Code of Conduct

Digital Forge has long been recognized as one of the world’s most ethical companies. For more than one hundred years, we’ve repeatedly reinvented ourselves to meet new challenges. What always has remained unchanged is our unwavering commitment to integrity.  Our values serve as a solid foundation for the business choices we make.

Code of Conduct

Integrity and compliance are vital to Digital Forge’s success – and yours. Our integrity, reputation and brand are in your hands, and we rely on you to protect them!  No matter where your workplace is – whether you work with Digital Forge employees, clients, partners, suppliers or other parties in person, over the phone, online or by any other means –you must follow our values and Digital Forge corporate directives, such as Digital Forge policies and guidelines as well as comply with all laws and regulations that apply to Digital Forge’s business.

Code of Conduct

Always use good judgment in your work. If you have questions about interpreting our values, laws, and regulations applicable to Digital Forge, don’t guess. Ask for help. It’s your responsibility to consult the Leadership at Digital Forge. If you violate corporate directives or the law, Digital Forge may take any action regarding your employment, including termination of employment, subject to applicable law. Failing to comply with laws could also result in fines, lawsuits, loss of business privileges and, in some cases, imprisonment.

Code of Conduct

Digital Forge has extensive assets of great value. They are critical to Digital Forge’s success in the marketplace, and we rely on you to protect them. Digital Forge’s assets include, for example, physical assets and systems that Digital Forge makes available to Digital Forge staff for work, Digital Forge facilities and premises, Digital Forge’s proprietary and confidential information and Digital Forge intellectual property. Our business may also require us to access and use assets belonging to others, such as their proprietary and confidential information, intellectual property, systems, data or tools.

Code of Conduct

You must use Digital Forge assets, including Digital Forge premises and facilities and physical assets and systems, only for Digital Forge’s legitimate business purposes. Digital Forge’s physical assets and systems include devices such as laptops, tablets and smartphones, information and communication systems, and connections to the Internet. Incidental personal use of physical assets and systems is permitted, however, if it is limited in duration, does not violate company policies, and does not affect your productivity or the productivity of others.

Do not use Digital Forge assets in ways that violate the law, that are inconsistent with Digital Forge’s business interests or to visit Internet sites that feature sexual content or gambling, or that advocate intolerance of others. Use assets belonging to others, including clients, only to the extent permitted by the other party; make sure you fully understand and follow the other party’s terms and agreements as well as any laws that may restrict access to the assets based on privacy, citizenship or other requirements.”

Code of Conduct

Digital Forge’s proprietary information and intellectual property are Digital Forge assets. They are the result of the hard work and innovation of many Digital Forge team members, and they give Digital Forge a competitive advantage. Most Digital Forge proprietary information is confidential; often, such information is also subject to copyright, patent, trademark, trade secret or other intellectual property or legal rights. You may not share Digital Forge confidential information with, or accept confidential information from, another party unless Senior Management has approved it and Digital Forge and the other party have signed a confidentiality or other suitable agreement approved by Digital Forge Legal Counsel. Improper disclosure of Digital Forge proprietary or confidential information could threaten Digital Forge’s competitive advantage. Follow all Digital Forge safeguards for protecting that information and share it only as authorized by Digital Forge.

Code of Conduct

Third parties, like our clients, trust Digital Forge with their data and other assets, and we rely on you to protect them – as well as Digital Forge’s own data and assets. Violating Digital Forge’s information security policies puts Digital Forge assets, and assets belonging to others, like client data, at risk. Even well-intentioned actions, such as creating workarounds and shortcuts to improve service delivery or downloading unapproved third-party software, can violate Digital Forge and client security policies and result in IT or data security breaches.

Code of Conduct

If you are aware of or suspect an IT or data security issue or incident, or any loss of assets, including data, belonging to Digital Forge or others, report it immediately by contacting Digital Forge.

To support our commitment, Digital Forge Cyber has adopted an Information Security Management System (ISMS), which includes an approach to information security risk management. The ISMS program shall identify the need regarding information security requirements and an operational security framework within all aspects of the organization. Digital Forge will adopt the standards and framework contained within the HITRUST CSF to ensure our ISMS program is effective and reliable. The HITRUST CSF, developed by the HITRUST Alliance, incorporates many regulatory and compliance planning such as: NIST, ISO {27001, 27002, and 27799), PCI DSS, COBIT, HITECH and HIPAA.

Employees or clients that have any questions or concerns about Digital Forge Code of Conduct or any other related question should contact the compliance department. Digital Forge Cyber incorporates a non-retaliation policy, for reports that are made in good faith, but self-reporting may not clear someone of misdeed.

Whether you are selling, buying or representing Digital Forge in any other capacity, you must be ethical and lawful in your business dealings. Your actions can directly affect Digital Forge’s competitiveness, reputation and compliance with applicable laws.

Digital Forge regularly works with other organizations – subcontractors, suppliers, consultants, agents, Digital Forge partners and competitors – and frequently has multiple relationships with these companies. You must understand these relationships and act in accordance with our guidelines.

Working with other parties can present risks – Digital Forge can be held liable for the misconduct of others, such as agents, consultants or Digital Forge partners. For example, if we know or have reason to believe a partner or client will offer or accept a bribe or kickback, Digital Forge may be held accountable, even if Digital Forge does not authorize or condone it. We require other parties with whom we interact to comply with many Digital Forge guidelines and meet our high standards of integrity in their work for us. If you are aware of or suspect another party is acting unethically or illegally, immediately report your concern to Digital Forge Senior Leadership, ore Digital Forge Corporate Counsel.

Digital Forge engages with government-owned or controlled entities in many ways – for example, as Digital Forge clients, suppliers, consultants or Digital Forge partners.  Government entities are government agencies, departments, branches, instrumentalities and public enterprises, whether regional, national, or local, as well as:

• Government-owned or -controlled schools, hospitals, utilities and other organizations that provide public services;
• Public international organizations, such as the United Nations or World Health Organization; and
• Entities that procure under public procurement laws and regulations.

State-owned enterprises can be any other type of entity, even those that are privately held or publicly traded, that are owned, controlled, organized, or sponsored by a government official. A government official is an officer or employee of a government-owned or controlled entity as well as any private individuals or entities acting in an official capacity on behalf of one.

Dealing with government-owned or controlled entities, their representatives and government officials or their family members raises unique business and compliance issues, and you must follow Digital Forge’s established processes and controls to address them. Before you engage in any business activity, including marketing or sales activities, it is your responsibility to determine if the party you are dealing with is a government-owned or controlled entity or a government official (or a family member of one).

Digital Forge works with many suppliers worldwide, purchasing both for its internal use and in support of client engagements. In general, all purchases from suppliers must be negotiated, signed, and managed by Digital Forge Global Procurement, unless a delegation is in place.

In deciding among competing suppliers, whether you are a procurement professional, or a businessperson involved in a purchasing decision, we weigh the facts impartially to determine the best supplier, regardless of whether it is a large or small purchase. You must not exert or attempt to exert influence to obtain special treatment for a particular supplier. Even appearing to do so can undermine the integrity of our established procedures.

As a general principle, Digital Forge does not buy or sell on a reciprocity basis. To maintain the high standards of our products, we should base our purchasing decisions on quality, price, and supplier reliability. Also, reciprocity may be unlawful in some situations. Of course, Digital Forge clients can also be suppliers to Digital Forge, and it can be appropriate for Digital Forge to consider its other relationships with a supplier in some cases. For example, when Digital Forge divests part of its business, Digital Forge often buys products in the divested business area from the acquiring company.

Competition laws, also known as monopoly, antitrust, fair trade, or cartel laws, are intended to prevent interference with the functioning of a competitive market system and exist in almost all countries where we do business. Prohibited conduct may include colluding with others to fix prices or divide territories, illegally monopolizing an industry or unlawfully abusing a dominant position. Contacts with competitors require extra care. Avoid discussion of or collaboration on proprietary or confidential information, including pricing policies, contract terms, costs, inventories, marketing and product plans, market surveys and studies, production plans and capabilities, and allocating clients or territories. Such discussions may be illegal.

If a competitor raises a prohibited subject, stop the conversation immediately and inform the competitor that you will not discuss these matters. If the competitor continues to discuss the prohibited subject, leave the meeting and immediately report the incident to Digital Forge.

Collaborating with competitors creates risk. It is your responsibility to understand the rules that apply to such activities and to avoid prohibited subjects. Obtain prior approval of your manager and seek advice from Digital Forge before collaborating with competitors, including competing Digital Forge Partners.

Digital Forge sells its products and services on their merits. You should compete vigorously for business, but always ethically and in compliance with our policies and the law, no matter how competitive the environment. Never make false or misleading statements about Digital Forge and its products and services or other companies, including competitors and their products and services. Always be accurate, complete and honest. Be sure all comparisons to competitors are substantiated. In certain countries, comparative advertising is prohibited or limited.

Code of Conduct

In today’s highly competitive environment, it is critical that Digital Forge employees know and understand our competitors’ offerings. Digital Forge may acquire information about individuals or organizations, including competitors, that we do business or engage with. Digital Forge properly gathers this kind of information from legitimate sources for legitimate purposes, including extending credit, evaluating suppliers and evaluating our own products, services and methods. Do not engage in or facilitate any improper or illegal practices, such as wiretapping, surveillance, hacking, bribery, theft, trespassing, misuse of social platforms or pretexting, to gather intelligence or obtain trade secrets or confidential or sensitive information. Do not hire or pay a competitor’s employees to obtain such information. Do not accept or use information if you have reason to believe it may have been obtained improperly or illegally. Treat information about other organizations and individuals with sensitivity and discretion. Use it in the proper context and consistently with the purpose for which you were provided access. Share it only with those who have a legitimate need to know. Whenever possible, aggregate or anonymize information to avoid disclosing the identity of organizations or individuals.”

Code of Conduct

Digital Forge prohibits bribery and kickbacks of any kind. Never offer or give anyone, or accept from anyone, anything of value that is, or could be viewed as, a bribe or kickback or an attempt to influence that person’s or entity’s relationship with Digital Forge. We expect everyone we interact with – including suppliers, Digital Forge Partners, resellers, contractors, and consultants – not to accept or offer bribes or kickbacks.

Code of Conduct

Anti-corruption laws around the world make bribery a crime. Some laws, like the U.S. Foreign Corrupt Practices Act and Brazil’s Clean Company Act, focus on bribery of government officials. Others, like the UK Bribery Act, also prohibit bribery of employees of commercial entities. Anti-bribery laws generally prohibit giving “anything of value” to a government official or employees of a government entity or in some countries, a commercial entity to obtain or retain business or some other benefit.

Code of Conduct

Any contact with government personnel intended to influence legislation, policies or government action may be considered lobbying, including submissions in response to government requests for comments on public policy matters. Under some laws, lobbying even includes normal marketing, procurement and sales activities directed to government customers. You are responsible for knowing and complying with all relevant lobbying and associated gift laws and reporting requirements. You must obtain prior approval from Government and Regulatory Affairs to lobby or to authorize anyone else – like a consultant, agent, trade association or Digital Forge Business Partner – to lobby on Digital Forge’s behalf.

Digital Forge, its subsidiaries and affiliates, and their agents are prohibited from complying with or supporting a foreign country’s boycott of a country that is friendly to the United States. Digital Forge is required to report promptly to the U.S. Government any request to support a boycott or to furnish information regarding a boycott.”

A conflict of interest occurs when you advance a personal interest at the expense of Digital Forge’s interests. Remember: a personal interest can be a direct benefit to you or a benefit to a family member or close friend. It is up to you to avoid any activity that creates, or appears to create, a conflict between your personal interests and the interests of Digital Forge. Disclose to your manager any actual or potential conflict of interest and discuss possible ways to mitigate or eliminate the conflict. Your primary responsibility is to Digital Forge, and any conflict must be resolved in Digital Forge’s favor.

Supplying Digital Forge, you may not be a supplier to Digital Forge or work for a supplier to Digital Forge in any capacity

As an employee, a representative, a consultant or a member of its board of directors or an advisory board or council – unless you obtain the prior approval of senior management and Digital Forge Senior Leadership.

You may not accept money or other benefits of any kind for any advice or services you may provide to a supplier in connection with its business with Digital Forge. You may, however, accept promotional discounts generally offered to the public by transportation companies, hotels, auto rental agencies and restaurants.

Code of Conduct

Aiding a competitor is an obvious conflict of interest, and you may not work for a competitor of Digital Forge in any capacity – as an employee, a representative, a consultant or a member of its board of directors or an advisory board or council.

Code of Conduct

Outside the office, you may wish to engage in activities that generally relate to technology, business advice or other products or services Digital Forge offers its clients but be careful that these activities do not conflict with Digital Forge’s business interests – which would be prohibited. Because Digital Forge is rapidly expanding into new lines of business and areas of interest, the lines of acceptable activity are continually being redrawn. It is your responsibility to consult, in advance and on a periodic basis, with your manager to determine whether your planned activities compete with any of Digital Forge’s actual or potential businesses.

Code of Conduct

You may not have financial interests in any organizations or companies (whether public or private, large or closely held) with which Digital Forge does business, such as suppliers, clients, competitors or Digital Forge Business Partners, if that interest could create or give the appearance of a conflict of interest with Digital Forge. You must consult with your manager if you think any of your investments raise conflict of interest issues. Do not evade these investment restrictions by acting indirectly through anyone else.

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Digital Forge understands employees may have interests in developing intellectual property outside of Digital Forge.  It is your responsibility to maintain Digital Forge confidential and proprietary information and avoid conflicts of interest at all times.

Code of Conduct

Close ties to others working in the industry – a spouse, domestic partner, family member, close friend and the like – present special security, regulatory and confidentiality concerns. Such a personal relationship might result in the inadvertent compromise of Digital Forge’s business interests. Disclose to your manager any such relationship. Frequently, periodic reminders and careful attention to avoiding inadvertent disclosure of Digital Forge or another party’s assets will help minimize risks to Digital Forge’s interests. However, in some instances, a change in your job responsibilities or those of the other person involved may be necessary.

Code of Conduct

During your employment with Digital Forge, you may become aware of information about Digital Forge or other companies that has not been made public. Using or disclosing this inside information for your financial or other personal benefit is unethical and against the law. Inside information is material information that is not available to the general public that could influence a reasonable investor to buy, sell or hold a company’s securities. Information can be material even if it would have only a small impact on the price of the securities.

Violation of these laws may result in civil and criminal penalties, including fines and jail sentences. Digital Forge will not tolerate the improper use of inside information. These prohibitions apply anywhere in the world where we do business. The rules are simple: do not improperly use or disclose inside information; and do not evade these guidelines by acting through anyone else or by giving inside information to others for their use, even if you will not financially benefit from it. If you have any questions about what you can or cannot do, consult Digital Forge Senior Leadership or Corporate Counsel.

Code of Conduct

As a good corporate citizen, Digital Forge encourages employees to participate in their communities. Speak with your manager to determine the proper approach if you think your personal activities could create a conflict of interest.

Public Service; Your participation in public service may create a conflict of interest for Digital Forge. As a board or committee member of a civic organization, for example, you may be confronted with a decision involving Digital Forge, such as a decision to purchase Digital Forge products or services, and your interest in Digital Forge and your obligation to the civic organization might pull you in opposite directions. Make it clear that you are a Digital Forge employee to avoid any perception that you concealed your association with Digital Forge and consider abstaining from participating in any decision-making on matters involving Digital Forge. Seek advice from the civic organization’s lawyer or from Senior Leadership or Corporate Counsel as needed.

Political Contributions and Endorsements; Digital Forge will not endorse, support or make contributions or payments to any political parties or candidates, including through political action committees, campaign funds, trade or industry associations or similar organizations. For example, Digital Forge will not purchase tickets, pay fees or reimburse expenses for any event where any portion of the funds will be used for election campaigns. Do not make any political contribution as a representative of Digital Forge, and do not use work time or Digital Forge assets in support of political parties or candidates – using work time or assets would be the equivalent of a contribution. Digital Forge will not reimburse you for any personal contributions you make.

Political Office; Digital Forge will not pay you for time spent running for public office, serving as an elected official or campaigning for a political candidate, unless required by law. Consult with Government and Regulatory Affairs before accepting a political appointment or running for government office at any level.”

Code of Conduct