities that could potentially breach sanctions.

Ogel IT carrying out due diligence and regular assessments of our key suppliers to identify and manage financial crime risk including tax evasion, sanctions, money laundering, bribery, and corruption.  We comply with our legal & regulatory obligations in relation to the prevention of tax evasion, sanctions, money laundering, fraud, bribery, and corruption.

You can find more guidance on the OGEL IT’s Supply Chain Charter and our Speak Up! channel and relevant policies on the OGEL IT website.  Otherwise please contact HR on HR@ogelit.com to request further information.

Conflict of Interest –

We avoid conflict of interest between business and personal interests.

WE each have a responsibility to make decisions in the best interest of OGEL IT, without being influenced by personal circumstances.  It is important to avoid situations in which a conflict could arise between OGEL IT’s and your personal interests.  Even the appearance of such a conflict should be avoided.

If a conflict of interest could exist or appears to exist, be transparent and discuss this with your colleagues, manager or HR.

Business Partners –

We seek to do business with partners who share our values and commitments to responsible business conduct.

WE believe it is important to work with customers, suppliers and other business partners who share our values and commitments to responsible business conduct.  Our continued global success depends upon this commitment.  After all, business partners can have a direct impact on our reputation through their behaviour.  We expect our customers and other business partners to act with integrity and fairness, observe applicable laws, and behave in a manner consistent with this Code.  In addition, suppliers are expected to comply with the Supplier Code.

We encourage you to speak up if you have any suspicion or doubt about misconduct by our business partners.  We also encourage our customers, suppliers and other business partners to speak up if they have any concerns regarding a possible violation of the law or this Code.

You can find more guidance on the OGEL IT’s Bribery Policy, Supplier Code, Supply Chain Charter and our Speak Up! channel and relevant policies on the OGEL IT website.  Otherwise please contact HR on HR@ogelit.com to request further information.

We safeguard our company’s assets

Use of company resources –

We safeguard our company resources.

Wherever we work and whatever our role, numerous company resources and assets are entrusted to us.  Think for example of laptops, IT systems, mobile phones, tools and inventory.  We all are required to use them carefully and professionally for their intended business purposed only, unless others use is specifically permitted.

You can find more guidance on the OGEL IT’s Acceptable Usage Policy (Standard & Privileged) and our Speak Up! channel and relevant policies on the OGEL IT website.  Otherwise please contact HR on HR@ogelit.com to request further information.

Fraud –

We do not accept any kind of fraudulent behaviour.

Fraud can have a significant financial and reputational impact of OGEL IT.  In order to protect the interest of all stakeholders, it is essential that we are alert of and prevent fraudulent behaviour.  Fraud covers a very broad range of activities.  Example of fraud includes falsifying documents, misappropriation of company assets and resources including theft – and in some cases, intentional misplacement of internal rules.

Falsification of sales records or of financial and non-financial statements also constitutes fraud.  Inaccurate information can mislead or deceive both internal and external stakeholders, which can have severe and long lasting consequences for OGEL IT.  We therefore all have a duty to ensure that our books, financial records and public reporting truly and accurately reflect our transactions and business.

We expect you to be alert on fraud and report any suspicion of fraud to your manager or HR or file a report through the Speak Up! channel available on the OGEL IT website.

Privacy and Data Protection –

We protect the privacy and personal data of our employees, customers, consumers, suppliers and other business partners. 

We respect and protect the privacy or all individuals.  We are committed to comply with all relevant data privacy requirements within the country we operate.  It is therefore important that we all ensure that we handle personal data, or any data that can relate to an individual, with care and for legitimate business purposes only, in line with applicable laws and our own privacy rules.

Intellectual Property and Confidential Information –

We respect and protect intellectual property and confidential information.

Our brand is among our most important assets.  In order to keep our competitive advantage and uphold our reputation, we must protect our intellectual property.  This includes our brand, services and innovations.  If you are involved in the development, marketing or sale of services and products supplied through OGEL IT, be aware of and protect our intellectual property rights, and respect the intellectual property rights of third parties.  Talk to HR if you have any questions regarding copyrights, trademarks, (industrial design, patents and domain names.

During our daily work we also come across all kinds of confidential information.  Examples are budget, and audit reports, service design, business plans, strategies, innovations agreements and financial statements.  It is essential that we respect and protect OGEL IT’s confidential information and only share and use it to the extent allowed.  This also applies to the confidential information of others.

Insider Dealing –

We do not engage in insider dealing or other forms of market abuse.

In our day to day business we may come across insider information.  This is non-public information of a precise nature that a reasonable investor would likely use for his or her investment decisions, for example: news about possible acquisitions or financial results.  You are not allowed to use such insider information to buy or sell OGEL IT securities, such as shares or other financial instruments.  Sharing this information with others may also be illegal.

Everyone involved with OGEL IT is responsible to keeping inside information confidential.  Only share inside information with OGEL IT on a need-to-know basis and with OGEL IT advisors who have signed a confidentiality agreement.

Responsible Communications –

We always communicate in a responsible way.

In order to protect OGEL IT’s reputation, we need to ensure that we always communicate in the right way, in the right place, at the right time and to the right audience.  When communicating externally or if you wish to engage in a speaking engagement on behalf of OGEL IT, you are expected to follow our internal policies and act as an OGEL IT ambassador.

Remember that any online communication, including social media, referring to the OGEL IT brand could affect the reputation of OGEL IT.  When you use social media, inside or outside work, do this in a responsible manner, always using common sense and professional judgement.

YOUR RESPONSIBILITIES

What are your Responsibilities?

We expect you to always act in accordance with the law, OGEL IT Code and the underlying policies.  Wherever laws, regulations or self regulatory agreements are more restrictive, they prevail.  We expect everyone to promote a culture of openness, in which we all feel comfortable raising questions, dilemmas and concerns regarding the interpretation of, or adherence to, this Code.  Those in management positions have greater responsibilities: you have an essential role to play in sustaining our reputation and ability to operate.  You are expected to lead by example and create a transparent and open environment, in which concerns or suspicions can be raised without fear or retaliation.

What do to when in doubt?

The Code and policies do not cover every situation that may occur, nor do they remove the need for using common sense and professional judgement.  If you are in doubt about what to do, ask yourself the following questions:

• Does it feel like it is the right thing to do?
• Is it legal and does it seem consistent with our values and our Code?
• Does it reflect well on OGEL IT
• Would I still accept full responsibility for this decision if I read about this in the media?

If the answer is ‘no’ to any of these questions or if you are uncertain, stop and seek guidance.  Discuss the matter with your manager or HR.  Or file a report through the Speak Up! channel.

Speak Up!

Do you have a concern about a possible violation of our Code or the underlying policies?  Speak up! Remaining silent can only worsen the situation and undermine trust.  When you honestly and truthfully raise a concern, you help to protect OGEL IT, your workplace, and ultimately your colleagues and yourself.  So speak up.  Raise any concern you have through your manager, HR or use our Speak Up channel.  You can report your concerns online, or by phone and email.  All reporting is done confidentially and you can share your concerns anonymously (is allowed by the laws set our in your country) or not.  Whatever feels comfortable to you.

You can find more guidance on the OGEL IT’s Speak Up Policy and our Speak Up channel and relevant policies on the OGEL IT website.  Otherwise please contact HR on HR@ogelit.com to request further information.

Non-retaliation

No one will suffer if we decline business to adhere to our Code or the underlying policies. Also, please feel confident that no one will be penalised for raising concerns in good faith about suspected misconduct via one of the Speak Up channels. Any form of retaliation against you for speaking up will not be tolerated. Retaliation against reporters is treated as a violation of this Code and consequently may lead to disciplinary measures.

Disciplinary Measures

A violation of the law, our Code, or any of the underlying policies can have serious consequences for OGEL IT and the individuals involved, including you. The same goes for turning a blind eye to any such violation. As an individual you can be held liable and fined or sent to prison. In addition, OGEL IT can be held liable and fined, and its reputation can be severely damaged. A violation of the law, our Code or the underlying policies can also lead to disciplinary measures, which may include dismissal. Using a third party or other means to bypass this Code is never allowed.

Questions?

More information and the policies are available through OGEL IT’s document library and through HR.  For any questions please:

• Contact your manager or HR
• Send an email to HR@ogelit.com