Code of Ethics

This Code of Ethics sets expectations for conduct by all directors, officers, employees, contractors, and agents of SCADAware and its subsidiaries. The company is committed to lawful, honest, and transparent business practices that protect customers, colleagues, partners, and the communities in which it operates.

1. Public commitment & leadership

 

  • SCADAware publishes a clear, public commitment to anti-corruption, integrity, and ethical business conduct on the corporate website and in corporate responsibility materials.
  • Senior leadership endorses and promotes this Code through periodic public statements and internal communications and will be measured on adherence to these principles.

2. Anti-corruption & gifts

 

  • Bribery, kickbacks, facilitation payments, or any form of improper payment to obtain or retain business are strictly prohibited.
  • Employees must not offer, promise, give, request, or accept gifts, hospitality, travel, or other benefits that could reasonably be perceived to influence business decisions. Routine, modest business hospitality is permitted only when (a) it is lawful, (b) it is reasonable in value, (c) it does not create a conflict of interest, and (d) it is pre-approved according to the Gifts & Hospitality Procedure.
  • All gifts, hospitality, and client travel that exceed the pre-approved thresholds must be disclosed and approved in writing by the Ethics Officer or Compliance Committee. Detailed records must be maintained.

3. Travel & entertainment

 

  • Expenditure on client travel and entertainment must have a legitimate business purpose, be pre-authorized, and be documented. Personal travel or lavish entertainment paid for by clients or partners is prohibited without written approval from the Ethics Officer.

4. Fair competition & antitrust

 

  • The company competes fairly and complies with all applicable competition and antitrust laws. Prohibited conduct includes price fixing, market allocation, bid rigging, exchanging competitively sensitive information, and any other activity that unlawfully restricts competition.

5. Privacy, data protection & intellectual property

 

  • Customer, partner, and employee personal data will be collected, used, stored, and deleted in compliance with applicable privacy laws and internal data protection policies. Access to personal or sensitive data must be limited to those with a legitimate business need.
  • Intellectual property — whether owned by the company, customers, or third parties — must be respected. Unauthorized use, sharing, or misappropriation of IP is prohibited. Proper licensing, attribution, and confidentiality procedures must be followed.

6. Child labor & supply-chain responsibility

 

  • The company prohibits the use of child labor in any part of its operations and expects suppliers and partners to do the same. Supplier selection and contract clauses will include commitments to labor standards and the right to audit or require corrective actions where violations are suspected.

7. Reporting, advice & non-retaliation

 

  • Multiple confidential channels are provided to report suspected violations or seek guidance: direct manager, HR, the Ethics Officer, or the anonymous reporting channel (phone/email/web form) listed on the corporate website.
  • Reports may be made anonymously where permitted by law. The company prohibits retaliation against anyone who, in good faith, raises a concern or cooperates in an investigation. Retaliation is a serious violation subject to discipline.

8. Training & awareness

 

  • Documented training on anti-corruption, competition law, privacy, IP, gifts & hospitality, and whistleblower procedures will be provided to employees on hire and at regular intervals thereafter. Completion of required training is mandatory and tracked.

9. Memberships & external engagement

 

  • The company may join or participate in reputable industry associations that promote ethical business conduct. Such memberships will be disclosed on the corporate website where appropriate.

10. Compliance, monitoring & enforcement

 

  • The Ethics Officer or Compliance Committee is responsible for monitoring compliance, conducting investigations, maintaining records, and recommending disciplinary action when necessary. Violations of this Code may result in corrective action up to and including termination and, where appropriate, referral to law enforcement.

11. Scope & updates

 

  • This Code applies globally to all parts of the business and will be reviewed periodically to reflect regulatory changes, best practices, and stakeholder expectations.