This policy (hereinafter referred to as “the Policy”) outlines DRILL’s position on prohibiting and preventing bribery, fraud, dishonesty, and illegal activity of any kind and provides a guide to ethical decision-making.
DRILL is committed to the highest standards of ethical conduct and integrity in all its business activities. DRILL expects all its personnel to conduct their job or business in accordance with the highest ethical standards and to not conduct their job or business in a manner that could damage the reputation DRILL or cause DRILL to be in violation of any law or regulation.
This Policy applies to all DRILL employees, and to temporary workers, consultants, contractors, agents, acting for, or on behalf of, DRILL. Every employee and associated person acting for, or on behalf of, DRILL is responsible for maintaining the highest standards of business conduct. Any breach of this Policy is likely to constitute a serious disciplinary, contractual and criminal matter for the individual concerned and may cause serious damage to the reputation and standing of DRILL.
Compliance with Laws, Rules and Regulations
DRILL acts honestly, with integrity and in compliance with all applicable laws, international treaties, relevant conventions and regulations in doing business in any country. All DRILL employees are required to comply with applicable legal regulations at all times. At the same time, the employees of DRILL must adhere to internal directives, rules and regulations agreed upon by the DRILL management.
Financial Responsibility and Accurate Books
DRILL’s books and records must accurately and fairly present the results of operations and the financial condition of the company. This helps us make responsible business decisions and disclose truthful and timely information to the owners. False or misleading entries are strictly prohibited, and DRILL does not condone any undisclosed liabilities or unrecorded bank accounts or other unrecorded assets established for any purpose.
No employee may authorize payment of DRILL funds knowing that any part of the payment will be used for any purpose other than the purpose described in the documents supporting the payment.
No action may be taken to, directly or indirectly, defraud, influence, coerce, manipulate or mislead any other employee, officer or director, or any independent auditor or lawyer for the purpose of rendering the books, records, or financial statements of DRILL incorrect or misleading.
All employees are required to comply with the internal controls that have been established by DRILL.
Each employee has an obligation:
- to inform his or her immediate supervisor, or any of the Partners and the Quality Management Representative of any errors, or possible errors or misstatements, in DRILL’s books and records, including its financial statements, promptly after such errors or misstatements are discovered or suspected;
- to report any actual or suspected breaches or violations of DRILL’s internal controls to any of the Partners and the Quality Management Representative promptly after such breaches or violations are discovered;
- to report any actual or suspected fraudulent or questionable transactions or occurrences that come to the attention of the employee to any of the Partners and the Quality Management Representative promptly.
Fair Competition and Anti-Trust
DRILL respects the rules of free and fair competition in all business relations and in particular not act against any competition and/or antitrust law. DRILL applies the highest commercial ethical standards and competes within the framework of competition rules. DRILL shall not be part of any illegal price cooperation, illegal market sharing or other practice in violation of applicable competition laws.
DRILL ensures compliance with any international sanctions that are in place and does not have business or dealings with a sanctioned country, group, organization or individual. Regular checks are made against DRILL CRM register to ensure that sanctions are followed.
Corruption, extortion and bribery
DRILL conducts its business in compliance with the anti-corruption laws and regulations in force in all countries which commercial activities are carried out and planned. DRILL refrains from any corrupt actions to obtain or retain business or obtain any improper advantage.
DRILL nor its employees, consultants, contractors, agents, acting for, or on behalf of, DRILL do not, directly or indirectly, solicit, receive or offer any form of a bribe, kickback, or other corrupt payment, to or from any person or organization. DRILL refrains from any form of corruption or even actions that could potentially be construed as such. DRILL may not offer, promise or grant illegal benefits to national or international public officials or decision-makers in order to achieve a preferential treatment or favorable decision.
Conflicts of Interest
There are many different ways in which conflicts of interest arise but generally a conflict of interest occurs whenever personal interests interfere in any way with the ability to perform job objectively and in the best interests of the company.
While conducting its business activities DRILL avoids all conflicts of interest and operates with full transparency with respect to any circumstances where a conflict exists or may arise.
DRILL employees are expected to make decisions based on solid business judgement unclouded by favoritism resulting from personal relations and opinions. Private interests and external activities must not affect, or be considered to affect, the judgement or actions of employees when carrying out their work for DRILL. Employees must refrain from entering into relationships or transactions that might impair their judgment as to what is best for DRILL. Even relationships that create the appearance of a conflict of interest should be avoided.
Any employee who is presented with a transaction or relationship which could create a conflict of interest must bring the transaction or relationship to the attention of any of the Partners and the Quality Management Representative.
Sponsorship & Political Contributions
All DRILL sponsoring measures must be in accordance with applicable current legislation.
It is a DRILL policy not to donate money or grant any monetary benefits to any political party, government officials and employees.
Whistleblowing and Protection Against Retaliation
DRILL has whistleblowing procedures to detect, prevent and avoid major misconduct, and also to encourage open communication with employees and related parties. The whistleblowing procedure enables employees, suppliers, partners, customers, and other third parties to report any suspected breach of DRILL Code of Ethics, DRILL Business Ethics Policy or other policies and directives.
Any concerns about our business conduct, or a potential breach of any policy or directive can be reported anonymously through our whistleblowing channel firstname.lastname@example.org. All information received will be fully and objectively investigated in a timely and confidential manner, regardless of whether or not it has been received anonymously. All documentation will be kept confidential. We do not tolerate retaliation of any kind against any person who makes a report in good faith.
If any illegal activities or unethical behaviors are found during an investigation, DRILL will make appropriate improvements, administer sanctions and/or take legal actions; the whistleblower will also be informed appropriately.
No employee or any other person that reports a potential or ongoing violation of valid legal and/or internal standards of DRILL shall be the subject to recourse, discrimination or revenge from DRILL or its employees. DRILL does not tolerate retaliation of any kind against any person who makes a report in good faith.
Confidentiality and Data Protection
All partners, managers and employees, incl. temporary workers, consultants, contractors, agents, acting for, or on behalf of, QuickSource® have an obligation to safeguard confidential information about QuickSource® and confidential information that our suppliers, customers, and other parties have entrusted to QuickSource®. Confidential information is information:
- that has not been disclosed to the public;
- that gives QuickSource® business an advantage over our competitors;
- that could expose QuickSource® to harm or liability if released prematurely or inappropriately.
QuickSource® partners, managers and employees and other involved parties are required to maintain the confidentiality of confidential information entrusted to them, except when disclosure is authorized by an appropriate QuickSource® representative, an authorized third-party representative or required by law.
QuickSource® is aware that its intellectual property (including patents, copyrights, trademarks, know-how and brands) is a valuable asset protection of which is essential to maintain competitive advantage and to make business and social development effective and fast. Therefore, QuickSource® protects its business through the proactive acquisition of intellectual property rights. QuickSource® adopts proactive approach in its effort to acquire, protect, and utilize intellectual property rights created during the course of its business activities, such as those pertaining to new technological concepts, designs and services.
All QuickSource® personnel are expected to respect intellectual property rights and to safeguard them against misuse, theft, fraud or improper disclosure.
In addition, QuickSource® respects intellectual property rights of third parties and shall not knowingly infringe them.
Roles and Responsibilities
QuickSource® personnel are required to acknowledge and commit to the adherence of responsible business principles of this Policy. Every employee is personally responsible for making sure that QuickSource’s business decisions and activities comply at all times with the spirit as well as the letter of this Policy.
If there are questions about the application of a standard, or if confronted with a situation that presents an ethical issue that is not addressed by this Policy, employees should seek guidance from one of QuickSource’s Partners and QuickSource Quality Management Representative. Partners, managers and supervisors have a special responsibility to lead according to the standards in this Policy, in both words and action.
All concerns, questions and complaints will be taken seriously and handled promptly, confidentially and professionally. No retaliation will be taken against any employee for raising any concern, question or complaint in good faith.