Code of Conduct

UPDATED ON 03.09.2020

In this Code, the board of Directory set out the principles and practices that define our ethical standard and the way we do business.

We follow this code in order to foster a culture where responsible behaviour, integrity and trust are the key factors to protect our people, our reputation, our customer and the shareholder value. This code sets the standards that help us to make that happen.

It is based on our three core values of consulteer, “all for one”, which is about an inclusive and approach towards how we work together within the company, with our suppliers and for our clients; No fear, which enables and encourages our employees to speak up in case of problems, risks and misconducts; and commitment we want to keep with our customers, employees, shareholders and the society to create a sum that is bigger than the individual effort, yet in a sustainable and responsible way.

It is absolutely essential that we follow these Principles every day. If we do business the right and responsible way we will be a better business and a more successful one – one that truly stands for our three core values “all for one”, “no fear” and “commitment”.

Once a year the board of directors will review the code to ensure that the key developments with regards to our customers, employees and key stakeholders are reflected in this code.

This code applies to everything and everyone

Our code is owned by each of the consulteer employee and sets our the principles and standards we have defined for ourselves. It covers our dealings with our stakeholders and counterparties and last but not least with how we deal with each other. It is the basis for all our policies, guidelines and procedures.

Ignorance is not excuse

As part of our company introduction and training program everyone at Consulteer learns about the standard in the code and how to apply them. Not knowing the code is no excuse for violating it.

Our Leadership are behind the code

This code has the full backing from the Group of Directors and the Executive Board of all Consulteer Groups. Every one of use needs to make sure that our business conduct and decisions follow those standards set out here. Foremost we must put the interests of our clients, the company and the shareholders first.

As this document will not be able to describe every possible situation. If you find yourself in an unexpected situation, apply these standards in your judgment and seek guidance or help.

Consulteer’s Code of Conduct Framework

Our Code of conduct looks at three dimensions on who we interact with each other and with our environment:

Inside View: Our responsibility towards one and each other

Outside View: Our responsibility towards our business partners and the communities

Environment: Our responsibility towards the planet

Our responsibility towards one and each other

Business Information and Technology

We use our information technology securely and cautiously to maintain the highest confidence our clients award us with. Information security threats are evolving rapidly and becoming every more sophisticated. We carefully store, treat and retain business information and treat it with the utmost care.

Business Information may include requirements, specifications, transactional data, contracts, strategies communications or any other information we receive from our business partners. Information technology is any software or equipment used to send, store or transform images such as text, images, video, audio or data in general.

Example: I got an e-mail that looks like from our accounting department. This E-Mail asked me to review an attached contract. As the sender e-mail looked suspicious I immediately informed our IT department that I may have been subject to a virus. Thanks to my fast response no harm was done.


We communicate in a truthful, transparent and thought through manner.

How we are perceived is heavily influenced on how we communicate. Our brand is build by a timely, accurate, clear and open communication. It helps to preserve Consulteer’s reputation. This is why we are careful how we communicate with one another, with our clients and other stakeholders.

Communication includes everything in written, speech, information sharing at conferences and gatherings on digital (for instance social media, mails, instant messaging) or physical channels.

Example: At a recent industry gathering I was asked by a journalist to give an interview for insights on a specific customer project. As I’m worried that I might expose some sensitive information about the project, I first contacted the account manager and my supervisor for guidance.

Conflict of Interests

All decision we make are in Consulteer’s best interest

Conflicts of interest may improperly affect our judgment, objectivity or loyalty. They can expose us to reputational, legal and financial risk.

Conflicts of interest arise when our personal interests interfere with those of Consulteer. Whenever we have a conflict of interest, we are transparent in disclosing our personal interest and we remove ourselves from the decision making. This behaivour fosts and open and fair environment.

Conflicts of interest may arise from personal relationships, financial interests or external positions or activities. These could negatively affect our individual performance or company interest.

Example: I’m in charge of hiring a new developer to our team. A distant relative applied and while she might be suitable for the position, I am biased. I therefore disclose this to human resources and take myself out from the decision making process.

Diversity & Inclusion and fair and equal treatment

A diverse and inclusive environment where everyone is treated with respect and without discrimination or harassment is our standard – nothing less.

Different talents, perspectives, background allow us to better understand our clients and to create richer and more meaningful solutions. Working together in such a diverse and inclusive environment enriches the team spirit and increases productivity.

We are fully committed to fair and equal treatment. We provide equal opportunity for all individuals to develop professionally. This is valid regardless of age, race, ethnicity, nationality, gender, religion, secual orientation, disability or any other class protected by law.

Example: A recent colleague has great ideas but rarely choses to share them in the team meeting as other colleagues take all of the airtime and he is afraid to speak up. Since I know how valuable particularly a new perspective can be I encourage the team to listen to him. If this does not work I will speak to my manager.


We behave honestly and in a transparent way to do legitimate business purposes.

Engaging in intentionally misleading or deceitful activity constitutes fraud. Conslteer is committed to ensure the highest standards of integrity and does not tolerate any form of fraud. Acting with the highest integrity fosters trust and builds a solid brand and reputation while increasing the customer loyalty and mutual respect.

Examples of fraud include theft of property, falsification of information, submitting dishonest timesheets and/or claims.

Example: End of the month I’m asked to turn in my timesheets. As I forgot to track my time beginning of the month, I’m tempted to estimate the hours worked. On the other hand I know the recordings must reflect reality. So instead of making up the hours, I try to construct the worked time based on the e-mails sent throughout the day and I do inform my supervisor.

Health, Safety and Security

We keep our workplace free from anything that endangers our healty, safety or security.

Vital to our well-being and team spirit is a healthy, safe and secure working environment. Our value “all for one” also encourage us to look out for another’s health and safety. Acts that undermine or damage our community are not tolerated.

We proactively avoid, detect and assess hazards. We follow security procedures and reports accidents, injuries, unsafe practices and conditions in a timely manner. We only engage in activities that allow us to conduct our work safely, effectively and always plan for business continuity.

Example: In our latest office anyone can enter our building without identification or batch. Anyone just can walk into the office without registration. As I want too keep our workplace safe I report this instantly to our office manager.

Intellectual Property

Knowledge is the key to our success, we are therefore obsessed in both the creation and protection of it.

Consulteer is a purely knowledge based company. Our ability to offer our expertise and to build knowledge for our clients is the key to our success and most important to our reputation. We therefore protect it all the time at all costs. We respect the intellectual properties of others since not doing so can cause financial and reputational damage.

Consulteer owns all intellectual property we create during the course of our work. Some of the Intellectual Property we get in touch with is owned by our clients. Even after we leave the company, it remains the property of consulteer or the clients. Intellectual property property could include Strategy Documents, Requirements, Software Specifications, Source Code or Transactional Data.

Example: I recently got my laptop replaced. The old laptop does contain source code from several client projects. As I recall that this might be sensitive for our clients I pro-actively clean up the laptop before I turn it in to our IT department.


We actively speak up if actions we observe are against the code of conduct and therefore may harm the company’s future.

We immediately report any potential violations of laws, rules, regulations, policies, professional standards and the principles laid out in this code of conduct to our manager or human resource department.

Any form of retaliation against whistleblowers is unacceptable.

Consulteer expects its line managers to escalate and report any violations of laws, rules, regulations, policies, professional standards and the code of conduct.

Example: During a recent customer visit I noted that one of my colleagues copied data to an USB stick. As we are usually working in the client environment I found this highly suspicious. I therefore informed my line manager.

Our responsibility towards our business partners and society

Bribery and Corruption

We conduct business in a fair fashion without accepting or offering benefits intended to improperly influence the decision making.

We do not engage in bribery and corruption in any way. It is not only illegal but also compromises our integrity and reputation and undermines fair market opportunities. Even more, it may expose us to criminal penalties and fines. A long-lasting relationship with business partners is based on a truthful and ethical exchange.

The giving and receiving of gifts, hospitality, charity or sponsorships must never improperly influence our decision or those of our business partners. This includes bribes indirectly made through third parties.

Example: During a recent business trip to a client I observed that the account manager in a quite minute gave the client a white enveloped. As I found this highly unusual and suspicious I reported this anonymously using our whistleblower site to the management.

Data Protection

We handle personal data with the utmost confidentiality and use it only for legitimate and specific business purposes

Our clients and stakeholders expects us to process and protect their personal data properly and with the greatest care. Data protection is vital to the trust we earn from our stakeholders and it allows us to conduct our business effectively and securely. Personal data is any information that can be used to identify someone such as a name, address, data of birth.

Example: I recently got a dataset from one of ouf clients for test purposes which includes their whole staff with what appears to be real data including the date of birth or private address. While I understand that test data is best as close as real world data, I talk to the client first on ways to get a fully anonymized data set. As this was not possible for my client I will talk to my manager to make sure we can put additional security measures into place.

Sustainability and Human Rights

We deliver products and services that do not compromise our future

Sustainability is at the forefront of or our business and behaviour. Taking this long term view helps us to improve our economic efficiency, protect the environment and contributes to sustainable development of societies in the countries we are active.

Consulteer is dedicated to corporate responsibility and intends to sign the UN Global Compact and is committed to implementing its ten principles in the area of human rights, labour, the environment and anti-corruption. Human rights are the basic standards needed to lead one’s life with dignity.

Our respect for those principles allow us to develop a balanced approach to our decisions. We select business partners that share these same values.

The ten principles of UN Global Compact include

  • Human Rights:
    • Principle 1 : Business should support and respect the protection of internationally proclaimed human rights
    • Principle 2 : Make sure that the yare not complicit in human rights abuses
  • Labour
    • Principle 3 : Business should uphold the freedom of association and the effective recognition of the right to collective bargaining
    • Principle 4 : The elimination of all forms of forced an compulsory labour
    • Principle 5: The effective abolition of child labour
    • Principle 6 :  the eliminiation of discrimination in respect of emploment and occupation
  • Environment
    • Principle 7 : Business should support a precautionary approach to environmental challenges
    • Principle 8:  Undertake initiative to promote greater environmental responsibility
    • Principle 9 : Encourage the development and diffusion of environmental friendly technologies
  • Anti-Corruption
    • Principle 10 : Business should work against corruption in all its forms, inclusion extortion and bribery.

Our responsibility towards the Planet

Environmental Compliance

We comply with all applicable legislation and sustainability commitments.


We rent eco-friendly, modern offices that are appropriate in size and incorporate energy efficiency measures.

We are in a very collaborative discipline and as such meeting people in person at different locations is a key element. We however strive to reduce our office footprint and rent location which are state of the art in terms of energy consumption and efficiency at the cities we are located. Our office fits the current and projected size of the next 2 years thus reducing spare capacities.

Example: Wherever possible we are using a “hot-desk” approach with dedicated spaces for collaboration instead a fixed office, fixed desk allocation.

Waste and Recycling

We separate waste in all our locations and have it recycled wherever possible

As a company we prevent pollution and reduce the consumption of resources through waste management strategies that promote waste minimisation re-use and recycling wherever appropriate.

Example: An employee leaves the company within the first year. As we his laptop was acquired less than a year ago we will have it re-used with the next employee that enters the company.


How we move drives our main energy consumption as a consulting company.

Part of our job is to travel to different locations at our clients to deliver our service. Therefore the mode of transportation we choose is a major driver for our energy consumption as a company. We therefore always strive to have the best economical/ecological ratio, to balance the travel time with the carbon footprint we incur.

Example: Some clients require our specialists to work on premise. For employees which do travel often we cover the public transportation costs in favour of reimbursement of individual transportation.

Virtual and Physical Meetings

A virtual meeting might be more efficient that seeing each other too much

Whenever possible and feasible we aim for virtual meetings, particularly outside our work location or country. We do support technologies that enable us to work virtually and asynchronously.

Example: The monthly management meeting at one of our subsidiaries has been held in person so far. As one of the board members however needs to fly in, we changed it to once a quarter in person while the rest of the meetings are virtual.