Yenlo’s Code of Conduct (hereafter referred to as “Code and/or MVO”) contains principles to comply with all applicable laws, promote ethical conduct in the workplace, respect for human rights, safe working conditions, the protection of sensitive information, and responsible, secure supply chains. These principles are of the utmost importance to Yenlo.
This Code applies to all Yenlo affiliates in the world including all employees, agents and any by Yenlo on secondment bases hired persons (hereafter called “Employees”)
We expect and endeavour that our customers, business partners and/or independent external suppliers (including subcontractors/sub processors and their employees/hired persons) that are doing business with Yenlo to uphold their own equivalent code and/or principles, that in substantive essence and content is more or less equal or similar to the principles as set out in this Code of Yenlo, however we don’t warrant the compliance thereof by our customers, business partners and/or suppliers.
Yenlo will lead by example, such as:
• Follow the law, this Code and our company policies.
• Listen to anyone who raises a concern with respect and compassion.
• Report suspected misconduct immediately.
• Never cover up or ignore misconduct.
• Never retaliate or allow retaliation against anyone.
We know that integrity is key to our success, so we prioritize ethics and compliance in our organisation.
SECTION A – Basic Human Rights
Yenlo values Basic Human Rights. Yenlo and its Employees will at all times respect and protect any and all (inter)national recognized basic human rights, be it political/civil, social or any other human rights (as set out in the Universal Declaration of Human Rights and internationally recognized declarations, such as those of the International Labor Organization (ILO) and the United Nations (such as BUPO, EVRM) subsidiary as set out in the local constitution of the country where we do business). Yenlo will not deliberately violate any Human Rights, nor do business or engage with anyone who deliberately violate or suppress Human Rights.
More specific: Yenlo will at all times comply with the 10 basic principles of the UN Global Compact, being as follows:
• Principle 1: companies should respect internationally proclaimed human rights within the limits of their sphere of influence.
• Principle 2: Companies should always ensure that they are not complicit in human rights violations.
• Principle 3: Businesses should uphold freedom of association and effective recognition of the right to collective bargaining.
• Principle 4: the elimination of all forms of compulsory and forced labour.
• Principle 5: the effective abolition of child labour.
• Principle 6: Combating Discrimination in Employment and Occupation.
• Principle 7: Companies should take precaution in their approach to environmental challenges.
• Principle 8: Take initiatives to promote greater environmental awareness.
• Principle 9: Stimulate the development and diffusion of environmentally friendly technologies.
• Principle 10: Businesses must fight corruption in all its forms, including extortion and bribery.
SECTION B – Compliance laws
Yenlo and its Employees will follow all laws and regulations everywhere we do business.
Yenlo will operate in full compliance with the laws, rules, and regulations of the jurisdictions (whether Dutch, EU, U.S. or otherwise) in which we operate or where we provide services to customers. In conducting international business, Yenlo, Employees, customers, business partners and suppliers are required to comply with all applicable (inter) national laws, executive orders, and regulations in the world, especially any applicable mandatory Dutch, EU and US laws, such as among others any US or EU: Bribery or Foreign Corrupt Practices Act, Anti-trust law, Boycott and Export restrictions rules. More specific below.
We Follow Trade and Sanctions Laws
We will not proceed with any transaction if the United Nations, U.S., EU or any nation in which we transact business has imposed a relevant trade sanction or embargo. We are committed to following all anti-money laundering and anti-terrorism laws. To avoid becoming an unknowing accomplice, we remain on the lookout for any red flags, including:
• Requests to pay more than the agreed price
• Payments from an unusual account
• Requests to pay in cash
• Payments from a third party not related to the account.
Therefore, we will not accept money if we don’t know where it came from.
Corruption, Bribery, Fraud and Money Laundering
We prohibit corruption and briberies for the benefit of any external or internal party. We expect employees to avoid any personal, financial, or other interests that might hinder their capability or willingness to perform their job duties. We are dedicated to conducting business with honesty and integrity and have a zero tolerance to corruption, briberies, and instances (or attempts) of fraud and money laundering. Yenlo expects its Employees not to engage in any forms of illegal or inappropriate activity, including corruption, extortion, embezzlement, or bribery, regardless of the country in which Yenlo receives services form suppliers and/or provides services to customers.
We will never make improper payments on our company’s behalf or allow anyone else to commit bribery for us. We will never accept bribes of any kind. For a good understanding: corruption concerns all forms of abuse of power by a person who has power. Bribery is a form of corruption that aims to get the person being bribed to do – or not do – something that puts the briber in a better position. See also our gift and sponsoring statement below.
The administration we keep – think of contracts and financial administration such as kilometres and working hours – is correct. We do not commit forgery. We prepare invoices in accordance with legal rules and business practices and are correctly dated, complete and transparent.
Yenlo competes fairly and openly. We adhere to competition law rules, which are aimed at effective and fair competition in a free market. We do not set prices or discuss prices with competitors or other competitively sensitive matters. We do not share company-sensitive information, for example about a tender, with competitors.
In some cases, regional policy and local laws may be stricter than our own. When this happens, we follow the local laws and policies. This Code supplements, but does not supersede, the Contracts between Yenlo and the customer.
SECTION C – ETHICS AND STANDARDS OF CONDUCT
Yenlo expects its Employees to act with honesty, integrity, and respect always in all their actions and to uphold the highest standards of ethics and behaviour.
1. Transparency and Business Integrity
Yenlo values conducting and winning business fairly. We never engage in unfair, deceptive or misleading practices, even if directly or indirectly requested by a Customer, business partner or supplier. We show our Customer, business partners and suppliers respect by being transparent at all times.
2. Conflicts of Interest
Yenlo requires that decisions made on its behalf be objective and fair and avoid even an appearance of a conflict of interest. Employees, Suppliers, and customers must avoid engaging in any activity that would create an actual or apparent conflict of interest regarding the provision of products or services by or to Yenlo. A conflict of interest exists when any relationships or activities impair, or even appear to impair, your ability to make objective and fair decisions when performing your job. In the event an actual or potential conflict of interest does arise, anyone must immediately report it to Yenlo compliance officer.
3. Gifts and Entertainment
We Don’t Give or Receive Gifts to Influence Decisions
We never give or receive anything that could inappropriately influence decisions or gain an unfair advantage. We discourage employees from accepting gifts from customers, business partners or suppliers.
Employees, customers, business partners and/or suppliers must never provide or accept (business) gifts, invitations or entertainment intended to improperly influence any person’s business judgment or that might create the appearance of undue influence or otherwise might compromise our independence of the recipient. It is never permissible to give or accept currency as a gift nor to give any kind of gift or donation to a governmental official (in connection with Yenlo) (Let alone when providing goods and services to government entities). Furthermore, any entertainment of any value are not permitted without the express written authorization of Yenlo.
Before accepting any a gift is accepted, please notify your Manager.
These are usually ok in consultation and after approval of your Manager: Promo Items, Flowers and Food. But here too only under the strict condition that it does not endanger your independence. Acceptance of inexpensive “token” non-cash gifts is permissible, provided that they are not excessive and do not create the appearance of impropriety.
These are never ok: Cash, gift cards, high value gift like laptop, vacations.
Sponsoring is at the heart of society. National, regional, local. That is why we might sponsor small and large events, always at the discretion of Management. Donations also occur. At the same time, we want to be careful with this. Sponsorship or donations can be seen as bribes, for example if someone receives an assignment or other favor in return. Do you suspect that sponsorship or donations are related to a new assignment? Please contact Legal/Compliance Department or Management of Yenlo.
Employees, customers, business partners and/or suppliers must not provide entertainment that could embarrass Yenlo or harm its reputation.
4. Competition, Advertising and Marketing
Yenlo embraces Free Competition. Yenlo expects Employees, business partners and suppliers to uphold fair and honest business standards in advertising, sales and competition. If any party, with Yenlo’s prior written approval, engages in any advertising, marketing or promotional activities that reference or implicate Yenlo, its name, logo or services in any manner, such materials must be truthful and accurate, with clear and conspicuous disclosure of Yenlo’s Intellectual property rights as well material terms and limitations of advertised offers.
5. Yenlo keep’s Accurate Books and Financial Records
We keep accurate, complete and timely financial records. Whether it’s revenue, expenses, marketing funds, or rebates, we record the details and purpose of every transaction. Our colleagues in the Finance Department ensure our financial disclosures are complete, fair, accurate, timely, and understandable. They maintain compliance with applicable accounting standards, laws and regulations that apply to Yenlo. Consistency and transparency help us build trust. The rest of us do our part by following our policies and processes for every transaction. We only use company funds for legitimate, authorized purposes, and we are never:
• Alter or misstate a financial record.
• Keep transactions “off the books.”
• Use fake transactions to hide a purpose, like using a fake invoice to conceal a bribe
6. Behaviour toward customer, business partner, supplier and colleagues
A professional attitude is expected towards customer, business partner and suppliers. After all, interests of the customer are always a priority in our line of work. Both project managers and project team members need to work on projects as accurately as possible and are friendly and polite in their communication towards clients. The contact with the customer takes place through the project managers / consultants or account management. For questions, problems or complaints the project manager is approached by the customer. The project manager deals with this properly and keeps the customer well informed about the state of affairs.
7. We Choose Our Words With Care
* When speaking on behalf of Yenlo, we have to be careful what we say and how it reflects on our company.
• If the media or an outside party comes to us with questions about Yenlo, we refer them to our Marketing Department.
• If a government authority raises any questions, we contact the Legal Department right away.
* We never remove, destroy or alter any related information.
• We conduct ourselves professionally on social media.
• We never communicate in any way that could be seen as offensive, harassing, abusive or illegal. We are a respectful, inclusive company. We want to be a place where everyone can come, thrive and feel respected. We would never want anyone to feel uncomfortable or unwelcome because of their personal identity. We demonstrate our commitment to inclusion in our words and actions.
SECTION D – Government Procurement and Governmental Interaction(s).
In case of any Government Procurement and/or interacting with any government officials or any other public sector employees you have to be even more extremely careful and all the rules as set in this Code (like in respect of Transparency/Business Integrity, Conflict of Interest, Gift and Entertainment, donations, Competition law etc. etc.) apply even more. In many countries, very strict rules apply to this kind of interaction. When bidding for tenders and contracting (in)directly with government agencies, we must comply with a complex set of rules and work closely with the legal department of Yenlo. At a minimum, we must ensure that:
• All government statements in project proposals, bids and reports are complete, accurate and not misleading;
• All invoices submitted accurately reflect the work in question and do not exaggerate the amount to which Yenlo is entitled;
• We cooperate in good faith with all government requests regarding audits and inspections; and
• We immediately report any suspected violation of law or regulation, company rules or our contractual obligations.
SECTION E – LABOR
We offer our employees good and safe working conditions and competitive terms of employment. We comply with the employment laws in all countries in which we operate, including minimum wage, overtime, maximum-hour rule and legally mandated benefits. Employees should have the ability to earn fair and equal wages, as determined by applicable local law. We believe that employment must be freely chosen. We forbid human trafficking, forced, bonded or involuntary labour. We will not tolerate the exploitation of children or child labour. Yenlo views it as a business imperative to uphold the human rights of workers by treating them with dignity and respect and we expect the same commitment from Employees, customers, business partners and suppliers.
SECTION F – NON-DISCRIMINATION
We are committed to the fair, equitable and inclusive treatment of all people. Everywhere we operate around the world, we work to serve people and be a force for good.
Yenlo embraces diversity and equal opportunity as fundamental principles and key components of its corporate strategy. We do not allow any kind of discriminatory behaviour, harassment, or victimization. Employees should conform with our equal opportunity policy in all aspects of their work, from recruitment and performance evaluation to interpersonal relations.
Yenlo will recruit, select, promote, and remunerate Employees solely based on a person’s work abilities and performance, regardless of race, colour, religion, age, gender, pregnancy, sexual orientation, gender identity and expression, national origin, disability, marital status, citizenship status, veteran status or military status.
We must maintain a workplace culture based on respect where all forms of unlawful harassment and abuse, including sexual harassment, is forbidden. Unlawful harassment includes conduct or language that creates a hostile or offensive work environment. It can be physical, verbal, or visual, and sexual harassment may include inappropriate touching, unwelcome romantic advances, lewd gestures or the display of obscene material.
Yenlo believes that building an inclusive organisation makes an economic impact in the communities we serve while creating a competitive advantage. We Respect Each Other. We all want to work in an environment that is respectful, professional, and safe.
SECTION G – HEALTH AND SAFETY
Yenlo is committed to maintaining a safe and healthy workplace in accordance with all applicable health and safety laws, regulations, and to industry codes. We expect the same commitment from Customers. Workplace health and safety is a priority for Yenlo. Maintaining a professional and productive workplace is an imperative for Yenlo. Yenlo is committed to maintaining a work environment that is free from violence and weapons, (sexual) harassment or threatening, hostile or abusive behaviour. Employees must never engage in violent or threatening behaviour toward anyone in the workplace, including to other personnel, customers, business partners or suppliers.
See also our art 10 of our Yenlo Employee Handbook 10 Health and Safety Policy – Yenlo Management System. As well our Sexual Harassment Policy in art 9.2.6 of our Yenlo Employee Handbook 9 Code of Conduct – Yenlo Management System.
Yenlo Employees will always adapt to the customer’s office rules. These may differ from Yenlo’s office rules.
SECTION H – COMPANY PROPERTY
The term company property must be interpreted in the broadest sense possible. It is not just about matters that are Yenlo property in the legal terms, it is also about all the things that are made available through Yenlo, but which are the personal or business property of others. All in all, every asset that is made available to Employee through or by Yenlo should explicitly be considered company property and therefore be handled as such.
“All things” includes more than just the things that are made available to you while exercising the tasks arising from your Employment Agreement with Yenlo. It also covers the assets that you produce or develop yourself on behalf of or for Yenlo based on the tasks arising from your Employment Agreement with Yenlo.
The term ‘made available to’ must be interpreted broadly. It does not just include the things that are physically – either directly or indirectly – handed over to an Employee, it also includes data or information you accidentally listen into or stumble upon, e.g., while chatting during lunch or walking down the hallway. Everything heard or used while exercising your duties is also considered company property.
We protect our company property, IT systems, sensitive and/or confidential information. Yenlo has a strong reputation. Correct handling of vulnerable information contributes to that reputation. We therefore handle it with the utmost care. Yenlo requires the proper use of its company property, proper use of its funds, and proper care of it and its customer’s, business partner’s, supplier’s non-public information. For our applicable confidentiality classification, we refer to Data Handling – Yenlo Management System. Every employee is bound by a duty of confidentiality. This is also stated in each employment contract. And applies among others, and even more to any customer and medical patient data.
When we are trusted with confidential information, we take steps to keep it confidential. • We do not discuss confidential information where it might be overheard.
• We do not leave confidential information unattended.
• We never post confidential information on social media or external sites. We never share confidential information with anyone outside of Yenlo unless authorized. If we are authorized to discuss confidential information with a third party for a legitimate business need, we always have an executed nondisclosure agreement (NDA) in place first (unless an existing Contract already foresees in a confidentiality clause). Like confidential information, intellectual property (IP) rights are a valuable resource. We protect those rights together.
In general, Employee and Yenlo are obliged to do everything and to refrain from whatever a good Employee and Yenlo is expected to do and not do More specific: Employees, customer’s, business partner’s and/or suppliers must use all Company property, including, but not limited to, equipment, funds, documents, electronic and written information and communications systems, with care and adherence to acceptable standards and Yenlo’s rules and procedures. We observe three rules of thumb: be careful and observant, always clean up documents, never share passwords with others. To avoid misunderstandings: Employees may only use company property for business purposes unless private use is (limited) permitted, for example lease cars. Furthermore, we will not provide information about Yenlo to clients or other business relations if this could harm Yenlo’s interests.
Yenlo will not tolerate falsification or improper alteration of records. Anyone must report any suspected or actual misuse, theft, vulnerability, improper exploitation, or sabotage of Company property. Records prepared for Yenlo, including records of all time worked and expenses, must be accurate and complete.
See also article 9 of our Yenlo Employee Handbook 9 Code of Conduct – Yenlo Management System – Confluence.
SECTION I – PRIVACY – Data Protection – INFORMATION SECURITY AWARENESS
We respect the individual privacy of our employees, but also of customers, business partners, suppliers and other parties with whom we do business. Our Customers, business partners and suppliers trust us with their personal information, which is information related to an identified or identifiable person. We repay that trust by treating their personal information with care. We are committed to collecting and using personal information in a lawful, fair and ethical way, and we will always respect the privacy of individuals. As a global company, we are responsible for complying with the data-protection laws and regulations of various regions, countries, states and local authorities. Personal data in the EEA (including export form EEA) is protected in accordance with the GDPR. Any information must be protected from unauthorized disclosure and must not be used except in accordance with applicable regulations and contractual requirements. Employees must comply with all applicable privacy, data protection, and information security laws and associated regulatory requirements as well as with all Yenlo’s privacy, data protection, and information security policies and updates thereupon. Especially if confidential or personal information, is collected, stored, processed, disclosed, transferred and/or shared. We have developed policies and procedures for collecting, handling and storing information to ensure its safety and security. We will continuously improve our technical and organizational measures, so that your data security and privacy protection is in good hands. Each Employee has his or her own responsibility in taking the necessary measures to protect information within the process for which he/she is responsible. For further information regarding information security see the Yenlo System Handbook.
SECTION J – SOCIAL MEDIA
We conduct ourselves professionally on social media. Visiting websites, sending e-mails or posting messages on the internet or that are of pornographic, racist, discriminatory, abusive, offensive, sexually harassing or otherwise unlawful nature, as well as posting messages that could in any way incite hatred and/or violence is strictly prohibited.
SECTION K – ENVIRONMENTAL & SUSTAINIBILITY
Yenlo embraces a Healthy Planet. Yenlo recognize that a sustainable, healthy environment and safe workplaces are critical to our society, economy, business and people. We are committed to using our role in the supply chain to make a positive impact on the planet. We know that preserving the planet starts in our own backyard. We want to add value to a healthy sustainable living environment and to the future of the world and our grandchildren,
Yenlo therefore will strive and endeavour to commit itself to the global efforts to become a more Sustainable Climate Neutral and Natural Environment world.
Our environmental policy includes two major components to help minimize our impact on and achieve our objectives around the environment.
Waste reduction and recycling
Helping to preserve the environment by using the principles of reducing, reusing, and recycling. For example we recycle office paper, lamps, computers/laptops and computer monitors, promote to reduce print outs and we dispose our batteries and glass waste separately.
Focusing on improving energy efficiency in building design and construction, reducing energy costs through for example usage of energy saving lights, Quookers and identifying opportunities in new and innovative programs in the future. Water conservation for example by using low flush toilets and promoting the usage of energy efficient and full electric lease cars.
We hold ourselves Accountable
Whenever we fall short of this Code, we put ourselves at risk. Our Customers, business partners and suppliers must know they can count on us every time. Even a single violation of our Code can kill that trust. When we receive a report by whomever, we will carefully investigate all good-faith reports on any possible violations of the Code, and if we find any unethical or illegal behaviour, even if the violator is at highest management level, we will take appropriate corrective action. Good to know: managers, confidential advisers and the compliance officer handle reports with complete confidentiality and any good faith reporter will be legally and actually protected. Yenlo prohibits retaliation against anyone who reports or participates in an investigation of a possible violation of our code, policies, or the law.
In case the management of Yenlo itself, despite a 30 days written substantiated notice of default remains structurally and gravely in material breach of this Code + any subsequent by Yenlo or parties drawn up remedy plan, Customer, business partners and/or independent external suppliers sole remedy will be to terminate the remaining term of its all its pending agreements with Yenlo. Termination of the remaining agreements constitutes full damage compensation for any aggrieved Customer, business partners and/or independent external suppliers in respect of any material breach of this Code.