It is the policy of Glokyl LLC to provide our Code of Ethics and Business Conduct, which will serve as a guide to proper business conduct for all users. We expect all users to observe the highest standards of ethics and integrity in their conduct. This means following a basic code of ethical behavior that includes the following.
Build Trust and Credibility
The success of our business is dependent on the trust and confidence we earn from our users, customers and businesses. We gain credibility by adhering to our commitments, displaying honesty and integrity and reaching company goals solely through honorable conduct. When considering any action, it is wise to ask: will this build trust and credibility for Glokyl LLC & myself? Will it help create a working environment in which Glokyl LLC & myself can succeed over the long term? Is the commitment I am making one I can follow through with? The only way we will maximize trust and credibility is by answering "yes” to those questions and by working every day to build our trust and credibility.
Respect for the Individual
We all deserve to work in an environment (virtual or otherwise) where we are treated with dignity and respect. Glokyl LLC is committed to creating such an environment because it brings out the full potential in each of us, which, in turn, contributes directly to our business success. Glokyl LLC is an equal employment/affirmative action employer and is committed to providing a workplace that is free of discrimination of all types from abusive, offensive or harassing behavior. Any user who feels harassed or discriminated against should report the incident directly to Glokyl Marketplace.
Create a Culture of Open and Honest Communication
At Glokyl Marketplace, everyone should feel comfortable to speak his or her mind, particularly with respect to ethics concerns. User have a responsibility to create an open and supportive environment where all feel comfortable raising such questions. We all benefit tremendously when users exercise their power to prevent mistakes or wrongdoing by asking the right questions at the right times. Glokyl LLC will investigate all reported instances of questionable or unethical behavior. In every instance where improper behavior is found to have occurred, Glokyl LLC will take appropriate action. We will not tolerate retaliation against users who raise ethics concerns in good faith.
Glokyl LLC has the added responsibility for demonstrating, through our actions, the importance of this Code. In any business, ethical behavior does not simply happen; it is the product of clear and direct communication of behavioral expectations, modeled from the top and demonstrated by example. Again, ultimately, our actions are what matters.
Sellers will be responsible for promptly addressing ethical questions or concerns raised by users and for taking the appropriate steps to deal with such issues. Sellers & Vendors should not consider customer’s ethics concerns as threats or challenges to their business, but rather as another encouraged form of business communication. We want the ethics dialogue to become a natural part of daily transactions.
Uphold the Law
Our commitment to integrity begins with complying with laws, rules and regulations where we do business. Further, each of us must have an understanding of Glokyl LLC policies, laws, rules and regulations that apply to our specific roles. If we are unsure of whether a contemplated action is permitted by law or Company policy, we should seek the advice from a resource expert. We are responsible for preventing violations of law and for speaking up if we see possible violations.
We are dedicated to ethical, fair and vigorous competition. We will sell Glokyl LLC & vendor products and services based on their merit, superior quality, functionality and competitive pricing. We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors. We will not offer or solicit improper payments or gratuities in connection with the purchase of goods or services for Glokyl LLC or the sales of its products or services, nor will we engage or assist in unlawful boycotts of particular customers.
It is important that we respect the property rights of others. We will not acquire or seek to acquire improper means of a competitor’s trade secrets or other proprietary or confidential information. We will not engage in unauthorized use, copying, distribution or alteration of software or other intellectual property.
We will not selectively disclose (whether in one-on-one or small discussions, meetings, presentations, proposals, blogs, forums or otherwise) any material nonpublic information with respect to Glokyl LLC, its business operations, plans, financial condition, results of operations or any development plan. We should be particularly vigilant when making presentations or proposals to customers to ensure that our presentations do not contain material nonpublic information.
Avoid Conflicts of Interest
We must avoid any relationship or activity that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our business. At times, we may be faced with situations where the business actions we take on behalf of Glokyl LLC may conflict with our own personal or family interests because of the course of action that is best for us personally may not also be the best course of action for Glokyl LLC.
We owe a duty to Glokyl LLC & our own businesses to advance its legitimate interests when the opportunity to do so arises. We must never use Glokyl LLC property or information for personal gain or personally take for ourselves any opportunity that is discovered through our position with Glokyl LLC. Determining whether a conflict of interest exists is not always easy to do. Users with a conflict of interest question should seek advice from the proper legal channels. Before engaging in any activity, transaction or relationship that might give rise to a conflict of interest, users should seek assistance from an attorney.
Business Conduct Accepting Business Courtesies
Most business courtesies offered to us in the course of our access are offered because of our connection with Glokyl LLC. We should not feel any entitlement to accept and keep a business courtesy. Although we may not use our position to obtain business courtesies, and we must never ask for them, we may accept unsolicited business courtesies acceptable within your jurisdiction. Users who award contracts or who can influence the allocation of business, who create specifications that result in the placement of business or who participate in negotiation of contracts must be particularly careful to avoid actions that create the appearance of favoritism or that may adversely affect Glokyl LLC’s reputation for impartiality and fair dealing. The prudent course is to refuse a courtesy from a supplier when Glokyl LLC is involved in choosing or reconfirming a supplier or under circumstances that would create an impression that offering courtesies is the way to obtain Glokyl LLC business.
Meals, Refreshments Entertainment and Gifts
We may accept occasional meals, refreshments, entertainment, gifts and similar business courtesies that are customary and conform to reasonable ethical practices of the marketplace, provided that:
• They are not inappropriately lavish or excessive.
• The courtesies are not frequent and do not reflect a pattern of frequent acceptance of courtesies from the same person or entity.
• The courtesy does not create the appearance of an attempt to influence business decisions, such as accepting courtesies or entertainment from a supplier whose contract is expiring in the near future.
• The user accepting the business courtesy would not feel uncomfortable discussing the courtesy with his or her manager or co-worker or having the courtesies known by the public.
Customary business entertainment is proper however, impropriety results when the value or cost is such that it could be interpreted as affecting an otherwise objective business decision. Users with questions about accepting business courtesies should speak with a legal professional.
Offering Business Courtesies
Any user who offers a business courtesy must assure that it cannot reasonably be interpreted as an attempt to gain an unfair business advantage or otherwise reflect negatively upon Glokyl LLC. Accounting for business courtesies must be done in accordance with approved company procedures. Other than to our government customers, for whom special rules apply, we may provide non-monetary gifts (i.e., company logo apparel or similar promotional items) to our customers. Further, management may approve other courtesies, including meals, refreshments or entertainment of reasonable value, provided that:
• The practice does not violate any law or regulation or the standards of conduct of the recipient’s organization.
• The business courtesy is consistent with industry practice, is infrequent in nature and is not lavish.
• The business courtesy is properly reflected on the books and records of Glokyl LLC.
Code of Ethics and Business Conduct Set Metrics and Report Results Accurately Accurate Public Disclosures
We will make certain that all disclosures made in financial reports are full, fair, accurate, timely and understandable. This obligation applies to all users, including all financial executives, with any responsibility for the preparation for such reports, including drafting, reviewing and signing or certifying the information contained therein. No business goal of any kind is ever an excuse for misrepresenting facts or falsifying records. Users should inform Glokyl LLC if they learn that information in any filing or public communication was untrue or misleading at the time it was made or if subsequent information would affect a similar future filing or public communication.
We create, retain and dispose of our company records as part of our normal course of business in compliance with all Glokyl LLC policies and guidelines, as well as all regulatory and legal requirements. All corporate records must be true, accurate and complete, and company data must be promptly and accurately entered in our books in accordance with Glokyl LLC and other applicable accounting principles. We must not improperly influence, manipulate or mislead any audit, nor interfere with any auditor engaged to perform an independent audit of Glokyl LLC books, records, processes or internal controls.
Each of us is responsible for knowing and adhering to the values and standards set forth in this Code and for raising questions if we are uncertain about company policy. If we are concerned whether the standards are being met or are aware of violations of the Code, we must contact the Glokyl LLC. We take seriously the standards set forth in the Code, and violations are cause for disciplinary action up to and including removal from our site and all business interactions. Integral to our business success is our protection of confidential company information, as well as nonpublic information entrusted to us by users, customers and other business partners. Confidential and proprietary information includes such things as pricing and financial data, credit card information, banking information, business addresses, customer names/addresses or nonpublic information about other companies, including current or potential suppliers and vendors. We will not disclose confidential and nonpublic information without a valid business or legal purpose and proper authorization.
Business Conduct Use of Company Resources
Company resources, including time, material, equipment and information, are provided for company business use. Nonetheless, occasional personal use is permissible as long as it does not affect job performance or cause a disruption to the workplace. Users and those who represent Glokyl LLC are trusted to behave responsibly and use good judgment to conserve company resources. Sellers are responsible for the business transacted with their stores and are empowered to resolve issues concerning proper use.
Solicitation of Company by non-users is prohibited at all times. Solicitation by a user of another user is prohibited, unless authorized while either the person doing the soliciting or the person be solicited is on Glokyl Marketplace. In order to protect the interests of the Glokyl LLC network and our fellow users, we reserve the right to monitor or review all data and information contained on an user’s store or profile. We will not tolerate the use of Glokyl LLC resources to create, access, store, print, solicit or send any materials that are harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate.
Compliance with these principles is an essential element in our business success. Our Compliance Committee is responsible for ensuring these principles are communicated to and understood and observed by all users. Day to day responsibility is delegated to all members who are responsible for implementing these principles, if necessary through more detailed guidance. Assurance of compliance is monitored and reported each year. Compliance with the code is subject to review by owners and subject to audit review. Users are expected to bring to Glokyl LLC’s attention any breach or suspected breach of these principles. Provision has been made for users to be able to report in confidence. From time to time, users will likely have questions as to how this Code of Ethics and Business Conduct applies in particular situations. We expect all users with such questions to discuss the exact circumstances with Glokyl LLC.