The Global Code of Conduct ('Code') is relevant to MORE FZ-LLC and all its direct or indirect majority-owned subsidiaries, collectively known as 'MORE' or the 'Company'.
Maintaining Authentic Records
MORE is dedicated to abiding by the law, pertinent technical, and professional benchmarks. We ensure the creation of financial and other documents promptly, reflecting truthfully and comprehensively. Our records, which cover all interactions between our firm and outside entities, along with all spending and labor charges, are meticulous and honest. Our goal is to uphold stringent financial, operational, and compliance checks alongside a solid risk management approach. Avoiding Interest Conflicts.
Conflict of interest
Our priority is MOREs'' best interests. Everyone is expected to operate in a manner that prevents actual or possible conflicts of interest, whether within MORE or with our clientele or suppliers. An interest conflict arises when personal gains don't match MOREs' objectives.
For instance, favoring a relative with a supplier deal at MORE, even if they aren't the optimal choice. Or hiring a friend's relative when they might not be the most qualified.
This implies using your position and MOREs' resources - tangible and intellectual - exclusively for valid business reasons. Using company tools, digital resources, or ideas for personal endeavors is discouraged. Always make choices free from financial or personal motivations that might cloud your discernment. Avoid showing bias to anyone due to personal connections, including relatives or acquaintances.
Steer clear of associations that might appear or lead to conflicts and promptly reveal any personal or professional ties that could be seen as conflicting with MOREs'' interests. This extends to actions that might seem improper or influence your role execution.
Avoid taking on external roles or tasks that could disrupt your duties or tarnish MOREs'' image. All potential interest conflicts, such as personal ties with clients, suppliers, or company colleagues, especially if it involves authority, should be promptly reported to your supervisor Chantal Aoun, at [email protected] for assessment.
DATA
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a. Communications
All communications at MORE should be professional, clear, and aligned with our mission.
Both traditional and contemporary communication methods, including social media, must be utilized responsibly. Misusing communication or sharing information without permission (e.g. images, comments, links, etc.) could pose legal or reputational risks to individuals, MORE, our clients, or others.
This encompasses harmful, false, discriminatory comments or any remarks that violate the company's anti-harassment policies on any platform. Moreover, statements representing MORE must not be made without authorization.
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b. Protecting Intellectual Property and Confidentiality
The information within MOREs' systems, our intellectual property, and confidential details are among our most treasured assets. This encompasses our brands, patents, copyrights, trade secrets, software, websites, apps, and other exclusive materials. It also includes financial details about the company and client data shielded by Non-Disclosure Agreements.
It's crucial to defend this information from unauthorized distribution or use. Always be cautious about where and how you discuss confidential matters. Do not share such information without a valid business reason. This confidentiality commitment remains even after ending your association with MORE.
Receiving confidential details from outsiders requires prior written consent. We also respect the rights of others, understanding the importance of doing so for our business and reputation.
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c. Data Privacy and Ethical Digital Practices
MORE honors the privacy rights of our employees, clients, vendors, and partners. We are dedicated to managing personal data ethically and according to local and international standards.
Personal data should be processed for specific, clear, and valid purposes. It must be accurate, relevant, and shielded from unauthorized access. If transferred to third parties, it should be properly protected. More details can be found in the Data Privacy Policy.
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d. Information and Technology Security
MORE equips you with the technology needed for your role, which should be used responsibly. The tools we provide, from email systems to software, can be vulnerable to cyber threats.
It's essential to use technology for valid business reasons, ensuring no harm comes to the company. Occasional personal use of the company's IT resources is allowed as per company policies, as long as there's no conflict of interest. Misusing or compromising our IT resources is prohibited.
MORE might monitor the usage of its IT resources, with some legal exceptions.
Fair Employment, Diversity & Inclusion
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a. Harassment
We stand firmly against any action or behavior that is demeaning, intimidating, or hostile. Everyone deserves a workspace that is void of any form of harassment, be it physical, mental, sexual, or verbal. While giving feedback, it's crucial to communicate respectfully, bearing in mind cultural nuances.
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b. Diversity and Inclusion
Our commitment is to ensure equal opportunities for all, tapping into the broadest talent spectrum to get the best candidates.
We cherish diversity and commit to non-discrimination at any employment phase based on race, nationality, faith, ethnicity, disability, age, sexual orientation, political beliefs, union affiliation, gender, marital status, or any other category protected by relevant laws.
Employment decisions, from recruitment to termination, are grounded in merit, skills, performance, and organizational needs.
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c. Training
Our extensive compliance program includes ethical training related to this Code for our colleagues. We expect full adherence to assigned training responsibilities, emphasizing the obligations within Employment Contracts and relevant Non-Disclosure Agreements.
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d. Compensation and Benefits
Our compensation meets the local legal minimum requirements, and we provide all benefits mandated by law.
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e. Working Conditions
We adhere to International Labour Organisation standards and local laws regarding work hours, rest periods, and annual leaves. Overtime is always voluntary.
Employees have the freedom to end their association with due notice as per employment agreements and applicable laws.
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f. Freedom of Association and Collective Bargaining
We respect individuals' rights to partake in collective bargaining and exercise their freedom of association, adhering to local laws, agreements, and traditions.
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g. Discipline and Grievance Mechanisms
We've instituted a clear and just disciplinary system to address concerns about a colleague's performance or behavior.
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h. Migrant Workers
A 'migrant worker' is someone employed in a country they aren't native to. MORE ensures their employment adheres to the host country's immigration and labor laws.
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i. Health & Safety
MORE aims for optimal occupational health and safety standards. We abide by all relevant regulations, ensuring a safe and health-conducive work environment.
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j. Political Involvement
MORE abstains from financially supporting political campaigns or activities. Individuals have the right to engage in legitimate political activities, but any opinions expressed must be distinctly personal, not representing MORE.
Prevention of Financial Crime
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a. Anti-Bribery and Corruption
MORE has zero tolerance for any form of bribery or influence peddling. We comply with the anti-bribery and corruption laws of the countries where we operate, as well as those that apply across borders.
We do not offer, pay, or accept bribes or kickbacks for any purpose, either directly or through a third party. We do not make facilitation payments or permit others to make them on our behalf.
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b. Gifts and Hospitality
We occasionally use hospitality and promotional opportunities to present our services, establish relationships or attract new clients and customers. Modest gifts, entertainment and hospitality can help build good working relationships with clients, customers, suppliers and stakeholders.
However, gifts, entertainment and hospitality should not be offered or accepted if these can be viewed as improperly influencing a business decision.
Before offering or accepting any gifts or hospitality, we must ensure that the value is reasonable and allowed under MORE internal policies and standards.
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c. Sponsorship & Donations
MORE supports local community organizations through voluntary contributions. We also use sponsorships as part of our marketing activities.
Charitable contributions, donations and sponsorship arrangements must be appropriate, reasonable in terms of value and frequency and approved in advance in line with MORE internal policies and standards. We must not use such arrangements to influence business decisions, disguise political payments or for any other improper purpose.
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d. Third Parties
The nature of our work requires us to interact frequently with third parties. These third parties may include clients, customers, suppliers, distributors, resellers, lobbyists, consultants and any other person or entity that is not a MORE company or Colleague.
Interactions with government officials or state organizations present particular risks that must be adequately addressed. Since they often control decisions or processes that can affect our business success, we must hold ourselves to the highest ethical standards when working with public officials.
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e. Anti-Money Laundering ('AML')
MORE complies with all applicable legal and regulatory AML requirements in those countries in which we operate, including reporting of suspected or actual cases in line with disclosure requirements. Violation of AML laws and regulations can lead to civil and criminal penalties, including fines, the disqualification of directors and imprisonment.
We prohibit the perpetration of any activity which can be interpreted as money laundering and terrorist financing, and ensure that we take appropriate action to prevent and detect any such cases.
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Fraud
MORE does not tolerate any form of fraud by attempting to obtain any improper benefit through deception, making false claims or acting fraudulently. This includes the misuse of MOREs' intellectual property and proprietary information.
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g. Sanctions
MORE complies with all trade laws and restrictions within the countries in which we operate. This may include sanctions and trade restrictions which stop us working in certain countries, or with individuals or entities.
We aim to ensure regulatory compliance by establishing an internal framework that minimizes the risk of trade sanctions, breaches and abuse of our products and services for money laundering purposes.
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h. Antitrust
MORE believes in free and open competition. We work hard to win against the competition by providing better products and services, not by unethical or illegal business methods. We never willingly undertake actions which would restrict free and fair competition, such as working with competitors to rig bids, exchange sensitive commercial information, fix prices or share markets.
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i. Insider Trading
MORE complies with national and international laws on insider dealing.
We do not use or communicate material non-public information about MORE or any other company for personal financial gain or advantage. Such information may be obtained in a wide range of ordinary business situations which if disclosed, might influence a person's decision to buy, sell or hold a company's securities/shares.
Further information regarding insider trading can be found in the Share Dealing Code and the Market Abuse Regulation Manual.
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j. Tax Evasion
MORE strives to comply with all local tax legislation in the countries where we operate and pay the right amount of tax for those activities. We have a zero-tolerance approach to tax evasion and always manage our tax affairs ethically. We also ensure we don't facilitate tax evasion by other parties, even accidentally.
