Code of Ethics and Business Conduct

1. INTRODUCTION
This code of ethics and business conduct (“the Code”) of BiZZdesign explains the ways we put BiZZdesign’s values into practice. It applies to all employees and contractors of BiZZdesign B.V. and its subsidiaries (“BiZZdesign”). Everything we do in connection with our work at BiZZdesign will be, and should be, measured against the highest possible standards of ethical business conduct. We set the bar that high for practical as well as aspirational reasons: our commitment to the highest standards helps us hire great people, build great software, and attract loyal customers. Respect for our users and for each other, is foundational to our success and is something we want to support every day.

We find the principles and responsibilities set forth in the Code important to BiZZdesign and we take them very seriously. We all feel it as our duty to ensure that our actions adhere to the requirements of our Code. Also, consistent with BiZZdesign’s policy to comply with all applicable laws, rules and regulations, it is the personal responsibility of all of us to adhere to the standards and restrictions imposed by those laws, rules and regulations.

1.1 At BiZZdesign we practice
honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;
full, fair, accurate, timely and understandable external and internal communication;
compliance with applicable governmental rules and regulations and internal BiZZdesign rules and regulations;
prompt internal reporting of Code violations to the appropriate persons identified in the Code, and;
accountability for adherence to the Code.
1.2 Different duties
We all have different duties with respect to our Code and we all are responsible for reflecting on this Code with respect to our individual situations and current duties, adhering to this Code while conducting our official duties.

1.3 Violations
Because of the importance of this Code, we understand that violations of it constitute grounds for disciplinary action, including dismissal (see for details: BiZZdesign Disciplinary Policy and Procedure). Violations include, but are not limited to, withholding of information concerning unethical conduct and failure by managers to see that employees and contractors under their management are briefed on the Code.

So please read our Code carefully and follow it in spirit and letter, always bearing in mind that each of us has a personal responsibility to incorporate and to encourage BiZZdesign colleagues to incorporate the principles of the Code into our work. And if you have a question or ever think that one of your BiZZdesign colleagues or the company may be falling short of our commitment, don’t be silent, contact HR. We want – and need – to hear from you. Also, if you are accused of having violated the Code you always have the right to be heard by BiZZdesign.

1.4 No retaliation / Whistleblowing
BiZZdesign prohibits retaliation against any colleagues here at BiZZdesign who report or participate in an investigation of a possible violation of our Code, policies, or the law. If you believe you are being retaliated against, please contact Human Resources. BiZZdesign wants you to feel encouraged to report any occurrences of malpractice, bribery, corruption or other deviation from the Code.

2. CORE VALUES
Our core values are the foundation of our business ethics. Our values determine the way we do business, they define our company culture and set the bar for our personal and professional conduct. We aim to live our values; we act as role models and promote ethical behaviour.

2.1 Customer Obsession
We start with the customer and work from there. We work vigorously to earn and keep customer trust. We obsess over customers, not competitors.

2.2 Ownership
We act on behalf of the whole company, not just your own team. We never say, “that’s not my job.” We don’t sacrifice long term value for short term results.

2.3 Results Focus
We focus on the key outcomes for the business. We deliver them with high quality and on time. We overcome setbacks and avoid distractions.

2.4 Think Big and Fast
We aim high, are bold, and inspire great results. We are not afraid to think differently. To us speed matters. We are decisive. We take calculated risks. We have a mission that matters.

2.5 Performance Excellence
We are meritocratic, invest in and reward high performance. We value performance not status; achievement not age; contribution not position. We raise the performance bar; insist on the highest standards from everyone. At BiZZdesign, every employee matters and has a role to make a difference.

3. CONDUCT
We all act and perform our duties ethically and honestly. Honest conduct refers to conduct that is free from fraud or deception. Ethical conduct refers to conduct that conforms to accepted professional standards of conduct, including the unbiased handling of actual or apparent conflicts of interest between personal and professional relationships. BiZZdesign commits to the following:

3.1 General commitment
3.1.1 Human rights

With due regard to the Universal Declaration of Human Rights, which states that all parties in society, including corporate entities, have a duty to respect and safeguard human rights, and within the framework of the legitimate role of business, BiZZdesign supports and respects human rights and strives to ensure that its activities do not make it an accessory to infringements of human rights.

3.1.2 Free market competition
BiZZdesign supports the principle of free market competition as a basis for conducting its business and observes applicable competition laws and regulations.

3.1.3 Embargo
BiZZdesign undertakes not to deliver to a country that is under an official UN or EU embargo.

3.1.4 Product safety
BiZZdesign aims, at all times, to supply safe products and services.

3.1.5 Privacy
The privacy of personally identifiable information about customers, employees, business partners and other individuals will be protected in line with the current privacy regulations.

3.1.6 Environmental protection
BiZZdesign will do all that is reasonable and practicable to minimize any adverse effects of it’s activities on the environment.

3.2 Our customers
Our customers are the reason for our existence. They value BiZZdesign, not only because we deliver great products and services but also because we uphold the highest possible standards of ethical business conduct in how we treat our customers.

3.2.1 Integrity
Our reputation as a company is our most valuable asset, and it is up to all of us to make sure that we continually earn that trust. All our communication and other interactions with our customers should increase their trust in us. We come to clear and concrete agreements with our customers and honour them.

3.2.2 Dealing with external relations
If we receive an invitation from a business associate, first our manager must be consulted to discuss whether the invitation may be responded to, before accepting or rejecting the invitation. If we accept the invitation, we are aware that in doing so we are representing BiZZdesign and should always therefore abide by our Code.

3.2.3 Privacy, Security, and Freedom of Expression
As we are asking users to trust us with their personal information, preserving that trust requires that each of us respect and protect the privacy and security of that information. Customer privacy should be respected. Our security procedures strictly limit access to and use of users’ personal information and require that each of us take measures to protect user data from unauthorized access.

3.2.4 Complaints
We always reported complaints to the relevant manager in writing, after which they are discussed and adequately solved as soon as possible in consultation with the customer. In addition, the customer must always be made aware of the possibility of filing an official complaint with the Management Team of BiZZdesign (“MT”).

3.3 Our colleagues
We are all committed to creating a safe work environment, where colleagues have the opportunity to reach their fullest potential. We are expected to do our utmost to create a workplace culture that is free of harassment, intimidation, bias, and unlawful discrimination.

Please also read the Employee Handbook, it covers in greater detail how we should conduct ourselves at work.

3.3.1 Dealing with conflicts of interests
We avoid conflicts of interests as they are generally prohibited as a matter of BiZZdesign’s corporate policy, unless they have been approved by BiZZdesign. If we become aware of an actual or potential conflict, or have a question about whether a conflict exists, we bring it to the attention of the MT and BiZZdesign’s Legal and Compliance Director.

Sideline activities; we seek the prior approval of our manager and the HR Department for all sideline activities, whether paid or unpaid, which could in any way lead to conflicts of interest and/or competition with respect to BiZZdesign, its customers, suppliers or other associates.

Attending to private business during working hours; as a rule, our private matters should be dealt with outside working hours. Limited time may however be spent on private matters during working hours, as long as it constitutes no more than a single phone call or a short email. If a private situation arises which demands more of our time, we first consult with our manager.

3.3.2 Personal relationships at work
We report a personal relationship (of an intimate nature) with a colleague immediately to Human Resources. Personal relationships between colleagues may never have a negative influence on our work quality. In addition, it is important to prevent a personal relationship negatively impacting the workplace atmosphere or our colleague relations. When an intimate relationship exists or develops between colleagues of the same department or between a superior and a subordinate, BiZZdesign reserves the right to take the appropriate measures it deems necessary to safeguard a workable situation.

3.3.3 Equal Opportunity Employment
Working at BiZZdesign is based solely upon individual merit and qualifications directly related to professional competence. We strictly prohibit unlawful discrimination or harassment on the basis of race, colour, religion, veteran status, national origin, ancestry, pregnancy status, sex, gender identity or expression, age, marital status, mental or physical disability, medical condition, sexual orientation, or any other characteristics protected by law. We also make all reasonable accommodations to meet our obligations under laws protecting the rights of our employees.

3.3.4 Safe working environment
BiZZdesign prohibits discrimination, violence, harassment and bullying in any form – verbal, physical, or visual. If you believe you’ve been bullied or harassed by anyone at BiZZdesign, or by a BiZZdesign partner or vendor, we strongly encourage you to immediately report the incident to both your manager and Human Resources. If we would learn of any such incident, we immediately report it to Human Resources. HR will thoroughly investigate any complaints and take appropriate action.

3.3.5 Drugs and Alcohol
We are convinced that use of drugs and alcohol is incompatible with the health and safety of our selves and our colleagues and we don’t permit it. Consumption of alcohol is not banned at our offices, but we use good judgment and never drink in a way that leads to impaired performance or inappropriate behaviour, endangers the safety of others, or violates the law. Illegal drugs in our offices or at sponsored events are strictly prohibited. If a manager has reasonable suspicion to believe that an employee’s use of drugs and/or alcohol may adversely affect the employee’s job performance or the safety of the employee or others in the workplace, the manager may request an alcohol and/or drug screening. A reasonable suspicion may be based on objective symptoms such as the employee’s appearance, behaviour, or speech.

3.3.6 Prevention of Involuntary Labour and Human Trafficking
BiZZdesign shall not traffic in persons or use any form of slave, forced, bonded, indentured, or prison labour. All work must be voluntary and BiZZdesign employees shall be free to leave work or terminate their employment with reasonable notice. Employees must not be required to surrender any government-issued identification, passports, or work permits as a condition of employment. BiZZdesign suppliers shall ensure that third-party agencies providing workers are compliant with the provisions of the Code and the laws of the sending and receiving countries, whichever is more stringent in its protection of employees.

3.4 Our suppliers and business partners
BiZZdesign pursues mutually beneficial relationships with its suppliers and business partners. BiZZdesign seeks to do business with suppliers and business partners who are committed to act fairly and with integrity towards their stakeholders and who observe the applicable laws of the countries in which they operate.

3.5 Assets and information
3.5.1 Use and protection of assets
We are responsible for the proper use, protection and conservation of our assets and resources as well as confidential information disclosed to us by our business partners. Our assets and resources, as well as any opportunities arising by virtue of one’s position, are to be used solely to pursue and achieve our business goals and not for personal benefit.

3.5.2 Improper disclosure
BiZZdesign regards information for the purpose of its business as a corporate asset that must be protected against loss, infringement and improper use and disclosure. BiZZdesign is committed not to make use of information disclosed to it by a third party if it is suspected that the discloser thereby violates an obligation of confidentiality, unless the information:

  • is generally available to the public other than as a result of disclosure by BiZZdesign;
  • has been developed independently by BiZZdesign;
  • or becomes available to BiZZdesign either on a non-confidential basis from a third party who is not bound by any confidentiality obligations or by operation of law.

3.6 Business integrity
3.6.1 Bribery.
BiZZdesign has a strict anti-bribery code. At BiZZdesign we insist on honesty, integrity and fairness in all aspects of our business, we view bribes in any form as unacceptable. None of us may accept or give a bribe (this applies to transactions with officials in the public sector, any private company or person anywhere in the world. It also applies to payments made or received directly or through a third party). We also state that commission payments and personal gifts or favors may only be made or accepted in strict accordance with internal regulations, which follow a strict anti-bribery code. Please also read the BiZZdesign Anti-Corruption and Bribery Policy.

3.6.2 Records of transactions
BiZZdesign strives to comply with the highest levels of transparency and accountability. Records of transactions should be maintained in an accurate, complete and timely manner in accordance our accounting principles. No unrecorded funds or assets should be established or maintained.

4. COMMUNICATION
We all shall do our best to ensure that any external and internal communication in the performance of our duties is full, fair, accurate, timely and understandable.

No one at BiZZdesign, apart from those who are employed to do so, will make comments to the media about any aspect of BiZZdesign unless we have been given express permission by the MT or the Legal and Compliance Director to do so.

We will not knowingly:

make, or permit or direct another to make, materially false or misleading communications regarding BiZZdesign;
fail to correct materially false and misleading communications regarding BiZZdesign;
sign, or permit another to sign, a document containing materially false and misleading information; or
materially falsely respond, or fail to respond, to specific external or internal enquiries.
5. MISCELLANEOUS
5.1 Changes
As a result of our commitment to keep our policies and procedures current, the Code may be modified from time to time. Any amendments or a waiver of any provision of the Code must be approved in writing by the MT and promptly disclosed, pursuant to applicable law and regulation. The current version of the Code is available to all employees and contractors via the company intranet and website.

5.2 Internal use
The Code sets forth our fundamental principles and policies with respect to our conduct of BiZZdesign’s affairs. It is not intended to, and does not, create any rights for any associate, customer, supplier, competitor, stockholder, or any other person or entity. The Code is intended solely for the internal use by BiZZdesign and does not in any way constitute an admission, by or on behalf of BiZZdesign, as to any fact, circumstance, or legal conclusion.

5.3 Compliance
Compliance with the Code is monitored by Human Resources in consultation with the Legal and Compliance Director under the supervision of the MT. Compliance processes and procedures are audited by Finance Department.