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Code of conduct
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Why we have a Code of Conduct
Native Teams helps people and companies work together across borders. Every day, we deal with technology, employment, payments, personal information, and relationships that span different countries and legal systems. Doing that responsibly takes more than simply following a contract, because how we do business matters as much as what we do.
Global work moves quickly. It crosses borders, connects different legal systems and brings together employers, workers, clients, suppliers and technology. This Code provides a common ethical baseline for how Native Teams operates and for how we expect people and organisations that work with us to behave.
This Code sits alongside our contracts and our other Legal & Compliance documents. It does not replace applicable law, an employment agreement, a Master Services Agreement, a Scope of Work or any other binding contract.
Who this Code applies to
This Code applies to Native Teams Limited and the companies in the Native Teams group, including our directors, employees and other people acting on our behalf.
We also expect our suppliers, service providers, contractors, professional advisers and other business partners to uphold standards consistent with this Code. Where appropriate, we expect our clients and other organisations that use our services to respect the same principles in their dealings with Native Teams and with the people who are employed, paid or supported through our services.
Our shared principles
Our expectations can be summed up in six principles, which guide everything in this Code.
When you are unsure, ask yourself
- Is it legal, in every country involved?
- Is it consistent with this Code and with our policies?
- Would I be comfortable if it were reported publicly or explained to a regulator?
- Could it harm a worker, a client, a colleague or Native Teams?
If the answer to any of these questions is uncertain, stop and ask for guidance before you act. You can contact our Legal & Compliance team at any time.
Compliance with laws
Business goals never come before the law. Working across borders means operating under different legal systems, and their requirements are not always the same. Everyone acting for or with Native Teams is expected to comply with the laws and regulations that apply to their activities.
No commercial target, client instruction, deadline or internal objective justifies unlawful conduct. We do not support arrangements that are designed to disguise the true nature of employment, misrepresent payments, avoid mandatory employment protections, or circumvent tax or social security obligations, and we do not support any attempt to achieve through form what the law does not permit in substance.
Respectful workplace and fair treatment
People are at the centre of our services, and we are committed to professional relationships built on dignity and respect. Native Teams does not tolerate discrimination, harassment, bullying, retaliation, violence or any other abusive conduct. We expect clients, suppliers and business partners who interact with workers through our services to provide a professional working environment and to respect applicable workplace protections.
- Employment and business decisions must never be based on unlawful discriminatory grounds.
- Harassment, intimidation, retaliation and degrading treatment are never acceptable.
- Different cultures, backgrounds and perspectives should always be treated with respect.
- People should have a safe and healthy working environment, wherever they work, including when they work remotely.
- Concerns about inappropriate behaviour should be raised promptly, so that they can be addressed through the proper process.
Human rights and responsible employment
Native Teams respects internationally recognised principles of human dignity and responsible employment. We do not tolerate forced or compulsory labour, slavery or servitude, human trafficking, or unlawful child labour. We also do not tolerate the coercion or exploitation of workers, the unlawful retention of passports, identity documents or personal property, or any practice intended to prevent people from freely exercising their lawful employment rights.
We expect our suppliers and relevant business partners to uphold equivalent standards. More information about our approach is available in our Modern Slavery and Human Trafficking Statement.
Anti-bribery and anti-corruption
We expect business to be won and conducted fairly. Native Teams does not tolerate bribery, corruption, kickbacks, facilitation payments or any other improper advantage.
- Never offer, promise, give, request or accept anything of value in order to improperly influence a decision.
- Gifts and hospitality must be reasonable and proportionate, and must never be intended to create an improper obligation.
- Take extra care when dealing with public officials, regulators and government-linked organisations.
- Never use a third party to do something that Native Teams would not be permitted to do directly.
Before giving or accepting a gift or hospitality, ask yourself
- Is it modest in value and appropriate to the occasion and the relationship?
- Is it being offered openly, and would I be comfortable recording it?
- Could it be seen as an attempt to influence a decision, such as a contract award, a renewal or a regulatory matter?
- Does it involve a public official, or a person who is currently making a decision that affects Native Teams?
If you are unsure about any of these questions, decline politely or ask the Legal & Compliance team for guidance before you proceed.
Further details are available in our Anti-Bribery and Anti-Corruption Policy.
Financial crime, sanctions and tax evasion
Our services involve moving money across borders on behalf of businesses and individuals. That makes it essential that our services are never used to hide the source of funds, to move money for prohibited purposes, or to help anyone avoid the taxes they owe.
- Never take part in, or help others with, money laundering, terrorist financing or any attempt to disguise the origin or destination of funds.
- Comply with applicable sanctions and export control laws, and never do business with, or make payments to or for the benefit of, sanctioned persons, entities or territories.
- Never facilitate tax evasion by anyone, whether a client, a worker, a supplier or a colleague, and report any request to do so.
- Never commit, assist or ignore fraud, including fraud that is intended to benefit Native Teams.
- Complete identity, due diligence and screening checks properly, and never help anyone to bypass them.
Warning signs to look out for
- A request to send a payment to a person or account that does not match the worker, supplier or client concerned.
- Pressure to skip, speed up or work around identity, due diligence or screening checks.
- Unusual payment patterns, such as frequent changes to bank details, split payments or funds routed through unrelated countries.
- Reluctance to provide information about who owns or controls a business, or where funds come from.
- A request to describe a payment, a role or a working relationship in a way that does not reflect reality.
If something about a payment, a client, a worker or a request does not feel right, raise it before acting. Our compliance team would always rather review a concern that turns out to be harmless than miss one that was not.
Conflicts of interest
Business decisions should be made objectively and for legitimate business reasons, and never because of undisclosed personal interests. A conflict of interest may arise where a personal, family, financial or other relationship could influence, or appear to influence, professional judgement. Potential conflicts should be disclosed promptly, so that they can be assessed and managed appropriately.
Data protection and confidentiality
Our services involve sensitive information about individuals and businesses. Personal data and confidential information should be accessed only where there is a legitimate reason to do so, and should be used only for authorised purposes.
- Protect information against unauthorised access, loss, disclosure and misuse.
- Share information only with people who have a legitimate need to receive it.
- Follow applicable privacy, confidentiality and information security requirements.
- Never use confidential information for personal advantage or for the benefit of an unauthorised third party.
More information is available in our Privacy Policy, our Data Processing Agreement and our other data protection documents.
Responsible use of technology and AI
Technology helps us make global work simpler, but convenience never removes responsibility. We expect our teams and business partners to use systems, automation and artificial intelligence responsibly, securely and with appropriate human judgement.
- Never use technology to deceive people or to create misleading records.
- Never use AI or automated tools to discriminate unlawfully or to bypass required human review.
- Never enter personal, confidential or restricted information into tools that have not been approved for that purpose.
- Follow applicable security and data protection requirements when using digital tools.
Our approach to artificial intelligence is described in our Responsible AI Policy.
Protection of assets and information
Company systems, funds, intellectual property, devices, credentials and other assets should be used only for legitimate business purposes. The same respect applies to the assets and information that belong to our clients, workers and business partners. Everyone working with Native Teams should take reasonable steps to protect systems and information against fraud, misuse, unauthorised access and security threats.
Fair competition and honest business practices
We believe that customers should choose Native Teams because of what we offer, and not because of misleading or unfair business practices. We do not support false or misleading statements about our services or about our competitors; collusion, market allocation, bid rigging or other improper agreements with competitors; the misuse of confidential information belonging to competitors or customers; or any other conduct intended to distort fair competition.
Responsible communication
What we say publicly reflects on Native Teams, our clients and the people we support, so our communications must be accurate, respectful and authorised.
- Only authorised spokespeople may speak to the media or make public statements on behalf of Native Teams.
- Never disclose confidential information about Native Teams, our clients or workers on social media or in public forums.
- Make sure that marketing and sales materials describe our services accurately, including what is and is not included.
Responsible business partners and suppliers
Our standards do not stop at our own organisation. We expect our suppliers, professional advisers, service providers, contractors and other business partners to operate lawfully, ethically and in a manner consistent with the principles in this Code.
Depending on the nature of the relationship and the risks involved, Native Teams may carry out appropriate due diligence before or during a business relationship. Where serious concerns arise, we may require corrective action, suspend activities or reconsider the relationship.
Speaking up and reporting concerns
Problems are easier to address when people feel able to raise them. We encourage employees, workers, clients, suppliers and other business partners to report suspected misconduct and any behaviour that is inconsistent with this Code.
Our commitments to anyone who speaks up
- You can raise a concern openly or, if you prefer, anonymously.
- Your concern will be taken seriously and handled as confidentially as possible.
- Concerns raised in good faith will never be met with retaliation, even if they turn out to be unfounded.
More information about our reporting channels and how concerns are handled is available in our Whistleblowing Policy.
Breaches and consequences
We take potential breaches of this Code seriously. Depending on the circumstances, Native Teams may investigate and take proportionate action, which may include guidance, training or corrective measures; disciplinary action where applicable; escalation to management, regulators or other competent authorities; the suspension or termination of a supplier or other business relationship; or other measures required by law or by contract. The appropriate response will depend on the nature, seriousness and circumstances of the issue.
Relationship with other legal documents
This Code is a statement of our standards and expectations. It does not itself create contractual rights for any third party, amend any employment or commercial agreement, or replace mandatory law. Specific rights and obligations are set out in the applicable agreements, employment documentation and other Native Teams policies and terms.
Questions and concerns
Questions about this Code can be directed to the Native Teams Legal & Compliance team at legal@nativeteams.com. For whistleblowing or confidential reporting, please use the reporting channels described in our Whistleblowing Policy.