Code of Conduct

1. This Code of Conduct applies to all those who are part of the ICCO community, in every position or function within the ICCO, including the ICCO Board of Directors and ICCO Leadership Team Members.
2. We aim to meet the highest standards of ethics, integrity, and professionalism. To this end, the Code of Conduct serves (1) to emphasize the ICCO’s commitment to ethical conduct and compliance with the law; (2) to set forth basic standards of ethical and legal behavior; (3) to provide reporting mechanisms for known or suspected ethical or legal violations; and (4) to help prevent and detect wrongdoing.
3. This Code of Conduct cannot comprehensively anticipate every instance in the varied activity of the ICCO, in which questions of ethics and integrity may arise. If a guideline cannot be found in the Code of Conduct, one should be guided by their common moral principles.
4. Where there is uncertainty or a need for further assistance, the persons listed under n” of this Code of Conduct may be contacted.
5. This Code of Conduct supplements other, more specific ICCO policies and regulations; it does not replace them. In order to meet the demands of new developments and challenges, the ICCO Board of Directors may revise these regulations from time to time.

6. Acting on behalf of and within the ICCO: We act on behalf of the ICCO with diligence and professionalism, complying with the highest standards of ethics and integrity. This includes, but is not limited to, being respectful of one another’s rights and forthright in all engagements with members of the ICCO community as well as third parties. We should not place our personal interests above the best interests of the ICCO. We respect the personal dignity, privacy, and rights of each individual. We believe diversity enriches our workplace. We work together without regard to ethnic origin, culture, religion, age, disability, skin color, gender, sexual identity and orientation, or beliefs.
7. Compliance with laws and regulations: Obeying the law is the foundation on which the ICCO’s ethical standards are built. We comply with the applicable laws and regulations of the countries in which the ICCO operates and ensure the implementation of all the ICCO’s guidelines, processes, and controls.
8. Conflict of interest: All decisions and actions of the ICCO community are to be made in the best interests of the ICCO and the public good. A conflict of interest exists when a party’s direct or indirect personal interests are inconsistent with or interfere with the best interests of the ICCO. The ICCO Conflict of Interest Policy sets forth in detail the standards and procedures to be followed when dealing with situations that may present a conflict of interest. ICCO Representatives who are required to sign an ICCO Conflict of Interest Statement will be notified individually.
9. Protection and proper use of ICCO assets: Proprietary information (e.g., intellectual property rights such as trademarks and patents, personal data) and other assets (e.g., facilities and equipment) that we have access to in the course of engaging with or acting for the ICCO, may not be used for personal benefit. We may not use ICCO proprietary information, other assets or our position within the ICCO for improper personal gain and/or non-ICCO activities.
10. Fair dealing: We act on the ICCO’s behalf and, regardless of whether we are dealing with colleagues within the ICCO or third parties, we are required to act honestly, in good faith, and with professionalism. We may not take unfair advantage of another person through harassment, manipulation, abuse of privileged information, misinterpretation of material facts, or other such unfair practice.
11. Confidentiality: We must maintain the confidentiality of confidential information entrusted to us, except when disclosure is authorized by an appropriate officer of the ICCO or required by law. Confidential information includes all information marked ‘confidential’ non-public information or which, due to its character and nature, may reasonably be assumed to be confidential. Such obligation to preserve confidential information continues even after the term of office or employment with ICCO. The ICCO Confidentiality Agreement sets forth the standards and procedures in respect of confidentiality in more detail. ICCO Representatives who are required to sign an ICCO Confidentiality Agreement will be notified individually.
12. Filings and public disclosures: All of whom are involved in the preparation of financial and other reports and documents to be filed with or submitted to any authority by the ICCO are required to file these accurately, in full and in a timely manner. The same standards apply to other public communications made by the ICCO.
13. Financial integrity: All of whom are involved, in particular those directly involved in financial matters shall ensure that timely, accurate and complete financial information is provided to the appropriate persons and bodies. Effective controls shall be maintained over financial reporting to ensure a complete and accurate record of our financial transactions.

Implementation and Procedures

14. Responsibilities: Up to three selected members of the board(s) of the Industrial Partner(s) of the ICCO shall be responsible for ethical matters and the implementation of this Code of Conduct. It shall ensure that risks and issues, together with appropriate recommendations, are reported to the ICCO Board of Directors. ICCO Headquarters is responsible for developing and maintaining the Code of Conduct, reviewing reports on compliance, and providing support and guidance.
15. Accountability and assistance: We are personally accountable for adhering to this Code of Conduct as well as to all ICCO policies, guidelines, and applicable laws. Where there is uncertainty or any need of further assistance, the President of the Board of MIKRONA GROUP can be contacted.
16. Breaches: Breaches of this Code of Conduct as well as of all ICCO policies, guidelines, and applicable laws will result in remedial, corrective, or disciplinary actions. Additionally, the ICCO may notify the relevant authorities. We all are obliged to report actual or suspected misconduct to the selected members of the board(s) of the Industrial Partner(s). The ICCO guarantees non-retaliation and confidentiality, to the extent legally possible, for good-faith reports of such breaches as well as for assisting or providing information during an investigation.