Code of Conduct

Created at: Feb 16, 2020
Reading Time: 7 minutes

Scope of Applicability The NCRYPTO Code of Ethics is binding for all NCRYPTO employees worldwide.

All NCRYPTO employees shall receive the NCRYPTO Code of Ethics as an electronic copy (via e-mail as a PDF file) or as a printed version in a language that they are familiar with. In addition to this, the NCRYPTO Code of Ethics is always available on the NCRYPTO Intranet and Internet for ease of reference.

All NCRYPTO executives shall ensure strict observance of the NCRYPTO Code of Ethics among their members of staff and aim to be role models for their employees. No employee should suffer any disadvantage as a result of complying with the NCRYPTO Code of Ethics.

In detail:

NCRYPTO Labs Good Conscience Principles We operate lawfully We avoid conflicts of interest We do not tolerate corruption We play fair We handle information carefully We follow export control and customs laws We observe occupational health and safety standards We manage assets carefully We do not support money laundering We do not tolerate discrimination We operate lawfully NCRYPTO abides the law All applicable legislation must be observed in all business decisions and operations both at home and abroad. Sustainable business for everyone’s benefit can only be achieved with fair competition and strict confor­mity with the law. Corruption, cartels, embezzlement and fraud distort com­petition and increase costs, which may cause significant fines, reputa­tion damage and, ultimately, could also endanger the employment at NCRYPTO.

In view of this, we refuse to conduct unfair and/or dishonest business prac­tices and carry out our business in a manner that is free of bribery and corruption.

It should be noted that breaches of the law will not be tolerated and may result in disciplinary action.

We avoid conflicts of interest NCRYPTO avoids conflicts of interest Independence, integrity and transpar­ency of our services are the founda­tion of our customers’ trust in us.

However, a conflict of interest can severely damage that trust. A conflict of interest can arise when the private interests of a NCRYPTO employee could or do conflict with the interests of NCRYPTO. For instance, if a NCRYPTO employee has a shareholding in a supplier, customer or competitor of NCRYPTO, or an employment of any kind with a third party this may lead to a conflict of interest.

We do not tolerate corruption NCRYPTO does not tolerate corruption Corruption distorts competition with the business world and causes damage to both individuals and society. Corruption can also result in actions being made under criminal and civil law for NCRYPTO employees as well as for NCRYPTO. This could include anything from a prison sentence to fines. Corruption is strictly prohibited in all countries in which NCRYPTO operates, and any violations of such are therefore not in the “beneficial interest of the company.” This contin­ues to apply to all employees, regard­less of their nationality.

We play fair NCRYPTO believes in fair game Fair and free competition between companies is the guarantor for free­dom of business behavior and effec­tive consumer protection. Fair and free competition is protected by anti­ trust laws, which forbid cartels and abuse by market­-dominating compa­nies. Mergers of companies are also subject to merger controls under certain conditions.

A cartel exists when several compa­nies coordinate their behavior on the market to restrict or eliminate compe­tition. For instance, if there are agree­ments in place between competitors about prices, quantities, territories or customer groups.

A position of market domination is abused when the possibilities for economic behavior of other com­panies – competitors, customers or suppliers – are significantly affected, without objective justification, by the behavior of the market­dominating company.

We handle information carefully NCRYPTO is committed to correct and truthful reporting The exchange of information and the use of our know­how are part of our daily commercial activity. It is import­ant to handle information correctly and transparently in order to protect it, our company and our customers.

Records and financial integrity

Internal and external transparency, as well as correct and truthful report­ing, is the standard of our entrepre­neurial action and behavior.

NCRYPTO protects its own and third party’s trade secrets and other confidential information Confidentiality

As a provider of technical services, NCRYPTO possesses valuable know­ how as well as comprehensive trade secrets, which are the basis for the successful business operations of NCRYPTO. The unauthorized disclosure or otherwise making this knowledge accessible can lead to severe losses for NCRYPTO, and result in sanctions under criminal or civil law. Therefore it is inadmissible. In order to secure our own and third­party information from unauthorized disclosures, we must adopt special precautionary measures when handling confidential information.

NCRYPTO provides for information security Information security

Information technology and data pro­ cessing play a key role for task ful­fillment at NCRYPTO. All important strategic and operational functions and tasks are significantly supported by information technology. But infor­mation technology and data process­ing also present risks concerning the security of the data.

NCRYPTO collects, processes, and uses personal data in compliance with the applicable data privacy laws Data privacy

Electronic information exchanged via Internet, Intranet, e­mail, etc., is part of our daily business. This electronic information exchange can also include personal data such as name, address or date of birth. The handling of per­ sonal data is regulated in many coun­ tries by data privacy laws in order to protect the individual’s privacy and right to determine what and when personal information is disclosed. In general, it is necessary to obtain the consent of the person affected for the collection, processing or use of their data. If the data is intended to be transferred abroad, further require­ ments must be observed (e.g. ensuring an appropriate data privacy level by using model contracts).

We follow export control and customs laws NCRYPTO follows the export control and customs regulations in all countries in which we do business As a worldwide operating enterprise, NCRYPTO is subject to various national and international foreign trade regula­tions. These treaties and laws regu­late the import, export and/or transfer (which can also take place electronic­ally) of goods, technologies, services, capital and currency over particu­lar international borders right up to the complete banning of trade with particular countries (embargo). Any trading restrictions and bans can arise from the character or purpose of use of the goods or services, the country of origin or country of use, or the business partner. The export of goods with both civilian and military uses (so­called dual use goods) also requires approval. Export controls cover exchanges between NCRYPTO subsidiaries too.

We observe occupational health and safety standards NCRYPTO observes occupational health and safety standards The protection of our employees is of primary importance for NCRYPTO, since our employees are essential for us as a provider of technical services.

We manage assets carefully NCRYPTO manages its own and third-party assets carefully Tangible and intangible assets of NCRYPTO (e.g. cash, machinery, know­how, patents and trademarks) constitute NCRYPTO’s business assets, which may only be used for business purposes. The same applies for the property of NCRYPTO busi­ness partners, with whom NCRYPTO employees come into contact in the course of their work.

We do not support money laundering NCRYPTO does not support money laundering Money laundering occurs when ille­gally acquired financial means (from criminal activities like organized crime, bribery, corruption or terrorism) are smuggled into the legal, financial and economic circulation in order to disguise their real origin or the identity of the owner.

NCRYPTO only maintains business relationships with respectable busi­ness partners, whose business activ­ities comply with all applicable laws and whose funds derive from law­ful activities. For this purpose, we at NCRYPTO observe money laundering regulations at home and abroad, and keep our distance from businesses that are used for money laundering.

We do not tolerate discrimination NCRYPTO does not tolerate discrimination NCRYPTO is a worldwide operat­ing company that is active in various countries, all with different cultures. At NCRYPTO, our attitude is that peo­ple of different ethnic origin, religion, world view, race, age, disability, gen­der or sexual identity are invaluable for our success.

No employee or business partner may be directly or indirectly discriminated against, sexually harassed or person­ally disparaged on the basis of any of these attributes, and will be protected by applicable equality legislation.