1. Introduction

This Code of Conduct defines the minimum standards of business conduct and business practices with which Trimlogic will comply regarding business relationships with customers, suppliers, employees, etc.

If applicable laws and regulations are more permissive than this Code of Conduct, Trimlogic will comply with this Code of Conduct. If applicable laws and regulations are more restrictive, Trimlogic will always comply with those legal requirements.

By establishing this Code of Conduct we are acknowledging our dedication to defining and protecting our most valuable collective asset — the trust that our clients, investors, colleagues, and communities place in Trimlogic.

Trimlogic will ensure that this Code of Conduct and any changes to this Code of Conduct (and other relevant information and related ongoing education) are provided to Trimlogic employees and contractors.

The industry and markets that we serve continue to undergo significant changes. As a result, these changes make the ways in which we do business more complex and constantly present new regulatory, ethical, and legal challenges. Trimlogic will demonstrate the highest ethical principles in all its activities and will avoid engaging in any activity that involves even the appearance of impropriety.

  1. Financial Integrity and Accounting

Accurate and reliable financial and business records are of critical importance for all enterprises. Trimlogic will not engage in any actions that could result in conveying false or inaccurate financial information to its clients and other interested parties.

  1. Dealing with Government Clients

Trimlogic is aware of and comply with all laws, rules, regulations, including procurement regulations, and contract clauses that govern the acquisition of goods and services by government entities to which we directly or indirectly market or recommend products and/or services, including federal, state, local, and other government-owned entities, as well as entities that are government-owned or controlled or subject to government procurement rules (“Government Clients”). Trimlogic is also aware that those activities that may be appropriate when dealing with nongovernmental customers may be improper and even illegal when dealing with Government Clients.

  1. No Wrongful Payments

Trimlogic at all times, will comply with all applicable local and foreign anti-bribery laws. Acceptable practices in the commercial business environment may be entirely unacceptable with government officials, and may even violate certain applicable laws and regulations in some countries. When dealing with government officials or those who act on the government’s behalf, Trimlogic will be aware of these restrictions. Trimlogic employees and consultants must not, directly or indirectly, make or offer bribes, kickbacks, or other payments of money or other things of value, including business amenities, to anyone, including officials, employees, or representatives of any government, political parties, candidates for office, or public or international organization, or to any other third party, for the purpose of wrongfully obtaining or retaining business.This includes giving money or business amenities to any third party where there is reason to believe that it will be passed on to anyone involved in the business decision process for the purpose of influencing the decision. Even where allowed by applicable laws and regulations, any travel-related expenses and business amenities provided to government-owned entities must be reasonable, tied to product demonstration and not provided for the purpose of wrongfully obtaining or retaining business.

Trimlogic will ensure that all business amenities which we provide to private, commercial or government-owned clients and others comply with all applicable laws and regulations, are in the ordinary and proper course of business, and cannot reasonably be construed as bribes or other improper inducements.

When dealing with others, Trimlogic will exercise reasonable due diligence to ensure that we are aware of any potential warning signals that may indicate potential issues and that they abide by the terms of this Code of Conduct.

  1. Anti-Trust and Competition Laws

Trimlogic will fully comply with all applicable antitrust and competition laws and regulations.

The following actions are forbidden at Trimlogic:

  • join together to boycott suppliers or clients,

  • divide or allocate markets or customers,

  • coordinate competing bids.

  1. Competing Fairly

Trimlogic will compete fairly and ethically for all business opportunities. Our employees involved in the sale of products and services will ensure that all statements, communications, and representations to clients are accurate, complete, and truthful.

Similarly, we will not make or attempt to make any unauthorized commitments on behalf of suppliers or clients.

  1. Compliance with Securities and Insider Trading Laws

Trimlogic will comply fully with applicable insider trading and securities laws governing transactions in suppliers and clients securities. Securities include common stocks, bonds, options, futures, and other financial instruments. In case Trimlogic  possess or have access to material, non-public information gained through its work with suppliers and clients; Trimlogic will use that information solely for the purpose for which it was provided. Trimlogic and its employees will not use it to trade in securities. These restrictions also apply to family members, friends, and associates.

  1. Intellectual Property

Trimlogic is responsible for protecting both suppliers’ and the client’s intellectual property rights. An important element of such protection is maintaining the confidentiality of suppliers’ and the client’s confidential information and other proprietary information. Trimlogic will not reproduce copyrighted software, documentation, or other materials unless we are properly authorized to do so. Trimlogic will observe applicable data privacy requirements.

When we market directly to an end user, we will ensure the appropriate license and product terms are provided to the end user in a format sufficient to create an enforceable agreement under applicable law (for example, certain countries require contracting in hard copy format) before the sale to the end user is finalized.

  1. Respect and Dignity

Trimlogic will always provide its employees and consultants with a work environment free of coercion, discrimination, and harassment.

  1. Social Media

Trimlogic will always comply with applicable laws and government guidelines governing social media. Further, when using social media (for example, any form of online publishing and discussion, including blogs, wikis, file-sharing, user-generated video and audio, and social network), Trimlogic will comply with this Code of Conduct and will not disclose any confidential information.

  1. Marketing to Other Remarketers

Trimlogic will require its remarketers to comply with this Code of Conduct.

  1. Acquiring Products from Unauthorized Sources

Acquiring products from unauthorized sources represents a significant risk to Trimlogic and its potential customers because there is no assurance that these products are free of defects or alterations (or both) or if the product is counterfeit, which may affect subsequent warranty claims and customer satisfaction.

Trimlogic will always acquire products for reselling, customization or enhancements from authorized sources.

  1. Monitoring / Record Keeping

Trimlogic will maintain documentation reasonably necessary to demonstrate its compliance with this Code of Conduct and provide our suppliers and customers or its independent auditors with access to such documentation.

  1. Compliance

Any violation of this Code of Conduct by Trimlogic employees or consultants will constitute the basis for the immediate termination of agreements/contracts under which these employees or consultants provided their services to Trimlogic.

  1. Reporting Violations

If anyone becomes aware of any unlawful or unethical situation against this Code of Conduct, he should immediately notify Trimlogic at tell_trimlogic@trimlogic.pl and communicate any information that he has regarding the incident or situation. Information that he will provide to Trimlogic must be accurate to the best of his knowledge, and Trimlogic expects him to assist Trimlogic with any investigations of an incident or situation that he reports to Trimlogic.