Last updated on
27/08/2026
Our Code of Conduct (the “Code”) is a reflection of our collective commitment to ethical and responsible conduct. The Code serves as a compass, guiding our actions and decisions, ensuring that everything we do aligns with the highest standards of integrity and professionalism.
This Code is applicable to each and every one of us, without exception, setting clear boundaries of what is and isn’t acceptable.
All employees are required to understand and comply with the Code, company policies and the laws that govern our business activities. Together with our core values and other policies, the Code helps us make the right decisions and take appropriate actions, regardless of our role, location or responsibilities.
We believe that every employee is a leader, regardless of job title or function. By following the Code, each of us acts as a role model for colleagues, business partners, customers and others who observe our actions.
All employees must comply with applicable anti-bribery and anti-corruption laws in the course of their work. Regardless of local customs or industry practices, all forms of bribery are strictly prohibited.
For the purposes of this Code, bribery includes any direct or indirect improper payment made to a government official, government employee or any other individual to secure or retain business or gain an unfair business advantage.
Additionally, employees are prohibited from offering, promising, or authorizing such payments, even if they are ultimately not carried out. Likewise, accepting improper payments in exchange for providing an unfair business advantage is strictly forbidden.
Bribery can take many forms beyond direct cash payments. Here are some examples of non-cash things that may violate anti-bribery or anti-corruption laws or our Code, and could be improper:
For more information, please refer to the Anti-Bribery and Anti-Corruption Policy and the Gifts and Hospitality Policy. If you are unsure whether an action is permissible, consult Compliance before proceeding.
Business gifts and hospitality should be used to foster goodwill and professional relationships, never to gain an improper business advantage or influence approvals. Employees must ensure that all gifts and hospitality are appropriate, ethical and comply with company policies.
Employees are strictly prohibited from giving or accepting gifts or hospitality involving government officials unless they have received express written pre-approval from the Compliance team.
Employees should exercise caution when giving or accepting gifts and hospitality to avoid even the appearance of impropriety. The following are always inappropriate:
Gifts and hospitality must not be given to or accepted from current or potential customers and/or vendors while active sales negotiations are in progress unless pre-approved by Compliance.
If there is any concern that a gift or hospitality might influence business decisions or create a conflict of interest, it should be declined to ensure fair and ethical decision-making. Employees are responsible for ensuring that their actions reflect integrity and transparency.
All charitable donations, sponsorships or initiatives involving company assets must receive pre-approval from Compliance and undergo thorough due diligence to prevent conflicts of interest.
Charitable donations must never be used to gain an improper business advantage or to influence decisions by government officials or other entities. Employees are welcome to support personal charitable causes but must do so on their own time and without company resources.
Employees are also encouraged to participate in personal political and civic activities, provided they do so on their own time and at their own expense.
If you are uncertain whether a political activity could be perceived as representing the company, consult Compliance before proceeding.
We are committed to conducting business in full compliance with all applicable international trade laws and regulations. This includes adherence to export controls, trade sanctions, customs laws and anti-boycott regulations in every jurisdiction where we operate. Employees must ensure that transactions involving goods, services, software and technology comply with all relevant laws, including obtaining necessary licenses or approvals when required.
Violations of trade compliance laws can result in severe penalties and we expect all employees to act with integrity, exercise caution and seek guidance when in doubt.
For more information, please see our Sanctions Compliance Policy.
Employees have a duty to act in the best interests of the company, prioritizing its success over personal gain. A conflict of interest arises when personal relationships, financial interests, or outside engagements could interfere, or appear to interfere with objective decision-making for the company.
Decisions should always be made based on what is best for the company, not personal benefit. Employees must never use their position for improper personal advantages, either for themselves or others, including family members or organizations in which they have significant involvement.
Conflicts can be actual (direct and existing), potential (could develop into a conflict) or perceived (appears to be a conflict, even if it isn’t). All types of conflicts can harm both the company’s and the employee’s reputation. Examples include:
If you are aware of an actual, potential or perceived conflict, do not proceed with the activity until you have disclosed it. Please consult with your manager, the Compliance team or the Legal Department for guidance.
Confidential information is one of our most valuable assets, and it is the responsibility of every employee to protect it.
Confidential information includes non-public information that could benefit competitors or harm our company or customers if disclosed, such as:
Additionally, employees may come across confidential information about other companies we work with. This information must be treated with the same level of confidentiality as our own. Even the fact that we are in discussions with another company should not be disclosed without authorization.
Confidential and proprietary information must never be shared or disclosed unless it has been made public through approved channels. Employees should only discuss such information with colleagues who have a legitimate business need to know. Unauthorized use, sharing or distribution, whether intentional or accidental, could be illegal and may result in civil or criminal penalties.
To prevent accidental disclosure, you should:
Protecting confidential information is essential to maintaining our competitive advantage, legal compliance and the trust of our customers and partners. If you are unsure whether certain information is confidential, consult with the Legal or Compliance team before sharing it.
Employees are responsible for protecting and using company assets appropriately. Physical assets, such as computer equipment, products and buildings, should be used only for legitimate business purposes, with limited personal use permitted when appropriate.
Employees must not misuse, exploit or personally benefit from the company’s intellectual property, including source code, technology, corporate name, brand names or trademarks.
When acting on behalf of the company or using company computing or communication systems, employees are prohibited from:
Employees must also respect the intellectual property and assets of others, ensuring there is no unauthorized use or misappropriation.
If you become aware of misuse or unauthorized access to company or third-party assets, report it immediately to your manager or the Compliance team.
Employees must ensure that all agreements, promises and commitments made on behalf of the company are formally documented in executed contracts, purchase orders or other approved legal documents.
Employees must not create verbal or written commitments that establish new agreements or alter existing ones without proper authorization and review by the Legal Department. Any modifications to company agreements must follow the official approval process.
We are committed to protecting the environment and responsibly managing natural resources in line with our core values. Guided by this commitment, we continuously work to reduce our environmental footprint across our operations and products.
You are expected to:
Generative Artificial Intelligence (GenAI) refers to AI systems capable of creating various forms of content, including text, images, audio and other media, based on the data they have been trained on. While this technology offers vast opportunities across industries, it remains in a state of continuous development. As such, it must be used with caution and in alignment with our ethical principles.
You are required to follow the Guidelines on the Responsible Use of Generative AI and must not utilize GenAI for any activities that would conflict with existing policies. The use of GenAI must be conducted in a transparent and accountable manner. Any past or future implementation of GenAI within business operations must be disclosed.
Additionally, outputs generated by AI must be carefully reviewed to mitigate potential risks, such as inaccuracy, bias, accountability concerns and violations of open-source software licenses.
For further clarification or guidance, please reach out to the Legal, Privacy or Information Security teams.
We are committed to conducting business fairly and honestly, ensuring that our success is based on the quality of our products and services, not on unethical or illegal business practices.
Employees must not acquire, use or attempt to obtain proprietary information or trade secrets through improper means. Pressuring or encouraging current or former employees of other companies or any other individuals, to disclose confidential information is strictly prohibited.
If you come across trade secrets or confidential information belonging to another business or customer or if you are unsure about handling such information, seek guidance from your manager, Compliance team or the Legal Department immediately.
We are committed to conducting business in full compliance with antitrust and competition laws, which protect fair competition, innovation and consumer choice. These laws ensure that customers receive the best products and services at competitive prices.
To comply with these laws, the company strictly prohibits any agreements, coordinated practices or informal understandings with competitors that could unfairly restrict competition. The following are not permitted, whether formal or informal, written or oral:
Violating competition laws can lead to severe penalties, including criminal charges, administrative fines and lawsuits. In some cases, fines may be tripled and violations can significantly damage our reputation and business operations.
If you are unsure whether a business practice complies with competition laws, seek guidance from the Legal Department or Compliance before proceeding.
We are committed to respecting and promoting human rights in all aspects of our business operations. Our actions align with internationally recognized human rights principles, including those outlined in the United Nations Universal Declaration of Human Rights and the International Labour Organization’s core conventions.
We do not tolerate any form of forced labor, child labor, human trafficking or discrimination. We strive to ensure fair wages, safe working conditions and freedom of association for all employees. Employees and business partners are expected to uphold these values.
If you become aware of any human rights violations or risks, you must report your concerns to Compliance immediately.
We are dedicated to creating a workplace that embraces diversity, fosters inclusion and ensures equal opportunities for all. We recognize that individuals bring unique perspectives, backgrounds and experiences that enrich our company and drive innovation. Our commitment to diversity extends across all aspects of our business, ensuring that everyone, regardless of race, gender, age, disability, sexual orientation, religion, or any other protected characteristic, is treated with fairness, dignity and respect.
Discrimination, harassment or exclusion of any kind has no place in our workplace. We actively promote policies and practices that support equity in hiring, career advancement and decision-making.
We encourage open dialogue, collaboration and accountability to ensure that every individual feels a sense of belonging. Employees are expected to uphold these principles and report any concerns related to discrimination or bias without fear of retaliation.
We are committed to maintaining a workplace that is free from harassment, intimidation and any form of inappropriate behavior. Harassment, whether verbal, physical, visual or online, will not be tolerated under any circumstances. This includes, but is not limited to, unwelcome comments, offensive jokes, bullying, threats, inappropriate physical contact or any conduct that creates a hostile or uncomfortable work environment.
Our zero-tolerance policy applies to all interactions in the workplace, including those involving employees, clients and business partners.
We encourage employees to speak up and report any concerns related to harassment without fear of retaliation. Complaints will be taken seriously, investigated promptly and addressed with appropriate action.
Employees must comply with all applicable health and safety regulations, follow company policies and use protective equipment as required. Hazardous conditions, unsafe practices or workplace injuries must be reported immediately to prevent harm and ensure corrective action is taken. We also promote a culture of well-being, encouraging employees to prioritize both physical and mental health.
Employees are expected to avoid illegal or controlled substances that could impair their ability to perform their job effectively. Possessing, using, soliciting, distributing or manufacturing illegal drugs or substances in the workplace or while working is strictly prohibited.
We do not tolerate malpractice or wrongdoing in any part of the company. If you witness or experience something concerning at work, our Speak Up Policy outlines how you can report it safely and confidentially.
For employees, concerns should normally be raised through your line manager, their manager or your HR business partner. If these channels are not appropriate, you should refer to the Speak Up Policy for alternative reporting options.
Employees can be assured that no one will face penalties for raising a concern in good faith, even if it turns out to be a mistake. Concerns should not be raised for personal grievances, and any malicious false allegations will result in disciplinary action.
Insight to Impact.
