Flowable Code of Conduct for Subcontractors and Suppliers (“Code”)

Flowable is an affiliate of the Mimacom Flowable Group.

The Mimacom Flowable Group (hereinafter called “Group“) is bound by the principles of ethical behavior, integrity and compliance. The acceptance of the Principles of Conduct is mandatory for all employees of the Group. Also, from its subcontractors and suppliers, the Group expects integrity and ethical, law-abiding behavior in line with the minimum standards set out below.

  • Compliance with general laws and regulations

Subcontractors and suppliers shall comply with applicable laws and regulations relating to their activities and the countries in which they conduct business. They shall respect intellectual property rights, conduct transfer of technology and know-how in a manner that protects intellectual property rights, and safeguard customer and supplier information.

  • Anti-Corruption / Anti-Bribery

Subcontractors and suppliers shall not, directly or indirectly, engage in any form of corrupt practices, including extortion, fraud, embezzlement or bribery. This includes but is not limited to the promising, offering, giving or accepting of any improper monetary or other incentives, such as bribes, unreasonable business entertaining, gifts or kickbacks.

  • Counteracting Corruption

Subcontractors and suppliers actively and consistently counteract criminal or unethical influence on decisions taken by the Group or other companies and institutions and fight corruptibility within their own companies.

  • Anti-Trust/Bid Rigging

Subcontractors and suppliers shall act in compliance with anti-trust regulations, not participate in anti-competitive bid rigging and take action against illegal cartels.

  • Counteracting Illegal Employment

Subcontractors and suppliers comply with the applicable legal requirements and effectively eliminate illegal employment.

  • Respect for the Fundamental Rights of Employees

Subcontractors and suppliers respect the health, safety, security and personal rights of their employees and adhere to the principles of respect, dignity, fairness and non-discrimination. They employ and remunerate their employees on the basis of fair and compliant contracts. They maintain applicable legal minimum labor and wage standards. They shall ensure normal working hours comply with national legislation or the prevailing industry standards. They shall commit to high standards of health and safety in their operation.          

  • Respect for the Environment & Sustainability

Subcontractors and suppliers shall conduct their business in an environmentally responsible manner by ensuring compliance with relevant legal environmental requirements, standards and regulations and minimize environmental pollution. They are encouraged to include appropriate environmental and social considerations into the full lifecycle of their processes, technologies, products and packaging in order to enhance their business’ overall environmental performance and maximize opportunities for positive social impact.

  • Governance

Subcontractors and suppliers forbid gifts to private or public officials that aim to influence business decisions or otherwise encourage them to act contrary to their obligations. Subcontractors and suppliers respect the privacy and confidential information of all their employees and business partners. Subcontractors and suppliers implement an appropriate Compliance Management System, with a scope that is related to the content of this Code which facilitates compliance with applicable laws, regulations, and standards.

a. The Group expects from its subcontractors and suppliers to communicate to their own employees, subcontractors and suppliers in order to ensure these principles are integrated into their operations.

b. Subcontractors and suppliers of the Group are required to report their own violations of this Code, insofar as these affect their business relations with Mimacom Flowable Group. They are also asked to report any knowledge of misconduct on the part of the Group employees.

c. Subcontractors and suppliers are required to actively resolve any suspicious cases and to cooperate unconditionally with the Group in this regard. If there are reasonable grounds to believe that a subcontractor or supplier has violated this Code or if a subcontractor or supplier, when a suspicious case arises, fails to sufficiently meet his obligations to resolve the case and to cooperate, Mimacom Flowable Group, on the basis of existing contractual or legal rights, can end all business relations with the subcontractor or supplier with immediate effect. In the event of a violation of this Code, the Group retains the right to initiate further legal measures, particularly damage claims.

d. The Group, from time to time, can appropriately update this Code and expects that its subcontractors and suppliers accept any such changes.


The Code applies to the suppliers and subcontractors of all legal entities of the Group, such as:

Switzerland and EU countries

mimacom AG

mimacom management AG

mimacom Deutschland GmbH

mimacom ibérica s.l.u. 

Flowable Holding AG

Flowable AG

Flowable Deutschland GmbH 

Flowable International GmbH

Flowable Licences AG

Flowable Mimacom Services Deutschland GmbH

Flowable Polska s.p. z. o.o.

Flowable Services GmbH

Flowable Services Spain s.l.u.

Non-EU countries

mimacom USA Inc.

Flowable Canada IT Services Inc.    

Flowable USA Inc.