Code of Conduct
09/01/2026
Introduction
Founded in 2011, Kurmi Software is a global leader in Service Management and Provisioning for Digital Workplace (Unified Communication and Collaboration +) user accounts in large organizations.
Our success has been possible by the combination of innovative software products and services with diligent and expert Employees1 and Partners2. It is also based on professional values that are at the heart of our culture: Engagement, Innovation, Team Spirit, and Sustainability.
Our Code of Conduct applies to Kurmi Software and our subsidiaries around the world, as well as to our Partners. Its purpose is to explain the issues surrounding the prevention of corruption and influence peddling, and to recommend solutions to be implemented in certain situations that Employees may encounter.
The Code of Conduct takes into account our commitment to respecting the fundamental principles of Corporate Responsibility covered by the ISO 26000 standard.
We ask our Employees to:
- read, understand, and adhere to this Code of Conduct,
- respect the laws in force, to act conscientiously and justly,
- seek advice when in doubt,
- cooperate fully with compliance investigations and audits,
- complete all required trainings,
- report any actual or suspected violation of the Code in compliance with applicable local legal provisions.
All the clauses set out below apply across any country where Kurmi Software operates.
1 Employees: refers to all employees, without any distinction relating to their function, whether they are on a fixed-term or permanent contract, on an internship, on an apprenticeship, temporary employees, or those seconded to the premises.
2 Partners: refers to service providers, subcontractors, external consultants, distributors, and our customers.
ARTICLE 1 – COMMITMENT OF GOVERNANCE BODIES
This Code of Conduct defines the commitments and ethical rules applicable to all of Kurmi Software’s activities. Compliance with it is fundamental to ensuring a culture of transparency, integrity, and accountability at all levels of the organization.
Because having an exemplary behavior is essential, all governance bodies, including management bodies, the entire managerial line, and the shareholders’ governance body, undertake to respect, apply, and enforce the principles and commitments defined by this Code of Conduct.
ARTICLE 2 – FIGHT AGAINST CORRUPTION
Kurmi Software acts in compliance with local and international regulations and legislation and categorically prohibits any act that may be characterized as an act of corruption, whether public or private. Influence peddling is also strictly prohibited.
2.1. CORRUPTION
Bribery (or Corruption) refers to any act by which a person abuses his or her power or office to obtain an undue advantage, for himself or others. It is the improper performance of one’s function or activity in return for an undue advantage (an advantage that the company should not have received), financial or not, for one’s personal benefit or for the benefit of a third party, whether the “price” of corruption is paid directly or indirectly by an intermediary, or whether it is intended for the corrupt person or a third party.
Corruption is generally:
- Active: proposing, promising, or offering an advantage to a person in a position of influence to obtain a favor or a favorable decision.
- Passive: accepting or requesting an advantage in exchange for an act related to one’s function.
It can concern both the public and private sectors.
Corruption is codified by European regulations (such as the French Criminal Code) and American regulations (e.g. FCPA). These regulations strictly regulate these practices.
Example of a situation that an Employee may be confronted with:
- A supplier offers you a commission to conclude a service contract.
- An Employee asks you to approve payment for a suspicious or unclear service that does not refer to any contract.
What are the behaviors to adopt?
✓ Categorically refuse the supplier’s offer and alert someone at the supplier or someone via the whistleblowing system described in this Code of Conduct.
✓ Report any suspicious behavior to your superiors or via the whistleblowing system described in this Code of Conduct.
✓ Maintain transparent accounting of relationships with partners.
2.2. INFLUENCE PEDDLING
Influence peddling consists of taking advantage of a real or supposed influence that one has over a public or private decision-maker, to obtain a favorable decision, in exchange for an advantage. This is an offence recognized and considered a special case of corruption, falling under blackmail, fraud, or conspiracy, depending on the context.
Influence peddling generally involves three actors:
- The person who proposes or agrees to abuse his or her real or supposed influence with a decision-maker.
- The decision-maker.
- The beneficiary of the decision made by the decision-maker.
Example of a situation that an Employee may be confronted with:
- A person claims to be able to influence a tender in exchange for gifts.
- A third party contacts you to inform you of his position, which would allow him to put you in touch with a person in a high position in the administration, to obtain a public contract. This third party is asking for remuneration for the service.
What are the behaviors to adopt?
✓ Do not use your network for undeclared personal or commercial purposes.
✓ Respect the separation of duties and responsibilities.
✓ Immediately alert your superiors or the Human Resources Department if you become aware of any actions that may be contrary to our anti-corruption policy.
Please note: Each Employee must be able to identify an act constituting corruption or influence peddling and refrain from participating directly or indirectly. Moreover, s/he must take appropriate measures upstream to avoid being involved in acts of corruption or influence peddling.
2.3. CONFLICT OF INTEREST
A conflict of interest is a situation in which a personal contact, family, or financial interest could compromise the objectivity, integrity or loyalty expected in the performance of a mission or function.
Example of a situation that an Employee may be confronted with:
- Participate in the selection of a supplier belonging to a relative.
- Invest personally in a project that competes with your company.
What are the behaviors to adopt?
✓ Immediately declare to the HR Department any interest that may lead to a conflict.
✓ Withdraw from relevant decision-making.
✓ Follow internal rules for managing conflicts of interest.
2.4. GIFTS AND HOSPITALITY
The exchange of gifts or invitations is a gesture that contributes to the improvement of business relations and makes them last over time. It’s a gesture of thanks and gratitude. However, this can lead to conflicts between personal interests and professional obligations. This is why they must only be carried out in complete transparency and according to the principle of proportionality. In any event, the gift, invitation, or advantage granted to a customer must remain ancillary to the professional objective.
A benefit can be a service rendered, a contract, cash and its equivalent, but also a discount, a gift, entertainment, a meal, transport, accommodation, confidential information, a promise of employment, a vacation, a promotion, etc. This list is not exhaustive.
A gift is a benefit (object, invitation to an event, etc.) intended for strict personal use.
Employees are prohibited from offering their interlocutors gifts, invitations, or other benefits that may influence current or future decisions.
An Employee may not accept a gift or benefit offered by a Kurmi Software Partners with a value greater than €50 (or $50). Under no circumstances may an employee accept gifts in cash, shares, or negotiable securities of any kind.
If gifts or invitations are received according to the criteria mentioned above, total transparency regarding the hierarchy must be required, and this must be done within the limits of what is acceptable and reasonable.
Example of a situation that an Employee may be confronted with:
- A supplier offers you an invitation to a show or a weekend in exchange for signing a contract.
- A Partner offers you a gift to thank you for renewing a contract.
What are the behaviors to adopt?
✓ Consider whether the gift or invitation could influence the final decision or the future of the business relationship.
✓ Make sure that the value of the gift or invitation does not exceed €50 (or $50).
✓ Declare the gift or invitation received to your superiors and justify that its value does not exceed the maximum authorized amount.
✓ Immediately alert the HR Department in case of doubt or identification of a suspicious situation.
2.5. LOBBYING, PATRONAGE, AND SPONSORSHIP ACTIVITIES
In some professional activities, lobbying, patronage, or sponsorship activities are part of the culture in the conduct of business. As part of its activity, Kurmi Software may participate in certain patronage or sponsorship operations within the framework of the CSR policy.
No Employee may engage Kurmi Software in any of these activities on its behalf. All lobbying, patronage, and sponsorship activities must be approved in advance by the COO and the HR Department, who must ensure compliance with Kurmi Software’s ethical standards, culture, and values.
Lobbying is an activity consisting of influencing the development or application of public policies through a transparent and supervised approach, often in the name of collective or sectoral interests.
Patronage consists of providing support to a project or an individual without direct compensation. This support may be financial, material, or in the form of expertise.
Sponsorship is the support given to a project, event, or person, in exchange for visibility or enhancement of the brand image. It is an act with a commercial purpose.
Example of a situation that an Employee may be confronted with:
You are approached by a third party who offers you, for a fee, to communicate about Kurmi Software’s activities to public authorities that can influence the course of Kurmi Software’s business and to promote the company’s image.
What are the behaviors to adopt?
✓ Ensure consistency between Kurmi Software’s values and the proposed sponsorship project and formalize mutual commitments in an agreement.
✓ Notify your superiors or the HR Department (no lobbying, patronage or sponsorship action must be implemented by the Employee without validation from the HR Department).
✓ Refrain from proposing or agreeing to carry out patronage or sponsorship actions with the sole aim of obtaining an undue advantage.
2.6. FACILITATION PAYMENTS
Facilitation payments are granted, directly or indirectly, to a public official3 in order to carry out or expedite an administrative formality.
In some states, facilitation payments are tolerated. However, Kurmi Software categorically prohibits these practices, which are considered acts of corruption.
Example of a situation that an Employee may be confronted with:
- A customs officer abroad asks you to grant him a sum of money to facilitate entry into the country as part of a business trip.
What are the behaviors to adopt?
✓ Refuse any facilitation payment and immediately inform your line manager or the HR Department, except in extreme situations where the physical integrity of the Employee is at stake. In this case, the HR Department must be immediately informed and will advise on the action to be taken. The safety of the Employee will be the number one priority of the company.
✓ In a case of extreme urgency, if a facilitation payment were to be made, it would be recorded in the company’s books.
3 A public official may be any person who holds a legislative, executive, administrative or judicial office, whether appointed or elected, whether remunerated or unpaid, at any hierarchical level; or who performs a public function, including for a public body or a public enterprise, or who provides a public service; or who carries out any activity in the public interest on delegation from a signatory, as the performance of a task in connection with a public contract.
2.7. ANTI-MONEY LAUNDERING
Money laundering refers to all the processes used to conceal the illicit origin of funds to reintegrate them into the legal economy. It can be characterized by unusual transactions, large cash payments, shell company accounts, or fund transfers without business justification.
Kurmi Software is firmly committed to preventing and combating all forms of money laundering, in compliance with national and international laws (such as the European AML/CFT Directive and FinCEN regulations in the United States), and expects the same commitment from its Employees and Partners.
Example of a situation that an Employee may be confronted with:
- A customer or supplier wants to make a cash payment of a large amount.
- A transaction involves a high-risk country without clear justification.
What are the behaviors to adopt?
✓ Refuse any suspicious payment, including cash beyond the legal limits.
✓ Verify the identity and reputation of customers, suppliers, and partners before any business relationship.
✓ Immediately report any suspicious transactions or behavior to the HR Department or the Finance Department.
ARTICLE 3 – RESPECT FOR WORKERS
Kurmi Software undertakes to comply with international and local regulations on labor law and, in particular, the conventions of the International Labor Organization (ILO) and expects its Partners to comply with these regulations in the same way.
Kurmi Software prohibits any infringement of the rights of people and property.
Kurmi Software undertakes not to solicit, in the conduct of its business, workers who do not benefit from decent and acceptable working conditions.
Kurmi Software strictly prohibits child labor in the context of its activity and prohibits the solicitation of labor that is the victim of forced labor or illegal labor, and who does not benefit from decent and acceptable working conditions as defined by ILO conventions. Kurmi Software refuses to work with Partners who do not respect these principles.
Kurmi Software is committed to upholding international human and labor rights.
3.1. PRECARIOUS LABOUR AND FORCED LABOR
Precarious labor refers to the employment of workers, often in substandard conditions, at very low wages, without adequate social protection, and/or with restricted fundamental rights. This type of workforce often:
- Has little or no qualifications,
- comes from vulnerable groups (migrants, women, minorities, etc.),
- is located in countries with less protective social legislation.
Kurmi Software undertakes not to resort to or fight against illegal or concealed work and to offer its Employees a decent salary.
Forced labor is defined as any work or service that is demanded of an individual under the threat of any penalty and for which that person has not offered himself or herself voluntarily.
This includes withholding identity documents, contractual debts, threatening unfair dismissal, or deprivation of freedom of movement.
The Living Wage consists of a salary sufficient to allow a worker and his family to live with dignity, cover their essential needs (housing, food, health, education, transport), with a margin for the unexpected. It differs from country to country and is often regulated by a legal minimum wage.
Illegal or concealed labor consists of any professional activity carried out in violation of legal obligations, in particular:
- Concealed work (failure to declare to the social and tax authorities).
- Employment of workers without a valid residence permit or work permit.
- Fraudulent posting, circumvention of residence and employment rules.
- Failure to comply with reporting or contractual obligations (e.g. no pay slip, lack of written contract).
3.2. CHILD LABOR
Child labor refers to any economic or professional activity carried out by a minor below the minimum legal age for work (usually 16 years old), and/or likely to harm his or her health, development, or schooling.
Example of a situation that an Employee may be confronted with:
- You notice or have doubts about the fact that a supplier uses children or forced laborers in the course of its activity and does not comply with the principles defined by the ILO.
What are the behaviors to adopt?
✓ Inform the HR Department immediately with as much detail as possible to allow for a full investigation.
✓ If the investigation concludes that the charges are true, the supplier’s contract will be terminated and Kurmi will no longer be allowed to do business with the supplier. Legal action may be taken.
ARTICLE 4 – FIGHT AGAINST HARASSMENT
Workplace bullying and sexual harassment is defined by French law (Labor Code and Penal Code), and also in European and American regulations. Kurmi Software is committed to providing its Employees and Partners with a healthy work environment where harassment has no place and has a firm policy on the matter. No situation of harassment, whether moral or sexual, can be tolerated, whether inside the company or outside.
Kurmi Software wants to remind that harassment is, in addition to being a professional misconduct, a crime punishable by law. Any proven harassment situation will be investigated, and the strictest measures will be taken against the offending person(s).
Please note also that Kurmi Software expects its Employees to adopt courteous and respectful communication with others.
4.1. WORKPLACE BULLYING
Workplace bullying is a set of repeated behaviors, with or without direct intent to harm, which have the effect of degrading working conditions, destabilizing, isolating, or harming a person’s psychological health. It can be characterized by constant and unjustified criticism, humiliation in meetings, and voluntary exclusion.
4.2. SEXUAL HARASSMENT
Sexual harassment is defined as any unsolicited sexual behavior, whether verbal, physical, or gestural, that creates an intimidating, offensive, or degrading environment. These behaviors don’t need to be repeated for harassment to be characterized.
It is not possible to list all acts or behaviors that may be considered sexual harassment. However, the following behaviors may constitute such harassment: unwelcome sexual advances, offensive and/or unwanted physical contact, requests for sexual favors, sexual jokes or epithets, explicit or offensive pictures, gossip about sexual activity or proclivity, comments, including compliments, about a coworker’s appearance, body or clothing, questions about a co-worker’s personal or sexual life, discussions about your own sexual or personal life, unwelcome leering, whistling, or suggestive or insulting comments.
Kurmi Software will deal with any act of harassment with the utmost firmness. As harassment is a crime, the person(s) responsible may be subject to criminal prosecution.
Example of a situation that an Employee may be confronted with:
- You witness a scene where one of your colleagues makes a degrading and disrespectful comment about another colleague.
- A colleague makes sexual advances to you even though you are not receptive.
What are the behaviors to adopt?
✓ Inform the HR Department or your manager immediately with as much detail as possible to allow for a full investigation. An investigation will be carried out by the HR Department.
✓ Use the whistleblowing system provided by Kurmi Software.
✓ You have nothing to fear, as a whistleblower, you are protected, and no action can be taken against you.
✓ Any false voluntary testimony may be subject to sanctions.
ARTICLE 5 – INCLUSION & DIVERSITY, FIGHT AGAINST DISCRIMINATION
Kurmi Software is committed to equal opportunities. Diversity is key for Kurmi Software, it is the unique composition of profiles, personalities and backgrounds all gathered around strong core values and a solid culture. Its purpose is to ensure equal employment opportunities for all Employees, to prevent unlawful discrimination against anyone working for or with Kurmi Software, and to provide a mechanism for individuals to report any concerns about discrimination or harassment to the attention of the company.
Every individual is expected to treat others with dignity and respect. Kurmi Software is committed to maintaining a safe working environment in which Employees and Partners are not subjected to different treatment due to legally protected characteristics.
Direct discrimination is a situation in which, based on a criterion mentioned by law (origin, sex, family status, state of health, disability, age, surname, etc.; see below), one person is treated less favorably than another is, has been, or will have been treated in a comparable situation.
Indirect discrimination is a provision, criterion, or practice which is neutral in appearance, but which is likely to place persons at a particular disadvantage in relation to other persons on any of the grounds set out below, unless that provision, criterion, or practice is objectively justified by a legitimate aim and the means of achieving that aim are necessary and appropriate.
Discrimination includes:
- Any act related to any of the grounds mentioned below and any act of a sexual nature, suffered by a person and having the object or effect of violating his/her dignity or creating an intimidating, hostile, degrading, humiliating, or offensive environment;
- Directing anyone to engage in discriminatory behavior.
Therefore, Kurmi Software will not tolerate any discrimination or differential treatment of Employees and Partners based on the following characteristics:
- Age
- Ancestry
- Caregiver Status
- Disability
- Domestic Violence Victim Status
- Employment Status
- Gender
- Gender Identity/Expression
- Genetic Information
- HIV Status
- Health Care Status
- Marital or Familial Status
- Military/Veteran Status
- National Origin
- Pregnancy
- Race, Ethnicity or Color
- Religion
- Sexual Orientation
- Reproductive Health Decisions
- Whistleblower
As the criteria for discrimination may vary from one country to another, this list is not exhaustive.
Kurmi Software will deal with any act of outright discrimination with the utmost firmness. As discrimination may constitute a crime, the person or persons responsible may be subject to criminal prosecution.
Example of a situation that an Employee may be confronted with:
- A person is excluded from a project because of their sexual orientation.
- A person is mocked by his colleagues because of his visible disability.
What are the behaviors to adopt?
✓ Immediately notify the team manager and the HR Department so that they can investigate the situation and investigate.
✓ As a manager, prevent discrimination and remind people of the rules in force regularly. Pay particular attention to weak signals (discrete, ambiguous or isolated cues).
ARTICLE 6 – HEALTH, SAFETY, AND WORKING CONDITIONS
Kurmi Software is committed to health and safety in order to protect the health and physical and mental well-being of its Employees.
To guarantee this commitment, Kurmi Software regularly follows the evolution of the risks and adapts prevention measures, whether primary, secondary, or tertiary, to ensure that these risks are controlled. This document is available on the company’s HR Confluence page.
Kurmi Software also regularly trains all its managers in the prevention of psychosocial risks.
As the health and safety of Employees and the respect for good working conditions also involve a work/life balance, Kurmi Software has established a Global Charter of the right to disconnect and to balance professional and personal life.
Kurmi Software requires its Partners to have a comparable commitment and strict compliance with the regulations in force and to take the necessary measures to ensure a safe and healthy working environment for their employees.
Example of a situation that an Employee may be confronted with:
- An employee presents signs of unhappiness at work (e.g. unusual irritability, isolation, unusual change in behavior, etc.).
- An employee is the victim of an accident at work or on the way to work.
What are the behaviors to adopt?
✓ Immediately notify the HR Department so that it can intervene and/or make the necessary declarations.
✓ As a manager, anticipate these risks and ensure regular follow-up with your employees.
ARTICLE 7 – OUR RULES OF BUSINESS CONDUCT
Kurmi Software is committed to promoting and respecting free, fair and equitable competition in all markets in which it operates. Kurmi Software is also committed to complying with local and international regulations relating to the principles of business conduct and competition law. This commitment applies to all of its activities, its relationships with its customers, suppliers and partners, as well as its actions on national and international markets.
The rules of good conduct in the fight against corruption are specified in Article 2 of this Code.
Kurmi Software expects its partners to adopt the same high standards of fairness and compliance with competition rules.
Kurmi Software ensures that competition rules are respected so that it is fair and equitable. No action by Kurmi Software shall prevent, restrict or distort competition.
Kurmi Software rejects all unfair commercial and competitive practices, including any agreements with competitors or concerted practices regarding financial terms, distribution of services, markets or customers.
Kurmi Software prohibits informal agreements or any concerted practice or informal discussion which has the effect or objective of restricting free or fair competition.
Kurmi’s financial terms are set independently.
Example of a situation that an Employee may be confronted with:
- A Partner offers you a questionable process in order to obtain a contract.
- A Partner seeks to disparage a competitor to prejudice it in a call for tenders.
What are the behaviors to adopt?
✓ Systematically refuse questionable proposals that may be unfair competition and notify your manager immediately.
✓ Alert the HR Department of any action relating to unfair competition.
ARTICLE 8 – CONFIDENTIAL INFORMATION & PERSONAL DATA PROTECTION
Kurmi Software takes the greatest care to protect its confidential information as well as that of its Employees and Partners.
The rules of confidentiality and data security are defined by the Chief Information Security Officer. The rules applicable at Kurmi Software in terms of the use of internal tools and data are set out in the IT Charter shared with all Employees upon their arrival in the company.
Each Employee undertakes to respect the principles of confidentiality and respect for confidential information. This obligation is in the employment contract.
Kurmi Software also complies with the General Data Protection Regulation (GDPR). The rules applicable within the company are defined by the DPO (dpo@kurmi-software.com). All the information that Employees may need is available on the Confluence Finance & Legal page.
Kurmi Software is responsible for the protection of personal data. It treats personal data with care and limits collection and access to it to protect the privacy of individuals.
Kurmi Software ensures that personal data is kept secure and confidential.
Example of a situation that an Employee may be confronted with:
- A person requests personal information about a Kurmi Software Collaborator.
- An individual uses an unsecured means to transmit confidential information.
What are the behaviors to adopt?
✓ Make sure that this person has the right to have access to this personal information. If in doubt, do not pass on the information and notify your manager or the HR Department
✓ Alert the person that the means used is not secure so that they can stop sharing and secure the data in question. If there is a proven risk, notify the CISO.
ARTICLE 9 – SOCIETAL AND ENVIRONMENTAL COMMITMENTS
9.1. COMMITMENTS TO THE COMMUNITY AND LOCALITIES
Kurmi Software is committed to conducting its business responsibly, contributing positively to the development of local communities, and preserving the environment.
Kurmi Software is committed to supporting local economic development, in particular through job creation, the use of local suppliers, and solidarity actions when possible (volunteering, sponsorship). Kurmi Software complies with local regulations and engages with stakeholders to meet their needs.
Kurmi Software encourages its Employees to conduct their business in a manner that respects the community and the communities in which they operate.
9.2. COMMITMENTS TO THE ENVIRONMENT
On the environmental front, Kurmi Software is committed to preventing pollution, optimizing waste management, limiting nuisances, and acting in favor of biodiversity. Kurmi Software regularly raises awareness among its employees about good ecological practices and regularly monitors its impact, in particular by calculating its carbon footprint and implementing actions to reduce it.
Kurmi Software’s role is to contribute to the deployment of environmental policies, promote the sharing of best practices, and encourage innovation in this field.
As such, Kurmi Software is committed to integrating corporate social and environmental responsibility concerns into its actions and strives to be a responsible corporate citizen.
Aware of the environmental impact of business activities, Kurmi Software is committed to identifying and complying with all legal and regulatory obligations relating to the impacts of its activities on the environment.
Kurmi Software expects its Partners to adopt the same principles of social and environmental responsibility.
ARTICLE 10 – SANCTIONS
Failure by an Employee to comply with the applicable legislative provisions and this Code of Conduct may result in a disciplinary sanction that may include dismissal for serious or gross misconduct, regardless of any civil and criminal proceedings that may be initiated with regard to the violations observed, in accordance with the Internal Regulations/Employee Handbook in force at Kurmi Software and the legal provisions in force.
We remind our Employees that acts of corruption and/or influence peddling are punishable under local regulations, some of which have an extraterritorial scope. An act committed in one state can be punished in another. This is the case for legislation such as the Act on Transparency, the Fight against Corruption and the Modernisation of Economic Life (known as “Sapin 2”) for France, and the Foreign Corrupt Practices Act (“FCPA”) for the United States.
The risks of sanctions for Kurmi Software are criminal convictions with significant fines, publicity measures, prohibitions on bidding in the context of public contracts, the impossibility of raising funds, and an impact on its image and reputation.
Any individual conviction may result in consequences for Kurmi Software.
ARTICLE 11 – ALERT PROCEDURE
In the event of doubt about the conduct of a third party or an Employee, or proven facts that would go against the provisions of this Code and of which the Employee and/or the third party is personally aware, it is essential that the latter, acting disinterestedly and in good faith, alerts his/her line manager, or the HR Department.
A whistleblower policy is applicable at Kurmi Software and specifies the terms and conditions for filing and processing whistleblowing, as well as the protection measures for whistleblowers and actors who have actively participated in the launch of this whistleblowing.
The alert must be sent by completing a form accessible via the HRIS.
Any natural or legal person may use this whistleblowing channel if they have identified behavior or action that would be in contradiction with this code.
ARTICLE 12 – NEED INFORMATION?
In case of doubt or for any need for clarification as to the terms of this Code, you can contact the HR Department by submitting the Contact Us form.
