VENZO Supplier Code of Conduct (January 2025)

Table of Contents

  1. Preamble
  2. Our valantic values 
  3. Human rights, labour and social standards
  4. Environmental protection
  5. Dealing with information
  6. Management System and Information Security
  7. Quality control
  8. Anticorruption
  9. Antitrust law
  10. Prevention of money laundering 
  11. Avoidance of conflicts of interest
  12. IT Continuity and Risk Management 
  13. Subcontractors
  14. Implementation of requirements 
  15. Review
  16. Questions and contact persons 

1. Preamble

1.1 This Code of Conduct applies to Suppliers having business relationships with VENZO A/S and its affiliated companies (the “VENZO Group Entities”). The Code applies to all actions or omissions of Suppliers related to the business of the VENZO Group Entities.

1.2 Should national, local and/or international regulations and laws be applicable and be stricter than the rules of this Code of Conduct, these stricter regulations and laws apply and prevail. All Suppliers must always inform themselves in advance about the relevant regulations they shall observe within the countries in which they operate and must comply with their requirements when performing their activities for the VENZO Group Entities.

1.3 This Code of Conduct shall apply to all services and deliveries from Suppliers to the VENZO Group Entities. Suppliers are required to fulfill the principles and requirements of the Code of Conduct and shall instruct and oblige their subcontractors to comply with the standards and regulations set out in there.

1.4 Our objective: Being number one in what we do

The VENZO Group Entities offer software and digital process solutions as well as strategic consulting services in order for customers to achieve profitable advantages. With such offer, we master the central challenges of digitalization with an exceptional, flexible and elementary organizational structure as well as with operational excellence. Our claim is to break through established ways of thinking by combining technological expertise with industry know-how. In this way, we want to be number 1 in the market in the fields in which we operate.

How business success is achieved at VENZO is just as important to us as the business success itself. This Code of Conduct reflect our values and is our orientation framework for such values. It combines two important aspects: the requirement to comply with the laws and the specific requirements for integrity.

We seek relationships with Suppliers working in accordance with the guidelines listed in this Code of Conduct. Suppliers to the VENZO Group Entities are expected to comply with the guidelines, to make reasonable efforts to disclose information relevant to these guidelines and to implement similar requirements in their supply base and business relationships.

The VENZO Group Entities may disqualify any potential Supplier or terminate any relationship with a Supplier that has failed to comply with these guidelines.

2. Our valantic values

PARTNERSHIP – Excellent IT specialists, managers and entrepreneurs have joined forces in the VENZO Group. We form a strong unit with our partners. We value long-term relationships characterised by trust, responsibility and respect.

ENTREPRENEURSHIP – The image of the strong entrepreneur is decisive for our actions. A real entrepreneur takes responsible risks and has the absolute will to lead his or her idea to success.

OPERATIONAL EXCELLENCE – For us, excellence means inspiring the customer with our solutions. This requires a sharp mind and the openness to listen and to look closely, as well as curiosity and a passion to understand things from scratch.

FAIRNESS – We are committed to the culture of fairness towards our colleagues, our customers, our investors and our environment.

ONE FIRM – We form an organisation in the sense of a “one-firm” partnership in which we share our common values: all VENZO Group Entities share and live these values and promote the goals and culture of the VENZO Group.

Suppliers shall work according to these values throughout the entire cooperation.

3. Human rights, labour and social standards

Suppliers shall observe applicable laws, internationally recognized conventions such as those of the International Labor Organization (ILO) or of the United Nations (UN), and all other binding regulations and industrial standards as a minimum standard.

As an internationally active group of companies, the VENZO Group Entities act in accordance with universally recognized principles of human rights and expect their Suppliers to implement the following standards:

3.1 Respect the rights to equal opportunities and to non-discrimination – Equal treatment of all employees is a fundamental principle of our corporate policy. Any discrimination or difference in treatment shall be generally prohibited, in particular in the course of hiring, employment or termination of employment. Applicants and employees may not be treated differently, given preferential treatment, excluded or otherwise disadvantaged on the basis of gender, skin color, race, religion, age, ethnic, national or social origin, disability, sexual orientation, political conviction or other personal circumstances, nor on the basis of other aspects from which a discrimination may be presumed.

3.2 Prohibit all forms of forced labor – In accordance with ILO Labor Standards, Suppliers shall reject all forms of forced and compulsory labor and servitude and slave labor of any kind in its business activities. Supplier’s employees must not be subject to any regulation or practice that restrict their personal freedom of movement and freedom to engage in other employment or that otherwise coerces them into involuntary labor.

3.3 Prohibit the use of child labor – The employment of young persons shall conform with ILO Conventions 138 and 182 and comply with all applicable laws and regulations concerning age, hours, compensation, health and safety.

3.4 Respect the worker’s rights of freedom of association and collective bargaining – The right of employees to form, join or withdraw from, and act on behalf of associations or organizations of their own discretion for the purpose of promoting and protecting their interests shall be respected and the exercise of the right protected. The same applies to the right to collective bargaining. No negative consequences for employment or employees and their representatives may be associated with the permitted exercise of rights. Employees must also be granted the right to elect employee representatives if national laws restrict freedom of association. Employee representatives must be allowed access to employees at the place of employment.

3.5 Fair pay and benefits according to local market conditions – Suppliers shall comply with all applicable laws on remuneration such as laws on minimum wage or overtime. Employees must be provided with all benefits required by law. Wage deductions as a punitive measure are prohibited. Suppliers shall ensure that employees receive clear, detailed, and regular written information on the components of their remuneration.

3.6 Providing healthy living and working conditions – Safety and health must be ensured at the workplace and in the working environment of employees. Framework conditions and occupational health and safety measures must be established to help prevent accidents and injuries during employment. In addition, Suppliers shall provide regular trainings on possible health hazards and shall instruct employees on the measures and behavior that can be taken to achieve and ensure the required level of safety.

3.7 Protection against eviction and land confiscation – Suppliers undertake not to conduct unlawful forced evictions. Furthermore, they undertake not to unlawfully withdraw land, forests and waters through acquisition, development or other utilization.

4. Environmental protection

Acting in an environmentally conscious manner is a corporate duty, but above all an important prerequisite for preserving natural resources and thus ensuring our survival in the long term. Not only our services are ecologically sustainable, but also our actions throughout the entire value creation process. Suppliers must promote and demand environmental awareness among their employees and implement actions to minimise the impact of their activities on natural resources and thus also the negative impact on our environment.

To be able to warranty an environmental compliance corresponding to the VENZO Group Entities’ values, Suppliers shall implement the following standards in their own organisation and ensure that the respective applicable legal environmental protection regulations and laws are respected.

4.1 Carbon footprint

4.1.1 Suppliers shall strive to reduce their Carbon footprint as far as possible within their business operations.

4.1.2 Supplier’s employees shall be encouraged to use public transport or carpool as often as possible. The Suppliers shall focus their efforts on promoting environmentally friendly employee mobility, as mobility is still the biggest influencing factor on the CO2 – balance.

4.1.3 Suppliers shall increase the energy efficiency of their offices by using offices with high energy efficiency and/or switching to green electricity. Where this is not possible, all efforts need to be taken to reduce the energy consumption of the facilities as much as possible.

4.2 Business travel

4.2.1 Suppliers shall significantly limit the frequency of business travel, especially by air or car, in order to reduce the strain on natural resources and to reduce their corporate carbon emissions.

4.2.2 Whenever reasonable and possible, Suppliers shall hold virtual meetings especially with clients, suppliers, colleagues and applicants, in order to avoid business trips.

4.2.3 Whenever business travel is necessary, Suppliers shall encourage their employees to use public transport or carpool as often as possible instead of travelling via aircraft or car unless it is strictly necessary.

4.3 Waste prevention and waste management

4.3.1 Suppliers shall promote sustainable consumption and discourage wastefulness at the workplace. Suppliers shall encourage their employees to observe waste prevention with regard to measures leading to material recycling and to the reduction of the amount of generated waste.

4.3.2 Suppliers shall support the effective collection and recycling of waste at the workplace. Indeed, the proper management of waste saves the environment from the toxic effects of inorganic and biodegradable elements present in waste, as mismanagement of waste can result in air and water contamination, as well as soil erosion.

5. Dealing with information

Data security is essential to the VENZO Group Entities as digital solutions, consulting and software companies. It is therefore important to the VENZO Group Entities that Suppliers protect all data – personal or not – belonging to companies, customers, business partners, shareholders and employees, from unauthorised access, unauthorised and improper use, loss and premature destruction, this by using all available suitable and appropriate technical and organisational measures. This shall be achieved in compliance with the respective legal framework and national laws as well as internal guidelines and regulations.

In order to be able to guarantee protection corresponding to the VENZO Group Entities’ values,

Suppliers shall:

  • Respect the privacy of employees, contractors, workers, customers and other persons as soon as Suppliers have access to their personal data, by complying with local and international laws as well as contractual provisions.

  • Comply with cross-border data transfer requirements in accordance with applicable regulations, including data transfer agreements with subcontractors.

  • Ensure that the data protection requirements resulting from the relationship with the respective VENZO Group Entity are transferred to their subcontractors and that the same obligations are imposed on such subcontractors.

  • Ensure that appropriate technical and organizational measures are implemented in order for Suppliers to sort all data received according to the appropriate categories established by law.

  • Ensure that management and staff have appropriate knowledge and skills in data protection
    management.

  • Report any suspected or actual breach of confidentiality and integrity of personal data to the competent authority and the relevant VENZO Group Entity contact person.

  • Not use or transfer or grant access to third parties to the information received from the VENZO Group Entities without prior written permission from the respective VENZO Group Entity.

6. Management System and Information Security

VENZO expects Suppliers to implement management systems that support compliance with applicable laws in their businesses and promote continuous improvement with respect to the expectations set forth in this Code of Conduct. This includes the following:

Legal and other contractual requirements – Suppliers shall comply with all applicable laws, regulations and contractual agreements and generally accepted standards.

Commitment and responsibility – Suppliers shall meet the expectations set forth in this Code of Conduct by providing appropriate resources for this purpose within their companies.

Risk Management – Suppliers shall implement processes to identify, determine and monitor risks in all areas addressed in this Code of Conduct and any applicable legal requirements.

Documentation – Suppliers shall provide adequate documentation to demonstrate compliance with the principles and values of this Code of Conduct.

Information Security – The VENZO Group Entities expect Suppliers to systematically audit their operations with appropriate information security practices to protect data and systems in order to improve and maintain business continuity and also to meet the standards pursued by the VENZO Group Entities. In order to ensure protection in line with the VENZO Group Entities values,

Suppliers shall:

  • Define strategies, goals and formal processes related to optimising data protection at the top management level.
  • Develop suitable processes and standards in order to maintain data confidentiality, integrity and availability.
  • Optimise incident response and risk management through monitoring and process implementation. Upon the occurrence of any of the events prohibited under this Code of Conduct, Suppliers shall contact the relevant regulatory authorities and the VENZO Group Entities as required by the circumstances.
  • Provide evidence of their efforts to ensure compliance with information security standards through appropriate certification or accreditation (for example ISO 27001).
  • Ensure that management and staff have appropriate knowledge and skills in data protection management.

7. Quality control

Suppliers must comply with the specifications agreed in the respective contract, order or any other contractual agreement. Suppliers must meet certain minimum quality requirements and comply with the relevant statutory regulations when supplying and offering products or services to the VENZO Group Entities. The VENZO Group Entities expect Suppliers to set up the necessary controls for this purpose at recurring intervals in order to ensure compliance with the quality requirements. This includes especially the following measures:

  • Establishment and fulfilment of quality requirements to ensure the integrity of the goods and services provided.
  • Continuous optimisation of process quality and efficiency.
  • Notification to the responsible contact persons of the VENZO Group Entities regarding the intended changes to specifications, methods, materials, manufacturing and delivery processes as well as production locations and the effects of these on the cooperation with the VENZO Group Entities.
  • Support of the responsible contact persons of the VENZO Group Entities or an authorised representative in the performance of quality audits and the evaluation of facilities, systems and documents in connection with the goods and services provided.

8. Anticorruption

8.1 Corruption generally means that someone demands, accepts, offers or grants personal benefits in connection with a business activity or public activity. Such benefits may take the form of a gift, invitation or other favour, and may benefit the individual or a third party, such as a family member. Since corruption usually distorts competition and endangers the integrity of state action when a public official is involved, it is prohibited by law in almost all countries.

8.2 Therefore, any form of corruption, including so-called facilitation payments, is prohibited at the VENZO Group Entities and for any Supplier working with any VENZO Group Entity. Facilitation payments are payments to a public official that are intended to initiate or accelerate a routine official act for which a claim exists.

8.3 In practice, gifts and invitations to employees, business partners or public officials are the most common type of benefit. The granting or acceptance of such benefits is only permitted if the benefits are appropriate. In particular, the acceptance of a reasonable benefit may not influence the decision-making of the employee, nor may the reasonable benefit give the impression that it influences the decision-making. Appropriateness is determined primarily by the financial value of the benefit, the function and position of the recipient, the timing of negotiations and decision-making processes, and the business practices of the country in question. Donations to related third parties, such as family members, are only permitted in extremely limited exceptional cases. Particularly strict legal restrictions apply to donations to public officials. Public officials do not only include all persons who exercise a sovereign office or function, such as representatives of public authorities. University professors and representatives of state-owned companies can also be considered public officials. Grants of any kind should therefore be made to the extent permitted by law.

9. Antitrust law

From our point of view, fair competition creates incentives for innovation and high product quality for the benefit of consumers; therefore, the VENZO Group Entities also promote fair competition and the observance of antitrust and competition law by their Suppliers. The competition rules do not only apply to formal agreements; they apply equally to loose, informal arrangements, confidential arrangements and “gentlemen’s agreements”.

10. Prevention of money laundering and terrorist financing

We pursue the strict goal of preventing and combating money laundering and terrorist financing. Money laundering means that illegally generated income is concealed and introduced into the legal economic and financial cycle. Therefore, the VENZO Group Entities comply with applicable laws on the prevention of money laundering and terrorist financing. We are particularly careful to ensure that the VENZO Group Entities are not misused for illegal purposes. Every Supplier is requested to critically observe his business fields and to react to the first suspicious facts. Payments are to be made in such a way that they are compatible with tax law as well as with the regulations of money laundering and of the prevention of corruption. All transactions that have the appearance of illegality should be rejected.

11. Avoidance of conflicts of interest

Actual conflicts of interest and even the appearance of a conflict of interest must be avoided by the Supplier. Conflicts of interest that arise in connection with the business activity must be reported by Suppliers to the respective VENZO Group Entity without being requested to do so. All Suppliers shall disclose actual or potential conflicts of interest to avoid possible negative consequences for the VENZO Group Entities.

12. IT Continuity and Risk Management

12.1 IT Readiness

IT readiness should be planned, implemented, maintained, and tested based on business continuity goals and IT continuity requirements. IT readiness to support business continuity is an important part of business continuity management and information security management to ensure that organizational goals can continue to be met during operational disruptions. The Sub-contractor must as a minimum abide to the NIS2 technical requirements and GDPR. Proportional technical measures must be incorporated to ensure security.

12.2 Screening Process

VENZO’s screening process will and that of the Sub-contractors supply chain should include stricter access restrictions if the screening cannot be completed before work on the delivery contract begins.

12.3 Sub-contractors and Risk Assessment

The Sub-contractor must have an overview of their supply chain who contribute to the delivery of services and conduct reasonable and proportional risk assessments of the supply chain. The Sub-contractor must have guidelines at the delivery of services indicating:

  • The types of customer information the Sub-contractor shares with its supply chain.
  • What the Sub-contractor has access to (e.g., IT infrastructure, networks, and physical environments).

Any entities in the supply chain to deliver services must be supported by a contract specifying information security requirements. The information security requirements must be proportional to the services the entity delivers to the provider and, thus, the customer.

The Sub-contractor must regularly, conduct risk assessments of critical entities in the supply chain, which includes:

  • The information handled by the entity.
  • Security measures used to protect critical and sensitive information.
  • Business significance if compromised.

12.4 SKI requirements

In relation to customer contracts based on Staten og Kommunernes Indkøbsservice (“SKI”) framework agreements, all security measures from SKI “sikkerhedsbilag” shall apply to the Sub-contractor and its supply chain, to the extent set out in VENZO’s agreement with the customer. VENZO reserves the right to perform audits on the SKI requirements yearly.

13. Subcontractors

Suppliers shall ensure compliance with these standards also for all their subcontractors and partners. We expect our Suppliers to identify risks within their supply chains and to take appropriate measures.

14. Implementation of requirements

14.1 In the event of violations or suspected violations by the Supplier within its company or within its supply chain, the Supplier shall inform the respective VENZO Group Entity immediately about the identified violations and risks as well as the measures taken.

14.2 If a violation of the regulations of this Code of Conduct is identified, we may terminate the business relationship and cancel all contracts concluded with the Supplier and claim damages. As far as reasonable and at our discretion, we will however seek discussion with the Supplier before terminating the cooperation, so that the Supplier may end the violation via appropriate measures and eliminate adverse effects already occurred.

14.2.1 We may engage in due diligence and audits at any time to confirm a Supplier’s conformance to the standards defined in this Code of Conduct, including on-site assessments of facilities, use of questionnaires, review of available information or other necessary measures and we may implement regular training programs.

15. Review

VENZO A/S (Legal and Compliance Department) will regularly review this Code of Conduct and make changes where necessary and appropriate. It supersedes all previous versions. This VENZO Suppliers Code of Conduct was approved by the Director Legal of VENZO.

16. Questions and contact persons

Employees of the Supplier should contact their own compliance/legal department to resolve internal ethics and compliance concerns. In case a concern might affect VENZO as the contract partner of the Supplier, VENZO Legal and Compliance Department must be informed immediately at:

VENZO A/S, General Counsel, legal@venzo.com,

M +45 33110085, Hejrevej 34D, DK-2400 Copenhagen NV.

In case employees of suppliers believe that a VENZO employee or anyone acting on behalf of VENZO has engaged in illegal or otherwise improper conduct, he or she should report the matter promptly to VENZO at: https://venzo.whistlesystem.com/login/MvCGtFhmYVb-QpniYoK

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