EDS Code of Conduct

Introduction to the Code of Conduct

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The Code of Conduct for Enterprise Data Solutions (EDS) sets forth the principles and standards that guide our global operations. It delineates the ethical, legal, and socially responsible ways we conduct our business, ensuring that our company values are reflected in our actions across various jurisdictions worldwide. This Code applies to all individuals associated with EDS, including directors, officers, employees, and independent contractors, highlighting our commitment to the highest ethical standards irrespective of local laws and cultural differences. It is important to note that this Code is not an employment contract and does not guarantee employment for any specific period. EDS retains the right to amend or revoke any part of this Code as needed.

 

Principles of Conduct

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We urge every member of the EDS community to exercise sound judgment and ethical behavior in all business dealings. This Code serves as a practical guide for navigating challenges that may arise, though it may not cover every potential issue. In instances where the application or interpretation of the Code is uncertain, we approach each situation individually, considering all relevant facts and circumstances. It's crucial for everyone at EDS to act with integrity and comply with all applicable laws and regulations in their work. Adherence to this Code, along with company policies and legal requirements, is fundamental to making ethical decisions. For any queries or concerns regarding the Code or related legal matters, the EDS legal team is available for consultation.

 

Maintaining Trust

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The trust we've built with our customers, vendors, employees, and stakeholders is vital to our success. This Code is instrumental in preserving that trust, which is essential for our continued growth and success.

 

Certification and Compliance

 

EDS may periodically require employees to certify their understanding and adherence to the Code. These certifications are crucial for ensuring accurate record-keeping, legal compliance, and making informed decisions. Failure to provide or properly complete a certification could lead to a breach of the Code, potentially resulting in disciplinary actions, including termination.

 

Code Exceptions

 

Exceptions to this Code are granted only under specific circumstances, following a rigorous review process by EDS General Counsel and, when necessary, the Board or its designated committee. These exceptions are made in compliance with legal standards and are rare.

 

In conclusion, the Code of Conduct is a foundational element of Enterprise Data Solutions, guiding our commitment to ethical business practices worldwide. By adhering to this Code, we uphold the values and integrity that are critical to EDS success and reputation.

 

Labour and Human Rights

 

EDS champions the principle that every worker deserves a fair, ethical, and dignified workplace. Our commitment extends beyond our own workforce to encompass every entity we engage with, ensuring adherence to the highest human rights standards across our operations.

 

Diversity and Inclusion: A Cornerstone of Our Ethics

 

EDS is steadfast in its dedication to creating a diverse and inclusive environment. We rigorously comply with all laws ensuring equal employment opportunities and adhere strictly to employment laws and regulations. Our aim is to cultivate a workplace devoid of unlawful discrimination or harassment, where every individual, irrespective of their race, creed, color, or any other protected characteristic, is respected and valued. This commitment pervades every facet of employment, from hiring and placement to promotion and compensation, underlining our zero tolerance for discrimination or harassment based on any protected characteristics.

 

Combatting Involuntary Labour and Human Trafficking

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EDS is unequivocally opposed to any form of involuntary labour or human trafficking. Our practices are built around the use of voluntary labour, and we expect the same standard from our partners and affiliates. Our stance against exploitation is clear and unwavering, encompassing any activity that leverages threat, force, or coercion for labour recruitment and employment.

 

Ensuring Workplace Safety and Health

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The health and safety of our workforce are paramount. EDS invests in comprehensive safety programs, focusing on awareness and incident response. We encourage proactive engagement from our team in adhering to safety protocols and reporting potential hazards, ensuring a secure work environment for all.

Addressing Criminal Activities and Substance Abuse

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EDS prioritizes the well-being of its employees, implementing strict policies against involvement in criminal activities or substance abuse. Actions detrimental to safety or performance are subject to disciplinary measures, informed by a thorough assessment of the situation. Our approach is rooted in fairness, considering all available information before taking disciplinary steps.

 

Upholding High Standards of Conduct

 

We strive to foster a thriving work environment at EDS. Our code of conduct outlines clear expectations for behavior, promoting safety, integrity, and respect within the workplace. Examples of unacceptable conduct include falsification of records, theft, abuse of company resources, substance abuse, violence, and any breach of safety or health policies. EDS remains flexible in its disciplinary approach, opting for measures that may include verbal warnings, written warnings, or suspensions, depending on the severity and nature of the violation.

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Navigating Conflicts of Interest

 

EDS acknowledges the potential for conflicts of interest and takes steps to mitigate such risks. Employees are encouraged to disclose any personal or financial interests that may conflict with the company's interests, ensuring transparency and integrity in all business dealings.

 

Maintaining Professional Boundaries

 

We recognize the importance of maintaining professional boundaries, particularly in the context of personal relationships within the workplace. EDS advocates for a clear demarcation between personal and professional interactions, establishing policies that prevent conflicts of interest and ensure fairness and objectivity in the work environment.

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External Engagements and Investments

 

EDS employees are expected to dedicate their professional energies exclusively to the company. Engagements in external activities, including outside employment or advisory roles, are closely scrutinized to prevent conflicts of interest. Similarly, investments in entities that may pose a conflict with EDS interests are subject to review and approval, underscoring our commitment to ethical business practices.

 

Gifts, Entertainment, and Ethical Business Practices

 

Our policies on gifts and entertainment are designed to prevent conflicts of interest and ensure ethical interactions with business partners and government officials. EDS employees are required to adhere to guidelines that promote transparency, legality, and appropriateness in all forms of business courtesies.

 

Ensuring Contractual Integrity

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EDS is committed to the integrity of its contractual engagements. All agreements must be formally documented, with no room for unapproved side deals or modifications. This approach safeguards the company's interests and ensures compliance with legal and financial obligations.

 

Effective Communication and Social Media Engagement

 

EDS emphasizes responsible and respectful communication, whether internally among employees or externally with clients, vendors, and other stakeholders. Our policies extend to social media engagement, advocating for professionalism and adherence to company values in all forms of communication.

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In essence, the EDS Code of Conduct serves as a testament to our unwavering dedication to labour and human rights, ethical business practices, and a respectful, safe work environment. Through adherence to these principles, EDS continues to build on its legacy of integrity, excellence, and social responsibility.

 

COMPLIANCE WITH THE LAW

 

Legal Compliance at Enterprise Data Solutions

 

EDS rigorously adheres to legal and regulatory standards in every region where we operate. Our commitment extends across a broad spectrum of legal domains, ensuring our business practices align with the principles of integrity and lawful conduct.

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Comprehensive Legal Adherence

 

Our operations are guided by a thorough understanding and respect for laws and regulations concerning bribery, corruption, money laundering, terrorist financing, and other illegal business practices. This includes strict compliance with the Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and various other anti-corruption frameworks, alongside laws regulating lobbying, public official interactions, and political contributions. Our legal framework also encompasses securities, antitrust, fair competition, trade controls, financial auditing, wage standards, and privacy and information security regulations.

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Zero Tolerance for Bribery and Corrupt Practices

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At EDS, we maintain a zero-tolerance policy towards bribery, kickbacks, and any form of corrupt practices.

Foreign bribery under Canadian law is governed by the Corruption of Foreign Public Officials Act (“CFPOA”) which makes it an offence to: i) directly or indirectly give, offer or agree to give or offer any form of advantage or benefit to a foreign public official to obtain an advantage in the course of business; or ii) engage in certain accounting practices where those practices are employed for the purpose of bribing a foreign public official or concealing a bribe.

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Domestic bribery and corruption is governed under the Criminal Code which prohibits various forms of corruption including bribery of various officials, frauds on the government, breach of trust by a public officer and secret commissions, as well as various corrupt accounting and record-keeping practices.

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All personnel and partners must align with the FCPA, the UK Bribery Act, and similar laws, upholding ethical interactions across all business dealings. Bribery, defined as offering value to influence improper actions, is strictly prohibited, as are facilitation payments and kickbacks, regardless of their nature or intent.

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Ethical Interactions with Government Officials

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Engaging with government officials demands a heightened level of caution and ethics. EDS mandates adherence to strict regulations governing gifts, meals, and entertainment offered to such officials, underscoring the importance of transparency and legality in these interactions. Our legal team provides oversight and guidance to ensure compliance with these stringent standards.

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Insider Trading and Confidential Information

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Employees privy to confidential information about public entities, including clients or partners, are prohibited from engaging in insider trading. This commitment to confidentiality safeguards the trust placed in us by our employees, clients, and stakeholders, ensuring that all actions are legally sound and ethically unimpeachable.

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Global Trade Compliance

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EDS recognizes the complexities of international trade, committing to compliance with all export, import, and trade control laws. Our policies facilitate lawful and ethical international commerce, navigating the nuances of global trade regulations to prevent illicit or restricted activities.

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Fair Competition

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We advocate for fair and aggressive competition, abiding by laws designed to prevent trade restraint. EDS's market conduct is regularly reviewed to avoid illegal agreements or practices that could undermine free competition.

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Fair Business Practices

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Honesty, transparency, and ethical dealings form the cornerstone of our business interactions. EDS prohibits misrepresentation and unethical conduct in securing business, emphasizing fair dealing in all transactions.

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Engagement with Third Parties

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Our engagement with agents, consultants, suppliers, and distributors is predicated on thorough legal due diligence. Confidential information disclosures are safeguarded by non-disclosure agreements, ensuring that all third-party interactions are governed by legal and ethical standards.

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Financial Integrity and Accountability

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EDS is committed to the accurate and detailed maintenance of our financial records, reflecting our business activities truthfully and facilitating informed decision-making. This commitment to financial integrity extends to all aspects of our operations, ensuring the reliability of our financial statements and adherence to auditing standards.

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Audits, Investigations, and Legal Inquiries

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EDS cooperates fully with audits, legal inquiries, and investigations, providing accurate information and supporting the resolution of queries or concerns. We encourage a culture of honesty and transparency, ensuring that all employees participate earnestly in these processes.

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Environmental Responsibility

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Aligned with our commitment to social responsibility, EDS actively engages in environmentally sustainable practices, complying with all relevant environmental laws and regulations. Our dedication to environmental stewardship reflects our broader commitment to ethical, legal, and responsible business operations.

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In summary, Enterprise Data Solutions stands committed to the highest standards of legal and ethical conduct, embodying these principles in every aspect of our operations. Through steadfast adherence to these standards, EDS ensures a foundation of trust, integrity, and compliance that supports our continued growth and success.

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HOW TO REPORT CONCERNS

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At Enterprise Data Solutions (EDS), we cultivate a culture that prioritizes open, honest communication regarding ethical behavior and business practices. Aligned with our dedication to ethics, legal compliance, and ethical governance, we openly welcome any queries or concerns about potential breaches of this Code, particularly issues that might involve illegal, deceitful, unethical, or retaliatory actions.

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We urge you to voice your concerns, no matter how minor the issue might seem. It's crucial for us to be aware of any problems to address them effectively.

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Obligations for All Associated with EDS

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This Code of Conduct, along with its underlying principles, applies universally across EDS's global network, including employees, independent contractors, consultants, and business partners. It mandates adherence to several key responsibilities:

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Upholding the Code: All associated parties are expected to fully abide by this Code's stipulations.

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Speaking Up: We count on our community to act as our first line of defense against breaches of this Code. Should you become aware of any potential violations, it's imperative that you report them through the channels specified under the “Reporting Violations” section.

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Exercising Sound Judgment: Before taking action, consider how EDS's values, ethical principles, and policies should guide your decision-making process.

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Seeking Guidance: Should you find yourself uncertain about the appropriate course of action, consult with an EDS manager, People Business Partner, or EDS Legal for direction.

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Neglecting to observe the guidelines of this Code, or failing to report a violation, may lead to disciplinary measures, potentially culminating in the termination of employment or business relations.

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Zero Retaliation Policy

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EDS strictly prohibits any form of retaliation against individuals who lodge good-faith complaints or participate in investigations concerning this Code. Our Whistleblower Policy provides further clarification on this stance.

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Expectations for Managers

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While this Code universally applies across EDS, managers bear additional responsibilities, particularly in fostering an ethical work environment and ensuring their teams are well-informed and compliant with this Code.

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Violation Reporting Channels

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To report a potential violation, you may utilize the following avenues:

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Direct Reporting to Your Manager: This is advisable unless the manager is implicated in the violation.

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Employee Relations Team: Reach out via email or Slack to your People Business Partner.

 

EDS Legal: Direct communication through email is encouraged for any legal concerns.

 

Ethics and Compliance Hotline: For anonymous reporting, where permissible by law.

 

Adherence to Legal and Regulatory Standards

 

EDS is steadfast in its commitment to observe all pertinent legal and regulatory requirements across the regions we operate. This encompasses strict adherence to laws against bribery, corruption, money laundering, and other illicit business practices, detailed in legislations like the FCPA and the UK Bribery Act. It also covers regulations related to securities, competition, trade controls, financial auditing, labour laws, and data protection.

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Prohibitions and Ethical Business Practices

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EDS enforces a stringent prohibition against bribery, corrupt dealings, and insider trading, advocating for fair competition and transparent dealings with all stakeholders. Our engagements with third parties are conducted under rigorous legal and ethical scrutiny to ensure alignment with our standards of integrity.

 

Financial Accountability and Environmental Responsibility

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We are committed to maintaining accurate financial records and upholding our environmental responsibilities, reflecting our broader commitment to ethical business practices and social responsibility.

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In essence, the EDS Code of Conduct is more than a set of rules; it is the bedrock of our ethical framework and business philosophy, guiding us towards making decisions that are not only legally compliant but also morally sound.