Trust
At Anniething®, it is essential that clients can place and continue to place their trust in the company. Therefore, Anniething® shall act in accordance with generally accepted social norms and values, as well as local laws and regulations, particularly in the acquisition and execution of assignments
Fair Competition
Management and employees must refrain from:
- Conduct that violates European or Dutch competition law;
- Unethical behavior toward clients, intermediaries, competitors, or other third parties;
- Criminal actions in dealings with clients or competitors.
Business Relationships
The acquisition and execution of assignments must always occur within a professional context. It is not permitted to offer or accept disproportionate gifts, or to provide or receive free services or products from (potential) clients, their relations, or other third parties with whom a business relationship exists.
Small tokens of appreciation are allowed, provided they do not create a sense of obligation for the recipient. Gifts that can be converted into cash or are equivalent to cash are always unacceptable. Payments that could place Anniething® in a compromising position are not permitted. The nature of the payment is just as relevant as its amount.
Gifts with a value exceeding €25 must be reported to management. Gifts exceeding €150 must be discussed by management with an independent third party. If a manager or employee feels compromised by a gift, this must be reported to the director, who will determine the appropriate course of action.
Sending or accepting invitations to non-business activities in the capacity of an Anniething® employee requires approval from management, which may consult an independent third party if necessary.
Administration and Invoicing
All transactions with clients must be documented in writing in accordance with applicable procedures. The administration of each project must be complete, accurate, and transparent. Invoices must be prepared in compliance with legal regulations and business practices. Cash payments or payments to be converted into cash may never be accepted unless they are handled according to widely accepted control procedures.
RESPONSIBILITY TOWARD BUSINESS PARTNERS
Trust
Anniething® expects its suppliers, subcontractors, and service providers to uphold the trust placed in them. Agreements must be honored punctually and in full. These partners can expect the same from Anniething®.
Fair Competition
Business decisions regarding partners are based on objective and professional considerations. Information about competitors, suppliers, or subcontractors must only be obtained lawfully. Anniething® will not use suppliers, subcontractors, or others to circumvent laws, rules, or generally accepted standards of ethical business conduct.
Employees must refrain from any criminal conduct in dealings with business partners.
Health, Safety, and Environment
In the preparation, planning, and execution of activities, Anniething® expects its business partners to comply with all applicable laws and regulations related to safety, health, and the environment. Anniething® will monitor compliance, provide reminders if necessary, and emphasize that these rules must be followed. The company aims to avoid causing any unnecessary environmental burden.
RESPONSIBILITY TOWARD EACH OTHER AND SOCIETY
Social Norms and Values
Every employee has individual ambitions, norms, and values. Anniething® also upholds its own internal values: integrity, transparency, entrepreneurship, customer focus, professionalism, results orientation, collaboration, flexibility, and solution-mindedness.
All individual and corporate values must align with generally accepted social norms. In all situations, employees must adhere to these norms and refrain from any criminal behavior toward colleagues or third parties.
Fairness and Equality
Employees are evaluated based on performance and demonstrated quality. Anniething® strictly rejects any form of discrimination based on race, religion, belief, political opinion, age, gender, disability, sexual orientation, or otherwise. Physical, verbal, or sexual intimidation is not tolerated.
Employees are encouraged to contact a confidential advisor or management in the event of complaints. Any observation of such conduct by others must be reported to the relevant director. The same duty to report applies in cases of legal violations, unreasonable behavior, suspected sabotage, or serious dysfunction on the part of any client representative.
Health, Safety, and Environment
All applicable regulations concerning safety, health, and the environment must be followed in the preparation and execution of projects. Misapplication is not permitted. Anniething® ensures a safe and healthy working environment in accordance with legal requirements. Every employee contributes by following safety and health rules. Unsafe situations must be corrected and reported immediately to the direct supervisor.
Anniething® aims to contribute to responsible development of the built environment. Environmental awareness is integrated into daily operations. Employees are expected to refrain from any action that contradicts this goal.
(External) Roles and Affiliations
Political ambitions or public/private positions held by employees must not conflict with the law. If necessary, it must be made clear that opinions or positions expressed are personal and not on behalf of Anniething®. Employees must not make public statements that could harm the (im)material interests of the company.
Paid or unpaid side activities that may conflict with the interests of Anniething® are not permitted. When in doubt, employees must consult with management.
Confidentiality
Employees are required to maintain full confidentiality about all confidential business matters, unless disclosure is legally required. In case of doubt, consultation with an independent third party is recommended.
The duty of confidentiality remains in effect even after the end of the employment relationship. Management may grant written exemption from this obligation.
Data Protection (GDPR)
Firm in Enterprise only processes personal data provided directly by the client and only insofar as it is necessary for the performance of services. Client and contact details are only used and stored when actively provided.
Access or deletion requests are honored. No personal data is shared without explicit consent, except with internal colleagues when necessary for service delivery. No third parties are granted access to systems where personal data is stored. These systems are password-protected.
Documents are stored digitally unless physical copies are essential for service execution. Printed documents are kept on-site or securely destroyed.
The director of Firm in Enterprise is ultimately responsible for data protection and acts as the central point of contact. The same care applies to data received via other (external) roles held by employees of Firm in Enterprise.
No personal data is shared via networks, cloud services, or systems, except through a secure, encrypted (paid) backup service and/or a physical backup on an external hard drive.
Accounting and Invoicing
No entries or invoices may be created that obscure the true nature of a transaction. Accounting must comply with generally accepted principles and be structured according to the policies and procedures of Anniething®. Claims must always be substantiated and justifiable.
Company Property
Business operations involve the use of information, machinery, tools, supplies, and equipment. These resources may only be used for Anniething®-related purposes. This also applies to confidential information such as sales figures, profit margins, marketing plans, or technical specifications. Employees must ensure such data is securely stored and handled with care.
Conflicts of Interest
Work at Anniething® must be based on objective decision-making. Personal interests must not interfere. Doing business with companies where family or friends have an interest may create conflicts and must be reported to management. In some cases, an independent third party may be consulted to determine the appropriate course of action.
Monitoring, Enforcement, and Sanctions
Management is responsible for overseeing compliance with this Code of Conduct. In cases not explicitly covered but potentially in conflict with its spirit, management will decide on its applicability.
An investigation may be launched based on a substantiated complaint from an employee or third party. Employees must fully cooperate. The employee in question will be heard.
The results of such investigations will be documented in a report. While an investigation is ongoing, management may impose temporary disciplinary or labor-law-related measures.
If a violation is confirmed, management may take disciplinary and/or legal action ranging from a warning, suspension, fine, or dismissal, up to and including summary dismissal. The employee may also be held liable for any resulting damages to Anniething®.
This Code of Conduct was adopted and entered into force on 7 February 2008.