Code of Conduct
Policy objectives
The goal of Accesa (the Company) is to sustainably strengthen the success of our shareholders and clients through competitive IT solutions and services.
Our Code of Conduct outlines the ethical principles and behaviours that govern our conduct as an organisation, that we all need to demonstrate.
They are mandatory and are published externally on Company’s website for transparency purposes.
Policy Principles
The trust our shareholders and customers place in our company and in the quality of our service depends largely on how we behave and how we use our skills for the benefit of our customers.
We believe in a world in which businesses use technology to have a meaningful impact on the way we live, work, and do business. Therefore, we are committed to making every effort to contribute to economic, environmental and social progress with a view to achieving sustainable development, in line with the OECD guidelines and United Nations Sustainable Development Goals (SDGs).
We do this through adopting this Code of Conduct, upholding our commitments to integrity, responsibility, and ethical business practices, fostering trust and professionalism within Accesa and its subcontractors. The following SDGs are of particular relevance to us:
SDG 5: Gender Equality
SDG 8: Decent Work and Economic Growth
SDG 12: Responsible Consumption and Production
SDG 13: Climate Action
SDG 15: Life on Land
In this endeavor, we partner with our clients on this journey to envision and engineer solutions that seamlessly integrate into their business and improve people’s lives. In doing this, we are guided by the following core ethical principles:
Honesty We uphold honesty by consistently communicating truthfully, refraining from deception or misleading information, and being forthright in all our business interactions. We strive to build trust through transparent and accurate communication.
Integrity We conduct ourselves with unwavering integrity, adhering to high moral and ethical standards in every facet of our operations. We keep our commitments, act ethically, and take responsibility for our actions, ensuring our business practices reflect our core values.
Transparency We promote transparency by openly sharing information that is relevant and appropriate with our employees, suppliers, clients, and stakeholders. We believe in being open and accessible, fostering an environment of trust and accountability.
Respect We treat everyone with respect, recognising every individual's inherent dignity and worth. We embrace diversity and inclusion, valuing different perspectives and cultures. We create a workplace and business environment that is free from discrimination, harassment, or bias.
Area of Applicability
This policy applies to all Accesa’s entities - Accesa IT Systems S.R.L., Accesa Managed Services, Accesa IT Group and Accesa LLC companies (collectively referred to as “the company”). As far as the term “employees” is used in this policy, it means all persons working for Accesa, including the board of directors (Management Board).
All suppliers and other third party’s personnel that are working on behalf of the Company, must adhere to the Supplier Code of Conduct, available on Company’s website.
Purpose
The purpose of this policy is to set the relevant ethical principles and fundamental values of the Company and to set the expected behaviour from employees, behaviour that the company considers fundamental to its successful operation.
All internal company guidelines and policies must be consistent with this code.
1. Main Principles
Anti-Bribery and Anti-Corruption
Integrity, lawful conduct, and impartiality in business decisions are prerequisites for a trusting business relationship.
We have a zero-tolerance policy for corruption, bribery, or any form of improper benefit, whilst we support all activities aimed at detecting, preventing, and reporting it.
We document and make transparent all business transactions related to donations and sponsorships.
We comply with anti-corruption laws and regulations and actively promote a culture of transparency and ethical behaviour.
All employees are prohibited from accepting or offering improper benefit, as defined in the Anti-Bribery and Anti-Corruption Policy and Conflicts of Interest Policy. Corresponding Internal Regulations apply, which must be observed by all employees in business dealings.
Anti-money laundering and international sanctions compliance
We are committed to preventing money laundering and terrorist financing by conducting thorough due diligence on all partners and transactions. We strictly adhere to all applicable international sanctions and trade restrictions, prohibiting business with sanctioned individuals or entities. Any suspicious financial activity must be reported immediately to the Compliance team.
Sanctions and Export Controls
We are committed to full compliance with all applicable trade sanctions, export controls, and import restrictions imposed by the European Union, the United Nations and any other applicable regulatory authority. We do not engage in any business activity, directly or indirectly, with individuals, entities, or countries that are subject to applicable sanctions, trade embargoes, or export restrictions, unless expressly authorized by the relevant authority.
We screen our business partners, customers, suppliers, and transactions against applicable sanctions lists prior to entering into any business relationship . Where screening identifies a potential match or raises concerns, we do not proceed until the matter has been reviewed and cleared by the Compliance function.
Compliance with laws and regulations
We comply with all applicable Romanian or local, where applicable, and international laws, regulations, and international standards governing our industry and business operations. This means we are committed to preventing and detecting illegal or unethical business practices.
We align our software/company’s products and services to legal requirements, including data protection, intellectual property rights, and cybersecurity.
Responsible Use of Technology including AI
We use technology responsibly, aiming to prevent that our software and services cause harm, violate privacy, or facilitate illegal activities.
We are mindful of the potential societal impact of our products and services and take measures to address any ethical concerns.
When deploying AI systems we comply with regulations, standards and best practices on responsible use of AI as further detailed in our company’s Policy for Deployment and Usage of Artificial Intelligence. AI systems deployed by the company are subject to risk assessment and monitoring by a team of diverse stakeholders (AI Governance Team) and users of AI systems undergo AI literacy training.
Intellectual Property
We respect and protect intellectual property rights, both our own and those of others, by having a zero-tolerance for software piracy, plagiarism, or unauthorized use of copyrighted materials.
We implement proper mechanisms to prevent any infringement of intellectual property rights, and we carefully monitor our products and services to fully comply with applicable legal requirements in this area.
Fair Competition
We compete fairly and ethically in the marketplace, adhering to anti-trust and competition laws.
We avoid using unlawful/ unfair competitive practices or providing any incentives, such as price fixing, collusion, improper gifts, or misleading advertising and maintain a strong commitment to fair and ethical competition.
All employees are instructed regarding their legal or contractual obligations not to disclose business secrets or other internal information to competitors or other third parties in an unauthorized and unjustified manner.
Data Protection and Data Security
We follow the highest standards to safeguard personal data, as well as other confidential or restricted information such as commercial or trade secrets and business data, in line with applicable regulatory requirements and recognized security standards.
We build trust and confidence among clients, employees, and business partners, by adhering to the GDPR, Data Protection principles and by integrating Data Protection and Data Security practices across our operations.
We collect and process data only for legitimate purposes, prioritize transparency towards data subjects and implement appropriated technical and organizational measures to ensure the confidentiality, integrity and availability of personal data and information assets.
We embed Data Protection and Data Security by design and by default in our systems, products and services, and apply a risk-based approach to identify, assess and mitigate privacy and security risks.
We respect data subjects’ rights, promptly respond to data breaches and security incidents, and safeguard personal information including when transferring data internationally, by applying appropriate safeguards and due diligence.
Our accountability extends to conducting privacy and security risk assessments, monitoring and auditing data handling activities and regularly reviewing and improving our data protection and data security practices.
All employees share responsibility for protecting personal data and information assets and are expected to act in accordance with Data Protection and Data Security principles, as well as applicable policies, procedures and security requirements.
Environmental Responsibility
We protect the environment, including climate change mitigation and adaptation where relevant, through an Environmental Management System (EMS) that drives continual improvement.
We promote responsible resource use, energy efficiency, and waste prevention and reduction (including reuse and recycling where feasible), and apply sustainable practices across our operations. Sustainability and ESG principles guide our procurement and supplier expectations, to support responsible sourcing and reduced environmental impact.
We comply with applicable environmental requirements and minimise our carbon footprint by setting, implementing, and reviewing objectives and operational controls aligned with our Environmental Policy.
Human Rights
We uphold internationally recognized human rights in the workplace, ensuring a respectful, inclusive environment free from discrimination, harassment, intimidation, or retaliation.
We have a zero-tolerance policy for all forms of forced labour, child labour, and modern slavery in our operations and supply chain. All work performed within our organisation must be voluntary, and every employee has the right to leave employment with reasonable notice in accordance with applicable law and their contractual terms.
We are committed to ensuring fair wages, reasonable working hours, and safe working conditions for all persons working within our organisation, in full compliance with applicable Romanian, local, and international labour laws and standards.We are committed to equal opportunity and fair treatment for all, respecting each person’s dignity regardless of any personal characteristic.
We protect employees’ rights to health and safe working conditions by maintaining a safe workplace, complying with OHS requirements, and continuously improving risk prevention.
We encourage speaking up and reporting hazards or concerns without fear of retaliation.
Conflicts of interest
We conduct ourselves with integrity and honesty in all our interactions within the organization and with external stakeholders.
We avoid conflicts of interest and act in the company's best interests, maintaining transparency and avoiding deceptive practices. When a conflict arises, it must be disclosed promptly to the compliance function so that steps are taken to resolve or mitigate such conflicts.
We strongly discourage our employees from using any confidential information about our clients, suppliers, or other business partners, for their personal gain/interest or for other purposes than those for which it was entrusted to us.
Whistleblowing Reporting
We ensure the transparency and honesty of our business operations; thus, our business processes are fully and truthfully documented. We have an internal control system and active risk management to avoid risks that could jeopardize the continued existence of the company.
We provide a dedicated channel for anyone to report ethical concerns, misconduct, or violations of the Company’s internal regulations and policies.
Whistleblowers will be protected from any kind of retaliation, and reports are treated confidentially, and promptly investigated, whilst appropriate actions are being taken.
2. Closing word
Trust in a company is measured in particular by how shareholders, clients, and business partners perceive the company. This code of conduct does not work simply because it is available it must be applied in daily business activities, therefore:
We provide regular training and communication to ensure awareness and understanding of this Code of Conduct.
Employees and subcontractors are expected to read, acknowledge, and comply with the principles outlined in this Code.
By following this Code of Conduct, we uphold our commitment to integrity, responsibility, and ethical business practices, fostering trust and professionalism within Accesa and its subcontractors.
When you doubt any topic related to this Code, please seek advice from the Compliance Office (compliance@accesa.eu).