Headquarters

ITRIS Group
Industriestrasse 169
8957 Spreitenbach

+41 56 418 65 65
info@itris.ch


Contact

Our Code of Conduct

The good reputation of our corporate group as a provider of high-quality solutions and services in the fields of IT and medical technology is a decisive competitive advantage. A fundamental basis for the trust our customers, suppliers, and the public place in our group is the respect for and compliance with laws, regulations, and internal company principles. The corresponding actions and behavior of every employee are the prerequisite for this. The Code of Conduct formulates general requirements intended to provide standards and guidance for daily work, thereby contributing to the strengthening of our company's reputation.

Code of Conduct

Ethics and Conduct Guidelines for the ITRIS Group and its Affiliated Companies
1. Introduction

The success of our company is based not only on successful business policy but also on compliance with the highest moral and ethical standards, integrity, and the trust placed in us by customers, suppliers, and business partners. You, as our employees, create and enjoy this trust. Gaining and preserving it requires that all employees, as well as our suppliers and business partners, adhere to the following ethics and conduct guidelines. Corruption is the abuse of a position of trust for private gain. In business, we understand this to mean the purchase of an economically unjustifiable decision. Various forms fall under this definition: payment or receipt of bribes, but also subtler methods such as targeted “grooming” or nepotism. From a criminal law perspective, corrupt practices are not permitted and are punished as crimes with up to 5 years of imprisonment. Even with the first payment, a corrupt company makes itself vulnerable to blackmail. It is difficult to break out of the vicious cycle once it has begun. If a case of corruption is uncovered, the company’s good reputation is gone, the damage to reputation is great, and the subsequent slumps in turnover are painful. The ITRIS Group therefore demands a zero-tolerance stance toward corruption not only from employees but also from suppliers and business partners. By signing this Code of Conduct, you commit to complying with the conduct guidelines contained therein, performing your work with complete integrity, and reporting any violations you identify. (*For reasons of readability, the simultaneous use of male and female personal designations is avoided, and instead only one form is used. Naturally, this refers to both male and female persons.)

The Code of Conduct applies to all employees at all levels, including the Executive Board and the Board of Directors. We expect our business partners to adhere to it accordingly. Every employee is personally obligated to comply with the conduct guidelines contained in the Code of Conduct as well as the supplementary regulations. Each division manager or managing director is responsible for ensuring that the Code of Conduct is discussed with every employee once a year and signed on that occasion. Furthermore, they must monitor compliance with the code. The ethical principles and conduct guidelines of the ITRIS Group apply to all countries in which the company operates. A deviation is only permissible after approval by the Group Management if something else corresponds to local custom or should be tolerated in a particular country.

The following principles are intended to serve as a primary “compass” in ethically difficult situations for which the Code of Conduct does not contain a conduct guideline directly applicable to the specific case:

  • We are committed to high-quality customer orientation, delivering first-class performance through the extraordinary enthusiasm, commitment, professionalism, and integrity of our employees;
  • In our personal behavior, we adhere to the principles of legal compliance, honesty, fairness, transparency, as well as responsibility and loyalty toward the ITRIS Group and its business partners;
  • We clearly distinguish between the interests of the ITRIS Group and our private interests and avoid potential conflicts of interest;
  • We refrain from improperly pushing through the employment or promotion of family members or personal friends;
  • We respect the human dignity and rights of every person. We refrain from any discrimination against colleagues, employees, applicants, customers, and business partners based on age, gender, origin, disability, political views, and other legally protected categories;
  • We refrain from any sexual harassment and adhere to the ITRIS Group’s “Regulations on Sexual Harassment in the Workplace”;
  • In all cases of doubt where we are not sure whether our behavior meets the required ethical standards, we contact our direct superior or the Group Management of the ITRIS Group. To verify compliance with the above principles, answering the following questions may be useful in individual cases:
  • Are the measures I want to take legally permitted and do they correspond to the applicable values, guidelines, and regulations?
  • Have I adequately informed myself about the values, internal guidelines, and external regulations?
  • Do I personally have a moral problem with the intended measure?
  • Am I acting honestly, fairly, and responsibly?
  • Could I justify my actions to family members, friends, and colleagues?
  • Have I appropriately considered possible alternatives?
  • Have I consulted my colleagues and superiors at the workplace?
  • How will I likely judge my actions in retrospect?
  • How would I feel if my actions were made public the next day?
  • Could the ITRIS Group lose customers, suppliers, or business partners if they found out about my actions?

4.1 Inadmissible Gifts and Invitations Business partners or public officials must under no circumstances be offered, nor may personal payments or gifts and invitations exceeding the usual scope be accepted from them, in order to influence the conclusion of projects or other business or to fulfill other illegal purposes. Regardless of their value, gifts and invitations may never be accepted or given if they:

  • are directly related to a specific project (e.g., shortly before a customer’s decision to conclude a contract or with a direct reference to the business of public officials such as the granting of permits and the like), whereby promotional gifts of low value (such as pens with a company logo) are excluded. However, in this case, gifts such as wine bottles, boxes of chocolates, invitations to lunch, etc., must also be rejected.
  • are offered or extended with the recognizable intention of obtaining a consideration or favor;
  • take the form of cash or monetary benefits (e.g., gift vouchers);
  • are unusual or inappropriate. For example, gold jewelry, expensive watches, or flight tickets are inadmissible in any case. Furthermore, generous invitations such as for a weekend in a luxury hotel with a spouse, etc., are inadmissible.

4.2 Permissible Granting of Gifts and Invitations to Customers and Public Officials

  • Occasional gifts and other irregular benefits for reasons of courtesy to customers and public officials up to a maximum amount of CHF 100 are permissible if they are customary and appropriate in type and value and are not related to a specific project or business. Several gifts to the same beneficiary are to be added together for the determination of the de minimis threshold. Every gift to be granted must be approved in advance by the Group Management of the ITRIS Group;
  • Occasional invitations to events that are appropriately related to ITRIS’s business activities (e.g., invitation to a trade fair or specialist presentation with a supporting program) are permissible up to a total maximum amount of CHF 300 (including partner) (for public officials, the maximum amount is CHF 100 per person). No travel or accommodation costs may be covered. The focus must be on strengthening the good business relationship, and a professional connection must exist between the event and the business framework. Every invitation to be granted for an event must be approved in advance by the Group Management of the ITRIS Group.
  • Occasional invitations to meals (no regular invitations) are permissible, provided the value of the meal does not exceed the maximum amount of CHF 150 per person (for public officials, maximum CHF 100). Meal invitations must be approved in advance by the direct superior.

4.3 Acceptance of Gifts and Invitations by ITRIS Employees

  • If there is no direct connection with ITRIS business (e.g., decisions on awarding contracts to suppliers, etc.), courtesy gifts up to a maximum value of CHF 200 may be accepted, provided there is no risk that the independence of the employee will be influenced. Examples: bouquet of flowers, bottle of wine, or box of chocolates for good services rendered. Several gifts from the same donor are to be added together for the determination of the de minimis threshold. Gifts that exceed this value or which could possibly impair the independence of the employee for other reasons must be reported to the superior. The superior will decide whether acceptance is permissible.
  • Occasional invitations to events (e.g., conferences, receptions, cultural or sporting events) that are appropriately related to ITRIS’s business activities are permissible up to a maximum amount of CHF 300 (including partner and including any travel and accommodation costs granted). There must be a professional connection between the event and the business framework. This generally requires that the host is also present at the event. If these requirements are not met and, in particular, the equivalent value of CHF 300 is exceeded, the direct superior must be informed before accepting the gift or invitation.
  • Occasional invitations to meals (no regular invitations) are permissible, provided the value of the meal does not exceed the maximum amount of CHF 150 per ITRIS employee present.

4.4 Procurement of Goods The procurement of goods and services is carried out solely according to professional criteria and at optimal conditions for the ITRIS Group.

4.5 Criminal Liability for Corrupt Behavior In the event of a violation of the above rules through corrupt behavior, the employee concerned is primarily liable and will be prosecuted. Fines and prison sentences of up to a maximum of 5 years may be imposed. However, criminal responsibility includes not only the employee but also their superior, the management, and the Board of Directors. In addition, the company that “has not taken all necessary and reasonable organizational precautions” to prevent corruption can also be prosecuted and sanctioned with a fine of up to CHF 5 million.

The ITRIS Group is committed to fair and open competition. The rules of antitrust law must therefore be strictly observed at all times. Agreements of any kind or concerted practices (e.g., informal cooperation) with competitors or with customers aimed at restricting competition or having an anti-competitive effect may constitute violations of antitrust law. These include, for example:

  • Price fixing (e.g., also regarding price components such as discounts, margins, or costs);
  • Agreements on the division of markets;
  • Allocation of customers (e.g., the agreement to refrain from competition, a restriction of business relations with third-party companies, the submission of sham bids in tenders, or the agreement on the submission of inflated bids);
  • Exchange of information with competitors (e.g., regarding prices, discounts, strategic plans that are not generally known, etc.);
  • Requirements for downstream companies (e.g., customers of the ITRIS Group) regarding minimum sales prices, prohibition of passing on discounts, etc.

In case of any doubt as to whether a behavior might violate antitrust regulations or

All employees are obligated to make business decisions in the best interest of the ITRIS Group and without regard to personal interests. If situations occur that cannot be avoided, in which the personal interests of the employee (including relatives) reduce their impartiality for business decisions, the Group Management must be informed immediately. Employees are not permitted to work for another company or to participate in another company that competes with the ITRIS Group.

The privacy of every individual employee and customer as well as business partner must be respected and protected. Data about natural persons may only be collected, stored, processed, forwarded, or used in any other way to the extent that this is expressly permitted by law. Every employee is obligated to take all technically and organizationally possible measures to protect the data of the ITRIS Group, employees, customers, and business partners from unauthorized access, inadmissible use, and unauthorized transfer. This also applies to the exchange of personal data between companies of the ITRIS Group. For this purpose, data, whether in the form of documents or electronic data carriers, must be kept secure at all times.

You can find our privacy policy here.

No employee may obtain or use confidential or copyright-protected information in an illegal manner. All employees are obligated to maintain confidentiality regarding confidential internal and other protected information (in particular intellectual property, business ideas, strategies, databases, offers, customer lists, etc.). Business secrets of the ITRIS Group must be preserved and may not be passed on to third parties (including family members and friends) or used by oneself in any way. The aforementioned obligations also apply after termination of the employment relationship with the ITRIS Group. All documents and data carriers must be returned at the time of the termination of the employment relationship. Every employee is obligated to protect the intellectual property and other business secrets, documents, and data carriers of the ITRIS Group from unauthorized access by third parties and unauthorized use by third parties. Third-party intellectual property (such as copyrights to software, images, music, etc.) must always be respected and may only be used after consent / licensing by the owner of the protective rights.

9.1 Operating Resources All employees commit to handling the operating property of the ITRIS Group carefully and responsibly and not to use the resources provided wastefully. Unless expressly determined otherwise, operating resources may not be used for the private purposes of employees.

9.2 Finance and Accounting The use of financial resources and assets of the ITRIS Group for any unethical purposes is prohibited. All business transactions must be documented truthfully, promptly, and as traceably as possible. To prevent money laundering, it is necessary that there is clarity at all times regarding customers, the identity of the payer, and payment channels, and that this can also be proven in documented form. Our accounting is carried out in accordance with legal and accounting requirements and in line with our internal guidelines. Through our internal control systems, we ensure the accuracy, appropriateness, and reliability of our business processes.

If a suspicion of a violation of the Code of Conduct arises, every employee is obligated to inform their direct superior or another internal body (HR department, management, or Group Management). Reports can also be made anonymously. All reports will be processed and treated confidentially. In case of uncertainties or questions, the aforementioned instances can also be asked for advice at any time. No employee who makes a report in good faith need fear any disadvantages, even if the report should prove to be unfounded. Violations of rules in connection with the Code of Conduct can, depending on the severity, lead to consequences under labor law up to and including summary dismissal. Furthermore, claims for damages against the employee as well as criminal prosecution may follow.

Spreitenbach, December 2017