Code of Conduct for Subcontractors and Suppliers
Valid from 1st April 2026
The Mimacom companies (Mimacom) are bound by the principles of ethical behaviour, integrity and compliance. These principles of conduct are mandatory for all employees of Mimacom. Also, Mimacom expects integrity and ethical, law-abiding behaviour in line with the minimum standards set out below (Code of Conduct) from our subcontractors and suppliers (Subcontractors and Suppliers).
This Code of Conduct outlines our expectations of Mimacom’s Subcontractors and Suppliers for transparency, accountability, and responsible business practices.
Mimacom expects our suppliers to adhere to this Code of Conduct to help us meet our commitment to ethical and responsible business practices. We believe that working together in a spirit of transparency, accountability, and shared values will create a sustainable and mutually beneficial partnership.
Table of Contents
1. Anti-Corruption / Anti-Bribery
Subcontractors and Suppliers shall not, directly or indirectly, engage in any act of corruption, extortion or embezzlement, nor in any form of bribery. This includes but is not limited to the promising, offering, giving or accepting of any improper monetary or other incentive such as bribes, unreasonable business entertaining and gifts as well as kickbacks.
2. Counteracting Corruption
Subcontractors and Suppliers shall actively and systematically prevent any form of criminal, corrupt, or otherwise unethical conduct that could influence decisions by Mimacom or any external organization. They are required to maintain, document, and enforce adequate internal controls and compliance measures to prevent corruptibility within their own operations and supply chains.
3. Bid Rigging
Subcontractors and Suppliers do not participate in anti-competitive bid rigging and take action against illegal cartels.
4. Counteracting Illegal Employment
Subcontractors and Suppliers comply with the applicable legal requirements and effectively eliminate illegal employment.
5. Confidentiality, Intellectual Property and Privacy
Subcontractors and Suppliers shall not disclose the confidential information of Mimacom or Mimacom’s clients without prior written consent from Mimacom. Confidential information includes any information about Mimacom, about Mimacom’s business or about Mimacom’s clients which is not generally available to the public.
Subcontractors and Suppliers shall protect the intellectual property and personal data provided to them as a result of working with Mimacom. Subcontractors and Suppliers shall comply with applicable privacy laws and regulatory requirements when dealing with personal data.
6. Cybersecurity
Subcontractors and Suppliers shall implement, maintain and regularly review and improve appropriate measures to protect data against unauthorised access and cybersecurity risks and have to strategies to safeguard data against emerging and evolving cyber security risks, in line with Mimacom’s information security management system.
Subcontractors and Suppliers must notify Mimacom immediately of any incident involving unauthorised access to Mimacom’s or Mimacom’s clients data, and of any security risk, vulnerability or threat potentially impacting Mimacom’s business or assets.
7. Artificial Intelligence
Subcontractors and Suppliers who, develop, deploy, operate or use artificial intelligence (AI), generative AI (GenAI) or AI agents that interact with, process, or produce outputs relating to Mimacom's data, personnel, or customers shall remain fully responsible and accountable for any output, communication, work product, or decision in which AI has played a role.
AI-generated content must always be reviewed, verified, and approved by Subcontractors and Suppliers before delivery. Subcontractors and Suppliers shall be transparent about the use of AI where required by Mimacom, client agreements, or applicable regulation. Subcontractors and Suppliers shall not use AI to generate misleading, deceptive, or fraudulent content. Subcontractors and Suppliers shall be aware that AI-generated outputs may incorporate third-party copyrighted material, or may themselves not be eligible for copyright protection. Before using AI-generated content in products, publications, or client deliverables, Subcontractors and Suppliers shall seek clearance from the Mimacom where intellectual property rights could be affected. Subcontractors and Suppliers shall apply the same security standards to AI tools as to all other Mimacom systems: use only AI tools that have been reviewed and approved by Mimacom, not share credentials, and report any suspected data exposure or security incident related to AI use promptly
8. Respect for the Fundamental Rights of Employees
Subcontractors and Suppliers respect the health, safety and personal rights of their employees and adhere to the principles of respect, fairness and non-discrimination. They employ and remunerate their employees on the basis of fair and compliant contracts. They maintain international minimum labour standards and shall prevent modern slavery and not engage in any form of forced or child labour.
10. 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 as well as protect data and intellectual property from. Subcontractors and Suppliers implement an appropriate Compliance Management System, which facilitates compliance with applicable laws, regulations, and standards.
a)
Mimacom requests from our Subcontractors and Suppliers that they require their own subcontractors and suppliers also to comply with the principles of this Code of Conduct.
b)
Subcontractors and Suppliers are required to report their own violations of this Code of Conduct, insofar as these affect their business relations with Mimacom. They are also asked to report any knowledge of misconduct on the part of Mimacom employees; reports may be made to the designated Mimacom contact, or the Legal & Compliance Department. For serious matters, the Whistleblower Platform may be used, including on an anonymous or confidential basis where appropriate.
c)
Subcontractors and Suppliers are required to actively resolve any suspicious cases and to cooperate unconditionally with Mimacom in this regard. If there are reasonable grounds to believe that a Subcontractor or Supplier has violated this Code of Conduct 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, 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 of Conduct, Mimacom retains the right to initiate further legal measures, particularly damage claims.
d)
Mimacom, from time to time, can appropriately update this Code of Conduct and expects that our Subcontractors and Suppliers accept any such changes.
11. Scope
The Code applies to the Suppliers and Subcontractors of all Mimacom legal entities, notably:
Switzerland and EU countries
- Mimacom AG
- Mimacom Deutschland GmbH
- Mimacom Iberica s.l.u.
Non-EU countries
- Mimacom USA Inc.