Policy

Code of Ethics and Business Conduct

Elemental World LLC wins and keeps business on the quality of its work, never through bribery or improper influence. This Code, which includes our anti-corruption policy, sets out the standards everyone who works for or with the company must follow.

Effective 7 October 2026 · Approved by the Owner of Elemental World LLC · Reviewed at least once a year

1. Who this Code applies to

This Code applies to the owner, every employee and contractor of Elemental World LLC, our resellers and subcontractors, and anyone else acting on the company's behalf, such as agents and consultants ("third parties"), wherever we do business. Everyone covered must comply with all applicable laws, with this Code, and with the codes of conduct of the technology vendors whose products and services we sell, implement or support.

Where local law is less strict than this Code, we follow this Code, even if the conduct would otherwise be legal. Where local law is stricter, we always comply with the law at a minimum. We avoid not only wrongdoing but anything that would look improper.

2. Fair competition

We compete on the merits and comply with the antitrust and competition laws of every country where we work, including United States antitrust law, which can apply wherever we are located. We never agree, directly or through others, with any competitor (including vendors' own sales teams and other partners) to:

  • fix or control prices;
  • rig bids, including agreeing who will win, staying out of a bid, or submitting "courtesy" or non-competitive bids;
  • boycott customers or suppliers;
  • divide or allocate markets, territories or customers; or
  • limit the production or sale of products or services.

We do not discuss prices, costs, profits or margins, volumes, or bids and quotes for a particular customer with competitors. We also take care with sales practices that can unfairly restrict competition, such as pricing below cost, exclusive dealing, tied or bundled sales, fixing customers' resale prices, or treating competing customers unfairly. If anyone, including a vendor's employee, asks us to take part in such conduct, we refuse and report it.

3. Anti-corruption: no bribes, kickbacks or improper payments

We comply with the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act 2010 and all other anti-corruption laws that apply to us. No one covered by this Code may offer, promise, authorise, direct, pay, give, request or accept a bribe, kickback, or any payment or anything of value, directly or through someone else, to improperly obtain or keep business or any other advantage for Elemental World, a vendor, a customer or themselves.

This applies to dealings with everyone, including:

  • government and public-sector bodies and their officials and employees, including public utilities, public universities and colleges, public healthcare organisations, and public international organisations;
  • companies wholly or partly owned or controlled by a government (state-owned enterprises) and their employees;
  • political parties, party officials and candidates for public office;
  • private companies and their employees, including our customers and vendors; and
  • the spouse, partner, children and other relatives of any of these people.

"Anything of value" is meant broadly: cash and cash equivalents such as gift cards, gifts, lavish or excessive meals and entertainment, travel (including personal travel or sightseeing), loans, favours, charitable or political donations, and offers of jobs or internships.

  • No facilitation payments. We never make small payments to officials to speed up routine government actions, such as processing applications, permits or visas, even where they are customary.
  • No indirect payments. We never ask or allow a third party to do anything we may not do ourselves.
  • No money laundering. We never take part in hiding, moving or converting money obtained unlawfully, and we watch for unusual payment requests that could signal it.
  • No unsanctioned boycotts. We do not take part in, or provide information to support, any economic boycott that the United States Government has not sanctioned.

The only exception is a payment demanded under an imminent threat to someone's health or safety. Such a payment must be reported to the Owner immediately and recorded accurately.

4. Dealing with government and the public sector

The rules for working with government and public-sector customers are stricter than those for commercial customers, and something acceptable with a private company may be illegal with a public one. When we work with any government body, we:

  • follow every law and regulation that governs public procurement and the performance of public contracts, including, for sales to the U.S. Government, the rules for commercial items and any applicable GSA Multiple Award Schedule regulations;
  • never try to obtain, from any source, procurement-sensitive or confidential government information that has not been officially released, such as source-selection or pre-award information, or a competitor's bid or proposal information;
  • never pay, or agree to pay, a contingent fee to anyone to win a government contract or influence government action, and never receive contingent, influence or referral fees on any transaction with a government or public-sector customer;
  • give no gratuity, gift, favour, entertainment, loan or anything of value to a government or public-sector official or employee except as the law clearly permits, and in any case only items of nominal value carrying the company's name (worth under US$25). Any meal, travel or hospitality for an official requires the Owner's written approval in advance;
  • submit only accurate invoices and follow all rules on invoicing and payment; and
  • keep internal controls that make sure these rules are followed.

We make no political contributions on the company's behalf.

5. Lobbying

Lobbying is any attempt to influence laws, regulations, policies or rules, and in some places it also covers procurement and business-development contact with officials. We find out whether our activities count as lobbying where we work and comply with all registration and reporting rules. We never lobby on a vendor's behalf, and we do not share government-relations consultants or lobbyists with vendors.

6. Gifts, meals and entertainment

Modest gifts and hospitality can be a normal part of business relationships, but they must never be, or look like, a bribe or an attempt to win unfair treatment. A good test: would it embarrass us, the recipient or a vendor if it became public? Any gift, meal or entertainment we give, whether to customers, vendors' personnel or anyone else, or accept, must be:

  • reasonable, ordinary and proper: no more than US$100 per person per occasion and no more than US$250 per person in a calendar year, unless the Owner approves in writing in advance;
  • given openly, never in cash or a cash equivalent, and never during a tender, bid or contract negotiation with the recipient;
  • permitted by the recipient's own organisation and by local law; and
  • recorded with its date, recipient, value and business purpose.

Anyone offered a gift or hospitality above these limits must decline it politely or report it to the Owner, who will decide whether it may be accepted or must be returned. For government officials, the stricter rules in section 4 apply.

7. Commissions, fees and third parties

Before engaging an agent, reseller, consultant, subcontractor or other third party who may deal with customers or officials for us, we:

  • check their background, ownership, qualifications and reputation, and record why they were chosen;
  • put the engagement in a written contract that requires them to comply with anti-corruption laws and this Code, allows us to audit compliance, and lets us end it if they break those rules;
  • pay commissions and fees only at reasonable rates for legitimate, documented services, by bank transfer to an account in their own name in the country where they work, never in cash; and
  • watch for warning signs, such as unusual payment requests, unexplained fees, requests to pay a different person or country, or a close relationship with an official, and resolve them before going further.

8. Financial integrity and accurate records

  • Accurate books. Every transaction, payment, discount, gift, commission and expense is recorded accurately, completely and promptly in our books, with supporting documents. Records are kept as our retention practices and the law require.
  • No side agreements. We make no side agreements, written or verbal, that change or add to the terms of a contract or order. No undisclosed or unrecorded fund or asset may be kept for any purpose.
  • Proper authority. Funds for vendor-related business are handled only under an authorised written contract with clear procedures. Documents are never altered improperly or signed by someone without authority.
  • Honest discount requests. Any request for special pricing or a non-standard discount is accurate and commercially justified, and any discount or benefit received is used only for the purpose that was disclosed and approved. We never structure a deal to create extra margin for an undisclosed purpose, such as rewarding a customer, a vendor's employee or anyone else.
  • No pre-loading. We place an order with a vendor or distributor only after receiving a matching order from an end customer, unless the vendor has specifically authorised otherwise in writing. We never "channel stuff".
  • Internal controls. We keep financial and other controls that make sure spending is authorised, responsible and appropriate.

9. Confidentiality, intellectual property and privacy

We respect the intellectual property of vendors, customers and others. We never copy licensed software without authorisation, or use anyone's confidential information, patented technology, software or documentation without permission or beyond what our work requires. Confidential information, such as source code, product plans, non-public pricing, business plans and customer or employee information, is used and shared only as needed for the work, stored securely, and shared internally only with people who need it. We follow applicable data privacy and data protection laws.

10. Insider trading

We never buy or sell the shares or other securities of a vendor, customer or any other company while holding material non-public information about it, and we never pass such information to anyone else ("tipping"). This also applies to our family members.

11. Export controls and sanctions

We comply with all applicable U.S. and international export control, import and sanctions laws. We never export, re-export or transfer any technology, software, data or services, directly or indirectly, in breach of those laws or for a prohibited use.

12. Conflicts of interest

A conflict of interest is anything that could cast doubt on our ability to act objectively. Anyone with a personal, financial or family interest that could affect a business decision must disclose it to the Owner before taking part in that decision. If we have an actual or potential conflict with a vendor or one of its employees, we disclose all relevant details to that vendor.

13. Honest contracting, advertising and marketing

Everyone involved in selling, negotiating or delivering our services must understand and honour the terms of our contracts. Every statement to customers about our own or a vendor's products and services must be accurate and truthful. We never make false or misleading claims, make claims we cannot back up, unfairly disparage competitors, or use anyone's trademarks in a way that could confuse people about the source of a product or service.

14. Our people, human rights and safety

  • Equal opportunity. We make employment and business decisions without regard to race, colour, religion, national origin or ancestry, sex, gender identity or expression, sexual orientation, age, disability, pregnancy, marital status, genetic information, political affiliation, military or veteran status, or any other characteristic protected by law.
  • No harassment. We do not tolerate harassment, discrimination or physical abuse of any kind.
  • Human rights. All work is freely chosen. We prohibit child labour, forced labour, human trafficking and slavery, and we comply with all wage, working-hours and labour laws.
  • Health, safety and environment. We provide a safe and healthy workplace, comply with all environmental, health and safety laws, and work to reduce our use of energy and materials and the waste we produce.

15. Due diligence, audits and cooperation

We answer due-diligence and onboarding questionnaires from vendors and customers truthfully, completely and accurately, including questions about our company structure, possible conflicts of interest and compliance with U.S. and local laws. We provide supporting documents when asked and cooperate with any audit our agreements allow.

16. Reporting concerns

Anyone who believes in good faith that this Code or the law may have been broken must report it promptly to the Owner, or in writing to [email protected]. Reports may be made confidentially and will be handled as confidentially as possible. Every report is reviewed and, where needed, investigated.

Where a concern involves a vendor or partner, or one of its employees, we also report it through that company's own reporting channels, such as its legal department or ethics helpline, and cooperate with its investigation.

We do not tolerate retaliation against anyone who raises a concern in good faith, even if the concern turns out to be mistaken.

17. Training, reviews and enforcement

This Code is published on our website and given to everyone it covers when they join, and each person confirms in writing that they have read it. We provide training on the Code at least once a year and review compliance with it at least once a year. Breaking this Code can lead to disciplinary action, up to and including termination of employment or of a contract, and may be reported to the authorities. The Owner reviews this Code at least once a year and updates it when laws, vendor requirements or our business change.