Devito Codes Ltd

Global Code of Conduct & Compliance Policy

1. Purpose

This Code of Conduct sets forth the ethical standards Devito Codes Ltd expects of its employees, management, contractors, and partners. We aim to comply with, or exceed, all relevant laws and regulations in every jurisdiction where we do business, including the UK, Brazil, EU, Norway, USA, Australia, and others. Our commitment is to maintain integrity, respect human rights, protect the environment, and foster an inclusive, harassment-free workplace.

2. Scope and Applicability

This Code applies to:

  • All Employees, including senior leadership, managers, and staff.
  • Third-Party Representatives, such as consultants, agents, subcontractors, and distributors who act on Devito Codes Ltd’s behalf or represent our interests.

We also expect our major suppliers to adhere to similar standards, reflecting the expectations of our global partners.

3. Compliance with Laws and Regulations

  1. Local and International Laws
    • We strictly comply with the UK Bribery Act (2010), the US Foreign Corrupt Practices Act (FCPA), relevant EU directives and regulations, Norwegian anti-corruption statutes, Australian criminal code for bribery offenses, and other local laws in the regions where we provide services.
    • We observe GDPR and other data protection/privacy laws in the EU, the UK Data Protection Act, and similar regulations elsewhere.
  2. Global Partner Standards
    • In addition to local law, we strive to meet or exceed the compliance standards of our multinational clients and technology partners.

4. Anti-Bribery and Anti-Corruption

  1. Zero Tolerance
    • Devito Codes Ltd prohibits any form of bribery, facilitation payments, or kickbacks, either directly or indirectly.
    • We do not offer, promise, or give anything of value to gain an improper business advantage.
  2. Gifts and Hospitality
    • Modest gifts or hospitality are permitted only if lawful, reasonable in value, and not intended to unduly influence a business decision. Any gift or entertainment must comply with internal approval guidelines.
  3. Dealing with Public Officials
    • Special caution is required when interacting with government officials, state employees, or representatives of state-owned enterprises. Any benefit offered to such persons must be lawful and transparent.
  4. Monitoring and Due Diligence
    • We conduct due diligence on high-risk third parties and maintain accurate records of all transactions. We promptly report suspicious or corrupt behavior to leadership.

5. Fair Competition and Trade

  1. Antitrust and Competition
    • Devito Codes Ltd upholds fair competition principles: no price fixing, bid rigging, or collusion with competitors.
  2. Export Controls
    • We observe applicable export/import regulations, sanctions, and trade compliance laws, especially relevant when providing HPC software solutions internationally.

6. Data Privacy and Confidentiality

  1. Data Protection
    • We comply with EU GDPR, UK Data Protection Act, US and other applicable data privacy laws. We securely handle personal data of employees, customers, and partners.
  2. Confidential Information
    • All proprietary data, trade secrets, client information, or research results must be kept confidential and only shared on a “need-to-know” basis.

7. Human Rights and Labor Standards

  1. No Forced or Child Labor
    • We do not tolerate forced, bonded, or child labor in our supply chain. We adhere to the UK Modern Slavery Act and relevant ILO conventions.
  2. Fair Treatment
    • We are committed to fair wages, lawful working hours, and safe conditions for our employees and contractors, consistent with local labor laws.
  3. Freedom of Association
    • We respect employees’ rights to form or join trade unions and bargain collectively where permitted by law.

8. Harassment and Non-Discrimination

  1. Equal Opportunity
    • All decisions on hiring, promotion, and compensation are based on merit, without discrimination on the basis of race, ethnicity, sex, religion, sexual orientation, gender identity, disability, or other protected characteristics.
  2. Harassment-Free Workplace
    • Any form of harassment, bullying, or hostility is strictly prohibited. We foster a respectful culture with no tolerance for offensive language, intimidation, or harassment.

9. Environmental Stewardship

  1. Resource Efficiency
    • Although primarily a software company, we aim to reduce our carbon footprint by minimizing energy usage, promoting efficient HPC solutions, and encouraging responsible consumption of resources in our offices.
  2. Compliance
    • We comply with environmental regulations of the regions we operate in, and we consider the environmental impact of HPC computing.

10. Implementation, Training, and Monitoring

  1. Training and Awareness
    • All employees and relevant third parties receive an introduction to this Code and periodic training on anti-corruption, data privacy, and workplace conduct.
  2. Monitoring and Audits
    • We maintain internal controls and may conduct compliance audits or reviews to ensure adherence to this policy and our partners’ standards.

11. Reporting Violations and Whistleblower Protection

  1. Duty to Report
    • Anyone who becomes aware of a potential violation of this Code, or who suspects any form of unethical or illegal behavior, is required to promptly alert Devito Codes Ltd by emailing compliance@devitocodes.com.. All reports will be treated with respect and confidentiality, and investigated in a fair and timely manner.
  2. Non-Retaliation
    • Devito Codes Ltd forbids retaliation against anyone who makes a good-faith report or cooperates in an investigation of alleged misconduct.

12. Enforcement and Discipline

  1. Investigations
    • Reported violations will be investigated promptly and impartially, with confidentiality maintained as appropriate.
  2. Consequences
    • Confirmed breaches may result in disciplinary measures, including termination of employment or contracts, and potentially referral to law enforcement if criminal activity is involved.
  3. Partner Consequences
    • If a third-party supplier or agent is found in violation, Devito Codes Ltd may terminate the relationship or take other legal action.

13. Governance and Updates

  • Responsibility: The CEO oversees this Code’s enforcement.
  • Revision: This Code may be revised periodically to reflect changes in law, best practices, or partner requirements. All employees and partners are responsible for remaining informed about updates.

14. Certification

All Devito Codes Ltd personnel, as well as relevant suppliers and service providers, must:

  1. Acknowledge they have read and understood this Global Code of Conduct.
  2. Agree to comply with all policies and procedures described herein.