At Job Accomm we want a productive, happy and agile community that can welcome new ideas in a complex field, improve every process every year, and foster collaboration between groups with very different needs, interests and skills.
We gain strength from diversity, and actively seek participation from those who enhance it. This code of conduct exists to ensure that diverse groups collaborate to mutual advantage and enjoyment. We will challenge prejudice that could jeopardise the participation of any person in the JobAccomm Community.
The Code of Conduct governs how we behave in public or in private and whenever JobAccomm will be judged by it’s actions. We expect it to be honoured by everyone who represents JobAccomm officially or informally, claims affiliation with JobAccomm, or participates directly.
We follow the laws of the countries where we do business, and we adhere to JobAccomm’s policies and procedure.
We personally set the example for each other and our stakeholders by being honest and fair.
We disclose promptly any conflicts of interests that might influence our business judgment, and avoid any appearance of impropriety in our dealings with others.
We are partners in promoting a culture of integrity through mutual respect and trust in each other and high standards of ethics.
We hold each other accountable to this code, and if we become aware of potential violations, we promptly report them.
CONFLICT OF INTEREST
We act in the best interest of JobAccomm, and use JobAccomm property and resources exclusively for JobAccomm’s benefit. We disclose promptly any interests that might objectively be perceived as affecting our judgment or that may create an appearance of impropriety. We avoid any activity at work or at home that might hurt the good reputation of JobAccomm.
WHAT DO I NEED TO KNOW?
• A conflict of interest arises when JobAccomm’s interests and your personal interests collide. Such a conflict of interest is not necessarily a problem in itself, but could become a problem if it is not promptly disclosed and properly managed.
• JobAccomm defines a conflict of interest as both an actual as well as a perceived impropriety resulting from the conflict of interest.
• A conflict of interests that is not properly disclosed and managed will cause others to question your integrity and loyalty to JobAccomm.
• Remember that the interests of your family members, close personal friends and other such relationships could give rise to conflicts of interest.
• You must promptly declare to JobAccomm the circumstances that could be perceived as a conflict of interest. Upon the submission of a “conflict of interest declaration,” you and your manager along with the Ethics & Compliance Team will discuss potential resolutions.
WHAT DO I NEED TO WATCH OUT FOR?
• Financial or other interests and positions in companies in which you could influence JobAccomm’s current or future business with those companies, customers, consultants or suppliers.
• Decisions where the potentially affected parties have close personal or family relationships with you, or where you or your family might stand to personally benefit.
• Discounts, gifts, payments or other benefits from suppliers, customers or others who conduct or want to conduct business with JobAccomm.
• Recruiting, hiring, or directly supervising family members or personal friends, or promoting someone with whom you have such a relationship.
• Performing outside work during JobAccomm business hours or using JobAccomm resources, intellectual property or confidential information for non-JobAccomm related work.
• Being an officer or director of a charitable or civic organisation that may obtain (or seek to obtain) funding or support from JobAccomm.
PRIVACY
JobAccomm respects privacy. JobAccomm collects, uses, holds and otherwise processes personal and customer data responsibly, lawfully and carefully. We apply applicable privacy management measures and we monitor compliance with our commitments. We collect personal data in an open and transparent fashion and provide fair and reasonable choices on its collection and use. We build privacy and security into the design of our products and services and employ appropriate safeguards to protect personal data against unauthorised use or disclosure.
WHAT DO I NEED TO KNOW?
• Our commitment to respect privacy goes beyond legal compliance. We earn our customers’ trust in JobAccomm by managing personal data in a responsible manner.
• The cost of privacy violations are substantial, and you and JobAccomm can be exposed to both civil and criminal penalties in certain cases.
• Personal data includes any information that could identify an individual. This data may include direct, business and HR-related information such as contact details, personal profiles, voice, image and location of an individual; indirect information includes subscriber identities, device and application identifiers and other such information. When in doubt, treat the information as personal data.
• Our customers also impose rules on how we access, collect and handle personal data in our contracts. Hence, we must not collect, process or store personal data in way that is incompatible with our customer agreement and other privacy commitments
• You may access and use only the personal data that is necessary to fulfill your assigned job responsibilities. There must be a legitimate business purpose for any use or sharing of that data.
• Protect personal data physically and electronically. Place personal data only on JobAccomm authorised environments, and not on unencrypted or unsecure computers, servers or removable media, or personal cloud-based services.
• Report identified privacy or security breaches or vulnerabilities to JobAccomm’s privacy and security personnel, and be familiar with JobAccomm’s privacy procedures that define JobAccomm’s privacy vision, principles and governance model for managing privacy.
WHAT DO I NEED TO WATCH OUT FOR?
• Storing, transferring or using personal data not required for a legitimate business purpose.
• Properly shredding and securely destroying unnecessary personal data.
• Ensure that you have processes and best practices for transmitting, processing or storing personal data in protected environments.
• Leaving personal or customer data at a printer, on a shared server, or on a publically accessible computer or site.
• Transferring personal data between countries without addressing varying data protection standards.
• Disclosing personal data to any unauthorised persons or organisations.
INTELLECTUAL PROPERTY & CONFIDENTIAL INFORMATION
JobAccomm invests in and rewards innovation. JobAccomm’s intellectual property ― which includes patents, software and other copyrighted materials, know- how and trade secrets, brands and trademarks ― is among its most valuable assets. We actively protect our intellectual property, and follow JobAccomm classification and handling guidelines for our intellectual property and confidential information. We respect the valid intellectual property and confidential information of others.
WHAT DO I NEED TO KNOW?
• When dealing with intellectual property or confidential information, ask these questions:
• “Who owns this? May I use it?”
• “With whom may I share this? How do I protect its value?”
• “Has the term of my licensed use expired? If so, is there any action I need to take?”
• Seek proper authorisation and have appropriate contract terms in place before providing JobAccomm intellectual property to a third party. For help, contact JobAccomm Legal & Compliance.
• Protect JobAccomm confidential information and trade secrets from unauthorised disclosure and misuse, and do not share them with third parties except under approved terms which restrict their disclosure and use.
• Respect and protect the intellectual property and confidential information of others with the same degree of care we give our own, and according to the terms of any applicable agreement.
• Theft, misuse or misappropriation of JobAccomm’s or a third party’s intellectual property can expose you and potentially JobAccomm to civil lawsuits and damages, as well as criminal liability. Violations of this policy can also lead to disciplinary action.
• Use JobAccomm’s, processes and intellectual property teams to help you properly harvest, protect and enforce intellectual property rights and confidential information.
WHAT DO I NEED TO WATCH OUT FOR?
• Obtaining or using the ideas, materials or information of another person/company without proper authorisation, which could include copying/using images, open source software, unsolicited ideas from outsiders, or written material obtained from online sources or third parties.
• Giving license, rights or access to our intellectual property or other information without authorisation, or accepting intellectual property or confidential information without consulting your legal professional.
• Using non-approved devices or tools, misusing approved devices/tools, or sharing your credentials, passwords, tools, or equipment ― all of which could lead to loss of intellectual property or damage to our IT systems.
• Sending sensitive information to unattended printers, discussing confidential information openly when others might be able to hear, or creating written materials without labelling them according to JobAccomm information classification and handling instructions.
• Misuse of JobAccomm intellectual property or confidential information or finding that others have reverse-engineered JobAccomm’s patented products, processes, services or designs. Report such misuse immediately to the JobAccomm Legal and Compliance team.
• Employing a new person who may have worked for a competitor without implementing safeguards to prevent the new employee from inadvertently disclosing the intellectual property or confidential information of others.
• Failing to honour your obligations under a non-disclosure agreement or invention assignment agreement between you and JobAccomm.
• Engaging in situations in which you’re not sure what to do — when in doubt, contact Legal and Compliance for help.
WORKING WITH SUPPLIERS
JobAccomm seeks productive, ethical and transparent relationships with its suppliers. We expect our suppliers to be qualified according to JobAccomm standards, to follow and exceed all applicable laws and regulations, and share the values expressed in our Code of Conduct. We follow JobAccomm purchasing procedures when selecting a new supplier and when managing a relationship with an existing supplier. Our interactions with suppliers are transparent and open and we do not accept or give gifts or entertainment beyond JobAccomm’s Gift, Entertainment and Hospitality Procedures.
WHAT DO I NEED TO KNOW?
• Suppliers perform work or provide services on behalf of JobAccomm, and you must take care that they do not cause harm to the good reputation of JobAccomm. Be familiar with key purchasing policies and requirements.
• Immediately raise a concern if you are asked to select or deal with a specific supplier and/or deviate from the approved supplier selection or relationship management process.
• We take prompt, thorough remedial steps and shift JobAccomm business away from suppliers whose legal or ethical performance is questionable.
• Accepting anything beyond JobAccomm Gift, Entertainment and Hospitality Procedures from suppliers may result in discipline, up to and including termination of employment. In addition, such actions can expose you to civil and criminal liability. You must immediately report any attempt by a supplier to provide anything of value or other consideration beyond JobAccomm Gift, Entertainment and Hospitality Procedures.
• We do not accept from suppliers any gifts, entertainment or hospitality beyond JobAccomm’s Gift, Entertainment and Hospitality Procedures.
WHAT DO I NEED TO WATCH OUT FOR?
• Being pressured to select a specific supplier – regardless of the outcome of the supplier selection process.
• Suppliers offering anything of value (e.g. hiring your relative) to be selected, maintain or increase business, to overlook contract terms, audit or quality issues or to avoid any other requirements or lawful practices.
• Suppliers that resist the standards contained in JobAccomm Supplier Requirements, including ethical behaviour, labour and human rights, health and safety and the environment.
• Suppliers that do not have a code of conduct in place with policies related to ethical behaviour, labour standards, sustainable business practices, quality control and safety and security, or do not commit to JobAccomm’s values as expressed in this Code of Conduct.
• Suppliers that do not address reasonable concerns, corrective actions or audit findings in a timely manner.
• Suppliers that claim they can meet unrealistic delivery schedules or pricing, expedite customs issues or attempt to use JobAccomm’s good name or logo in an unauthorised manner.
• Suppliers that are owned or controlled by the government or a government official or close family member, or a supplier that claims it can exercise improper influence with the government or with a customer.
• Conflicts of interest in conducting business with suppliers, such as when someone in your family or anyone else with whom you have a close personal relationship has a substantial role in or relationship with a certain supplier.
TRADE COMPLIANCE
JobAccomm’s provision of services around the world is regulated by national and international laws and standards, and these regulations affect JobAccomm’s operations in multiple ways. The transmission of information and data across borders by email and the web, or even the exchange of information among citizens of different nations who are all co-located in one country, can be strictly regulated.
We comply with all applicable trade compliance laws and regulations that affect our operations.
WHAT DO I NEED TO KNOW?
• Consider the applicable trade rules when arranging any cross-border transactions, including those that are free of charge.
• Many countries impose restrictions on the transfer of certain technologies and data; some even completely forbid business with certain countries. Export restrictions and sanctions may apply depending on several factors:
• the destination country;
• hardware, software, and technology;
• companies and people involved in international and domestic business transactions.
WHAT DO I NEED TO WATCH OUT FOR?
• If you initiate import or exports, you are responsible for following JobAccomm’s policies and procedures for obtaining proper clearance.
• Take time to understand what would be considered, by local authorities, imports and exports with the help of the Global Trade Management team.
• Manual shipments or luggage carried on business trips.
• Any controlled technology transmitted by email, server access or other means.
• Obtain clear and complete answers from customers or third parties about the end use/end-user, delivery dates and locations.
• Archive import and export documentation carefully for audit purposes.
HEALTH, SAFETY AND LABOUR CONDITIONS
JobAccomm has a deep commitment to the health and safety of our employees and those who work with us. We earn the respect of each other, our contractors, partners, customers and members of the public by providing a safe, healthy and fair working environment. We do this through robust and consistent implementation of our processes that meet or exceed regulatory requirements. We also expect the same of our contractors and suppliers.
WHAT DO I NEED TO KNOW?
• All JobAccomm employees are responsible for ensuring healthy, safe and fair working conditions for all.
• Occupational health and safety management is integrated into our business and processes including design, production, distribution, installation and support of our product and systems.
• We continuously improve our health and safety performance through risk management, prevention of work-related accidents and the spread of communicable diseases, and implementation of new working practices and technologies.
• We promote healthy lifestyles and support activities that enhance employees’ health, well-being and work- life balance.
• We take immediate action to remedy situations in which incidents, audits and feedback identify areas for improvement in our health, safety and labour conditions management.
• We expect our suppliers, contractors and other business partners follow the same standards and place equally high priority on health, safety and labour conditions in their operations.
• JobAccomm takes this policy seriously, and may impose discipline for violations. Likewise, regulatory authorities may seek to impose civil and criminal penalties for violations of health, safety and labour condition laws.
WHAT DO I NEED TO WATCH OUT FOR?
• Situations that could be dangerous; for example, a colleague not wearing a safety belt in a taxi, participating in a conference call while driving, or working at steep heights without the proper safeguards in place.
• Anyone who disregards our policies, legal requirements or otherwise acts in a way that places others at risk, such as a manager requesting anyone work when not fit for duty.
• Look for opportunities in your daily work routines to improve safety, processes and health practices.
CONTROLLERSHIP
JobAccomm classifies and records its transactions and assets appropriately. JobAccomm implements appropriate controls to represent its financial data accurately and consistently, protects its assets adequately, and report its transactions in a timely and objective manner. JobAccomm is committed to complying with the applicable laws and regulations that govern its financial accounting and reporting to government agencies, investors and the public.
WHAT DO I NEED TO KNOW?
• It is critical to maintain complete and accurate records of JobAccomm financial transactions and assets, including operating metrics and results, to ensure a complete audit trail.
• You should pay close attention to the safekeeping of JobAccomm’s financial, physical and informational assets, including intellectual property.
• When presenting business information or making financial forecasts, you should be candid and transparent.
• Before signing a document or approving a transaction, verify the facts and completeness of the information, and consider the underlying business rationale for the approval.
• Cooperate fully with any external or internal audits and provide full, complete and timely answers to questions and document requests.
• You should ensure that JobAccomm’s accounting procedures, as well as other applicable accounting principles and regulations are consistently followed ― when in doubt, ask.
• You should preserve records and financial information in accordance with law and with JobAccomm’s document retention procedures.
• Misrepresenting facts, transactions or financial data is a serious matter, and can lead to civil and criminal liability for those involved and for JobAccomm.
WHAT DO I NEED TO WATCH OUT FOR?
Financial transactions recorded in error, with the wrong date or with a misleading description, including false expenses, purchase orders, inaccurate time sheets or vouchers.
Any transaction that does not make fundamental business sense, decisions that are inconsistent with sound business economics, or financial results that do not appear consistent with the actual business performance.
Any effort to avoid appropriate reviews for a transaction, or actions inconsistent with an employee’s level of authority.
Any physical assets that are not appropriately protected against loss or theft, or any effort to dispose of an asset without proper authorisation.
Any absence of controls on transactions, such as dual signatures on checks or required approvals on expenses, particularly where cash is involved.
Any effort to circumvent document retention requirements, particularly associated with pending or reasonably foreseeable litigation, audits or investigations.
FAIR EMPLOYMENT
JobAccomm must be an employer of choice — and its employees represent JobAccomm’s future. JobAccomm cultivates a diverse workplace culture of respect, where challenging opportunities for individual and collective renewal, achievement and growth abound. In our recruiting, retention, promotion and other employment activities, we are committed to complying with the applicable employment and labour laws and regulations where we do business, including wage & hour, privacy, immigration, compulsory and child labour, collective bargaining, anti-discrimination and similar employment rules. We publish for our employees and managers internal guidelines, procedures and standards for their internal employment-related decision-making.
WHAT DO I NEED TO KNOW?
• Every country regulates the workplace, and JobAccomm has the appropriate employment practices and process to comply with applicable law as well as our own internal guidelines, procedures and standards.
• JobAccomm issues a single Human Resources Policy, Standard Operating Procedures and Guidelines to regulate the individual areas within Human Resource Management. This Fair Employment statement summarises the commitments of the JobAccomm Group HR Policy and all SOP’s and Guidelines that fall under that umbrella.
• Complying with the legal requirements is only part of the formula for cultivating a culture of respect in our workplace — we are all responsible for assuring that everyone at JobAccomm is treated with respect and given fair consideration.
• Ensure that employment decisions are based on job qualifications and without regard for a person’s race, age, gender, sex (including pregnancy), national origin, ethnicity, colour, sexual orientation or expression or religion or other characteristic prohibited by law.
• Many countries have particular rules on immigration, limitations on expatriate workers, and secondments or use of temporary workers.
• JobAccomm regularly validates its Standard Operating Procedures and Guidelines, against applicable law – please raise promptly any matter that may require review or adjustment.
WHAT DO I NEED TO WATCH OUT FOR?
• Our Employment standards are high and we do not waiver. Just because a particular legislation would allow or does not specifically forbid certain practices, our global policies still hold and we abide by them.
• Requests or attempts internally or by third parties to compromise or subvert JobAccomm’s Human Resources policy, Standard Operating Procedures or Guidelines.
• Hiring or promoting practices that do not follow our approved processes or are not based on JobAccomm’s values and individual merit.
• Creating a hostile work environment, bullying or similar offensive conduct (by making jokes or displaying materials that are offensive to an ethnic, racial or gender group).
• Failing to observe labour laws where you work, for example, prohibitions on child or compulsory labour, denying or limiting freedom of choice of employment.
• Taking adverse employment action against anyone who has raised a good faith concern regarding a potential violation of JobAccomm’s Code of Conduct or applicable law.
HUMAN RIGHTS
JobAccomm provides products and services that expand opportunities to communicate and contribute directly to the exercise of such fundamental rights as free expression and political participation.
JobAccomm is committed to the principles of The Universal Declaration of Human Rights and the United Nations’ Global Compact, and we expect our suppliers and business partners to share these values.
JobAccomm seeks to ensure that materials used in our products come from socially responsible sources. We do not tolerate, contribute to, or facilitate any activity that fuels conflict or violates human rights.
WHAT DO I NEED TO KNOW?
• JobAccomm conducts due diligence in the pre-sales process and follows international standards to help ensure that our products are used to enhance, and not infringe, human rights.
• JobAccomm provides limited, core and UN mandated “lawful intercept” capabilities based on clear standards and on a transparent foundation in law. Operators are required in most countries to provide such capabilities to assist authorities in legitimate law enforcement.
• JobAccomm also conducts due diligence on its suppliers and business partners to ensure that they share JobAccomm’s commitment to human rights.
• JobAccomm complies with applicable laws and participates in industry initiatives to support human rights and to validate that the minerals and metals used in our products do not contribute to conflict.
• Unlawful, exploitative or improper use of natural resources can expose JobAccomm to penalties or criminal prosecution.
WHAT DO I NEED TO WATCH OUT FOR?
• Be particularly sensitive when conducting business in countries where the rule of law is weak, or where the government is not a result of free and open democratic processes.
• Requests for subscriber data beyond that which is provided in the normal course of business in cases where JobAccomm hosts the network.
• Requests from operators in higher-risk countries for specific features such as location-based data, more detailed subscriber data on traffic or events, in addition to standard functionality.
• Suppliers or contractors that appear to employ underage workers, or do not provide safe or healthy workplaces.
• Use of minerals from conflict countries that are regulated by international authorities. JobAccomm tracks the origin of these metals in our products all the way to smelters in our supply chain.
ENVIRONMENT
JobAccomm’s longstanding commitment to the protection of the environment and management of environmental issues actively, openly and ethically meets and often exceeds legal and regulatory requirements. JobAccomm continuously seeks to prevent pollution and to reduce the environmental impacts of its products
and services during design, procurement, manufacturing, use and end-of-life. We embed environmental considerations into our operations, business planning, decision-making and monitoring activities to understand impacts and continuously improve. We also expect our business partners and suppliers to share our commitment to the environment.
WHAT DO I NEED TO KNOW?
• JobAccomm meets or exceeds the legal requirements for protecting the environment. JobAccomm expects its employees, suppliers, contractors and other business partners to follow the same or equivalent standards, placing a high priority on protecting the environment.
• Be aware of the environmental impacts relevant to your work and how the specific requirements are met in the function where you work (e.g., product requirements in R&D or transportation selection in logistics).
• Take immediate action to remedy situations in which incidents, audits and feedback highlight areas for improvement in JobAccomm’s environment management.
• Be aware that non-compliance with environmental laws can lead to civil and potential criminal liability; in addition, JobAccomm employees may be subject to discipline for breaches of this policy.
WHAT DO I NEED TO WATCH OUT FOR?
• Failing, promptly, to address environmental complaints or concerns from employees, suppliers, customers or other third parties.
• Suppliers or contractors that do not engage in sound or sustainable environmental practices.
• Ignoring applicable environmental regulations or company guidelines.
• Missing opportunities to decrease the environmental impact of our products and services by reducing waste, increasing energy or material efficiency, or preventing pollution.
• Taking action on acquisitions, dispositions, or other new ventures without first conducting thorough due diligence to evaluate their environmental risks.
• Obtaining, maintaining, renewing and extending all environmental permits, licenses, or other clearances (such as environmental impact studies) on a timely basis necessary to JobAccomm’s operations.
• Making the Code of Conduct part of everyday business
YOUR RESPONSIBILITIES UNDER THE JOBACCOMM CODE OF CONDUCT
The Code of Conduct sets high standards of integrity for JobAccomm employees and business partners. It outlines our commitment to act compliantly and ethically in our business activities.
The Code cannot possibly address every specific situation employees will face in our complex, global businesses. There will continue to be emerging areas, legal and regulatory uncertainties, risks and challenges going forward. This does not mean that we are relieved from our responsibilities to act in an ethical manner: in all cases, your obligations under the Code include:
• Read, understand and follow the Code of Conduct and its polices;
• Promptly raise any and all compliance concerns through one of the channels provided by the business;
• Know when to seek assistance or get more training;
• Do not retaliate against anyone for raising a compliance concern;
• Cooperate fully and transparently in all compliance investigations;
• Avoid any practices that may lead to unlawful conduct, an appearance of impropriety or harm JobAccomm’s reputation.
JobAccomm managers and leaders are compliance stewards for their organisations: they own the culture of compliance. Thus, leaders and and managers have additional responsibilities to engage actively with their teams and create an effective culture of compliance in their organisations. This means that managers must:
• Know and anticipate business compliance risk areas that would affect your team operations;
• Take proactive steps to mitigate risks that may affect team operations and ensure your team is trained to deal with them
• Communicate regularly with your team about the importance of compliance;
• Emphasise the value of reporting potential compliance concerns promptly and foster an environment of open reporting;
• Ensure that employees feel comfortable raising concerns with no fear of retaliation;
• Reward and recognise employees who go above and beyond with respect to compliance;
• Allocate appropriate resources to ensure compliance, and set goals to track compliance;
• Hire and promote only those people who have high standards of integrity;
• Participate actively and meaningfully in the compliance process and governance for the company;
• Demonstrate visibly ― through your own words and actions ― your personal commitment to the JobAccomm Code of Conduct and its policies.
RAISING CONCERNS
Violations of our Code of Conduct erodes the trust we have built with our shareholders, customers and other stakeholders. In addition, a failure to follow the Code can put your colleagues and our business at risk. Thus, you are obligated to raise a concern promptly should you become aware of a potential or suspected violation of the Code. By quickly reporting potential violations, you are therefore helping the company maintain its reputation and address potential problems before they have an adverse impact — financial, reputational or legal — on the company.
JobAccomm provides multiple ways to raise a confidential concern. You may talk to your line manager, the JobAccomm Compliance team or your local legal team. You may also write to our Chairwoman or our Board.
You may raise your concern anonymously. You are not required to provide your name or other identifying information, but you should provide sufficient detail on your concern so that JobAccomm can follow up appropriately. JobAccomm will track your concern by number so that the investigation team can follow up with you on an anonymous basis.
JOBACCOMM’S POLICY ON RETALIATION
JobAccomm is committed to maintaining a culture in which our employees feel comfortable raising good faith concerns about potential violations of the Code of Conduct. JobAccomm will not tolerate any adverse employment action against an employee who raises a compliance concern. Any employee who retaliates against another employee for raising a compliance concern will be subject to strict discipline, up to an including termination of employment.
REPORTING CONCERNS: Email ethics@jobaccomm.com
PROCESS
We take each concern seriously. The Compliance team will review and promptly address your concern for appropriate follow-up and resolution; this may involve assigning a neutral party or auditor to investigate and understand the concern. The Compliance team will also assign a high-level “familiar manager” from the business to oversee the investigation. The team will track your concern from initiation to its resolution to ensure that it receives careful and thorough attention.
At the end of the investigation, if the JobAccomm Code of Conduct has been violated, the Compliance team will decide the appropriate corrective action or discipline. We will share feedback (respecting confidentiality) with the person who raised the concern and lessons learned with the business.
CORRECTIVE ACTION AND DISCIPLINE
An important aspect of our compliance program is taking effective corrective action and, where appropriate, employee discipline. Subject to local law, discipline, up to and including termination of employment, will depend on a number of factors, including but not limited to the following examples:
The conduct was intentional or deliberate, or involved a violation of law;
• The conduct involved dishonesty, theft, fraud, or personal gain;
• The conduct was repetitive or systemic or included efforts to conceal;
• The employee cooperated fully and openly with the investigation;
• The employee has set the right culture for compliance in the organisation;
• The employee’s level within the organisation.
Employees will be provided an opportunity to present any additional relevant information that may not have been considered before a disciplinary decision is made.
THE JOBACCOMM ETHICAL DECISION-MAKING MODEL
1. Was your first reaction OK?
Are you comfortable with the issue or decision?
2. Is it legal?
Does it comply with local or global laws and regulations?
3. Is it consistent with our Values, Code, and policies?
Read our Code, and think about how the decision or action may be inconsistent with our Values.
4. Would others think it was OK if they read it in the news or Internet? Thinking through how others would see and judge our actions and their consequences can be a useful tool for assessing the ethical impact of our decisions.
5. Proceed
Share your learnings and best practices with others.
STOP Not sure? Check with: A manager, HR, Legal or the Ethics and Compliance Office.
V2 March 2021