CUALIS Code of Ethics 

1. Ethics Key Principles

Our conduct must always be governed by the principles of Integrity, Transparency, Honesty, and Fairness. No business objective justifies a deviation from these rules. 

• Compliance with Laws: We are committed to fully complying with the laws and regulations of the countries in which we operate. 

• Reputation: Employees must never act in a manner which may tarnish the reputation of Cualis or raise doubts about its ethical integrity. 

• Responsibility: Every manager and employee is responsible for knowing and applying the Code. In situations where laws do not clearly state what to do, our core principles will guide our course of action. 

2. The Core Ethical Pillars
3. Integrity

• Integrity of Services: Reports and certificates must accurately reflect the actual findings, professional opinions, or results obtained. Data fabrication, “cherry-picking” results, or modifying samples is strictly prohibited. 

• Integrity of Documents: Every employee is personally responsible for the information they provide in reports, test results, and certificates. 

• Financial Integrity: All financial and accounting information must be duly and correctly recorded. Incomplete, erroneous, or fraudulent treatment of financial data is prohibited.
• II Conflict of Interest

• Employees must be independent and report any commitment or link that may create a potential conflict of interest. 

• Conflicts can arise from personal investments, outside employment, or relationships with clients and competitors. 

III. Confidentiality and Data Protection 

• We undertake to protect our clients’ confidentiality, including all commercial and personal data. 

• Confidential information must be safeguarded and used only for authorized purposes.
• IV. Anti-Corruption

• Zero Tolerance: Cualis has a zero-tolerance policy regarding bribery and corruption. 

• Gifts and Hospitality: Directors, officers, and employees are prohibited from giving or accepting bribes. Gifts or entertainment must be modest, occasional, and must not be used to influence business decisions. 

• Intermediaries: Our intermediaries, sub-contractors, and joint-venture partners are required to comply with our Code of Ethics.
• VI. Fair Business Conduct

• Fair Competition: We comply with antitrust and competition laws. We do not engage in unfair competitive practices or deceptive business practices. 

• Trade Compliance: We follow international trade laws, including sanctions and export/import regulations. 

1. Health and Safety

• We provide information, instructions, and training to ensure necessary health and safety measures for our teams. 

• Safety is an “Absolute” value; everyone is subject to health and safety obligations to protect themselves and others. 

VII. Fair Labor and Human Rights 

• Respect for Individuals: We respect differences without discrimination based on nationality, ethnicity, age, gender, religious, or political beliefs. 

• Human Rights: Forced labor, child labor, and human trafficking are strictly prohibited. 

• Working Conditions: We respect all applicable employment laws regarding working hours, minimum wages, and freedom of association. 

3. Ethics Governance & Implementation

• Training: 100% of employees are required to be trained in Ethics Compliance. 

• Reporting (Whistleblowing): Employees are encouraged to report any suspected violations. Cualis ensures that the anonymity of the whistleblower is protected as far as reasonably practicable, and no employee will suffer retaliation for reporting in good faith. 

• Evaluation: Employees are evaluated not only on what they achieve but also on how they achieve it, specifically regarding adherence to ethical standards. 

The Ethics Decision Tree 

When faced with an ethical dilemma, employees are encouraged to ask: 

1. Is it legal? 

1. Is it consistent with the Cualis Code of Ethics? 

1. Would I be comfortable if my action was made public? 

1. Does it protect the reputation of the company?