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ProSight Solutions Code of Conduct

Introduction

Welcome to ProSight Solutions. Our code of conduct sets out the principles and standards of behavior that we expect from our employees, contractors, and partners. This document is designed to ensure that we operate with integrity, transparency, and respect in all our dealings.

Purpose

This code of conduct aims to:

• Define acceptable and unacceptable behaviors.
• Promote a culture of ethical conduct and compliance with the law.
• Protect the company’s reputation and assets.
• Provide guidance on handling ethical dilemmas and conflicts of interest.
• Outline compliance and regulations procedures that are in place. 

Scope

This code applies to all employees, officers, directors, and contractors of ProSight Solutions, as well as any third parties representing or acting on behalf of the company.

Core Values

• Integrity: Act honestly and with strong moral principles.
• Transparency: Communicate openly and honestly.
• Respect: Treat everyone with dignity and respect.
• Accountability: Take responsibility for your actions.
• Innovation: Encourage creative thinking and continuous improvement.

Compliance with Laws and Regulations

We comply with all applicable laws, regulations, and industry standards. Employees must understand and follow the legal requirements relevant to their job responsibilities.

• Antitrust and Competition Laws: We compete fairly and comply with all competition laws. Our business practices are designed to promote free and fair competition. We avoid any activities that could be interpreted as anti-competitive, including price fixing, market division, bid-rigging, and monopolistic practices.
• Telecommunications Regulations: We adhere to all regulations governing telecommunications services and infrastructure. This includes compliance with licensing requirements, privacy and data protection laws, and adherence to service quality standards. Employees, officers, directors, and contractors of ProSight Solutions must ensure that all activities related to our telecommunication consulting services are conducted in accordance with regulatory requirements to maintain the integrity and reliability of our services.
  • Relevant Laws: Telecommunications ACT(USA); Communications ACT(UK); Telecommunications ACT(Canada); General Data Protection Regulation(GDPR-EU)
• Environmental Laws: We commit to environmentally responsible practices and compliance with environmental regulations. This involves adhering to laws related to waste management, emissions, resource conservation, and pollution control. We strive to minimize our environmental impact through sustainable practices and innovations.

Ethical Business Practices

We are committed to conducting business ethically and transparently.

• Integrity: Act with honesty and integrity in all business dealings. We ensure that our actions reflect our commitment to ethical conduct. We are truthful in our communications fostering a culture of trust and reliability within the company.
• Accountability: We take responsibility for our actions and decisions. Employees, officers, directors, and contractors of ProSight Solutions are expected to be accountable for their conduct and to report unethical behavior. We encourage an environment where concerns can be raised without fear of retaliation, ensuring the empowerment to uphold ethical standards.
• Transparency: We maintain transparency in our communications and operations. We ensure that stakeholders have access to accurate and timely information about our business practices. This transparency builds trust and creates positive relationships with customers, partners, and the broader community.
• Respect: We treat all individuals with respect and dignity. We promote a culture of respect and inclusion within our organization and in our interactions with external parties. We value diverse perspectives and ensure that all individuals are heard and considered.
• Fair Dealing: Treat customers, suppliers, and competitors fairly. ProSight Solutions avoids conflicts of interest and makes decisions based on objective criteria. Our goal is to build long-lasting relationships based on mutual respect and trust.
• Gifts and Entertainment: We do not offer or accept inappropriate gifts, favours, or entertainment that could influence business decisions. 

Protection and Proper Use of Company Assets

Safeguard and use company assets responsibly. Proper management and protection of company assets are vital to maintaining our operational effectiveness and ensuring long-term success: these are the principles that guide our approach: 

• Asset Management: Protect and maintain company assets, including physical, intellectual, and digital assets. These assets are critical to our business operations and must be handled with care and responsibility.
  • Physical Assets: This includes buildings, equipment and supplies. We should use physical assets efficiently, avoid misuse, and report any damage or loss immediately.
  • Relevant 
  • Intellectual Property: Protect our trademarks, copyrights, trade secrets, and other proprietary information. Unauthorized use or disclosure of intellectual property is prohibited and must be reported.
  • Digital Assets: Safeguard digital assets such as software, databases, and electronic files. Ensure compliance with software licenses and use company technology resources responsibly.
• Confidential Information: Protect confidential information and only use it for its intended purpose. Confidential information includes proprietary data, business strategies, financial information, and personal data of employees and customers.
  • Access Control: Limit access to confidential information to authorized personnel only. Use strong passwords, encryption, and other security measures to protect sensitive data.
    • Relevant Laws: SOX-USA; GDPR-EU
  • Data Handling: Handle confidential information with care, whether in digital or physical form. Avoid discussing sensitive information in public places or with unauthorized individuals.
    • Relevant Laws: HIPAA-USA, Data Protection Act-UK
  • Non-Disclosure: Adhere to non-disclosure agreements and company policies regarding the sharing of confidential information. Report any breaches or potential breaches immediately.
    • Relevant laws: UTSA-USA, DTSA-USA
• IT Security: Follow company policies on IT security and data protection. Protecting out IT infrastructure and data is essential to preventing unauthorized access, data breaches, and other security threats.
• Security Protocols: Adhere to company IT security protocols, including using secure networks, regularly updating passwords, and avoiding the use of unauthorized software or devices.
  • Relevant Laws: CISA-USA; NIS-EU
• Cybersecurity Awareness: Stay informed about cybersecurity threats and best practices. Participate in mandatory security training and report any suspicious activities or security incidents.
  • Relevant Laws: FISMA-USA; GDPR-EU
• Device Management: Use company devices for business purposes only and ensure they are protected with antivirus software and other security measures. Report lost or stolen devices immediately.
  • Relevant Laws: ECPA-USA; GDPR-EU
• Asset Utilization: Ensure responsible and efficient use of company assets. Misuse of company assets can lead to financial losses and damage our reputation.
• Policy Adherence: Follow all company policies and guidelines regarding the use and management of assets. Regularly review and stay updated on relevant policies.
  • Relevant Laws: SOX-USA; Companies Act-UK
• Reporting: Promptly report any misuse, damage, or loss of company assets. Cooperate with investigations and take corrective actions as needed.

By adhering to these principles and relevant regulatory laws, we ensure the proper use and protection of company assets, which supports our operational integrity and contributes to overall success.

 Data Protection

• Regulations: Adhere to laws such as the General Data Protection Regulation (GPDR), California Consumer Privacy Act(CCPA), and other relevant data protection regulations.
• Data Security: Implement robust technical and organizational measures to protect data against unauthorized access, loss, or alteration.
• Access Control: Limit access to personal and sensitive data to authorized personnel only.
• Encryption: Encrypt personal data both in transit and at rest.
• Data Minimization: Collect only the data that is necessary for the intended purpose and ensure it is kept no longer than required.
• Data Subject Rights: Ensure individuals’ rights to access, correct, delta, or restrict the processing of their personal data are upheld.
• Legal Compliance: Comply with data subject rights as outlined in the GDPR, CCPA, and other relevant laws or regulations.

Privacy Policy

• Transparency: Clearly communicate how personal data is collected, used, stored, and shared through a comprehensive privacy policy. 
• Information Disclosure: Provide details on the types of personal data collected, the purpose of collection, and how the data is used and shared.
• Consent: Obtain explicit consent from individuals before collecting their personal data, where required by law.
• Informed Consent: Ensure that individuals are fully informed about the data collection process and their rights before they consent.
• Data Sharing: Only share personal data with third parties when necessary and ensure these parties comply with applicable laws and data protection standards.
• Third-Party Agreements: Establish data protection agreements with third-party service providers to guarantee they adhere to the same standards of data protection.
• Data Breach Notification: Implement procedures to promptly notify affected individuals and relevant authorities in the event of a data breach.
• Legal Requirements: Follow the data breach notification requirements as specified in the GDPR, CCPA, and other applicable regulations.

Respect and Fair Treatment

We value and respect all individuals.

• Non-Discrimination: Treat all individuals with respect and fairness, without discrimination based on race, color, religion, sex, national origin, age, disability, or any other protected characteristic.
• Harassment-Free Environment: Foster a workplace free from harassment, bullying, and any form of abusive behavior.
• Anti-Harassment Policies: Implement and enforce policies that prohibit harassment and outline the procedures for reporting and addressing complaints.
• Inclusive Workplace: Promote diversity and inclusion within the organization by valuing and respecting differences among employees.
• Diversity Initiatives: Support initiatives and programs that encourage a diverse and inclusive work environment.

Customer Commitment

We are dedicated to serving our customers with excellence.

• Quality Service: Provide high-quality and reliable consulting services.
• Customer Privacy: Protect customer data and ensure their privacy is maintained.
• Relevant Laws: GDPR; CCPA; HIPAA
• Responsive Communication: Address customer concerns promptly and effectively.
• Fair Marketing Practices: Ensure that all marketing and advertising practices are truthful and not misleading.

Professional Conduct

• Conflict of Interest: Avoid situations where personal interests conflict with company interests. Disclose any potential conflicts to your manager.
• Confidentiality: Protect sensitive company information. Do not disclose confidential information to unauthorized persons.
• Fair Dealing: Engage in fair and honest business practices with customers, suppliers, and competitors.
• Anti-Corruption: Do not engage in bribery or any form of corrupt practices.

Corporate Social Responsibility

We strive to make a positive impact on society and the environment.

• Sustainability: Implement sustainable practices in our operations.
• Community Engagement: Support community development and social initiatives.
• Ethical Sourcing: Ensure that our suppliers adhere to ethical standards.

Reporting Violations and Concerns

We take violations of our code of conduct seriously and encourage all employees to report any concerns they may have. Your voice matters, and we are committed to maintaining a safe and respectful work environment for all.

• Whistleblower Protection: Our company is dedicated to protecting whistleblowers who come forward with reports of misconduct. We have established clear policies to safeguard whistleblowers from retaliation and ensure their confidentiality. Employees who report in good faith will not face any form of reprisal. If you witness or suspect any violation of our code of conduct, we urge you to speak up without fear.
• Safe Reporting: Anytime you have a question or concern or face a situation where the course of action is not clear, speaking with your direct supervisor is usually the first step. Prosight Solutions has zero tolerance for retaliation in any form.”

Enforcement and Accountability

At our organization, we are committed to upholding our code of conduct and ensuring accountability at all levels. Violations of our code will not be tolerated, and appropriate measures will be taken to address misconduct and promote a culture of integrity.

• Disciplinary Action: In the event of a confirmed violation of our code of conduct, we will take swift and decisive disciplinary action. The severity of the disciplinary measures will be determined based on the nature and impact of the violation, and may include, but are not limited to, verbal or written warnings, performance improvement plans, suspension, demotion, or termination of employment. Our disciplinary actions are designed to be fair, consistent, and in line with our organizational values. For more detail on our policies regarding disciplinary actions, please refer to our Disciplinary and Corrective Action Process
• Continuous Improvement: We are dedicated to continuous improvement in our enforcement mechanisms and accountability processes. Feedback from investigations, disciplinary actions, and employee suggestions will be used to enhance our code of conduct policies and procedures. We are committed to learning from past incidents and implementing changes that strengthen our ethical standards and foster a culture of compliance.

By holding all employees accountable for their actions and promoting a culture of responsibility, we aim to create a workplace where integrity, respect, and professionalism are upheld at all times.

Review and Updates

At our organization, we recognize the importance of regularly reviewing and updating our code of conduct to ensure it remains relevant, effective, and aligned with best practices and legal requirements. The review and update process is vital to maintaining a culture of integrity and ethical behavior within our workplace.

• Regular Review Process: Our code of conduct will be subject to regular reviews to assess its effectiveness in guiding employee behavior and promoting a positive work environment. The review process will involve key stakeholders, feedback from employees, compliance audits, industry trends, and legal developments will be considered during the review process.
• Updates and Revisions: As part of the review process, updates and revisions to the code of conduct may be necessary to address changes in our business operations, external regulations, or emerging ethical issues. Any updates or revisions to the code will be communicated to all employees to ensure awareness and understanding of the changes. Employees will be expected to familiarize themselves with the updated code and adhere to its provisions.
• Training and Communication: To support the implementation of any updates or revisions, training sessions and communication initiatives will be conducted to educate employees on the changes to the code of conduct. Training may include workshops, online modules, or informational sessions to ensure that employees understand their responsibilities and obligations under the updated code.
• Feedback Mechanisms: We value the feedback of our employees in improving our code of conduct. We encourage employees to provide suggestions, raise concerns, or report any inconsistencies they may identify in the code. Feedback mechanisms, such as suggestion boxes, anonymous surveys, or open-door policies, will be available to facilitate employee input and engagement in the review and update process.
• Compliance Monitoring: Continuous monitoring and evaluation of compliance with the code of conduct will be conducted to ensure that employees are following the established guidelines and standards. Compliance audits, reporting mechanisms, and regular assessments will be used to measure the effectiveness of the code and address any gaps or areas of non-compliance.

Closing remarks from the Prosight Solutions team

It is our privilege to lead Prosight Solutions with Integrity. The mission of our team is to inspire, guide and enable us all to grow Prosight Solutions´ business by doing the right thing, the right way. We minimize risks to our business while embracing opportunities to deliver excellence for our customers and colleagues.