Responsible Business Conduct
Good business behavior
Respect for business ethics and the rule of law are a precondition for a fair and sound business environment. SimCorp’s 'Guidelines for Good Business Behavior' guide our employees’ daily decisions to act within our core business principles and reinforce our compliance culture. It covers a wide range of issues, including anti-bribery and corruption, conflict of interest, anti-bullying and anti-harassment, respecting human rights and labor rights and maintaining high standards for data privacy and information security.
As part of our onboarding program, all employees must confirm compliance with our Guidelines for Good Business Behavior and, annually, complete the mandatory associated e-learning program.
Responsible procurement
Code of conduct for suppliers
We also extend ethical requirements to our suppliers in our Code of Conduct for Suppliers. The Code of Conduct has been established as a contractually binding framework to guide and support external parties to act in accordance with SimCorp’s values and its core principles and requires suppliers to apply similar standards to companies within their own supply chain. These principles include requirements relating to human rights and labor practices (such as anti-harassment, discrimination, and equal opportunity), governance impacts (such as antibribery and corruption) and other sustainability issues (such as environmental protection and climate change).
SimCorp's Code of Conduct for Suppliers
Self-assessment of suppliers
Further, in 2022, we added sustainability requirements to our sourcing process. Major suppliers are being asked to complete a self-assessment ESG questionnaire, where they are expected to demonstrate that they are in alignment with our sustainability standards and have the required ESG processes and policies in place.
Human rights and labor rights
Human and Labour rights policy
We are are dedicated to respecting human rights, and we strive to prevent any kind of modern slavery related to our business and our supply chain. We are committed to respecting all internationally recognized human rights in our dealings with employees, workers in our supply chain, and anyone else connected to our business. SimCorp is a signatory to the UN Global Compact and we support the rights set forth in the International Bill of Human Rights and the core Conventions of the International Labor Organization (ILO).
Statement on Modern Slavery Act - SimCorp’s Statement on Modern Slavery Act sets out our actions to identify and understand all potential modern slavery risks related to our business and to put in place steps that are aimed at ensuring that there is no slavery or human trafficking in our own business and in our relations with external partners.
Whistleblower policy - SimCorp provides a whistleblower system for internal or external parties to report any potential misconduct without fear of retaliation, whether they are employees, suppliers or other business partners.
Data privacy and security
SimCorp maintains an Information Security Policy, based on ISO 27001 principles, which defines the security-related rules and requirements for use of Information Technology across the company. The policy ensures the accessibility, performance, confidentiality, and integrity of the IT infrastructure and applications and is applicable to all SimCorp employees.
Our Privacy Policy is compliant with EU General Data Protection Regulation (GDPR) and informs contacts about their right to insight, deletion, and to complain about the processing of personal data. Further, we provide Employee Privacy Policies detailing the information gathered and used by SimCorp during the course of the employee’s employment with SimCorp.
Responsible and secure handling of our client’s data has always been part of SimCorp’s DNA
Data security is crucial to the way we develop products and services that handle a significant amount of client financial data. In general, SimCorp does not process data when developing software. However, our clients use our products in the processing of large amount of financial data and to make decisions on investments that eventually concerns individuals. The functionality of our products therefore has a big impact on our clients’ data processing. It is thus a core value for SimCorp that our products are built and set up to provide the opportunity to exercise ethical and responsible data processing.
Additionally, all our employees undergo mandatory GDPR compliance and IT security courses as part of our online learning.
Norwegian Transparancy Act/Åpenhetsloven
SimCorp is a large, international group with entities out of many countries, including several European, and with one of them being in Norway, SimCorp recognises the need to comply with the Norwegian Transparency Act. While we are working with the headline of Human Rights and Labour Rights based in international principles, including the United Nations Universal Declaration of Human Rights, the UN Guiding Principles on Business and Human Rights, the OECD Guidelines for Multinational Enterprises, we also recognise the need to address our work specifically under the Transparency Act.
With offices, clients and suppliers all around the world, SimCorp recognises the need to assess our potential and actual impact. Last year, we concluded a double materiality assessment, the result of which is included in our Sustainability report. The focus of the assessment was to identify key areas ESG which our employees and clients values, and wants SimCorp to focus on. This year, we have started delving deeper into this assessment, in order to identify the actual and potential impacts, risks and opportunities, that SimCorp either have or creates, both among our employees, clients and suppliers.
Though the work with locating our actual and potential impacts is not yet finalised, we do expect our employees and suppliers to comply with our policies, including our Supplier Code of Conduct (link) and the Human and labor rights policy.
We encourage you to use our external Whistleblower site if you are aware of any breach of the policies. You can read about how we handle any reports through the Whistleblower site in our Whistleblower policy.
Once our work with assessing our potential and actual impacts is finalised, any impacts found will be handled by relevant internal and external stakeholders, which can include Procurement, Legal, Sustainability and suppliers as needed.
To minimise any potential negative impacts and risk, we ask all suppliers to acknowledge our Supplier Code of Conduct when entering into a contract with SimCorp, and perform due diligence assessment on relevant suppliers, which, as needed, can include topics such as sustainability, workers rights and data protection.
Our work with human rights and labor rights is detailed in our Human Rights policy.