Uphold and promote fair operating practices in dealing with Companies, Authorities and
Individuals. This can be achieved by:
• Refraining from any unethical transactions such as giving or accepting Bribes &
Unlawful or unjustified payments.
• Consider human rights, labor practices, the environment, consumers and
communities and the effects on them in our strategic decision making.
Our worldwide Customers, Accounts, Transferees and Interested Parties playing their
role in modern Society require us not to only provide excellent relocation Services but to
also exercise safe work practices, reduce the imprint of our activities on the
Environment, obey Human Rights, be ethical in our Business dealings, respect other
peoples’ privacy, give something back to society, and prove that we do so.
In order to make sure we all talk about the same thing when addressing these topics,
we have laid down our standards in this document - The Code. It gives us the standards
we abide by, and tells us how to use them, and what to do if the code is breached.
What is the Code?
The code outlines CML’s commitment in dealing with healthy and safe working
environment for employees, protection against harassment, and anti-discrimination
based on race, religion, disability and sexual orientation.
The code addresses establishing legal, ethical, honest and professional relationships
with Customers, Employees, Vendors, and Suppliers. In addition to anti-trust or anti-
competitive activities; especially top-level commitment to free and fair competition, such
agreements with potential competitors which prevents, restricts or distorts competition;
exchange of sensitive data regarding prices or quantities (including sales, market share,
territories or customers).
How to use The Code?
The Code in everyday practice
The reputation of our company and our network for integrity and honesty is built one
decision at a time and the Code of Conduct (our “Code”) was created to help all of us
make the right decisions.
Our Code, together with our company policies, give us the
guidelines we need to do the right thing, each and every day.
We are responsible for acting with integrity, understanding and adhering to The Code
and company policies, and following all laws and regulations that apply to our jobs.
As a member of Harmony Relocation Network, we can demonstrate our commitment to The
Code and its principles by:
• Always choosing to do the right thing.
• Ask questions about the right course of action when in doubt.
• Report Code violations.
Who must follow The Code?
Managers and Supervisors
Managers and supervisors are expected to promote The Code by:
• Addressing Employees about The Code and other relevant Policies and
Procedures making and comply with the applicable Legislations relating to
Staff’s recruitment and employment.
• Leading by Example.
• Appropriately respond to concerns and questions.
• Be aware of what is going on in their area and keep an eye out for misconduct.
• Avoid any actions or behavior that could be viewed as retaliation.
• Never excuse or promote violations of The Code or the law.
• Ensure that all operative crew personnel assigned to work at or in a
transferee’s private residence are known to them.
• Ensure that all personnel, whether direct employees or contractors are legally
entitled to work in the country which they are employed, are employed through
their own free will, are aged at least 15 years, are able to work free from
harassment of any kind, and are at least paid the national minimum wage.
Workers and staff
• Uphold the Code.
• Report a breach of one or more aspects of The Code if they notice any.
Suppliers & Subcontractors
Subcontractors performing work directly for the network must be aware of our
standards, commit to them and uphold them.
Speak up
We must always choose to do the right thing. This means we must speak up whenever
there are suspicions or concerns and address them the Manager or Senior
Management:
• When we have a question or concern about the lawful or ethical course of
action.
• When we believe or suspect that you or someone else has violated or may
violate the code.
Retaliation
Employees under CML Safe Pak are protected against retaliation through:
• Abiding to confidentiality and anonymity when handling employees’ complaints.
• Providing the employees with the safe space to speak up regarding any
discrimination problems or harassment complaints that they are facing without
implementing retaliatory circumstances.
• Informing employees on laws that protect them from workplace retaliation and the
different dimensions of retaliation; direct (such as demotion, firing and salary
reduction) or more subtle job actions.
• Offering employees with a clear and considerate reporting methodology against
any violation of the code or retaliation.
Retaliation
Employees under CML Safe Pak are protected against retaliation through:
• Abiding to confidentiality and anonymity when handling employees’ complaints.
• Providing the employees with the safe space to speak up regarding any
discrimination problems or harassment complaints that they are facing without
implementing retaliatory circumstances.
• Informing employees on laws that protect them from workplace retaliation and the
different dimensions of retaliation; direct (such as demotion, firing and salary
reduction) or more subtle job actions.
• Offering employees with a clear and considerate reporting methodology against
any violation of the code or retaliation.
Investigations
All reports of potential misconduct will be taken seriously and thoroughly investigated to
determine whether The Code or any Law or Regulation has been violated.
If you are asked to participate in an investigation, you must cooperate fully and answer
all questions accurately and truthfully.
Note that since confidentiality is maintained to
the fullest extent possible, you may not know all details of an investigation.
Working conditions and meaningful work
Our employees are our most important asset.
We are well aware that it is our dedicated
and hard working people who have made the company what it is today.
They are the face of our company and are in daily contact with our customers. We believe that happy,
satisfied employees not only feel better about their work but also take better care of
customers.
Therefore, CML ensures the well-being of the employees by complying with
contractual obligations towards employees.
The employment conditions which are
applied by CML are never averse to our employees.
We strive for fair contractual terms
in the employment contract because we believe in the benefits of fair, honest and
balanced relationships with our employees.
Through providing regular and continuous improvement opportunities such as trainings
for the employees, CML ensures enhanced productivity, which supports the ultimate
objective of CML, strengthening the customer satisfaction experience.
Occupational trainings to elevate the awareness and skills are also provided to our
crew, in order to ensure a safe and healthy environment throughout the complete
working process, which reflects positively to offer the customer a safe and dependable
platform of relocation services.
CML also stands for openness and transparency towards its employees.
Communication is a key element in motivating staff and workers; people who know what
is expected of them and know their role in delivering excellent service perform better
and safer.
Open and honest communication also creates understanding for and
involvement in the company’s decision making and goals.
Human Rights
Human rights are based on moral principles and standards.
They are understood as absolute fundamental rights to which a person is inherently entitled simply because she
or he is a Human Being, and which are inherent for all human beings regardless of their
Nationality, Residence, Language, and Religion, Ethnic Origin or any status.
We strive for Management and Strategies that are compliant with universal Human
Rights.
CML ensures that every development in our strategy or management is
compliant with human rights. It is strictly prohibited to conflict with human rights. For
example: CML maintains a strict policy against employing children.
Moreover, child labor is prohibited by law.
Harmony Relocation Network strictly prohibits discrimination, in any form. CML as a
member company adheres to this principle and does not discriminate in any form. It is
important to understand what discrimination is, only then can we prevent it.
Discrimination
the practice of treating a person or a particular group of people differently, especially
less favorably, than you treat other people, based on their skin color, sex, religion,
ethnic believes and so on. There is an important distinction between direct and indirect
discrimination. Direct discrimination is treating someone less favorably because of
certain attributes. Examples of direct discrimination include dismissing someone,
deciding not to employ them, refusing them training, denying them a promotion, or
giving them adverse terms and conditions because of a ‘protected’ characteristic.
The protected characteristics include: age, disability, gender reassignment, sexual
orientation, marital status and/or civil partnership, pregnancy and maternity, race,
religion or belief, sex, or other differences.
An example of indirect discrimination: An employer has a policy of not letting any staff
work part- time.
People with children or family responsibilities could be disadvantaged.
The policy may be fair, but it presents a disadvantage for those who have children, and
that makes the policy an act of indirect discrimination.
The employees of our members are mostly local nationals of the particular country. We
believe that local people know the country better than anyone else. Consequently, we
work with member companies with embedded local heritage. CML as party of Harmony
Relocation Network not only provides job opportunities, we respect the rights, traditions
and cultural values of the local nationals.
Ethical Business Practices
Ethical business practices are the philosophical core of our business and are crucial for
economic development. Business ethics are more than values and principles that
determine our conduct in the business world. Our ethical principles help build an honest
reputation and ensure the smooth running of our organization. Therefore, it is very
important to us that the principles are strictly pursued by everyone at CML.
We value our customers, members, agents, suppliers, and other business partners. We
treat these parties the way we want to be treated: fairly and honestly. It is our duty to
represent our organization accurately and use truthful sales and marketing practices.
Each one of us is accountable and responsible in the prevention of unethical business
practices.
We conduct business free of bribery and corruption. Laws around the world prohibit the
payment of bribes. We, as an international organization, must never offer, authorize, pay
or promise any form of bribe or kickback in order to further our business interests.
Bribes can include anything of value that might influence a person’s judgement or
conduct.
In addition to cash, bribes may be given as gifts, meals, job offers, contract awards or
other favors. Not only gifts to governmental officials can be considered bribes. Under
certain local laws, and under the internal policies of many organizations, business gifts
of entertainment provided to employees of private organizations may be considered
prohibited bribes or kickbacks. Check to make sure any business gift or entertainment
complies with the local laws in the area of the recipient, and if an individual is authorized
to accept it on behalf of his or her organization.
These rules apply to our own behavior, as well as to that of third parties conducting
business on our behalf. We must not use consultants, brokers, agents or intermediaries
if there is reason to believe that they endorse paying bribes or if some part of the
payment we make to them will be used for a bribe.
We compete fairly and in compliance with all antitrust laws. We must avoid any form of
discussions with competitors about actions and avoid activities that may appear to be
anti competitive, such as cartels.
Consumer affairs
The health and safety of our customers, as well as third parties, may be directly affected
by the safe performance of our operations. We are committed to taking measures to
prevent any action or situation that could pose a danger either to our customers, our
workers or third parties. CML is committed to our Health and Safety program, which
includes norms to prevent any danger of injury or ill health to our customers and to the
public health.
All advertisements must follow the rules and regulations of the local/national
government. Additionally, it should not contain any misleading information about the
service.
Our advertisers must have proper knowledge of ethical norms and principles, so they
can understand and decide what is correct and what is wrong or what can potentially be
perceived as wrong.
We believe that advertising carries with it a strong social
responsibility. Therefore, we must have a deep sense of social responsibility and norms.
When ethical norms are followed, our organization is able to answer for all its activities,
and reduce the chance of getting called out by critics or any regulatory body. This helps
in gaining the confidence, and trust of our prospects and customers.
Copyright © 2023 CML.