Code of Conduct

Introduction

Treat others like you would like to be treated. This means that whatever is hurtful to you, do not do to any other person. However, complex business environment requires a detailed explanation of this saying.

For the most part, obeying this rule means thattreating our colleagues and clients with the respect they deserve. But there’s more.

This saying implies acting according to the highest moral values in our day-to-day life, which means applying those ethical principles to the business environment. We have defined high ethical standards, which helps to bring morally aware people, the ones that are committed to their work, have great knowledge and are constantly working on expanding it. Trust, respect, loyalty, and concern for others are just some of the principles we stick to.

Every employee has his/her own moral values. Listening to the internal, moral compass and contributing to everyday work is the base of every good company. However, each person has a different moral compass. To avoid any misunderstanding, we created a Code of Conduct, a code that harmonizes personal, moral norms into ethical business norms.

Please be sure read our Code of Conduct. If you have any questions regarding the Code of Conduct or think that a colleague is not acting according to the Code, be sure to get in touch with the Manager or the CEO. We want to hear from you.

What if I have Code-related question and concern?

If you have any question or concern, be sure to contact the Manager or, if needed, the CEO. If you believe a violation of the Code has occurred, be sure to notify the Manager as soon as possible.

Our Principles

There are a few ethical principles we obey, in order to establish a trustworthy relationship with clients and employees. These principles and ethical processes contribute to the overall success of our company:

Integrity and Honour

As we previously mentioned, a quality relationship is a relationship built on trust. That’s why we keeping things real. We tell our clients the truth and nothing but the truth.

Loyalty

We don’t bail out on clients. Period. We don’t leave out clients dry. If a rough time comes, we find the solutions.

Privacy

We have to remember that we are asking clients to trust us with their business and private information. Preserving that trust requires that each employee respects and protects the privacy and the security of each information we are given. Every employee should take measures to protect client’s data from unauthorized access.

Accountability

It is our duty to accept the consequences of our acts.

Commitment to Excellence

Kolosek is always striving to get better. Anytime you feel that the company hasn’t provided the client best possible service, be sure to let someone in the company know about it. Being proactive means being morally invested in the working environment.

Working in a Supportive Environment

Having a supportive working environment means allowing employees to reach their full potential. Our company culture does not support discrimination, harassment, and intimidation of any kind.

Equal Opportunity

Employment is strictly based on professional competence - knowledge, experience, and willingness to learn more. Kolosek prohibits discrimination or harassment on the basis of race, color, religion, veteran status, national origin, ancestry, pregnancy status, sex, gender identity or expression, age, marital status, mental or physical disability, medical condition, sexual orientation, or any other characteristics.
Kolosek is, also, protecting the rights of the disabled.

Discrimination and Harassment

We prohibit discrimination, harassment, and bullying in any form – verbal or physical. If you believe you’ve been discriminated or harassed by anyone at Kolosek, immediately report the incident to the Manager, or, if needed to the CEO directly.

Drugs and Alcohol Abuse

Anything that can harm the health and the safety of our employees, including drugs and alcohol, is forbidden.
Consumption of alcohol is only allowed during company’s celebrations. Please note that alcohol directly affects the level of productivity, can cause inappropriate behavior and endangers the safety of others.
Illegal drugs in our offices or at celebrations are strictly prohibited.

Safety of Our Employees

It is important to us that our co-workers feel safe and protected in the workplace. We will not tolerate any level of violence or the threat of violence in the workplace. If you become aware of a violation of this clause of the Code, please report it to the Manager or CEO.

Pet-friendly Workplace

We believe that pet-friendly working environment lowers our employees’ stress level and stimulates the conversation. Kolosek is a company of which consists of animal lovers.

Avoiding Conflicts of Interests

Conflict of interest means having to decide whom to be loyal to - the company or some third party. If an act can lead to potential benefit for you, your friends, or your family at the expense our clients and users, you are faced with a conflict of interest. Keep in mind that any action that can benefit yourself, your friends and family at the expense of the company is considered as a conflict of interest situation.
Here are some areas in which the conflicts of interest can arise:

• another employment and roles, and starting your own business,
• investments,
• other business opportunities,
• accepting gifts and other business courtesies,
• friends, relatives, and co-worker relationships,
• inventions.

Another Employment and Roles, and Starting Your Own Business

Avoid accepting employment and other roles and positions with Kolosek competitors if it appears that can be harmful to Kolosek. Also, you are forbidden to start a business that will be a competitor to Kolosek.

Investments

Avoid making investments in companies that are Kolosek competitors, since this kind of investment can cause harm to Kolosek.
When determining whether a personal investment creates a conflict of interest, consider the relationship between the business you are willing to invest and Kolosek.

Other Business Opportunities

This clause is covering business opportunities which are discovered through your work at Kolosek. These opportunities belong to Kolosek, except as otherwise agreed to by Kolosek.

Accepting Gifts, Entertainment, and Other Business Courtesies

Accepting gifts and other business courtesies from someone other than the client is strictly prohibited.
Accepting inexpensive, non-cash gifts as a sign of gratitude from clients is allowed. In addition, occasional business meals and entertainment with clients are allowed.
Kolosek is operating according to the Law of the Anti-corruption Agency.

Friends, Relatives and Co-Workers Relationships

Avoid participating in decision-making regarding potential or existing Kolosek business relationships that involve your friends, relatives, spouse or a partner.
Romantic relationships between co-workers can, in certain situations, create a conflict of interest. If a romantic relationship does create a conflict, it may require changes to work arrangements or even the termination of employment of either or both individuals involved, depending on the seriousness of the situation.

Inventions

It is forbidden to develop or help develop any product that can relate to Kolosek’s products and services or employee’s position in the company. If you have any question about intellectual property or inventions, be sure to contact the Manager.

Communication and Information Confidentiality

Every part of our relationship with the client is highly confidential. Any intentional leakage of the information is forbidden, as well as giving information to Kolosek competitors.

Information Confidentiality

Every information about the client, company’s process or employees is highly confidential, except the information that is widely available (the Law on Free Access to the Information of Public Importance). Furthermore, if there is a need for a third party to receive the confidential information, we require a security assessment evaluation of that party.
However, sharing information isn’t always “black and white”. You will need to apply your best judgment in making sure you don’t disclose any confidential information.
Regarding the pictures you and your guests take at Kolosek are not to be widely used and published. Pictures taken at Kolosek can only be used by the Kolosek’s team, as a part of the promotional content.
Finally, if a family member, a partner or a friend works at competitors company, be sure not to share confidential information about the company.

Transparency

It’s equally important not to disclose any confidential information from our clients. However, don’t accept confidential information from other companies.

Competitors and Former Employers

Competing fairly means not wanting to get the hand on their confidential information. On other matter, if there is an opportunity to take advantage of a competitor’s or former employer’s confidential information, don’t do it. If you are in the possession of a competitor’s confidential information, contact the Manager immediately.

Outside Communications

You should also ensure your outside communications (including online and social media posts) do not disclose confidential proprietary information or represent (or give the impression) that you are speaking on behalf of Kolosek unless you’re authorized to do so by the company. The same applies to communications with the press.

Protecting Kolosek’s Assets

Our ability to continue to build a respectful relationship with the clients is directly affected by our ability to create and perform best mobile and web apps. That’s why we need to protect company assets and data.

Intellectual Property

Kolosek’s intellectual property rights (trademarks, logos, copyrights, trade secrets, and “know-how”) are among our most valuable assets. Every employee must respect all copyright and other intellectual property laws. You should never use Kolosek’s logos, marks, or other protected information for any business or commercial use before having an authorization from the Manager. That being said, you should report any misuse of trademarks, logos, or other company’s intellectual property to the Manager. Inappropriate use of intellectual property may expose you to criminal and civil fines and penalties. The same rule applies for using some other intellectual property.
On the other hand, Kolosek is committed to open-source software development, which means we strictly stick to the license requirements under which open source software is distributed.

Equipment and Other Physical Resource

Company funds, equipment, and other physical resources should not be used for personal matters.

The Hardware

The company’s communication hardware like computers and mobile devices are a critical aspect of our company’s property, both physical and intellectual.

Physical Security

We are a small team and chances of someone stealing your equipment is almost non-existent. However, always be sure to secure your laptop, important equipment, and your personal belongings.

Being Financially Responsible

A financially responsible company is a company of professionals. Financial integrity is so much more than financial reporting. You must remember that the money you spend on behalf of Kolosek’s is not yours - it’s the company’s.

Company’s Money

The Manager is responsible for all money that is spent. When you want to submit an expense or spend money on company’s behalf, make sure that the cost is:

• reasonable,
• directly related to company business,
• is related to building your professional skills and experience
• and is supported by appropriate documentation.

If you’re uncertain about whether you should spend money or submit an expense, check with the Manager.

Retention Period of the Records

It’s important that we keep records for an appropriate length of time. There are a few suggested minimum record retention periods, depending on the type of the records. If you have any questions regarding the correct length of time to retain a record, be sure to contact the Manager.

Obeying the Law

Kolosek obeys laws and regulations very seriously and each employee is expected to obey them, as well. We are aware there are over a dozen laws you should be aware of, but we will name a few that can be violated unintentionally and easily:

Company’s Trading

Kolosek can send or receive products and/or services.
If you are in any way involved in sending or making available Kolosek products, services, software, equipment, or any form of technical data from one country to another, work with the Manager to be absolutely sure that the transaction stays well within the bounds of applicable laws.

Competition Law

Competition law makes sure we are competing fairly on the market. Generally speaking, competition law prohibits:

• making arrangements with competitors that can affect trading in some way,
• creating a business strategy which the main goal is harming a competitor,
• sharing important information with competitors,
• abusing intellectual property rights.

Kolosek competes fair and square. If you observe that anyone at the company is violating the competition laws, be sure to notify the Manager.

Insider Trading

Using a non-public information in any way is called insider trading. Not only that Insider trading violates this Code, it violates the law.

Anti-bribery Law

As we previously mentioned, Kolosek operates according to the Law of the Anti-corruption Agency. Bribing anyone is forbidden.

Business Relationships

You should be careful when you give gifts and pay for meals, and making other business courtesies on behalf of Kolosek. Kolosek wants to minimize the possibility of a gift, a meal or some other courtesies to be perceived as a bribe. To avoid it being perceived as a bribe, keep the courtesies occasional and provide a gift of a moderate value.

Dealing with Government Officials

Offering gifts or other business courtesies that could be perceived as bribes especially if you’re dealing with a government official. Don’t give gifts to thank government officials for doing their jobs.

Conclusion

Treat others like you would like to be treated. Code of Conduct is a simple guide that explains how to act in certain situations. We are aware of the fact that that the Code doesn’t cover all ethically challenging situations and we are advising you to follow the spirit of the Code and make a morally acceptable decision.
Treat others like you would like to be treated covers a pretty wide range of actions. Always have this saying in mind and we believe you will be able to reach your most pure self.