Our Code of Conduct & Anti-Corruption Program
Netway Communication wishes to be more than just a good company – we want to be a great company. We are committed to our mission of empowering every person and every organization on the planet to achieve more. Achieving our mission isn’t just about building innovative technology. Our mission reflects who we are as a company, how we manage our business internally, and how we work externally with customers, partners, governments, and suppliers.
Netway Communication Values & Expectations
Netway Communication partners and their employees, agents, and subcontractors (collectively referred to as “Partners”), in collaboration with Netway Communication, serve our customers. It is important for Netway Communication that Partners embrace and continually improve on the Netway Communication values. While conducting business with Netway Communication customers, Netway Communication expects its Partners to commit to operating in full compliance with all applicable laws and regulations, and to adhere to the principles outlined in this Partner Code of Conduct.
Netway Communication’s values are the foundation of our success and reflect our continued commitment to ethical and responsible business practices. Our Standards of Business Conduct establishes our standards which help live our values and apply to all Netway Communication employees, directors and officers. Our values include:
- Integrity & Honesty: It’s how we act when no one is looking and when the whole world is watching. It’s at the heart of our every interaction, deed, and decision. Integrity and honesty add up to trust. And when there is trust, anything is possible.
- Accountability: We make commitments every day, spoken and unspoken. Each instance is an opportunity to build credibility, partnership, and trust. We value accountability. It matters.
- Big Challenges: We have never picked the easy problems to solve. Our very existence was borne of the desire to innovate and bring the power of personal computing to everyone, everywhere. The bigger the challenge, the more grit, fortitude, courage, and optimism we apply.
- Passion: At Netway Communication, our passion comes from our deep belief in the potential of human beings. We believe that our combined contributions have the power to change every person’s life for the better, for real. That’s what brings us to work every day.
- Open and Respectful: We listen and assume good intent in each other every day. It’s how we relate to each other and the world we live in, love in, and create in.
This Partner Code of Conduct is not intended to replace, supersede or conflict with any applicable law, regulation or contractual obligation with Netway Communication.
Partners may report any issue related to this Code of Conduct, including any request by a Netway Communication representative for Partners to act in a manner that conflicts with this Code of Conduct, by using any of the resources.
Business Practices, Ethics and Compliance
While conducting business with Netway Communication customers, Netway Communication Partners will conduct their business practices and activities in accordance with applicable law, with integrity, respect and in an ethical manner.
- Anti-Corruption: Netway Communication Partners will comply with all applicable anti-corruption and anti-money laundering laws. All forms of bribery, kickbacks and other corruption are prohibited. No Netway Communication Partner will improperly influence any act or decision of any governmental official, employee or political candidate, including, without limitation, through the provision of any improper or unlawful gifts, meals, travel or entertainment.
- Fair Competition and Antitrust laws: Netway Communication Partners will conduct their business in full compliance with all applicable fair competition and antitrust laws.
- Public Sector Procurements: When selling to public sector entities, Netway Communication Partners will support fair and open competition by complying with all laws and regulations related to government procurement, tenders, and bids. Netway Communication Partners will not conspire with other partners, including but not limited to, bid rigging, placing orders prior to tender finalization, price fixing, or other forms of collusion.
- Business Records and Accounting: The business records of Netway Communication Partners will conform with applicable legal, accounting and regulatory requirements. Netway Communication Partners will not place any orders for Netway Communication technologies, products, support or services without the existence of a corresponding customer order or agreement.
- Technology Fraud: Netway Communication Partners are prohibited from engaging in false or deceptive business practices, including any activities which may mislead customers or consumers. These prohibited practices include engaging in technology fraud and activities which may mislead seniors, children or other vulnerable consumers to purchase or subscribe for unneeded technical support or services. In order to better protect these vulnerable consumers, Netway Communication Partners should also not engage in the “cold-calling” of such consumers for the purpose of engaging in any of those prohibited practices.
- Conflicts of Interest: Where a Netway Communication Partner is advising a customer, especially a governmental customer, on the selection of products and/or services and has a fiduciary or contractual obligation to that customer, the Netway Communication Partner will avoid engaging in business activities that constitute or could create the appearance of a conflict of interest.
- Disclosure of Fees to Governmental and State-Owned Entities: If required by law or under a contract, Netway Communication Partners will disclose to the applicable governmental entity customer or state-owned entity customer, the potential fees, commissions or other compensation that Partner will receive from Netway Communication in connection with the products or services being procured.
- Advertising and Marketing: Netway Communication Partners’ advertising and marketing activities will be conducted truthfully, accurately and in accordance with applicable law, rules and regulations.
Netway Communication Partners must ensure that all communications to its customers be truthful, accurate, and not misleading.
Human Rights and Fair Labor Practices
Netway Communication Partners will provide a safe and healthy work environment, fully compliant with all employment, health and safety laws.
- No Forced Labor; No Child Labor: Netway Communication Partners will abide by local minimum wage and maximum working hour requirements, are not to use forced labor or to use labor contacts that impose unreasonable limitations on a worker’s ability to leave Partner’s employment. The use of child labor is prohibited.
- Non-Discrimination: Netway Communication Partners will not illegally discriminate in hiring, compensation, access to training, promotion, termination and/or retirement decisions based on race, sex, national origin, religion, age, disability, gender identity or express, marital status, pregnancy, sexual orientation, political affiliation, union membership or veteran status.
Environmental Regulations and Protections
Netway Communication expects Netway Communication’s Partners to share Netway Communication’s commitment to the environment.
- Registrations; Permits: Netway Communication Partners will comply with all applicable environmental laws and regulations, keep current all required environmental registrations and permits relevant to its businesses and implement appropriate conservation measures.
Intellectual Property and Protection of Information
Netway Communication’s Partners will respect intellectual property rights, protect confidential information and comply with privacy rules and regulations.
- Legitimately Acquired Software: Netway Communication Partners will only use information technology and software that has been legitimately acquired and licensed.
- Comply with Ownership Rights: Netway Communication Partners will respect the intellectual property ownership rights of all third parties. Netway Communication Partners will only use lawful methods of gathering competitive intelligence about products or manufacturers that compete with Netway Communication technologies.
Netway Communication’s Partners are expected to develop a culture of compliance with view for continuous improvement.
- Risk Management: Netway Communication Partners will have applicable business controls to detect and prevent unlawful conduct by their employees and counterparties. These business controlsฃ should be adequately resourced and be periodically reviewed and updated to take into account the current risk environment.
- Training: Netway Communication Partners will ensure that they have an adequate training program that achieves the appropriate levels of knowledge and skills to maintain compliance with applicable laws, regulations and standards.
- Assistance: Netway Communication Partners will provide reasonable assistance to Netway Communication in connection with any investigation of a violation of this Partner Code of Conduct or applicable law. Netway Communication Partners will permit Netway Communication reasonable access to all records and other applicable documentation concerning Partners’ compliance with this Partner Code of Conduct and applicable law.
Raising Concerns and Reporting Questionable Behavior
Partners are encouraged to work with their primary Netway Communication contact in resolving a business practice or compliance concerns. However, Netway Communication recognizes that there may be times when this is not possible or appropriate. In such instances, Netway Communication Partners should report any concerns about violation of this policy or applicable laws to their legal department and/or their ethics and compliance officer. Netway Communication
Partners should also report to Netway Communication through the following alternatives: