This Code of Ethics aims to establish the ethical standards, professional values and integrity principles of OMADUDU N.V. The Code provides a binding framework for all internal and external stakeholders acting on behalf of or in cooperation with OMADUDU N.V.
1. Scope
This Code applies to:
1.1 All employees, managers and directors of OMADUDU N.V.
1.2 External consultants, suppliers, partners and other third parties acting on behalf of OMADUDU N.V.
1.3 All entities within OMADUDU N.V. and its service lines.
2. Core values and principles of conduct
OMADUDU N.V. adheres to the following fundamental values:
2.1 Integrity — We act honestly, transparently and in accordance with applicable laws and regulations.
2.2 Accountability — Individuals are accountable for their actions and the consequences thereof.
2.3 Respect — We treat colleagues, customers and partners with respect, dignity and equality.
2.4 Transparency — Decisions and processes are documented and auditable.
2.5 Professionalism — We strive for excellence in service delivery, communication and collaboration.
3. Anti-corruption and conflicts of interest
3.1 Zero tolerance: OMADUDU N.V. has zero tolerance for corruption, bribery or conflicts of interest.
3.2 Prohibition of bribery: Giving or receiving gifts, payments or advantages intended to influence business decisions is prohibited.
3.3 Reporting conflicts of interest: Employees must promptly report potential conflicts of interest via the compliance channel or to their manager.
4. Confidentiality and data protection
4.1 Confidential information: All company information, customer data and intellectual property are treated as strictly confidential.
4.2 Privacy: OMADUDU N.V. complies with Surinamese privacy legislation. Processing of personal data is performed in accordance with the Privacy Statement.
5. Compliance with laws and regulations
5.1 OMADUDU N.V. complies with all applicable international, national and local laws and regulations.
5.2 Employees should be aware of relevant compliance requirements, including export controls, tax laws and industry-specific standards.
6. Dealing with customers, suppliers and partners
6.1 Fair competition: We compete on the basis of quality, reliability and service — not through unethical practices.
6.2 Objective selection: Suppliers and partners are selected based on transparent and objective criteria.
6.3 Contractual compliance: All contracts include provisions on compliance with this Code and related policies.
7. Whistleblowing and incident reporting
7.1 Reporting channel: Employees may report suspected violations or unethical conduct to [email protected] or via the internal reporting portal.
7.2 Protection against retaliation: OMADUDU N.V. guarantees protection for whistleblowers who report in good faith.
7.3 Investigation and follow-up: All reports are handled confidentially and investigated by the Compliance department.
8. Enforcement and sanctions
8.1 Violations of this Code may result in disciplinary measures, including:
8.1.1 Written warning
8.1.2 Suspension or termination of employment
8.1.3 Criminal prosecution for serious breaches
9. Responsibilities and oversight
9.1 Executive management: Holds ultimate responsibility for enforcement and compliance with this Code.
9.2 Managers: Act as role models and are responsible for actively communicating this Code within their teams.
9.3 Compliance department: Monitors compliance, conducts audits and advises on ethical matters.
10. Review and amendments
10.1 This Code is reviewed annually and amended where necessary.
10.2 Amendments take effect after approval by executive management and are communicated via internal channels.
11. References to related documents
11.1 Privacy Statement
11.2 Anti-Corruption Policy
11.3 MSP™ Terms & Conditions
11.4 CyberShield™ and CyberGuard™ Terms
11.5 Master Services Agreement
Versioning & changelog
12.1 Version 2.0.1 — 14 September 2025
12.1.1 Legal restructuring and harmonization
12.1.2 Addition of reporting procedures and sanctions
12.1.3 Integration with the Privacy Statement and Anti-Corruption Policy