Code of Conduct

AnyConnect has a Code of Conduct that seeks to offer guidance for the business dealings of our employees, representatives, and partners.

Our Code of Conduct (“Code”) applies to all Business Partners and representatives and their employees, agents, suppliers, and others working on their behalf worldwide (our “Business Partners”). It sets AnyConnect’s minimum standards for their behavior. Compliance with this Code helps to sustain and enhance the good reputation of both our Business Partners and AnyConnect.

We expect all Business Partners to adopt this Code or their own code if it meets the minimum standards set out below. We also expect them to participate in appropriate training regarding these minimum standards.

Comply with laws

Business Partners are required, as a minimum standard, to comply with all the laws and regulations of the countries in which they operate.

Act with integrity in all business dealings

AnyConnect acts with integrity at all times, and we expect our Business Partners to behave in the same way. Business Partners will not engage in personal activities or public comments that are intended to damage AnyConnect’s business interests or reputation. Business Partners will not offer, promise, give (including facilitation payments), demand or accept bribes or other improper advantages, including excessive gifts and entertainment, in order to obtain, retain or give business. Business Partners must record all business transactions accurately, prudently, and transparently, in compliance with applicable accounting standards and recognized best practice.

Compete fairly

AnyConnect believes in competing fairly. We expect our Business Partners not to engage in, nor be a party to, agreements, business practices or conduct that are anti-competitive.

Treat other suppliers, partners and customers properly

Business Partners should work in partnership with AnyConnect and its other suppliers, to meet the expectations of our customers, and to ensure quality, and timeliness throughout the supply chain. Business Partners should respect and treat in accordance with agreed terms the physical property, IT equipment, communication resources, technology, intellectual property, confidential information, data, and any other tangible or intangible assets received from AnyConnect and other suppliers. Business Partners should insist and ensure their agents, suppliers, and others working on their behalf act lawfully, and in accordance with the standards set out in this Code.

Treat co-workers respectfully

Business Partners should recruit, select, and promote their employees solely on the basis of qualifications and skills. In employment-related decisions, Business Partners are required to comply with anti-discrimination requirements in the relevant jurisdictions concerning matters of race, gender, age, disability, national origin, religion, sexual orientation, marital status, etc. Business Partners must treat all employees with respect and dignity.

Health, safety, and security

AnyConnect requires Business Partners to remain committed to conducting all activities in a manner that achieves the highest practicable standards of health and safety. Business Partners should protect their employees, physical assets, information, and reputation from potential security threats, including cybersecurity threats.

Respect the environment

Business Partners should ensure that, as far as reasonably practicable, any detrimental effects from its activities, products, and services upon the environment are minimized.

Respect human rights

AnyConnect requires Business Partners to uphold all internationally recognized human rights wherever their operations are located. AnyConnect will not tolerate the use by Business Partners or their supply chains of child or compulsory labor, human trafficking, slavery, and any behavior that does not maintain human dignity and respect.

Application and compliance

AnyConnect’s Code of Conduct, or the Business Partner’s own code, should apply throughout any subsidiaries and to all its employees worldwide. This Code is not intended to replace Business Partners’ existing policies or those of its subsidiary businesses. We expect our Code, or your own code, to serve as a governing document to which your internal policies must adhere. Business Partners must expect and encourage employees to bring promptly to management’s attention any suspected or actual breaches of their code.

AnyConnect reserves the right to conduct inquiries and investigations of Business Partners’ conduct to satisfy ourselves that these minimum standards are being met.