Code of Conduct

Introduction

Each employee is responsible for understanding and following this Code and all the laws, regulations, Global App Testing (GAT) policies and procedures that apply to their role and duties at GAT. This means that each employee is also responsible for seeking advice when needed.  Questions or concerns about how this Code or GAT policies apply should be raised with their manager. Suspected breaking of the law or the rules contained within this code of conduct should be raised with their manager or Code of Conduct Supervisor.

Confidentiality

We are committed to maintaining the highest degree of integrity in all our dealings with potential, current and past clients, both in terms of normal commercial confidentiality, and the protection of all personal information received in the course of providing the business services concerned. We extend the same standards to all our customers, partners and associates, especially according to US and EU laws in the EU partnership cooperation.

Ethics

We always conduct our own services honestly and honourably, and expect our clients and partners to do the same. Our services take proper account of ethical considerations, together with the protection and enhancement of the moral position of our clients and partners.

Duty of care

Our actions and advice will always conform to relevant law, and we believe that all businesses and organizations, including this one, should avoid causing any adverse effect on the human rights of people in the organizations we deal with, the local and wider environments, and the well-being of society at large.

Contracts

Our contract will usually be in the form of a detailed proposal, including aims, activities, costs, timescales and deliverables. The quality of our service and the value of our support provide the only true basis for continuity. We always try to meet our clients’ contractual requirements.

Fees

Our fees are always competitive for what we provide, which is high quality, tailored, specialized service. We always try to propose solutions which accommodate our clients’ available budgets and timescales. Wherever possible we agree our fees and basis of charges clearly in advance, so that we and our clients can plan reliably for what lies ahead, and how it is to be achieved and financially justified.

Intellectual property and moral rights

We retain the moral rights in, and ownership of, all intellectual property that we create unless agreed otherwise in advance with our clients. In return we respect the moral and intellectual copyright vested in our clients’ intellectual property.

Quality assurance

We maintain the quality of what we do through constant ongoing review with our clients, of all aims, activities, outcomes and the cost-effectiveness of every activity. We encourage regular review meetings and provide regular progress reports.

Professional conduct

We conduct all of our activities professionally and with integrity. We take great care to be completely objective in our judgement and any recommendations that we give, so that issues are never influenced by anything other than the best and proper interests of our clients.

Equality and discrimination

We always strive to be fair and objective in our advice and actions, and we are never influenced in our decisions, actions or recommendations by issues of gender, race, creed, colour, age or personal disability.

Anti-Bribery and Corruption

All GAT business is subject to the anti-bribery laws of the countries in which it operates. GAT has developed policies, procedures and internal controls for complying with anti-bribery and corruption laws, and prohibits any improper promise, offer, or the provision of anything of value to government officials, or to any other person for the purpose of obtaining or retaining business or influencing official action. “Anything of value” is a broad concept that includes any kind of advantage or benefit, for example, a cash payment, offer of employment (including internships) and tickets to a sporting or cultural event. “Government Officials” include, but are not limited to, any person employed by or representing a government, officials of a political party, officials of public international organizations, candidates for office and employees of state owned enterprises.

GAT employee not give, offer or promise anything of value to an official or a family member of a government official. Under no circumstances may you offer, promise or grant anything of value, including employment opportunities or internships, to a government official, or to any person, or members of their family, or to a third party or charitable organization suggested by the recipient, for the purpose of influencing the recipient to take or refrain from taking any official action, or to induce the recipient to conduct business with GAT. Payments made indirectly through an attorney, consultant, broker, contractor, or other third party are subject to the same restrictions and it is your obligation to understand what such a party is doing on your behalf.

In addition, you may not make a facilitation payment of any kind, regardless of the provisions of applicable law. Facilitation payments are small payments to government officials to expedite or secure performance of a non-discretionary, routine governmental action, such as obtaining permits or other official documents to qualify to do business, processing governmental papers such as visas, or providing postal or utility services.

To support compliance with applicable anti-bribery and corruption laws, it is your responsibility to adhere to all GAT pre-approval and reporting requirements. The full anti-bribery policy is available for review upon request.

Anti-Money Laundering

Money laundering is the process of converting illegal proceeds so that funds are made to appear legitimate and thereby enter the stream of commerce. It is not limited to cash transactions but can include monetary instruments and other proceeds of illicit activity. Terrorist financing includes the financing of terrorists, terrorist acts and terrorist organizations. Terrorist financing may involve proceeds from both illegitimate and legitimate sources.

GAT and its employees must act diligently to prevent our products and services from being used to further money laundering and terrorist financing and to detect suspicious activity in accordance with relevant laws and regulations. GAT is committed to combating money laundering, terrorist financing and other crimes to the fullest extent permitted by law. No client relationship is worth compromising our commitment to combating money laundering, terrorist financing and other crimes.

GAT complies with the relevant regulator’s AML rules in each jurisdiction it operations and also with each individual bank’s AML policies. GAT has its own AML policy and procedure in place.

Global Trade

GAT complies with all applicable laws and regulations concerning embargoes and sanctions and does not, directly or indirectly, conduct transactions with individuals, entities, or countries that are the subject of restricted party or embargoed country lists (also known as interdiction lists). GAT complies with consolidated lists of financial sanctions targets from the United States, the European Union and the United Kingdom.