Garnes Gruppen Code of Conduct
Code of Conduct
- for companies and all employees in the Garnes Group
This document applies to all employees in all companies in the group.
Garnes Group - Statement of Our Core Values
Company Vision – Passion for Technology!
We are driven by our passion for technology. We love excellent technology, and we love helping our clients to
lead and thrive in their industry.
Values – We are Innovative, Solid, and Honest!
We are innovative, solid, honest, and loyal tech companies with teams dedicated to stay true to our passion
and share it with our clients.
Mission – Create, Deliver and Care!
We are dedicated to bringing the best of insights and technology to our clients positioning them for optimal
performance and digital leadership in their current and future markets.
We:
1. Create technology and solutions by innovating, disrupting, and collaborating.
2. Deliver optimal technology and solutions by striving to be excellent, agile, skilled, and experienced.
3. Care for our clients, suppliers, partners, and their people by being proactive, available, helpful, transparent
partners.
Build Trust and Credibility
The success of our business is dependent on the trust and confidence we earn from our employees,
customers, partners, and shareholders. We gain credibility by adhering to our commitments, displaying
honesty and integrity, and reaching company goals solely through honourable conduct. It is easy to say what
we must do, but the proof is in our actions. Ultimately, we will be judged on what we do.
When considering any action, it is wise to ask: Will this build trust and credibility for Garnes Group? Will it help
create a working environment in which Garnes Group can succeed over the long term? Is the commitment I
am making one I can follow through with? The only way we will maximize trust and credibility is by answering
“yes” to those questions and by working every day to build our trust and credibility.
Garnes Group Code of Conduct v1.01
Garnes Gruppen Code of Conduct
Respect for the Individual
We all deserve to work in an environment where we are treated with dignity and respect. Garnes Group is
committed to creating such an environment because it brings out the full potential in each of us, which, in
turn, contributes directly to our business success. We cannot afford to let anyone’s talents go to waste.
Garnes Group is an equal employment/affirmative action employer and is committed to providing a workplace
that is free of discrimination of all types and from abusive, offensive, or harassing behaviour.
All Garnes Group employees are also expected to support an inclusive workplace by adhering to the following
conduct standards:
Always treat others with dignity and respect.
Address and report inappropriate behaviour and comments that are discriminatory, harassing, abusive,
offensive, or unwelcome.
- Foster teamwork and employee participation, encouraging the representation of different employee
perspectives.
- Seek out insights from employees with different experiences, perspectives, and backgrounds.
- Avoid slang or idioms that might not translate across cultures.
- Support flexible work arrangements for co-workers with different needs, abilities and/or obligations.
- Confront the decisions or behaviours of others that are based on conscious or unconscious biases.
- Be open-minded and listen when given constructive feedback regarding others' perception of your
conduct.
Garnes Group will not tolerate discrimination, harassment or any behaviour or language that is abusive,
offensive, or unwelcome.
Create a Culture of Open and Honest Communication
At Garnes Group everyone can speak his or her mind, particularly with respect to ethics concerns. Managers
have a responsibility to create an open and supportive environment where employees can raise such
questions. We all benefit tremendously when employees exercise their power to prevent mistakes or
wrongdoing by asking the right questions at the right times.
Garnes Group will investigate all reported instances of questionable or unethical behaviour. In every instance
where improper behaviour is found to have occurred, the company will take appropriate action. We will not
tolerate retaliation against employees who raise genuine ethics concerns in good faith.
For your information, Garnes Group’s whistle-blower policy is as follows:
Employees are encouraged, in the first instance, to address such issues with their managers or HR, as most
problems can be resolved swiftly. If for any reason that is not possible or if an employee is not comfortable
raising the issue with his or her manager or HR, Garnes Group’s CEO does operate with an open-door policy.
Set Tone at the Top
Management has the added responsibility for demonstrating, through their actions, the importance of this
Code. In any business, ethical behaviour does not simply happen; it is the product of clear and direct
Garnes Group Code of Conduct v1.01
Garnes Gruppen Code of Conduct
communication of behavioural expectations, modelled from the top and demonstrated by example. Again,
ultimately, our actions are what matters.
To make our Code work, managers must be responsible for promptly addressing ethical questions or concerns
raised by employees and for taking the appropriate steps to deal with such issues. Managers should not
consider employees’ ethics concerns as threats or challenges to their authority, but rather as another
encouraged form of business communication. At Garnes Group, we want the ethics dialogue to become a
natural part of daily work.
Uphold the Law
Garnes Group’s commitment to integrity begins with complying with laws, rules, and regulations where we do
business. Further, each of us must understand the company policies, laws, rules, and regulations that apply to
our specific roles. If we are unsure of whether a contemplated action is permitted by law or Garnes Group
policy, we should seek the advice from the resource expert. We are responsible for preventing violations of
law and for speaking up if we see possible violations.
Because of the nature of our business, some legal requirements warrant specific mention here:
- The General Data Protection Regulation (GDPR), the European legal framework that sets guidelines
for the collection and processing of personal information from individuals.
Competition
We are dedicated to ethical, fair, and vigorous competition. We will sell Garnes Group products and services
based on their merit, superior quality, functionality, and competitive pricing. We will make independent
pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our
competitors. We will not offer or solicit improper payments or gratuities in connection with the purchase of
goods or services for Garnes Group or the sales of its products or services, nor will we engage or assist in
unlawful boycotts of customers.
Proprietary Information
It is important that we respect the property rights of others. We will not acquire or seek to acquire improper
means of a competitor’s trade secrets or other proprietary or confidential information. We will not engage in
unauthorized use, copying, distribution or alteration of software or other intellectual property.
Selective Disclosure
We will not selectively disclose (whether in one-on-one or small discussions, meetings, presentations,
proposals or otherwise) any material non-public information with respect to Garnes Group, its securities,
business operations, plans, financial condition, results of operations or any development plan. We should be
particularly vigilant when making presentations or proposals to customers to ensure that our presentations do
not contain material non-public information.
Garnes Group Code of Conduct v1.01
Garnes Gruppen Code of Conduct
Health and Safety
Garnes Group is dedicated to maintaining a healthy environment. Each business, country and location have
safety manuals or guidelines on safety in the workplace.
Avoid Conflicts of Interest
Conflicts of Interest
We must avoid any relationship or activity that might impair, or even appear to impair, our ability to make
objective and fair decisions when performing our jobs. At times, we may be faced with situations where the
business actions we take on behalf of Garnes Group may conflict with our own personal or family interests. We
owe a duty to Garnes Group to advance its legitimate interests when the opportunity to do so arises. We must
never use Garnes Group property or information for personal gain or personally take for ourselves any
opportunity that is discovered through our position with Garnes Group.
Here are some other ways in which conflicts of interest could arise:
Being employed (you or a close family member) by, or acting as a consultant to, a competitor or potential
competitor, supplier, or contractor, regardless of the nature of the employment, while you are employed with
Garnes Group.
- Hiring or supervising family members or closely related persons.
- Serving as a board member for an outside commercial company or organization.
- Owning or having a substantial interest in a competitor, supplier, or contractor.
- Having a personal interest, financial interest, or potential gain in any Garnes Group transaction.
- Placing company business with a firm owned or controlled by a Garnes Group employee or his or her
family.
- Accepting gifts, discounts, favours or services from a customer/potential customer, competitor, or
supplier, unless equally available to all Garnes Group employees.
Determining whether a conflict of interest exists is not always easy to do. Employees with a conflict-of-interest
question should seek advice from management. Before engaging in any activity, transaction or relationship
that might give rise to a conflict of interest, employees must seek review from their managers or HR.
Gifts, Gratuities and Business Courtesies
Garnes Group is committed to competing solely on the merit of our products and services. We should avoid
any actions that create a perception that favourable treatment of outside entities by Garnes Group was
sought, received, or given in exchange for personal business courtesies. Business courtesies include gifts,
gratuities, meals, refreshments, entertainment or other benefits from persons or companies with whom
Garnes Group does or may do business. We will neither give nor accept business courtesies that constitute, or
could reasonably be perceived as constituting, unfair business inducements that would violate law, regulation
or policies of Garnes Group or customers, or would cause embarrassment or reflect negatively on Garnes
Group’s reputation.
Garnes Group Code of Conduct v1.01
Garnes Gruppen Code of Conduct
Accepting Business Courtesies
Most business courtesies offered to us in the course of our employment are offered because of our positions
at Garnes Group. We should not feel any entitlement to accept and keep a business courtesy. Although we
may not use our position at Garnes Group to obtain business courtesies, and we must never ask for them, we
may accept unsolicited business courtesies that promote successful working relationships and good will with
the firms that Garnes Group maintains or may establish a business relationship with.
Employees who award contracts or who can influence the allocation of business, who create specifications
that result in the placement of business or who participate in negotiation of contracts must be particularly
careful to avoid actions that create the appearance of favouritism or that may adversely affect the company’s
reputation for impartiality and fair dealing. The prudent course is to refuse a courtesy from a supplier when
Garnes Group is involved in choosing or reconfirming a supplier or under circumstances that would create an
impression that offering courtesies is the way to obtain Garnes Group business.
Meals, Refreshments and Entertainment
We may accept occasional meals, refreshments, entertainment, and similar business courtesies that are
shared with the person who has offered to pay for the meal or entertainment, provided that:
- They are not inappropriately lavish or excessive.
- The courtesies are not frequent and do not reflect a pattern of frequent acceptance of courtesies
from the same person or entity.
- The courtesy does not create the appearance of an attempt to influence business decisions, such as
accepting courtesies or entertainment from a supplier whose contract is expiring soon.
- The employee accepting the business courtesy would not feel uncomfortable discussing the courtesy
with his or her manager or co-worker or having the courtesies known by the public.
Gifts
Employees may accept unsolicited gifts, other than money, that conform to the reasonable ethical practices of
the marketplace, including:
- Flowers, fruit baskets and other modest presents that commemorate a special occasion.
- Gifts of nominal value, such as calendars, pens, mugs, caps, and t-shirts (or other novelty, advertising,
or promotional items).
Generally, employees may not accept compensation, honoraria, or money of any amount from entities with
whom Garnes Group does or may do business. Tangible gifts (including tickets to a sporting or entertainment
event) that have a market value greater than USD100 may not be accepted unless approval is obtained from
management.
Employees with questions about accepting business courtesies should talk to their managers or HR.
Offering Business Courtesies
Any employee who offers a business courtesy must assure that it cannot reasonably be interpreted as an
attempt to gain an unfair business advantage or otherwise reflect negatively upon Garnes Group. An employee
may never use personal funds or resources to do something that cannot be done with Garnes Group
resources. Accounting for business courtesies must be done in accordance with approved company
procedures.
Garnes Group Code of Conduct v1.01
Garnes Gruppen Code of Conduct
Other than to our government customers, for whom special rules apply, we may provide nonmonetary gifts
(i.e., company logo apparel or similar promotional items) to our customers. Further, management may
approve other courtesies, including meals, refreshments, or entertainment of reasonable value, provided that:
- The practice does not violate any law or regulation or the standards of conduct of the recipient’s
organization.
- The business courtesy is consistent with industry practice, is infrequent in nature and is not lavish.
- The business courtesy is properly reflected on the books and records of Garnes Group.
Set Metrics and Report Results Accurately
Accurate Public Disclosures
We will make certain that all disclosures made in financial reports and public documents are full, fair, accurate,
timely and understandable. This obligation applies to all employees, including all financial executives, with any
responsibility for the preparation for such reports, including drafting, reviewing, and signing or certifying the
information contained therein. No business goal of any kind is ever an excuse for misrepresenting facts or
falsifying records.
Employees should inform Executive Management and the HR department if they learn that information in any
filing or public communication was untrue or misleading at the time it was made or if subsequent information
would affect a similar future filing or public communication.
Corporate Recordkeeping
We create, retain, and dispose of our company records as part of our normal course of business in compliance
with all Garnes Group policies and guidelines, as well as all regulatory and legal requirements.
All corporate records must be true, accurate and complete, and company data must be promptly and
accurately entered in our books in accordance with Garnes Group’s and other applicable accounting principles.
We must not improperly influence, manipulate, or mislead any unauthorized audit, nor interfere with any
auditor engaged to perform an internal independent audit of Garnes Group books, records, processes, or
internal controls.
Promote Substance Over Form
At times, we are all faced with decisions we would rather not have to make and issues we would prefer to
avoid. Sometimes, we hope that if we avoid confronting a problem, it will simply go away.
At Garnes Group, we must have the courage to tackle the tough decisions and make difficult choices, secure in
the knowledge that Garnes Group is committed to doing the right thing. At times this will mean doing more
than simply what the law requires. Merely because we can pursue a course of action does not mean we should
do so.
Although Garnes Group’s guiding principles cannot address every issue or provide answers to every dilemma,
they can define the spirit in which we intend to do business and should guide us in our daily conduct.
Garnes Group Code of Conduct v1.01
Garnes Gruppen Code of Conduct
Accountability
Each of us is responsible for knowing and adhering to the values and standards set forth in this Code and for
raising questions if we are uncertain about company policy. If we are concerned whether the standards are
being met or are aware of violations of the Code, we must contact the HR department.
Garnes Group takes seriously the standards set forth in the Code, and violations are cause for disciplinary
action up to and including termination of employment.
Be Loyal
Confidential and Proprietary Information
Integral to Garnes Group’s business success is our protection of confidential company information, as well as
non-public information entrusted to us by employees, customers, and other business partners. Confidential
and proprietary information includes such things as pricing and financial data, customer names/addresses or
non-public information about other companies, including current or potential supplier and vendors. We will
not disclose confidential and non-public information without a valid business purpose and proper
authorization.
Use of Company Resources
Company resources, including time, material, equipment, and information, are provided for company business
use. Nonetheless, occasional personal use is permissible if it does not affect job performance or cause a
disruption to the workplace.
Employees and those who represent Garnes Group are trusted to behave responsibly and use good judgment
to conserve company resources. Managers are responsible for the resources assigned to their departments
and are empowered to resolve issues concerning their proper use.
Generally, we will not use company equipment or technology resources such as, but not limited to, servers,
networks, domains, e-mail accounts, computers, an copiers in the conduct of an outside business or in support
of any religious, political, or other outside daily activity, except for company-requested support to non-profit
organizations. We will not solicit contributions nor distribute non-work-related materials during work hours.
To protect the interests of the Garnes Group network and our fellow employees, Garnes Group reserves the
right to monitor or review all data and information contained on an employee’s company-issued computer or
electronic device, the use of the Internet or Garnes Group’s intranet. We will not tolerate the use of company
resources to create, access, store, print, solicit or send any materials that are harassing, threatening, abusive,
sexually explicit, or otherwise offensive or inappropriate.
Questions about the proper use of company resources should be directed to your manager.
Media Inquiries
Garnes Group is a profiled company in our community, and from time to time, employees may be approached
by reporters and other members of the media. To ensure that we speak with one voice and provide accurate
information about the company, we should direct all media inquiries to the CEO. No one may issue a press
release without first consulting with the CEO.
Garnes Group Code of Conduct v1.01
Garnes Gruppen Code of Conduct
Do the Right Thing
Several key questions can help identify situations that may be unethical, inappropriate, or illegal.
Ask yourself:
- Does what I am doing comply with the Garnes Group guiding principles, Code of Conduct, and
company policies?
- Have I been asked to misrepresent information or deviate from normal procedure?
- Would I feel comfortable describing my decision at a staff meeting?
- How would it look if it made the headlines?
- Am I being loyal to my family, my company and myself?
- What would I tell my child to do?
- Is this the right thing to do?