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Code of Ethics

The very essence of the services Windmolen Asia provides - demands that we consistently maintain the highest possible standards of honest and ethical behavior.

Windmolen Asia has Guiding Principles that express these high standards and they form the foundation for our behavior. These principles are closely related to our way of doing business and govern our relations with our partners, customers & principles. They help us achieve our goals and motivate us to excel in the way we render our services, and ensure that; We lead, others follow

  1. Our Principles
  2. Legal Compliance
  3. Equal Employment Opportunity
  4. Free Workplace
  5. Secure Work Environment
  6. Fair Dealing Practise
  7. Gift & Entertainment Policy
  8. Loyalty
  9. Misappropriation
  10. Information Technology Use / Information Security
  11. Obedience of instructions
  12. Confidentiality

(1) Our Principles

  1. High ethical conduct is everyone's responsibility. Directors, officers, employees, and consultants are expected to do what is right.
  2. We are expected to treat each other with respect, and we all have the right to work in an environment in which we are respected and valued.
  3. We are expected to raise questions and make reports about conduct which we believe in good faith to be an ethical or legal violation.
  4. Employees are encouraged to work with supervisors to resolve ethical issues; supervisors are to foster an "open door" environment to discuss ethical issues.
  5. We are protected from retaliation for reports made in good faith under the Code of Ethics and Business Conduct.

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(2) Legal Compliance
Windmolen Asia conducts it's business in compliance with all applicable laws and regulations. Because we conduct business in Pakistan currently, we are required to comply with the laws of Pakistan and the laws applicable to our business. We have high ethical principles that guide our work performance, we conform to a strict standard of moral, professional, and ethical conduct. At times this Code of conduct establishes requirements for our behavior that go beyond our legal obligations.

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WINDMOLEN ASIA WORK ENVIRONMENT

(3) Equal Employment Opportunity
We value diversity and promote an inclusive work environment. Windmolen Asia is committed to recruiting, developing, promoting, and retaining a well-qualified workforce without regard to race, color, religion, gender, age, national origin, disability, military service or status, veteran status, citizenship status, or any other characteristic recognized by the Government of Pakistan. We do not tolerate unlawful discrimination. Instead, we actively seek to create a workplace that allows employees to feel respected and valued. Our efforts to achieve diversity and equal employment opportunity are driven by more than compliance with the law; we firmly believe that an inclusive workplace will foster greater business success.

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(4) Free Workplace
We have no tolerance whatsoever for unlawful harassment based on race, color, religion, gender, age, national origin, disability, military service or status, veteran status, citizenship status, or any other characteristic recognized by the Government of
Pakistan. Harassment includes but is not limited to racist, sexist, ethnic, or other inappropriate comments, jokes, or gestures, or any action or statement that demeans individuals or creates a hostile, intimidating, or offensive work environment. All Windmolen Asia employees deserve a workplace where they are free from violence or the threat of violence. Further, we are entitled to be treated with respect. We will not tolerate threatening, hostile, demeaning, or abusive language or behavior.

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(5) Secure Work Environment
We are committed to providing a safe and healthy work environment. Employees, officers, directors, and consultants are responsible for complying with all health and safety laws and regulations. Employees are also expected to report immediately any work-related accident or injury to their management. As part of our commitment to a safe work environment, we have established a drug-free workplace. All employees are required to pass a drug screen before commencing work and may be subject to additional drug testing in appropriate circumstances during their employment. We will not tolerate the use, sale, or purchase of illegal drugs or the abuse of prescription or over-the-counter medications, alcohol, or other substances.

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HONESTY IN BUSINESS

(6) Fair Dealing Practise
Employees, officers, directors, and consultants will deal fairly with the Company's customers, suppliers, competitors, and employees. No one should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information,
misrepresentation of material facts, or any other unfair-dealing practice.

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(7) Gift & Entertainment Policy
The purchase of supplies, materials, and services from vendors, suppliers, and subcontractors must be accomplished following a fair and nondiscriminatory process based solely on quality, performance, price, and customer criteria. These decisions must be free from even the perception that Windmolen Asia employees provided favorable treatment in exchange for business courtesies or gifts. Windmolen Asia expressly prohibits employees from offering, attempting to give, soliciting, or receiving any form of bribe or kickback. Violation of this policy could subject the employee and the Company to criminal penalties. Even the receipt of a
request for a bribe or kickback may be a reportable event under the law. Thus, all employees,officers, and directors should immediately seek advice from the Legal Department if they receive any such request.

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(8) Loyalty
The employees of Windmolen Asia are responsible for the honesty and for the integrity which prevails in their work environment and consequently, they must protect not only the rights and the assets of the clients, but also the reputation of their employer.The employees of Windmolen Asia and of its subsidiaries are protected from adverse repercussions which they
could be exposed to by reporting irregularities if they denounce an employee who acts in a dishonest way, which is carrying out illegal activities, which carries out operations or maintains a relationship that could give rise to a conflict of interests, which is falsifying records, breaches any of the Guiding Principles of the present document, or commits any other serious infraction that has occurred either inside or outside the corporation.

Our Employees are to promptly report any facts to their
manager, to senior management or to any designated
persons, each of whom is then required to report the
issue through a process established by the legal
department of Windmolen Asia.

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(9) Misappropriation
The employees of Windmolen Asia recognize that the funds and the property which are entrusted to them by the clients must be treated with the greatest care. Our employees understand their responsibility to protect any and all property. An unsuitable or negligent attitude in the way of protecting funds and property constitutes a violation of this Guiding Principle. At all times, Windmolen Asia and its subsidiaries must protect their clients assets and of their companies. They must prevent, by any means, any form of unsuitable use of these assets. An unsuitable use can include theft, fraud and misappropriations.

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(10) Information Technology Use/Information Security
The employees of Windmolen Asia are required to follow the policies, procedures and standards relating to Information Technology, Information Security and Privacy. Any observed or suspected Information Technology, Information Security or Privacy incidents or lapses are to be reported as expediently as possible to the responsible person of the department. Our
employees are prohibited to participate in any online forum, or send or display any material in a manner that can tarnish the image and reputation of Windmolen Asia. Our employees are not to violate copyright, trademark or patent laws, or any other legal right.

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(11) Obedience of instructions
The employees of Windmolen Asia must carry out the tasks which are assigned to them, according to the directives and powers which are conferred to them, while respecting the policies, the methods and the standards in force.

They must carry out their work while respecting the limits of the powers which are conferred to them whether it is for a signature, a delegation of powers or other requirements stipulated in the policies. They must avoid being placed in a conflict of interests, falsifying writings or reports or breaching the Guiding Principles stated in this document. They must prevent being responsible of
a breach or of any other infraction whether inside or outside the corporation.

Our employees who witness an unusual situation in the course of business of a client, a situation that is likely to have negative repercussions, must report it without delay to their manager or with senior management.

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(12) Confidentiality
Windmolen Asia have undertaken to implement procedures to conform with protection of personal information laws in the territories where they carry out their activities.

(12 A) Internal Information
All employees, whatever their role, level, department or area, are to scrupulously avoid using, sharing or disclosing non-public information about Windmolen Asia or clients (both current and prospective), except in the legitimate course of doing business. Certain information concerning the plans, methods, practices and activities of Windmolen Asia is proprietary and classified as either Restricted, Confidential or Windmolen Asia Internal. Client lists and information (i.e. computer/electronic files, paper records, etc.) are the property of Windmolen Asia.

Employees of Windmolen Asia recognize that all the information which they obtained during the course of their work is the sole property of Windmolen Asia and that they are not to remove any proprietary information from the corporation's premises without permission. When they leave the service of Windmolen Asia, they are obliged to continue safeguarding the privacy of both clients and employees, and to protect the confidentiality of the corporation.

(12 B) External Information
Our Employees are to share restricted, confidential or Windmolen Asia internal information only with third parties who have undertaken in writing to keep the information confidential in accordance with Windmolen Asia requirements and then they may share only that information which is needed to satisfy the conditions of a contract and only with those who need to know.

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