Code of Ethics and Business Conduct
This Code of Ethics and Business Conduct (“Code”) is applicable to all employees
of ProSkills, regardless of where they are doing business. ProSkills IT & Training Services
requires that all employees comply with all applicable laws, regulations, and this Code.
All employees of ProSkills must also make sure that all our business partners, resellers,
customers are aware of our Code of Ethics and Business Conduct.
Compliance with laws, regulations, and business practices means not only observing the
law, but also conducting corporate business in a way that recognizes our ethical
responsibilities and fulfills them.
Anti-trust and Competition Laws
We are committed to observing the applicable antitrust or competition laws
of all countries we have operations in. We, at ProSkills realize that those laws seek to
protect the competitive process so that consumers receive the benefits of competition.
Compliance with antitrust or competition laws is required at all times.
Therefore, ProSkills employee must not agree with any competitors to (i) fix or control
prices, either by agreeing directly with a competitor or any other method, such as
through third parties; (ii) structure or orchestrate bids to direct a contract
to a certain competitor or reseller (bid rigging), including abstaining from
bids or submitting noncompetitive or “courtesy” bids; (iii) boycott suppliers
or customers; (iv) divide or allocate markets or customers; or (v) limit the
production or sale of products or product lines. We refrain from
prohibited discussions with competitors about prices, costs, profits or profit margins,
production volumes or bids, or quotes for a specific customer’s business.
Improper Payments, Money Laundering, and Economic Boycotts
ProSkills cannot offer or pay bribes. ProSkills employees are prohibited from offering,
promising, authorizing, directing, paying, making, or receiving any bribes, kickbacks, or
payments of money or anything of value (directly or indirectly) to improperly obtain
business or any other advantage for ProSkills its employees.
ProSkills also prohibits all forms of money laundering, which involves disguising,
channeling unlawfully obtained money, or transforming such money into legitimate
The above prohibition applies to:
- Government and public sector, which includes public utilities, higher education, public healthcare entities, and public international organizations and their employees or officials
- Political parties or candidates for political office
- Business entities partially or wholly owned or controlled by government interests (often referred to as state-owned enterprises) and their employees or officials
- Privately held commercial companies and their employees
- Vendors’ (such as Oracle) employees
- Any other third party
We at ProSkills prohibit giving money or anything of value directly or indirectly to a
government official or employee of a state-owned enterprise, or to the spouse,
significant other, child, or other relative of any such person, for the purpose
of influencing or rewarding an action or decision of the government or public
sector employee or official or to gain any improper advantage for ProSkills.
“Anything of value” is intended to be broad and covers not only money,
but also gifts, lavish or excessive entertainment, funding of personal travel
such as sightseeing, contributions to charity, and employment opportunities.
ProSkills also prohibits facilitation or facilitating payments, which are payments
to an official to speed up or expedite routine government actions, including
processing and approving applications and permits.
Dealing with Government
We strictly observe the laws, rules, and regulations that govern the acquisition of goods
and services by any governmental entity of any country and the performance of
If we deal with any governmental entity, including public international organizations,
we make sure to know and comply with all rules that apply to government contracting
and interactions with government or public sector employees and officials, including
but not limited to the following:
- We must not attempt to obtain, directly or indirectly, from any source,
procurement-sensitive information that is not publicly available or otherwise authorized
for disclosure by the government; confidential internal government information, such as
pre-award, source selection information; or any proprietary information of a competitor,
including, for example, bid or proposal information, during the course of a procurement
or in any other circumstances where there is reason to believe that the release of such
information is unauthorized.
- We must ensure the submission of accurate invoices to the government
and comply with all laws regarding invoicing and payments.
- We must not give or offer, either directly or indirectly, any gratuity,
gift, favor, entertainment, loan, or anything of monetary value to any
government or public sector employee or official except as may be
permitted by applicable law.
- We must not provide, attempt to provide, offer, or solicit a kickback,
directly or indirectly, to obtain or reward favorable treatment in connection
with any transaction.
- We must not pay or enter any agreement to pay, directly or indirectly, a
contingent fee to any party for the purposes of obtaining a government
contract or influencing government action.
Lobbying of Government Officials
All ProSkills employee are responsible for understanding when their activities may
legally be considered lobbying in a particular jurisdiction and for complying with all
Business Courtesies that May Be Extended
All ProSkills employees use discretion and care to ensure that expenditures on
customers, or representatives are reasonable, ordinary, and proper. They also ensure
that expenditures could not reasonably be construed as a bribe or an improper
attempt to secure unfair preferential treatment or violate applicable laws and
Business Courtesies that May Be Received
All ProSkills employees are responsible for ensuring that acceptance of any business
courtesies, gifts, or entertainment is proper and could not reasonably be construed as
an attempt by the offering party to secure favorable treatment or otherwise violate
applicable laws and regulations.
ProSkills accurately documents all transactions related to our contract with
our vendors (such as Oracle) and relevant order forms in our financial books, records,
statements and reports, and other documents provided to the vendors and prevent
side agreements, whether oral or written. The handling and disbursement of funds
related to the vendors’ business transactions must be pursuant to a duly authorized
written contract (or via email) with clearly defined procedures. Documents must not
be inappropriately altered or signed by those lacking proper authority. No
undisclosed or unrecorded fund or asset related to any transaction may
be established or maintained for any purpose.
Our financial books, records, and statements properly document all assets and liabilities
and accurately reflect all transactions of the company related to the vendors’ products
and services. Our business records are retained in accordance with record retention
policies and all applicable laws and regulations. We establish and maintain internal
financial and other controls that ensure our transactions are executed and our
expenditures are in accordance with the appropriate authorization(s), and that we
spend money responsibly and appropriately.
All approval requests for nonstandard discounts must be accurate and commercially
justified. Any approved discount or benefit are used only for the purpose disclosed and
authorized. Structuring a transaction to create additional margin which will be used for
any undisclosed or unapproved purpose is never allowed, including paying or
otherwise rewarding a customer, employee, or other third party.
Intellectual Property and Obligations of Confidentiality
ProSkills respects the intellectual property rights of others
The vendors’ intellectual property, confidential information, patented technology,
documentation, or other materials must not be used without written permission or
outside the scope of work performed for the vendor.
Additionally, copyrighted software is not reproduced at ProSkills. In the course of
working with or for the vendor (such as Oracle), we do not use proprietary information,
patented technology or copyrighted software, documentation, or other materials of
third parties without authorization.
We observe applicable data privacy standards. Materials that contain confidential
information or that are protected by privacy standards should be stored securely and
shared only internally with employees on a need-to-know basis.
Confidential information may include, but is not limited to: source code, software
and other inventions or developments (regardless of the stage of development)
created or licensed by or for the vendor, marketing and sales plans, competitive
analyses, product development plans, nonpublic pricing, potential contracts
or acquisitions, business and financial plans or forecasts, internal business
processes and practices, and prospect, customer, and employee information.
Trade Compliance Laws and Regulations
ProSkills complies fully with all applicable global trade laws and regulations.
Conflicts of Interest
ProSkills’ loyalty is free from any conflicts of interests.
ProSkills and its employees are keen to compete fairly and ethically for
all business opportunities. We ensure that all statements, communications, and
representations to customers are accurate and truthful as they relate to the vendors.
Advertising and Marketing
We prohibit unfair methods of competition and deceptive practices.
Examples of these include making false or misleading statements about the offered
products or services, falsely disparaging a competitor or its products or services, making
product or service claims without facts to substantiate them, or using another
company’s trademarks in a way that confuses the customer as to the source of the
product or service.
Business and Employment Relationships
ProSkills affirms the principle of equal employment and business opportunities
without regard to any protected characteristic, including but not limited to:
race, religious creed, national origin, color, sex or gender, gender identity or
expression, age, mental or physical disability, mental condition, pregnancy,
marital status, national origin/ancestry, genetic information, political affiliation,
military and protected veteran status, sexual orientation, or any other
characteristic protected under federal or state law or local ordinance. ProSkills policy
prohibits harassment in any form and we practice and promote a work environment
free from harassment, as appropriate under local laws.
Human Rights of Workers
ProSkills upholds the human rights of workers and to treat them with dignity and respect.
Compliance with fair labor and antislavery practices that allow for freely chosen
employment is assured, which includes the prohibition of child labor, human trafficking,
and slavery. Additionally, the adherence to applicable wage and labor laws an
standards is also assured.
Physical abuse, sexual or other harassment, and discrimination on the basis
of race, religious creed, caste, national origin/ancestry, genetic information,
military and protected veteran status, religion, age, disability, gender, gender
identity or expression, pregnancy, marital status, sexual orientation, union
membership, political affiliation, or any other characteristic protected under
applicable law or local ordinance is strictly prohibited at ProSkills.
Environment, Health, and Safety
ProSkills recognizes its social responsibility to protect the environment.
We make sure that we comply with all applicable environmental laws and regulations
and are expected to work to reduce consumption of resources, including raw
materials, energy, and water, throughout all aspects of the product or service lifecycle.
We encourage our employees to reduce or eliminate waste of all types by
implementing appropriate conservation measures in our facilities and by recycling, re-
using, or substituting materials.
Worker health, safety, and well-being are also important to ProSkills. We provide and
maintain a safe and healthy work environment and fully comply with all applicable
safety and health laws, regulations, and practices while also minimizing the
environmental burden of our operations and products on the environment.
Adequate steps are also taken to minimize the causes of hazards inherent in the
working environment, prevent workplace accidents and injuries, and promote safe and
Duty to Cooperate
We are committed to cooperate with the vendors’ (such as Oracle) periodic requests
for documents and/or information made in connection with ProSkills onboarding and
due diligence processes.
Additionally, ProSkills is committed cooperate with any audit request made
by the vendor as required by the vendor’s Partnership Agreement (e.g. Oracle
PartnerNetwork Agreement) or any Distribution Agreement.