CODE OF CONDUCT FOR CRM TECHNOLOGY OÜ
This Code of Conduct sets out in general terms the conduct principles for how we guide our business and relations, and serves as our policy on ethics. For detailed principles and further guidance, we need to look for information in each relevant specific regulation.
Being part of CRM Technology and sharing its brand identity, means adhering to this Code of Conduct. Each and every employee in CRM Technology shall follow the Code of Conduct and all other laws and external and internal rules and regulations, as well as good industry standards relevant to our area of responsibility. The highest possible ethical standards of professionalism and conduct is required from all employees of CRM Technology. Managers have a special responsibility to lead according to these standards which means that they shall act and communicate as role models.
Purpose, vision and values
Our values are innovation, integrity, teamwork, being ethical, passionate about mobility in order to provide world class service for dealerships. Our vision is a financially sound and sustainable society where we empower the many people and businesses to create a better future.
To ensure the delivery of our purpose and vision, we shall be an attractive, inclusive workplace with clear accountability. Furthermore, we aim for a low risk profile, and to be an efficient, profitable and compliant financial services provider and financial services platform with a standardised, scalable and stable infrastructure.
In doing so, we aim to uphold our reputation for acting responsibly and with openness and integrity, respecting laws and regulations as well as internationally accepted standards of responsible business conduct with due consideration to the traditions and cultures of the countries where we operate.
CRM Technology shall operate with transparency, trust and integrity. CRM Technology ´s foundation is built on maintaining the trust of our customers, owners, employees, business partners, as well as the trust of the society. We need to manage risk awareness and base all our decisions on high ethical standards. In making decisions, we must not only be guided by what is allowed and legal, but also by what is right and proper from an ethical perspective.
We handle large financial values and have access to confidential information and other sensitive information, on a day-to-day basis. We are committed to protect CRM Technology from activities that pose threats to CRM Technology ´s operations and customers, and in the long run the integrity and the stability of the financial system. As a result hereof, we are expected to place more strict requirements on employees in a financial institution than in other business sectors.
Employees
CRM Technology provides a work environment that is safe, developing and creates conditions for good performances and long-term relationships, both internally and externally. All employees shall have the same opportunities and have a right to be treated with respect and dignity. By diversity and inclusion, CRM Technology means that every employee, within their own abilities, qualifications and life experiences, is an equal part of the collective.
Expectations on all employees
As CRM Technology employees, we are expected to be accountable and to perform our tasks with relevant stakeholders in focus and take responsibility for understanding, prioritising and delivering on what is expected in the role. We shall act according to our job descriptions and the expectations there upon. We are expected to take responsibility to provide feedback and highlight the issues that come to our attention for the benefit of CRM Technology. We are expected to act as team members and to cooperate with others across the organisation.
We shall take responsibility for our own long-term development, by prioritising and acting on our personal development.
We shall always strive to improve and to be aware of the impact of our tasks. We are expected to integrate sustainable economic, sustainable, social, environmental and ethical thinking into everything we do. We are expected to treat everybody, including colleagues and customers, with respect and according to our values (open, simple and caring).
Every employee, within our own ability, qualifications and life experiences, is an equal part of the collective. All employees regardless of gender, ethnic background, religion or other belief, age, sexual orientation, gender identity and gender expression or physical ability shall have equal access to development and career opportunities. We apply zero-tolerance against discrimination, harassment, sexual harassment and bullying.
Expectations on leaders
Leaders are responsible for ensuring that the objectives of the team and team members are clear, meaningful and simple to understand. Leaders should inspire and empower not only by ensuring that employees deal effectively with their responsibilities and by following up on the work delegated to them, but also by nurturing talent and providing opportunities for professional development.
Leaders are responsible for supporting and coaching employees in their development and continuously using a dialogue to ensure a sustainable development. Leaders take responsibility to manage the full cycle of their employees’ performance. Leaders are responsible for creating a high level of team spirit and engagement and to ensure right competences and conditions for the employees to be able to deliver.
Leaders shall act according to their job description and the expectations upon them in their role. Leaders shall look for synergies, improvements, addressing potential issues and concerns not limiting themselves with their direct area of responsibility.
Each leader is responsible for ensuring that the Code of Conduct as well as all other applicable regulations are known, and conformed to, by all employees within their respective area of responsibility. Each leader shall act in a manner that sets a proper example.
Compliance culture
We are committed to comply with the letter, spirit and intent of all applicable regulations, laws and standards of good market practice in every jurisdiction in which we operate.
All employees shall at all times comply with CRM Technology ’s regulations and other applicable rules and regulations as well as good industry standards relevant to our area of responsibility. Due regard shall be given to privacy matters in relation to our clients, employees and other individuals which we come into contact with. We work to detect, prevent, report and respond to any risks we face in our business.
We must always manage information in a responsible and secure way in order to maintain trust from our customers, the society, and the regulators, and to fulfill CRM Technology’s legal obligations. We shall maintain the confidentiality of any information which shall be kept confidential due to law, regulation or a confidentiality undertaking. Only the people that need confidential information in order to perform their tasks, are entitled to it. Only internally approved and provided tools, services and storage alternatives shall be used to share and store internal and confidential information.
Data protection
We are committed to adequately protect personal data and respect the right to privacy of our customers, employees and others. This constitutes an important part in CRM Technology ’s efforts to act in compliance with laws and regulations and ensuring the individuals’ fundamental rights and freedom, including their fundamental right to protection of their personal data.
Money laundering and terrorist financing
CRM Technology has a responsibility to its customers, shareholders, supervisory authorities and to the society to prevent CRM Technology from being used to facilitate the movement of criminal proceeds with money laundering or transfer of funds to finance terrorism. We are committed to identify and manage the money laundering and terrorist financing risks that CRM Technology is exposed to, and to take the adequate measures required to manage these risks across all jurisdictions in which we operate. We must uphold robust and consistent Anti-Money Laundering and Counter Terrorist Financing standards and procedures to prevent the use of products, services or channels for purposes of money laundering and terrorist financing in the jurisdictions in which CRM Technology operates.