Code of Conduct

General Conduct

AlfaPeople aspires to be more than just a good company – we want to be a great company. We are committed to our mission to 

• Inspire 
  to use new technology, globalization, and empowered customers to reinvent customer engagement models 
• Lead 
  to the forefront of advanced digitalization with global cloud solutions and agile services, utilizing the short innovation cycle of the future to enable competitive advantages 
• Service 
  worldwide and for years, optimizing local adoption, satisfaction, and compliance to maximize return of investments

Achieving our mission isn’t just about building innovative technology. Our mission reflects who we are as a company, how we manage our business internally, and how we work externally with customers, partners, and suppliers. 

AlfaPeople and our employees and subcontractors (collectively referred to as “AlfaPeople”), serve our customers. While conducting business with subcontractors, and customers we are committed to operating in full compliance with all applicable laws and regulations, and to adhere to the principles outlined in this Code of Conduct. 

AlfaPeople’s values are the foundation of our success and reflect our continued commitment to ethical and responsible business practices. Our Code of Conduct establishes our standards which help live our values and apply to all our employees, directors, and officers. Our values include: 

• Respect: We recognize that the thoughts, feelings, and backgrounds of others are as important as our own. It starts with our belief that every person has intrinsic worth. We invite in perspectives that are different from our own and then we really listen. We treat each other with decency, and when we disagree, we do so without diminishing each other. 
• Integrity: We are honest, ethical, and trustworthy. Trust is built when we keep our word and do what we know is right. Even when it’s hard, when we’re under stress, and when no one is looking. We’re transparent, while respecting confidentiality. We tell others the truth with care. 
• Accountability: We accept full responsibility for our decisions, actions, and results. Credibility is created when we take ownership for what we say and do and for the outcomes we create and how they’re delivered. We make our intentions and goals clear and invite input from others on how we’re doing. 

Business Practice, Ethics and Compliance 

While conducting business with our customers, AlfaPeople will conduct our business practices and activities in accordance with applicable law, with integrity, fairness, respect and in an ethical manner. 

• Anti-Corruption: AlfaPeople will comply with all applicable anti-corruption and anti- money laundering laws. All forms of bribery, kickbacks and other corruption are prohibited. AlfaPeople warrant that none of its officers, employees or other persons associated with it will improperly influence any act or decision of any governmental official, employee or political candidate, including, without limitation, through the provision of any improper or unlawful gifts, meals, travel or entertainment. 
• Anti-facilitation of Tax Evasion: AlfaPeople will not engage in any activity, practice or conduct which could constitute either a local tax evasion facilitation offence or a foreign tax evasion facilitation offence. AlfaPeople will establish, maintain and enforce policies and procedures as are both reasonable to prevent the facilitation of tax evasion by another person and to ensure compliance with any local or federal law. 
• Fair Competition and Antitrust laws: AlfaPeople will conduct our business in full compliance with all applicable fair competition and antitrust laws. 
• Public Sector Procurements: When selling to public sector entities, AlfaPeople will support fair and open competition by complying with all laws and regulations related to government procurement, tenders, and bids. AlfaPeople will not conspire with other partners, including but not limited to, bid rigging, placing orders prior to tender finalization, price fixing, or other forms of collusion. 
• Business Records and Accounting: The business records of AlfaPeople will conform with applicable legal, accounting and regulatory requirements.  
• Conflicts of Interest: Where AlfaPeople is advising a customer, especially a governmental customer, on the selection of products and/or services and has a fiduciary or contractual obligation to that customer, the AlfaPeople will avoid engaging in business activities that constitutes or could create the appearance of a conflict of interest. 
• Advertising and Marketing: AlfaPeople’s advertising and marketing activities will be conducted truthfully, accurately and in accordance with applicable law, rules and regulations. AlfaPeople will ensure that all communications to its customers be truthful, accurate, and not misleading. 
• Registrations; Permits: AlfaPeople will comply with all applicable environmental laws and regulations, keep current all required environmental registrations and permits relevant to its businesses and implement appropriate conservation measures. 
• Confidentiality: At AlfaPeople, we have a strong commitment to our clients, collaborators, partners and suppliers to preserve the privacy of the information shared with us. With this in mind, we must always remember the importance of this theme, which is the Confidentiality of Information. The term “Confidential Information” covers all and any information that is received or somehow accessed, whether it belongs to AlfaPeople, its clients, collaborators, partners, and suppliers. Confidential Information is a valuable part of the existing commercial relationship between the parties, belongs to its respective holder/subject and is protected by Law, so it is our duty to respect the secrecy of such Information, ensuring the preservation of its value. 
• Data Protection. AlfaPeople adopts actions to ensure transparency in the treatment of personal data. Such actions seek to ensure that data is used only for the specific purposes for which it was collected, considering its effective need and respecting all the terms of the respective applicable legislation. In case of doubts, please check our global policies: AlfaPeople Global IT Policy and Privacy Policy. 
• Intellectual Property: All and any rights related to computer programs, as well as data, information, products and services, inventions, discoveries, or innovations, shall belong exclusively to their respective holder/owner. Therefore, it is everyone’s duty to respect the intellectual property of all creations, whether owned by AlfaPeople, its clients or third parties. AlfaPeople will respect existing rights, including, but not limited to trademarks, patents, copyrights, and image rights of third parties and counts on the commitment and cooperation of all its collaborators, always seeking a performance based on ethics, transparency, and responsibility. 

Human Rights and Fair Labour Practices

AlfaPeople will provide a safe and healthy work environment, fully compliant with all employment, health and safety laws. 

• No Forced Labour; No Child Labour: AlfaPeople will abide by local minimum wage and maximum working hour requirements, are not to use forced labour or to use labour contacts that impose unreasonable limitations on a worker’s ability to leave their employment. The use of child labour is prohibited. 
• Non-Discrimination: AlfaPeople will not illegally discriminate in hiring, compensation, access to training, promotion, termination and/or retirement decisions based on race, sex, national origin, religion, age, disability, gender identity or expression, marital status, medical condition, physical or mental disability, pregnancy, sexual orientation, political affiliation, union membership, veteran status or other protected characteristic or status. 
• Anti-Slavery & Human trafficking: AlfaPeople will comply with all local or global applicable anti-slavery and human trafficking laws, statutes, regulations, and codes from time to time in force and warrant that none of our officers, employees or other persons associated with it AlfaPeople: 

• – has been convicted of any offence involving slavery and human trafficking; and 
• – having made reasonable enquiries, to the best of our knowledge, has been or is the subject of any investigation, inquiry or enforcement proceedings by any governmental, administrative or regulatory body regarding any offence or alleged offence of or in connection with slavery and human trafficking. 

• Health, Safety and Environment (HSE): At AlfaPeople we are concerned with the integrity of our professionals and the individuals around us, and, for this reason, issues related to safety, health and the environment must be treated seriously, with the observance of all legislation related to these themes, ensuring an ethical, healthy and safe environment by stimulating the search and adoption of sustainable practices. 

Professional Conduct

AlfaPeople will conduct themselves in a professional manner at all times to create an inclusive, productive, respectful, and professional environment, free from any forms of discrimination or harassment. 

• Inappropriate Language: AlfaPeople will not use any form of language which may be considered discriminatory, intimidating, harassing, threatening, abusive, sexually explicit, or otherwise offensive or inappropriate. 
• Treat Others with Fairness, Dignity and Respect: AlfaPeople will not tolerate, and anybody associated with AlfaPeople must not engage in, any form of sexual or other harassment. Sexual harassment is unwelcome verbal or physical behaviour based on sex and includes gender-based harassment of a person of the same gender. Examples include unwelcome sexual advances or physical contact, sexual comments or inappropriate gender-based jokes, unwelcome romantic attention, offering a benefit or preferential treatment in exchange for sexual favours, sharing or displaying sexually explicit content and using sexually degrading words. Other examples of harassment include comments, jokes or degrading words based on race, sex, national origin, religion, age, disability, gender identity or expression, marital status, medical condition, physical or mental disability, pregnancy, sexual orientation, political affiliation, union membership, veteran status or other protected characteristics or status. 
• Sanction lists: AlfaPeople will to the best of our knowledge not engage or in any other way do business with corporations fully or partially owned by people on  

• – the United Nations Security Council Consolidated Sanction list, https://www.un.org/securitycouncil/content/un-sc-consolidated-list 
• – OFAC Sanctions Program 

Or with companies’ origin from countries who are listed on the 

• – EU sanction map (https://www.sanctionsmap.eu/#/main) 
• – Or otherwise, sanctions by the United Nations or US Government. 

AlfaPeople pledges to set up and maintain measures to enable our employees to determine whether a potential client is involved with a business or corporation on the above mentioned lists. 

Alfapeople expects everyone to maintain constant attention to the issues set forth herein and to report any concerns, questions, or allegations to the respective communication channels in their country. 

In case of doubts about the proper application of the guidelines contained in this Code, collaborators (own employees and third parties) shall submit the matter to their immediate management and/or their respective legal department.