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Code of Ethics English PDF
Code of Ethics English PDF
July 2015
Code of Ethics | 2
Code of Ethics
and Business Conduct
Dear Colleague,
At Amdocs, we pride ourselves on our commitment to uphold the highest professional and ethical standards at all times.
The trust and confidence of our customers, shareholders, suppliers and employees is one of our greatest assets. Our success
depends on maintaining our reputation for integrity in everything we do.
We pledge to maintain the highest ethical standards, not only out of our legal obligation, but because we believe that it is
the right thing to do. I t is imperative that we all conduct ourselves honestly, fairly and with integrity in our dealings with
customers, suppliers and co-workers.
P lease take the time to read our Code and use it in guiding your day-to-day behavior on the job. As a valued member of the
Amdocs team, you represent the company and are personally responsible for full adherence to these standards.
S incerely,
Eli Gelman
President and Chief Executive Officer
Amdocs Management L imited
Code of Ethics | 3
Table of Contents
Introduction
Introduction
To access the Ethics When you access the hotline, you will be able to talk to a concerns. B y speaking up, you are helping us uphold an
Hotline: specially trained representative who will document your honest and ethical Amdocs.
concern in detail and relay the information to Amdocs for
Click here to submit an Amdocs’ Code complements the company’s policies,
action.
anonymous and confidential procedures and employment agreements. If you encounter
report about any unethical Depending on the nature of your concern, the information an inconsistency or conflict, discuss it with your Senior
behavior, theft or fraud in the will be forwarded to either the Amdocs’ Human R esources Leader Human Resources representative, or contact the
workplace. or I nternal Audit departments for investigation. All Compliance Officer to determine the proper course of action.
Code violations and the results of any investigations are
reported to the Audit Committee of the Amdocs B oard of
You can find the Directors on at least a quarterly basis.
Amdocs Code of Ethics What if a local law where I work
and Business Conduct on: conflicts with the Code?
Tip: I f you report a concern, it’s a good idea to
keep all relevant documents ( including computer As a company operating in a global marketplace, we
> The Amdocs intranet homepage,
discs, tapes, hard drive and audiotapes) in case there is an experience a wide range of social customs, rules and
under Corporate Governance
investigation. regulations, cultures and laws. We have an obligation to
Policies, and
comply with all applicable laws wherever we operate. I f a
> Amdocs.com. local law conflicts with the Code, you should follow the law,
You Are in Charge of Your Decisions and
Actions but please advise the Compliance Officer of the conflict. If
you find, however, that a local business practice conflicts
Always act legally and ethically even if someone tells you with the Code, you should follow the Code. Not sure? Ask
to do otherwise. R emember, no one has the authority to for help.
cause you to violate the law or the Amdocs Code of E thics
and B usiness Conduct. I t’s important to know and follow the Code at all times. Anyone
who violates the Code will be subject to disciplinary action,
I f you suspect illegal or unethical activities, share your which may include termination and, in some cases, legal action.
Code of Ethics | 6
Introduction
What You Might Be We Look to Managers to Lead with Integrity > Be there for your employees.
Concerned About: Help them understand the Code. E ncourage them to
Managers have a special responsibility: come to you with any questions or concerns they may
> Retaliation. E veryone can
> Set a good example. have and guide them when they need it.
raise concerns about illegal or
S erve as a role model for your employees. Model ethical > Stand by the Code.
unethical behavior without fear
behavior on the job and work according to Amdocs’ I n your day-to-day business, make sure policies and
of retaliation. Amdocs doesn’t
values, policies and procedures. procedures you develop fit into the framework of the
tolerate retaliation against
employees who speak up. > Support the annual signing campaign. Code. Take action to report any Code violations.
> Reporting Concerns about B e sure members of your team receive a copy of our
Your Manager. Use the company’s Code of E thics and B usiness Conduct and
Amdocs E thics Hotline. I t’s a that every year they certify that they have received and
confidential way to share your understand its importance.
concerns.
Introduction
Make Good Choices > Would you feel comfortable if everyone knew you did it?
> Would it be viewed positively by your co-workers, your
Amdocs counts on you to use good judgment in your
company and companies Amdocs does business with?
decision-making. B ut if you are ever faced with a complex
ethical situation and the right course of action is unclear,
ask yourself the following questions: I f you are in doubt as to any of the above or if you feel
uncomfortable about a situation, discuss it with your Senior
> I s it legal? Leader or your Human Resources representative, or contact
> I s it in line with Amdocs’ Code and other company policies? the Compliance Officer for guidance.
? I s it legal? NO
YES
If in doubt I f you can’t answer
? I s it in line with Amdocs’ Code and other
discuss it with your company policies?
NO Yes to these
Senior Leadrer, your YES
questions
HR representative, Don’t do it
or contact the ? Would you feel comfortable if everyone NO
knew you did it?
Compliance Officer YES
for guidance.
Would it be viewed positively by your
? co-workers, your company and companies NO
Amdocs does business with?
YES
Employment Principles
Respect for Amdocs’ Employees demotions, transfers, layoffs and terminations, and
disciplinary actions.
Amdocs’ employees are the company’s greatest asset. This
section of the Code includes policies that ensure that every These kinds of decisions are based solely on an individual’s
employee is treated with dignity and respect. performance, experience, training, work history and overall
job suitability.
Celebrate Amdocs’ Diversity
Amdocs is committed to providing employment
I think I may have been denied an off-
opportunities for all qualified candidates and does not
site training opportunity because of my
discriminate on the basis of race, color, religion, gender,
sexual orientation. What should I do?
sexual orientation, age, national origin, disability or All employment decisions must be made without regard
veteran status or any other status that is protected by law. to sexual orientation or any other status that is protected
by law. I f you feel you were treated unfairly, contact your
With thousands of employees serving customers in more Human R esources representative, the Compliance Officer
than 60 countries, Amdocs is proud of the diversity of or the Amdocs E thics Hotline.
cultures, experiences and talents we each represent.
Speak Out Against Discrimination Harassment: Recognize it, Report it.
Amdocs’ commitment to a diverse workforce is reflected As employees, we value and respect each other. We do not
in all its employment practices, including decisions about harass others based on their race, color, religion, gender,
recruiting and hiring, working conditions, appraisals, sexual orientation, age, national origin, disability or veteran
compensation and benefits, training, promotions and status or other status that is protected by law.
Code of Ethics | 9
Employment Principles
What You Might Be gender boundaries and involve people of the opposite sex
Concerned About: What is harassment? or the same sex.
Speaking Out on Behalf of Others. Harassment is when words or actions are used in a way that To ensure the protection of every employee, Amdocs has
You have a responsibility to act interferes with someone’s work or creates a work environment a sexual harassment policy that provides details about the
when you see or suspect a threat that is intimidating, hostile or offensive. Harassment can take kinds of behaviors that are considered to be harassment.
or risk to anyone at Amdocs. many forms including words, derogatory statements, signs, The policy also provides information on how to file a sexual
Notify your Senior Leader, your HR offensive jokes, cartoons, pictures, posters, e-mails, pranks, harassment complaint.
representative or the Compliance intimidation, physical contact or assault.
Officer or access the Amdocs B e sure you know, understand and follow Amdocs’ sexual
E thics Hotline. harassment policy. Details of the policy vary according
What if the person harassing me is my to local laws, but remember, Amdocs will discipline any
manager? I’m afraid that if I complain, employee who is found to be guilty of harassment. This
What You Need to Do: I’ll lose my job. may include dismissal.
You are a valued member of Amdocs and you have a right
> Treat others with dignity and to work without fear of intimidating, hostile or offensive
respect.
behavior from anyone, including your manager. I f you feel
> S upport and promote a
workplace that values all people, you are being harassed, contact your Human R esources Sexual harassment includes…
regardless of culture, background representative, the Compliance Officer or the Amdocs R equests for sexual favors, graphic verbal comments about
and life experience. E thics Hotline. a person’s body or sexually degrading descriptions of a
> I f you know or suspect that person. S exual harassment also includes the display of
others are being harassed or Sexual Harassment sexually suggestive objects or pictures at work or anything
discriminated against, report it that creates an uncomfortable environment that prevents
immediately. Any form of sexual harassment, including unwelcome
someone from focusing on his or her job.
> K now Amdocs S exual sexual advances of either a physical or verbal nature, is
Harassment Policy. strictly prohibited. S exual harassment can cross age and
Code of Ethics | 10
What You Might Be Amdocs respects the privacy of your personal information
Concerned About: and the workspace you use as an Amdocs employee. Tip: “ Company property” includes, for example,
> Sharing Private Information B e aware, however, that if the company suspects an desks, cupboards, computers, telephones, mail, voicemail,
about Employees. I f you are employee of illegal behavior, it has the authority to search e-mail and I nternet access.
ever unsure about what kind and monitor company property without notification
of employee data is considered in advance. Amdocs also reserves the right to search
private, ask. employee property, such as briefcases, bags and private
vehicles on Amdocs’ premises.
Think you may have a Respect for the Company Amdocs counts on you to make fair, objective decisions
conflict of interest? based on good business practices and not let personal
E ach of us has a responsibility to watch over our co- interests, associations or investments interfere—or appear
> Talk to your manager. workers, our company and our reputation. Policies in to interfere—with Amdocs’ interests.
> Document the facts in writing. this section of the Code will help you understand how
> S ubmit the information to the to protect Amdocs’ interests and use Amdocs’ resources What’s the best way to avoid a conflict of interest?
Compliance Officer. wisely. Be open and honest about your actions on and off the
job. Inform your Senior Leader about any outside activities
Avoid Conflicts of Interest or relationships (with customers, suppliers, competitors,
Amdocs respects your right to conduct activities and friends or family) that could influence your job
pursue interests outside of work. But a “conflict of responsibilities or the decisions you make at Amdocs.
interest” can occur whenever those activities or interests Together, you and your Senior Leader will document the
begin to interfere with your job responsibilities or affect facts in writing and submit them to the Compliance Officer
the way you make decisions as an Amdocs employee. for review, who will then provide you with advice on how
Conflicts of interest can happen to proceed.
when you...
Conflicts of Interest Can Take Many Forms
> Have a financial interest in an Amdocs competitor,
customer, supplier or vendor; Being aware of possible conflicts of interest can help you
> Take on a second job; avoid them. Make sure you’re familiar with the following
> Hire ( or work with) family or friends at Amdocs; situations which can present potential conflicts of interest:
> Take advantage of a business opportunity that rightfully Improper Investments
belongs to Amdocs; or
> S erve on the board of another company. Ask yourself: Do I or does any member of my immediate
family own or have a “financial interest” in an Amdocs’
competitor, customer or vendor?
Code of Ethics | 13
Is it okay for my neighbor to apply for a As an employee of Amdocs, you may sit in meetings with
What You Need to Do: job opening in the department I manage? customers or suppliers or read Amdocs company
> I f you think you might have documents and learn about opportunities to invest in
There is nothing to stop your neighbor from working for Amdocs’ customers, competitors or suppliers. You may
a conflict of interest, act you, but think about it carefully. E ven if you try to be
promptly. Notify your Senior not take advantage of this information for personal gain.
objective in your business dealings, the very fact that you
Leader, your Human Resources share a personal relationship can suggest the appearance Before participating in any business
representative or the of a conflict of interest. Before proceeding, discuss the venture or investing in any project…
Compliance Officer. situation with your Senior Leader. Get the written approval of the Group President of Human
Resources. If you are an officer at Amdocs, you must
What about family and friends who work obtain prior written approval from Amdocs’ Chief
for Amdocs’ competitors, customers, Executive Officer before proceeding.
suppliers, vendors?
Serving on the Board of Another Company
S ometimes, family members or friends may work for
Amdocs competitors or for companies that do ( or want to You may serve on the board of a community or nonprofit
do) business with our company. These kinds of situations organization as long as it does not interfere with your
can affect your ability to make objective decisions on work. However, if you wish to serve on the B oard of
behalf of Amdocs, so you must let your Senior Leader Directors of another company, you must first obtain
know about them in order to avoid a conflict of interest. approval from the Compliance Officer.
Bribes and Kickbacks are Illegal Executives of one of our company’s customers
What you need to do:
Never give or accept bribes. As a company that is expect us to pay special fees to do business in
> Never give or accept bribes. committed to fair and honest business practices and to the country where I operate. What should I do?
> Know and comply with the Amdocs the highest standards and promotion of good practices Special payments made directly, or indirectly, to a customer,
procedure on ‘Appointment and and promotion of good practices in prevention of bribery even if considered okay under local custom, could violate
Operating Agents in the Group’ prior and corruption, we trust you to never offer payment or the U.S. FCPA or other laws or regulations. Before making
to engaging any agent, consultant, accept payment from an Amdocs’ customer or supplier in any kind of payment to a customer, contact the Compliance
partner, reseller, subcontractor or any exchange for gaining or keeping business. In all Amdocs’ Officer for approval.
representative otherwise acting on transactions, our company must make sure that business is
behalf of Amdocs won strictly on the products and services we offer.
Amdocs may be liable for the conduct of
To help you understand the rules, Amdocs has an Anti- third parties
Bribery and Corruption Procedure. The FCPA and similar laws and regulations also
extend to the conduct of third party agents, sub-
contractors and other representatives or business
What you might be What is the FCPA? partners.
The U.S Foreign Corrupt Practices Act (FCPA) and simillar
Concerned about: laws and regulations such as the UK Bribery Act make it a We must be sensitive to potential abuses and careful to
> Violating the U.S. FCPA. crime to offer payment or a promise of payment, or to offer avoid situations involving third parties which might lead
Never pay, promise to pay, give, or or give anything of value to government officials in exchange to a violation of the FCPA, the UK Bribery Act and/or
promise to give anything of value to a for business. any other local law or regulation.
government official in exchange for
business
A “government official” includes…
The employee of any government-owned or controlled entity or
any public international organization, political party, party
official or candidate for public office.
Code of Ethics | 16
Proprietary and Confidential Information Use proprietary and confidential information only as
Did You Know? needed to do your job and never share it with people who
Amdocs proprietary information is any information do not have a need for it, even within Amdocs.
Your responsibility to protect Amdocs owns. I t includes things like the processes our
confidential information applies company creates, strategies it develops, specifications I f you leave your job at Amdocs, you must return all
to work you did before coming it designs, sales lists it generates, systems it develops, proprietary and confidential information.
to Amdocs and to any work you personnel information, information related to current
will do after you leave Amdocs. Nondisclosure Agreements
or future products and services, confidential market
I f you have any pre- or post- search, sales and marketing plans, earnings or financial Never share confidential information outside Amdocs
employment restrictions, such data, organization information and many other types of without your manager’s approval and without a
as confidentiality agreements, information. nondisclosure agreement in place. L imit the amount of
Amdocs requires you to abide by
confidential information shared to the minimum necessary
them. All proprietary information about Amdocs is confidential
to address the business need. When dealing with suppliers,
information and should be handled and protected in the
vendors, or other third parties, use extreme care from
same way.
improper disclosure. Original copies of nondisclosure
Disclosing confidential information of Amdocs can agreements should be kept with the L egal Department
seriously damage our company and put current—and
future—business opportunities at risk. I t can also expose What are some examples of
you and Amdocs to legal penalties. For any questions “confidential” information?
on confidential information, contact your Senior Leader or S uch information includes employment and personnel
the Compliance Officer
. information ( such as health, salary or performance
Confidential information includes also information you information), product specifications, designs and pricing,
may be exposed to as part of your job, whether about business strategies, technical information and data,
Amdocs or about its customers, suppliers or other third customer lists, trade secrets, government classified
parties. I t can be verbal, written or electronic information. information, marketing plans and nonpublic financial
information.
Code of Ethics | 20
What You Might Be Protecting Amdocs Customers’ Information is Occasional, personal use of internet and e-mail access
Concerned About: Critical and voicemail, is permitted but make sure you do so in
moderation.
Not Recognizing Confidential Keep information on Amdocs’ customers’ customers
Information. I f you are ever To protect Amdocs’ technology assets:
confidential too. Due to the nature of Amdocs’ business,
unsure about what information many of us have access to the personal and private > DO
is considered confidential or information of millions of Amdocs’ customers’ subscribers. Use extreme caution when opening e-mail attachments
how it should be handled, This information is not only considered highly confidential, from unknown or suspicious senders.
contact your Senior Leader. but is also protected by numerous laws and regulations. > DO
B e aware that sharing this data can result in serious Use only software that is legally licensed to Amdocs.
consequences both for you and for Amdocs. > DO
Contact the systems administrator before installing data
Open Source Software or software not provided by Amdocs.
Open source software is software for which normally > DO
the source code is available free of charge under a free P rotect and do not share your individually assigned
software or open source license. Just because open source passwords and personal I Ds.
software is downloadable without charge does not mean > DON’T
we can use it without restrictions. Open source software Use of someone else’s password, which you may have
licenses often impose obligations that could have serious learned by chance or while performing your duties.
implications if violated. B efore downloading, using or > DON’T
modifying any open source software, whether for internal Download files from unknown or suspicious sources.
use or for use as part of a product development, you must > DON’T
review Amdocs’ F OS S Policy and obtain the approvals of Send e-mails that contain offensive, harassing, illegal or
the L egal Department and others mentioned in that policy. otherwise inappropriate content.
Code of Ethics | 23
Fair competition Amdocs is committed to conducting its business fairly, B y following good business practices, we maintain the
means we… honestly and in accordance with the highest ethical respect of Amdocs customers and Amdocs competitors
principles. Amdocs provides you with the information and ensure future Amdocs business. I f you have questions
> Never interfere in contracts
you need to do your job with integrity and expects you to about fair competition practices, contact your Senior Leader.
between a prospective customer
observe ethical business practices everywhere Amdocs
and an Amdocs competitor
operates in the world.
> Don’t engage in industrial
espionage or offer bribes Good Corporate Citizens What is “industrial espionage?”
> Don’t say disrespectful or S omeone who is involved in industrial espionage is
untruthful things about Amdocs’ Amdocs recognizes that our company has a responsibility using illegal means to try to obtain information about a
competitors’ products or services to respect individuals, the environment and the global company’s plans, products, clients or trade secrets.
> Never take unfair advantage of community in developing its corporate strategies. Amdocs’
anyone through manipulation, Corporate R esponsibility R eport describes our company’s
concealment, abuse of privileged commitment and the steps it is taking to measure
information or misrepresentation our company’s economic, environmental and social
of facts. performance. Do your part to support these initiatives.
Amdocs is a Fair and Honest Competitor
Our company competes against other companies based
only on the merits of our products and services and
our ability to support our clients. We depend on you to
be truthful in all customer interactions and accurately
represent Amdocs’ product and service quality, features
and availability.
Code of Ethics | 25
Code of Ethics
and Business Conduct