Partners Code of Conduct


As a company that is based in the Netherlands and conducts business globally, ReaQta BV (“ReaQta” or “Company”) conducts a wide array of activities in the cybersecurity market, including research and development, marketing and sales.

ReaQta is committed to complying with all applicable laws, regulations, and other legal requirements and operating in a manner that reflects high ethical standards in every country in which it does business. Accordingly, ReaQta seeks to conduct business with agents, resellers, and other third parties, and their employees, agents and subcontractors (collectively, “Business Partner(s)”), who share the Company’s commitment to high ethical standards and operate in a responsible and ethical manner.

Business Partners are expected to seek guidance from and raise concerns to ReaQta related to potential or actual violations of this Global Business Partners Code of Conduct (“Code”) or any ReaQta policies. If you have knowledge of, or suspect any misconduct, please contact ReaQta at compliance@reaqta.com. By accepting our business terms and agreeing to do business with ReaQta, you are agreeing to comply with this Global Business Partners Code of Conduct.

Scope

The ReaQta Global Business Partners Code of Conduct is applicable to all Business Partners that represent and/or assist the Company in any way in connection with any actual or proposed sales, licensing or services transaction, whether or not the employee, company or firm is paid any form of remuneration directly or indirectly by the Company, including sales commissions or discounts. All Business Partners must adhere to this Global Business Partners of Conduct and all applicable laws and regulations while conducting business with or on behalf of ReaQta.

General Responsabilities

The integrity and professionalism of our Business Partners can impact ReaQta’s reputation. Therefore, ReaQta requires its Business Partners to comply with the guidance provided in this Global Business Partner Code of Conduct. Compliance with this Global Business Partner Code of Conduct is required for a Business Partner to be considered in good standing and as a condition of continuing a business relationship with ReaQta.

Business Partners are expected to seek guidance from and raise concerns to ReaQta related to any and all potential or actual violations of law or ReaQta’s policies, including this Global Business Partners Code of Conduct.

Third-Party Conduct and Ethics

ReaQta requires its Business Partners to conduct their business in an ethical manner and with integrity. All ReaQta Business Partners must comply with the following policies and procedures.

Anti-Bribery and Anti-Corruption

ReaQta does not tolerate bribery or corruption in any form. As a result, all ReaQta Business Partners must comply with all applicable laws governing Government Officials, commercial bribery, business entertainment, travel and gifts, political contributions and charitable contributions and other applicable laws. ReaQta takes its commitment to ethical conduct very seriously and seeks to only partner with Business Partners adhering to the highest ethical standards.

No ReaQta Business Partner, employees, agents or others acting on its behalf, may at any time offer or provide bribes or kickbacks of any kind, whether in dealings with Government Officials or individuals in the private sector. ReaQta and its employees, as well as Business Partners acting on ReaQta’s behalf, can be held civilly or criminally liable for the misconduct of its Business Partners.

Business Partners are required to comply with all applicable anti-bribery, anti-corruption (“ABAC”) laws.

Compliance with this Code of Conduct requires that Business partners maintain effective ABAC policies and procedures sufficient to prevent and detect potential bribery and/or corruption, and enable the Business Partner to ensure compliance with all Sections of this Code. Business Partners must provide training to their employees, agents or others acting on its behalf, on compliance with their ABAC policies and procedures.

Finally, Business Partners, employees, agents or others acting on its behalf, may not accept gifts or entertainment that may appear to be an inducement or reward for actions taken or that place them under an obligation to take future action. Providing anything of value without an appropriate service being provided, even if considered local custom, may be inconsistent with this Policy and/or applicable ABAC laws.

Gifts, Meals and Entertainment

In general, Business Partners may not provide anything of value to a Government Official.

However, as long as no bid is pending, Business Partners may occasionally provide courtesy gifts of nominal value (e.g., pens, mugs, calendars) and entertainment to ReaQta employees when such items are:

  • lawful under local laws and regulations
  • customary in a business relationship
  • reasonable in value (e.g. under $100)
  • occasional and provided in support of ReaQta business

Notwithstanding the above, Business Partners must not provide ReaQta employees with any gifts of cash or cash equivalent (such as prepaid or gift cards). In addition, Business Partners must not provide any ReaQta personnel with any travel support, including overnight accommodations.

At least one Business Partner representative must be present during any meal or entertainment that it provides to ReaQta employees.

Business Partners seeking exceptions should secure ReaQta’s Legal Department pre-approval.

Antitrust

All ReaQta Business Partners must conduct business in full compliance with antitrust and fair competition laws that govern the jurisdictions in which they conduct business.

Business Records

All ReaQta Business Partners must honestly and accurately record and report all business information and comply with all applicable laws regarding their completion and accuracy. Business Partners must create, retain and dispose of business records in full compliance with all applicable legal and regulatory requirements. In addition, Business Partners must devise and maintain an adequate system of accounting controls, including controls sufficient to detect and prevent bribery, money laundering and/or other acts of corruption.

Trade

Many countries periodically impose restrictions, controls or sanctions on exports and other dealings with certain other countries, persons or groups. These restrictions, controls or sanctions could be violated by doing business with a certain person, traveling to a particular country, or allowing a certain person to view or access certain information. All Business Partners are expected to comply with all applicable trade controls, as well as all applicable export, re-export, and import laws and regulations governing their business.

Press / Media

Unless authorized in writing by ReaQta, business partners must not speak on behalf of ReaQta under any circumstance.

Confidentiality

Business Partners may not engage in unauthorized external communications, including in marketing presentations, about ReaQta’s prospects, performance, or policies, nor disclose ReaQta’s confidential or proprietary information.

Privacy

All Business Partners must comply with all applicable privacy and data protection laws and regulations related to the collection, use, disclosure, destruction or otherwise processing of personal information. Business Partners must have documented, implemented, and maintain a written information security and privacy program containing the appropriate administrative, technical and organizational measures, procedures, and other safeguards, appropriate to the size and complexity of its operations, the nature and scope of its activities, and the personal information involved, to protect personal information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, and against all other forms of unlawful use or processing, including, but not limited to, unnecessary collection or further usage or processing. Business Partners’ use and disclosure of personally identifiable information must be limited to those purposes for which it was received to ensure that individuals’ privacy rights are protected. Personal information means any information relating to an identified or identifiable person.

Intellectual Property

Business Partners must comply with the intellectual property ownership rights of ReaQta, including but not limited to copyrights, patents, trademarks and trade secrets; and manage the transfer of technology and know-how in a manner that protects intellectual property rights.

Any use of the ReaQta Trademarks (as defined in ReaQta’s External Brand Guidelines) is subject to ReaQta’s External Brand Guidelines, located at: https://www.reaqta.com/newsroom.

Marketing and Promotional Practices

Business Partners must maintain only marketing and promotional materials and activities that conform to high ethical standards and comply with all applicable laws and regulations. Promotional materials and activities that mention the products or services of third parties (e.g., ReaQta competitors) must fairly and accurately represent those products and services. Use of ReaQta name, trademark and any representations of Company products or services are highly restricted unless written authorization has been provided by ReaQta’s Legal Department.

Labor

ReaQta expects its Business Partners to share its commitment to human rights and equal opportunity in the workplace and conduct their employment practices in full compliance with all applicable laws and regulations, and to treat their employees with dignity and respect.

Accordingly, ReaQta expects its Business Partners to share its dedication to a workforce and workplace free of harassment and unlawful discrimination. While we recognize and respect cultural differences, we require that Business Partners not engage in discrimination in hiring, compensation, access to training, promotion, termination, and/or retirement based on race, color, sex, national origin, religion, age, disability, gender identity or expression, marital status, pregnancy, sexual orientation, political affiliation, union membership, or veteran status. Business Partners must accommodate all disabilities to the extent required by law.

Anti-Slavery and Human Trafficking

ReaQta regards all forms of slavery and human trafficking as unacceptable and strives to ensure that it must play no part anywhere within its business. ReaQta is committed to ensuring that everyone it deals with is treated with dignity and respect and that the way it conducts its business and its dealings with Business Partners reflects its values and deters any form of modern slavery and human trafficking from occurring within its business and supply chain.

ReaQta expects each of its Business Partners to share its commitment to respect for human rights and equality of opportunity in the workplace. ReaQta expects each such Business Partner to reflect this in their own employment practices so as to achieve full compliance with all applicable laws and regulations.

For additional information about ReaQta’s zero tolerance approach to modern slavery, please refer to ReaQta’s Modern Slavery Act Transparency Statement, available at: https://www.reaqta.com/compliance/modern-slavery-statement.

Environment, Health and Safety

Business Partners must operate in an environmentally responsible and efficient manner to minimize adverse impacts on the environment. Business Partners are encouraged to conserve natural resources, avoid the use of hazardous materials, and engage in activities that reuse and recycle resources. The environmental, health and safety elements require that Business Partners comply with all applicable environmental regulations. All required environmental permits, licenses, information registrations and restrictions shall be obtained, and their operational and reporting requirements followed.

Conflicts of Interest

ReaQta expects all Company personnel to be free from actual or potential conflicts of interest—including in their interactions with Business Partners. A conflict of interest occurs whenever the prospect of direct or indirect personal gain may influence, or appear to influence, an individual’s judgment or actions while conducting ReaQta business. ReaQta expects all Business Partners to diligently avoid such conflicts and to report any and all actual, potential and/or perceived conflicts that may arise.