COMSOL Code of Conduct

COMSOL is committed to conducting business in an honest and ethical manner. The purpose of this Code of Conduct is to ensure that COMSOL and those with which COMSOL has a direct business relationship adhere to applicable laws and share COMSOL’s commitment to ethics. The requirements of this Code of Conduct are based on globally accepted minimum standards found in the UN Global Compact and the UN Guiding Principles on Business and Human Rights.The principles in this Code of Conduct shall apply to the COMSOL organization, as well as COMSOL partners, vendors, and suppliers (collectively referred to as “Workers”).

COMSOL expects those within its organization as well as those with which it conducts business to operate in a manner that adheres to COMSOL’s core values and principles as outlined in this Code of Conduct. Additionally, Workers shall undertake commercially reasonable efforts to make those with which they have a direct business relationship work towards meeting the requirements of this Code of Conduct or their own equivalent code of conduct.

Ethical Business Conduct

The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. Workers will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which they operate, including the Foreign Corrupt Practices Act in the US and the Bribery Act 2010 in the UK. Workers are prohibited from offering, promising, giving or accepting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage.

All transactions shall be recorded in relevant financial records in a transparent and correct manner. Documentation for transactions shall be in a transparent and correct manner for the appropriate period required for such transactions, as guided by common practices and regulations. No transaction or decision to commit resources shall be approved by any person having a conflict of interest regarding such transaction or decision. All Workers are expected and encouraged to report transactions or decisions suspected to be in violation of this Code of Conduct.

Labor Practices

COMSOL is committed to complying with applicable laws and regulations related to labor practices both in its own organization as well as in those with which it does business. Workers agree not to use or purchase supplies or materials that are produced using any illegal form of forced labor, including human trafficking. Workers shall comply with local laws regarding child labor and minimum working age laws and requirements. Workers shall treat each employee with respect and prohibit any inhuman, harsh, or degrading treatment or punishment of employees. Workers shall not discriminate in employment practices on the basis of race, religion, sex, age, physical disability, or any other basis prohibited by applicable local law.

Confidentiality

COMSOL takes the treatment of its own confidential information as well as the confidential information of its customers and business associates very seriously. Workers agree to make such confidential information available only to those with a need to know in order to accomplish the intended purpose and to use confidential information in accordance with agreed upon terms between the parties or, if no such terms exist, to use confidential information with reasonable care but no less than the standard by which they treat their own confidential information. Confidential information may include, but is not limited to, business and financial information, technical data, and marketing plans, present and future technology and product plans and developments, information related to present and future partnerships, and customer information customers which is either designated as confidential, or would be understood by the exercise of reasonable business judgment to be confidential.

Reporting

COMSOL depends on its employees, partners, and suppliers to help ensure that ethical business practices are followed. Workers will undertake commercially reasonable measures to enable their employees, business associates, or other stakeholders to raise concerns regarding the principles in this Code of Conduct or any other concerns related to ethical business conduct to the identified contact in this Code of Conduct.

Additionally, any employees, business associates, and other stakeholders raising such a concern shall be protected from any retaliatory personnel action or inaction (including threats of personnel action or inaction) with respect to any employee due to any disclosure of information that the employee reasonably believes evidences a violation of this Code of Conduct; applicable laws, rules, or regulations; gross mismanagement; gross waste of funds; an abuse of authority; or substantial and specific danger to public health or safety.

Non-Compliance

In the event a Worker is found to not be in compliance with the principles of this Code of Conduct, COMSOL reserves the right to terminate the business relationship with immediate effort.

For all inquiries related to this Code of Conduct, please contact:

Phil Kinnane
VP of Business Development
COMSOL, Inc.
100 District Avenue
Burlington, MA 01803 USA
Email: phil@comsol.com
Telephone: 781-273-3322