Asperii’s Code of Business Conduct and Ethics

Our Mission

Ethical conduct builds trust and enhances relationships between people and organizations across the globe, which is why we view compliance with applicable laws and highest level of ethical standards as crucial to our business. This Code of Business Conduct and Ethics (the “Policy“) serves as a guide to our legal and ethical responsibilities, and it represents our strong commitment to live up to the high ethical values we espouse.

Asperii and its affiliates comply with this Policy and with all relevant laws, regulations and standards in the countries they operate. We lead by example, and we expect all of our consultants, associates, agents, suppliers and other business partners (collectively, “Business Partners”) to comply  with this Policy even  if  it stipulates a higher standard than required by applicable laws and regulations. This Policy is in no way intended to derogate from your or your organization’s requirement to comply with such applicable laws or adhere to its own codes of conduct. In case of any discrepancies between applicable laws, our Policy or your organization’s Code of Conduct, the provisions that hold up to the highest ethical standard should apply.

This Policy is designed to assist us and you, as our employees, consultants, or Business Partners, in making appropriate ethical decisions, based on values of integrity, transparency, honesty and mutual respect. If you are unsure how any of the standards described in this Policy apply to a particular situation you are facing, please reach out to your direct supervisor or contact us directly at We will treat all of your questions and concerns on the basis of the values represented by this Policy, maintaining, where possible, your anonymity and confidentiality.

Non-compliance with this Policy may result in disciplinary action, which will be applied on a case by case basis, depending on the nature and severity of the violation, and which may lead to termination of the engagement between you and Asperii.

1.        Hiring Practices

Asperii promotes equal opportunity in our hiring practices and makes its hiring decisions on the basis of objective criteria related to the relevant position and the applicants’ skills and aptitude.

We value diversity in our environment and believe that diverse, respectful views enhance businesses. Therefore, both in our hiring practices and in our general approach to employment and business relationships, we treat one another with dignity and respect and do not tolerate any kinds of discrimination based on prejudice, such as discrimination based on race, color, gender, sexual orientation, marital status, pregnancy, parental status, religion, political opinion, nationality, ethnic background, social origin, social status, indigenous status, disability, age and any other characteristic protected by local law, as applicable.

Asperii conducts background checks subject to limitations of applicable laws and will not knowingly hire any person who has a record of behavior which is inconsistent with this Policy.

2.       Labor Standards

Forced labor avoidance – Forced, bonded or compulsory labor will not be tolerated and employees/consultants are free to leave their work at any time after reasonable notice as required by applicable law or contract.

Fair employment conditions – Employees/consultants should have clarity and transparency with respect to their working conditions. Pay and work terms should be fair and reasonable and comply at a minimum with applicable laws or industry standards, whichever is higher. Deduction from wages, physical or verbal abuse, or other coercive  measures are  never to be used as disciplinary measures.

Child labor avoidance – Only persons who are above the minimum legal age for employment in the applicable jurisdiction (“Legal Age“) are to be hired for work. Children and youth who are of Legal Age should not be hired for any hazardous work, or work that is inconsistent with their personal development. Where a child who is of Legal Age is hired, the best interests of that child should be the primary consideration.

Safe working environment – A healthy and safe working environment should be provided for all employees, consultants and Business Partners working on Asperii’s premises, in accordance with applicable law. Appropriate health and safety information and training should be provided to employees and consultants, including, but not limited to, arrangements for safe evacuations of buildings.

General standards for professional behavior – Asperii expects its employees, consultants and Business Partners to conduct themselves in a businesslike and professional manner. Drinking on the job (except for official work-related social events), gambling, use of illegal drugs, offensive language, illegal possession of weapons, and other such unprofessional conduct is strictly prohibited while on the job. Employees/consultants must adhere to applicable sexual harassment policies, and should conduct themselves in a way that could not be construed as sexually inappropriate (e.g. sharing inappropriate materials with co-workers, clients or Business Partners, accessing inappropriate materials on their work computer, et cetera). In general, any behavior that is harassing, coercive, sexually inappropriate, threatening abusive or otherwise corrosive of a respectful and dignified working environment will not be tolerated.

3.       Environment

We strive to develop, produce and offer products and services with excellent sustainability performance and contribute to the sustainable development of society.

We strive to continuously improve, with a life cycle perspective, the environmental performance of our products. We will work to continuously reduce the negative impact of our own operations and take a precautionary approach to environmental challenges.

4.       Anti-corruption – Giving and Receiving Gifts

No form of extortion and bribery, including improper offers for payments to or from individuals performing work for Asperii is permitted.

  • Except only as otherwise expressly authorized pursuant to section 4(c) below, no employees, consultants or Business Partners of Asperii may engage, either on their own behalf, or on behalf of Asperii, or on behalf of any third party, in the making, authorization or offer or promise of any gift to any third party, in connection with or in furtherance of any present or prospective business activity/opportunity of Asperii or of any business venture in which Asperii is a participant. This applies regardless of whether or not the donor or recipient of such gift actually intends such gift to be construed as a bribe, and regardless of whether or not the donor or recipient of such gift actually intends such gift to have any influence on the outcome or terms or prospects of any bid/tender/proposal/transaction.
  • No employee, consultant or Business Partner of Asperii may accept or receive, either on their own behalf, or on behalf of Asperii, or on behalf of any third party, any gift connected with or arising in any way from the employee’s/consultant’s engagement with Asperii, except only as expressly authorized pursuant to Section 4(c) below.
  • Notwithstanding the general prohibition against receiving or giving gifts, Asperii recognizes that in certain cultures, the giving, exchanging and acceptance of modest gifts (e.g. gifts which reflect local culture or history or moderate mementos which bear the donor’s logo), are matters of etiquette and custom as gestures of friendship, and are not construed as bribes or as attempts to influence business decisions. Indeed, the non-giving or non- acceptance of such gifts may be construed as insulting. Accordingly, in order not to cause any such insult, such local customs may be taken into account, subject to section 4(d) below.
    • All gifts received by an employee or consultant of Asperii, whether modest, non-personal, or otherwise, should be reported to Asperii’s Chief Executive Officer (the “CEO”), who will determine whether such gift/s may be retained by an employee/consultant, or whether they should be returned to the donor or handled in any other manner.

5.       Conflicts of Interest

Asperii expects that employees and consultants will perform their duties conscientiously, honestly, and in accordance with the best interests of Asperii. Employees/consultants must not use their positions, or the knowledge gained as a result of their positions, for private or personal advantage. Regardless of the circumstances, if any employees or consultant senses that a course of action she or he has pursued, or is presently pursuing, or is contemplating to pursue, may involve a conflict of interest, s/he should immediately communicate all the facts to their supervisor.

6.       Reporting/Whistle-Blowing

It is paramount that you feel comfortable to raise any ethical or legal concerns that affect you or Asperii. Any employee, consultant or Business Partner of Asperii who knows or suspects any action or activity by any other employee, consultant or Business Partner (including an immediate supervisor, manager or another person in a position of power relative to you or to others), which is, or arouses suspicion that it may be, inconsistent with this Policy, should report his or her concerns to the immediate attention of a direct manager, CEO, or any other employee at a managerial level with whom you feel comfortable to share your concerns. Such manager or supervisor is then expected to raise the matter with the CEO or any person designated as the Ethics Officer of the Company. To the extent possible, Asperii will treat all concerns raised in connection with this Policy with the appropriate anonymity and confidentiality.

7.       Confidentiality

We are committed to maintaining the highest degree of integrity in all our dealings with potential, current and past clients, both in terms of normal commercial confidentiality, and the protection of all personal information received in the course of providing the business services concerned. We extend the same standards to all our Business Partners.

8.       Intellectual Property and Moral Rights

We retain the moral rights in, and ownership of, all intellectual property that we create, unless agreed otherwise in advance with our clients. In return we respect the moral and intellectual copyright vested in our clients’ intellectual property.

9.       Public Statements and Announcements

We strive to communicate with the public and with our Business Partners in an honest, transparent and non-misleading manner. We ensure this by carefully reviewing our marketing or other publicized materials for accuracy and clarity. Employees, consultants and Business Partners are not authorized to make public statements or announcements on behalf of Asperii (whether in any written or digital publications, on social media networks or otherwise) without prior authorization of the specific content by the CEO (or another authorized supervisor of Asperii) or, with respect to Business Partners, as may be expressly stated in our written agreements.

10.    Duty of Care

Our actions will always conform to relevant law, and we believe that all businesses and organizations should avoid causing any adverse effect on the human rights of people in the organizations we deal with, the local and wider environments, and the well-being of society at large.

Last updated: 10 February,  2022