Exhibit 14.1 - TechTeam Global, Inc. Code of Business Conduct
TechTeam Global, Inc.
Code of Business Conduct
The Board of Directors and Senior Management of TechTeam Global, Inc
("TechTeam") have approved this Code of Business Conduct. It applies equally to
all employees, officers and directors of TechTeam and any of its subsidiaries.
1. Overview
Since it was founded, one of the keystones of TechTeam Global, Inc.'s success
has been integrity in its dealings with people both inside and outside TechTeam.
TechTeam is in a position of trust with respect to many external organizations
and agencies. All TechTeam personnel have a responsibility to the company, its
stockholders, customers, and other personnel to use TechTeam's funds prudently,
ethically and for the purposes for which they are designated.
As ethical conduct is the very foundation of our company, each of us, as
individuals, will:
- Help TechTeam meet its commitments to its stakeholders.
- Help safeguard TechTeam's reputation for integrity in our business
dealings.
- Be respectful, cooperative and helpful toward each other and our
business partners, never acting in an abusive, obscene or
disrespectful manner.
- Not disparage or misrepresent the company or any TechTeam employee.
- Take responsibility for our personal actions, honestly account for and
report on our activities.
- Seek assistance when we have questions about this Code of Business
Conduct or when faced with a challenging ethical question.
- Raise concerns and report any potential or actual violations of the
Code of Business Conduct, as well as any company policy and procedure,
or any law or regulation.
- Fully cooperate with any TechTeam investigation.
- Never act unethically, even when directed to do so by another person.
- Never ask or require another person to act unethically or violate this
Code or any law or regulation.
As management employees, we will:
- Ensure that all employees meet the company's ethical objectives.
- Consistently communicate and reinforce this Code of Business Conduct
and related policies and procedures to employees.
- Foster a work environment that encourages employees to act ethically
and in compliance with this Code.
- Ensure that we maintain open communication and discussion with
employees, encouraging them to ask questions and raise difficult
issues.
- Appropriately address our own or employees' ethical concerns or
reports of potential or actual misconduct in a timely manner and seek
guidance as needed.
- Demonstrate leadership by acting with respect and integrity.
2. Business Relationships
We want to sustain our customer's confidence in us and demonstrate that we are
worthy of their trust. We want to show our partners and suppliers that they are
valued business partners and build relationships based on integrity and trust.
This policy requires each individual to conduct TechTeam business transactions
with the utmost honesty, accuracy and fairness. Each situation needs to be
examined under this standard. No unethical practice can be resorted to on the
grounds that it is "customary" outside of TechTeam or that it serves other
worthy goals. Expediency should never compromise integrity.
To this end, we will:
- Transact business in compliance with the laws of the jurisdictions in
which we do business. In any instance where TechTeam policies appear
difficult to interpret or apply, TechTeam personnel should contact the
TechTeam officer with oversight responsibility for the policy.
Questions about interpretation or application of laws and regulations
should be referred to the General Counsel.
- Adhere to and fulfill our contractual obligations, unless they are
excused. In any instance where particular contractual requirements are
difficult to interpret or apply, TechTeam personnel should consult
with senior management. Legal issues should be referred to the General
Counsel.
- Earn and maintain a reputation for integrity. As even the appearance
of misconduct or impropriety can be very damaging to TechTeam, we will
strive at all times to maintain the highest standards of quality and
integrity.
- Govern our conduct by rules of fairness, honesty, and respect for the
rights of others.
3. Interpersonal and Employee Relations
We will treat others with whom we interact on behalf of TechTeam and within
our workplace with respect and fairness.
- Abusive, harassing or offensive conduct is unacceptable, whether
verbal, physical or visual.
- We value the difference of diverse individuals. Employment decisions
are based on business reasons, such as qualifications, talent and
achievement, and will comply with local employment laws.
- TechTeam has an open door policy, and employees are encouraged to
voice their opinions freely and report violations of the policies of
the company.
- TechTeam endeavors to keep its employees informed about the policies,
plans and progress of the company through regular communication.
- We will respect other's privacy, but recognize that our privacy at
work is limited and subject to business needs.
- We will follow healthy and safe business practices while on TechTeam
business.
4. Avoiding Conflicts of Interest
Business decisions must be based upon what is in the best interest of
TechTeam, and not on personal considerations or relationships. We will:
- Ensure our personal interests do not conflict or appear to conflict
with our responsibilities to TechTeam.
- Not be employed by, consult with, own, perform services, or aid a
company that is a vendor, supplier, contractor, subcontractor or
competitor of TechTeam or in the same lines of business.
- Strictly separate any outside activities from TechTeam employment and
take steps to assure outside activities do not harm job performance at
TechTeam.
- Ensure our financial interests do not create conflicts, including with
respect to securities ownership, participation in financial offerings
or acceptance of loans.
- Ensure our relations with family and friends do not interfere with our
business responsibilities, such as conducting business with these
parties.
- Not accept or offer kickbacks, lavish gifts or gratuities. We will not
accept anything that might make it appear our judgment for TechTeam
has been compromised. We will not give, offer or promise anything of
value to any prime contractor, subcontractor or others for the purpose
of improperly obtaining or receiving favorable treatment. Nor shall we
solicit or accept anything of value from any prime contractor,
subcontractor or others for such a purpose.
- Disclose to our manager or TechTeam's General Counsel any vendor or
employee of a vendor who is related, by blood or marriage, to us or
with when we have a personal relationship.
5. Use of Company Property and Assets
As we are responsible for treating all corporate assets with care and
respect, we will:
- Use company property for the purposes for which it was intended, and
protect it from loss, theft or misuse;
- Work with corporate funds in accordance with company policies,
ensuring the company receives good value in exchange for the funds;
- Seek reimbursement only for expenses that are reasonable, in accord
with the company's business expense policy, and otherwise authorized;
- Ensure records that we approve reflect appropriate use of company
funds, and are accurate, honest and prepared timely.
6. Use of Confidential Information
Information that we use in our business is a vital TechTeam asset. This
information includes many kinds of confidential, proprietary and private
information. In this regard, we will:
- Carefully handle both TechTeam information and information entrusted
to us to assure that those who have access to this information do not
make any unauthorized disclosures of the information, either during or
after employment;
- Not trade in TechTeam or any other company's securities, including
derivatives thereof, on the basis of inside information, even if
obtained accidentally or unintentionally. We will check with the
company's General Counsel if we intend on trading in company stock
when we may have inside information.
- Safeguard TechTeam's intellectual property rights.
7. Accuracy Of Company Records
Maintaining the integrity of records is essential to meeting legal and
regulatory obligations, as well as demonstrating how we conduct business
with all our stakeholders. Therefore, we are all responsible for the
honesty and integrity of our records, and we will:
- Prepare company records completely, accurately, and truthfully in
accordance with applicable company policies and procedures; applying
the highest standards in accurately recording and accounting for
discrepancies;
- Not knowingly prepare, maintain or provide false or misleading records
or data;
- Not knowingly suppress relevant information in any company record or
system;
- Record our work time honestly and carefully;
- Make sure that all financial books, records and accounts accurately
reflect transactions and events, and conform both to required
accounting principles and TechTeam's system of internal controls.
8. Reporting Suspected Violations
a. Reporting to Management -- Employees should report suspected
violations of applicable laws, regulations, contracts or this Code.
This reporting should normally be made initially through standard
management channels, beginning with the immediate supervisor.
Alternatively, employees may go to a higher level of management and
may also report suspected violations or problems to the General
Counsel.
b. Confidentiality -- Such reports may be made confidentially, and even
anonymously, although the more information given, the easier it is to
investigate the reports. Raising such concerns is a service to
TechTeam and will not jeopardize anyone's employment.
c. Cooperation -- All employees should cooperate fully in the
investigation of any misconduct.
9. Consequences Of Violations Of TechTeam Policies
Each person is responsible for ensuring that his or her own conduct and the
conduct of anyone reporting to him or her fully comply with this Code and
with TechTeam's policies. Violations will result in the taking of
appropriate disciplinary action up to and including discharge from
employment. Disciplinary action will be taken in accordance with applicable
procedures. Conduct representing a violation of this Code may, in some
circumstances, also subject an individual to civil or criminal charges and
penalties.