Company Policy

Company Code of Conduct

The goal of Accesa is to sustainably strengthen the success of our owners and customers through competitive IT solutions and services. Our Code of Conduct defines ethical behaviours that we all need to demonstrate. They are mandatory. 

The purpose of the Code of Conduct is to set the relevant principles and fundamental values of the Company and to set expected behaviour from employees and partners, behaviour that the company considers fundamental to their successful operation. All internal company guidelines and regulations must be consistent with this code.​​​​​​​ ​​​​​​​ 

This Code of Conduct does not work simply because it is available; it must be lived on a daily basis.

1 Compliance with laws

All employees comply with the relevant laws and official regulations as well as the company's internal regulations, especially the internal authority and signature regulations. 

2 Data protection and data safety

As an IT service provider, data protection and data security are fundamental. Employees have a special responsibility in handling the personal and business data of the company and of our clients. It is prohibited to use insider information for themselves or their related persons’ interests.

3 Corruption

All employees are prohibited from accepting or offering improper benefits in their interest, their relatives or close friends' interest.

4 Conflict of interest

All employees should be aware that transactions with related persons and companies are carried out on customary market terms. Any potential conflict of interest must be handled fairly, openly, and transparently with the participation of the compliance function and direct manager.

5 Competition

No employee passes on business secrets or other internal information to competitors or to other third parties in an unauthorized and unjustified manner.

6 Human and environment

Nobody may be discriminated against due to their gender, origin, nationality, worldview, sexual orientation, age, religion, civil status or appearance. The Company ensures a safe and healthy work environment and has established a company health management system for employees.

7 Financial reporting

To ensure transparency and correctness of business operations, business processes must be fully and truthfully documented in accordance with the regulatory framework. 

Supplier Code of Conduct

Based on the Group core values addressing business ethics and social and environmental commitments, Accesa IT Systems S.R.L., Accesa IT Consulting S.R.L. and Accesa IT Group GmbH companies, from now on, are called “Partner” requires the Supplier to adhere to the hereafter listed Principles (as defined below) which will be attached to the contract entered between them (the “Contract”).

The Supplier shall do its utmost to implement these Principles throughout its whole supply chain. This Supplier Code of Conduct is not intended to replace the laws and regulations in force. It seeks to encourage and respect these laws and regulations and ensure that they are faithfully and effectively enforced.

PRINCIPLES

1. Compliance with National and European Law

In addition to complying with the following provisions as detailed in sections 1 to 6 below, the Supplier shall always comply with applicable laws, regulatory requirements and the contractual obligations as agreed between the Parties. This shall include the US Foreign Corrupt Practices Act and the UK Bribery Act, where applicable.

Furthermore, the Supplier shall adhere to any international trade sanctions (including embargoes), which shall include any sanctions that may be in force because of a resolution passed according to Chapter VII of the UN Charter by the UN Security Council and any sanction that the European Union may have imposed. The Supplier shall bind its contractors and/or subcontractors (from now on referred to as “Subcontractors”) to the Principles of this Supplier Code of Conduct as they are involved in provisioning deliverables under the Contract. The Parties agree that adhering to this Supplier Code of Conduct is a primary contractual obligation under the Contract.

2. Social Responsibility Practices

2.1. Freedom of Association and Right to Collective Bargaining

The Supplier shall seek to implement internationally recognized standards, e.g. International Labor Organization (ILO) Conventions, without violating national legislation. It shall ensure that its employees and representatives, including temporary (agency) workers, may openly express themselves in their company concerning matters related to their working conditions.

2.2 Child Labour Child labour is strictly prohibited

"Child labour" means the definition of Article 32 of the United Nations Convention on the Rights of the Child (UNCRC). If any child is found working at the Supplier's premises, the Supplier shall immediately take steps to redress the situation in the child's best interests.

2.3 Diversity and Non-Discrimination 

The Supplier shall prohibit and fight harmful discrimination based on race, colour, sex, sexual orientation, language, religion, political or another opinion, national or social origin, property, birth or another status, and shall promote diversity, equality of opportunity or treatment in employment and occupation.

The Supplier shall treat all employees with respect and shall not use physical punishment, mental or physical coercion, any form of abuse or harassment or threat of such treatment.

2.4 Remuneration

The Supplier shall provide remuneration according to national legal standards on minimum wage. Where no national legal standards exist, the remuneration shall be sufficient to meet basic needs (ILO C131 – Minimum Wage Fixing Convention). The basis on which workers are paid shall be conveyed to them on time.

2.5 Working Hours

The Supplier shall respect the individual worker’s need for recovery and secure that all workers have the right to adequate leave from work with pay. Where no national legal standards exist, ILO standards shall apply. Working hours, including overtime, shall comply with applicable local laws.

2.6 Health and Safety

The Supplier shall provide its workers with a safe and healthy workplace and should implement effective programs to – where necessary - improve the working environment.  

The Supplier shall do its utmost to control hazards and take necessary precautionary measures against accidents and occupational diseases.

The Supplier shall provide adequate and regular training to ensure that workers are educated on health and safety issues. This shall include provisions and instructions to use appropriate personal protective equipment.

The Supplier shall secure that, where it provides accommodation, it shall be clean, safe, meet the workers' basic needs and, where appropriate, for their families.

The Supplier is encouraged to implement a Health & Safety Management System based on international standards such as OHSAS 18001 or similar.

3. Environmental Responsibility Practices

3.1 Environmental Protection

The Supplier shall take a precautionary approach towards environmental challenges (e.g. climate change, biodiversity, etc.), undertake initiatives to promote greater environmental responsibility and encourage the development and usage of environmentally friendly technologies.

The Supplier shall act following relevant local and internationally recognised environmental standards and applicable local laws, whereby the highest standard shall be applied.

The Supplier shall minimise its environmental impact and should implement measures contributing to pollution prevention and protecting the environment. The Supplier shall minimise or strive to avoid hazardous air emissions, energy consumption and CO2 emissions. In particular, the Supplier shall develop products and services that feature low energy consumption and CO2 emission reduction during the life cycle.

The Supplier shall obtain and adhere to all necessary permits and strive to implement an Environmental Management System based on international standards such as ISO 14001.

3.2 Natural Resources and Waste Management

The Supplier shall limit the use of materials and resources, including water when sourcing or producing goods to minimise environmental impact.

The Supplier is encouraged to track the source of conflict minerals, promote transparency along its supply chain and put measures in place for this purpose. The use of rare resources shall be limited or avoided where possible.

The waste produced by all its activities shall be identified, monitored and managed. The Supplier shall strive to reduce waste. Waste treatment shall follow applicable environmental laws.

4. Prohibited Business Practices

4.1 Anti-Corruption

The Supplier shall refrain from any form of corruption or actions that could potentially be construed as such. The Supplier may not offer, promise or grant illegal benefits to national or international public officials or decision-makers operating in the private sector to achieve preferential treatment or a favourable decision; the same applies when dealing with donations, gifts or invitations to business meals and events.

The Supplier may not allow itself to be promised or offered advantages and shall not accept the same if this may or shall create the appearance to the party bestowing the benefits that it can thus be influenced in business decisions.

Likewise, the Supplier may not request advantages. The Supplier shall avoid conflicts of interest that may lead to corruption risks. If the Supplier is also a customer, it shall not draw any unfair advantages from this and shall keep procurement and sales separate.

The Supplier undertakes and requires its directors, officers, employees, suppliers, affiliates, Subcontractors and each respective representative (from now on, the “Third Parties”) to respect the rules of this Section together with the regulations by appropriate means for the effective implementation and to maintain of a compliance framework, that:

(i) the Third Parties involved in the performance of the Contract comply with these Rules and that

(ii) every necessary means used by Third Parties to perform the Contract comply with the Rules. To ensure compliance with the Rules for the duration of the Contract, the Supplier shall provide on demand. At all times, all elements requested to establish such compliance and shall inform the Partner without any delay, when it knows or has reason to know, of any failure to comply with the Rules by itself or any Third Party, as well as the corrective

measures adopted to ensure compliance with the Rules. A material non-compliance with the Rules may trigger a termination right of the Contract following its provisions.

4.2 Competition

The Supplier shall respect the rules of free and fair competition in all business relations and not act against any competition and/or antitrust law.

4.3 Sponsorship

All sponsoring measures by the Supplier must follow current legislation.

4.4 Political Contributions

The Supplier shall not donate money or grant any monetary benefits to any political party unless permitted by law.

4.5 Money Laundering

The Supplier shall take all measures to prevent money laundering within its sphere of influence.

4.6 Data Security and Data Protection

The Supplier shall adhere to all applicable data protection laws and all specific data protection and security requirements agreed to in the Contract.

5. Monitoring and Audits

To ensure compliance with the Principles as outlined in this Supplier Code of Conduct for the duration of the Contract, the Supplier shall provide on demand all elements requested to establish such compliance and shall inform the Partner without any delay when it knows or has reason to know, of any failure to comply with the Principles by itself or by any Subcontractor, as well as the corrective measures adopted to ensure compliance with the Principles.

Accesa, therefore, expects all employees and its partners to behave in accordance with these requirements.

The employees, customers or suppliers of the Company are encouraged to make disclosures of offences, cases of suspected illegal behaviour, or serious irregularities-omissions in connection with the Code of Conduct through a dedicated reporting platform.