Tech Tribes Code of Conduct

 

Message from the CEO 

At Tech Tribes, we believe that technology truly makes an impact through the power of people who are collectively committed to progress. That is why everything within our group revolves around optimal collaboration, knowledge sharing, and inspiring each other – both within and outside our Tribes. We are building a challenging, supportive, and inclusive work culture where everyone can apply their passion for technology, develop themselves, and proudly collaborate on groundbreaking results.

 

Tech Tribes is a vibrant community of entrepreneurial doers, innovative thinkers, and true team players. What binds us? Shared values, the courage to innovate, and the conviction that true transformation begins with human ambition and connection. Here, people are central, we prove that diversity and enjoyment lead to the strongest teams, and together we strive for impactful results – for ourselves, for our customers, and for society.

 

This Code of Conduct is a reflection of our values and norms, and I encourage everyone to adhere to it. Together, we can make a positive impact on our customers and society.

 

Sincerely,

 

Benjamin Goesaert

 

CEO, Tech Tribes

 

Who does this Code of Conduct apply to?

This Code of Conduct serves as the compass for everyone working for Tech Tribes or one of its individual Tribes; employees, partners, interns, freelancers, temporary workers, agency workers, and directors.

 

It reflects our shared norms and values, and explicitly outlines how we, as Tech Tribes, interact with each other and the world. Only by collectively adhering to these standards can we achieve our ambition: realizing technological change and ensuring that people become stronger and happier as a result.

 

Tech Tribes encourages its suppliers to implement policies that align with this Code of Conduct and to respect its rules. Should there be a suspicion of a breach of the provisions of this Code of Conduct, Tech Tribes may require the supplier to take measures to comply with the Code of Conduct. This also applies to customers and other partners of Tech Tribes.

 

Code of Conduct

Tech Tribes and its Tribes adhere to all applicable (inter)national laws and regulations, industry standards, and behavioral principles. Integrity, honesty, and diligence always form the basis for decision-making and collaboration, both within and outside the organization. We actively distance ourselves from corruption, conflicts of interest, bribery, extortion, fraud, money laundering, and other forms of unethical or illegal behavior. We have zero tolerance for these. Suppliers and partners are selected based on clear, objective, and ethical criteria.

For the information of our employees, references to relevant internal documents are also included.

 

Well-being and Work Environment

Tech Tribes stands for openness and trust. We create a safe, healthy, and respectful work environment for all employees, partners, and suppliers. We comply with applicable laws and regulations as a minimum and align with internationally recognized standards for working conditions, health, and well-being.

 

We foster a diverse and inclusive culture where everyone can develop their talent and ambition. Psychological safety, open communication, and accessibility are paramount, ensuring that everyone feels respected, valued, and supported. Inappropriate behavior is not tolerated. This includes, among other things, sexual advances, unwanted comments or touching, aggression and verbal or non-verbal violence, bullying, and all forms of discrimination.

 

Within our organization and supply chain, we periodically conduct risk analyses and evaluations, with appropriate control and precautionary measures and clear procedures. Timely identification, sharing, and follow-up of (potential) risks and incidents are an integral part of our collaboration with employees and suppliers. Our processes, facilities, workplaces, and assets demonstrably comply with laws and regulations and internal policy frameworks. We strive for continuous improvement and promote healthy and sustainable working, including appropriate training, tools, and preventive measures.

 

Human Rights, Anti-discrimination, and (Modern) Slavery

Tech Tribes respects all internationally recognized human rights for employees, candidates, customers, suppliers, partners, and other stakeholders. We maintain zero tolerance for discrimination, aggression or violence, (sexual) harassment, bullying, exploitation, and other undesirable behaviors. Everyone is treated equally and with respect, regardless of gender, gender identity, sexual orientation, age, race or ethnicity, skin color, nationality, religion or belief, marital status, health, (functional) disability, contract type, or union membership. We promote a diverse and inclusive work environment with equal access to information, opportunities, and development, and make reasonable accommodations where necessary.

 

Modern slavery in all its forms is prohibited, including forced or compulsory labor, human trafficking, debt bondage, involuntary (prison) labor, and child labor. Illegal employment and participation in the grey or informal economy are rejected.

 

Employment conditions are fair and transparent. All employees receive a written, understandable, and legally valid employment contract. Working hours, breaks, rest periods, and leave at least comply with applicable laws and regulations and collective labor agreements; remuneration is correct, timely, and sufficient to meet basic needs; any deductions are made solely according to the law and in a transparent manner. Freedom of association and the right to collective bargaining are respected, including constructive dialogue about fair remuneration and working conditions.

 

We expect suppliers and customers to adhere to these standards, both within and outside the EU. Within the EU, applicable legal and collective agreements apply; outside the EU, at least local legislation and internationally recognized standards apply.

 

Tech Tribes provides clear reporting procedures and confidential channels for concerns or suspicions of human rights violations or undesirable behavior, including in customer environments. Reports made in good faith are handled carefully, discreetly, and without retaliation. In case of violations, we implement appropriate remediation, due diligence, audits, and improvement plans to restore compliance and prevent recurrence.


Acting with Integrity

At Tech Tribes, we make decisions based on objective, commercial considerations. Employees avoid any activity, relationship, or interest that leads or could lead to (the appearance of) conflicts of interest. The interests of Tech Tribes and personal interests must not conflict. Employees do not abuse their position for personal gain and do not use or share confidential information from customers, suppliers, partners, or colleagues for personal benefit or with third parties. Potential or alleged conflicts of interest must be reported immediately and in writing to the manager or the next management level.

 

The selection of suppliers and other business decisions proceeds transparently and is based on merit, quality, price, and integrity. Personal relationships or interests must not influence outcomes and must not give the appearance that they do.

 

Extortion, Bribery, Corruption, and Criminal Acts

Tech Tribes maintains a zero-tolerance policy regarding extortion, bribery, corruption, and other criminal acts, in all countries and contexts in which we operate. Employees, managers, and third parties acting for or on behalf of Tech Tribes must never, directly or indirectly, offer, give, promise, award, ask for, receive, accept, or authorize money or anything of value to obtain, retain, or direct an improper business or personal advantage. This applies equally to facilitating payments, forced payments, and quid pro quo arrangements. Anti-trust violations, such as cartel agreements or market allocation agreements, are strictly prohibited; Tech Tribes supports free and fair competition.

 

Gifts, hospitality, and entertainment may only be offered or accepted if they are transparent, proportionate, and appropriate to the nature of the relationship, are never intended or understood as influence, and are correctly recorded in our administration. Cash or cash equivalents (such as gift cards) are not permitted. As a rule of thumb, the value of a gift is a maximum of EUR 100.00; any offer or acceptance requires prior approval from the manager or a designated member of the management team. Interactions with government officials have extra strict safeguards: any gift, invitation, or contribution requires prior written approval from the management team or the Compliance function. Political donations and charitable contributions are only made on behalf of Tech Tribes after explicit prior approval; personal contributions are permitted, but never on behalf of or at the expense of Tech Tribes.

 

Tech Tribes expects the utmost diligence in preventing and reporting (potential) conflicts of interest. Employees and third parties must report conflicts of interest that could harm objectivity in a timely manner so that appropriate measures can be taken. We do not conduct business with third parties to circumvent prohibited actions: due diligence, clear contractual obligations, and oversight are mandatory for agents, consultants, suppliers, and other intermediaries, especially if they have contact with governments or strategic partners.

 

Integrity and transparency form the basis of our accounting and reporting. All payments and transactions must be accurately described and fully documented. Fraud, embezzlement, money laundering, tax evasion, deception, theft, the (financing of) terrorist activities, or related criminal offenses are prohibited and will lead to disciplinary measures, including immediate dismissal and, where applicable, reporting to the authorities and termination of collaborations.

 

Everyone at Tech Tribes has the duty to immediately report (suspicions of) bribery, corruption, fraud, conflicts of interest, and other integrity violations through their manager, or the (anonymous) reporting channel. Tech Tribes protects individuals reporting in good faith against retaliation. Compliance with legislation, this Code of Conduct, and internal guidelines is a core task for every employee and every third party acting for or on behalf of Tech Tribes.



Data Protection, Information Security, and Privacy

Tech Tribes respects the privacy of employees, customers, suppliers, and other business partners and processes personal data only when necessary for clearly defined, legitimate, and communicated purposes. We strictly adhere to all applicable data protection laws and regulations, including the GDPR, and apply the principle of data minimization: we collect no more data than necessary, retain it no longer than necessary, and do not use data for new purposes without an appropriate legal basis and transparent communication. Individuals whose data we process can count on clear information about the processing and careful handling of their rights, such as access, rectification, erasure, restriction, and portability.

 

Information security is an integral part of our daily practice. Tech Tribes takes appropriate technical and organizational measures to ensure the confidentiality, integrity, and availability of data, including risk assessments, access control based on "need to know," encryption where appropriate, secure storage and transfer, and periodic checks and audits. Sensitive business information, including personal data, customer and pricing information, and intellectual property, is never unnecessarily shared or publicly discussed and is retained or destroyed in accordance with contractual and legal obligations. For high-risk processing activities, we apply privacy by design and privacy by default and conduct a data protection impact assessment where necessary.

 

Every employee is responsible for the careful handling of personal data and confidential information. This includes keeping data correct and up-to-date, sharing it only with individuals who need it for their work, and avoiding unnecessary copies or exports. Suspected data breaches or security incidents must be reported immediately through the designated internal reporting channels, so that appropriate measures can be taken and, if required, notifications to supervisory authorities and affected parties can occur in a timely manner. Processing by third parties takes place exclusively on the basis of written agreements that comply with legal requirements; transfers outside the EEA only occur with adequate safeguards.

 

Tech Tribes maintains a privacy and security management system that evolves with legislation, standards, and risks. This includes continuous improvement, training, and awareness for employees, and providing the necessary resources to ensure compliance. Suppliers, intermediaries, and other partners working for or with Tech Tribes must apply the same principles and standards, ensure full compliance with relevant legislation, and promptly inform us of incidents or material risks, so that we can take appropriate measures together. In this way, we protect the interests of all stakeholders and trust in our organization.


Whistleblower Procedure

Tech Tribes encourages everyone who works with or for us to safely report suspicions of wrongdoing. Employees, suppliers, and other partners can report (potential) violations of this Code of Conduct, including bribery and corruption, fraud, unfair competition, market abuse, human rights violations, information security and privacy incidents, working conditions, health and safety, the environment, and unauthorized use of entrusted resources or brand names.

 

Reports can be made through the manager or the independent (optionally anonymous) reporting channel listed on the intranet and our website. External reporters (such as suppliers) can also use this channel. We confirm receipt and inform the reporter, where possible and legally permissible, about the progress and outcome of the investigation.

 

Tech Tribes ensures the confidentiality, integrity, and security of reports and protects the identity of whistleblowers and those involved. Reporters acting in good faith and based on reasonable suspicions are protected against any form of retaliation, discrimination, or disadvantage. This protection also applies to individuals assisting the reporter or associated with the report. Intentionally false or misleading reports are not permitted and may lead to measures.

 

We handle every report carefully, independently, and impartially, take appropriate corrective actions, and comply with applicable laws and regulations, including any obligations to inform authorities. In this way, we ensure an open and honest reporting culture.