Code of Business Ethics

Date Last Updated: September 21, 2023

At CIMCO, we are committed to conducting our business in an ethical and lawful manner, and to respecting human rights and preventing any form of bribery and corruption in our operations. This Code of Business Ethics policy defines the ethical principles and values that govern our business decisions and actions, and provides clear guidelines and expectations for our employees, managers, and stakeholders.

Our Mission and Values

Our mission is to provide our customers with the best solutions for Computer Integrated Manufacturing, and to help them optimize their manufacturing processes with advanced technology. Our core values are:

Integrity: We act with honesty, fairness, and accountability in everything we do.
Excellence: We strive for excellence in our products, services, and performance.
Innovation: We embrace innovation and creativity in our solutions and practices.
Customer Satisfaction: We listen to our customers and deliver solutions that meet their needs and expectations.
Social Responsibility: We care about our impact on society and the environment, and we contribute to the well-being of our communities.

Our Ethical Principles

We adhere to the following general ethical principles in our business conduct:

Respect: We respect the dignity, rights, and interests of all our stakeholders, including our employees, customers, partners, suppliers, regulators, and the public.
Fairness: We treat all our stakeholders with fairness and impartiality, and we do not discriminate or harass anyone on the basis of race, color, gender, age, religion, national origin, disability, sexual orientation, or any other protected characteristic.
Accountability: We take responsibility for our actions and outcomes, and we report and correct any errors or mistakes promptly and transparently.
Transparency: We communicate openly and honestly with our stakeholders, and we disclose relevant and accurate information in a timely manner.
Compliance: We comply with all applicable laws and regulations in the countries where we operate, and we follow the highest standards of professional and ethical conduct.

Our Ethical Guidelines

We expect our employees, managers, and stakeholders to follow the specific ethical guidelines and expectations outlined below on various topics:

Conflicts of Interest: We avoid any actual or potential conflicts of interest that may interfere with our objectivity, judgment, or loyalty to the company.
Confidentiality: We protect the confidentiality of the information that we receive, create, or use in the course of our business, and we do not disclose or misuse such information without proper authorization or consent. We respect the privacy of our stakeholders, and we seek to comply with all applicable data protection laws and regulations.
Intellectual Property: We respect the intellectual property rights of our company and our stakeholders, and we do not infringe, misappropriate, or violate such rights. We use our company’s intellectual property only for authorized purposes, and we safeguard it from unauthorized access, use, or disclosure. We also respect the intellectual property rights of third parties, and we obtain their permission before using or sharing their intellectual property.
Insider Trading: We do not trade or tip others to trade in the securities of our company or any other company based on material nonpublic information that we obtain or possess in the course of our business. We also do not use such information for personal gain or advantage, or to influence or manipulate the market. We comply with all applicable insider trading laws and regulations, and we follow our company’s insider trading policy and procedures.
Gifts and Hospitality: We do not offer or accept any gifts or hospitality that may influence or appear to influence our business decisions or actions, or that may create or imply an obligation or expectation of favor.
Political and Charitable Contributions: We do not make any political or charitable contributions on behalf of our company or with our company’s funds or resources, unless they are authorized by our Board of Directors, and they comply with all applicable laws and regulations. We respect the personal political and charitable activities of our employees, but we do not reimburse or support them with our company’s funds or resources, or allow them to use our company’s name, logo, or reputation for such purposes.
Competition: We compete fairly and ethically in the market, and we do not engage in any anticompetitive or unlawful practices, such as price-fixing, market allocation, bid-rigging, or predatory pricing. We comply with all applicable competition laws and regulations, and we follow our company’s competition policy and procedures.
Health and Safety: We provide a safe and healthy work environment for our employees, customers, partners, suppliers, and visitors, and we take all reasonable measures to prevent and eliminate any hazards or risks that may cause injury, illness, or damage. We comply with all applicable health and safety laws and regulations.
Environmental Protection: We minimize the environmental impact of our operations, products, and services, and we seek to reduce our consumption of energy, water, and other natural resources, and to prevent or minimize our waste, emissions, and pollution. We comply with all applicable environmental laws and regulations.
Human Rights: We respect and support the human rights of all people, and we do not tolerate any human rights violations or abuses in our operations or in our supply chain. We comply with all applicable human rights laws and regulations, and we follow the United Nations Guiding Principles on Business and Human Rights and the Universal Declaration of Human Rights. We also expect our business partners, suppliers, and contractors to respect and support human rights, and to comply with our human rights policy and procedures.

Anti-Bribery and Anti-Corruption

We condemn and prohibit any form of bribery and corruption in our business, and we have a zero-tolerance policy and approach to preventing, detecting, and reporting any such activities. We define bribery and corruption as:

Bribery: The offering, promising, giving, requesting, accepting, or receiving of anything of value, directly or indirectly, to or from anyone, in order to obtain or retain a business advantage, or to induce or reward an improper or illegal action.
Corruption: The abuse of entrusted power or position, directly or indirectly, for private gain or advantage, or to the detriment of others.

We seek to comply with all applicable anti-bribery and anti-corruption laws and regulations, such as the US Foreign Corrupt Practices Act, the UK Bribery Act, and the OECD Anti-Bribery Convention. Our company procedures include:

Business Assessment: We assess our business partners, suppliers, and contractors to mitigate any bribery and corruption risks that may arise from our business relationships and transactions. We evaluate the bribery and corruption risks that may affect our business activities, both domestic and international.
Training: We provide training to our employees, managers, and stakeholders on our Code of Business Ethics Policy, and ensure that they understand and comply with them.
Monitoring and Auditing: We monitor and audit our business activities and transactions, and we verify that they are conducted in accordance with all applicable laws and regulations.
Reporting and Investigation: We encourage and enable our employees, managers, and stakeholders to report any actual or suspected bribery and corruption activities, either internally or externally (see Reporting). We investigate and resolve any reported cases promptly and thoroughly, and we cooperate with any external investigations or inquiries.

Anti-Human Trafficking

CIMCO has a zero tolerance policy on regards to human trafficking and forced labor of any kind. CIMCO will not tolerate and will not work with customers, resellers, suppliers or contractors that use or condone the use of slavery, forced, involuntary or coerced labor, child labor, or human trafficking of any kind by any employee, subcontractor or supplier. Effectively a zero tolerance policy.

Business Assessment: We are committed to and do carry out ongoing assessment and evaluation of our internal operations and supply chain to identify and eliminate any kind of human trafficking or slavery. All employees have both a duty and the freedom, without fear of retaliation, to report possible violations of our policies (see Reporting below).
Reporting and Investigation: The same duty and access also applies to our resellers and contractors. This includes any violation of law and labor laws. Any suspected activity of this type must be reported to CIMCO management and the proper authorities.

Our Reporting and Enforcement Mechanisms

We have established the following reporting and enforcement mechanisms to ensure the effective implementation and compliance of our Code of Business Ethics policy:

Reporting: We encourage and enable our employees, managers, and stakeholders to report any ethical issues or concerns, either internally or externally, through our email legal@cimco.com, or apropriate external authorities. We protect the confidentiality and anonymity of the reporters, and we do not tolerate any retaliation or discrimination against them.
Investigation and Resolution: We investigate and resolve any reported ethical issues or concerns promptly and thoroughly, and we take appropriate corrective and preventive actions to address them. We cooperate with any external investigations or inquiries, and we comply with any legal obligations or orders.
Disciplinary Actions and Sanctions: We impose disciplinary actions or sanctions for any violations of our Code of Business Ethics policy, or any applicable laws and regulations. The disciplinary actions or sanctions may include verbal or written warnings, suspension, termination, or legal action, depending on the nature and severity of the violation.

Our Commitment and Responsibility

We are committed to upholding and promoting the highest standards of ethical and lawful conduct in our business, and to respecting human rights and preventing any form of bribery and corruption in our operations. We expect our employees, managers, and stakeholders to share this commitment and responsibility, and to comply with our Code of Business Ethics policy, and with all applicable laws and regulations.

We review and update our Code of Business Ethics policy periodically.

If you have any questions or comments about our Code of Business Ethics policy, please contact us at legal@cimco.com