Code of business conduct

This Code sets out the standards of conduct that govern how Axtero does business. It binds Axtero and everyone who works for or on behalf of Axtero, including any employees, independent contractors, subcontractors and agents, in every country where Axtero operates.

Axtero delivers endpoint and workspace management services to institutional customers, works inside customer environments, and holds partner status with technology vendors. That combination means Axtero routinely handles privileged access to customer systems and confidential information belonging to third parties. The standards below follow from that responsibility.

Where this Code and a contractual obligation differ, the stricter applies. Where this Code and local law differ, the law applies, and the conflict is to be raised rather than resolved quietly.

Axtero complies with all applicable laws and regulations in every jurisdiction in which it operates. That is the minimum standard of this Code, not the whole of it: conduct can be lawful and still fall short of what is written here.

Axtero has a zero-tolerance policy on bribery and corruption in all forms, including facilitation payments, kickbacks, extortion and embezzlement.

No person covered by this Code may offer, promise, give, request or accept any payment or anything of value, directly or through a third party, in order to obtain or retain business or to secure any improper advantage. This applies to dealings with private parties and to dealings with public officials, and it applies whether the benefit is intended for the recipient or for someone else.

This obligation is grounded in, among others, the Swiss Criminal Code provisions on bribery (Art. 322ter and following), the United States Foreign Corrupt Practices Act, and the United Kingdom Bribery Act. Several of these laws apply across borders, so the strictest applicable standard governs.

Public sector work carries a higher bar. A material part of Axtero's market is hospitals, schools, universities and public administration. Anything of value offered in that context is treated as capable of improper influence, and the answer is no unless it is plainly customary, modest, transparent and permitted by the recipient's own rules.

Business courtesies are acceptable only when all of the following hold: modest in value, infrequent, customary in the setting, never cash or a cash equivalent, never solicited, never conditional on any business outcome, and capable of being disclosed without embarrassment to either side. Anything that fails one of those tests is declined.

Business decisions are made on the merits. Any personal, financial or family interest that could reasonably be seen to compromise a decision taken on Axtero's behalf must be disclosed before the decision is taken, and the person concerned steps out of it.

Axtero works alongside vendors, resellers and other partners who are sometimes each other's competitors. Where Axtero advises a customer on a product it also has a partner relationship with, that relationship is disclosed to the customer. Advice is given on what serves the customer.

Axtero competes on the quality and price of its work. No agreement or understanding with a competitor on prices, on the allocation of customers, territories or markets, or on the rigging of tenders. Competitive information is obtained only through lawful and public means. Swiss cartel and unfair competition law applies, alongside the equivalent rules in other markets Axtero serves.

Axtero complies with applicable export control and sanctions rules, including Swiss measures administered by SECO and, where they reach Axtero's activity, those of the European Union and the United States. Products, software, technical data and services are not supplied to any sanctioned party or restricted destination.

Confidential information belonging to customers, vendors, partners or Axtero itself is used only for the purpose for which it was provided, disclosed only to those who need it, and protected for as long as the obligation lasts.

Personal data is processed in accordance with the Swiss Federal Act on Data Protection and, where applicable, the EU General Data Protection Regulation: lawful basis, stated purpose, no more data than the purpose needs, and retention no longer than necessary.

Privileged access is used only for the task it was granted for. Administrative access to a customer's device fleet, identity systems or management platforms is not used to view, extract, retain or act on anything outside the scope of the engagement. Customer data is not used to train or evaluate any system, and is not moved into a third-party service, without the customer's instruction.

Books, records, invoices, time records, expense claims and reports are complete and accurate. No undisclosed or unrecorded funds or assets. Accounting records are maintained in accordance with Swiss law, and no entry is made that disguises the true nature of a transaction.

Axtero does not use or tolerate forced labour, child labour, human trafficking, harassment, retaliation or unlawful discrimination, in its own operations or knowingly in its supply chain. Working conditions comply with applicable law.

Suppliers, subcontractors and downstream partners are expected to comply with the substance of this Code. Compliance with anti-bribery and anti-corruption requirements is a condition of doing business with Axtero, and is required of downstream partners rather than merely encouraged. Axtero will not engage a third party to do anything this Code prohibits Axtero from doing directly.

Everyone covered by this Code is informed of it when they begin working for or with Axtero, and reminded of it periodically. This Code is reviewed at least annually, and whenever a change in Axtero's business or in applicable law makes a review necessary.

Any suspected breach of this Code or of applicable law should be raised directly with Chris Leduc at info@axtero.com. Concerns may be raised in confidence. Axtero does not retaliate against anyone who raises a concern in good faith, and retaliation is itself a breach of this Code.

Customers, vendors and partners are equally welcome to raise concerns through the same address.

A breach of this Code may result in the end of the employment, contract or engagement, and may be reported to the relevant authorities where the law requires it.