Introduction
We expect all of our employees and Board members to know and follow the Acowalian Code of Conduct. Failure to do so can result in disciplinary action, including termination of employment. Moreover, while the Code is specifically written for Acowale employees and Board members, we expect Acowale contractors, consultants, contingent workers and others who may be temporarily assigned to perform work or services for Acowale to follow the Code in connection with their work for us.
Failure of a Acowale contractor or consultant or other covered service provider to follow the Code can result in termination of their relationship with Acowale and group companies.
Message From CEO
“The entire team of Acowale is thrilled to welcome you on board. We hope you’ll do some amazing work here!
There’s a lot to learn in these first weeks, but I wanted to take a minute to start with the heart of the matter — our company core values. At Acowale, these values guide everything we do: Innovating for Future, We’re working hard to give small business the power to rediscover digitally, empower them with technology and bring their customers closer together.
Innovation is at the core of everything we do at Acowale. As you become part of the team, I’m excited about how they’ll shape your professional growth and experience, too.
A big congratulations on your new role! On behalf of all Acowalers, I would like to welcome you to the Acowale family. We are delighted and excited about working as a team starting today. Our Code of Conduct is designed to support these values and ensure integrity in all our actions.
Let’s build something cooooooooool!”
CJ
For Employees, Intern & Others
All Acowalers are required to:
- Act in accordance with Acowalian principles and follow the requirements of this Code and Company policies.
- Act lawfully, honestly, ethically and in the best interests of Acowale and our Acowale users at all times.
- Complete required training, use the Code of Conduct and speak up when you have a question or concern.
- Cooperate with Company Investigations.
- Never retaliate against anyone who raises a concern in good faith about a possible violation of the
- Code, Acowale policies or the law, or who cooperates in an investigation.
- Lead by example, recognising that our behaviours and decisions influence others, including by
- Championing the importance of abiding by the Code of Conduct and Company policies.
- Promote a positive work environment in which everyone feels included and empowered to do the
- Right thing and speak up when they have ideas or concerns – this means listening to questions and concerns and escalating when needed.
- Promptly report potential or known violations of the law, this Code or Company policies to Legal.
Managers
Managers at Acowale must be leaders in compliance and ethics. Managers must serve as role models for understanding and explaining the rules and demonstrating integrity at all times. Managers must encourage the reporting of compliance issues and create environments in
which employees know they can and should raise concerns without fear of retaliation. Managers must
- Learn the Code and use it to onboard new employees and explain to teams, on a routine basis, how it applies to their line of business
- Demonstrate through actions that you always choose integrity
- Ensure that employees who report to you, either directly or indirectly, complete all mandatory compliance education courses and other Acowale Compliance and Ethics Program requirements in a timely manner
- Ensure that employees who report to you, either directly or indirectly, understand where and how to report compliance concerns
- Maintain an open-door policy that encourages employees to ask questions, including those related to business conduct and ethics
- Encourage employees to challenge and report questionable conduct
- Create an environment in which employees understand and believe that they may raise and report compliance concerns without fear of retaliation
Managers should consider an employee’s completion of compliance trainings and ethical behavior and/or violations when determining
Questions or Concerns
Speak Up
Code-Related Questions or Concerns
Acowale is committed to being a world-class company trusted by thousands globally. To maintain this trust, we address any problems with our personnel, business, or operations promptly. We provide various resources for reporting misconduct, which Acowale will review or investigate and, if necessary, take corrective action.
As an Acowale employee, you must report any conduct you believe in good faith violates the Code or indicates non-compliance with legal or ethical obligations. Acowale will not tolerate retaliation against any employee who reports a concern in good faith or cooperates with an investigation, even if the allegations are unsubstantiated.
Options for Reporting Concerns or Allegations of Misconduct:
😁Your manager
👨👩👦Acowale People Ops Department
👨 ️A member of the Legal team
🤓Your Regional Compliance and Ethics Officer
🦍The Chief Compliance and Ethics Officer
👻Your employee representative (where applicable)
☎️The Acowale Integrity Helpline
If you wish to remain anonymous or feel uncomfortable reporting a concern through these channels, or if you feel your concern has not been properly addressed, you should email the CEO at crisbinjoseph@acowale.com. Please provide as much detail as possible, including the parties involved, relevant dates, and specific conduct at issue.
Due to confidentiality, the CEO’s office generally does not disclose the specifics of any internal investigation. However, you may contact crisbinjoseph@Acowale.com to learn whether an investigation has been closed.
Real World Q&A
A: No. Acowale competes honestly and fairly. You must avoid all discussions and the exchange of information with competitors involving topics such as pricing, supplier or customer relationships, or market allocation because they are illegal. Disassociate yourself from any such discussions immediately and report the incident to the Acowale Legal Department.
A: No. Acowale’s partners are also frequently our competitors and in no circumstances should Acowale employees be engaged in manipulating the outcome of bid processes by coordinating with competing bidders. Prohibited behavior includes rotating bids or submitting noncompetitive bids to benefit another competitor. Disassociate yourself from any such discussions immediately and report the incident to the Acowale Legal Department.
A: No. This type of market allocation agreement is a clear violation of antitrust and competition laws. Such agreements restrict competition and harm consumers by reducing choices and potentially raising prices. You must disassociate yourself from such discussions immediately and report the incident to the Acowale Legal Department.
A: No. This type of market allocation agreement is a clear violation of antitrust and competition laws. Such agreements restrict competition and harm consumers by reducing choices and potentially raising prices. You must disassociate yourself from such discussions immediately and report the incident to the Acowale Legal Department.
A: No. Limiting production to manipulate market prices is considered anti-competitive behavior and is prohibited under antitrust laws. Such actions harm consumers and the market by artificially inflating prices. You should refuse the request and report the incident to the Acowale Legal Department for further guidance.
A: No. Exclusive dealing arrangements that restrict Acowale from purchasing from other suppliers can be illegal under antitrust laws if they limit competition and harm the market. Such agreements can lead to reduced choices and higher prices for consumers. You must seek approval from the Acowale Legal Department before entering into any such agreements.
A: No. Agreeing not to hire each other’s employees is considered a form of market allocation and is illegal under antitrust and competition laws. You must not engage in or continue this conversation and should report the incident to the Acowale Legal Department immediately. Acowale believes in fair competition, including in the labor market.
A: No. Setting minimum resale prices in collaboration with a competitor is a form of price-fixing and is illegal under antitrust and competition laws. You must not engage in such agreements and should report the proposal to the Acowale Legal Department. Acowale’s policy strictly prohibits any form of price-fixing.
FAQ
A: No. It would not be a proper use of Acowale’s funds to pay for this trip. It is equally improper for a partner to do so using “margin” created through a discount. Depending on the trip, the participants, and whether Acowale retained or obtained business as a result of the trip, the
conduct could be viewed as a bribe punishable both criminally and civilly for the companies and the individuals involved.
A: No. This is a kickback, which is prohibited by Acowale’s Code of Conduct, Anti-Corruption Policy, and local and international law. The Code of Conduct and the Anti-Corruption Policy apply to dealings with both public and private entities.
A: No. Acowale employees are prohibited from offering or giving money or anything of value to government or public sector employees or officials either directly or indirectly through third parties. This prohibition generally includes the use of success fees or utilizing unapproved or ad hoc consultants. You should consult Compliance and Ethics before you hire any third-party sales consultants to obtain, procure, or close government deals.
Real World Q&A
A: It depends on the value and whether or not other mementos have been given to this customer within the year. Acowale policy prohibits giving anything of value to government officials unless applicable law and Acowale policy permit it. Please refer to the “Business Courtesies
You May Extend” sections of both this Code and Acowale’s Anti-Corruption Policy and consult with Compliance and Ethics to determine the proper conduct.conduct could be viewed as a bribe punishable both criminally and civilly for the companies and the individuals involved.
A: It depends on the value and whether or not other things of value have been given to this potential customer within the year. Public university employees are government employees and Acowale policy prohibits giving anything of value to government employees unless
applicable law and Acowale policy permit it. Please refer to the “Business Courtesies You May Extend” sections of both this Code and Acowale’s Ant-Corruption Policy and consult with Compliance and Ethics to determine the proper conduct.
A: Maybe. You may offer the customer hotel accommodations for all three days of the conference if: (a) The customer will attend all three days of the conference; (b) The entire conference is dedicated to the promotion, demonstration, and/or explanation of Acowale products
and services; (c) The business courtesy otherwise conforms with the mandatory requirements set forth in bold type under the heading “Business Courtesies You May Extend” above; and (d) You will need to refer to the Anti-Corruption Policy, and Business Courtesies Guidelines for specific approval processes and requirements.
A: No. An observer might reasonably conclude that a lavish meal for the customer’s entire deal team on the eve of closing was intended to influence the team’s negotiating position, a violation of the Anti- Corruption Policy. If you wish to entertain a customer during a deal negotiation, you need to obtain advance approval.
A: It depends. Acowale policy requires that all suppliers be treated fairly and impartially. Therefore, you should accept nothing from a supplier that could give even the appearance of favoritism. However, you can more readily accept reimbursement for expenses from associations and professional groups because such organizations are generally not comprised of vendors who might be using a speaking invitation as a device to secure favorable treatment. In any case, written approval from your senior vice president and regional Compliance and Ethics Officer is required.
A: Customers should not solicit gifts or entertainment from Acowale. If you have been asked for this and would like to explore
accommodating your customer, please contact the Acowale Compliance and Ethics team to determine what, if anything, you may offer.
A: No. You may receive only gifts that are not of material value. If you receive a gift exceeding the threshold limits that are spelled out in the Anti-Corruption Policy, you will need to obtain approval from the Acowale Compliance and Ethics team.
Yes. As long as the item is not of a material value and is widely available to others under similar circumstances, you may keep it for your personal use. If the item does not meet these criteria and if you have not otherwise received the required approval, politely return it to the donor.
SECTION A- COMPLIANCE AND LEGAL FRAMEWORK
A.1 Antitrust and Competition Laws
- Typically, the countries in which Acowale operates have laws and regulations that prohibit unlawful restraint of trade, usually referred to as antitrust or competition laws. These laws are designed to protect consumers and markets against unfair business practices and to promote and protect healthy competition. Acowale commits to observing applicable antitrust and competition laws around the world.
- Antitrust or competition laws vary from country to country, but generally, these laws prohibit agreements or actions that reduce competition without benefiting consumers. Among those activities generally found to violate antitrust or competition laws are agreements or understandings among competitors that
- Fix or control prices, including a reseller’s prices to its customers
Structure or orchestrate bids to direct a contract to a certain competitor or reseller or anti-competitively influence pricing (bid rigging)
Divide or allocate markets or customers
Limit the production or sale of products or product lines for anti-competitive purposes
Agreements like those listed above are against public policy and Acowale policy. We must never engage in discussions of such matters with representatives of other companies, including Acowale partners. You should promptly report to the Acowale Legal Department any instance in which employees or third parties initiate such discussions. Contracts or other arrangements that involve exclusive dealing, tie-in sales, price discrimination, or other terms of sale may be unlawful under applicable antitrust or competition laws.
You should not enter into such arrangements without the approval of the Acowale Legal Department. Requests for the issuance of exclusivity certificates or employee involvement in drafting public tender bidding documents are generally prohibited and should also be raised to Acowale Legal for further review and approval. Acowale also strives to ensure that our global practices comply with Indian antitrust laws. In addition to local laws, antitrust laws of the India apply to our international business operations and transactions, including imports to and exports from India.
Acowale has developed a substantial partner network through which we extend our reach to industry sectors and customers around the world. Acowale is committed to ensuring that our partners comply with all applicable laws. To support this objective, Acowale conducts enhanced reviews of certain transactions in select geographies and may obtain end-user documentation and information necessary for anti-bribery compliance purposes while fully respecting antitrust laws.
Only authorized non-sales personnel, who are obligated to protect the information from further unauthorized disclosure, may collect and access such documents and information. Antitrust and competition laws are complex; please seek advice from the Acowale Legal Department on any related questions.
A.2 Global Anti-Corruption and Bribery Laws
Acowale believes in doing business honestly and is committed to transparency in our business practices. We have no tolerance for corruption and bribery in connection with our business. You must comply with anti-corruption laws, such as the Indian Anti-Corruption Laws, US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, or the respective law of the country we’re in business at
Acowale is also committed to ensuring that our partners comply with all applicable laws, including anti-bribery and anti-corruption laws. To support this objective, Acowale conducts enhanced reviews of certain transactions in select geographies and may obtain end-user documentation and information necessary for anti-bribery compliance purposes while fully respecting antitrust laws. Only authorized non- sales personnel, who are obligated to protect the information from further unauthorized disclosure, may collect and access such documents and information.
No Improper Payments
We do not offer or pay bribes. You are prohibited from offering, promising, authorizing, directing, paying, making, or receiving any bribes, kickbacks, or payments of money or anything of value (directly or indirectly) to improperly obtain business or any other advantage for Acowale or yourself. The FCPA and other similar international anti-corruption laws outlaw bribery. Penalties for violating these laws are severe and can include prison time and large fines for you personally.
The above prohibition is applicable to
Government and public sector, which include public utilities, higher education, public healthcare entities, and public international organizations and their employees or officials
Political parties or candidates for political office
Business entities partially or wholly owned or controlled by government interests (often referred to as state-owned enterprises) and their employees or officials
Privately-held commercial companies and their employees Acowale employees
Any other third party
Acowale believes in doing business honestly and is committed to transparency in our business practices. We have no tolerance for corruption and bribery in connection with our business. You must comply with anti-corruption laws, such as the Indian Anti-Corruption Laws, US Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, or the respective law of the country we’re in business at
Acowale is also committed to ensuring that our partners comply with all applicable laws, including anti-bribery and anti-corruption laws. To support this objective, Acowale conducts enhanced reviews of certain transactions in select geographies and may obtain end-user documentation and information necessary for anti-bribery compliance purposes while fully respecting antitrust laws. Only authorized non- sales personnel, who are obligated to protect the information from further unauthorized disclosure, may collect and access such documents and information.
No Improper Payments
We do not offer or pay bribes. You are prohibited from offering, promising, authorizing, directing, paying, making, or receiving any bribes, kickbacks, or payments of money or anything of value (directly or indirectly) to improperly obtain business or any other advantage for Acowale or yourself. The FCPA and other similar international anti-corruption laws outlaw bribery. Penalties for violating these laws are severe and can include prison time and large fines for you personally.
The above prohibition is applicable to
- Government and public sector, which include public utilities, higher education, public healthcare entities, and public international organizations and their employees or officials
- Political parties or candidates for political office
- Business entities partially or wholly owned or controlled by government interests (often referred to as state-owned enterprises) and their employees or officials
- Privately-held commercial companies and their employees Acowale employees
- Any other third party
Gifts, Meals, and Entertainment Acowale can pay for bona fide business expenses and certain gifts for third parties, but only if done without corrupt intent and according to Acowale’s Anti-Corruption Policy. Acowale’s Anti-Corruption Policy provides specific guidelines to ensure that you comply with applicable anti-corruption laws, including the FCPA and UK Bribery Act.
Government entities and state-owned enterprises generally are governed by strict laws and regulations concerning the ability of their employees to accept entertainment, meals, gifts, gratuities, and other things of value from companies such as Acowale. In dealing with employees of these entities, it is Acowale‘s general policy that nothing of value will be given. Limited exceptions that may apply are covered in the Anti-Corruption Policy and the Supplemental Policy on Government Contracting and Dealing with Government Officials and Employees. Refer to the “Business Courtesies You May Extend” section of this Code for information regarding nongovernment entities. If you have any questions, contact a member of the Compliance and Ethics team.
Business Courtesies You May Extend
Furnishing meals, refreshments, entertainment, and event access in conjunction with business discussions with nongovernment personnel may be appropriate as long as the offering of such courtesies does not violate any policies of the recipient‘s organization, any contractual agreement with a customer, Acowale’s Global Travel and Expense Policy, or the Anti-Corruption Policy. You are responsible for familiarizing yourself with any such standards, agreements, and policies and for complying with them
Acowale prohibits giving anything of value (including charitable donations or sponsorship of events), directly or indirectly, to any privateindividual, firm, or entity as a means of improperly inducing business.
Employees who seek or approve expenditures for meals, refreshments, or entertainment must use discretion and care to ensure that these events are reasonable and modest in cost, not lavish or extravagant, justified by a legitimate business purpose, and not offered improperly to influence the recipients’ business judgment.
Acowale‘s standards and the applicable laws for dealing with government employees and employees of state-owned enterprises are more stringent than standards for private sector company employees. In dealing with government employees and officials, it is our general policy
that nothing of value will be given to such individuals. Limited exceptions that may apply are covered in the Anti-Corruption Policy and the Supplemental Policy on Government Contracting and Dealing with Government Employees and Officials. You are responsible for being
familiar with the rules and regulations of the government entities with which you interact. Contact Compliance and Ethics if you have any questions about your activities and interactions with the government.
In any case, business courtesies must be small enough not to appear to influence the judgment of the recipient, secure unfair preferential treatment, or gain an improper advantage. A final test of appropriate business courtesies, even if allowed under the law, is whether public
disclosure would be embarrassing to Acowale or the recipient.
We may also use the information collected across different services and devices for these purposes. For example, if you watch videos about guitar playing on one service, you might see ads for guitar lessons on a different site that uses our ad products. Depending on your settings, activity on other sites and apps may be linked with your personal information to improve services and ads.
If others have your email address or other identifiable information, we may show them your publicly visible account details, like your name or photo, to help identify communications from you.
Before using your information for any purpose not covered in this Privacy Policy, we will ask for your consent.
Business Courtesies You May Receive
You may accept unsolicited gifts or other business courtesies from actual or potential customers, suppliers, or other business partners provided they are reasonable and modest in nature and amount, are justified by a clear and legitimate business purpose, or are not given to influence a business decision.
Furthermore, accepting these courtesies should not impose a sense of obligation or give rise to the expectation that another party will receive anything in return. It is never appropriate to solicit these courtesies, either directly or indirectly. Before accepting a gift or other business courtesy, you must also confirm that doing so is permitted under local laws. Many countries impose limitations on gifts that may be exchanged, even among employees of private sector companies. Contact Compliance and Ethics for information about laws in
specific countries. Acowale recognizes that in some parts of the world gift giving is a common,
accepted practice and that refusing a gift could reflect poorly on Acowale. Even in those instances, however, you must comply with this Code, Acowale’s Anti-Corruption Policy and all relevant local laws. Please refer to Acowale’s Anti-Corruption Policy for additional information, including circumstances under which written approval is required.
You may accept occasional meals, refreshments, or other entertainment appropriate to the circumstances in connection with normal business discussions. Again, it is inappropriate to accept such favors if they are offered solely to influence your business decision. If an individual or firm doing or seeking business with Acowale offers you entertainment that is more than modest, routine, or outside of the guidelines provided in Acowale’s Anti- Corruption Policy and Business Courtesies Guidelines, you must obtain written approval. Refer to the Anti-Corruption Policy, and Business Courtesies Guidelines to understand the processes and approvals required prior to accepting such entertainment. We are all personally responsible for ensuring that acceptance of
any business courtesy, gift, or entertainment is proper and does not reasonably appear to be an attempt to secure favorable treatment.
A.3 Trade Compliance Laws and Regulations
Acowale is committed to complying with all applicable global export, import, and economic sanctions, laws, and regulations. Compliance with global trade laws and regulations protects Acowale’s ability to conduct international business. Failure to do so can result in disciplinary action for the company, serious supply chain disruptions, loss of sale and service opportunities, monetary penalties, fines and imprisonment for individual employees and their management chain, and the potential revocation of our trade privileges. You are responsible for understanding how trade compliance laws and regulations apply to your job, and strict adherence to these laws is required. Trade compliance laws and regulations govern all exports and imports of commodities and technical data into and from the respective country the business is in, which include:- Physical items (hardware, laptops, software media, and the like) Electronic or physical distribution of software and source code
Written, electronic, or oral disclosure of technical data to a visitor outside of the United States or H1-B Visa worker whether it occurs within the US or abroad
Any oral or written disclosure of technical data to a visitor from outside of the India must comply with the same export control restrictions that are applicable to the physical export of such data. You may not ship Acowale commodities, including but not limited to hardware, software, documentation, source code, technical data, or technology, without processing the transaction through authorised Acowale order entry, distribution, export request, and support processes and/or through authorised Acowale subsidiary channels. As part of Acowale’s Global Trade Compliance program, Acowale maintains an International Traffic in Arms Regulation (ITAR) Compliance Policy to ensure all Acowale transactions involving the export or re-export of US-origin defence articles, defence services, and related technical data comply with the ITAR policy. The policy also establishes standards and procedures to ensure no transfer of covered defence articles, defence services, and related technical data takes place beyond what is authorised by the ITAR or by the terms of any export license or other approval granted by the US Department of State, Directorate of Defence Trade Controls.
Questions concerning trade compliance matters or any potential violation of these laws or regulations should be directed to Acowale Global Trade Compliance. Additional information may be found on the Global Trade Compliance website.
A: Yes. Any oral or written disclosure of technical data to a foreign visitor must comply with the same export control restrictions that apply to the physical export of such data.
A: No. An export can take place at any location when technical data or software is made available to anyone who is a foreign national. You must obtain proper export authorization before sharing technical data or software in any manner with a foreign national.
A: Yes. Even though the presentation is happening within the US, sharing technical data with a foreign national is considered an export and must comply with export control restrictions. You need to obtain the appropriate export authorization before including such technical data in the presentation. Ensure compliance by consulting with Acowale Global Trade Compliance.
A: No. You must process the transaction through authorized Acowale channels to ensure compliance with export regulations. Sending proprietary software to another country without proper authorization could violate trade compliance laws. Always follow Acowale’s procedures for distributing software internationally and consult Global Trade Compliance for guidance.
A: Yes. Discussing sensitive technical details with colleagues in another country, even via virtual meetings, is subject to export control restrictions. Ensure you have the necessary export authorization before sharing any technical data. Always verify compliance with Acowale’s trade compliance policies before such discussions.
A: Yes. Providing access to technical documentation to a foreign national intern, even if they are working in the UK, constitutes an export. You must obtain the appropriate export authorization to ensure compliance with trade laws before granting access to the technical documentation. Consult with Acowale Global Trade Compliance to navigate this process correctly.
A: No. Providing technical support to a customer in an embargoed country is likely prohibited under economic sanctions and trade compliance laws. You must refrain from engaging in any transaction or support with embargoed countries and should report the request to Acowale Global Trade Compliance immediately. Ensure all customer interactions comply with applicable trade sanctions.
A.4 No Economic Boycotts
Acowale does not participate in any economic boycott not sanctioned by the Indian government, or the respective government of the country we the sub-organisation is in. Acowale and our employees are prohibited from discriminating against or refusing to do business with a country, its nationals, or companies that are the object of an unsanctioned boycott.
Additionally, Acowale and our employees may not furnish information concerning Acowale’s or any other person’s business relationships with a boycotted country or blacklisted company. If requested to supply any information, take any action, or refrain from taking any action to further or support a boycott of a country, you must immediately contact the Acowale Legal Department.
For further information on identifying and handling boycott requests, please refer to Acowale’s Foreign Economic Boycott Policy, which is available on the Compliance and Ethics website. This policy is intended to ensure that we comply with foreign economic boycott laws of the nation. Address questions or requests for information regarding Foreign Economic Boycott Policy or anti-boycott laws to the Acowale
Legal Department.
A: No. Accepting this order may subject Acowale to criminal and tax sanctions. Acowale complies with anti-boycott provisions of Indian law. The division receiving this request should immediately seek Acowale Legal and Corporate Tax Department advice on how to proceed.
A: No. Acowale cannot agree to such a certification because it would violate the anti-boycott provisions of Indian law and Acowale’s policies. Any request to support an unsanctioned boycott should be immediately reported to the Acowale Legal Department. Engaging in or supporting such boycotts can lead to severe legal and financial consequences for the company. Always seek guidance from the Legal Department when faced with such requests.
A.5 Securities and Insider Trading
Acowale expects you to comply with applicable insider trading and securities laws. Acowale maintains an insider trading policy, which is applicable to all employees worldwide, non-employee directors, and the immediate family members of employees and directors. The Insider Trading Policy, which is available on the Acowale Legal Department website, sets forth your obligations under the law and as required by Acowale, regarding trading in the securities of Acowale and other companies. You are expected to understand the policy and comply with it.
If you trade in Acowale securities or the securities of any other company trading on a United States stock exchange, you are subject to United States securities laws, as well as any other securities or insider trading laws that may apply to you locally, including Acowale’s Insider Trading Policy.
Similar rule apply for Indian stock exchange and other countries where we do business in. Failure to comply with insider trading and securities laws may result in substantial civil and criminal
penalties. Under Acowale’s Insider Trading Policy, if you possess material, nonpublic information (also referred to as “inside information”) gained through your work at Acowale, you may not trade in Acowale securities or the securities of another company to which the information pertains.
You also may not pass on to others (for example, a “tip”) material, nonpublic information. These restrictions also apply to your immediate family members.
Material information is any information that a reasonable investor would consider important in a decision to buy, hold, or sell securities. It includes any information that could reasonably be expected to cause a change in the price of securities of Acowale or the securities of another company to which the information relates.
There are other ways to control the information Acowale collects whether or not you’re signed in to an Acowale Account, including:
Browser settings: For example, you can configure your browser to indicate when Acowale has set a cookie in your browser. You can also configure your browser to block all cookies from a specific domain or all domains. But remember that our services rely on cookies to function properly, for things like remembering your language preferences.
Device-level settings: Your device may have controls that determine what information we collect. For example, you can modify location settings on your Android device.
Examples of Material information
- Financial performance and operating metrics (especially quarterly and year-end earnings) or significant changes in financial performance, operating metrics, or liquidity (including forecasts)
- Potential or ongoing major mergers, acquisitions, joint ventures, divestitures, or other strategic transactions
- Award or cancellation of a major contract or strategic partnership Key management changes
- Changes in dividend or stock repurchase programs, offerings of securities, or credit transactions
- Changes in auditors, knowledge of a qualification in an auditor’s opinion or report, or any change in the ability to rely on prior auditor reports
- Actual or threatened significant litigation or investigations Gain or loss of a substantial customer or supplier.
Nonpublic information (or inside information) is material information that is not available to the general public. It is typically made public through the issuance of a press release or a filing with the relevant government body. Generally, you must refrain from trading from the time you become aware of inside information through the first full trading day after Acowale has made the information public.
Securities include common stock, bonds, employee stock options, futures, derivatives, and other financial instruments. See Acowale’s Insider Trading Policy for more information regarding how the policy applies to stock options, restricted stock units, and the Employee Stock Purchase Plan.
Acowale has established quarterly “no trading” periods for certain groups of Acowale employees and non-employee directors. In addition, individuals with knowledge of proposed strategic transactions must obtain preclearance prior to trading Acowale securities. All employees and non-employee directors are prohibited from engaging in speculative transactions in Acowale securities. Please refer to the Insider Trading Policy for details on these restrictions. If you have any questions about compliance with insider trading laws or Acowale’s Insider Trading Policy, you should consult with the Acowale Legal Department.
A: No. Sharing nonpublic, material information with others, known as “tipping,” is illegal and against Acowale’s policy. You must keep this information confidential and not share it with anyone, including friends and family. Violation of insider trading laws can result in severe penalties. Always maintain confidentiality and consult Acowale’s Insider Trading Policy for guidance.
A: No. Selling shares based on nonpublic, material information you possess because of your position at Acowale is considered insider trading and is illegal. You must refrain from trading in the supplier’s securities until the information is publicly disclosed and the market has had time to absorb it. Adhere to Acowale’s Insider Trading Policy and seek advice from the Legal Department if you have any doubts.
A: No. You cannot share nonpublic, material information with your spouse or any other person, even if it is for their benefit. This constitutes insider trading and is illegal. Ensure that your spouse makes investment decisions without relying on inside information you have because of your employment at Acowale. Follow the guidelines in Acowale’s Insider Trading Policy and maintain the confidentiality of material information.
A: No. Buying stock options based on nonpublic, material information about the upcoming product launch is considered insider trading and is prohibited. You must wait until the information has been made public and sufficient time has passed for the market to react. Always adhere to the restrictions and guidelines outlined in Acowale’s Insider Trading Policy.
A: No. Acting on nonpublic, material information about internal cost-saving initiatives to make investment decisions is insider trading and illegal. You must wait until the information is disclosed to the public and the market has had time to absorb it. Follow the protocols in Acowale’s Insider Trading Policy to ensure compliance with insider trading laws.
INTERACTIONS & ENGAGEMENT
B.1 Engaging Government and Public Sector Employees
Government Contracting
Acowale strictly observes the laws, rules, and regulations that govern the acquisition of goods and services and the performance of government contracts by governmental entities. Activities that may be appropriate when dealing with non government customers may be improper and even illegal when dealing with government. The penalties for failing to follow government procurement laws are severe and include substantial civil and criminal fines, imprisonment, and debarment of Acowale from doing business with the government. Acowale employees who deal with any government agency, including international organizations, are responsible for learning and complying with all rules that apply to government contracting and interactions with government officials and employees, including the rules in Acowale’s Supplemental Policy on Government Contracting and Dealing with Government Officials and Employees.
If you deal with government or public sector employees and officials, you are required to complete the Dealing with Government: Government Contracts and Political Compliance training course. Both the supplemental policy and the training course are located on the Compliance and Ethics website.
Government Procurement Integrity
Our commitment to comply with government procurement rules extends to how we acquire relevant information. You must not attempt to obtain from any source
Procurement-sensitive government information
Confidential internal government information, such as pre-award, source selection information
Proprietary information of a competitor including, for example, bid or proposal information, during the course of a procurement or in any other circumstances where there is reason to believe the release of such information is unauthorized
If such information is inadvertently communicated to you by another vendor, a consultant, or a government employee, you should promptly contact the Acowale Legal Department.
Organizational Conflict of Interest (OCI) You must ensure that when performing government contracts there is no actual or potential organizational conflict of interest (OCI) that would provide Acowale unequal access to nonpublic information, provide an unfair advantage in a competitive procurement, or impair your objectivity in providing assistance or advice to the government or in performing contract work for the government. All actual or potential OCIs must be disclosed by consulting the Acowale Legal Department. Post-Government Employment Restrictions
Various laws impose requirements and restrictions on government employees related to post-government employment in the private sector. These laws restrict the former government employee’s activities after he or she leaves the government and accepts employment with a private company.
Before engaging in any discussions related to possible employment or entering into a business opportunity with a current or former government employee, you must obtain the appropriate approvals by consulting the Acowale Legal Department. Lobbying of Government Officials Our interactions with the government are generally governed by lobbying laws and regulations. Lobbying is any activity that attempts to influence laws, regulations, policies, and rules, but in certain jurisdictions can also cover sales and business development activity. These laws can apply to elected officials, as well as appointed officials and government employees. The company may have an obligation to register and/or report the company’s lobbying activities under applicable law, including activities by employees and outside consultants or advisors on government relations. You are responsible for knowing when your activity or the activity of any third party you engage with on government matters for Acowale may be considered lobbying, and should consult the Acowale Legal Department for guidance.
For more information, please see the Supplemental Policy on Government Contracting and Dealing with Government Officials and Employees, and the Elected Officials, Legislation and Public Policy Approval Process, which are both located on the Compliance and Ethics website.
Political Contributions
Acowale takes seriously our obligation to comply with the laws relating to political contributions. These laws vary greatly among jurisdictions and countries. All political contributions made by Acowale, including attendance, participation, and/or sponsorship of political candidates, parties, campaigns, and related events must be approved in advance by Acowale’s Government Affairs and the Acowale Legal Department. In addition, in many instances corporations are prohibited from giving to political campaigns. Some campaign laws interpret use of corporate resources (such as equipment, email, stationery, or personnel) as corporate donations.
You should obtain approval from the Acowale Legal Department before using any company resources for political campaigns or fundraising. For more information on Acowale’s political activities policy in North America, see the Supplemental Policy on Government Contracting and Dealing with Government Officials and Employees, located on the Compliance and Ethics website.
Personal Political Activity
Acowale encourages its employees to participate personally in civic affairs and the political process. To do so, you must Make all personal political contributions with your own money Conduct any personal political activities on your own personal time Conduct all personal political activities in accordance with applicable laws Comply with Acowale policies
Guidelines regarding personal political activity:
Your personal contributions to a candidate for elective office or a political party must not be—or appear to be—made with, reimbursed from, or facilitated by the company’s funds or assets. You will not be paid by Acowale for any time spent running for public office, serving as an elected official, campaigning for
B.1 FAQ
A:No. Regulations vary depending on the government agency. Because these regulations vary so greatly, seek advice from the Acowale Legal Department if you are uncertain about the applicable regulations.
A: Yes. Because the contract requires that we perform both tests, no change in testing requirements or quality controls should be made without first informing and obtaining the approval of the appropriate level of management, as well as the approval of a contracting officer. To knowingly deliver a product to the government that does not meet the contract specifications, without specific prior approval from the –customer for any change in specification, could be considered fraud and a violation of law.
A: No. It is not permissible for Acowale to obtain any information that another party considers proprietary or confidential regarding competitive procurement, including information about pricing. However, Acowale may consider information about a competitor’s prices that we obtained from publicly available sources.
A: No. You should not perform this type of work unless you have obtained approval from the Acowale Legal Department and other appropriate internal approvals.
A: It depends. Sales activity should be kept separate from any political activity. In addition, donations—including attendance at political undraisers—are never to be expensed. Rather, for an activity that has been approved by the Acowale Legal Department, you must submit a check request.
A: It depends. States law imposes several restrictions on Acowale’s ability to hire respective country government employees. State and local laws may impose similar restrictions. Before even speaking with any government employee about employment opportunities at Acowale, consult with the Acowale Legal Department to ensure compliance with applicable laws.
A: No. You may receive only gifts that are not of material value. If you receive a gift exceeding the threshold limits that are spelled out in the Anti-Corruption Policy, you will need to obtain approval from the Acowale Compliance and Ethics team.
A: Yes. However, the day off may not be charged to Acowale. You’ll have to use vacation or unpaid time off to attend this event.
A: No. Even if your manager is not pressuring you, the request is inappropriate. An Acowale sponsored event is okay, but managers should never solicit donations for personal charitable causes or personal sponsorships from employees that are in their reporting chain. If you are
not comfortable speaking to your manager about this, you should speak with his or her manager, Acowale People Ops, or your regional Acowale Compliance and Ethics officer. You may also report your concern to the Acowale Legal Department.
B.2 Gathering Information on Competitors or Third Parties
You may not seek to obtain proprietary information about Acowale competitors, and you may not seek to obtain any information about Acowale competitors or other third parties illegally or in a way that involves a lack of integrity or a breach of any confidentiality or employment agreement.
You must always disclose your employment with Acowale and never misrepresent your identity when attempting to collect competitive information. In the event that you inadvertently obtain a third party’s confidential or proprietary information without authorization, you must not disseminate the information within Acowale and you must immediately contact Acowale Legal at legal@Acowale.com.
Unless Acowale Legal instructs otherwise, you must promptly destroy all copies of such information in your possession. We may make appropriate observations about competitors’ products and activities when basing them on publicly available information, such as public presentations and marketing documents, journal and magazine articles, advertisements, and other published information.
A: No. Instead, do not send or forward the information to any other
employees, and immediately contact Acowale Legal at legal@Acowale. com, Unless Acowale Legal instructs otherwise, you must promptly destroy all copies of such information in your possession. Proper intelligence gathering is a legitimate marketing strategy, but Acowale will never approve use of apparent proprietary information that it receives from unknown sources.
A: No. It’s tempting to use information about a competitor that you obtained during your prior employment to Acowale’s advantage but, in this case, it is not permitted. We expect you to protect confidential knowledge obtained from your employment with former employers.
B.3 Charitable Donations
Acowale is committed to using our resources to advance education, protect the environment, and enrich community life. Each year Acowale Giving donates millions of dollars to nonprofit organsations around the world. Through grants and sponsorships, as well as Acowale Volunteers’ support, we work to improve the quality of life in the communities where we do business. Additionally, our education programs—Acowale Academy and Acowale Education Foundation—prepare students for success in life and work.
Acowale does not make charitable donations to close deals or seek favour from decision makers. It is possible, however, for business units to support nonprofit organisations, as long as they approach it as part of an ongoing, positive business relationship and not to close business or otherwise secure favourable treatment on decisions affecting Acowale. All donations must be made in compliance with the Policy for Cash Donations. Raise questions about any potential conflict of interest
issues that may arise from charitable donations to Compliance and Ethics.
A: No. You must make clear to the nonprofit organization that your board service is personal, that you are representing yourself only, and that it is unlikely that you will be able to secure a donation from Acowale. If the nonprofit organization has historically received donations from Acowale or has any formal relationship with Acowale, approval from Acowale Compliance and Ethics is required before you may serve on the board. Also, see the “Conflicts of Interest” section of this Code.
A: No, only Acowale CSR Division can organize events to support nonprofit organizations on behalf of Acowale. Acowale employees can support nonprofit organizations through the Acowale Volunteers program.
A: No. Acowale sponsors special events only for nonprofit organizations with which we have strong existing relationships. Additionally, we sometimes provide sponsorships for events in which our senior executives are engaged (for example, serving on the organizing committee being recognized).
B.4 Corporate Social Responsibility
Acowale recognizes the important responsibility we have to respect universally recognized human rights throughout our operations and in the products and services we offer. As a global company, we address important human rights issues every day, including online privacy, human trafficking, conflict minerals and labor rights, freedom of expression, and data privacy.
We support and respect the protection of human rights and ensure that our business partners and suppliers do the same. We avoid involvement in human rights violations that could arise through our businesses actions. We require that child labor, prison or forced labor,
and physical punishment are never permitted in any operation of Acowale. We similarly require that our business partners or suppliers not
engage in such practices. We respect your right to organize in labor unions and collectively bargain in accordance with local laws and
established practices.
Acowale is committed to using our technology and resources to advance education
in innovative ways, promote diversity, enrich the life of communities, and protect the environment. In balancing the needs of our business with the needs of the environment, Acowale‘s policy is to maintain our facilities and run our business operations in a manner that minimizes any adverse impact on the environment. As an example, we seek to reduce, reuse, and recycle as many resources as we can.
We must comply with all applicable environmental laws and regulations. For additional information regarding Acowale’s position on environmental management, please refer to Acowale’s Environmental Policy.
SUMMARY
This section outlines guidelines for ethical conduct when engaging with government and public sector employees, emphasizing transparency and adherence to legal standards. It also covers the company’s commitment to corporate social responsibility, including charitable donations and community support. Additionally, it provides protocols for ethically gathering information on competitors or third parties, ensuring integrity and respect for confidentiality.
Section C- Information & intellectual Property
C.1 Intellectulal Property
Besides our people, Acowale‘s most important assets are its intellectual property rights, which include
1. Copyright
2. Patents
3. Trademarks
4. Trade secrets
We are each responsible for protecting Acowale‘s intellectual property rights by complying with Acowale‘s policies and procedures for their protection. Maintaining the confidentiality of Acowale‘s trade secrets and proprietary information is an important element of such protection. This obligation continues even after you leave Acowale. We also respect the intellectual property of others. Acowale will provide any software necessary for you to perform your functions adequately under appropriate licensing agreements with vendors. It is against Acowale policy to use, copy, display, or distribute third-party copyrighted software, documentation, or other materials without permission or approval from Acowale’s Legal Department. For example, you may not post another entity’s copyrighted content to any internal or external website or other electronic forum without first obtaining the necessary
approvals. You are not permitted to use or copy software or documentation except to the extent that applicable license agreements allow.
Consult the Acowale Legal Department website for relevant policies and guidelines, some of which are
1.Information Protection Policy
2. Employee Proprietary Information Agreement Copyright Compliance Policy
3. Policy on Patent Communication and Searches
A: No. You may not allow third parties to access Acowale computer systems without appropriate authorization. Moreover, you should safeguard your passwords to Acowale systems, change them regularly, and not disclose them to any other person. Follow Acowale‘s Network Access Policy to obtain authorization for this consultant, and be sure that you have completed all necessary paperwork and obtained all necessary approvals for retention of an outside consultant.
A: No. You may not auto-forward your Acowale email to a personal email account outside the Acowale domain without approval from Global Information Security. Auto-forwarding your email would allow Acowale confidential information to pass outside the Acowale network and be accessible by third parties.
C.2 Protecting Confidential Information
You are required to protect all confidential information that you have access to in connection with your Acowale employment. The Acowale Information Protection Policy, located on the Acowale Legal Department website, provides the requirements for treatment of confidential information. It also provides a description of the different categories of confidential information, which are
Public, Confidential, Acowale Internal Confidential, Acowale Restricted Confidential, Acowale Highly Restricted
The Information Protection Policy provides guidance on the proper handling of each information category, including restrictions on use,
disclosure, storage, transmission, and deletion. All information related to Acowale‘s business that is not intended for public disclosure or any
information identified as confidential by Acowale’s customers, partners, prospective customers, and vendors should be considered
confidential.
Confidential information includes
1. Information customers provide to Acowale for the performance of cloud, technical support, consulting, and other services
2. Source code
3. Inventions or developments (regardless of the stage of development) Marketing and sales plans
4. Competitive analyses
5. Product development plans
6.Pricing
7. Potential contracts, mergers, or acquisitions
8.Financial plans or forecasts
9.Acowale employee and customer personal information
Security Policies and Practices
Acowale has required security policies designed to protect our confidential information, as well as Acowale’s systems and resources. These
are available on the Corporate Security website. Individual lines of business and organizations may have additional security practices in place to govern their operations. You are required to report any unauthorized access of an Acowale facility to Acowale’s Global Corporate Security and report any unauthorized access to or use of Acowale’s networks, systems, or confidential information to Acowale’s Global Information Security as well as Global Corporate Security.
Your obligation to protect Acowale confidential information and personal information continues after you leave Acowale. Similarly, we expect you to abide by your obligations to protect the confidential information of your former employers. No confidential information obtained during or as a result of your work with former employers should be brought on Acowale premises or used in any form in your work at Acowale.
Privacy Policies
Acowale’s external privacy policies located on legal site of Acowale govern the collection, use, transfer, and security of personal, customer, and prospect information, and information Acowale may access or be provided in connection with the performance of services. Acowale’s internal privacy policy governs Acowale’s treatment of Acowale employee and contractor personal information. You are required to abide by these policies when collecting, processing or handling this information.
C.3 Social Media & Communications
As a company, we encourage communication among our employees, customers, partners, and others—and web logs (blogs), social networks, discussion forums, wikis, video, and other social media can be a great way to stimulate conversation and discussion. The Acowale Social Media Participation Policy, located on the Legal Department website, sets forth the requirements for employee participation in
social media. It is particularly important to remember the following:
The Acowale Code of Ethics and Business Conduct and Acowale‘s corporate and legal policies apply to your online conduct (blogging, liking, tweeting, commenting, and all forms of online activity) just as much as they apply to your offline behavior.
Do not use social media for confidential, substantive, or direct Acowale business communications with customers.
Do not discuss merger and acquisition activity, product roadmaps and future product offerings, or certain communications during Closed
Communications Periods (“Quiet Periods”), public policy or legislation, and legal commentary, in accordance with the Social Media Participation Policy.
Respect others’ intellectual property rights, including copyrights and privacy/publicity rights, particularly when using photographs or video content.
Unless you are an official Acowale spokesperson who has been trained by Acowale Public Relations and/or Acowale Analyst Relations, you are not authorized to speak on behalf of Acowale—or to represent that you do. Guidelines for external communications are provided in Acowale’s Policy Regarding Communications with the Press and Analysts.
When using your personal social media account(s) to discuss Acowale- related topics, identify yourself as an Acowale employee, and make it clear that your opinions are your own and do not necessarily reflect the views of Acowale.
Disclose any material connections you have with Acowale or with the provider of any product or service you are reviewing.
Do not disclose confidential information through any social media platform.
Do not make abusive, objectionable, or inflammatory posts.
You should take care to ensure that all business records and communications, including electronic communications, are clear and accurate. Electronic communications include, but are not limited to: email, messaging (Workchat/WhatsApp/Slack), video conferencing, chat rooms, Wikis, phone, and fax (as described in our Electronic Communication Guidelines). The Company may have obligations to preserve electronic communications and other information in connection with existing or reasonably foreseeable Legal Matters, such as litigation, investigation, subpoenas, or enforcement proceedings. Upon direction from the Legal Department (known as a Legal Hold Notice), you must not alter, delete, or destroy electronic communications or information subject to a Legal Hold Notice. Please refer to our Legal Hold Policy. Please remember that your business communications may be shared or become public through these legal events or publication in the media. Potential risks from inaccurate or misleading statements include, but are not limited to, claims of false advertising, misrepresentation, breach of contract, securities fraud, unfair disclosure, and antitrust violations. You must consult with the Communications Department and your department director before making formal statements or providing information about Acowale, our products, or our business and fellow Acowale Personnel to journalists, bloggers, and industry analysts through any public forum (such as a tradeshow or conference or your Acowale profile). Please refer to our External Engagements Policy on the wiki.
You also cannot make any statements about the privacy or security of Acowale data without approval from a Privacy Review. You may not give an endorsement or other statement on behalf of Acowale or personal endorsement that identifies your affiliation with Acowale, except when approved by the Communications Department or Legal Department. In addition, you may not discuss Acowale’s business, including financial condition, business or financial performance, products, or business prospects, with financial analysts or actual or potential investors without the prior approval of the Investor Relations Department. All requests for a representative of Acowale to participate in a financial conference (including speaking on a panel or attending a dinner or any event that targets the financial community) must be referred to Investor Relations for review and managing. If any such analysts or investors contact you, please refer such inquiries to support@Acowale.com. Social Media & CommunicationsThe term “conflict of interest” describes any circumstance that could cast doubt on your ability to act in Acowale
C.4 Public Disclosure
As a public company, Acowale must disclose accurate and complete information regarding the company and the results of our operations. Our policy is to report Acowale’s financial results and other significant developments fully, fairly, accurately, timely, and understandably. Acowale will not tolerate unauthorised “leaks” or disclosures of corporate information to third parties, including the press or financial community.
All communications with the press and financial community must be authorised by Acowale‘s Public Relations or Investor Relations organisations. Those organisations alone, at the direction of executive management, are responsible for determining the appropriate spokespersons for communicating with the press and analysts. Direct any inquiries from the press or financial community immediately to Acowale Public Relations or Acowale Investor Relations. For further information, see Acowale‘s Policy Regarding Communications with the Press and Analysts on the Acowale Legal Department website.
A: No. You should not speak with this analyst. Only spokespersons authorized by Acowale Investor Relations, at the direction of executive management, are allowed to speak with the financial community about Acowale or our financial prospects. Acowale commits to providing full, fair, understandable, timely, and accurate public information about our financial prospects, and we do so openly, rather than selectively. Refer any such inquiries to Acowale Investor Relations. Other than that, make no comment.
A: No, at least not without first obtaining permission from Acowale Public Relations. Acowale Public Relations must approve in advance all communications with the press. Acowale Public Relations may conclude that you are the best spokesperson for the company on this issue, but it—not you—must make that decision.
C.5 Record Retention
The Acowale Records Retention Policy (“Retention Policy”) sets forth guidelines governing the retention and disposal of Acowale business records. The Retention Policy requires that you maintain records in accordance with the Corporate Records Retention Schedule (“Retention Schedule”). The Retention Schedule identifies the company records that we must retain and the retention period for each record type. You must not retain records that are not identified on the Retention Schedule, unless the records have a current business purpose or the Acowale Legal Department has instructed that the records be retained or preserved. You are responsible for reading and abiding by the Retention Policy and Retention Schedule. Please be advised that if you
receive a Legal Hold Notice, the processes noted in the Retention Policy should be suspended regarding certain or all Acowale documents that you have in your possession. If you have any questions regarding a Legal Hold, refer to our Legal FAQs or contact a member of the Acowale Legal Department.
The Retention Policy and the Retention Schedule cover both electronic (soft copy) and hard copy materials. They apply to all record types regardless of the medium in which they exist, including
1. Paper
2. Email
3. Video
4. Hard Drive
5. Compact disc or other electronic storage device
You should give special care to ensure that records containing confidential information are retained and disposed of in accordance with both
the Retention Policy and the Information Protection Policy. If it appears that local circumstances require a record to be retained for a longer period, please contact the Acowale Legal Department or email legal@Acowale.com. If you have questions about the Retention Policy or the Retention Schedule, contact the Legal Department.
A: No. Acowale’s Records Retention Policy requires you to preserve all
records that may be relevant to a matter in which Acowale reasonably
anticipates litigation. The manager should immediately escalate this
demand letter to the litigation and legal team.
A: No. Records such as original invoices represent expenses, which will
eventually have to be reported, reviewed, and audited in connection with
the company’s periodic reporting to the Securities and Exchange
Commission and Acowale‘s investors. Please see the Retention Schedule
for guidance on how long to keep the invoices.
Summary
The Acowale Rule Book prioritizes safeguarding information and intellectual property. It emphasizes protecting confidential information, responsible social media and communications use, and securing intellectual property. Guidelines for public disclosure ensure proper information release, while record retention policies maintain essential document preservation.
Conducts & Ethics
D.1 Conflict of Interest
The term “conflict of interest” describes any circumstance that could cast doubt on your ability to act in Acowale’s best interests and to exercise sound business judgment unclouded by personal interests or divided loyalties. The term also refers to situations in which it appears that your business judgment has been compromised. The Conflict of Interest Policy explains how to avoid financial, business, or other relationships that create conflict of interest issues and how to deal with those situations. You must read and understand this policy.
Conflict of interest situations may arise in many ways. Some actions that can create a conflict include, but are not limited to :
1. Family, friends, and romantic relationships – For example: a manager continues to supervise an employee with whom the manager has a romantic relationship, or approves discounts for a partner owned by the manager’s brother, or engages a vendor or vendor organization owned by a close personal friend or a person with whom he/she has a romantic relationship.
2. Personal financial interests – For example: an employee directs Acowale business to a vendor in which he/she has a financial interest.
3. Corporate business opportunities – For example: an employee purchases real estate in which he/she knows Acowale plans to build a facility.
4. Outside business activities – For example: an employee begins to serve on the board of a start-up company that is reasonably likely to compete with Acowale or is part owner of a reseller that is selling products and services.
5. Public service or office – For example: an employee takes a position on the council of a city in which Acowale has an office.
6. Public speaking, books, and other publications – For example: an employee agrees to conduct a series of lectures on the future of cloud security.
Other potential conflict of interest scenarios are outlined in the Conflict of Interest Policy. The presence of a conflict does not necessarily mean that an activity will be prohibited. If you feel that you have a potential conflict of interest, you must, first, refrain from the activity that creates the conflict, second, you must promptly disclose the conflict of interest or potential conflict of interest in writing via the Conflict of Interest Disclosure Form and submit it to a member of the Compliance and Ethics team.
If you observe any situation involving another employee that you believe in good faith to be a conflict of interest, you must report the situation to your manager, your HR manager, your regional Compliance and Ethics Officer, or the Integrity Helpline. Reports from employees will be handled as confidentially as possible. Acowale’s senior officers—chief executive officer, chief technology officer, president, chief operating officer, chief financial officer, chief accounting officer, executive vice president, and senior vice president—are subject to additional reporting requirements, which are spelled out in detail in the Conflict of Interest Policy.
Non-employee members of the Acowale Board of Directors are subject to the conflict of interest provisions of Acowale’s Corporate Governance Guidelines in lieu of the conflict of interest provisions contained in this Code. Senior officers and members of the Acowale Board of Directors who have questions regarding this Code or other relevant policies should contact Acowale’s General Counsel.
A: It depends. Whether or not this activity could constitute a conflict of interest depends on
A: Yes. This could create a conflict of interest because other vendors, suppliers, or customers of Acowale might suspect you of favoritism to this particular company even though none may be present. The objectivity of your business decisions could be questioned. In addition, this would create a conflict of interest if you are performing services for the customer personally that Acowale might otherwise have been retained to perform.
• The position you hold with Acowale
• The influence others may believe you have in the selection of Acowale suppliers
• The amount of your investment
• The importance of Acowale as a prospective customer
You should fully disclose the matter by submitting a Conflict of Interest Disclosure Form to Acowale Compliance and Ethics to obtain the appropriate approvals.
A: Not without approval. If you wish to serve on a board of directors, you must receive the written approval via the use of the Conflict of Interest Disclosure Form. The company for which you serve should not be in a competitive position with Acowale and should not be a customer, partner, or
supplier of Acowale, and the time required to serve on the board should not be substantial. You may receive compensation when serving in an approved position.
A: Yes. It is permissible to teach at an educational institution with written approval via the use of the Conflict of Interest Disclosure Form.
D.2 Potentially Conflicting Relationshipd Between Acowalers
Acowale does not prohibit dating among Acowalers, nor does it prohibit relatives from working together within, for, or on behalf of the Company. However, if a potentially conflicting relationship, romantic or otherwise, involves two employees in a direct reporting relationship, in the same chain of command, or otherwise creates an actual or apparent conflict of interest, the employees must disclose the relationship to People Ops Department. While both employees have a responsibility to disclose any such potential conflict, if you are a manager, your failure to properly disclose may result in more serious discipline. Upon learning of any potential conflict, Acowale may reassign at least one of the individuals to a different position or role within the Company. In any event, where your significant other, relative, or any other potentially conflicted person is within your chain of command, you must recuse yourself from any decision-making concerning the person’s compensation, promotion, discipline, or termination and must refrain from participating in his/her performance review.
If you have a personal or financial relationship with any service providers to Acowale, such as vendors, suppliers, or contingent workers, for which you have work-related responsibilities (e.g., where you are the Acowale assignment manager, participating in vendor selection, determining the terms of a contract or assignment, etc.) you must disclose that relationship to the People Ops Department and recuse yourself from any decision-making regarding that service provider.
In addition, Acowale’s Board of Directors may from time to time adopt separate policies with respect to directors’ conflicts of interest in order to address the particular circumstances arising from their role as members of the board. Any such policy will supersede the conflicts of interest guidelines above to the extent applicable.
D.3 Our Employees
Acowale provides regional employee handbooks or regional HR sites that can be used to answer common questions around employee-related policies, practices, and programs. We encourage you to express ideas for improving the workplace and any concerns you may have about the workplace or specific job-related problems. We will not retaliate and will not tolerate retaliation against any employee who raises an issue, complaint, or concern in good faith. Our goal is to deal fairly and
equitably with each employee.
Immigration Laws You must ensure that you, and any employees that report to you, comply with all applicable immigration laws and/or the advice of Acowale’s designated immigration service providers. At all times, Acowale employees must possess proper work authorization for the country in which they are working. If you travel internationally on business, you are responsible for obtaining the appropriate visa before attempting to enter a host country.
Visa requirements apply to all Acowale employees who travel outside of their home countries for business purposes or who work on projects or international assignments outside of their home country for any duration. Acowale also prohibits you from allowing contractors or other employees to work on a project without the proper authorization or documentation.
If you need information on immigration issues, contact US Immigration for US-specific issues or the Mobility Group for countries other than the US through Global People Ops Department website. For US Immigration, including all US visa matters, contact Acowale’s People Ops Department.
For Global Immigration (excluding US-inbound), contact Acowale’s Global Mobility group. You can also review Acowale’s Working Worldwide site for information related to Acowale’s Global Mobility and Global Immigration program, including: Global Immigration Program Policy & Guidelines
Global Immigration Program Frequently Asked Questions (FAQs)
Diversity
Acowale affirms the principle of equal employment opportunity withoutregard to any protected characteristic, including but not limited to
1. Race, Religious Creed, National Origin
2. Color
3. Sex or gender
4. Gender identity or expression
5. Age
6. Mental or physical disability or medical condition Pregnancy
7. Marital status
8. National origin/ancestry
9. Genetic information
10. Political affiliation
11. Military and protected veteran status Sexual orientation
12. Any other characteristic protected under federal or state law or local ordinance
13. Military and protected veteran status Sexual orientation
14. Any other characteristic protected under federal or state law or local ordinance
We practice and promote such policies in all locations as appropriate under the law. We affirm this principle of freedom from discrimination in all aspects of the employment relationship, from recruitment and hiring, through performance evaluations, compensation, and promotions, to the end of your employment relationship with Acowale. We base personnel actions strictly on individual ability, performance, experience, and company need. We avoid actions influenced by personal relationships and discriminatory practices of any kind. Our goal is to compensate personnel—with wages, salaries, and other benefits—in relation to their responsibilities, performance, and experience. Acowale is also committed to adhering to wage, hour, and minimum-age guidelines provided by applicable laws. We strive to structure the content of jobs so that work provides personal satisfaction and challenge.
Harassment
You are expected to treat your fellow colleagues and/or employees with mutual respect and dignity. Acowale‘s policy is to provide a work environment free from harassment. Harassment is prohibited in any form: physical, verbal, and nonverbal. Harassment is prohibited by law and Acowale policy prohibits the berating or verbal abuse of employees. You may review our policy in detail by accessing the Anti-Harassment Policy. Although “harassment’’ most frequently refers to sexual harassment, workplace harassment may also include harassment based upon a person‘s race, religious creed, national origin, color, sex or gender, sexual orientation, gender identity or expression, age, mental or physical disability or medical condition, pregnancy, marital status, national origin/ancestry, genetic information, political affiliation, military and protected veteran status, or any other characteristic protected under federal or state law or local ordinance. Report instances of harassment to your manager, your Acowale People Ops manager, your regional Compliance and Ethics team, or the Acowale CEO’s Office. Your report will be kept confidential to the greatest extent possible and retaliation is not tolerated for any report made in good faith. Safety and Security Threats or acts of violence against you, temporary employees, independent contractors, customers, clients, partners, suppliers, or other persons and/or property will not be tolerated. Immediately report potential threats or acts of violence to Acowale Global Physical Security, which is responsible for defining, developing, implementing, and managing all aspects of physical security to ensure your protection, the business enterprise, and assets. In case of an emergency, contact local law enforcement. You are obligated to provide accurate and complete information requested by Acowale Global Physical Security. This includes investigations regarding threats to persons or property, theft of Acowale assets, and theft of personal assets (where the theft occurred on Acowale property). Photography and videography of Acowale’s property is prohibited without prior review and written approval from either Acowale Global Physical Security or your Regional VP of Acowale Real Estate and Facilities.
Environment, Health and Safety
Acowale is committed to conducting its business operations in a
manner that protects the health and safety of its employees, visitors,
contractors, and the public, while also minimizing the environmental burden of our operations and products. Acowale’s Global Environment,
Health and Safety (EHS) Department, NHS in UK, Health Ministry in India works with all lines of business and employees around the globe to comply with applicable health department requirements.
As an employer, Acowale has responsibilities and obligations in preventing workplace accidents and injuries and promoting safe and healthy workplaces. Immediately report any instances of noncompliance with environmental laws and regulations to your local facilities manager, your regional Compliance and Ethics Officer or, where permitted by law, the Acowale Support Helpline. We expect you to pay all applicable taxes on all income from Acowale, including taxes on income from the exercise of stock options.
D.4 Investing Process
Serving on Boards and Investing in Other Companies
Acowale is committed to maintaining an internal investigations process focused on accuracy, precision, fairness, and respect for all parties involved. Your regional Compliance and Ethics Officer is responsible for addressing business conduct and ethical concerns, including directing the investigation of allegations of misconduct. Investigations are conducted in compliance with applicable law and Acowale policies and in such a manner that all parties receive ethical and fair treatment.
Acowale complies with applicable laws in conducting investigations. To the extent permitted by applicable law, and when appropriate, investigation methods may include interviews with the parties and witnesses, review of relevant financial, electronic, and other records, reviews of publicly available information, and monitoring and/or analysis of computers, systems, offices, and other resources. You have a duty to fully cooperate with investigations and to promptly, completely, and truthfully comply with all requests for information, interviews, or documents during the course of an investigation.
To the extent possible, Acowale treats all reports of alleged misconduct confidentially, and only those persons with a need to know are informed of and involved in an investigation. Only the Acowale General Counsel, Chief Compliance and Ethics Officer, a regional Compliance and Ethics Officer, or the Compliance Officer’s designee may commence a Code of Conduct investigation relating to a Code of Conduct violation. All reports of misconduct and related investigative records are treated in accordance with the Internal Privacy Policy and Information Protection Policy, both of which are available on the Legal Department website. Unsubstantiated allegations will have no effect on an employee accused of wrongdoing, and retaliation will not be tolerated against any employee who reports a concern in good faith or cooperates with a compliance investigation.
For investigations in which misconduct occurred, Acowale calibrates the application of disciplinary and remedial actions to the conduct established through the investigation process. In addition, Acowale may report civil or criminal violations to the relevant authorities.
Summary
Acowale is dedicated to upholding the highest ethical standards. Employees must disclose any Conflicts of Interest to ensure decisions are made impartially. We address Potentially Conflicting Relationships between Acowalers to maintain a professional work environment. Our commitment to Our Employees includes fostering a culture of respect and inclusion. If issues arise, our Investigations Process guarantees that all matters are handled fairly and transparently, reinforcing our ethical commitments.
Business operations & resources
E.1 Public Contarcting
You are expected to compete fairly and ethically for all business opportunities. If you are involved in the purchase, sale, or licensing of products/services, the negotiation of agreements, or the delivery of services to customers, you are expected to understand and honor the terms of Acowale‘s contractual agreements. Also, you must ensure that all statements, communications, and representations to customers, suppliers, and internal approvers are accurate and truthful. Acowale is committed to meeting all of our contractual obligations. You must obtain all appropriate approvals before executing, modifying, or amending any contract. Acowale prohibits unauthorized contracts or modifications of contracts, including side letters or oral agreements. A “side agreement” or “side letter” is any agreement, promise, or commitment (whether written or oral) by or on behalf of Acowale with a customer or partner from whom revenue has been or will be recognized, that is either undocumented or documented in agreements separate from the main contract. Such side agreements are prohibited under Acowale policy.
Spending and Signing Authority
Before acquiring any goods or services, signing any document, or making any other commitments on behalf of Acowale, you must ensure that you have spending authority equal to or greater than the total amount of payments or other concessions to which you are committing Acowale. You should aggregate the total cost of a purchase when making this determination. It is not permissible, for example, to open several purchase requisitions for a single vendor on the same project to avoid going outside the limits of your spending authority. If you do not have adequate spending authority, obtain approval from the manager in your chain of management who has the appropriate signing authority. If you have questions about your spending authority, consult your manager. You should also familiarize yourself with the Global Spending Approval Policy, Global Source-to-Settle Policy, and the Document Signing Authority Policy.
A: No. This would constitute an unauthorized side letter modifying the terms of the contract. Execution of unapproved side letters is grounds for disciplinary action.
A: No. Acowale may be willing to modify the contract to allow the use desired by your customer, but such a change to the contract requires the necessary business review and approval. Treat the request as one for a formal contract amendment and process the request in compliance with Acowale‘s business practice guidelines.
E.2 Use of Acowale Resources
We use a number of company and personal assets and resources to perform our jobs. These include Acowale facilities, computers, telephones, and email, as well as certain personal devices. It is critical that each of us fully understands the requirements for appropriate use of these resources.
You are required to comply with the Acceptable Use Policy for Company Resources, located on the Legal Department website. The topics covered include Personal use of Acowale resources and appropriate conduct Reporting data loss and security incidents Use of Acowale and third-party instant messaging, email, voicemail, mobile phones, removable media, and applications Use of passwords and prevention of viruses Protecting confidential information Issuing public statements
Marketing and customer communications Investigations and access to resources and facilities Acowale may employ security procedures at our facilities to monitor and maintain security, including the use of closed circuit television.
Also, use of Acowale computers, systems, resources, and employee personal devices used for business purposes may be monitored or imaged for legal preservation to the extent permitted by applicable law. In addition, Acowale requires you to comply with Acowale’s Information and Physical Security policies at all times. Acowale property may not be sold, loaned, given away, or disposed of without proper authorization. Upon leaving employment with Acowale, all Acowale property including keys, security badges, computer equipment, software, handbooks, and internal documents—must be returned.
E.3 Financial Integrity
Accurate and reliable financial and business records are of critical importance in meeting Acowale‘s financial, legal, and business obligations. Acowale‘s financial books, records, and statements must properly document all assets and liabilities and accurately reflect all transactions of the company. No false entries are ever permitted on Acowale’s books or records, for any reason. Below are some helpful guidelines regarding financial record keeping. Billing of time or expenses by consultants, submission of Acowale timecards, entry of orders by sales administrators, and submission of travel and expense reports shall be made timely and accurately and in compliance with Acowale policy, professional standards, regulations, and laws. No documents shall be inappropriately altered or signed by those lacking proper authority. Please refer to Acowale’s Document Signing Authority Policy on the Acowale Legal Department website for more information. Acowale funds or assets must not be used for any unethical, inappropriate, or illegal purpose.
The handling and disbursement of funds related to an Acowale transaction must be pursuant to a duly authorized Acowale written contract with clearly defined procedures. No undisclosed or unrecorded fund or asset related to any Acowale transaction shall be established or maintained for any purpose. No payment on behalf of Acowale shall be made or approved with the understanding that it will or might be used for something other than the stated purpose. All approval requests for nonstandard discounts must be accurate and commercially justified. Margins derived from misleading and/or unjustified nonstandard discounts are inappropriate, and may not be used to pay or otherwise reward an Acowale customer, employee, or other third party. Placing an order with Acowale without the existence of a corresponding end user agreement (also known as “pre-loading” or “channel stuffing”) is not an acceptable Acowale business practice and is prohibited. Acowale partner agreements require partners to provide a copy of the end user agreement (Proof of End User—POEU) documentation upon Acowale’s request and such documentation is required for certain orders to be booked as outlined in Acowale’s Revenue Recognition Policy.
In working with Acowale partners (VADs, resellers, and the like), you are expected to maintain neutrality and take all reasonable measures to ensure partner adherence to Acowale policies and contractual obligations. Partners or other third parties should never be engaged to make or facilitate improper payments, misrepresent the nature or substance of a transaction, or structure deals in a manner intended to circumvent the design and intent of Acowale policies and controls. For further information, see Acowale’s Partner Engagement Guidelines and Guidelines for Working with Partners.
Summary
In the Business Operations and Resources section of the Acowale rule book, we emphasize the importance of maintaining high standards in Contracting by ensuring all agreements are transparent and mutually beneficial. The Use of Acowale Resources must be efficient and responsible, prioritizing sustainability and ethical practices. Upholding Financial Integrity is paramount, requiring meticulous record-keeping and honest reporting to foster trust and accountability within our operations.
Relationship & Interaction
F.1 Our Customer, Our Partner, Our Supplier
Our Customers
We prosper to the degree—and only to the degree—that we serve our customers well. Our appeal in the marketplace must be based on the quality of our products and services, the perception that our products and services are priced fairly to provide value to our customers, and the competence and honesty of our product and sales presentations. Accordingly, we prioritize pleasing our customers and anticipating and being responsive to their needs.
Our Partners
Together, Acowale and its partners provide customers around the world with industry-leading solutions and services. These standards can only be met with our partners’ cooperation. Acowale expects its partners to conduct business fairly and ethically, to comply with anticorruption laws around the world, to cooperate with Acowale’s requests for information, and to avoid engaging in any activity that involves even the appearance of impropriety. We require our partners to adhere to the standards of the Acowale Partner Code of Ethics and Business Conduct. We also expect our partners to comply with all applicable laws and regulations. Partners are encouraged to report concerns to the Support Helpline.
Our Suppliers
We maintain open and frank business dealings with our suppliers and strive to develop mutually advantageous relationships. Acowale expects its suppliers to conduct business fairly and ethically, to comply with the anti-corruption laws around the world, to cooperate with Acowale’s requests for information, and to avoid engaging in any activity that involves even the appearance of impropriety. We require our suppliers to comply with the Acowale Supplier Code of Ethics and Business Conduct. We also expect our suppliers to comply with all applicable laws and regulations and to ensure that all goods and services provided by them conform to all applicable legal standards. Suppliers are encouraged to report concerns or issues to the Integrity Helpline.
F.2 Special Instructions For Acowalers
Serving on Boards and Investing in Other Companies
We encourage Acowalers to be active in industry and civic associations. However, Acowalers who serve on boards of directors or advisory boards of any entity or organization are required, prior to acceptance, to obtain approval from the Chairman of Board. Any passive investment of not more than two percent (2%) of the total outstanding shares of a publicly traded company is permitted without Acowale Board Chairman approval, provided that the investment is not so large financially (either in absolute dollars or percentage of your total investment portfolio) that it creates the appearance of a conflict of interest. However, any investment in more than two percent (2%) of a public company or any investment in a private company that is a current or potential competitor of Acowale or that has a business relationship with Acowale requires prior approval from the Board Chairman. Acowale reserves the right to review and revisit any prior investment approvals in order to avoid an actual or apparent conflict of interest. Acowale may periodically conduct an inquiry of Acowalers in order to determine the status and circumstances of board memberships or investments, and Acowalers are responsible for continually monitoring and reporting any change in circumstances that might give rise to an actual or apparent conflict of interest.
Corporate Opportunities
Acowalers may not exploit or take advantage of business opportunities that are discovered through the use of Acowale’s property, information, or position for personal gain unless the opportunity is disclosed fully in writing to the Company and Acowale declines to pursue such opportunity.
Outside Business and Consulting Engagements
Acowalers must obtain approval from the Conflicts Committee via the online tool prior to (1) beginning any employment, business, or consulting relationship with another company that is a current or potential competitor of Acowale or that otherwise has a business relationship with Acowale, or (2) accepting any teaching engagements with an educational institution, establishment, or other organization. In addition, you should avoid conducting Acowale business with members of your family or others with whom you have a significant personal or financial relationship without the prior approval of the Conflicts Committe
Summary
In the Acowale rule book, the “Relationships and Interactions” section emphasizes the importance of fostering strong connections with Our Customers, Partners, and Suppliers. It highlights the need for mutual respect, clear communication, and collaboration to ensure seamless operations and shared success. Additionally, Special Instructions for Acowalers underline the commitment to maintaining professionalism, adhering to company values, and consistently delivering exceptional service.
Basic
Integrity
We are honest and choose integrity in all business transactions and dealings
Communication
We share information effectively and protect its confidentiality.
Ethics
We act ethically in every business context
Innovation
We innovate and seek new and creative approaches to problem solving
Compliance
We comply with all laws, regulations, and Acowale policies.
Customer Satisfaction
We treat customer satisfaction as a top priority
Mutual Respect
We treat individuals with respect and dignity
Quality
We incorporate excellence, quality, and strive for continuous improvement.
Teamwork
We work together as a team to benefit Acowale
Fairness
We deal fairly with customers, suppliers, partners, and colleague