Code of Ethics

Ontotext places great importance on the principle that business should be conducted responsibly. Ultimately Ontotext complies with applicable laws in all countries it operates in. But this is not enough: Ontotext wants to conduct its business with good ethical principles and practices internally and with Customers and Partners.

This Code of Ethics is intended to remind all Ontotext employees of the requirement to act honestly, fairly and with integrity in their day-to-day work.

This Code of Ethics is not intended to provide an exhaustive list of acceptable and unacceptable behaviors but a general guide to good business practice. It should be interpreted within the legal framework in force in each country where Ontotext is conducting business, the more stringent rule prevailing.

General Business Integrity Principles

Ontotext applies the highest standards of professional integrity internally and with third parties, based on merits and qualifications, without consideration for race, nationality, sex, age, handicap or any other distinctive trait.

Ontotext firmly believes in the following principles as the basis of dealings with and between its people and with clients, suppliers, partners and other third parties throughout the world:

  • Ontotext is a fair competitor;
  • Ontotext does not tolerate conflict of interest;
  • Ontotext protects its assets;
  • Ontotext protects confidential information;
  • Ontotext rejects any form of corruption or bribery.

This Code of Ethics applies to Ontotext employees and its principles must be shared by third parties assisting Ontotext in developing our business, partners or suppliers; therefore, Ontotext expects all of them to comply with both the letter and the spirit of the Code of Ethics, in addition to the laws and regulations of the countries where they operate.

These principles shall be detailed hereafter. Additional explanations, examples, and recommendations on these principles may be provided in specific policies, training sessions to Ontotext directors and employees and shared with third parties assisting Ontotext in developing business. These documents and training will help us understand and apply our Code of Ethics, understand when behaviors and actions are right or when they are not acceptable.

Fair Competition

Ontotext treats its customers, suppliers, partners and intermediaries
 with respect and shall not take
unfair advantage nor practice discriminatory conditions. It does not mean that all customers, suppliers or partners must be treated in the same manner, but that there must be no advantage granted to someone (supplier, customer, partner…) without a proper objective justification.

Neither Ontotext employees nor third parties assisting Ontotext in developing business can take part in an agreement, understanding or concerted practice which would contravene the applicable laws and regulations concerning anticompetitive practices.

This means that Ontotext will not directly or indirectly exchange information with competitors on prices, terms and conditions, volumes, market shares, or customers… nor fix prices or agree on conditions of supply, share markets or customers or sources, collude for a bid, ban a supplier or a customer in a way that infringes Competition laws.

Ontotext may have a dominant position in a given sector but will never take unfair advantage of this dominant position. Explanations regarding the authorized exchanges of information are available from the Legal Department.

Conflicts of Interest

Conflicts of interest arise when Ontotext employees (or members of their families) can potentially benefit from their part in the conduct of company business. Such interest can be material or immaterial. Ontotext directors’ and employees’ personal interests or obligations should never conflict or interfere with Ontotext’s business activities, and Ontotext employees must always act for the benefit of Ontotext.

To avoid conflicts of interest arising during their employment with Ontotext unless he or she has obtained the prior written consent of the Chief Executive Officer:

  • No Ontotext employee can accept or exercise any management position as an officer or director of any company which is outside the Ontotext group;
  • No Ontotext employee can enter into or maintain, directly or indirectly, any financial or family relationships with any Ontotext partner, customer, supplier or competitor – except for pure non-controlling and in accordance with compliance with the principle of insider information protection;
  • No Ontotext employee can be engaged or be interested (in either case, whether directly or indirectly) in any other activity, business or employment within the consulting or IT sectors or in a manner that interferes with his/ her employment with Ontotext.

Any current position or interest in conflict not previously disclosed shall immediately be disclosed to the CEO. In addition, Ontotext employees willing to be active politically shall maintain a complete separation between such political activities and professional responsibilities.

Ontotext employees shall notify the HR Department annually if they are in a conflict of interest situation.

Protection of Ontotext Assets

Ontotext has many valuable assets on which its future is built. Ontotext information, hardware, tools and intellectual property rights are some of the most important ones that must be protected, and this is an obligation for all Ontotext directors and employees. Intellectual property rights cover, for instance, Ontotext copyrights, patents, software in object or source code form, technical information, inventions, trade secrets…

These assets must be used only for conducting Ontotext business and according to the general principle of carefulness. Particular attention must be paid to the safeguarding of assets: using USB sticks or laptops when traveling or even at home requires specific care, as the loss or theft of this device does not just mean a loss of the hardware value, but also a loss of the data that it contained.

Misappropriation of resources or manipulation of data or assets, wrong financial reporting, may constitute fraud and as such may lead to sanctions from Ontotext, as well as civil and criminal sanctions. Similarly, giving wrong information to a customer in order to sign a contract could be a misrepresentation with potential civil and criminal sanctions.

Fraudulent acts or suspicions of such acts must be reported immediately to the Company’s Chief Operating Officer.

Protection of Confidentiality – Insider Information

As a general rule, Ontotext protects the confidential information it owns or which is made available to it by third parties (customers, suppliers or partners) during the performance of business operations.

Ontotext employees have the duty to hold this information in confidentiality, to use it only for business purposes, to disclose it only to persons having a need to know it for the purposes defined by the management or agreed with the concerned third party and to protect it against unauthorized or accidental disclosure by use of physical or logical protection devices. Encryption is one of the possible safety tools which is available.

No Bribery or Corruption

Ontotext shall not tolerate any form of bribery or corruption, i.e. providing something of value to influence someone in our favor or accept something for acting against Ontotext interest, nor participate in any form of money laundering.

As a participant to the United Nations Global Compact, Ontotext adheres to United Nations principles related to human rights, labor, environment and anticorruption. The 10th principle states “Businesses should work against corruption in all its forms, including extortion and bribery”.

Ontotext thus commits to:

  • Avoid bribery, extortion and other forms of corruption;
  • Develop policies and effective programs to avoid corruption within Ontotext organization and business operations;

This clearly means Ontotext firmly rejects to offer, give, request, receive or accept, directly or indirectly (active or passive corruption) an inducement or reward (money, gift, hospitality, entertainment, trip, service…) to or from a potential customer or supplier, in the public or in the private sector in order to influence his behavior in our favor: get business or to do or forbear to do any act or show or forbear favor or disfavor to someone.

Negotiation and competition may be hard, but Ontotext will always stick to fair and honest practices. Gifts and invitations of small value to or from a customer, supplier or partner may under certain circumstances, be accepted. Conditions are strict and employees have to check with their hierarchy and legal department whether in such circumstances the giving or receiving of gifts or invitations is permissible.

Ethics Violations

All Ontotext employees are required to comply with the Code of Ethics and to report any observed violations. An unethical or illegal conduct should be reported to appropriate management and, if necessary, to those affected by the conduct. Ethics complaints should only be filed when they are substantiated by facts. Disciplinary actions might be pursued against an individual who retaliates against a person raising ethics concerns.