Code of Ethics - Glartek Code of Ethics - Glartek

Glartek Documentation

Code of Ethics

Introduction and Purpose

GLARTEK – Technology Solutions, S.A. (“Glartek”) is committed to the highest standards of integrity, transparency, and accountability. Our Code of Ethics guides all employees and partners to conduct business honestly, comply with laws and regulations, and foster trust with customers and stakeholders.

By publishing and enforcing this Code, Glartek demonstrates our dedication to ethical conduct as a foundation of sustainable success.

Company and Values

Glartek, a VC-backed company founded in 2017, develops EHS Connected Worker solutions for the industrial sector. Our core mission is to help our customers increase safety, ensure quality, and deliver exceptional operational performance. We achieve this with Connected Worker technologies, integrating AI, AR, and IoT, providing visibility, and optimization tools, and offering reassurance throughout the work lifecycle: before, during, and after work execution. Glartek’s mobile-first, scalable platform supports leading companies in Safety (e.g., risk management and control of work), Quality (e.g., audits and inspections), and Learning and Development (e.g., skills and training management), as well as Sustainability and real-time Communication & Collaboration. Our customer base includes large asset-intensive organizations like EDP and global manufacturers such as International Paper. To learn more about Glartek and our solutions, please visit www.glartek.com.

These values are reflected in our culture, solutions, and every interaction – with customers, colleagues, and partners:

We solve valuable human-centered challenges.
We make it simple, innovative and scalable.
We own and perform as a team, fast.
We share the pain and jointly celebrate success.
We exceed customers’ expectations.

Scope and Applicability

This Code applies to all Glartek directors, officers, employees, contractors, and agents worldwide. It covers every aspect of our business, including sales, procurement, finance, and partnerships. All individuals and third parties acting on Glartek’s behalf must understand and adhere to these standards. Local laws and customs are respected, but in all cases this Code sets the minimum standard of behaviour. Violations may result in disciplinary action, up to termination and legal consequences. Customers and partners can rely on Glartek to enforce these standards throughout our operations.

Principles

Glartek’s conduct is guided by fundamental principles of honesty, integrity, fairness, accountability and transparency. All individuals are expected to:

Comply with Laws: Follow applicable laws, regulations and internal policies in every country where we operate, including anti-corruption and AML laws.
Act with Integrity: Be honest and ethical in all dealings; fulfil commitments, honour contracts, and speak up if something seems wrong.
Advocate for Fairness: Treat colleagues, customers, suppliers and competitors with fairness and without discrimination. Protect confidential information and intellectual property.
Be Accountable: Take responsibility for actions and decisions; maintain accurate, complete records; accept oversight and evaluation.
Promote Transparency: Make business decisions openly, document transactions clearly, and avoid hidden or misleading arrangements.

These principles set the tone for ethical behaviour and guide the specific policies below.

Employees' Relationship

At Glartek, we value diverse perspectives, inclusive teams, and an environment where every employee feels respected and empowered. We believe that diversity of background, thought, experience, and identity leads to better innovation, decision-making, and business performance.

Glartek has zero tolerance for any form of bullying, harassment, intimidation, or abuse—whether verbal, physical, psychological, or digital. All employees have the right to work in an environment that is respectful, safe, and free from behaviours that demean, threaten, or harm.

Glartek is an equal opportunity employer. Employment decisions are made based on qualifications, merit, and business need, regardless of race, colour, religion, sex, gender identity or expression, national origin, age, disability, sexual orientation, or any other status protected by law.

Conflicts of Interest

Employees must avoid situations where personal interests conflict (or appear to conflict) with Glartek’s interests. A conflict of interest arises when a private interest could improperly influence one’s professional judgment or duties:

Disclosure: Employees must promptly disclose any potential conflict, such as family relationships with suppliers, outside business activities, or personal investments in competitors.
Prohibited Activities: Executives and directors may not engage in business outside Glartek that competes with or conflicts with company interests. Employees must not use Glartek property or information for personal benefit.
Prior Authorization: Any exception requires written approval from management or the Board. The approving authority will evaluate whether the arrangement can be managed without harm to Glartek.
Objective Decision-Making: Job duties must be performed objectively. For example, employees involved in procurement or hiring should not award business to family members or friends without transparent selection processes.

Health & Safety

Glartek is committed to maintaining a safe, healthy, and legally compliant work environment for all employees, contractors, and visitors. As a provider of EHS solutions, we lead by example by embedding safety practices into our culture and operations:

Zero Harm Commitment: Our goal is to eliminate work-related injuries and illnesses through proactive risk management and preventive action.
Compliance: We comply with all applicable occupational health and safety laws, standards and regulations in the jurisdictions where we operate or deliver services.
Risk Prevention: We identify, assess, and mitigate risks in the workplace using appropriate tools, procedures, and employee feedback.
Training and Awareness: Employees receive training on health and safety best practices, emergency procedures, ergonomics, and role-specific hazards.
Workplace Ergonomics: We promote healthy work environments – whether in the office, remote, or on-site at customer facilities – to reduce physical and mental strain.
Incident Reporting: All incidents, near misses, or unsafe conditions must be reported immediately. We investigate them promptly and take corrective actions to prevent recurrence.
Third-Party Safety: Contractors and suppliers working with Glartek must adhere to equivalent health and safety standards and are held accountable for unsafe behaviour or violations.

Vendor and Third-Party Relationships

Glartek recognises that vendors, suppliers, consultants, and other third parties play a critical role in delivering value to our customers. We are committed to building ethical, compliant, and transparent relationships with all third parties:

Due Diligence: All third-party entities are subject to a vetting process before engagement, including checks related to legal status, financial stability, ethical history, and alignment with Glartek’s values.
Contractual Obligations: Contracts should include clauses requiring compliance with Glartek’s Code of Ethics, data protection policies, anti-corruption standards, and confidentiality terms.
Ethical Alignment: We partner only with vendors who demonstrate a commitment to lawful and ethical business conduct. We do not tolerate any form of bribery, forced labour, child labour, or environmental irresponsibility from our suppliers.
Performance Monitoring: We assess and monitor third-party performance to ensure continued compliance with our standards and to mitigate risk. In cases of non-compliance or unethical behaviour, corrective actions will be taken, including possible contract termination.
Security and Data Protection: Third parties with access to Glartek or customer data must comply with our information security requirements, including controls for confidentiality, integrity, and availability, in line with ISO 27001.
Conflict of Interest Disclosure: Vendors must disclose any personal, financial, or professional ties that may create a conflict of interest with Glartek employees or decision-makers.

Corruption

Glartek maintains zero tolerance for bribery and corruption in any form. Employees and third parties are strictly prohibited from offering, giving, requesting or accepting any improper payment, gift, or favour to influence business decisions. We comply with all anti-corruption laws (e.g. Portuguese Penal Code, UK Bribery Act and US FCPA) and international agreements. Key measures include:

Prohibition of Bribery: No person may authorize or engage in direct or indirect bribery of public officials or private parties. This includes facilitation payments, kickbacks, or gifts outside normal business courtesies.
Gifts and Hospitality: Modest gifts or entertainment are permitted only if they are lawful, customary, and approved by management. All such items must be recorded transparently to avoid any appearance of impropriety.
Third-Party Due Diligence: Partners, agents, vendors and consultants must be vetted before engagement. Contracts include anti-corruption clauses requiring compliance with this Code. We monitor third-party performance and terminate relationships if red flags arise.
Accurate Recordkeeping: Financial and expense records must be complete and truthful. Every payment and receipt must have a legitimate business purpose and documented authorization.
Training and Oversight: All employees receive regular anti-bribery training to recognize and avoid corrupt practices.

Anti-Money Laundering

Glartek is committed to preventing money laundering and terrorism financing. We adhere to EU and global Anti-Money Laundering (AML) frameworks, including customer due diligence and transaction monitoring. Key practices include:

Know Your Customer (KYC): We identify and verify the identity of clients and counterparties before establishing business relationships. This ensures funds are from legitimate sources.
Transaction Monitoring: Financial transactions are reviewed for unusual size, origin or frequency. Any suspicious activity or attempts to structure payments are immediately reported to compliance.
Record Retention: We retain financial and contractual documentation to provide an audit trail. Records are kept as required by law so that any inquiry by authorities can be supported by evidence.
Reporting Obligations: Employees must report any detected or suspected money laundering via the whistleblower channel (https://forms.office.com/e/2xFgiRVwpR). Glartek will cooperate fully with law enforcement and regulators in investigations.
Global Compliance: We follow updated AML directives (e.g., EU AMLD) and Financial Action Task Force (FATF) recommendations.

Fraud

Glartek prohibits all forms of fraud, defined as intentional deception or misrepresentation for unlawful gain. Fraud includes asset misappropriation, falsifying documents, or any dishonest act to harm Glartek or others. The following measures are in place:

Anti-Fraud Controls: We implement strong internal controls and segregation of duties in finance and operations. For example, expense approvals, invoice processing and payroll management require multiple sign-offs to reduce opportunities for theft or error.
Regular Audits: Independent audits of financial statements and operational processes are conducted regularly. Auditors have direct access to management if they identify irregularities.
Clear Policies: Detailed policies define acceptable accounting, spending and reporting practices. Employees must follow procedures for recording time, expenses, and project costs.
Whistleblower Support: Employees are encouraged to report suspected fraud without fear of retaliation. All reports are investigated promptly and objectively.
Awareness and Training: Employees receive guidance on ethical financial practices. We emphasize vigilance: understanding “red flags” like unexplained transactions and verifying unusual requests.

Corporate Responsibility & Sustainability

At Glartek, we believe that responsible business practices and long-term sustainability are essential to our success and that of our customers. As a technology company serving safety-critical industries, we embrace our role in supporting a safer, cleaner, and more equitable world. Our Commitments:

Environmental Stewardship: We actively minimize our environmental footprint by reducing waste and conserving energy. Our digital solutions also help customers achieve their own environmental goals by improving efficiency and reducing paper and process waste.
Social Impact: We promote inclusive growth by supporting diversity, offering fair employment practices, and investing in continuous learning for our team.
Sustainable Innovation: We develop technology with a purpose—empowering industrial workers, improving health and safety outcomes, and enabling organizations to meet their ESG (Environmental, Social, and Governance) objectives.
Community Engagement: We seek opportunities to contribute to the communities we serve through partnerships, volunteerism, and awareness campaigns—particularly in areas related to workplace safety and digital inclusion.
Transparency and Ethics: Our approach to sustainability is grounded in ethical governance, open communication, and compliance with all relevant regulations and standards.

Confidentiality

Glartek is committed to protecting the confidentiality of all information it handles—whether internal, customer-related, or related to partners and suppliers. This duty applies to all employees, contractors, and third parties acting on Glartek’s behalf:

Confidential Information: Includes technical, financial, strategic, personal, or any proprietary data not intended for public disclosure. This may relate to customers, employees, intellectual property, or internal operations.
Access Control: Only authorized personnel may access confidential or classified information. Access must be based on legitimate business need and comply with internal access protocols.
Non-Disclosure: Employees must not share confidential information with unauthorized persons, inside or outside the company. Disclosure to external parties requires prior written approval.
Information Handling: Documents and systems containing confidential data must be stored, transferred, and disposed of securely. Classification and protection measures are to be followed rigorously.
Third-Party Confidentiality: Glartek expects its vendors, partners, and service providers to follow equivalent confidentiality standards and signs Non-Disclosure Agreements (NDAs) as appropriate.
Obligations Continue Post-Employment: Employees remain bound by confidentiality obligations even after leaving Glartek.
Reporting Breaches: Any accidental or intentional disclosure, misuse, or breach of confidential information must be reported immediately to the Information Security team.

These commitments support our ISO 27001 certification and reflect Glartek’s dedication to protecting sensitive information throughout its lifecycle.

Procedures and Controls Overview

Glartek implements robust risk-based procedures and controls to enforce this Code across all functions:

Risk Assessment: We identify and evaluate risks of bribery, money laundering, and fraud through periodic risk assessments. This includes reviewing new business lines, geographic factors, and customer profiles.
Financial Controls: We establish controls on financial transactions and third-party payments. All financial systems have audit trails and approval workflows to detect anomalies.
Third-Party Management: Vendors and partners undergo due diligence. Contracts include clauses requiring anti-corruption and AML compliance. We monitor their performance and can terminate if they violate ethical obligations.
Monitoring and Auditing: Periodic review of processes and transactions for compliance. This includes random checks, analytical reviews, and investigations of irregularities. Findings are reported to senior management for action.
Recordkeeping: Accurate record retention is maintained to support compliance. We keep financial and compliance documents for the required periods, enabling traceability of decisions and payments.
Technology and Security: Information systems protect data integrity and confidentiality. Access to sensitive systems (e.g., finance and customer data) is controlled and logged, preventing unauthorized alterations that could facilitate fraud.
Continuous Improvement: Controls are updated as laws evolve. Management reviews control effectiveness and takes corrective actions when gaps are identified. We pursue ongoing improvement in our compliance program.

Training and Awareness

To uphold this Code, Glartek provides comprehensive training for all personnel. Training ensures staff know how to apply policies in practice:

Mandatory Training: Every employee completes ethics, anti-corruption, AML, and fraud-awareness training upon hire and at least annually.
Role-Specific Sessions: Employees in high-risk roles (e.g., finance, procurement and sales) receive enhanced training on relevant rules (e.g., third-party vetting). Managers get instruction on how to enforce controls and mentor their teams.
Ongoing Communication: We reinforce ethics through regular communications: newsletters, intranet updates, and briefings on real-world case studies. Management openly discusses compliance issues to keep awareness high.
Assessment and Certification: Employees certify that they have read and understand this Code and company policies annually.

Reporting Violations

Glartek encourages prompt reporting of any suspected misconduct or Code violations. We provide multiple channels to raise concerns safely and confidentially:

Internal Reporting: Employees should first report issues to their manager, human resources, or the Management Team. Each report is taken seriously and investigated impartially.
Whistleblower Channel: An anonymous form is available 24/7 (https://forms.office.com/e/2xFgiRVwpR). This allows concerns to be raised confidentially without fear of retribution. Managers are prohibited from discouraging reports.
Protection from Retaliation: Glartek strictly forbids retaliation of any kind against individuals who report concerns in good faith. Any retaliatory act is a serious violation of this Code and will result in disciplinary action.
Compliance with Laws: In jurisdictions where mandated, we follow legal protections for whistleblowers. This includes non-retaliation provisions under applicable EU or Portuguese legislation.
Accountability: Employees have an affirmative duty to report: “all directors, officers and employees must report any suspected violations of the Code”. The Company will act on credible reports, which may involve audits, disciplinary measures, or notifying regulators as required.

Governance and Review

Oversight of this Code and its implementation is a responsibility shared by all levels of Glartek leadership:

Executive and Board Oversight: Senior management, including the CEO and Board, champion ethical conduct. Committees or teams meet whenever relevant to review compliance metrics, incidents, and risk assessments.
Periodic Review: The Code and related policies are reviewed at least annually and updated as needed. This ensures alignment with changing laws, regulations, and industry best practices. Revisions involve cross-functional input and evidence of executive involvement to reinforce a culture of compliance.
Internal Audit and Evaluation: Internal Audit periodically evaluates the effectiveness of controls and compliance processes. Findings and corrective plans are reported to leadership. This continuous feedback loop helps improve our compliance framework over time.
Public Commitment: Glartek’s Code is published for employees and partners. We reaffirm our dedication to ethical conduct through leadership messages and whenever possible by integrating ethics goals into performance objectives.

Through these measures, Glartek maintains a strong culture of ethics and compliance. Our Code of Ethics underscores that responsible, lawful behaviour is essential to the trust and success of our company. By adhering to this Code, Glartek demonstrates to enterprise customers that we are committed to the highest standards of integrity and governance.

Version: December 19th, 2024

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