Dear Colleague:
AnyTech365 is the leading European IT support service for private consumers and businesses; a rapid-growth success story based on the huge demand for an easy and convenient way to get PC and Internet help in your language - from nativespeaking, friendly IT experts.
Since our inception, we have recognised that you, our employees and partners, are absolutely vital to our continued success. Our reputation for providing trustworthy technical support with an unrivalled customer experience is the direct result of both our continued collaboration and our individual efforts.
We are all responsible for maintaining and nurturing our reputation; our foundation of trust and respect. How we treat each other, how we treat our customers, and how we conduct business will determine if our reputation is that of trustworthy, experienced, and helpful professionals.
Each and every one of us in the AnyTech365 family must be personally accountable for acting with integrity every day - in compliance with ethical conduct as well as with laws and regulations.
As we continue to grow, the AnyTech365 Code of Conduct sets out our agreed standards which we see reflected in every single AnyTech365 interaction, business activity, workplace, and event. We are committed to acting honestly, ethically, and in complete compliance with not only the letter but also the spirit of the law. It is critical to our continued success, and the only way to operate.
With your help, I am confident that AnyTech365 will continue deserving our reputation for acting with integrity every day as we expand to support more people around the world.
Thank you for joining me in this effort!
Warm regards,
Janus R. Nielsen Founder and Chief Executive Officer, AnyTech365
The AnyTech365 Mission
To provide the most friendly, helpful and cost-effective remote technical support service in the world.
We strive towards achieving our mission by acting with integrity every day - in line with these core values:
Attitude
Our attitude to each other, to our work, and to our customers is vital to the successful completion of our mission. Having the right attitude is especially important when we support and resolve high-concern or stressful problems for a customer, and towards achieving our goals. We remain positive and professional with a “can-do” attitude in each and every AnyTech365 interaction.
Commitment
We are committed to the company and our mission, and to our customers. We strive to make a positive difference every single day. We are committed to always help and support each other; to give our complete effort to our duties; to always aim high and try to surpass our goals; to follow through every issue to resolution; and to remain professional and act with integrity at all times.
Team Work
Our strength lays in our diversity and in our collective knowledge, experience, and skills. We are always here for each other, ready to help – by supporting and encouraging each other; by sharing our ideas, time and knowledge; by listening carefully and speaking up thoughtfully; and by always working with integrity together to provide the best service to our customers.
Performance
We are a company with many employees and many customers, and as such we have a duty to ourselves and each other to always give 100% performance with 100% integrity. We work every day to ensure our individual performance supports the company, our mission, and our customers, and do everything we can to encourage and support the best performance in each other.
We believe with the right attitude and commitment to your work, to your colleagues and being a team player, and to the company and our mission - your performance and the future success of AnyTech365 will be outstanding.
About the Code of Conduct
We are all representatives of AnyTech35; as such, we are all empowered to make decisions and take action for ourselves that affect the company reputation.
Every AnyTech365 family member, throughout the course of his or her working day, is actively shaping how the world views our company and services. We must each take personal responsibility for the AnyTech365 mission and act ethically and with integrity at all times.
The AnyTech365 Code of Conduct details who we are, what we do, how we act, how we do business, and how we expect anyone involved with the company to act. The Code is your guide to ensure all daily work and interactions are in line with the highest legal and ethical standards.
If you are ever unsure of how to act in any situation, you have plenty of support available to you: Speak with your supervisor, manager, or personnel from HR or Compliance about any concerns you may have.
Please read the Code of Conduct carefully. If you have any questions, see the “Asking for Advice and Expressing Concerns” section of this booklet.
Contact hr@anytech365.com for more information.
Violations of the Code may result in disciplinary action up to and including termination of employment and legal action.
Asking for Advice and Expressing Concerns
AnyTech365 requires that all employees and partners operate in full compliance with the law and always conduct themselves ethically.
If you feel that the standards laid out in the Anytech365 Code of Conduct have not been adhered to, if you have any questions, or if you need further information or access to additional policies, it is your duty and responsibility to ask for guidance or voice your concerns by speaking with:
- Your direct supervisor or manager
- Any HR representative
- Eric Bertin, Chief Operations Director
- Georgi Medzhidiliev, Chief Compliance Officer
Your concerns will be taken seriously and all information provided will be treated as confidential and appropriately investigated.
Anti-Retaliation Policy
AnyTech365 strictly prohibits any victimisation of or retaliation against any employee who asks questions or expresses concerns about any potential violation of the Code of Conduct that he or she believes reasonably to have occurred.
Integrity in the Workplace
How we treat each other
Acting with integrity every day begins with how we treat each other - from the first interaction in the hiring process, through to daily life in the workplace, and beyond; we treat one another with respect, dignity, and courtesy at all times. All employees are entitled to work free from discrimination, bullying, and harassment.
AnyTech365 is an equal opportunities employer, and as such we recruit and promote staff based on job-related criteria only.
The guidelines here apply to all employees and partners, including C-level executives and officers; managers and supervisors; full-time, part-time, casual, temporary, or permanent staff; job candidates; student placements, apprentices, contractors, sub-contractors, and volunteers.
Discrimination
AnyTech365 is committed to providing a safe, respectful, and flexible work environment, free from all kinds of discrimination.
Harassment, bullying and discrimination take many forms, including:
- Unwelcome comments, gestures, or physical contact
- Displaying or circulation of offensive, derogatory, graphic or sexually explicit pictures or other materials, including via email, any other messaging service, or online
- Offensive or derogatory jokes or remarks (either explicit or implicit/by innuendo)
Discrimination is treating, or proposing to treat, someone unfavourably because of a personal or legally protected characteristic, such as:
- Any disability, disease or injury, including work-related injury
- Race, colour, descent, national origin, or ethnic background
- Age, whether young or old or because of age in general
- Physical attributes
- Biological gender
- Sexual orientation or gender identity
- Marital status, whether married, divorced, unmarried or in a samesex relationship
- Being pregnant or breastfeeding
- Religious beliefs
- Political opinion
- Social standing or origin
- Medical background
Sexual Harassment
Sexual harassment is considered to be “in the workplace” when it happens on company premises, at work-related events, between people sharing the same workplace, or between colleagues outside of work.
A single incident is enough to constitute sexual harassment - it doesn’t have to be repeated.
Any report of sexual harassment – no matter how large or small, or who is involved – requires an appropriate and confidential response and immediate investigation.
Sexual harassment can include:
- Comments about a person’s private life or the way they look
- Sexually suggestive comments or jokes
- Intrusive questions or statements about a person’s private life
- Insults or taunts of a sexual nature
- Repeated unwanted requests to go out
- Requests for sexual intercourse, intimacy, or acts
- Sexually suggestive behaviour, such as leering or staring
- Unwanted physical contact
- Sending sexually explicit emails, SMS, MMS, or other messages
- Displaying offensive screensavers, photos, calendars or objects
- Inappropriate advances on social networking sites
- Accessing sexually explicit internet sites
- Behaviour that may also be considered to be an offence under criminal law, such as physical assault, indecent exposure, sexual assault, stalking or obscene communications.
AnyTech365 strongly encourages any staff member who believes they have been discriminated against, bullied, sexually harassed, or victimised to take immediate action by contacting the supervisor, manager or HR representative with whom they feel most comfortable speaking with.
How our supervisors treat team-members
From our team-leaders all the way up to our C-level officers and executives at AnyTech365, we understand that the words, actions, attitude, and approach of anyone in a supervisory position must be aligned with the Code of Conduct at all times in order to preserve and grow the positive, professional culture of integrity that we demand.
As a Supervisor, Team-Leader, Manager, Director, C-level officer or executive, you must:
- Ensure that your team know and understand their responsibilities under the Code and other Company policies
- Model the Code at all times, especially during appraisals, team meetings, and any required disciplinary actions - we cannot reinforce the importance of ethics and compliance with the Code to our employees if we ourselves are not compliant, ethical, and acting with integrity
- Conduct in private any meeting necessary to deliver constructive criticism, feedback, disciplinary action, or in any situation with the potential to escalate or potentially embarrass any partner
- Ensure employees feel comfortable raising concerns without fear of retaliation – treat any concerns seriously and with confidentiality
- Consider conduct in relation to the Code and other Company policies when evaluating any employee
- Never encourage or direct employees to achieve business results at the expense of ethical conduct or compliance with the Code or the law
- Always be vigilant and act to stop any violations of the Code
- Take any question or concern related to the Code seriously and act upon it accordingly, and in the quickest possible time - listen carefully and give the employee and the matter your complete attention
Failure to act professionally, even in times of high stress or increased workload, is a failure in your role as a supervisor and can lead to disciplinary action, relief from the position, or termination of employment.
How we treat our customers
Our customers deserve exceptional service delivered with integrity. The AnyTech365 mission is to be the friendliest, most helpful and professional technical support provider available - how we treat customers is pivotal to our continued success.
The core of who we are is simple: we are people helping people, and as such, customer service and satisfaction are top priorities for us. We must consistently act ethically, be professional and polite, and fulfil the needs of each customer in every single interaction.
Specifically, you must:
- Treat every customer with dignity, respect, and courtesy
- Always act with integrity and in line with the Code
- Always present AnyTech365’s (and affiliates’) products and services in an honest and forthright manner to customers and potential customers
- Never offer, promise, or provide any product or service to a customer which does not fulfil a specific need
- Never engage in unfair, deceptive, or misleading practices
- Never harass or discriminate against our customers or potential customers in any way
Alcohol, Drugs, and Substance Abuse
AnyTech365 has strict standards regarding alcohol, illegal drugs, and substance abuse. AnyTech365 takes these rules very seriously. It is essential that you understand and follow them carefully.
The following policy applies to all AnyTech365 employees and partners of all levels, and will be strictly enforced:
- Employees are not permitted to use or possess any alcoholic beverages on company property, except where alcohol is specifically permitted at an AnyTech365 social event
- You also may not use or possess illegal drugs or controlled substances on AnyTech365 premises or while you are engaged in any job-related activity
- You may not report for work while under the influence of alcohol, drugs, or controlled substances
- Any employee or partner who can be reasonably deemed as unfit for work due to alcohol, illegal drugs, or substance abuse will be sent home immediately
- All matters concerning alcohol, drugs, or substance abuse will be treated with the utmost confidentiality
- AnyTech365 will report to the Police immediately any person in possession of or attempting to supply illegal drugs on company premises
In addition, if you are taking any kind of pharmaceutical drug or medication, prescribed or otherwise, you must:
- Ensure that you are familiar with the potential side-effects listed in the informational insert supplied with the medication
- Advise your line manager of any potential side-effects of any medication that you are taking that may affect your work performance, or the health and safety of yourself, your colleagues, company property, or any other individuals or property
AnyTech365 is committed to supporting any employee or partner who comes forward to ask for help with substance abuse. If you admit to your supervisor that you have a problem with any kind of substance abuse, AnyTech365 will work to help you with finding appropriate treatment. All such matters will be treated with the utmost confidentiality.
Integrity in Business
Legal and Regulatory Compliance
AnyTech365 is 100% committed to acting with integrity in business every day: we operate in full compliance with all applicable laws, regulations, and rules.
You are required to comply with the Code and all applicable laws, regulations, and rules when performing your duties for the company.
If you have reason to believe that there is a discrepancy between the Code of Conduct and any applicable law, regulation, or rule, or unsure or concerned about the legality of your own conduct, or the conduct of any other AnyTech365 employee or partner, speak with your supervisor or manager immediately.
Marketing and Sales Practices
The success of AnyTech365 is based on the merits of our products and services – we sell and market truthfully and accurately. This must be apparent at all times in any communications with customers or potential customers. We must be able to prove any claims we make about our products or services. We sell the truthful quality of our products and services; we do not misrepresent ourselves, disparage our competitors, or use our technical knowledge (or our customers’ lack thereof) to sell products or services based on fear or negativity of any kind.
You must not in any way suggest, imply, claim, or state, neither directly nor indirectly, that the company is recommended by, associated with, partners with, working for, endorsed by, or is itself Microsoft, Apple, or any other recognised and trusted IT companies.
If you are personally one of our Support Technicians who are genuinely Microsoft Certified, you may mention, if and where appropriate, that fact about yourself. You must not suggest, state, or claim that certification or association is with AnyTech365 directly, or that AnyTech365 itself is Certified in that way.
Competition Law
AnyTech365 promotes and supports open competition in a free market; it is not only fair and ethical, but it is also in our best interests to do so. All
AnyTech365 business decisions must be made independently, free from any supplier or competitor arrangements or understandings that restrict competition.
When involved in AnyTech365 business, all employees and partners must:
- Not discuss internal pricing, practices, or business / marketing strategies with competitors
- Always present AnyTech365 services and products in a manner consistent with the Code
- Not induce a third party to breach an existing agreement
- Never attempt to exclude present or potential competitors or to control market prices, or conduct yourself in a manner which could be perceived as such
Competitive Intelligence Gathering
Understanding of our competitors is essential for us to provide the best service to and value for our customers, and to ensure our continued success. When we act with integrity and follow the Code to obtain it ethically, such information is an extremely useful asset.
Employees are encouraged to collect, share and use information about our competitors only in a legal and ethical manner. We respect the non-public information of others, just as we do our own.
It is acceptable to collect competitive intelligence through publicly available information or ethical inquiries. For example, you may gather and use information about our competitors from public sources, such as:
- Published pricing and product features on their official websites
- News, trade journal articles, and publications about them
Conflicts of Interest
Each employee and partner of AnyTech365 must take steps to avoid conflicts of interest and the appearance of conflicts of interest. A conflict of interest, or the appearance of one, can arise when your personal interests or activities interfere with the duties performed at or owed to AnyTech365.
The appearance of a conflict of interest can potentially cause conflict or concern, or integrity to be questioned – even in the most ethically-minded and well-respected individuals could be unconsciously influenced by a conflict of interest.
Any actual or potential conflict of interest must be immediately brought to the attention of your direct supervisor or manager.
Some examples of situations where a conflict of interest could potentially arise:
- Working for or operating a business, including a consultancy firm, that does or wishes to do business with AnyTech365 or that competes with AnyTech365 (for example, working for a competitor’s technical support company)
-
Making a significant direct investment in any such business (either by you directly, or by a member of your immediate family)v
- Acting on behalf of any party other than AnyTech365 in any transaction involving AnyTech365 (for example, attempting to sell products or services to AnyTech365, or helping someone to)
- Getting personally involved in any interactions in which AnyTech365 has an interest
In any potential conflict of interest situation, ask yourself:
- Could my personal interests interfere with those of AnyTech365?
- Might it appear that way to others, either inside or outside of the company?
If you are unsure or would like guidance, please speak with your supervisor or manager.
Company Assets
We strive to create and maintain the ideal working environment to enable you to fulfil your duties in the most efficient and productive way. We all have a responsibility to protect company assets and use all assets in the manner intended.
All company assets are provided for use in your role and duties and for the benefit of AnyTech365. You must not use any company assets for your own personal benefit, or for the benefit of any other party other than AnyTech365.
AnyTech365 are committed to supporting a healthy and appropriate worklife balance, and as such, personal phone calls, emails, or messaging during company time or using company assets are acceptable within reason. Frequent or excessive personal communications or activities are strictly prohibited.
You may not use company assets:
- To engage in any personal activities during work hours which interfere with or prevent you from fulfilling the duties of your role
- To benefit yourself or any third-party (see “Conflicts of Interest” section in this booklet for more information)
- For any illegal or unethical activities, or other activities not compliant with the Code (for example gambling, creation or dissemination of pornographic or other offensive or disturbing materials)
Privacy
AnyTech365 respects the right to privacy of all employees, partners, and customers. We must handle personal data responsibly and in compliance with all applicable privacy laws, regulations, and rules. Employees who handle the personal data of others must:
- Act in accordance with applicable national, EU, and international law
- Act in accordance with any relevant contractual obligations
- Collect, use and process such information only for legitimate business purposes
- Limit access to the information to those who have a legitimate business purpose for seeing the information
- Take care to prevent unauthorized disclosure
Integrity of Information and Intellectual Property
Confidential Information
While fulfilling your duties at AnyTech365, you will naturally gain some nonpublic knowledge that is the property of AnyTech365. We trust and expect that all employees and partners maintain the confidentiality of this valuable information.
Confidential information includes things such as contracts, supplier or partner information, business strategy, marketing plans, management changes, existing and future product launches, Personally Identifiable Information (PII) of employees or partners, scripts, internal technical or operational details, financial data, and product costs.
It is prohibited to disclose AnyTech365 information to anyone outside of AnyTech365; it must only be used for company purposes. Within the company, confidential information must also only be accessible to employees and partners whose specific duties require access to said information. If you leave AnyTech365, you must return all company property, materials, and any copies.
Confidential materials must:
- Be maintained and stored securely at all times
- Not be left visible to non-authorised individuals
- Be plainly marked as confidential
- Not be sent to unattended printers or fax machines
- Not be discussed where non-authorised individuals might hear
Fairness and equality are important to AnyTech365 – we must also act with integrity with regards to the confidential information and materials of others and respect their confidentiality at all times.
Here are some basic guidelines:
- You must not bring any materials with you to AnyTech365 from any previous employer
- You must not make use of or receive the confidential information of others
- You must not attempt to obtain confidential information from another company’s present or former employees, partners, or suppliers.
- Do not engage in espionage; be ethical, transparent, and compliant with the law when obtaining information about competitors or the marketplace
Intellectual Property
Any work product you create or develop, either totally or partially, through use of company information or resources, as part of your duties, or on company time – is the sole property of AnyTech365. This includes ideas, improvements, software programs, artwork, inventions, discoveries, and works of authorship.
Any such work product that is a result of your work efforts must be disclosed to AnyTech365 in writing, and you must cooperate with AnyTech365 in order to secure the correct legal protection of the product for the company.
When contracting any work from a third party, you are required to secure the appropriate written agreement or release before any such work begins to ensure that AnyTech365 receives the legal benefit of and protection for any work.
Be sure to follow any and all applicable rules regarding the use of the work product of others. For example, you must only use software for which we have a valid license and must only use that software in accordance with the license terms for that software. Written materials, artwork, photographs, images, and music may be subject to copyright protection and should be used only if and when permitted. Note that some copyrighted material does not clearly display the copyright symbol – be sure to confirm legal right to use anything before you use it.
Company Records
You must manage information in such a way that supports business needs while ensuring efficiency, security, and full compliance with any applicable laws, regulations, or rules. This policy applies to records maintained in all forms at AnyTech365, including both electronic and paper.
- Records must always be prepared accurately and reliably, and stored properly in accordance with company policy
- All required transactions and events must be accurately and fairly recorded
- AnyTech365 strictly prohibits any unrecorded company funds, assets, or other types of “off the books” accounts, regardless of any perceived reason for such accounts
- It is forbidden to knowingly destroy or discard any information that is subject to a legal hold
Integrity in the Community
Social Media and Online Communities
The majority of our business is conducted online, and as such, our online communities are of vital importance for our reputation, for our continued service to customers, and for our successes as a company.
For the purpose of this policy, we define “social media” as any social networking sites, blogs, wikis, microblogs, message boards, chat rooms, electronic newsletters, online forums, and any other sites and services that permit users to share information or materials with others in a contemporaneous manner.
The social media policy applies equally to the business use of social media on behalf of AnyTech365 conducted by authorised personnel, to personal use of social media by any employee or partner in reference to AnyTech365, or in relation to any AnyTech365 websites or accounts.
You must:
- Always act with integrity and follow the Code when using social media in reference to or on behalf of AnyTech365
- Never publish, post, or release in any form any non-public or confidential information
- Immediately notify your line manager in the event that AnyTech365 receives media attention or legal questions via social media, without responding directly
- Be aware of the effect your actions may have on your own, as well as AnyTech365’s, reputation
- Never post material that is either inappropriate or harmful to AnyTech365, our employees, or our customers
- Disengage politely from any dialogue that threatens to become antagonistic while using social media (involving AnyTech365, our partners, customers, or any employee) and seek the advice of your manager
- Ensure you have the appropriate permissions before referring to or posting images of current or former employees, partners, vendors or suppliers
- Ensure you obtain appropriate permission to use a third party’s copyrights, copyrighted material, trademarks, service marks or other intellectual property
- Never neglect your duties and responsibilities to use social media
- Never use social media for any personal blogging or content sharing using company assets, and never during working hours
- If authorised and related to your duties, only use social media for the benefit of the company, in line with our mission and the Code
Subject to applicable law, an after‐hours online activity that violates the AnyTech365 Code of Conduct or any other company policy may lead to disciplinary action up to and including dismissal
Personal Activities
AnyTech365 encourage employees and partners to be involved in their communities and understand the importance of balance between work, personal, and family lives. However, you must not impose your personal opinions or beliefs on others, or represent your personal views as those of AnyTech365.
While you are entitled to keep your personal activities outside of the workplace confidential, you must always keep in mind that you are a representative of AnyTech365. Your behaviour can positively or negatively affect our reputation and ability to complete our mission.
Political Activities
AnyTech365 strictly prohibits any political activities while on company time, premises, or using company resources. Do not promote any political views or beliefs by any means, including distribution or posting notices or other materials around AnyTech365 premises or online. Outside of the workplace, you must not suggest or indicate that AnyTech365 supports your views, or that you speak on behalf of the company.
Public Relations
Acting with integrity is the correct way to do business, and all public relations situations allow us to present our integrity and professionalism. It is vital that all information regarding the company must be accurate, consistent, and complete, and propagated in accordance with the Code and all other AnyTech365 policies.
If someone asks you for information or comment (for example, a journalist or potential investor), immediately notify your line manager about the request. Do not attempt to answer these questions yourself –the appropriate person will supply the requested information directly to the inquirer in line with correct procedures.
Administration of the Code
The responsibility for administering the Code rests with Janus Nielsen (Chief Executive Officer), with oversight by Juan Salazar (General Manager), George Medzhidiliev (Chief Compliance Officer), and the management team.
Decision Making
The management team will make all decisions regarding any perceived or actual Code violations and any necessary disciplinary action. Decisions which fall into certain categories may be delegated to others as necessary.
Disciplinary Action
If an employee or partner is found to be in violation of the Code, full notation of the details and circumstances, the final decision, and a copy of any letter of reprimand will be placed in employee’s permanent record.
Immediate Termination Offences
While any violation of the Code should be avoided, and many infractions can involve termination of employment, the following actions of misconduct will result in immediate termination of employment, and prosecution to the full extent of the law where applicable:
- Claiming that AnyTech365 is recommended by, associated with, partners with, is endorsed by, or is itself Microsoft, Apple or any other well-known IT company in order to mislead the consumer and gain selling advantage
- Theft or unlawful access of customer payment card/bank details
- Theft of unlawful access of Personally Identifiable Information (PII) from company records
Acknowledgement
All new and existing employees and contracted staff must by personally signed declaration acknowledge their receipt of, and agreement to abide by, the AnyTech365 Code of Conduct.
Failure to read the Code or sign the acknowledgement form does not disqualify an employee or partner from compliance with the Code.
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