1.1. Windcave is committed to conducting business ethically, responsibly and in compliance with applicable laws and international standards. Windcave values respectful and constructive relationships with its merchant customers and business partners.
1.2. This Code of Business Conduct (“Code”) sets out the minimum standards that are expected of merchants, suppliers, customers, referral partners, resellers, integrators and other business partners ("Business Partners") when doing business with Windcave. Business Partners are required to conduct their dealings with Windcave in a manner that is consistent with the principles set out in this Code.
2.1. Business Partners must comply with all applicable laws, regulations and regulatory requirements in the countries in which they operate and maintain appropriate policies, procedures and controls to ensure ongoing compliance.
2.2. Where local laws and this Code address the same subject, the higher standard shall apply.
3.1. Business Partners must respect internationally recognised human rights, including the principles set out in the UN Guiding Principles on Business and Human Rights and the International Labour Organization (ILO) core conventions.
3.2. Without limiting the generality of clause 3.1, Business Partners must:
3.2.1. take reasonable steps to identify, prevent and mitigate modern slavery risks in their operations and supply chains;
3.2.2. maintain policies and procedures addressing modern slavery risks; and
3.2.3. cooperate with Windcave in connection with any modern slavery reporting obligations under relevant laws.
3.3. Business Partners must provide their staff wages, benefits and working hours in accordance with applicable law and provide a safe and healthy workplace.
4.1. Windcave adheres to ethical standards and behaviour throughout the organisation by complying with our internal policies. Business Partners are also expected to conduct business with integrity and must not engage in bribery, corruption, fraud, money laundering or sanctions breaches, or anti competitive behaviour or collusion.
4.2. Business Partners must promptly disclose any actual or potential conflicts of interest relating to their relationship with Windcave.
5.1. Windcave is committed to providing a safe, respectful and professional working environment for its employees, contractors and representatives. Business Partners must treat Windcave personnel courteously, professionally and with respect at all times.
5.2. Windcave does not tolerate any form of abusive, threatening, intimidating, discriminatory, harassing or offensive behaviour directed towards its personnel, whether in person, by telephone, electronically or through any other means.
5.3. Where a Business Partner engages in conduct that Windcave considers abusive, threatening or otherwise inappropriate, Windcave reserves the right to suspend the provision of services or engagement activities while the matter is addressed and/or terminate the relevant commercial relationship with immediate effect.
6.1. Windcave is committed to data security. We use a variety of technologies and adhere to a broad range of security standards to protect sensitive information from unauthorised access, use or disclosure.
6.2. We expect our Business Partners to have adequate data privacy and security protection to protect against any unauthorised access, use and disclosure of personal information.
7.1. Windcave aims to minimise the environmental impacts of our operations. Business Partners are also expected to minimise environmental impacts where reasonably practicable and support responsible resource use, waste reduction and emissions management.
8.1. Windcave reserves the right to request Business Partners to provide reasonable information or certifications to verify compliance with this Code.
8.2. If a Business Partner fails to comply with this Code, Windcave may suspend engagement while issues are remediated or terminate the relationship for material or repeated non-compliance.