R E S P E C T, VA LU E A N D

SUPPORT PEOPLE

CODE OF ETHICAL CONDUCT JULY 2020 • 10

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EPAM People are Professional, Supportive and Fair

Respect and Support People

N O D I SCRI M I N AT I ON
Our people maintain a culture where we respect and support our work
colleagues, build productive relationships, and value inclusion and diversity. I a m h i ri n g for a n e w p roj e c t
a n d k n ow t h at E PAM st ron gly
va lue s d i ve rsi t y. Sh ould I se le c t
NO DISCRIMINATION
c a n d i d at e s b a se d sole ly on t h e
We do not treat people less favorably because of “protected characteristics,” fa c t t h at t h e y e xh i b i t “ p rot e c t e d
c h a ra c t e ri st i c s, ” e ve n i f t h e y
which include*:
la c k i m p ort a n t sk i lls t o p e rform
t h e j ob i n q ue st i on ?

R AC E G EN DE R AG E MED ICAL
COND ITION
CO LO R SE X REL IGION

N AT I O N A L
SEX UA L
ORIEN TAT ION
MARITAL STATU S
MED ICAL TESTS

PREGNANCY
A
O RI G I N O R
VETERAN/
A N CE S T RY
G EN DE R MIL ITARY STATU S PHYSICAL OR
IDEN T IT Y OR MENTAL
ETHNICIT Y E X P RESSION CITIZENSHIP D ISABIL IT Y
STATU S
EPAM values diversity and we are made
GENETIC P ER SON A L POL ITICAL OR stronger by employees with different backgrounds,
IN F O R M AT I O N A P P E A R A N C E ** CASTE U NION AFFIL IATION perspectives and ideas. We conduct searches
that help us identify talented individuals who
continue to build our diverse profile. And we do
not treat candidates less favorably because of
* and any ther legally protected basis
protected characteristics. That does not mean,
** where not inconsistent with lawful EPAM or customer policy
however, that we compromise on quality or job
effectiveness in hiring decisions. At EPAM, our hiring
decisions are always based on our fair assessment
of who best meets our job qualifications for the role.

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EPAM People are Professional, Supportive and Fair

NO HARASSMENT

We do not participate in offensive comments, offensive actions or N O H A R A SSM E N T

harassment.
My m a n a ge r som e t i m e s m a ke s
Harassment is unwelcome conduct based on protected characteristics, se xua l c om m e n t s t o m e a n d
whether in words or in actions, that unreasonably interferes with work sugge st s w e sh ould t ry t o st a rt
performance or job benefits or produces an intimidating, hostile or a re lat i on sh i p . Th e re m a rks
m a ke m e un c omfort a b le , I d on ’t
offensive work environment.
li ke t h e m , a n d I’ve a ske d h i m t o
Harassment may take many forms, such as: st op se ve ra l t i m e s b ut h e h a s
n ot . I d on ’t w a n t h i m t o le a rn
• offensive or disparaging remarks
I re p ort e d h i m , b ut I w a n t i t t o
• jokes st op . Wh at sh ould I d o?
• slurs
• gestures
A
• negative stereotypes
• intimidating acts
EPAM does not expect anyone to tolerate
as well as other verbal, non-verbal, visual, audio, electronic or unwelcome sexual remarks or propositions as
physical conduct. part of the workplace environment, and there
are alternative reporting channels outside of
your manager. You should promptly raise your
concerns through one of the reporting channels
in our Code, and we will treat the matter with
appropriate confidentiality and discretion.

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EPAM People are Professional, Supportive and Fair

NO RETALIATION OR DELIBERATE HARM

EPAM does not tolerate retaliation, which is conduct that punishes E N COU R AG E R A I SI N G QU E ST I ON S A N D CON CE RN S

someone for or is likely to discourage or prevent someone from raising Wh at sh ould I d o i f I t h i n k m y

concerns, reporting misconduct, or participating in an investigation. c olle a gue m a y h ave vi olat e d
our C od e , b ut I’m n ot sure ?
At no time does EPAM tolerate intimidation, bullying, threats of violence, or
deliberate mental or physical harm.

LIKE HARASSMENT, RETALIATION MAY TAKE MANY FORMS, IN WORDS, WRIT TEN OR SPOKEN, A
OR IN ACTIONS, AND INCLUDES:

•a
 ctual or implied threats or intimidating acts
•a
 dverse employment action affecting an employee’s compensation,
job assignment, opportunities for advancement or other features
of employment
• d emotion, suspension or termination of employment
• d eliberately rude or hostile behaviors or speech
• c reating or permitting a work atmosphere hostile to an employee who
reports a concern
• d eliberate exclusionary behaviors
• harassing behaviors
It is always easier to ignore things that
seem wrong, but to build a better company,
we must all take affirmative steps to get
there. So in this case, take action. Because
we always respect our co-workers, a first
step may be speaking directly with him/
her to see if you can resolve the issue
informally. But for matters that do violate
our Code and can’t be solved informally,
escalate the question. EPAM welcomes
good faith questions and concerns, will act
on them, and does not tolerate retaliation
for raising them.

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EPAM People are Professional, Supportive and Fair

FAIRLY, OBJECTIVELY AND REGUL ARLY RECOGNIZE EMPLOYMENT CONTRIBUTIONS

At EPAM, we make employment decisions fairly and objectively based on capabilities and performance.
We also foster a satisfying and productive work experience by regularly recognizing our individual and collective contributions.

IMPROVE OUR PERSONAL WELL- BEING - BE SAFE, HEALTHY AND SECURE

Always behave in ways that keep EPAM’s working environment safe, healthy and secure and that promote
environmental sustainability.
Dangerous practices, hazards, violence, threats, aggression or substance-related impairment are unacceptable.

RE Q U IRE D HE ALT H AN D SAF E T Y BE HAVIORS

DO N ’T US E A LCO HO L
PRIORITIZE H EA LTH K E E P WO RK S PAC E S BE MIND FU L O F
O R UN L AW F UL DRU G S
AND SAF ET Y S E C URE THO S E ARO U ND YO U
AT WO RK

NE VE R E N G AG E
IN T HRE AT EN I N G
OR AGGRE SS I VE AC TS
N E V E R B RIN G W E A P O N S NE V E R RE TALIATE
RE P O RT UN S A F E O R
IN T O A N Y E PA M O R AG AINS T S O ME O NE
UN H E A LT H Y S IT UATIO NS
C LIE N T WO RK P L AC E WHO RAIS E S A CO NCE RN

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EPAM People are Professional, Supportive and Fair

Use Social Media Communications Responsibly

SOCI A L M E D I A COM M U N I CAT I ON S – R E SPON SI B L E U SE
Social media is a powerful tool for communicating about many things,
I use soc i a l m e d i a t o b log a b out
both personal and professional.
soft w a re d e ve lop m e n t a n d
If you use it to communicate about EPAM, make it clear you are speaking c od i n g a p p roa c h e s, j ust a s a
personally and not on behalf of EPAM (unless you are specifically w a y t o e d uc at e ot h e rs, a n d n ot
authorized), and be responsible, professional, and abide by our Code. for p a y. I s t h at oka y ?

NEVER USE COMMUNICATIONS TO:

REV E A L CON FID ENTIAL
LIE ABOUT OTHERS OR “M AT ERIAL”
IN F OR MATION
V IOL AT E T R A D EMARKS,
VI O L AT E T H E P RI VAC Y
COP YRIG HT S , TRAD E EPAM’S CONTRACTUAL
RI G H T S O F O T H ER S
SE C RE T S OR PATENTS
A
HARASS OR
D ISCRIMINATE It depends on the content that you are posting
AGAINST OTHERS
and sharing, but there are certainly “best
practices.” First, always be clear that you are
speaking personally and not for or on behalf
of EPAM. Second, never disclose EPAM’s, a
VIOL ATE THE L AW OR
customer’s, or another company’s software
PROMISES code or confidential information. Third, if
there is any doubt whether your activities
may conflict with EPAM’s legitimate business
interests, check with your manager first and
get specific approval. And fourth, never allow
your communications to violate any of the
standards in EPAM’s Code of Ethical Conduct.

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EPAM People are Professional, Supportive and Fair
Personal Relationships That Cause Business Conflicts
Must Be Resolved
When business conflicts arise from our close, personal relationships,
we address and resolve them so that our duties to EPAM, our business
judgment, and our decision-making are not improperly influenced.
PERSO NAL REL ATIONSHIPS THAT MAY REQUIRE SUCH ACTION INCLUDE:
MARITAL FAMILY
ROMANTIC
SIMIL ARLY CLOSE
PERSONAL REL ATIONSHIPS
YOU HAVE AN OBLIGATION TO RAISE, ADDRESS, AND REMOVE YOURSELF FROM BUSINESS
CONFLICTS WHERE:
• Y ou exercise managerial influence over a person with whom you have a
close, personal relationship, or you are in a direct managerial or reporting
relationship with such a person.
• Y ou make business decisions about a company where a decision-maker and
you have a close, personal relationship.
CODE OF ETHICAL CONDUCT
Q
PE R SON A L RE L AT I ON SH I PS T H AT
CAU SE B U SI N E SS CON F L I CT S
I a m goi n g t o b e p rom ot e d t o a
m a n a ge ri a l p osi t i on on t h e Java
Solut i on s t e a m . My c ousi n w i ll
b e re p ort i n g t o m e i n t h at n e w
role . D o I n e e d t o t a ke
a n y a c t i on ?
A
Yes. Many potential conflicts of interest can
be resolved if we act on them promptly and
with transparency. You need to disclose your
relationship to management in advance
of the decision, so EPAM can implement a
solution to eliminate the personal conflict.
We resolve personal conflicts of interest that
could improperly influence key aspects of our
business decisions with other companies or
our hiring and performance review processes.
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EPAM People are Professional, Supportive and Fair

Respect the Company in your Own Actions SOCI A L M E D I A COM M U N I CAT I ON S – R E SPON SI B L E U SE

I have a personal blog that only

You represent our company, every day, wherever you are. For that my close friends follow. Tonight,
reason, your behavior is one of the best ways to build and enhance after work, I was planning to post
EPAM’s positive reputation. a short cartoon poking fun at one
of my teammates who would rather
By behaving in ways consistent with our Code, you show respect for complain about the customer than
come up with effective software
your colleagues and EPAM as a company. solutions. It’s just a joke and I doubt
the teammate would ever know about
it, and anyway it’s my personal blog.
Is this a problem?
Respect the Company’s Right to Speak for Itself

EPAM only speaks about its business and financial plans and activities
through official and authorized communications and communication
channels. Only specifically authorized personnel may speak on behalf of
EPAM. And only authorized personnel with specialized knowledge speak
on behalf of EPAM to the news media and to securities professionals, such
as analysts, investors, broker dealers, investment advisors and investment
companies (direct all such questions to Investor Relations and Legal).
A
Yes. The conduct you describe would conflict with
our Social Media policy. Remember, your social
media activity, even on a personal blog, may affect
EPAM’s legitimate business interests, especially if
you were to mention EPAM employees or customers.
Such activities require the same care you use in all
your EPAM communications. Things on the internet
last forever, and you have no way of knowing who
may read your blog, including our customers.
Take a moment to read what our Code and our
social media policy say about proper use of
social media, and follow those rules.

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