From the Board of Directors
With over 200 clients worldwide and tens of thousands of users, Squaretalk is becoming a leader in business communications. As we mature and grow as a company, we also strive to reach the highest standards of ethical and moral behavior. These internal guidelines outline the kinds of behaviors we expect from ourselves and any other entities we do business with.
Squaretalk holds the values of diversity, transparency, openness, and flexibility above all others. These values are at the core of the company DNA and the reason for our continued growth and success. They are an integral part of everything we do, every action we take, and every interaction we have with clients, partners and competitors.
This code of conduct is designed as a reference for our team. Sometimes situations arise without intention that put us all in uncomfortable or ambiguous positions. It is essential that we know how to detect an unethical or potentially criminal situation and how to act to maintain our values and avoid any possibility of liability.
This Code of Conduct deals with sensitive matters that are often complex human interactions. For clarity, it includes tips and examples that will further instruct and illustrate appropriate behavior. If something is not clear or you have any questions at all please contact the Anti-corruption leader who will be glad to help clarify your situation.
Should a situation arise where someone attempts to persuade you through gifts, gratuities, favors, or bribes to act against the best interest of Squaretalk, please inform your supervisor or the Anti-corruption leader immediately. You can also report the situation directly to the board of directors at any time.
Openness and transparency are two of our highest stated values. You should feel comfortable and empowered to report any behavior from any person or entity you have contact with should you ever feel uncomfortable in any way.
This Code of Conduct is a vital part of the Squaretalk culture. Please take time to read it and communicate any questions or comments to your supervisor. Thank you for your continued commitment to our company.
Avoiding Conflict of Interest
What is a conflict of interest?
A conflict of interest occurs when an employee or entity becomes unreliable because of a clash between personal (or self-serving) interests and professional duties or responsibilities. Such a conflict occurs when a company or person has a vested interest—such as money, status, knowledge, relationships, or reputation—which puts into question whether their actions, judgment, and/or decision-making can be unbiased. It may apply to both employees and consultants as well as the interest of people close to them.
By signing a contract with the company, you agree to be guided by the best interest of the company, and the company agrees to pay you remuneration specified in the agreement and ensure you tools you require, and the benefits provided by the agreement and regulations.
Avoiding conflict of interests
Principally, any relationship that you have that might present a conflict of interest should be reported to your supervisor immediately.
- Having personal, professional, or property relationships with entities that may be our competitors, providers, or clients is not reprehensible itself.
- Evaluate whether your relationships with clients may cause a conflict of interest. If you have any doubts, consult them with your supervisor.
Here are some examples of rules of conduct for situations that may result in a conflict of interest.
Working with relatives and friends
If two family members or close people co-work or provide services for Squaretalk, there cannot be a professional dependency between them (for example, a supervisory relationship) without the company’s consent.
If your relative or close person is the owner, worker, or provider of services at the company doing the business with Squaretalk, you must report it. To conduct business related to the mutual interest of Squaretalk and this company, you need to get the approval of the board of directors.
Family members and close people are parents, siblings, a spouse, siblings of a spouse, children, parents-in-law, your and spouse’s grandparents, grandchildren, life partners, and other people who permanently live within your household.
Ownership of shares, stocks or other securities of our competitors, clients, or providers must be reported to your supervisor or the Anti-corruption Representative. It is necessary to evaluate the risk and determine responsibilities that will not cause a conflict of interest. Detailed regulations in this respect are in the contracts signed by the employees and consultants.
It is also applicable when the owners are relatives or people close with the employees or consultants who cooperate with Squaretalk, regardless of the form of cooperation.
Squaretalk rejects all corruption and bribery practices. We do not tolerate offering or accepting bribes from our employees or consultants. We do not gain clients this way, and we do not practice that in our contacts with state administrative authorities or self-government administrative authorities, providers, and competitors. We do not tolerate this kind of practice in our internal relationships.
We are aware that bribery and corruption may occur in official as well as in business relations. Therefore, we ask all employees and consultants to discuss with their supervisors, the board of directors, or the Anti-corruption Representative their concerns and abnormal behavior of the external stakeholders.
Benefits due and undue.
Benefits due are those resulting from the agreement concluded with the company, internal regulations, and legal provisions. They include remunerations, bonuses, training financed by Squaretalk, awards, equipment passed on contractually, social benefits, paid holidays, commissions, etc.
A benefit due is also what the employee or consultant will receive from other entities with the knowledge and approval of the company.
In conclusion, what we get from the company or with its approval or from the state institutions is, in general, a benefit due (exception: if we misled them to gain benefits.)
Other benefits received concerning the work or services of the different entities or people are, in principle, undue benefits.
Let us remember that the same rules that stand for what is a benefit due and what is undue apply to persons performing public functions and representatives of our providers, clients, and competitors.
Corruption in the public sector
Corruption crimes in relationships with persons performing public functions consist of giving undue benefits in exchange for:
- professional activities (such as affecting decision making, the conclusion of a contract),
- failure to act (such as exemption from control or punishment.)
To ensure the transparency of our relationships with persons performing public functions, we adopt the principle: we do not give, do not offer, and do not promise any benefits. We do not give gifts, even no company gadgets of negligible value. We do not provide or promise a token of gratitude. We do not invite public officials to the company’s parties.
Sales for the public sector – restrictions
Every establishment of the business relationship to sell services for the public sector requires the approval of the board of directors.
It includes the following types of entities: offices, agencies and other state entities and local governments, companies owned by the State Treasury or local government companies, state-owned enterprises and local government enterprises, public health care facilities, public universities, and research institutions, international organizations and their entities, political parties and their foundations.
Corruption in business
Giving, offering, or promising undue benefits to the representative of another company in return for the unreliable performance of the official or contractual duties is against the law, especially if:
- May expose other companies for the property damage.
- Constitutes an act of unfair competition (unfair favoring of a provider.)
- Constitutes unacceptable favoring of a buyer (unfair favoring of a client.)
Additionally, acceptance, demanding, or promise acceptance of an undue benefit by the company representative in the above-mentioned situations is also a crime.
To ensure the application of business ethics and fair competition in relationships with our business partners and competitors, we have adopted the following principles.
- We accept and offer only those benefits that are consistent with our gift and hospitality policies.
- We check if our business partners apply gift policy and ethical code, and we do not make proposals that exceed those principles.
- We refuse to accept any undue benefits or promises in return for acting against our company or for favoring a provider or client.
- We do not give or promise benefits undue in return for acting against the company of the gifted person or for unfairly favoring our company.
The rules of conduct if corruption is suspected.
In the case of being offered a corrupt proposal, apply the following rules:
- Refuse unambiguously.
- If possible, refuse in front of witnesses.
- Inform your supervisor, the board of directors, or Anti-corruption Representative immediately, either orally and in writing
- Secure evidence and documents concerning the case e.g., email correspondence, paper documents.
- If an offer of direct bribery was made do not attempt to prove it by accepting the offer.
- If an undue benefit was transferred indirectly (by a courier, hidden in a document or a gift given) — report it to your supervisor immediately, secure it, and write a protocol jointly with the Anti-corruption Representative.
After your report, its analysis, and gathering evidence, the company pursues proper legal action. If and evidence is sufficient, the company prepares a notification to the authorities.
Remember, you have the right to:
- Skip the chain of command and report a corruption incident directly to the board of directors.
- Directly inform the authorities about an attempted crime.
Gift and gratuity policy
To preserve transparency and fairness in conducting our business, we apply the following rules.
The rules of giving gifts and expressing gratitude.
- Do not give, offer, or promise gifts and other benefits on the quid quo pro principle.
- We do not provide any gifts (even promotional gadgets of a negligible value) to persons performing public functions; we do not fund them anything or invite them to private parties.
- We do not propose to business representatives of other companies anything that could violate their own gift and hospitality policies. We should check in advance whether such a policy exists (it may be a part of a document of a different name). We apply the principles of a partner in mutual relations unless ours are more stringent.
- In cases justified by business needs, we can provide official promotional gadgets from our company.
- In cases justified by business necessities, the marketing department can offer gifts to customers and business partners only when the value and nature of the offerings are appropriate in the circumstances.
- Offering refreshments (hot and cool soft drinks and snacks) to any visitors in our office or at the official exhibition stand (for example, during trade fairs or events) is allowed.
- In the case of organizing marketing events open for all visitors such as business breakfast, it is allowed to offer a small refreshment (soft drinks, sandwiches, sweets, etc.).
- In the case of closed marketing events (that is, by invitation only for specific individuals or companies) combined with entertainment and consumption paid by Squaretalk, the participants can be the existing clients and other business partners.
- In cases not described above or in the event of any doubts related to applying those rules, consult with the Anti-corruption Representative.
The rules for receiving gifts or gratuities.
- We do not accept any gifts or gratuities on the quid quo pro principle because it may be a crime.
- We do not accept any gifts or gratuities from our competitors or potential providers because it may cause a conflict of interest.
- We are allowed to accept gifts and invitations from the rest of our business partners or clients (the current and potential ones). But only when the value and nature of gifts or invitations are appropriate in the circumstances and both a beneficent and a beneficiary case. Gifts and invitations must always be given and accepted openly and shared with the whole company.
- In the case of receiving a questionable or unacceptable gift proposal or gratuity, it should be refused assertively as inconsistent with the applicable Code of Conduct of the company.
- In cases not described above or in the event of any doubts related to applying those rules, consult with the Anti-corruption Representative.
Fair competition. Conspiracy
In selling our services, we comply with the rules of fair competition.
We do not tolerate any form of collusive bidding or other acts of unfair competition. They are subject to financial penalties and sometimes criminal liability.
To avoid collusion, we do not agree or consult in any way on our actions concerning current and potential clients with our competitors.
In the case of such an attempt by competitors — refuse, assertively and report this as a Corruption Incident.
Account books, records, and financial statements of Squaretalk are kept with the appropriate level of detail to reflect company operations accurately. It is both required by the law and the system of the internal control of the company.
The company documents are safely stored and archived. This applies to paper as well as electronic documents.
Fairness in relations with business partners
Squaretalk makes every effort to be fair and reliable toward all clients, providers, and other business partners. Never provide misleading information about our company’s quality, functions, or product availability and never do anything illegal or unfair to gain or implement an order.
An attempt to obtain information by lying or pretending to be someone else is unethical and may be illegal. Do not do this. If, by mistake, you receive another company’s confidential information, return or destroy it immediately.
Fairness in the internal relations
Proper use of company equipment
Squaretalk trusts its employees and consultants, allowing them to use a wide range of devices and technologies to enable them to perform at the highest levels. These tools should be used in accordance with their purpose.
Computers, mobile phones, and other devices provided by Squaretalk are the company property. This also applies to the Internet, electronic business mail, and other systems and tools used at Squaretalk.
Provided devices and technologies should be used in accordance with the policy of security of information.
The company’s property should be used for its purpose, responsibly, and in a manner that protects it against loss or destruction.
Audits and external inspections
From time to time, you may meet internal and external auditors and inspectors who ask you to provide information. Never mislead or try to affect any investigation, audit, or inquiry.
In case of any legal doubts, consult your supervisor.
This Code applies equally to all the employees and consultants of Squaretalk regardless of the form of cooperation. However, management and team leaders/supervisors are under additional obligations.
If you are a manager, supervisor, or team leader, please be aware that the success of the Code Conduct and adherence to ethical values are dependent on your leadership and commitment. Therefore:
- Be a good example; always choose fairness.
- React proportionally to minor irregularities to prevent major abuse.
- Speak up if you see a problem and encourage others to do the same.
- Do not accept gifts or gratuities from your subordinates if the value of those may cause a conflict of interest and interfere with objective evaluations.
- Make sure that your subordinates understand this Code of Conduct and what is expected of them.
- Encourage your subordinates to consult you about their doubts and discuss situations of the potential conflict of interest; evaluate the risks and make corresponding decisions.
- If necessary, consult the Anti-corruption Representative.
- Encourage your subordinates to report abuse, and justified suspicion of abuse or corruption, protect whistleblowers from retaliation, pass the information on to the Anti-corruption Representative.
Treating people with dignity and respect.
We respect, support, and protect human rights and dignity. We believe that successful cooperation can only be realized while maintaining mutual trust in the atmosphere of support. At Squaretalk, we do not tolerate behaviors that contribute to an atmosphere of intimidation, hostility, or abuse.
We all have the right to work in an environment free from harassment and violence. This applies to the way we treat each other and all the people with whom we maintain business relationships.
At Squaretalk, we do not tolerate:
- All instances of mobbing, physical, verbal, or sexual harassment and other behaviors with that aim to insult, humiliate or intimidate, etc.
- We do not accept spreading rumors, making false accusations, and sharing unproven information.
- We do not use professional status to reap personal or financial benefits unlawfully.
- We do not offer personal or financial benefits in return for improving our professional position.
At Squaretalk, we value diversity; we do not tolerate discrimination in any form. We follow the rules of equal opportunities in employment. We recruit, employ, remunerate, train, promote and dismiss employees in accordance with applicable principles and regulations, regardless of race, skin color, faith, age, gender, nationality, marital status, sexual orientation, or disability.
Health and Safety
Squaretalk conducts activities in a manner ensuring the health and safety of our employees, counterparts, and all the people visiting our offices. We comply with accepted principles of occupational health and safety.
Personal data of our employees and business partners is used only for the purpose for which it is stored and is treated as strictly confidential. We adhere to the rules of data protection strictly.
Reporting on violations and consulting on suspicious situations.
If you have any doubts
Feel free to share any concerns you have with:
- Your supervisor
- Other managers you trust
- The anti-corruption representative
The choice of person or persons you consult with is up to you.
Though it is crucial management is informed of any potential issues we want to provide you with a secure, confidential, and supportive place to share your concerns. Advice on any of these ethical concerns will be given in the strictest of confidence.
If you see something – Report it
You are the first line of defense of the ethical code. If you suspect that someone’s behavior may be against this Code, immediately take your concerns to your supervisor or senior management.
Reporting violations and corruption
If you encounter attempted bribery or are encouraged to engage in what you suspect are corrupt practices, please follow the rules in the “Anti-corruption practices “ section of this document
In situations like this, we encourage you to report the issue in one of the following ways:
- In-person, by phone or email to your manager or the Anti-corruption Representative.
- In justified cases, you can skip the chain of command and report the issue directly to the board of directors or other senior management.
You can also report the case anonymously.
Remember, if you witness a crime or preparation for a crime (for example, corruption or fraud), reporting the issue is mandatory and advisable also for your legal protection. Failure to report leads to no less than the moral co-responsibility for the incident and its consequences, and in some situations, even criminal or civil liability.
Reporting in good faith and protection of whistleblowers
Reporting in good faith means that any report of the possible violations of this Code, the company’s policy, or law are reported sincerely and honestly. In other words, regardless of whether your suspicions are confirmed or not, you must report them with the best of intentions.
Early reporting prevents converting small irregularities into serious crimes. It is in the best interest of the company and all employees and consultants who follow the Code of Conduct.
The board of directors pledges to protect whistleblowers from retaliation from people who break our ethical rules. Reports are perused with respect of the dignity and the good name of the persons involved. At the same time, in a way that protects the identity of a whistleblower. (In the circumstances provided by the law, the whistleblower’s identity may be revealed to the authorities.)