Code of conduct

This Code of Conduct serves as the ethical road map for Qube Financing B.V. and its subsidiaries and/or affiliates, incl. Qube Servicing B.V. (together “Qube”) employees and companies, and provides the guidelines by which Qube conducts its businesses.

 

  1. National interest
    Any local operating company of Qube is committed to contribute to the economic development of the countries in which it operates.
    No Qube company shall undertake any project or activity to the detriment of the wider interests of the communities in which it operates.
    Qube company’s management practices and business conduct shall benefit the country, localities and communities it operates, to the extent possible and affordable, and shall be in accordance with the laws of the land.
    Qube, in the course of its business activities, shall respect the culture, customs and traditions of each country and region in which it operates. It shall conform to trade procedures, including licensing, documentation and other necessary formalities, as applicable.
  2. Financial reporting and records
    Qube shall prepare and maintain its accounts fairly and accurately and in accordance with the accounting and financial reporting standards which represent the generally accepted guidelines, principles, standards, laws and regulations.
    Internal accounting and audit procedures shall reflect, fairly and accurately, all of the company’s business transactions and disposition of assets, and shall have internal controls to provide assurance to the company’s board and shareholders that the transactions are accurate and legitimate.
  3. Competition
    Qube shall fully support the development and operation of competitive open markets and shall promote the liberalisation of trade and investment.
    Specifically, no Qube company or employee shall engage in restrictive trade practices, abuse of market dominance or similar unfair trade activities.
    Qube or employee shall market the company’s products and services on their own merits and shall not make unfair and misleading statements about competitors’ products and services. Any collection of competitive information shall be made only in the normal course of business and shall be obtained only through legally permitted sources and means.
  4. Equal opportunities employer (Subject to Visa approval)
    Qube shall provide equal opportunities to all its employees and all qualified applicants for employment without regard to their race, caste, religion, colour, ancestry, marital status, gender, sexual orientation, age, nationality, ethnic origin or disability. Human resource policies shall promote diversity and equality in the workplace, as well as compliance with all local labour laws, while encouraging the adoption of international best practices.
  5. Gifts and donations
    Qube and its employees shall neither receive nor offer or make, directly or indirectly, any illegal payments, remuneration, gifts, donations or comparable benefits that are intended, or perceived, to obtain uncompetitive favours for the conduct of its business. The company shall cooperate with governmental authorities in efforts to eliminate all forms of bribery, fraud and corruption. However, Qube and its employees may, with full disclosure, accept and offer nominal gifts, provided such gifts are customarily given and / or are of a commemorative nature.
  6. Health, safety and environment
    Qube shall strive to provide a safe, healthy, clean and ergonomic working environment for its people. It shall prevent the wasteful use of natural resources and be committed to improving the environment, particularly with regard to the emission of greenhouse gases, and shall endeavor to offset the effect of climate change in all spheres of its activities.
  7. Quality of products and services
    Qube shall be committed to supply goods and services of high quality standards, backed by after-sales services consistent with the requirements of its customers, while striving for their total satisfaction. The quality standards of the company’s goods and services shall meet applicable national and international standards.
  8. Corporate citizenship
    Qube shall be committed to good corporate citizenship, not only in the compliance of all relevant laws and regulations but also by actively assisting in the improvement of quality of life of the people in the communities in which it operates. The company shall encourage volunteering by its employees and collaboration with community groups. The company shall not treat these activities as optional, but should strive to incorporate them as an integral part of its business plan.
  9. Ethical conduct
    Every employee of Qube including directors and the chief executive, shall exhibit culturally appropriate deportment and deal on behalf of the company with professionalism, honesty and integrity, while conforming to high moral and ethical standards. Such conduct shall be fair and transparent and be perceived to be so by third parties. Every employee of Qube shall preserve the human rights of every individual and the community, and shall strive to honour commitments. Every employee shall be responsible for the implementation of and compliance
    with the Code in his / her environment. Failure to adhere to the Code could attract disciplinary action, including possible termination of employment.
  10. Regulatory compliance
    Employees of Qube, in their business conduct, shall comply with all applicable laws and regulations, in letter and spirit. If the ethical and professional standards of applicable laws and regulations are below that of the Code, then the standards of the Code shall prevail.
  11. Concurrent employment
    Consistent with applicable laws, an employee of Qube shall not, without the requisite, officially written approval of the company, accept employment with any other company, nor provide freelance services to anyone, with or without remuneration.
  12. Conflict of interest
    An employee or director of Qube shall always act in the interest of the company, and ensure that any business or personal association which he / she may have does not involve a conflict of interest with the operations of the company and his / her role therein.
  13. Protecting company assets
    The assets of Qube shall not be misused; they shall be employed primarily and judiciously for the purpose of conducting the business for which they are duly authorised. These include tangible assets such as equipment and machinery, systems, facilities, materials and resources, as well as intangible assets such as information technology and systems, proprietary information, intellectual property, and relationships with customers and suppliers.
  14. Integrity of data furnished
    Every employee of Qube shall ensure, at all times, the integrity of data or information furnished by him/her to the company. He/she shall be entirely responsible in ensuring that the confidentiality of all data is retained and in no circumstance transferred to any outside person/party in the course of normal operations without express guidelines from or, the approval of the management.
  15. Reporting concerns
    Every employee of Qube shall promptly report to the management, when she / he becomes aware of any actual or possible violation of the Code of Conduct or an event of misconduct, act of misdemeanor or act not in the company’s interest.

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