PURPOSE AND APPLICABILITY
This Code of Conduct is mandatory for all Service Partners having a business relation with Movenet, by supplying global mobility services, acting on behalf of or having other kind of collaboration with Movenet, such as i.e., Suppliers, Vendors, Consultants, Landlords, Agents, Service Providers and Organizations (hereafter referred to as “Supplier”) as well as all internal staff working at Movenet.
Movenet values the fact that all the operations are characterized by honesty, transparency, integrity, and fair play. As a service partner to Movenet, you should read and comprehend the content in Movenet Code of Ethics and comply with it in all your service delivery to Movenet. All global mobility services carried out on behalf of Movenet should always be conducted in accordance with the Company Code of Conduct and follow applicable laws and regulations in the country of business. Therefore, Movenet expects that its service partners are governed by the same or similar principles as expressed in this Code (hereinafter” the Code”). Movenet also expects its service partners to ensure that the principles are communicated and followed by their employees and consultants.
Ethics are fundamentally about what actions we consider right and what we ought to do, or not do, in different situations. At Movenet, the laws and regulations applying in the countries where we have service partners operating are the obvious starting point, but there are areas where Movenet has higher ambitions. Movenet has a clear aim in terms of ethics: zero ethical breaches.
For example, we do not tolerate any form of corruption, inducement, bribery, actions that limit competition, discrimination, harassment, forced labour, child labour or unnecessary environmental impact. Movenet´s corporate management team has adopted a Code of Conduct that summarizes the principles that govern our business ethics. Movenet and all its employees and consultants must follow the Code of Conduct. Movenet also requires the same from its service partners. This Code of Ethics for Service Partners stipulates the principles for business ethics that Movenet requires its service partners to accept and comply with. The Code applies to all service partners providing global mobility services to Movenet. It includes the service partners (and its sub-suppliers), its employees and consultants, jointly referred to as “Suppliers” below. The Suppliers shall have a process in place to verify compliance with this Code and is liable for following up compliance with its sub-suppliers. Movenet will take appropriate measures where we believe our service partners act in a way which is not consistent with this Code or the contractual obligations, including verifying your compliance with the Code.
Service Partners are obliged to respect and comply with the laws and regulations that apply in the countries where they conduct business. The Code might go further than the laws and regulations and are based upon respect for human rights and dignity which shall be supported through fair business practices and prohibition against illegal and unethical practices, including indirect support for such practices. The Code describes Movenet´s fundamental ethical principles and gives guidance on decisions and actions to our Suppliers. The Code outlines the minimum standards Suppliers must observe even when they are more stringent than local legislation.
CORRUPTION
Movenet objects to all forms of corruption, bribery, and fraudulent practice. Movenet and its Suppliers shall comply with applicable legislation, industry rules and generally accepted codes of business conduct for the jurisdiction in question. Suppliers may never offer or receive favours or other funds that might be considered undue benefits. Under this Code of Conduct a bribe includes financial or other advantages which are given, promised, offered, accepted, requested, or received with the intention to influence the ability to make objective and fair business decisions. As a service partner to Movenet, you must not carry out any actions involving bribes when you act in connection with the Movenet service delivery. This includes both domestic and international services and it should be incorporated in all dealings, both with private actors’ and public officials. Facilitation payments are not permitted when acting for or on behalf of Movenet. Any local practice or custom will thus be disregarded, unless explicitly permitted or required by local written law. The Supplier has a financial responsibility and shall keep accurate records of their finances.
MONEY LAUNDERING
Suppliers must never accept, facilitate, or otherwise support activities that are based on money laundering. Suppliers are expected to comply with all applicable anti-money laundering and counter-terrorist financing laws wherever they operate and shall not engage in, nor assist any third parties with these crimes.
COMPETITION
Suppliers must always act in accordance with applicable legislation governing anti-trust and competition law. Suppliers must not exchange information or enter into agreements with competitors, customers or suppliers in a manner that risks preventing, limiting, or distorting competition on the market, and must also avoid all direct potential conflict of interest.
CONFIDENTIAL INFORMATION
Suppliers are expected to pay particular attention to ensuring that confidential information received from Movenet is protected and not disclosed to unauthorized parties. Suppliers shall not access, duplicate, reproduce or utilize the information other than what is required to deliver agreed global mobility services to Movenet.
Suppliers shall protect personal privacy and comply with applicable privacy and data protection laws. Suppliers shall secure personal data in accordance with GDPR standards, against unauthorized access and use, and do not re-use data for their own business purposes without prior permission. Suppliers shall be aware that any use, sharing or retention of personal data must be supported by, or based on, consent or a legitimate, compelling service delivery purpose, and strictly in accordance with the contractual terms and conditions agreed with Movenet.
DISCRIMINATION
Suppliers shall not treat people differently or less favorably in relation to any hiring or employment decision because of characteristics that are not related to an individual’s contributions, skills or capabilities, or the inherent requirements of the job. Many local laws around the world prohibit discrimination against people based on certain characteristics, including discrimination based on race, religion, age, gender, gender identity or expression, sexual orientation, nationality, social or ethnic origin, marital status, pregnancy, disability, HIV/AIDS status, political affiliation, or union membership. Suppliers are expected to comply with all such laws against discrimination. In certain countries, local laws may require Suppliers to, or may give Suppliers the right to, protect or give priority to a particular category of people when taking certain hiring or employment decisions. Suppliers are expected to comply with all such laws, which prevail in the relevant jurisdictions.
WOMEN´S RIGHTS & DIVERSITY, EQUITY, AND INCLUSION
Gender equality is at the very heart of human rights and equality and non-discrimination are fundamental principles of a sound work environment. Therefore, our Suppliers shall commit to workforce diversity, creating equity across groups, and fostering and advancing a culture of inclusion. A culture of belonging is about uniting different backgrounds, beliefs, abilities, and experiences in an environment where everyone feels valued and works together to achieve meaningful outcomes.
Effectively ensuring full enjoyment of human rights by women, men, and people of diverse gender identities requires the Supplier to seek a comprehensive understanding of their social structures, norms, and stereotyping.
ENVIRONMENT
Suppliers shall endeavor to prevent and continuously decrease any adverse impact their operations may have on the environment, embracing decarbonization and strive to track GHG emissions, affecting their direct Scope 1 and 2 emissions as well as their indirect Scope 3 emissions. Suppliers shall endeavor to conduct its operations in an environmentally sustainable manner, and will comply with, or exceed, those standards stipulated by laws, regulations, and international conventions in terms of reducing emissions to the air, soil, and water to preserve good quality of same. Suppliers’ services, materials and processes should be designed to utilize energy efficiency and renewable energy where possible, use natural resources, and raw materials efficiently, and to minimize the volume of waste and residual products through sustainable resource management. Suppliers shall avoid material and methods that involve risks to the environment and that could impact biodiversity, land use and deforestation, when there are other available and suitable alternatives. They are conscious of their impact on the environment and strive to minimize negative impacts to preserve natural resources for future generations, considering land, forest, and water rights as well as animal welfare. At a minimum, Suppliers comply with all applicable environmental laws and regulations, and consider additional environmental management on their most significant environmental aspects. This should include carbon emission reduction targets to mitigate impact on climate change and consideration for the principles of the circular economy in recycling/disposal and waste management, where appropriate. Suppliers commit to reducing their negative environmental impact and provide visibility to their progress toward this commitment. They encourage the development and use of environmentally friendly technologies and practices and the reduction of negative environmental impacts throughout their supply chain.
WORKING CONDITIONS AND WORKING ENVIRONMENT
Suppliers shall respect their employees’ rights of free association and collective bargaining. No employee may be subjected to discrimination or harassment on grounds of age, sex, religion, ethnicity, sexual orientation, disability, political opinion, or ethnicity. During work hours, all Suppliers’ employees involved in the service delivery to Movenet, shall refrain from using alcohol and/or drugs. Suppliers shall comply with all applicable employment laws and regulations, comply with applicable health and safety laws, providing a safe, healthy working environment and take necessary precautions to protect everyone from workplace injuries and occupational and contagious disease. Suppliers shall provide their employees’ wages and benefits that, as a minimum, comply with applicable laws and collective bargaining agreements. Deduction from wages is permitted only if and to the extent prescribed by applicable law, regulations, or collective bargaining agreements.
Suppliers are expected to support and respect internationally recognized human rights as expressed in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work. Accordingly, Suppliers shall treat people with dignity and respect, and maintain a respectful and safe, inclusive, and accessible workplace, physical and virtual not tolerating physical violence, threats, corporal punishment, mental coercion, verbal abuse, disrespectful behavior, bullying or harassment of any kind.
HUMAN TRAFFICKING – CHILD LABOR
Suppliers shall not use, encourage, or engage in human trafficking or child laboring, depriving children of their childhood, their dignity as harmful to their physical or mental development.
USE OF PRIVATE OR PUBLIC SECURITY FORCES
Suppliers shall maintain the safety and security of their operations, and deliver their services in a respectful manner, encouraging human rights thus having a positive impact on local governance, peace, and stability. Should supplier, or their sub-supplier location be in a deemed high-risk country, there may be a need for extractives companies to operate, encouraging high standards of conduct by security forces.
ADVANTAGE – GIFTS AND HOSPITALITY
Movenet does not allow its employees or other representatives to request, accept, arrange, offer, or give any kind of advantage in connection with Movenet services. The term ‘advantage’ may include –but is not limited to – the following: gift, loan, money (regardless currency), fees, reward, journeys, services, bonuses, lavish meals, vouchers of any kind, product samples for personal use, event tickets, discount on private purchases, sponsoring, or any personal favours. It does not matter whether the advantage is given directly or by a third party, the recipient is in breach of this Code although he or she receives the advantage directly or through a third party or if another person is the genuine beneficent. Movenet does not allow the offer or receipt of hospitality whenever such arrangements could affect the outcome of service delivery i.e., the purpose is to obtain or retain business with Movenet.
BREACHES OF THE CODE AND WHISTLEBLOWING
Suppliers are liable for ensuring that their employees, and those of potential sub-suppliers engaged in the service delivery to Movenet, have read, understood, and undertaken to comply with the principles of the Code. This Code shall be deemed an integral part of any agreement between the Supplier and Movenet. For any identified non-compliance with the Code, the Suppliers shall provide a corrective action plan to be approved by Movenet management, irrespective of which Movenet reserves the right to cancel outstanding and future orders. Repeated or serious breaches of the principles of the Code are to be considered as material breach of the agreement.
Movenet may or via a third party appointed by Movenet, from time-to-time request certain information from Suppliers, carry out a review or inspection at the Suppliers in relation to their compliance with this Code of Ethics Standards in order that Movenet may fulfil its obligations regarding monitoring, reporting and verification of its supply chain. Suppliers are expected to comply with such requests in a full and timely manner. Movenet shall inform Suppliers if any matters of concern are identified by its review or information provided by it.
All Suppliers are urged to report suspected breaches of applicable laws and regulations of the Code. Suppliers may report to their main contact person at Movenet or to Movenet´s Customer Experience & Compliance Manager, suppliercompliance@movenet.com. Reports may be made anonymously. Reported breaches and/or incidents will be investigated diligently and with care. Movenet does not accept any discrimination or other negative consequences for Suppliers or Suppliers’ employees that have reported suspected breaches in good faith. All business relations between Movenet and our Suppliers must be based on honesty, trust, and cooperation. By accepting the Code, the Supplier commits to working proactively to meet these requirements within its own operations and supply chain.
COMPLIANCE
You should read and comprehend the content in Movenet´s Code of Conduct and commit to comply with the policies and procedures mentioned in the Code. You have the responsibility to inform all your employees involved in the Movenet service delivery about the content in our Code of Conduct to ensure their compliance. In addition, you also have the responsibility of informing all related sub-suppliers about our Code of Conduct to secure their awareness and possibility of compliance.
By accepting the Code, the Supplier commits to define and implement similar standards toward their own Tier-1 suppliers.
A deliberate violation of the Movenet Code of Ethics may lead to termination of all business connections with our Company. If you, your employees, sub-suppliers, or any other representatives of your company have questions concerning the meaning or application of Movenet´s Code of Conduct, please contact: contact@movenet.com
Movenet is committed to continuously review and update its policies and procedures, therefore this Code of Conduct may be subject to modification. We will inform you whenever there is any major change or update in the Code.
Please sign the compliance commitment on the last page of this Code of Conduct and return it to Movenet, indicating that you have received, read, understood, and agreed to comply with the Movenet Code of Conduct. If your Company has an Anti-Corruption Policy/Code, you are welcome to enclose this when you submit the signed page to Movenet.
For information, all concerned Movenet employees sign up to Movenet Code of Conduct and thereby undertake to comply with it.