Edver's Code of Ethics & Professional Conduct

Introduction

Edver’s professional code of ethics and professional conduct aims to give our members of staff guidelines on our business ethics and stance on various controversial matters. We trust you to use your better judgment, but we want to provide you with a concrete guide you can fall back on if you’re unsure about how you should act (e.g. in cases of conflict of interest). We will also use this policy to outline the consequences of violating our business code of ethics.

Edver’s Big 5

We believe these five qualities characterise all Edver members of staff: smart, conscientious, honest, responsible, and non-toxic. This Code should serve as a guide to help you to live up to these characteristics.

Training

Every new member of staff is expected to complete “Edver’s Trailmix for Newcomers” training course, available as a “trailmix” at this URL: https://tinyurl.com/Trailmix-for-Newcomers. Please note that completing the “Ethics and Integrity for Salesforce Partners” module from the course is compulsory before commencing work.

And our interns are encouraged to complete Edver’s Trailmix for Interns: https://tinyurl.com/Trailmix-for-Internship

Honesty, Integrity and Fair Play

Edver and its staff are fully committed to the principles of honesty, integrity and fair play in the delivery of services and goods to the public. All staff should ensure that the business operations, applications for services, procurement or staff recruitment, are dealt with in an open, fair and impartial manner.

This Code sets out the basic standard of conduct expected of all staff and Edver’s policy on matters like acceptance of advantages and conflict of interest of staff in connection with their official duties. This Code also applies to temporary and part-time staff employed by Edver.

Equality of Opportunity for All Members of Staff

Edver is an equal employment opportunity employer. Employment opportunities are available regardless of race, sex, religion, ethnicity, age, disability or other legally protected status. This Principle applies to all aspects of the employment relationship, including recruiting, hiring, training, work assignment, promotion, transfer, termination, and wage and salary administration.

Safety, and Health Practices

Edver is committed to an injury-free and illness-free workplace that is operated in an environmentally sound manner in compliance with all relevant laws and regulations that protect worker safety and the environment. Members of staff should perform work in a safe manner.

Fair Competition

Edver’s policy will prohibit any anti-competitive practices which could affect in bounding, restraining or distorting competition, as well as any practices of unfair competition. Accordingly, our members of staff cannot agree (formally or informally) with competitors to fix prices or any other conditions of transaction; to limit or control the production, commercialization, technical development or investment; to manipulate or divide markets or sources of provisioning; to participate with fake offers in tenders or any other forms of competitions for offers; to limit or restrain access to market and freedom of competition for other enterprises; to apply unequal conditions for equivalent performance to commercial partners, creating in this way a disadvantage in competition; to condition signing of acceptancy contracts by partners to supplementary obligations which, by their nature or according to commercial usage, have no connection with the subject of such contracts.

Our members of staff are prohibited from performing any act of unfair competition manifested through: misappropriating clients of another company by using the relations established with such clients within the function previously held at that company, dismissal or attracting members of staff of another company for the purpose of setting up a competing company to capture customers of that company or hiring members of staff of another company in order to disorganize its work. Simultaneously, our members of staff must not take actions that harm the legitimate interests of consumers or other operations in breach of the competition law.

Governance and Anti-corruption

Edver has zero tolerance for corruption. All members of staff must never offer to provide anything of value directly or indirectly to government officials and business partners to secure an undue advantage. Edver prohibits payment, offers of payment as well as anything of value directly or indirectly with the purpose of influencing or obtaining undue business or personal advantage.

Third parties will only be contracted to perform tasks which aid business interests provided: fees to be paid are reasonable; all arrangements are clearly documented; arrangements are in compliance with Edver’s policies.

Financial Reporting

All transactions of Edver must be duly recorded so as to permit preparation of clear financial statements in conformity with generally accepted accounting principles. No false or misleading entries may be made in the books and records of Edver for any reason, and no member of staff may engage in any arrangement that results in such a prohibited act.

No undisclosed or unrecorded fund or asset of Edver may be established for any purpose. No payment on behalf of Edver (including those by cash) may be done without adequate supporting documentation or made with the intention or understanding that any part of such payment is to be used for any purpose other than as described by the documents supporting the payment.

From time to time, Edver may publish or inform of policies on financial reporting, disclosure and compliance to reinforce the financial reporting expectations in this Code. All members of staff at any level are expected to implement and strictly follow these policies.

Restrictive Agreements with Third Parties

Edver does not condone activities that seek to gain an unfair competitive advantage. No individual may engage in any activity which violates any valid restrictive agreements entered into by that individual for the benefit of a third party, and no individual may, directly or indirectly, use or disclose any confidential information or trade secrets of a third party that the individual obtained while employed by or associated with such third party.

No Government Contracts

It is Edver’s current policy not to engage in any government (public procurement) contracts.

Acceptance of Advantages 

It is the policy of Edver to prohibit all staff from soliciting or accepting any advantage from any persons having business dealings with Edver (e.g. clients, suppliers, contractors). Members of staff who wish to accept any advantage from such persons should seek advice and permission from Edver’s Managing Partner (see the “Managing Partners” section).

Any gifts offered voluntarily to the staff in their official capacity are regarded as gifts to Edver and they should not be accepted without permission. By default, staff should decline the offer if the acceptance could be perceived as against the interest of Edver, or that of society, or lead to complaints of bias or impropriety.

For gifts presented to staff in their official capacity and of low nominal value (below 800 UAH or 30 USD), the refusal of which could be seen as unsociable or impolite, can be exceptionally accepted. In other circumstances, the staff should seek for a clear (i.e. in writing) and immediate (within 5 days from the offer) consent from Edver’s Managing Partner to accept the gifts.

Edver’s Managing Partner should keep proper records of the applications and permissions. Each permission will indicate the name of the applicant; the occasion of the offer; the nature and estimated value of the gift, and whether permission has been granted for the applicant to retain the gift or other directions have been given to dispose of the gift. The permissions must be signed and dated by both Edver’s Managing Partner and the applicant. Possible ways of disposal of such gifts are listed at Appendix 2.

Conflict of Interest 

A conflict of interest situation arises when the “private interests” of the staff compete or conflict with the interests of Edver. “Private interests” means both the financial and personal interests of the staff or those of their connections including: family members and other close affiliates; personal friends; the clubs and societies to which they belong; and any person to whom they owe a favour or are obligated in any way.

Staff should avoid using their official position or any information made available to them in the course of their duties to benefit themselves, their affiliates or any other persons with whom they have personal or social ties. They should avoid putting themselves in a position that may lead to an actual or perceived conflict of interest with Edver. Failure to avoid or declare any conflict of interest may give rise to criticism of favouritism, abuse of authority or even allegations of corruption.

In particular, staff involved in the procurement process should declare conflict of interest if they have beneficial interest in any company which is being considered for selection as Edver supplier of goods or services. Appendix 3 provides some examples of conflict of interest situations that may be encountered by staff. When called upon to deal with matters of Edver for which there is an actual or perceived conflict of interest, the staff member should make a declaration in writing to Edver’s Managing Partner. He should then abstain from dealing with the matter in question or follow the instructions of Edver’s Managing Partner who may reassign the task to other staff.

Misuse of Official Position

Staff who misuse their official position for personal gains or to favour their relatives or friends are liable to disciplinary action or even prosecution. Examples of misuse include a staff member responsible for the selection of suppliers giving undue favour or leaking information to his/her relative’s company with a view to giving away an undue advantage.

Handling of Classified or Proprietary Information 

Staff are not allowed to disclose any classified or exclusive information to anybody without authorization. Staff who have access to or are in control of such information should always provide adequate safeguards to prevent its abuse or misuse. Examples of misuse include disclosure of information in return for monetary rewards, or use of information for personal interest. It should also be noted that unauthorized disclosure of any personal data may result in a breach of the applicable legislation on privacy.

Property of Edver

Staff given access to any property of Edver should ensure that it is properly used for the purpose of conducting Edver’s business. Misappropriation of the property for personal use or resale is strictly prohibited.

Outside Employment 

Members of staff who wish to take up paid outside work, including those on a part-time basis, must seek written (date and signed) permission and guidance from Edver’s Managing Partner before accepting the job. Approval will not be given if the outside work is considered to be in conflict with the interests and values of Edver.

Compliance with the Code 

It is the personal responsibility of every staff member to understand and comply with this Code. Every member of the staff shall sign a declaration of Principle for this purpose. Edver’s Managing Partner or other mandated member of staff will keep declarations of Principle.

Higher ranked members of staff should ensure that their subordinates understand and comply with the standards and requirements stated in the Code. Any doubts of interpretation or problems encountered, as well as any suggestions for improvement, should be addressed to Edver’s Managing Partner for consideration and advice. 

Any staff member who violates any provision of the Code will be subject to disciplinary action. In cases of suspected corruption or other criminal offences, a report will be made to the appropriate authorities.

Sanctions

Edver can take prompt and appropriate remedial action in response to violations of the Code. Any member of staff who engages in conduct prohibited by the Code as determined by Edver’s Managing Partner will be subject to discipline actions and sanctions in accordance with the labour law.

Once a complaint has been placed, Edver’s Managing Partner will initially analyse it and s/he may meet privately with the applicant to understand the facts surrounding the issue. Following a fact-finding phase, an investigative meeting could be held with the member of staff alleged of the violation, to ascertain the facts further and receive observations. The decision should be issued in writing (date and signed), indicating a summary of the facts, reference to the specific violation and motivations.

The sanction may be under the form of:

• Warning;

• Private or public letter of reprimand;

• Transfer to other tasks or unit;

• Suspension from duties;

• Termination or removal.

Edver’s Managing Partner shall report serious violations to the appropriate government or legal authorities.

Reporting 

Members of staff have a responsibility to report to Edver any violation of the Code promptly. Edver shall put in place appropriate email and messaging communications channels to allow members of staff to address communications to Edver’s Managing Partner with the highest degree of trust and confidentiality.

Members of staff will not be disciplined or retaliated against in any way for reporting violations in good faith. Retaliation against any member of staff for reporting policy violations, or for testifying, assisting or participating in any manner in inspections is strictly prohibited. Any member of staff who believes he or she has been subjected to or has witnessed retaliation must immediately report the alleged retaliation to Edver’s Managing Partner.

Managing Partners

Edver’s Managing Partners are the company’s senior members of staff responsible for the day-to-day running of the company. Their identities are made known to every member of staff during hiring and onboarding processes and their contact details can be found in Edver’s internal “Employee Manager” system.

Edver’s Managing Partners will handle day-to-day compliance matters, including:

• Receiving, reviewing, investigating and resolving concerns and reports on the matters described in this Code;

• Interpreting and providing guidance on the meaning and application of this Code; and

• Reporting periodically and as matters arise to senior staff of Edver on the implementation and effectiveness of this Code and other compliance matters, and recommending any updates or amendments to this Code deemed necessary or advisable.

Appendix 1: Definition of Advantage and examples of prohibitions

“Advantage” means:

• any gift, loan, fee, reward or commission consisting of money or of any valuable security or of other property or interest in property of any description;

• any office, employment or contract;

• any payment, release, discharge or liquidation of any loan, obligation or other liability, whether in whole or in part;

• any other service, or favour, including protection from any penalty or disability incurred or apprehended or from any action or proceedings of a disciplinary, civil or criminal nature, whether or not already instituted;

• the exercise or tolerance from the exercise of any right or any power or duty; and

• any offer, undertaking or promise, whether conditional or unconditional, of any advantage within the meaning of any of the preceding paragraphs above.

Every member of staff commits to:

• Do not solicit, accept, offer, promise or pay a bribe either directly or through a third party. This includes “facilitation payments”.

• Do not accept transportation, travel expenses or accommodations for trips that are not business related.

• Do not offer or accept donations for parties, including going-away parties.

• Do not solicit or accept personal discounts that are not available to all members of staff or available to the general public.

• Do not offer or accept personal rebates or refunds that are a result of company’s purchases.

• Do not offer or accept excessive or inappropriate meals or entertainment. Generally, an excessive amount would be an amount you would not normally spend on yourself.

Gifts provided should not give the appearance of unduly influencing, obligating the recipient or providing an improper advantage to Edver. Gifts or entertainment should not reflect adversely on Edver or the recipient’s company and the gifts should be given openly. The gift or entertainment should be accurately accounted for in the member of staff’s expense report and on Edver’s books and records. If you have questions regarding whether or not to accept or offer a gift or invitation, consult with Edver’s Managing Partner.

Appendix 2: Examples of ways to dispose of gifts presented to a staff member in their official capacity 

• If the gift is of perishable nature (e.g. food or drink), it shall be shared among the office or during an activity organized by Edver.

• If the gift is a useful item, it may be sent to a charitable organization.

• If the gift is of historical or other interest, it may be sent to a library or museum.

• If the gift is suitable for display (e.g. a painting, vase, etc.), it may be retained for display on Edver’s premises.

• If the gift is a personal item of low value (below 800 UAH or 30 USD), it may be retained by the recipient.

Appendix 3: Examples of Conflict of Interest Situations 

• A staff member has a financial interest in a company that is being considered for selection as Edver’s supplier of goods or services.

• A staff member accepts frequent gifts from Edver’s suppliers or contractors.