CODE OF CONDUCT POLICY
This Workplace Code of Conduct (“Code”) establishes the principles and expectations for professional conduct and ethical behavior for all employees of omiics. By adhering to this Code, we foster a positive, inclusive, and respectful work environment that aligns with our core values and organizational objectives.
1. SCOPE AND APPLICABILITY
This Code applies to all employees of omiics, regardless of their position or location. Also, this includes board members, advisors, investors, contractors and volunteers, who may have access to confidential information.
Contractors and temporary staff are also expected to adhere to this Code while working for or on behalf of the company.
2. CORE VALUES AND PRINCIPLES
The core of the omiics values is to serve the customers with quality, reliability, expertise and care.
The omiics employee must act first and foremost with the highest integrity, the utmost respect of life and society. No person may ever merely be a means to an end in our team. We stand together.
3. PROFESSIONALISM
Employees are expected to conduct themselves in a professional manner at all times. This includes punctuality, reliability, and commitment to delivering high-quality work.
4. RESPECT AND INCLUSION
We value diversity and are committed to fostering an inclusive environment where all employees feel valued and respected.
Harassment, discrimination, or any form of bullying will not be tolerated.
5. INTEGDRITY AND ETHICS
Employees must act with integrity and uphold the highest ethical standards in all professional interactions.
This includes avoiding conflicts of interest and acting in the best interests of the company.
6. CONFIDENTIALITY
This policy affects all employees, including board members, investors, contractors and volunteers, who may have access to confidential information.
Confidential and proprietary information is secret, valuable, expensive and/or easily replicated. Common examples of confidential information are:
Employees may have various levels of authorized access to confidential information.
WHAT EMPLOYEES MUST DO
WHAT EMPLOYEES MUST NOT DO
When employees stop working for omiics, they're obliged to return any confidential files and delete them from their personal devices.
CONFIDENTIALITY MEASURES
We'll take measures to ensure that confidential information is well protected. We'll:
EXCEPTIONS
Confidential information may occasionally have to be disclosed for legitimate reasons. Examples are:
In such cases, employees involved should document their disclosure procedure and collect all needed authorizations. We're bound to avoid disclosing more information than needed.
DICIPLINARY CONSEQUENCES
Employees who don't respect omiics confidentiality policy will face disciplinary and, possibly, legal action.
We'll investigate every breach of this policy. We'll terminate any employee who willfully or regularly breaches our confidentiality guidelines for personal profit. We may also have to punish any unintentional breach of this policy depending on its frequency and seriousness. We'll terminate employees who repeatedly disregard this policy, even when they do so unintentionally.
This policy is binding even after separation of employment.
7. TECHNOLOGY AND SOCIAL MEDIA USAGE
Company technology and social media should be used responsibly and in accordance with company policies.
Confidential information must not be shared online or through social media platforms.
8. HEALTH AND SAFETY
Employees must comply with all health and safety regulations and report any hazards or unsafe conditions.
A commitment to maintaining a safe and healthy work environment is the responsibility of every employee.
9. CONFLICT RESOLUTION
Any workplace conflicts should be resolved in a professional and respectful manner.
Employees are encouraged to seek the assistance of their supervisor or CEO if needed.
10. REPORTING MECHANISMS
Employees are encouraged to report any unethical behavior or violations of this Code.
Omiics is committed to protecting the anonymity and safety of those who report misconduct.
By adhering to this Code, employees contribute to the success and reputation of omiics. Failure to comply with this Code may result in disciplinary action, up to and including termination of employment.
ANTI-FRAUD & BRIBERY POLICY
1. SCOPE
This policy applies to all relevant persons of Omiics ApS. relevant persons include staff, board members, volunteers, and short-term contractors.
2. DEFINITIONS OF CORRUPTION; FRAUD AND BRIBERY
2.1. Definitions of corruption, fraud, and bribery are found in Appendix I, below.
2.2. It is also bribery to make unofficial payments (known as ‘grease’ or ‘facilitation’ payments) to a public official to secure or speed up a routine action to which you may feel entitled to. For example, you pay a public official a small “fee” to speed up the issuing of a visa.
2.3 Some examples of fraud and bribery relevant to Omiics ApS are described in Appendix II.
3. ZERO TOLERANCE ON FRAUD OR BRIBERY
3.1. Omiics ApS’s position on fraud and bribery is to take a zero-tolerance approach, and we are committed to pursuing this approach throughout its operational practices for the following reasons:
3.2. All members of staff and the board, together with volunteers and contractors, are required to sign the zero-tolerance declaration form Appendix III.
3.3. We support the application of the zero-tolerance policy by providing:
3.4. Anyone found guilty of fraud or bribery will be subject to disciplinary measures, which ordinarily include dismissal, prosecution, and recovery of losses.
4. ANTI-BRIBERY POLICY
4.1. Omiics ApS employs all legal and safe tactics to avoid and resist paying bribes to public officials, even if it results in denials, delays, inconvenience, and increased cost to our operations.
4.2. No person is authorized to pay a bribe on behalf of Omiics ApS or use Omiics ApS funds.
4.3. Individuals are not expected to resist bribery to the point of putting themselves or others at real risk of personal harm or injury. A payment under such circumstances is considered extortion rather than bribery.
5. CONFLICT OF INTEREST
5.1. A conflict of interest exists where an employee or a board member has an interest, relationship, or friendship which could, or could be seen to, interfere with their ability to decide an issue in the best interests of Omiics ApS.
5.2. The purpose of this policy is to ensure that all conflicts of interest are declared, declared conflicts are managed to mitigate the associated risks, and that decisions and actions are documented to ensure transparency and accountability.
5.3. Examples of conflicts of interest include (but are not limited to):
5.5. The existence or discovery of a conflict of interest does not constitute a breach of policy as long as it is disclosed promptly.
5.6. The following people are required to make a conflict of interest declarations using the form in Appendix IV.
5.7. All staff (including those listed above) are required to disclose conflicts of interest as soon as they arise, or the staff member becomes aware of the conflict of interest. Examples of such disclosures would include:
5.8. The recruitment conflict of interest declaration form in Appendix V should be signed by all relevant persons involved in the development or design of selection tools, those with access to the selection tools, and those involved in the selection process. It should be signed as soon as all the applications are received and before any short listing.
5.9. The Procurement Committee meeting agenda should always include a clear listing of all suppliers on the approved suppliers list, and all who have provided quotes for the purchases under consideration. All members present should be required to declare that they have no interests in any of the suppliers under consideration at that meeting, and this should be recorded in the minutes.
5.10. If a conflict arises or is discovered, it should be immediately declared using the form in Appendix VI.
5.11. Appropriate actions should be taken to resolve the conflict of interest, which may be temporary or permanent, for example:
5.12. The steps taken to manage the conflict of interest and mitigate the risk of conflicted decision taking should be documented on the declaration form.
6. GIFTS AND ENTERTAINMENT
6.1. Gifts and entertainment should never be used or allowed to influence business decision-making.
6.2. When offers of gifts and entertainment are made or accepted in situations where they are inappropriate, they can look like, or may be, bribes. They can expose us to accusations of unfairness or even break the law and can put our reputation for ethical behavior at risk.
6.3. Positive, healthy, normal business practices can include accepting and making offers of gifts and entertainment, which develop and maintain positive and strong business relationships. We should be able to accept and make offers of gifts and entertainment ONLY when they are appropriate, i.e., when they:
6.4. The following gifts may never be offered or accepted and will always be deemed inappropriate.
6.5. It is never allowed to request a gift or entertainment.
6.6. Gifts or entertainment below the limits above [6.4] are not necessarily appropriate.
6.7. In some circumstances, an element of judgment is required to decide whether a gift is appropriate or not. If any staff or board member is in any doubt, they should consult a leadership team member (or the board chair in the case of the Executive Director) and obtain written permission before accepting or offering a gift.
6.8. The following circumstances imply the giving or receiving of a gift or entertainment offer may be appropriate:
6.9. The following circumstances imply the giving or receiving of the gift or entertainment may be inappropriate:
6.10. If any staff or board member is offered an inappropriate gift, they should politely decline it and inform their line manager or board chair.
6.11. In the event that declining an inappropriate gift in the moment might be culturally inappropriate or embarrassing, it should be returned within no less than a week, with appropriate documentary evidence to prove that the gift was returned.
6.12. In the event that an inappropriate gift is received publicly, steps should be taken to restore the organization’s reputation, in addition to returning the gift.
6.13. In the event that inappropriate gifts are received without consent (such as courier deliveries, bank, or mobile money transfers), these should be declared immediately using the conflict-of-interest declaration form. Steps should be taken to return the gift or notify authorities if money laundering is suspected.
6.14. Inappropriate gifts received by employees and subsequently declared should not be received into the organization’s funds – rather they should be returned in all cases.
6.15. Appropriate gifts, given to the organization as a whole, or to a particular team, should normally be enjoyed or shared by all relevant staff members (e.g., gift basket or flowers). Where an appropriate item is not easily sharable, it should be raffled off by random and transparent means.
7. SPEAKING UP
7.1. Omiics ApS’s policy on speaking up is designed to build confidence to report genuine concerns about fraud, bribery, or other types of misconduct. For many cases of misconduct, someone reporting it is the only way it can be discovered and dealt with.
7.2. A genuine concern is sincerely felt and based on information the reporting person believes to be true or trustworthy. Upon further investigation, a genuine concern may or may not turn out to be true. The motivation of the person reporting a genuine concern is not relevant to its definition as a genuine or not.
7.3. A false accusation is when the reporting person knowingly fabricates information or reports information, they know to be false.
7.4. Omiics ApS’s whistle-blower lines should be used by all relevant persons to raise any genuine concerns.
7.5. Omiics ApS has zero tolerance to anyone who is found to have wilfully and deliberately abused a speaking up line to knowingly make false accusations. Appropriate disciplinary measures will be taken.
7.6. A genuine concern should be reported when there is evidence or a strong suspicion of misconduct in any of the following areas:
Fraud or bribery
7.7. Concerns may be reported, either in person or by email, using any of the following whistle-blower lines below:
Den Nationale Whistleblowerordning (Denmark)
Carl Jacobsens Vej 35
2500 Valby, Denmark
Phone (+45) 33 19 32 02
7.8. All relevant persons are strongly encouraged to report genuine concerns. They should report as much detail as possible, including who, when, where, and how and whether they have evidence for the basis of their suspicion.
7.9. Concerns may be reported anonymously, but people are encouraged to give their name and/or contact details. It is easier to investigate allegations when follow-up questions with the reporting person is possible.
7.10. Omiics ApS will address any concerns raised with the reporting person within 24 hours, assuming contact details have been provided.
7.11. Information about the speaking up lines will be made available:
8. SUPPORTING REPORTING PERSONAS
8.1. Omiics ApS has zero tolerance to any form of retaliation against reporting persons (also known as ‘whistle-blowers’).
8.2. All relevant persons who report genuine concerns will be properly protected and supported.
8.3. Details of any allegations or suspicions raised should be recorded on a Fraud, Bribery, and Misconduct report form Appendix VII and submitted to the Executive Director/CEO.
8.4. Omiics ApS commits to take the support of whistle-blowers seriously by:
POLICIES
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