This Code of Conduct covers a wide range of business practices and procedures. It does not cover every issue that may arise, but it sets out basic principles to guide all employees and officers of Qwince. All of our employees and officers must conduct themselves accordingly and seek to avoid even the appearance of improper behavior. The Code should also be provided to and followed by Qwince suppliers, agents and representatives.

If a law conflicts with a policy in this Code, you must comply with the law. If a local custom or policy conflicts with this Code, you must comply with the Code. If you have any questions about these conflicts, you should ask your supervisor how to handle the situation. Employees and officers are responsible for understanding the legal and policy requirements that apply to their jobs and reporting any suspected violations of law, this Code or Qwince policies. The basic principles discussed in this Code are subject to any Qwince policies covering the same issues.

Competition and Fair Dealing

We seek to outperform our competition fairly and honestly. We seek competitive advantages through superior performance, never through unethical or illegal business practices. Stealing proprietary information, possessing trade secret information that was obtained without the owner’s consent, or inducing such disclosures by past or present employees of other companies is prohibited. We will compete vigorously but fairly in the market, being honest and trustworthy in all our dealings.We will use our resources, knowledge and expertise to our competitive advantage, but we will avoid undermining the operation of free markets and we will respect the rights of others to carry on their business. We will also avoid putting undue pressure on customers in ways that may reduce or remove their ability to choose between the services of competitors. It is always sensible to accumulate information about our competitors’ business, but the information has to be passed on openly in order that we can use it. We should never set out to get such information in an underhand way (for example, by misleading someone about your identity or secretly eavesdropping on a conversation), nor use information about competitors that has been gained dishonestly. Reaching ‘agreements’ with competitors to avoid each other’s customers and territories is unethical and would normally be unlawful. This type of situation is dangerous for you as an individual and also for Qwince UK and could result in fines or financial claims against us. Each employee and officer should endeavor to respect the rights of and deal fairly with Qwince’s clients, suppliers, competitors and employees.

Discrimination and Harassment

The diversity of Qwince’s employees is a tremendous asset. We are firmly committed to providing equal opportunity in all aspects of employment and will not tolerate any illegal discrimination or harassment based on race, colour, religion, sex, national origin, age, sexual orientation, national origin, disability, political affiliation, union membership, and marital status.

Bribery

Bribery, in any form, is illegal and carries immediate substantial financial and reputational risks as well as risks of criminal charges. It also undermines our business integrity and consequently impacts our long term business success. We do not give or accept improper payments or gifts in order to conduct business anywhere in the world. We agree the terms of supplier payments at the start of business and pay in accordance with our contractual obligations. We operate a zero tolerance approach to the making or receiving of bribes or corrupt payments, in any form. This type of conduct is absolutely prohibited whether committed by employees or anyone else acting on the Company’s behalf.

Gift and Entertainment

All employees are required to follow the rules on Gifts, Hospitality and Entertainment. In addition, employees of Qwince Joint Ventures or subsidiaries, whether in the UK or elsewhere, are required to follow these standards. We also expect employees of our franchise partners and suppliers to conduct themselves in accordance with these standards. Our Anti-Bribery Policy sets out what is and is not acceptable in general terms. It is essential that you read and comply with this policy.

Facilitation Payments

Facilitation Payments are minor payments made to a private or Public Official for the purpose of expediting or facilitating the performance by the official of a routine action. Facilitation Payments are prohibited in Qwince in each countries.

Record-Keeping, Financial Controls and Disclosures

Qwince requires honest, accurate and timely recording and reporting of information in order to make responsible business decisions. All business expense accounts must be documented and recorded accurately in a timely manner. If you are not sure whether a certain expense is legitimate, ask your controller. Policy guidelines are available from your controller. All of Qwince’s books, records, accounts and financial statements must be maintained in reasonable detail, must appropriately reflect Qwince’s transactions, must be promptly disclosed in accordance with any applicable laws or regulations and must conform both to applicable legal requirements and to Qwince’s system of internal controls. Business records and communications often become public, and we should avoid exaggeration, derogatory remarks,and we should avoid exaggeration, derogatory remarks, guesswork, or inappropriate characterizations of people and companies that may be misunderstood. This applies equally to e-mail, internal memos, and formal reports. Records should always be retained or destroyed according to Qwince’s record retention policies. In accordance with those policies, in the event of litigation or governmental investigation, pleaseconsult the executive management.

Code of Conduct Violations

Any employee who violates any section of this Code of Conduct is subject to disciplinary action up to and including termination and appropriate legal relief.

Our Mission

Our mission is researching, developing and deploying new enabling technologies (also including mobile devices) and delivering the highest quality solutions in cost-effective ways.

Our Values

Customer orientation

We maintain clear and open communication with our clients, suppliers and stakeholders in order to deliver innovative and competitive products and services to our clients’ satisfaction.

Quality

We strive to provide our clients with products and services of excellent quality by:

  1. Making and meeting commitments
  2. Carefully planning and staffing projects
  3. Paying attention to details
Respect and integrity

We act with respect and integrity to everyone at every level of our business – our clients, our suppliers, our stakeholders, our competitors, and our co-workers.

Accountability

We take responsibility for our actions as individuals, as team members, and as an organization. We work together, support one another and never let the client or our co-workers down.

Teamwork

We always work as a team with respect and trust for each other and a professional attitude to our work. We confront and solve problems and continuously learn and improve in conducting our job.

Compliance with Laws, Rules and Regulations

Obeying the law, both in letter and in spirit, is the foundation on which this Qwince’s ethical standards are built. All employees and officers must respect and obey the laws, rules and regulations of the cities, states and countries in which we operate.Respect for and compliance with laws and regulations that apply to our business is fundamental, whether in the UK or elsewhere. In an event that a customer requests something that would mean breaking our obligations, even just a little, it is imperative that you find another way to satisfy that customer, which stays within the law. If you break the law during the course of your work, both you and/or Qwince UK could be held liable in civil and/or criminal proceedings.Qwince will comply with any relevant requirements of its clients, where these are more stringent than local laws and regulations and where the clients’ requirements do not contradict any local laws or regulations

Personal Data

Qwince committed to handling personal information in line with data protection laws. Our Data Protection Policy sets out the rules which all employees must follow when handling personal information. It will help you ‘Do the Right Thing’ to protect yourself and our business, by protecting any personal information you handle. The unauthorized use or release of confidential information during or after employment with Qwince is a breach of this Code of Conduct.Confidential information includes all nonpublic information obtained as while conducting your work for Qwince, including but not limited to all internal correspondence and documentation as well as all communications with and materials obtained from or created for Qwince’s clients. It includes information that suppliers and clients have entrusted to us. Confidential information with respect to Qwince, its clients, prospective clients, suppliers, shareholders, and employees acquired in the course of business is to be used solely for corporate purposes and never to be discussed  with  or divulged  to un authorized people. The need for confidentiality extends to everyone, including  family, friends  and acquaintances, and continues even after the relationship with the client or partner is finished.Customers, suppliers, shareholders and employees expect Qwince and its employees to keep information regarding their personal and business affairs in strict confidence at all times. Examples of confidential information include, but are not limited to corporate policies, objectives, goals and strategies; lists of clients, clients or vendors; employee records; and other materials such as graphs, memoranda, documents, manuals, reports, records, software or hardware for use in computer or word processing equipment, training materials, bulletins, and similar originals or copies of records whether or not you have contributed to their creation.

When an employee leaves Qwince, the employee may not retain any confidential information. Confidential information available to one affiliate or department of Qwince should only be communicated to other affiliates, subsidiaries or departments when there is a legitimate business need to know.