Our Code of Conduct is one of the ways we put our values into practice.
It’s built around the recognition that everything we do in connection with our work at Amazing Electronics will be, and should be, measured against the highest possible standards of ethical business conduct.
We set the bar that high for practical as well as aspirational reasons – our commitment to the highest standards helps us hire great people, build/sell great products, and attract loyal customers followed by respect for our clients, for the opportunity, and for each other are foundational to our success and are something we need to support every day.
So please go through our Code of Conduct, and follow them completely, keeping in mind that each of us has a personal responsibility to incorporate, and to encourage other people in our organization to incorporate, the principles of the Code of Conduct and values into the work.
And if you have a question or ever think that one of your fellow workers or the company as a whole may be falling short of our commitment, don’t be silent. Just blow the whistle.
Who Must Follow Our Code of Conduct?
We expect all of our people to know and follow our Code of Conduct seriously. Failure to do so can result in disciplinary action, including termination of employment. Moreover, while the Code of Conduct is specifically written for our employees and management team members, we expect our contractors, consultants, and others who may be temporarily assigned to perform work or services for us to follow the Code of Conduct in connection with their work for us. Failure of an Amazing Electronics contractor, consultant, or other covered service providers to follow the Code of Conduct can result in the termination of their relationship with us.
What If I Have a Code of Conduct related Question or Concern?
If you have a question or concern, you can write to our Human Resources Department at firstname.lastname@example.org.
We prohibit retaliation against any worker here at Amazing Electronics who reports or participates in an investigation of a possible violation of our Code of Conduct, policies, or the law. If you believe you are being retaliated against, please write to our Human Resources Department at email@example.com.
I. Serve The Customers
Our customers value us not only because we deliver great products and services, but because we hold ourselves to a higher standard in how we treat users and operate more generally. Keeping the following principles in mind will help us to maintain that high standard:
Our reputation as an organization that our customers can trust is our most valuable asset, and it is up to all of us to make sure that we continually earn that trust. All of our communications and other interactions with our users should increase their trust in us.
Our products, services, support, and training should make us more useful for all our customers. We have many different types of customers, from individuals to large businesses, but one guiding principle: “Is what we are offering best?”
Privacy, Security, and Freedom of Expression
Always remember that we are asking our customers to trust us with their personal information. Preserving that trust requires each of us to respect and protect the privacy and security of that information. Our security procedures strictly limit access to and use of customers’ personal information and require that each of us take measures to protect customers’ data from unauthorized access. Know your responsibilities under these procedures, and collect use, and access user personal information only as authorized by our Security Policies, our Privacy Policies, and applicable data protection laws.
We are committed to advancing privacy and freedom of expression for our customers globally. Where customer privacy and freedom of expression face government challenges, we seek to implement globally recognized standards that respect those rights as we develop products, do business in diverse markets, and respond to government requests to access customer information or remove customer content. Write to our Human Resources Department at firstname.lastname@example.org, if you have questions on implementing these standards in connection with what you do at Amazing Electronics.
Part of being useful and honest is being responsive: We value relevant customer feedback when we see it, and we do something about it. We take pride in responding to communications from our customers, whether questions, problems or compliments. If something is broken, fix it. It is as simple as that.
Any time you feel our customers aren’t being well-served, don’t be bashful – let someone in the organization know about it. Continually improving our systems and businesses takes all of us, and we’re proud that our people always take the initiative to step forward and do the needful when the interests of our users are at stake.
II. Support Each Other
We are committed to a supportive work environment, where employees have the opportunity to reach their fullest potential. Our people are expected to do their utmost to create a workplace culture that is free of harassment, intimidation, bias, and unlawful discrimination.
Equal Opportunity Employment
Employment here is based solely upon individual merit and qualifications directly related to professional competence. We strictly prohibit unlawful discrimination or harassment on the basis of race, color, religion, veteran status, national origin, ancestry, pregnancy status, sex, gender identity or expression, age, marital status, mental or physical disability, medical condition, sexual orientation, or any other characteristics protected by law. We also make all reasonable accommodations to meet our obligations under laws protecting the rights of the disabled.
Harassment, Discrimination, and Bullying
We prohibit discrimination, harassment, and bullying in any form – verbal, physical, or visual. If you believe you’ve been bullied or harassed by anyone at Amazing Electronics, or by an Amazing Electronics partner or vendor, we strongly encourage you to immediately write to our Human Resources Department at email@example.com. Similarly, supervisors and managers who learn of any such incident should immediately report it to our Human Resources Department. Our HR Team will investigate any complaints thoroughly and take appropriate action quickly.
Drugs and Alcohol
Consumption of alcohol and drugs of all kinds are completely banned at our offices.
We are committed to a violence-free work environment, and we will not tolerate any level of violence or the threat of violence in the workplace. Under no circumstances should anyone bring a weapon to work. If you become aware of a violation of this policy, immediately write to our Human Resources Department at firstname.lastname@example.org. In case of potential violence, contact the Local Police Station immediately and ask for help.
III. Avoid Conflicts of Interest
When you are in a situation in which competing loyalties could cause you to pursue a personal benefit for you, your friends, or your family at the expense of the organization or the customers, you may be faced with a conflict of interest. All of us should avoid conflicts of interest and circumstances that reasonably present the appearance of a conflict.
When considering a course of action, ask yourself whether the action you’re considering could create an incentive for you, or appear to others to create an incentive for you, to benefit yourself, your friends or family, or an associated business at the expense of the organization. If the answer is “yes,” the action you’re considering is likely to create a conflict of interest situation, and you should avoid it.
Below, we provide guidance in seven areas where conflicts of interest often arise:
- Personal Investments
- Outside Employment, Advisory Roles, Board Seats, and Starting Your Own Business
- Business Opportunities Found Through Work
- Friends and Relatives – Co-Worker Relationships
- Accepting Gifts, Entertainment, and Other Business Courtesies
- Use of Office Products and Services
In each of these situations, the rule is the same – if you are considering entering into a business situation that creates a conflict of interest, doesn’t. If you are in a business situation that may create a conflict of interest, or the appearance of a conflict of interest, review the situation with our Human Resources Team. Finally, it’s important to understand that as circumstances change, a situation that previously didn’t present a conflict of interest may present one.
Avoid making personal investments in companies that are our competitors or business partners when the investment might cause, or appear to cause, you to act in a way that could harm us.
When determining whether a personal investment creates a conflict of interest, consider the relationship between the business of the outside company, our business, and what you do at Amazing Electronics, including whether the company has a business relationship with us that you can influence, and the extent to which the company competes with us.
You should also consider
- any overlap between your specific role at Amazing Electronics and the company’s business,
- the significance of the investment, including the size of the investment in relation to your net worth,
- whether the investment is in a public or private company,
- your ownership percentage of the company, and
- the extent to which the investment gives you the ability to manage and control the company.
Investments in venture capital or other similar funds that invest in a broad cross-section of companies that may include our competitors or business partners generally do not create conflicts of interest.
However, a conflict of interest may exist if you control the fund’s investment activity.
Outside Employment, Advisory Roles, Board Seats, and Starting Your Own Business
Avoid accepting employment, advisory positions, or board seats with our competitors or business partners when your judgment could be or could appear to be, influenced in a way that could harm us. Additionally, because board seats come with fiduciary obligations that can make them particularly tricky from a conflict of interest perspective, you should write to email@example.com before accepting a board seat with any outside company. Finally, do not start your own business if it will compete with us.
Business Opportunities Found Through Work
Business opportunities discovered through your work here belong first to Amazing Electronics, except as otherwise agreed to by it.
Developing or helping to develop outside inventions that
- relate to our existing or reasonably anticipated products and services,
- relate to your position at Amazing Electronics, or
- are developed using Amazing Electronics corporate resources may create conflicts of interest and therefore prohibited.
If you have any questions about potential conflicts or intellectual property ownership involving an outside invention or other intellectual property, write to our Human Resources Department at firstname.lastname@example.org.
Friends and Relatives; Co-Worker Relationships
Avoid participating in the management of or decision-making regarding potential or existing Amazing Electronics business relationships that involve your relatives, spouse, or significant other, or close friends. This includes being the hiring manager for a position for which your relative or close friend is being considered or being a relationship manager for a company associated with your spouse or significant other.
To be clear, just because a relative, spouse/significant other, or close friend works at Amazing Electronics or becomes an Amazing Electronics competitor or business partner doesn’t mean there is a conflict of interest.
However, if you are also involved in that Amazing Electronics business relationship, it can be very sensitive.
The right thing to do in that situation is to discuss the relationship with our Human Resources Team.
Finally, romantic relationships between co-workers can, depending on the work roles and respective positions of the co-workers involved, create an actual or apparent conflict of interest.
If a romantic relationship does create an actual or apparent conflict, it may require changes to work arrangements or even the termination of employment of either or both individuals involved.
Consult our Human Resources Team for additional guidance on this issue.
Accepting Gifts, Entertainment, and Other Business Courtesies
Accepting gifts, entertainment, and other business courtesies from an Amazing Electronics competitor or business partner can easily create the appearance of a conflict of interest, especially if the value of the item is significant.
Generally, acceptance of inexpensive “token” non-cash gifts is permissible. In addition, infrequent and moderate business meals and entertainment with clients and infrequent invitations to attend local sporting events and celebratory meals with clients can be appropriate aspects of many of our business relationships, provided that they aren’t excessive and don’t create the appearance of impropriety. Before accepting any gift or courtesy, consult the HR Team, and be aware that you may need to obtain a manual approval.
Use of Office Products and Services
Avoiding potential conflicts of interest also means that you should not use office products, services, internal tools, or information in a way that improperly benefits you or someone you know or creates the appearance that you have an unfair advantage over users outside of the organization.
IV. Preserve Confidentiality
We get a lot of press attention around our innovations and our culture, and that’s usually fine. However, certain kinds of company information, if leaked prematurely into the press or to competitors, can hurt our product launches, eliminate our competitive advantage, and prove costly in other ways. Our responsibilities extend beyond not revealing Confidential Company materials – we must also:
- properly secure, label, and (when appropriate) dispose of confidential company material,
- safeguard the confidential information that we receive from others under non-disclosure agreements,
- take steps to keep our trade secrets and other confidential intellectual property secrets.
Make sure that information that is classified as “Need to Know” or “Confidential” in our Data Classification Guidelines is handled in accordance with those Guidelines and our Data Security Policy. At times, a particular project or negotiation may require you to disclose Need to Know or Confidential information to an outside party: Disclosure of that information should be on an “only as needed” basis and only under a non-disclosure agreement. In addition, Our policy may require a prior security assessment of the outside party that is to receive the confidential information. Be sure to conduct the appropriate due diligence and have the appropriate agreement in place before you disclose the information.
There are, of course, “gray areas” in which you will need to apply your best judgment in making sure you don’t disclose any confidential information.
And don’t forget about pictures you and your guests take at the office – it is up to you to be sure that those pictures don’t disclose confidential information.
Finally, some of us will find ourselves having family or other personal relationships with people employed by our competitors or business partners. As in most cases, common sense applies. Don’t tell your significant other or family members anything confidential, and don’t solicit confidential information from them about their company.
Just as you are careful not to disclose confidential company information, it’s equally important not to disclose any confidential information from our partners. Don’t accept confidential information from other companies without first having all parties sign an appropriate Non-disclosure Agreement approved by Legal. Even after the agreement is signed, try only to accept as much information as you need to accomplish your business objectives.
We respect our competitors and want to compete with them fairly. But we don’t want their confidential information. The same goes for confidential information belonging to any of your former employers. If an opportunity arises to take advantage of a competitor’s or former employer’s confidential information, don’t do it.
You probably know that our policy is to be extremely careful about disclosing confidential proprietary information. Consistent with that, you should also ensure your outside communications (including online and social media posts) do not disclose confidential proprietary information or represent (or otherwise give the impression) that you are speaking on behalf of the organization unless you’re authorized to do so by the authority. The same applies to communications with the press. Finally, check with your senior and HR Team before accepting any public speaking engagement on behalf of the company.
V. Protect Company Assets
We have a well-earned reputation for generosity with our employee benefits and openness with confidential information shared within the company. Our ability to continue these practices depends on how well we conserve company resources and protect company assets and information.
Our intellectual property rights (our trademarks, logos, copyrights, trade secrets, “know-how”, and patents) are among our most valuable assets. Unauthorized use can lead to their loss or serious loss of value. You must respect all copyright and other intellectual property laws, including laws governing the fair use of copyrights, trademarks, and brands. You must never use our (or our affiliated entities’) logos, marks, or other protected information or property for any business or commercial venture without pre-clearance from the Marketing Team. We strongly encourage you to report any suspected misuse of trademarks, logos, or other intellectual property to email@example.com at your earliest.
Likewise, respect the intellectual property rights of others. Inappropriate use of others’ intellectual property may expose us and you to criminal and civil fines and penalties. Please seek legal advice before you solicit, accept, or use proprietary information from individuals outside the company or let them use or have access to our proprietary information. You should also check with legal if developing a product that uses content not belonging to us.
A word about open source – we are committed to open source ecosystem development. Consistent with our policy of respecting the valid intellectual property rights of others, we strictly comply with the license requirements under which open source software is distributed. Failing to do so may lead to legal claims against us, as well as significant damage to the company’s reputation and its standing in the open-source community. Please seek legal guidance from the Open Source Programs Office before incorporating open source code into any of our products, services, or internal projects.
Amazing Electronics gives us the tools and equipment we need to do our jobs effectively, but counts on us to be responsible and not wasteful with the company stuff we are given. Nobody’s going to complain if you snag an extra cup of coffee on Friday morning, but company funds, equipment, and other physical assets are not to be requisitioned for purely personal use. Not sure if a certain use of company assets is okay? Please ask your manager or Human Resources.
Our communication facilities (which include both our network and the hardware that uses it, like computers and mobile devices) are a critical aspect of our company’s property, both physical and intellectual. Be sure to follow all security policies. If you have any reason to believe that our network security has been violated – for example, you lose your laptop or smartphone or think that your network password may have been compromised – please promptly report the incident to firstname.lastname@example.org.
If you’re not careful, people may steal your stuff. Always secure your laptop, important equipment, and your personal belongings, even while on office premises. Always wear your I-Card visibly while on site. Don’t tamper with or disable security and safety devices. Watch people who “tailgate” behind you through our doors. If you don’t see an I-Card, please ask for it (and, as appropriate, direct the person to a receptionist for assistance). Promptly report any suspicious activity to your senior.
Use of Company Equipment and Facilities
Anything you do by using the company’s corporate electronic facilities (e.g., our computers, mobile devices, network, etc.) or store on our premises (e.g., letters, memos, and other documents) might be disclosed to people inside and outside the company. For example, we may be required by law (e.g., in response to a subpoena or warrant) to monitor, access, and disclose the contents of corporate email, voicemail, computer files, and other materials on our electronic facilities or on our premises. In addition, the company may monitor, access, and disclose employee communications and other information on our corporate electronic facilities or on our premises where there is a business need to do so, such as protecting employees and users, maintaining the security of resources and property, or investigating suspected employee misconduct.
We collect and store personal information from employees around the world. Access this data only in line with local law and our internal policies, and be sure to handle employee data in a manner that is consistent with our Data Classification and Employment Data Guidelines and other company policies.
VI. Ensure Financial Integrity and Responsibility
Financial integrity and fiscal responsibility are core aspects of corporate professionalism. This is more than accurate reporting of our financials, though that’s certainly important. The money we spend on behalf of the company is not ours; it’s the company’s and, ultimately, our shareholders’. Each person at the company – not just those in Finance – has a role in making sure that money is appropriately spent, our financial records are complete and accurate, and internal controls are honored. This matters every time we hire a new vendor, expense something to the company, sign a new business contract, or enter into any deals on the company’s behalf.
To make sure that we get this right, we maintain a system of internal controls to reinforce our compliance with legal, accounting, tax, and other regulatory requirements in every location in which we operate.
Stay in full compliance with our system of internal controls, and don’t hesitate to contact the HR Team if you have any questions. What follows are some core concepts that lie at the foundation of financial integrity and fiscal responsibility here at Amazing Electronics.
Spending Company’s Money
A core company value has always been to spend money wisely. When you submit an expense for reimbursement or spend money on the company’s behalf, make sure that the cost is reasonable, directly related to company business, and supported by appropriate documentation. If you’re uncertain about whether you should spend money or submit an expense for reimbursement, check with the HR Team.
Signing a Contract
Each time you enter into a business transaction on the company’s behalf, there should be documentation recording that agreement, approved by the HR Department. Signing a contract on behalf of the company is a very big deal. Never sign any contract on behalf of the company unless all of the following are met:
- You are authorized to do so under our Signature Authority and Approval Policy. If you are unsure whether you are authorized, ask the HR Team.
- The contract has been approved by the authority concerned. If you are using an approved company form contract, you don’t need further approval unless you have made changes to the form contract or are using it for other than its intended purpose.
- You have studied the contract, understood its terms, and decided that entering into the contract is in the company’s interest
All contracts at Amazing Electronics should be in writing and should contain all of the relevant terms to which the parties are agreeing – we do not permit “side agreements,” oral or written.
If your job involves the financial recording of our transactions, make sure that you’re fully familiar with all of the company policies that apply.
Reporting Financial or Accounting Irregularities
It goes without saying (but we’re going to say it anyway) that you should never, ever interfere in any way with the auditing of the company’s financial records. Similarly, you should never falsify any record or account, including time reports, expense accounts, and any other company records.
Familiarize yourself with our Reporting of Financial and Accounting Concerns Policy. If you suspect or observe any of the conduct mentioned above or, for that matter, any irregularities relating to financial integrity or fiscal responsibility, no matter how small, immediately report them to the concerned authority.
As the company grows, we enter into more and more deals with suppliers of equipment and services. We should always strive for the best possible deal for the company. This almost always requires that you solicit competing bids to make sure that you’re getting the best offer. While the price is very important, it isn’t the only factor worth considering. Quality, service, reliability, and the terms and conditions of the proposed deal may also affect the final decision.
It’s important that we keep records for an appropriate length of time. The Company Records Retention Policy suggests minimum record retention periods for certain types of records. These are great guidelines, but keep in mind that legal requirements, accounting rules, and other external sources sometimes specify longer retention periods for certain types of records, and those control where applicable. In addition, if asked by Legal to retain records relevant to a litigation, audit, or investigation, do so until legal tells you retention is no longer necessary. If you have any questions regarding the correct length of time to retain a record, contact the HR Team.
VII. Obey the Law
We take the responsibility to comply with laws and regulations very seriously and each of us is expected to comply with applicable legal requirements and prohibitions. While it’s impossible for anyone to know all aspects of every applicable law, you should understand the major laws and regulations that apply to your work. Take advantage of the HR Team to assist you here. A few specific laws are easy to violate unintentionally and so are worth pointing out here:
If you are in any way involved in sending or making available company products, services, software, equipment, or any form of technical data from one country to another, work with your senior to be absolutely sure that the transaction stays well within the bounds of applicable laws. If you or your manager are not sure, please contact the HR Team.
Most countries have laws – known as “antitrust,” “competition,” or “unfair competition” laws – designed to promote free and fair competition.
Generally speaking, these laws prohibit
- arrangements with competitors that restrain trade in some way,
- abuse of intellectual property rights, and
- use of market power to unfairly disadvantage competitors.
Certain conduct is absolutely prohibited under these laws and could result in your imprisonment, not to mention severe penalties for the company.
Examples of prohibited conduct include:
- agreeing with competitors about prices
- agreeing with competitors to rig bids or to allocate customers or markets
- agreeing with competitors to boycott a supplier or customer
Other activities can also be illegal, unfair, or create the appearance of impropriety.
Such activities include:
- sharing competitively sensitive information (e.g., prices, costs, market distribution, etc.) with competitors
- entering into a business arrangement or pursuing a strategy with the sole purpose of harming a competitor
- using the company’s size or strength to gain an unfair competitive advantage
Although the spirit of these laws is straightforward, their application to particular situations can be quite complex, we are committed to competing fair and square, so please contact the HR Team if you have any questions about the antitrust laws and how they apply to you. Any personnel found to have violated Company’s Antitrust Policies will, subject to local laws, be disciplined, up to and including termination of employment. If you suspect that anyone at the company is violating the competition laws, notify the HR Team immediately.
Insider Trading Laws
As we said earlier, internally we share information, including non-public information, about the company’s business operations pretty freely. In addition, you may overhear a hallway conversation or come across a memo at a copy machine, either of which might involve confidential information. To use this non-public information to buy or sell the stock, or to pass it along to others so that they may do so, could constitute insider trading. Insider trading not only violates this Code of Conduct, but it also violates the law. Don’t do it.
Like all businesses, we are subject to lots of laws, both India and non-India, that prohibit bribery in virtually every kind of commercial setting. The rule for us at Amazing Electronics is simple – don’t bribe anybody, anytime, for any reason.
You should be careful when you give gifts and pay for meals, entertainment, or other business courtesies on behalf of the company. We want to avoid the possibility that the gift, entertainment, or other business courtesy could be perceived as a bribe, so it’s always best to provide such business courtesies infrequently and, when we do, to keep their value moderate.
Dealing with Government Officials
Offering gifts, entertainment, or other business courtesies that could be perceived as bribes becomes especially problematic if you’re dealing with a Government Official. “Government Officials” include any government employee; candidate for public office; or employee of government-owned or -controlled companies, public international organizations, or political parties. Several laws around the world, specifically prohibit offering or giving anything of value to Government Officials to influence official action or to secure an improper advantage. This not only includes traditional gifts, but also things like meals, travel, political or charitable contributions, and job offers for GOs’ relatives. Never give gifts to thank GOs for doing their jobs. By contrast, it can be permissible to make infrequent and moderate expenditures for gifts and business entertainment for GOs that are directly tied to promoting our products or services (e.g., providing a modest meal at a day-long demonstration of company services). Payment of such expenses can be acceptable (assuming they are permitted under local law) but may require pre-approval from the concerned team.
We aspire to be a different kind of company. It’s impossible to spell out every possible ethical scenario we might face. Instead, we rely on one another’s good judgment to uphold a high standard of integrity for ourselves and our company. We expect all our people to be guided completely by this Code of Conduct. Sometimes, identifying the right thing to do isn’t an easy call. If you aren’t sure, don’t be afraid to ask questions to the authority concerned.
And remember… don’t be evil, and if you see something that you think isn’t right – speak up!
This page was last updated on 24/09/2020