Version 1.1 as of February 5, 2025
Message from our Chief People Operations Officer (CPOO)
As a company built by people and for the people, Trinetix emphasizes the importance of adhering to high ethical and professional standards on every level of our business operations.
Outlined explicitly in the Code of Ethics and Conduct, these standards represent our shared core values and are foundational to defining TXians.
I expect each of you to recognize your role – not only as a company representative at working hours and office premises but also as a brand ambassador outside the walls of the corporate establishment.
Please read through this document thoroughly, follow the guidelines provided, and help us keep Trinetix up to the exemplary mark that has been established.
Thank you.
1. Scope, Purpose, and Users
1.1. Scope: This Code of Ethics and Conduct (the “Code”) sets the guidelines for ethical and professional conduct of our Team Members. It covers all aspects of our business operations and concerns every decision and action of Trinetix and our Team Members.
The Code applies to all our operations around the globe and to all Team Members irrespective of their position, legal status, cooperation type, or place of office.
The Code is not intended to replace Trinetix’ other policies but rather to codify the most important aspects of Team Member’s ethics and conduct. Some standards and principles presented here may be revealed and governed in more detail in the respective policies.
1.2. Purpose: This Code serves as a guiding framework for our and our Team Members' decision-making and behavior. It reflects our commitment to operate with integrity, professionalism, and in compliance with all applicable laws and regulations.
The Code is designed to foster a culture of ethics and compliance within Trinetix’ worldwide presence, ensuring that our business practices align with our core values.
1.3. Users: This Code applies to a broad range of individuals associated with Trinetix referred to as Team Members. They include for the purposes of this Code all Trinetix’ employees (whether temporary or permanent, part-time or full-time), consultants, individual contractors, trainees, interns, agents, sponsors, or any other individual associated with Trinetix (including third parties), or any of Trinetix’ affiliates' team members, irrespective of their location or place of office, at all levels and grades, including senior managers, executive officers, directors, members of any established boards. Team Members however do not comprise Trinetix’ shareholders, clients, partners, suppliers, and any other organizations.
Team Members are expected to adhere to the standards and principles of the Code. High-ranking Team Members, such as Executive officers or Board Members, being leaders, must exemplify and uphold the standards and principles set forth in the Code.
2. Quality of Service
2.1. Scope of Offered Services: We are committed to delivering a broad spectrum of IT services that meet the diverse needs of our clients. These services must be defined and communicated clearly, ensuring that the clients understand what we offer and what they can expect. We are dedicated to maintaining transparency in our service offerings, ensuring that our clients make well-informed decisions based on accurate and comprehensive information about our capabilities and limitations.
2.2. Professional Competence and Due Care: We uphold a high standard of professional competence and due care in all our services. This involves continuous learning, staying abreast of industry developments, and applying our knowledge and skills to deliver services that meet or exceed professional standards. Our Team Members are expected to exercise sound judgment and maintain a critical and questioning approach, ensuring that our work consistently reflects our commitment to excellence and the best interests of our clients.
2.3. Consultation and Subordination: We expect and encourage consultation on non-routine or emerging issues and practices. We place a high value on the sharing of insights and knowledge within Trinetix. Our professionals are urged to frequently engage with internal resources and industry experts to ensure that we maintain a unified approach and understanding of technical and practice-related matters.
While we foster a culture of diverse viewpoints and encourage the expression of different perspectives, it is important that final determinations made by the authorized leads within our company are respected and adhered to. These determinations reflect our collective expertise and the unified voice of our company.
2.4. Proper Billing: Our billing practices are fair, transparent, and based on the actual services rendered. We ensure that all charges are clearly communicated to and understood by our clients. Billing is conducted with integrity, reflecting the true scope of work and agreed-upon terms. We avoid any practices that could be perceived as unfair or deceptive, maintaining trust and credibility with our clients.
2.5. Quality Assurance and Control: At the heart of our service delivery lies a strong commitment to quality assurance and control. Our quality assurance processes are separated and involve proactive measures to ensure that the highest standards are embedded in every aspect of our work, from initial planning to final execution. This includes setting clear quality objectives, developing robust methodologies, and ensuring that our Team Members are fully trained and equipped to meet these standards.
Parallel to this, our quality control procedures are in place to rigorously evaluate and monitor the products and other outcomes of our services. Regular reviews, audits, and client feedback are integral components of this process. These measures enable us to identify and rectify any deviations from our quality standards, ensuring that the final deliverables consistently exceed client expectations. Together, quality assurance and control form the backbone of our commitment to reliability and excellence in service delivery.
2.6. Professional Certifications: Our team comprises individuals with various professional certifications, reflecting our commitment to maintaining a high level of expertise. We encourage and support ongoing professional development and certification among our Team Members. This commitment to professional growth ensures that our team is equipped with the latest knowledge and skills, enabling us to provide services that are at the forefront of industry standards and best practices.
In line with this, all Team Members holding professional certifications have a personal responsibility to maintain these credentials in good standing. This involves timely renewals and, where required, the attainment of the appropriate level of continuing professional education. By doing so, our professionals not only uphold their individual qualifications but also contribute to the collective expertise and capability of our company.
3. Mutual Respect
3.1. Equal Opportunity: We are committed to providing equal opportunities for all Team Members and potential Team Members. Our employment decisions are based on merit, qualifications, and abilities. Trinetix ensures that all employment practices, including recruitment, promotion, compensation, benefits, training, and termination, are conducted without discrimination on any basis, fostering a fair and equitable workplace.
We specifically prohibit discrimination of any kind on the basis of race, color, religion, sex (including pregnancy, sexual orientation, or gender identity), marital status, national origin, disability, age or genetic information (including family medical history), veteran status or any other characteristic protected by the applicable laws and regulations.
3.2. Diversity and Inclusion: We value and respect diversity in all forms. We strive to create an inclusive environment where the unique backgrounds, perspectives, and experiences of each individual are valued and contribute to our collective success. We believe that a diverse workforce enriches our work culture and enhances our ability to innovate and serve our clients effectively.
Trinetix is also committed to fostering an inclusive workplace. This includes providing reasonable accommodations to ensure that all employees, including those with disabilities, have equal opportunities to succeed. We actively work to identify and eliminate barriers that may prevent full participation in the workplace. By accommodating individual needs where feasible, we demonstrate our commitment to an inclusive environment where every employee feels valued and empowered to contribute their best.
3.3. No Harassment and Retaliation: Our workplace is free from harassment in any form. We do not tolerate any behavior that creates an intimidating, hostile, or offensive work environment. This includes sexual harassment, bullying, slurs, graffiti, offensive or derogatory comments, or other forms of inappropriate conduct. Additionally, we strictly prohibit retaliation against anyone who reports bias, discrimination, harassment or participates in an investigation of such reports.
3.4. Health & Safety: The health and safety of our Team Members are of greatest importance to us. We are dedicated to maintaining a safe workplace by complying with all health and safety laws, regulations, and best practices. We also encourage Team Members to be proactive in identifying potential hazards and to report any concerns about health and safety issues.
3.5. Personal Relationships: We recognize that personal relationships can occur within the workplace. These relationships should not interfere with our professional environment or create conflicts of interest. Team Members involved in close personal relationships are expected to maintain professionalism and respect the boundaries between personal and work life.
In the interest of transparency and in order to manage potential conflicts of interest, Team Members should disclose any close personal relationships within the workplace to the Talent team. This disclosure will remain confidential but enable Trinetix to take appropriate steps to ensure that professional standards are maintained and that both parties in the relationship, as well as their colleagues, are treated fairly and with respect.
3.6. Honesty and Trust: Honesty and trust form the foundation of our professional relationships and business dealings. We expect all Team Members to conduct themselves with integrity, honesty, and respect in all interactions within and outside the company. This commitment to ethical behavior builds trust among colleagues, clients, and our broader community, and upholds Trinetix’ reputation.
4. Protection of Information and Property
4.1. Confidential Information: Our commitment to maintaining the confidentiality of information is paramount. We handle sensitive information, including business secrets, client data, and internal communications, with the utmost care and discretion. Unauthorized disclosure of confidential information (even if not marked “confidential”) is prohibited and could lead to negative consequences for our clients and our company. Team Members are required to understand and adhere to our policies on information confidentiality and are expected to protect this information during and beyond the term of their relations with us.
4.2. Information Security: We recognize the critical importance of robust information security practices in protecting the integrity and reliability of our data and systems. This includes implementing and following stringent security protocols, using secure networks and systems, and staying vigilant against cybersecurity threats. Our Team Members are responsible for adhering to these security measures and for reporting any suspected security breaches.
4.3. Personal Data Protection: The protection of personal data, also known as personally identifiable information (PII), is of significant importance. We are committed to complying with all relevant privacy and data protection laws and regulations. This includes responsibly collecting, storing, processing, and sharing identifiable information of Team Members, clients, and other stakeholders. Team Members must be aware of and comply with our data protection policies to ensure the privacy and security of personal data.
4.4. Intellectual Property: Respecting and protecting intellectual property rights is fundamental to our business. This includes both our own intellectual property and that of others, such as clients and partners. We expect Team Members to use intellectual property in a lawful and ethical manner, and to avoid any infringement of intellectual property rights.
4.5. Open-Source Software: Our Team Members respect the licensing terms and community norms associated with open-source software. We acknowledge the value and contributions of the open-source community and ensure that our use of open-source software complies with legal and ethical standards. This includes adhering to licensing requirements, attributing sources where required, and contributing back to the community when appropriate.
4.6. Third-Party Software: Our use of third-party software is guided by strict adherence to legal and ethical standards. It is imperative that all software used by our Team Members, whether for development, operations, or any other purpose, is fully authorized and properly licensed. Unauthorized use, copying, or distribution of software, including but not limited to pirated or unlicensed software, is strictly prohibited.
Team Members are responsible for ensuring that all software they use is compliant with these requirements and must seek approval from the IT Department for any new software acquisitions. This commitment helps protect Trinetix from legal risks and upholds our reputation for integrity and ethical conduct in all our business practices.
4.7. Assets and Resources: The responsible use of Trinetix’ assets and resources is essential. This includes physical assets such as laptops or other technical equipment, and digital resources such as archived files, cloud services, etc. Team Members are expected to use these assets and resources appropriately and solely for legitimate business purposes. Misuse, theft, or wastage of Trinetix’ assets and resources are prohibited.
4.8. Artificial Intelligence: As a forward-looking company, we engage with artificial intelligence (AI) in various aspects of our operations. We are committed to the ethical development and use of AI, ensuring that our practices in this area are transparent, fair, and in compliance with relevant laws and ethical guidelines. This involves addressing concerns related to bias, privacy, and the broader social impacts of AI technologies.
5. Sustainable Development
5.1. Environmental Responsibility: Our commitment to environmental responsibility is integral to our operations. We actively work to reduce our carbon footprint, optimize energy use, and implement sustainable practices in our offices. Recognizing the urgency of climate change, we are dedicated to adopting strategies that mitigate our environmental impact. This involves regular assessment of our practices, setting measurable goals for improvement, and integrating environmental considerations into all business decisions. Our team is encouraged to contribute to these efforts, fostering a culture of environmental awareness and action.
5.2. Sustainable Resource Use and Waste Management: We prioritize the responsible use of resources and efficient waste management in our daily operations. This includes conserving energy, water, and other materials, and striving for minimal waste generation. Our recycling initiatives are designed to reduce the environmental impact of our waste, and we actively seek innovative ways to reuse and recycle materials. By managing resources wisely and reducing waste, we not only lessen our environmental footprint but also set an example of responsible stewardship.
5.3. Green Technology: We are committed to leveraging and improving green technologies to enhance the sustainability of our services and internal processes. This commitment extends to exploring new ways to incorporate environmental considerations into our product development, helping our clients achieve their sustainability goals. Our focus on green technology and innovation reflects our belief in the power of technology to drive positive environmental change.
5.4. Sustainable Supply Chain Management: Our approach to supply chain management is rooted in sustainability and ethical practices. We carefully select suppliers and partners who share our commitment to environmental responsibility and ethical operations. This involves evaluating the sustainability practices of our suppliers and encouraging them to adopt greener and more sustainable methods. By doing so, we aim to create a supply chain that is not only efficient but also aligns with our environmental and ethical standards.
6. External Communication and Outside Activities
6.1. Client, Supplier, and Partner Relations: In our interactions with clients, suppliers, and partners, we maintain the highest standards of professionalism and integrity. These relationships are crucial to our success and are built on mutual respect, fairness, and honesty. We commit to transparent and ethical communication with our clients, suppliers, and partners, ensuring that all dealings are conducted legally and in a manner that upholds our company’s values and reputation. Our Team Members are expected to nurture these relationships with the utmost respect for contractual obligations and mutual interests.
6.2. Government Relations: Our engagement with government entities is anchored in a dedication to ethical behavior and strict adherence to legal standards. We conduct all interactions with government officials and entities in a transparent and responsible way, ensuring full compliance with relevant laws and regulations. We categorically oppose any unlawful lobbying practices or attempts to influence government decisions through unethical means. Team Members responsible for government relations are thoroughly trained to maintain these high standards in all their dealings.
6.3. Public Statements: Public statements made on behalf of Trinetix should reflect our values and align with our strategic goals. Authorized spokespersons are designated to communicate with the media and the public. Team Members who are not authorized spokespersons must refrain from making public statements that could be perceived as official positions of the company. All public communications must be accurate, respectful, and consistent with our commitment to integrity and transparency.
6.4. Protection of our Brand: Our brand is a valuable asset, and its protection is imperative. Team Members must ensure that their external communications and activities do not harm our brand’s reputation. This includes being mindful of how the company is represented in all forms of interaction, from formal presentations to casual conversations. Unauthorized use of Trinetix’ trademarks, logos, or other brand elements in external communications is strictly prohibited.
6.5. Social Media: Our Team Members are encouraged to use social media responsibly and in a manner that reflects positively on our company. While expressing individual views, Team Members should clearly distinguish their personal opinions from the company’s positions. Confidential information and content that could harm Trinetix’ reputation or business interests must not be shared on social media. We respect the personal nature of social media but expect our Team Members to exercise discretion in their online activities.
6.6. Conflict of Interest: We expect our Team Members to avoid conflicts of interest in their outside activities. This involves ensuring that personal relationships, activities, or financial interests do not conflict, or appear to conflict, with the interests of the company. Team Members are required to disclose any potential conflicts of interest to their direct supervisor and the Talent team and to take appropriate steps to manage or resolve the conflict in line with company policies.
7. Legal Compliance
7.1. No Bribery and Corruption: We adhere to a strict zero-tolerance policy against bribery and corruption. All forms of bribery, whether directly or through intermediaries, are strictly prohibited. This includes offering, giving, receiving, or soliciting anything of value to influence the actions of a governmental official or any other person in a position of trust.
7.2. Export Controls: Our business practices comply with all applicable export control laws and regulations. We are committed to ensuring that our products, services, and technologies are not used for purposes prohibited by law, including but not limited to unauthorized military, terrorist, or illicit activities. Team Members responsible for sales, distribution, and international transactions must be familiar with and adhere to these export control regulations, and seek guidance when necessary to ensure compliance.
7.3. No Money Laundering: We are committed to preventing money laundering and comply with all applicable laws and regulations designed to combat money laundering activities. This includes undertaking enhanced due diligence, where appropriate, to understand the nature of our clients’ and vendors’ businesses and reporting any money laundering activities to the appropriate authorities as required by law.
7.4. Sanctions and High-Risk Jurisdictions: Our company respects and adheres to international sanctions imposed by governments and international bodies. We conduct thorough due diligence to ensure that we do not engage in or facilitate transactions with any persons (individuals, companies, or other entities) from sanctioned jurisdictions, countries, and territories. We also take enhanced measures in each case before establishing any business relations with any persons (individuals, companies, or other entities) from high-risk jurisdictions, countries, and territories known for corruption, terrorism, or other illicit activities.
7.5. No Fraud and Accurate Accounting: We are committed to maintaining accurate and complete accounting records. All financial transactions must be recorded in a timely and precise manner, reflecting the true nature of the transactions. We do not engage in any fraudulent activities, including but not limited to misrepresentation of financial statements, manipulation of accounts, or tax evasion. Our Team Members are expected to act honestly and accurately and report all financial information, in compliance with applicable laws and accounting standards.
8. Raising Concerns
8.1. Encouraging Open Communication: We foster an environment where open communication is encouraged and valued. We understand that identifying and addressing ethical concerns is vital to maintaining our integrity and reputation. Team Members are encouraged to raise concerns or report suspected violations of our Code of Ethics and Conduct, company policies, or applicable laws without fear of retaliation. This can include, but is not limited to, issues related to workplace conduct, legal compliance, financial reporting, or any other unethical behavior.
8.2. Channels for Reporting: We provide several channels to report concerns, ensuring accessibility and confidentiality. Team Members can report their concerns directly to their supervisors, the Talent team, or the Legal department, or through available whistleblowing options. These channels are designed to ensure that concerns are heard and addressed appropriately.
8.3. Handling of Reports: All reports of unethical behavior or violations will be taken seriously and investigated promptly and thoroughly. The process will be conducted with sensitivity and discretion, and the identity of the individual raising the concern will be kept confidential to the extent possible. We are committed to a fair investigation process, ensuring that all parties involved are treated with respect and without prejudice.
8.4. Protection Against Retaliation: It is our policy to protect anyone who raises a concern in good faith from retaliation. Retaliation against an individual for reporting a violation or participating in an investigation is strictly prohibited and will result in disciplinary action. We stand by the principle that no one should suffer adverse consequences for doing the right thing in reporting concerns or violations.
8.5. Responsibility and Accountability: While it is the responsibility of every Team Member to raise concerns about unethical behavior or violations, it is equally the responsibility of Trinetix to address these concerns effectively. We are committed to ensuring that all concerns are addressed in a timely and appropriate manner and that corrective actions are taken when necessary.
9. Non-Compliance Implications
Violations of this Code are taken very seriously. Non-compliance with the standards and principles set forth in the Code, regardless of whether it constitutes a violation of law, will not be tolerated. We are committed to investigating all reported issues promptly, thoroughly, and fairly. Disciplinary actions will be taken as appropriate, depending on the severity of the violation. This can range from formal warnings to termination of employment or contract. Our aim is to ensure that actions are proportionate to the nature of the breach and are executed with fairness and integrity.
10. Responsibility and Implementation
10.1. Managers: Company’s managers of all levels are responsible for:
- promptly relaying any reports of ethical violations to the Talent team and/or Legal Department as applicable while ensuring confidentiality;
- regularly educating their teams about this Code, ensuring understanding and compliance, and providing necessary training to reinforce its principles.
10.2. Talent Team: The Talent Team is responsible for:
- regularly communicating the details of the Code to all Team Members and ensuring widespread understanding;
- handling disclosures of personal relationships and conflicts of interest, ensuring that such situations are managed in a manner that aligns with our ethical standards and mitigates potential conflicts;
- actively monitoring for any retaliation against individuals who report concerns, and addressing such issues promptly with the CPOO or other appropriate authority.
10.3.Legal Department: The Legal Department is responsible for:
- keeping abreast of relevant legal and regulatory changes and proposing updates to the Code as necessary;
- randomly reviewing reported cases to check adherence to the Code’s standards;
- offering guidance related to the Code and maintaining essential documentation for compliance and oversight.
10.4.CPOO: The CPOO is ultimately responsible for:
- ensuring that the Code is integrated and operational within the company;
- handling all issues arising from unethical conduct or other violations of the Code;
- addressing the raised concerns and making necessary modifications to the Code, company policies, and internal processes;
- overseeing the investigation of reported retaliation cases and ensuring appropriate remedial actions are undertaken.
11. Document Management
11.1.Ownership: The owner of this document is Trinetix’ CPOO who must check and, if necessary, update the document at least once a year.
11.2.Consulting: When checking and updating the document, the owner of this document should consult with Trinetix’ VP of Talent and Chief Legal and Compliance Officer on matters within their competence.
11.3.Effectiveness Evaluation: When evaluating the effectiveness and adequacy of this document, the list of reported incidents and their outcomes should be analyzed.