This Code of Conduct describes the standards we hold ourselves to and that we expect from anyone we do business with. It applies to every DuoCircle employee, contractor, officer, director, and to vendors and partners while engaged with us. It exists in part because procurement teams at our customers reasonably ask whether we have one. The honest answer is yes, and this is it.
Honesty in commerce
We tell the truth. About what our products do, what they cost, and what they do not do. We do not name customers we do not have. We do not invent capabilities at the contract stage. If we say we will do something, we do it. If we cannot, we say so quickly so you can make a different decision.
Anti-bribery and anti-corruption
We do not pay bribes. We do not take bribes. We do not facilitate or look the other way on either.
| Item | Position |
|---|---|
| Cash payments to government officials | Prohibited without exception |
| Gifts to public officials | Prohibited without exception |
| Gifts to private-sector counterparties | Permitted only if nominal in value, customary for the local business culture, transparent, and not contingent on any pending decision |
| Entertainment and travel | Permitted only if reasonable, infrequent, and primarily business-related; lavish or junket-style entertainment is prohibited |
| Charitable donations on behalf of a counterparty | Prohibited if used as an inducement or in lieu of a gift; otherwise permitted with disclosure |
| Political contributions | DuoCircle does not make corporate political contributions |
| Facilitation payments | Prohibited |
We comply with the United States Foreign Corrupt Practices Act, the United Kingdom Bribery Act 2010, and equivalent statutes in jurisdictions where we operate. Vendor contracts include corresponding flow-down obligations.
Reporting concerns
If you observe or suspect a violation of this Code, including by anyone at DuoCircle, email ethics@duocircle.com. The address routes to the General Counsel and the CEO. We do not retaliate against good-faith reporters. Anonymous reports are accepted and investigated.
Equal opportunity and respectful workplace
DuoCircle hires, develops, promotes, and compensates people based on the work they do. We do not discriminate on the basis of race, color, ancestry, national origin, religion, age, sex, sexual orientation, gender identity, gender expression, marital or family status, pregnancy, disability, veteran status, or any other characteristic protected by law in the jurisdictions where we operate.
We expect a workplace where people are treated with respect. Harassment, discrimination, retaliation, and bullying are not tolerated, including by customers, vendors, and partners while interacting with our people. We will end commercial relationships when good-faith effort to address such conduct fails.
We believe a team made of people with different backgrounds and experiences makes better products. We hire to that. The objective is not a quota; the objective is a team that can see what a homogeneous team would miss.
Fair dealing with customers and vendors
We negotiate honestly. We honor our commitments. We pay our suppliers on time. We do not exploit asymmetric information. We do not use proprietary information shared with us in confidence to compete with the source of that information, beyond what the underlying agreement allows. We escalate disputes to a working conversation before legal process whenever possible.
Conflicts of interest
DuoCircle people disclose outside business relationships, vendor financial interests, and family ties to counterparties when there is any chance of an apparent conflict. The default is over-disclose. The General Counsel decides whether the conflict requires recusal, divestiture, or simply documentation.
Confidentiality
DuoCircle people protect customer, partner, and DuoCircle confidential information at the standard set out in the Mutual NDA. Confidentiality survives the end of employment or the relationship. The legal-process exceptions in the Legal Request Response Policy apply.
Use of DuoCircle products and infrastructure
DuoCircle people use DuoCircle products and infrastructure in compliance with the Acceptable Use Policy. Internal access to customer data is limited to legitimate business need under the security controls described in /legal/security/.
How this Code changes
We revise this Code when our business changes or when better practice emerges. Material changes are announced internally and posted here with a revision date. Continued employment, engagement, or commercial relationship after the revision date constitutes acceptance.
Earlier versions
Documents previously published as the DuoCircle Anti-Bribery Corruption (ABAC) Policy Statement and the DuoCircle Diversity, Equity and Inclusion Policy are superseded by this Code of Conduct.
Questions about this document?
DuoCircle LLC, 5965 Village Way, Suite 105-234, San Diego, CA 92130. Email legal@duocircle.com for legal inquiries, or support@duocircle.com for everything else.