Code of conduct
Introduction
IAR is committed to upholding high standards of integrity and professionalism in all its business activities. We recognize the importance of respecting applied laws and regulations while adhering to our shared values and ethical standards. We have developed a comprehensive Code of Conduct that sets clear guidelines for conducting business and making decisions.
This Code of Conduct reflects our core values of integrity, accountability, respect, and excellence. It provides a framework for us to work together in a way that is ethical, responsible, and respectful of our colleagues, customers, partners, and the communities in which we operate. It is not simply a set of rules but a reflection of who we are as a company and what we stand for. We encourage you to promote and uphold the principles described in the Code of Conduct in your daily work and interactions. Our success as a company depends on our ability to operate with integrity and excellence continuously. The Code of Conduct is based on UN principles, EU regulations, and applicable international laws and regulations, including but not limited to
- UN Universal Declaration of Human Rights and connected UN Conventions
- UN Guiding Principles on Business and Human Rights
- UN Global Compact
- Tripartite Declaration of Principles of the International Labor Organization concerning Multinational Enterprises and Social Policy
- OECD Guidelines for Multinational Enterprises
- European General Data Protection Regulation (GDPR)
- European Climate Law
- EU Whistleblowing Directive
- UK Bribery Act
Scope of application
This Code of Conduct applies to all our employees and business partners that provide products or services to IAR or are engaged or instructed to act for or on behalf of IAR, such as suppliers, contractors, consultants, distributors, agencies, and other representatives.
Legal compliance
We require all our employees and business partners to operate in accordance with the principles in the Code of Conduct, and in full compliance with all applicable laws and regulations. The Code of Conduct does not replace legislation; if they conflict, legislation takes precedence. If the Code of Conduct sets a higher standard than the existing legislation, the Code of Conduct takes precedence.
Implementation and monitoring
We will continue to monitor the implementation and adherence to the Code of Conduct. We conduct regular Supplier Due Diligence to assess our business partners’ compliance with this Code and secure a resilient supplier base. We expect our suppliers to support and cooperate in the process. Any violations will be handled immediately and may jeopardize the business partner’s business relationship with IAR, up to and including termination.
Report of misconduct
Improper behavior or violation of any kind against the Code of Conduct will be actively addressed at IAR. IAR employees and external business partners or stakeholders are encouraged to speak up freely and without fear of repressive measures. Repressive measures against reporters who speak out in good faith are prohibited. A strong speak-up culture is a crucial element of success. External third parties, including business partners, customers,
suppliers, and other stakeholders, are invited to report concerns using the whistleblower function, ”A Safe Place to Be Heard.” This function is accessible via the HR page on HiBob, Your voice, and through a link on the website, Whistleblowing. Your messages and identity will be kept anonymous, and your voice is important.
Business ethics
IAR and its business partners are obligated to all stakeholders to observe high standards of integrity and fair dealing. We respect the laws and regulations of the countries where we operate and require that our business partners do the same. We do not tolerate any form of corrupt activities, including but not limited to bribery, conflicts of interest, fraud, extortion, embezzlement, and unlawful kickbacks. Our employees or business partners shall not engage in or cause IAR to commit corrupt activities.
Competition and antitrust laws
Our employees and business partners conduct business in a fair and ethical manner and comply with all applicable competition and antitrust laws and regulations. This means, among other things, not engaging in price fixing, market sharing, bid rigging, or customer allocation.
Anti-bribery and corruption
We conduct our business with honesty, integrity, and transparency and avoid any actions that could compromise our ethical standards, including offering or accepting bribes or kickbacks, violating the UN Convention against Corruption. We do not tolerate any illegal or unethical behavior.
Accounting practices
We comply with applicable laws, regulations, and accounting principles, including EU and international financial reporting standards. We maintain accurate, complete, and transparent financial records through established internal controls and processes that support the integrity and security of our financial reporting.
Conflict of interest
Conflict of interest between a business partner and IAR must be avoided or identified and communicated to the CEO. Conflicts of interest may include external business activities, personal financial interests, internal information, and employment of, buying from, and selling to family members and close personal friends.
Trade and export control
We are committed to complying with all applicable trade policies, export control laws, and regulations in the countries where we operate. We follow the EU guidance on internal compliance program (ICP) to ensure that our products, including software, technology, and services, are only exported, re-exported, or transferred physically or electronically with the required export authorization. We know the complexity of export control regulations, including sanctions, and will continue to monitor the related changes and update our export control policies or procedures accordingly when necessary. We provide compulsory, periodic training for all staff with compliance responsibilities to ensure they possess sufficient knowledge to comply with the export regulations. For further guidance, refer to IAR Export Control Policy and Process.
Protection of assets and information
We protect our as well as our business partners’, assets and confidential information from unauthorized access or misuse. We do not use company resources or confidential information for personal gain or benefit. We set high security requirements to reduce the risk of illegal intrusion, sabotage, damage, disruption, data intrusion, or any other action that may lead to any form of loss. Information security refers to material, equipment, information, and knowledge. All employees are responsible for maintaining a high standard of security, including managing passwords and PIN codes and using our communication systems appropriately when processing, storing, or sharing information. Employees must not use our systems to send, store, or distribute information that is false, illegal, harassing, or not compliant with professional behavior. Intellectual property, such as inventions, patents, copyrights, knowhow, trade secrets, designs, trademarks, and related licenses, are highly valuable assets. The value of these assets can be lost or compromised if they are misused or inappropriately disclosed. Therefore, it is crucial that all employees protect our intellectual property and respect the intellectual property rights of others. Any misuse or inappropriate disclosure of intellectual property will be addressed with appropriate actions to defend our rights. Any crime, such as theft, waste, embezzlement, fraud, blackmail, or receipt of bribes, is unacceptable and can lead to disciplinary action, such as written notice or dismissal. Any such violations within IAR will be reported to the police or other appropriate authorities.
Responsible social media use
We use social media, such as Facebook, LinkedIn, WeChat, and other sites responsibly and professionally, per company policies and guidelines set about confidential information. We do not engage in offensive or defamatory behavior on social media, and we respect the privacy and intellectual property rights of others.
Data privacy
We respect individuals’ privacy rights and protect personal data belonging to each other, our business partners, customers, and those we work with, in accordance with the EU General Data Protection Regulation (GDPR). We do not share or disclose personal data without proper consent and take all necessary measures to prevent data breaches or unauthorized access.
Customers, business partners, and shareholders
We prioritize the satisfaction and trust of our customers, business partners, and shareholders. We strive to provide high-quality products and services and maintain transparent and respectful relationships with our stakeholders. We require that our business partners take due care and put in place quality assurance processes to ensure their products or services provided to IAR meet applicable quality standards or exceed the contract requirements.
People
IAR is dedicated to its social responsibility to create long-term value for all stakeholders and expects its employees and business partners to ensure compliance with all applicable laws, regulations, and organizational requirements.
Human rights & labor standards
We respect and promote human rights and fair labor practices. We do not tolerate any form of child labor, forced labor, or bonded labor — including the use of prison labor or unauthorized workers — in violation of applicable national or international laws and related conventions. We expect the same commitment from our business partners. We acknowledge that forced or bonded labor can include requiring a deposit of payment or demanding a deposit of identity documents or other personal belongings, all of which are prohibited. If business partners employ foreign workers on a contract basis, they must not be required to remain in employment against their will and shall further have the same rights as local workers. The employer will pay for commissions and recruitment agency fees in connection with the employment where applicable. All workers have the freedom to leave their workplace and accommodation (if provided).
Responsible for sourcing minerals
We expect our suppliers to take reasonable steps to identify, assess, and address potential human rights and environmental risks in their operations and supply chains, in line with international frameworks such as the OECD Due Diligence Guidance. We encourage transparency in mineral sourcing and prioritize collaboration with suppliers who strive to uphold high environmental and labor standards. We are committed to complying with relevant laws and regulations requiring the disclosure of the use of conflict minerals. Conflict minerals are minerals from high risk and conflict affected areas that have directly or indirectly contributed to financing armed groups, where some groups are believed to be responsiblefor serious human rights violations. Goods provided to IAR shall comply with relevant laws and regulations regarding conflict minerals.
Freedom of association and collective bargaining
We respect the rights of our employees in having the freedom to join, or not to join, an association of free choice, as well as establish an association of free choice, to organize, and to bargain collectively or individually by local laws and regulations. No employee should risk being harassed or retaliated against for exercising these rights.
Workers’ contracts, working hours, and compensation
We expect our business partners to comply with local laws and regulations regarding workers’ contracts and working hours, including overtime and overtime compensation. Salaries should be paid regularly and comply with applicable legislation and local market situation. Workers should be entitled to a minimum of one day off in seven and time off for established national and local public holidays. Workers should be granted the stipulated annual, sick, and maternity/paternity leave without any negative repercussions.
Discrimination, harassment, and diversity
We value and promote diversity and gender balance and expect our business partners to provide a work environment where everybody is treated with respect and dignity and given fair and equal opportunities for development. We do not tolerate discrimination or harassment in the workplace, and our business partners shall not discriminate against any worker based on race, ethnicity, sexual orientation, gender, religion, age, disability, political opinion, nationality, or any other potentially discriminatory factor.
Work environment
We strongly value and rely on our passionate employees and strive to practice our corporate culture, improve our work environment, and encourage everyone to contribute their best performance and creative ideas. We work systematically with health and safety, are committed to providing a safe work environment, and expect our business partners to do the same. Risks that can cause accidents or impair the health and well-being of individuals while working for IAR shall be reduced. A safe work environment includes clean and well-organized workspaces, ergonomic working conditions, and a comfortable indoor climate with appropriate lighting, temperature, and noise levels. Clear routines, accessible guidance, and tools that support employees in performing their work efficiently and safely are essential. Health and safety risks should be continuously identified, assessed, and managed as part of our preventive work environment efforts.
Building and fire safety
Hazardous materials and equipment must be stored according to applicable laws. There should be marked emergency exits in all workplaces. Exits must not be blocked and should be well-lit. All employees shall receive information about safety arrangements, such as emergency exits, fire extinguishers, first aid equipment, and similar applicable measures. An evacuation plan shall be displayed on each floor of the building. The fire alarm should be tested, and evacuation drills should be done regularly.
First aid and medical care
First aid equipment must be available at appropriate locations. The business partner shall ensure that any injuries occurring on their premises are promptly addressed and that necessary medical care is provided. In cases where such care is not covered by social security or insurance, the business partner is expected to cover the costs, provided that applicable safety procedures and regulations have been followed.
Alcohol, drugs and performance-impairing substances
We are committed to a safe and productive work environment. Working under the influence of alcohol, illegal drugs, or any substance — legal or illegal — that impairs performance, judgment, or safety is strictly prohibited. Responsible alcohol consumption may occur at company-approved social functions.
Environment and sustainability
Climate and environmental commitment
We support climate action and aim to contribute to the global transition towards net zero emissions, in line with the Paris Agreement and the UN Sustainable Development Goals (SDGs). While we are at the beginning of this journey, we are working to align our activities with these targets. As a software services company, our direct environmental impact is relatively low. Therefore, we focus on the areas where we can make the greatest difference, such as minimizing our
operational footprint, supporting the development of energy-efficient applications, and reducing emissions in Scope 2 and 3 through conscious supplier selection and reduced packaging, transportation, and business travel. We expect business partners with significant environmental impact to adopt structured environmental management practices, such as ISO 14001, and to work actively to reduce emissions and improve environmental performance.
Environment and sustainability
We follow environmental laws, regulations, and other codes of practice and make continuous efforts to improve our environmental performance. Our ambition is to move towards net zero emissions over time, and we are gradually implementing measures that support this direction. We continuously seek ways to reduce the consumption of resources, including energy and water, and expect partners to manage waste, pollution, and chemicals responsibly while minimizing environmental impact throughout the value chain. Further, chemicals and hazardous materials shall be adequately labeled and safely stored, recycled, reused, and disposed of correctly.
Circular solutions and resource efficiency
In addition to our commitment to resource reduction, we are actively working on implementing circular solutions and enhancing resource efficiency. This includes promoting the reuse, recycling, and responsible disposal of materials to minimize waste and environmental impact.
Voluntary sustainability reporting
We are developing our sustainability reporting and currently include voluntary environmental disclosures in our annual report. This work supports greater transparency and helps us track our environmental impact and progress toward our sustainability goals. Over time, we aim to provide more comprehensive insights into our resource consumption, greenhouse gas emissions, and improvement initiatives.
Responsible technology and ethical AI
We promote responsible innovation by ensuring that our digital products are developed and deployed in ways that respect human rights, protect cybersecurity, and contribute to sustainable and inclusive technological development. This includes ethical AI practices and support for circularity. We aim to develop energy-efficient software solutions that reduce power consumption in embedded systems and contribute to extended product lifecycles. Through these efforts, we strive to support our customers’ sustainability goals.
Product safety and environmental conformity
We safeguard people’s health and safety by providing products in compliance with applicable environmental and safety directives or regulations. We observe and follow the guidance of the legal product safety regulations from product design, manufacture, and use to final disposal and expect our business partners to apply the same level of care when developing and delivering products or services for IAR.
