Business Ethics Code

1. Introduction

As a global provider of IT staffing solutions, Montreal Associates (Systems) Limited and its subsidiaries (‘Montreal Associates’, ‘MA Group ‘, ’we’, ‘us’, and ‘our’) recognise the need to do business with integrity and in a sustainable manner.

We connect curious people who believe in technology with the mission to build a sustainable, responsible, and smarter future.

To this end, MA expects all its employees, partners, and supply chain actors, to operate in an ethical, honest, compliant, and professional manner.

There are several principles of business ethics that guide the code of conduct of our business. These business ethics principles include:

I. Integrity

II. Accountability

III. Respect for Human Rights & Fair Working Conditions

IV. Information Confidentiality & Data Protection. Transparency

V. Healthy Competition

VI. Respect for the Rule of Law

VII. Sustainability & Environmental Protection

2. Scope of the Code of Conduct

This document applies to all persons working for Montreal Associates or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, consultants, and business partners, or any other person associated with us, wherever located, hereinafter the “Stakeholders.

3. Overview

The Code reflects MA’s values and sets forth what is required and expected of its Stakeholders with respect to the following topics:

1. Compliance with applicable laws

2. Ethics and integrity

3. IPR, data privacy and security

4. Inclusion and diversity

5. Employment, working conditions, and human rights

6. Wellbeing, health, and safety

7. Environmental protection

4. Compliance with Applicable Laws

MA’s Stakeholders shall comply with applicable international, national, and local regulatory, anti-corruption, health and safety, labour and environmental laws and regulations.

Business must be conducted in a compliant manner and with the observance of legality in all relevant jurisdictions.

5. Ethics and Integrity

5.1. Anti-Corruption

All applicable anti-bribery and anti-corruption laws must be complied with including, without limitation, the UK Bribery Act 2010 and the UK Criminal Finances Act 2017, or any other acts replacing or complementing those.

MA Group must maintain policies and ensure to implement procedures to mitigate and prevent bribery and corruption in any form.

5.2. Gifts

Stakeholders shall not offer or accept any gift or anything else of value to obtain improper advantages or influence for the relevant Stakeholder, for the MA Group (including MA Group’s employees and/or their family members and associates), or for any third party. Gifts include but are not limited to benefits, fees, commissions, dividends, cash, gratuities, services, or any inducements.

Stakeholders may offer business partners a gift, travel, or entertainment only if it is: (a) appropriate (no cash or cash equivalents or other excluded gift type), it does not create an actual impropriety or a perception of impropriety, and complies with all laws, regulations, and policies for all parties, (b) of reasonable value, and (c) with full transparency of its value.

5.3. Conflicts of Interest

Stakeholders must avoid financial, business, or other relationship which may affect compliance with MA’s policies. Any conflict of interest, whether real or perceived, must be immediately reported to according to MA’s Policy on Conflict of Interest.

For illustrative purposes, a conflict of interest may arise when the personal interest of an MA employee interferes with MA ‘s best interests. This may occur when an employee or a family member or friend receives a personal benefit because of this employee’s position within MA.

5.4. Non-retaliation for Reports of Concern

MA has in place a Grievance Policy, as well as a Whistleblowing Policy, for reporting of workplace concerns.

All of MA’s policies provide confidentiality and protection from retaliation for both reporters and for those participating in any related investigations.

5.5. Compliance with Competition Laws

MA is committed to operating in accordance with the Competition and Consumer Act 2010, or any other act replacing or complementing it.

None of the Stakeholders shall enter into agreements or engage in conduct that restricts, prevents or distorts competition in local and global markets in violation of applicable competition laws.

5.6. Compliance with Anti-Money Laundering Rules

MA implements an adequate Know-your-Client/Know-your-Supplier policy to comply with AML applicable rules, and with its prudent risk management and risk-based approach.

The components of our KYC policy include:

  • Ascertaining and verifying the identity of the relevant partner,
  • Ascertaining and verifying their beneficial owner,
  • Information on the purpose of each transaction.

6. Data Privacy & Security & IPR

MA Group has in places policies and measures to protect the privacy of individuals, including but not limited to employees, customers, other trade partners, and the security of confidential assets and information.

6.1. Confidentiality

Stakeholders shall not use or disclose to third parties any confidential or commercially sensitive information in its possession relating to the relationship with MA Group, unless authorised in writing by MA Group.

6.2. Data Security

In terms of data protection and information security, MA Group complies with the required standards for its industry.

Thus, we have established and maintain adequate security systems, measures, and procedures to protect any private, personal and/or confidential information, whether in paper or electronic format, from unauthorized access, use or disclosure.

6.3. Data Protection

MA Group requires its Stakeholders to protect personal information in compliance with all applicable laws and regulations. Personal information provided by or on behalf of MA Group must only be used, accessed, and disclosed as permitted by all applicable laws and regulations.

6.4. IPR Aspects

MA Group authorizes the use by Stakeholders of only information technology and software that it has acquired or licensed legitimately. Stakeholders shall not transfer any of MA Group or MA Group’s clients’ technology, proprietary information, or trade secrets without their prior written consent.

6.5. Transparency & Recordkeeping

MA Group strives to ensure that transparent, accurate and up-to-date books and business records are always maintained, in accordance with all applicable legal and contractual obligations.

7. Inclusion & Diversity

MA fosters a culture of inclusion & diversity, taking the stance that diversity should be celebrated, and no form of discrimination should be tolerated.

7.1. Non-discrimination & Work Diversity

Every employee should be entitled to a working environment which promotes dignity and respect.

MA is proud to be a little different and supports employees to reach their full potential while allowing them to be their full authentic selves. We strive to create a work environment that recognises the unique cultures and communities that compose our company.

Our Stakeholders must not engage in inhumane treatment, or abuse of their workers; any form of discrimination or harassment or retaliation should be prohibited and addressed.

MA Group promotes an inclusive and respectful environment within its workforce and supply chain.

In keeping with this principle, MA promotes equal opportunity in the workplace and prohibits any type of discriminatory practices based on race, age, gender, marital status, sexual orientation, nationality, social or ethnic origin, ideology or political affiliation, religion, disability, health condition, pregnancy or any other personal, physical or social condition.

7.2. Supplier Diversity

MA actively works for promoting diverse and underrepresented businesses in its procurement and outsourcing processes.

MA searches for suppliers that similarly value diversity in suppliers’ own supply chain and that support MA’s goals with respect to supplier diversity.

8. Employment, Working Conditions, and Human Rights

MA supports the international conventions on human rights and labour conditions, including:

  • the Ten Principles on human rights, labour, environment, and anti-corruption,
  • the Universal Declaration of Human Rights,
  • the International Labour Organization’s (ILO) Declaration on Fundamental Principles and Rights at Work; and
  • the UN Guiding Principles on Business and Human Rights,
  • and it expects its Stakeholders shall carry out their activities accordingly.

8.1. Modern Slavery & Human Trafficking

MA recognises that all businesses have an obligation to prevent modern slavery, forced labour, and human trafficking and it will do its utmost to prevent abuse within its business and the supply chains through which it operates.

MA carries out a diligent process to ensure its full compliance with human trafficking laws including, but not limited to, the UK Modern Slavery Act 2015.

All suppliers’ business operations should be free from slavery and human trafficking practices, whether in the UK or elsewhere, both internally and within the supply chains and any other external business relationships.

8.2. Child Labour

MA does not tolerate child labour in any form and at any stage of the supply chain.

This applies to any person employed below the age of 16 or higher under the applicable statutory minimum age for workers in the relevant country.

8.3. Human Rights

MA is committed to respecting human rights, and it expects its Stakeholders do the same.

MA enacted practices to maintain a respectful and safe workplace, and to not tolerate physical violence, threats, corporal punishment, mental coercion, verbal abuse, disrespectful behaviour, bullying, or harassment of any kind.

8.4. Respect for Employment Laws & Freedom of Association

MA strives to comply with all applicable wage and labour laws and regulations.

Also, MA respects workers’ rights with respect to freedom of association, including the right to form or join labour or trade unions or to join workers’ councils in accordance with local laws.

9. Wellbeing, Health, and Safety

MA implements sound health and safety practices across business operations.

9.1. Health & Safety

MA provides its workers a healthy and safe working environment in compliance with applicable local and national laws and regulations in all countries of operation, including laws on occupational risk prevention, work hygiene, protection equipment, adequate lighting and ventilation, preventive measures for work accidents and emergency response plans.

Information, instruction, and training is provided to MA’s employees for them to work safely and without risks to their health.

10. Environmental Protection

MA is committed to reducing the impact of its operations on the environment.

We will take a positive, solutions-oriented approach that recognises our impact on the environment.

We aim to encourage our employees and suppliers to reduce their own negative impact on the environment.

10.1. Environmental Footprint

MA aims to reduce negative impacts on the environment, including but not limited to reducing consumption of water, energy (gas, electricity, and solid fuels) and other manufacturing and/or office materials and, where possible, encouraging recycling and the use of recycled materials.

Our employees & suppliers are trained and supported in reducing their impact on the environment.

MA expects all employees, customers, partners, suppliers, shareholders, and stakeholders to speak up promptly about any conduct or circumstances they believe may constitute a violation of this Business Ethics Code or any other MA policy.

Suppliers shall promptly notify the Legal & Compliance Department of MA, at, regarding any known or suspected illegal or improper behaviour relating to dealings with or on behalf of MA, including behaviour by MA's employees or agents.

12. Acknowledgment. Managing Violations

MA expects Stakeholders to commit to compliance with this Code of Conduct and to be fully accountable in case of any breach.

12.1. Acknowledgement

Each Stakeholder required to sign a statement (essentially in the form enclosed under Schedule 1 herein) which confirms that such person:

  • Has received a copy of this Code,
  • Has read and understands the Code, and
  • Has agreed to comply with the Code.

12.2. Managing Lack of Compliance

Failure to abide by the standards of this Business Ethics Code may trigger discipline measures.

Persistent and repeated non-compliance, depending on the gravity of the circumstances, shall have consequences ranging from a warning to termination of employment/contract, as well as any other legal or administrative actions that may be deemed appropriate.

13. Responsibilities

The board of directors has overall responsibility for ensuring this Business Ethics Code complies with our legal obligations, and that all those under our control comply with it.

MA’s COO shall have the authority to approve any revisions.

The Legal & Compliance Department has primary and day-to-day responsibility for monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective.