Code of Business
Conduct & Ethics
Our commitment to integrity, excellence, and ethical principles guides every aspect of our business operations and relationships with customers, partners, and stakeholders.
Explore Our StandardsOur Commitment to Ethical Business
The Company's directors, officers and employees are required to comply with our Code of Business Conduct and Ethics to promote honest, ethical conduct across all operations.
The purpose of the Company's Code of Business Conduct and Ethics is to deter wrongdoing and to promote, among other things, honest and ethical conduct and to ensure to the greatest possible extent that the Company's business is conducted in a consistently legal and ethical manner.
Employees may submit concerns or complaints regarding ethical issues on a confidential basis by means of a telephone call to an assigned unit via email. All concerns and complaints are investigated by the audit committee.
Access Our Full Code
The Company's Code of Business Conduct and Ethics is posted on the Company's website, at www.koltelecom.com
Our Core Values
KOL TELECOM's continued growth, profitability and prosperity is linked to our employees' ability to make decisions consistent with our core values and ethical principles.
Passion for Excellence
Strive to achieve the best in everything we do.
Integrity
Hold ourselves to the highest ethical standards. To interact in an open, honest, positive manner and be guided by what is right.
Teamwork
Work together with trust, openness, honesty and respect.
Inspired People
Build a culture where people are motivated, engaged, valued and growing. Our people make the difference and are the essence of KOL TELECOM.
Our core values support and guide our leadership in establishing the strategic direction of the Company. Sound judgment shall be exercised in the service of our reputation as a business leader, employer of choice, and good corporate citizen. Our employees and representatives are expected to conduct their business in accordance with these values and with our Standards of Business Ethics and Conduct ("The Standards").
Ethics & Conduct Standards
Explore the pillars that define our commitment to ethical business operations.
The Ethics Committee and Compliance
The KOL's Ethics Committee is dedicated to giving employees the support and advice they need to act according to The Standards and KOL TELECOM's ethical principles. Appointed by KOL TELECOM's Executive Team, we act as a resource, providing the information, tools, and strategies to assist employees in making ethical business decisions.
The Ethics Committee has a charter to:
- Help employees use the Company's ethical principles in their decision-making processes
- Provide guidance for employees who have questions about business ethics and compliance issues
- Support employees who may be facing ethical challenges in the workplace
- Interpret policies
- Provide easily accessible information on The Standards, policies, and procedures
- Foster an atmosphere of trust and open communication where employees feel comfortable coming forward and talking about issues
As such, we expect employees to act proactively, raising concerns about ethical issues, and reporting any conduct believed to be a violation of The Standards, a Company policy or procedure, or a government law or regulation. Members of KOL TELECOM's management team are expected to maintain an "open-door" policy regarding employee questions, and to support any employee who comes forward to discuss an issue or report a potential violation.
Retaliation is Prohibited
KOL's prohibits retaliation or retribution against any employee for cooperating in an investigation or for making a complaint. Retaliation or retribution for cooperating in or filing a complaint is illegal and is grounds for immediate termination. If you feel you have been retaliated against, you should contact Human Resources or the Ethics Committee.
Taking ACTION
When you are confronted with an ethical dilemma, it is your responsibility to TAKE ACTION. The decision-making model outlined below can help you assess whether or not a particular action is "the right thing to do." Keep in mind that not taking action is itself an action that can have serious consequences to the Company and its employees.
Remember: Work stress and too-rapid decision-making can often impact ethics. If you feel that you are under pressure to make a decision that you aren't yet comfortable with, take a few minutes and run through the ACTION model.
Compliance with Rule of Law and Our Core Values
KOL TELECOM operates within the bounds of the laws, rules, and regulations that are relevant to our business. The rule of law is fundamental to civil society, to the democratic process, and to the conduct of business in a dynamic global marketplace. However, today's market demands that companies meet higher standards—simply obeying the law is not enough.
Legal Compliance
The first and foremost obligation of responsible corporate citizenship is to obey the laws of the countries and communities in which KOL TELECOM does business.
Beyond Compliance
We aspire to "do the right thing" by being faithful to and executing the principles and guidelines cited in The Standards and to act in ways that exceed the minimum standards set by law.
Any case of noncompliance with applicable law may subject the violating employee to disciplinary action. The fact that in some countries certain standards of conduct are legally prohibited, but these prohibitions are not enforced in practice, or their violation is not subject to public criticism or censure, will not excuse an illegal action by a KOL TELECOM employee.
Employee Responsibilities
Each KOL TELECOM employee is responsible for displaying integrity. Business integrity means honesty, obeying the law, treating those with whom we work with fairness and respect, and being accountable and taking responsibility for actions and consequences.
It is also the responsibility of each KOL TELECOM employee to comply with The Standards, and to take action or report to management when aware of criminal acts or acts in violation of the Standards. Employees who fail to comply with The Standards, including not reporting known unethical activities, will be subject to disciplinary action.
Important: Individuals who report an ethical or legal concern in good faith will never be subject to retaliation for reporting. Any employee responsible for retaliation against an individual who in good faith reports a known or suspected violation will be subject to disciplinary action, including termination.
Manager Responsibilities
Managers are expected to exemplify the highest standards of ethical business conduct and encourage discussion of the ethical and legal implications of business decisions. Managers have a responsibility to create and sustain a work environment in which employees, consultants and contract workers know that ethical and legal behaviour is expected of them.
This responsibility includes ensuring that the Standards are communicated to all those working for the manager. Managers are also responsible for ensuring that employees who need to know additional information in order to do their jobs receive appropriate policies and training.
Respect Others — Value Personal Dignity and Differences
We respect the personal dignity of each individual, honor diversity, and are intolerant of violence, discrimination, harassment, or retribution in our workplace. We strive to be an employer of choice committed to creating, managing, leveraging, and valuing diversity.
Human Rights and the Law
KOL TELECOM complies with employment laws in every country in which it operates and supports fundamental human rights for all people.
- • We will not employ children or forced labor
- • We will not allow physical punishment or abuse
- • We respect the right of employees to exercise their lawful right of free association
- • We enthusiastically support laws prohibiting unjustified discrimination
Fair Treatment and Opportunity
KOL TELECOM is firmly committed to the fair treatment and compensation of employees. All applicants and employees are judged by their qualifications, demonstrated skills and achievements.
We believe in recognizing and rewarding excellent performance, and offering opportunities for advancement through training and promotions.
Diversity
We believe that differences should be valued. Every employee deserves the opportunity to work and grow in an environment that is free of discrimination and harassment, and that supports work/life flexibility. At KOL TELECOM, diversity will be accepted throughout the organization. In exchange, we will benefit from the creativity, varied perspective, innovation, and energy that result from a diverse workforce.
Harassment
KOL TELECOM's employees have the right to work in an environment that is free from intimidation, harassment, and abuse. At KOL's, we are committed to providing a work environment free of unlawful harassment of any kind.
Verbal or physical conduct by any employee that harasses another or disrupts another's work performance or creates an intimidating, offensive, abusive, or hostile work environment will not be tolerated. Our anti-harassment policy applies to all persons involved in the operation of the Company and prohibits unlawful harassment by any employee.
In addition, unwelcome sexual advances, requests for sexual favors, and other unwelcome verbal or physical conduct of a sexual nature are specifically prohibited. Employees are encouraged to help each other by speaking out when a co-worker's conduct makes them or others uncomfortable, and are responsible for promptly reporting harassment when it occurs.
Reporting Harassment
KOL TELECOM has internal complaint procedures to immediately address and undertake an effective, thorough, and objective investigation. If an employee believes that he/she has been unlawfully harassed, they should submit a written complaint to their manager, the CEO, COO, or Human Resources as soon as possible after the incident.
Action Taken: If it is determined that unlawful harassment has occurred, effective remedial action will be taken. Any employee determined by KOL TELECOM to be responsible for unlawful harassment will be subject to appropriate disciplinary action, up to and including termination.
Promote a Healthy and Safe Workplace
When we protect the health and safety of our co-workers, our community, and the environment, we demonstrate respect and contribute to a positive work environment.
KOL TELECOM is committed to protecting the health and safety of our employees, the public, our customers, suppliers, and visitors. Our policy is to maintain a drug-free, secure workplace where all employees are attentive to hazard prevention and the avoidance of accidents and injuries.
To support this commitment, each employee is responsible for observing the safety and health rules and practices that apply to his or her job. Employees are also responsible for taking precautions necessary to protect themselves and their co-workers, including immediately reporting accidents, injuries, and unsafe practices or conditions.
Build Trust — Keep Accurate, Complete Company Books and Records
Our reputation depends on the confidence others have in us, which is partially based on the accuracy of our written records and verbal statements. By demonstrating honesty in our accounting and labor-charging practices, we generate trust with our stakeholders and enhance our reputation.
When we fail to record financial information and time accurately, we severely damage our reputation; risk losing business, and decrease customer and shareholder confidence.
Financial Record Keeping Standards
KOL TELECOM will only use Company funds or assets for purposes that can be disclosed and recorded promptly and accurately in our books and records. We will not make false entries for any reason, nor will we alter documents or sign documents when we lack the proper authority to do so.
We will not make or approve payments on behalf of the Company if they will not be used, or might be used, for something other than the stated purpose. KOL TELECOM's financial books, records, and statements shall properly document all assets and liabilities, shall accurately reflect all transactions of the Company, and shall be retained in accordance with KOL TELECOM's record retention policies and all relevant laws and regulations.
Keep Your Commitments — Negotiate, Perform, and Market in Good Faith
Our success in the marketplace is based on the quality of our services, the perception that our services provide value to our clients, and the competence and honesty of our sales presentations. KOL TELECOM prospers only to the degree that we serve our clients well—and treat them, our co-workers, our customers, our vendors, and our competitors fairly and honestly.
Marketing & Negotiations
We are committed to the truthful and accurate communication of information about our services. Promotional materials will be honest and factual, not misleading or deceptive. KOL TELECOM employees are expected to execute Company agreements in an ethical and conscientious manner.
Contract Performance
Quality at KOL TELECOM means doing the job right, on time, and always to the satisfaction of the client. Quality does not come from an "after-the-fact" repair or rework job—it is a behaviour that results in doing our job right the first time.
Fair Competition
Fair competition is the hallmark of our relationships—our business dealings will be frank and respectful, and we strive to generate mutually advantageous relationships and satisfactory outcomes. KOL TELECOM believes in doing business with those suppliers, contractors, partners, agents, sales representatives, distributors, and consultants who embrace and demonstrate lofty standards of ethical business behaviour.
Act Responsibly — Disclose and Resolve Potential Conflicts of Interest
Integrity in a business relationship means that all participants are working together for the common good, and are not making decisions based on self-interest. When we act with integrity, we earn trust and build long-term client and customer relationships. When we act, or appear to be acting, in our own self-interest, we lose trust and damage our reputation.
Disclosure Requirement
You must disclose any matter that casts doubt on your ability to act objectively and in KOL TELECOM best interest. Employees, representatives, and agents of the Company who may have an actual or potential conflict should report all pertinent details in writing to their manager and the Ethics Committee.
Guidelines — Situations That Could Present a Conflict
Any of the following situations could present a conflict of interest and should be disclosed:
Act with Integrity — Stay Clear of Improper Business Courtesies
To maintain trust in our business relationships, we must always act with integrity. We must steer clear of giving or receiving gifts that are intended to influence, or appear to influence, business decisions. When we accept or give such gifts, it can undermine customer relationships, hurt our reputation, and put the Company in legal jeopardy.
Unacceptable Practices
- • Requesting or soliciting personal gifts, favors, entertainment, or services
- • Accepting gifts of cash or cash equivalents
- • Exploiting position to solicit vendors for individual preferential treatment
Acceptable Practices
Gifts and entertainment should further the business interests of KOL TELECOM and not be lavish or in excess of the generally accepted business practices of one's industry. No gift, favor, or entertainment should be accepted or provided if it will obligate or appear to obligate the recipient.
Guidance for Decision Making
When considering whether to accept or offer a gift, gratuity, or other business courtesy, KOL TELECOM employees are expected to use moderation and prudent judgment. Although specific policies and procedures must be your guide, begin by assuring yourself that any offer you would make or courtesy that you would accept would leave you feeling comfortable if known by your manager, co-worker, family member, or the public.
Special Note: If you are a buyer, influence buying, or are involved in procurement transactions in any way (e.g. determine specifications, evaluate bids, etc.), you must refrain from offering or accepting business courtesies that could be perceived as affecting your objectivity or influencing your decisions.
Reporting Protocol
Recipients of prohibited gifts or favors should let management know and return the gift with a letter explaining KOL TELECOM's policy. If a gift is perishable or impractical to return, management should first attempt to donate it to charity or, alternatively, distribute it to employees, with a letter of explanation to the donor from the originally intended recipient.
Focus on Global Responsibility — Our Reputation Extends Across Borders
KOL TELECOM could be expanding globally in the future. Success in any global business transaction depends on our compliance with country-specific constraints and conditions, and sensitivity to local customs. Laws, regulations, and conventions governing business relationships vary from country to country. KOL TELECOM obligation to comply with U.S. law and regulation does not end, however, when we, or our services, exit the United States, nor does our commitment to treat our stakeholders with concern and respect.
Protect Sensitive Information — Assets Worthy of Care
One of KOL TELECOM's most valuable assets are information. We are contracted with our clients to maintain the security of their customers' information. Like all other assets, information that is not generally disclosed and is helpful to the Company, client Company, (or would be to competitors) must be protected.
Client Data
Customer databases and confidential client information
Trade Secrets
Intellectual property and proprietary technologies
Business Plans
Marketing strategies and financial projections
Safeguarding Confidential Information
Safeguard confidential information by keeping it secure, limiting access to those who have a need to know in order to do their job, disposing of proprietary documents in secure containers and avoiding discussion of confidential information in public areas, for example on planes, elevators and mobile phones. The obligation to preserve KOL TELECOM confidential information is ongoing, even after employment ends.
KOL TELECOM employees will protect the Company's intellectual property, and act responsibly with the sensitive information of clients, competitors, customers, and other stakeholders. Each employee and those that are granted access to such sensitive information (including Company private, competition sensitive, and proprietary information) are obligated to protect and maintain its confidentiality.
Prohibited Practices
KOL TELECOM employees will not use improper means to seek proprietary information about a competitor—especially theft, illegal entry, electronic eavesdropping, or surveillance. We will not misrepresent ourselves, our positions, or our circumstances to persuade another to release information (by posing as a customer, for example), nor will we commission a third party to do so.
We will be careful not to transfer outside the Company confidential electronic mail messages or any message intended for internal use only. We will respect our co-workers' personal privacy and protect private personnel information from those inside or outside KOL's who have no need to know.
Care for Company Assets — Respect Our Resources
Effective use of Company resources is critical to our bottom line. When we use Company resources wisely, we demonstrate our efficiency. When we waste Company resources, we increase Company costs and reduce productivity.
Company Resources Include:
- • Computers and networks
- • Telephones and mobile devices
- • Internet access and email tools
- • Office equipment and supplies
- • Reproduction and printing equipment
- • Office facilities
Responsibilities:
All employees are entrusted with numerous Company assets, and have a special responsibility to protect them. This includes not only cash and other financial assets, but also assets like office equipment, inventory, computer networks and supplies.
Important: Any act by a KOL TELECOM employee that involves theft, fraud, embezzlement, or misappropriation of any property is prohibited and will be grounds for immediate termination.
Personal Use Guidelines
Employees shall use Company or customer-owned assets first and foremost for business purposes and to advance the Company's strategic objectives. However, occasional limited personal use may occur when it does not compromise KOL TELECOM's interests.
When using the Company's assets for personal reasons, follow these guidelines:
When in Doubt, Ask
When unsure of what constitutes appropriate use of KOL TELECOM's assets, consult with your manager or the Ethics committee.