ConnectedSky Legal & Corporate Consultants Limited (hereinafter referred to as “ConnectedSky”), including its representative offices and affiliates, will conduct its business in an ethical and proper manner at all times and in full compliance with all laws and regulations. We view these as the fundamental standards underlying our approach to doing business.
A good reputation is difficult to earn, easy to lose and almost impossible to regain. We must not lose sight of this.
We strive for the highest level of integrity and ethics in our dealings with each other, our clients, our partners, public and government establishments. We are relying on your integrity, continued dedication and adherence to the requirements in this Code of Conduct to help keep us there. Consequently, each director, officer and employee is expected to read and become familiar with the ethical standards described in this Code.
The Company's Chief Executive Officer is responsible for setting the standards of business conduct contained in this Code and updating these standards as it deems appropriate to reflect changes in the legal and regulatory framework applicable to the Company, the business practices within the Company's industry, the Company's own business practices, and the prevailing ethical standards of the communities in which the Company operates. While the Company's Chief Executive Officer will oversee the procedures designed to implement this Code to ensure that they are operating effectively, it is the individual responsibility of each director, officer and employee of the Company to comply with this Code.
Compliance with Laws and Regulations
Every Service Provider must comply with all laws and regulations that apply to that Service Provider, its employees and its business activities (“applicable laws and regulations”).
Conflicts of interest; corporate opportunities
Except as provided below (disclosure and approval) directors, officers and employees should not be involved in any activity, which creates or gives the appearance of a conflict of interest between their personal interests and the Company's interests. In particular, except as provided below (disclosure and approval) no director, officer or employee shall:
Employees who are not directors or officers shall notify their immediate supervisor of the existence of any actual or potential conflict of interest providing full disclosure of the circumstances.
Directors and officers shall notify the Company's Chief Executive Officer of the existence of any actual or potential conflict of interest providing full disclosure of the circumstances.
No Bribery or Money Laundering
The Company has no tolerance for bribery or corruption in any aspect of its business or in any country in which we operate. Our Company policy prohibits engaging in any form of corruption, bribery, kickback, extortion, embezzlement or money laundering. We are committed not only to complying with all applicable laws and regulations regarding such activities, including but not limited to the U.K. Bribery Act and the Anti-corruption conventions adopted by Cyprus Law, but also to acting with integrity and the highest ethical standards.
We shall not participate in, facilitate or permit any form of corruption, bribery, kickback, extortion, embezzlement or money laundering, with respect to any other legal or physical person.
The Company is committed to promoting the values of honesty, integrity and fairness in the conduct of its business and sustaining a work environment that fosters mutual respect, openness and individual integrity. Directors, officers and employees are expected to deal honestly and fairly with the Company's customers, suppliers, competitors and other third parties. To this end, directors, officers and employees shall not:
It is our Company policy to comply with accepted accounting rules, controls and disclosures at all times and to ensure that the auditors are provided accurate information. ConnectedSky will not knowingly participate in any scheme to avoid such accounting rules, controls or disclosures. To this end, the Company shall:
Conﬁdential and Proprietary Information
We shall safeguard our clients’ conﬁdential and proprietary information. This obligation includes using commercially reasonable means to safeguard information technology systems on which Company information is stored or transmitted.
In addition, we shall refuse any improper access to conﬁdential or proprietary information of any other company, including competitors or others.
Directors, officers and employees shall maintain the confidentiality of all information entrusted to them by the Company or its suppliers, customers or other business partners, except when disclosure is authorized by the Company or legally required.
Confidential information includes (1) information marked "Confidential," "Private," "For Internal Use Only," or with other similar legends, (2) sensitive information relating to current and future services, (3) business or marketing plans or projections, (4) earnings and other internal financial data, (5) personnel information, (6) supply and customer lists, and (7) other non-public information that, if disclosed, might be of use to the Company's competitors, or harmful to the Company or its suppliers, customers or other business partners.
To avoid inadvertent disclosure of confidential information, directors, officers and employees shall not discuss confidential information with or in the presence of any unauthorized persons, including family members and friends.
Directors, officers and employees are personally responsible for protecting those Company assets that are entrusted to them and for helping to protect the Company's assets in general.
Directors, officers and employees shall use the Company's assets for the Company's legitimate business purposes only.
Directors, officers and employees shall respect the intellectual property rights of our clients and partners, and shall comply with applicable laws and regulations related to patents, copyrights, trademarks and business/trade secrets.
It is our Company policy to provide all legal information that is as accurate as possible to guide our clients in the proper way. Directors, officers and employees shall never knowingly provide or use any false information.
We shall promptly evaluate and resolve any suspected instances of noncompliance with applicable laws and regulations, and we reserve the right to undertake to report such noncompliance matters aﬀecting the Company to any relevant establishment.
The Company will not allow any retaliation against a director, officer or employee who acts in good faith in reporting any such violation and will ensure this in accordance with an internal enforcement mechanism put in place for this purpose.
ConnectedSky shall never discriminate in hiring or employment practices on the basis of race, national origin, gender, age, sexual orientation, citizenship, marital status, disability, veteran status or religion. ConnectedSky shall provide a workplace free from unlawful harassment.
ConnectedSky shall maintain a safe and sanitary workplace that includes appropriate protective equipment, and is in compliance with applicable environmental, health and safety laws, rules and regulations.
ConnectedSky shall comply with all applicable laws and regulations regarding employment, including but not limited to such laws and regulations related to minimum wage, maximum work hours, overtime and beneﬁts.
ConnectedSky shall maintain and operate its business in an environmentally responsible manner. We recognize the importance of our environment and natural resources, we embrace the responsibility to society for prudently using natural resources and preventing harm to the environment, and therefore, we shall comply with applicable environmental laws and regulations.
ConnectedSky shall communicate the standards set forth herein to its employees and monitor their conformity to them.