AutoSmart Code of Conduct and Ethics

Introduction:

AutoSmart Audit is a leading automotive audit software provider and digital audit platform designed for the automotive industry’s dealership networks. As an audit management system powering dealer compliance and oversight, our reputation as an ethical SaaS solution is paramount. This Code of Conduct and Ethics (the “Code”) sets out the standards that guide our business behavior and compliance practices. It aligns with standard enterprise expectations – including the UK Bribery Act 2010 and global best practices – to ensure integrity, trust, and accountability in all we do. Every AutoSmart employee, contractor, and partner is expected to understand and abide by these principles, which are key to maintaining the trust of our clients, partners, and the broader community. Purpose and Scope:
This Code exists to deter wrongdoing and promote ethical conduct across AutoSmart’s operations. It applies to all team members, officers, and anyone representing AutoSmart Audit. We choose to do business in a manner consistent with our core values and legal obligations. By adhering to this Code, we demonstrate to enterprise clients that our values align with their compliance requirements.

The Code covers areas such as compliance with laws, anti-bribery measures, conflicts of interest, data protection, fair labor practices, and more. It also provides real-world examples to illustrate how these principles apply in daily situations. Ultimately, the goal is to ensure that AutoSmart’s audit management platform not only delivers compliance automation benefits, but does so with uncompromising ethics and integrity.

1. Integrity and Honesty in All Dealings

Our Principle: We conduct all business with integrity, honesty, and transparency. Every AutoSmart employee must act truthfully and in good faith in every interaction – whether with customers, colleagues, suppliers, or competitors. We do not tolerate any form of deceit, fraud, or misrepresentation. All communications, marketing materials, and audit reports must be accurate and honest. We honor our commitments and operate with the highest ethical standards to maintain the trust that enterprise clients place in our ethical SaaS solution.

AutoSmart mirrors this approach by requiring every team member to be truthful, accountable, and fair in all business dealings. By consistently choosing honesty, we build long-term partnerships founded on trust.

2. Compliance with Laws and Anti-Bribery

Our Principle: AutoSmart complies with all applicable laws and regulations in every jurisdiction where we operate. This includes anti-corruption laws such as the UK Bribery Act 2010 and the U.S. Foreign Corrupt Practices Act (FCPA), among others. We strictly prohibit bribery and corruption in any form – whether in dealings with private clients, public officials, or third-party partners. Offering, giving, or accepting any bribe, kickback, improper gift, or payment to influence a business outcome is forbidden. The UK Bribery Act 2010, for instance, “criminalizes the act of offering or accepting bribes, whether done directly or indirectly… encompassing both public and private sectors”, and we fully abide by both the letter and spirit of that law. We also reject facilitation payments and any “hidden” forms of bribery, such as excessive gifts, lavish hospitality, or charitable donations given to curry favor. All business decisions at AutoSmart must be based on merit and legitimate factors – never on inappropriate advantages. Example: If a sales representative of AutoSmart is negotiating a software contract with a dealership group and the client’s executive hints that a cash “incentive” would secure the deal, our representative must immediately decline and report this request. Similarly, an employee should never offer anything of value (money, gifts, lavish entertainment, etc.) to a client or government official to influence an audit’s outcome or procurement decision. In one scenario, a procurement officer for a potential client suggests that a personal “consulting fee” paid to them will guarantee AutoSmart is selected – our team must refuse such a bribe, end the discussion, and inform our Compliance Officer. These actions uphold our zero-tolerance policy on bribery. Best Practices: Our commitment is reinforced by global best practices and laws. We maintain internal anti-bribery policies and training that echo the “adequate procedures” defense outlined in the UK Bribery Act guidance – ensuring we have robust controls to prevent corruption. For example, we have clear rules on gifts and hospitality: any business gift or entertainment offered or received must be modest, infrequent, and transparently recorded. Offering or accepting anything extravagant that could be seen as an attempt to influence a decision is strictly forbidden. Third-Party Due Diligence: We also conduct due diligence on our agents, suppliers, or partners to ensure they share our anti-bribery stance.

If a third-party acting on our behalf were to engage in bribery, AutoSmart could be held liable under law – so we insist that all associated persons uphold the same standards. Our contracts with partners include clauses requiring compliance with anti-corruption laws and allow termination if any violation occurs. By integrating these principles into our operations and even our product, AutoSmart helps clients enforce anti-corruption controls. In fact, our platform’s features support tracking of compliance activities and red flags, effectively making it an anti-bribery audit software tool that automotive companies can use to monitor ethical compliance.

3. Conflicts of Interest

Our Principle: AutoSmart personnel must avoid any situations where personal interests conflict with the interests of the company or our clients. A conflict of interest occurs when an individual’s personal relationships or financial considerations could improperly influence their professional judgment and objectivity. All decisions at AutoSmart should be made in the best interest of the business and our clients, not to serve personal gain. Examples of conflicts to avoid:

• Personal Relationships: An employee should not be in a position to influence hiring, contracting, or evaluation of a family member or close friend. For instance, if a manager’s sibling works for a dealership that uses our digital audit platform, the manager must disclose this relationship and recuse themselves from any decisions involving that client.
• Outside Employment: Team members should not engage in outside business or employment that competes with AutoSmart Audit or that interferes with their ability to perform their job objectively. For example, an AutoSmart Audit software engineer should not moonlight for a competitor or develop a side audit tool that conflicts with our business.
• Gifts and Favors: Do not accept or give any gift, favor, or entertainment that might appear to compromise your objectivity or create an obligation. As a guideline, expensive or lavish gifts are inappropriate. For example, if a supplier offers an employee a luxury trip or an expensive watch in hopes of preferential treatment, the employee must decline. Any gift or hospitality beyond a nominal value should be cleared with management and recorded. Indeed, companies require that employees “may not offer or receive anything of value… where the offer or acceptance might compromise the company’s interest or influence an impartial decision”. We follow the same standard.

All potential conflicts of interest must be transparently disclosed to the company (e.g., to a manager or the HR/Compliance team). Disclosure allows the situation to be reviewed and managed (for example, by reassigning a project to avoid bias). When in doubt, disclose. By proactively addressing conflicts, we maintain trust and objectivity in our work. Real-World Example: If an AutoSmart compliance auditor is assigned to review a dealership but discovers their college friend is the dealership’s finance director, this could be a perceived conflict. The auditor should inform their supervisor and likely be reassigned to avoid any question of bias. Our impartiality in conducting audits and delivering software services is crucial to our credibility as an audit management system for dealer compliance.

4. Fair Competition and Business Practices

Our Principle: AutoSmart is committed to fair and lawful competition. We compete in the marketplace based on the merits of our products and services – such as quality, innovation, and price – never through unethical or illegal business practices. This means we comply with antitrust and competition laws that prohibit anti-competitive behavior. We do not engage in collusion with competitors, price fixing, bid rigging, or market allocation. We gather business intelligence ethically and lawfully, and we never resort to industrial espionage or misuse of confidential information. All marketing and sales practices must be truthful and not mislead customers or unfairly disparage competitors. Example: If our company is bidding to provide audit software to a large automotive group, we will not attempt to secretly agree with any competitor to divide the market or fix prices. Likewise, if a competitor’s former employee approaches us with their previous employer’s confidential client list or trade secrets, we must refuse to accept or use such information – it’s unethical and likely unlawful. In meetings or trade shows with industry peers, our employees should avoid any improper discussions about pricing or customers that could be seen as an attempt to undermine competition. We strive to win business through superior service and features, not through any underhanded tactics. Fair Dealing: Every employee should treat customers, partners, and competitors fairly. No AutoSmart representative should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, or misrepresentation. For instance, during software sales, we must not promise functionalities we cannot deliver or omit material facts about our product. Building our business on integrity and fairness not only keeps us compliant with laws but also enhances our reputation as a trusted, ethical provider.

5. Data Protection, Privacy, and Confidentiality

Our Principle: In our role as a compliance automation platform handling sensitive audit data, we place the utmost importance on data protection and confidentiality. AutoSmart is committed to safeguarding all personal data and confidential business information entrusted to us by our clients, users, and employees. We comply with data privacy laws such as the EU General Data Protection Regulation (GDPR), and all other applicable regulations on privacy and cybersecurity. Unauthorized use, disclosure, or mishandling of sensitive information is strictly prohibited. Customer Data Confidentiality: Our clients (automotive manufacturers, dealerships, etc.) rely on us to keep their audit results, financial information, and operational details secure. Employees must only access client data on a need-to-know basis to perform their job, and must follow all security protocols for our digital audit platform. Do not share any client data or system access credentials with unauthorized parties. Even within the company, confidential information should be shared only with those who are authorized and require it for their work. We also expect our clients and partners to respect our confidential information (such as our software code, algorithms, pricing, or strategies). Personal Data and Privacy: When handling any personal data – for example, contact information of dealer personnel or consumers’ info encountered in an audit – employees must treat it in accordance with our Privacy Policy and legal requirements. This includes using data only for authorized purposes, protecting it from breaches, and retaining it only as long as necessary. Never transfer personal data to unauthorized devices or accounts, and report any suspected data breach immediately to the IT Security team. Example: If an AutoSmart employee working on a dealer compliance project downloads dealership records (which include sales data and customer details) onto a laptop, they must ensure the laptop is encrypted and secure. They should not copy that data to a personal device or cloud drive. If they receive an email from someone claiming to be the client asking for sensitive files, the employee must verify the request through official channels to prevent phishing leaks. In one scenario, an employee noticed a colleague discussing a client’s upcoming audit results loudly in a public place – this is inappropriate. We must always be discreet and secure in our handling of information. Cybersecurity: Maintaining robust security measures is part of our ethical duty. All staff must follow our IT security policies (using strong passwords, respecting access controls, being vigilant against phishing attacks, etc.). We regularly update our systems and undergo security audits to protect data, recognizing that data integrity and confidentiality are critical to our credibility. By doing so, we uphold our promise that AutoSmart is a trustworthy custodian of information in the era of cloud-based audit management.

6. Accurate Record-Keeping and Transparency

Our Principle: We believe in transparency, accuracy, and completeness in all business records and reports. Whether it’s financial records, audit logs, project documentation, or communications with clients, AutoSmart requires that records be maintained honestly and in accordance with applicable standards. No false or misleading entries shall be made in any records. All financial transactions must be properly authorized and recorded. We also commit to transparent reporting to stakeholders and regulators, as needed, about our business operations and compliance. Audit Integrity: Given that our core product involves auditing and compliance reporting, maintaining the integrity of those reports is non-negotiable. Our software features and our professional services must reflect actual findings and data. Employees must not alter audit outcomes for favoritism or under outside pressure. If errors are discovered in a report or data set, we correct them promptly and communicate necessary clarifications to the client. Financial Integrity: Our accounting practices comply with applicable accounting standards and regulations. We do not maintain off-the-books accounts or engage in any form of financial fraud. All expenses, invoices, and financial dealings must be documented truthfully. For example, if you are submitting a business expense report, you must ensure it’s for legitimate business expenses and includes accurate receipts. Inflating numbers or misclassifying costs would violate this Code and could be illegal. Example: Suppose AutoSmart is preparing a performance report for a client’s dealership network, summarizing compliance scores and areas of risk. Even if there is pressure from a sales executive to gloss over negative findings to keep the client happy, we will present the data as it is, alongside constructive recommendations. In our own internal records, if an implementation project missed a deadline, we document the delay and reason honestly instead of adjusting the timeline after the fact. By ensuring accuracy in records and openness in communication, we uphold trust. As another example, if a regulatory body or a client’s auditor requests information about our security controls, we will provide a truthful, fact-based account of our controls and any incidents, rather than obscuring facts. This transparency strengthens our credibility as a compliance partner. Speak-Up Culture: Transparency also means internally we encourage employees to speak up about any wrongdoing. Part of accurate record-keeping is reporting issues rather than hiding them. If an employee notices any irregularity – say, a colleague circumventing a control or a discrepancy in data – they should report it (as detailed in Section 9 on Reporting) so it can be addressed. We prefer to confront problems honestly and fix them, rather than papering over them. This approach aligns with the expectation that companies maintain honest records and promptly address any violations

7. Respect, Diversity, and Fair Workplace Practices

Our Principle: AutoSmart is committed to providing a workplace that is respectful, inclusive, and in full compliance with labor and employment laws. We value diversity and provide equal opportunity to all employees and applicants without regard to race, color, religion, gender, sexual orientation, gender identity, age, national origin, disability, veteran status, or any other protected characteristic. Harassment, bullying, or discrimination of any kind is strictly prohibited – whether in our offices, at client sites, or anywhere representing AutoSmart. We foster a work atmosphere of mutual respect and professionalism, as this is not only ethically right but also essential to our success as a team. Fair Employment: All hiring, promotions, evaluations, and rewards at AutoSmart are based on merit, qualifications, and performance. We comply with all wage and hour laws, providing fair compensation and benefits as well as honoring all employee rights to leave, rest, and a safe working environment. We do not tolerate any form of forced labor, child labor, or human trafficking in our operations or supply chain. In alignment with global human rights principles, we expect our vendors and partners to also uphold fair labor standards (including compliance with laws like the Modern Slavery Act, where applicable). Harassment-Free Workplace: Every employee has the right to work in an environment free from harassment – this includes sexual harassment, offensive remarks, intimidation, or any behavior that creates a hostile atmosphere. Example: Unwelcome advances or derogatory jokes about one’s background are not acceptable. If an employee feels harassed or witnesses harassment, they should report it immediately to HR or management. Retaliation against anyone who raises concerns in good faith is forbidden (see Section 9 on Reporting). Safety and Health: We are dedicated to maintaining a safe and healthy workplace. Employees must follow all safety guidelines and report any hazards or incidents. While our work is primarily office and remote-based, we still prioritize ergonomics, mental well-being, and a supportive work culture. When visiting client sites such as dealerships or corporate offices, our team will also adhere to all safety and security procedures in place. Example: An AutoSmart team member hears a coworker repeatedly make sarcastic remarks belittling a junior colleague’s technical skills in meetings. This behavior is disrespectful and against our values of teamwork and respect. The team member should speak up or report it to a manager/HR. We will address such issues promptly, as no one should feel disrespected or marginalized. In another scenario, if a highly skilled candidate for a position is differently-abled, we will provide reasonable accommodations during the hiring process and on the job, in line with our commitment to inclusivity and laws like the Americans with Disabilities Act. By cultivating a culture of respect and fairness, AutoSmart not only meets the ethical standards expected by enterprise clients but also creates an environment where our employees can thrive and innovate.

8. Environmental and Social Responsibility

Our Principle: AutoSmart recognizes that ethical responsibility extends to our community and the environment. We are committed to sustainable and socially responsible practices in our operations. While our business is a software-based service (with a relatively small environmental footprint compared to manufacturing), we continually seek ways to reduce waste, conserve energy, and make environmentally conscious choices. We comply with all applicable environmental laws and regulations, and we strive to support the automotive industry’s broader goals of sustainability and compliance. Environmental Practices: We minimize negative environmental impact wherever feasible. For example, we have adopted cloud infrastructure and digital workflows to reduce paper usage in audits (promoting a “paperless audit” approach). Our data centers and cloud services are chosen with consideration for energy efficiency and, when possible, powered by renewable energy. In our offices, we encourage recycling, efficient energy use (like turning off equipment when not in use), and eco-friendly procurement. When traveling to client sites, our employees are mindful of reducing unnecessary travel – leveraging virtual meetings and efficient scheduling to limit our carbon footprint. Social Responsibility: AutoSmart aims to be a positive presence in society. We support initiatives and charitable activities, particularly those aligned with compliance, education, or community development. Employees are encouraged to volunteer and participate in community service, and we sometimes organize company volunteer days (for example, mentoring students in technology or participating in local environmental clean-ups). We also uphold human rights in our sphere of influence: treating people with dignity and opposing abuses. As mentioned, we hold our suppliers to ethical standards – including labor rights and anti-corruption – as communicated through our procurement policies and vendor agreements. Example: As a real-world illustration of these commitments, during the implementation of our audit software at a client’s facilities, we might notice that the client still uses extensive paper records. We not only help them digitize their audit processes for efficiency, but also highlight the environmental benefit of reducing paper waste – thus combining compliance automation with sustainability. Internally, if we upgrade office equipment, we dispose of or recycle old electronics through certified e-waste recyclers. And if an employee comes up with an idea like planting trees to offset our travel emissions, management will seriously consider and likely support such a proposal, reinforcing our culture of environmental responsibility. By integrating environmental and social considerations into our decision-making, AutoSmart demonstrates the kind of corporate citizenship that enterprise customers expect from their partners. We understand that operating responsibly is part of being an ethical business and ultimately contributes to long-term success.

9. Reporting Concerns and Enforcement

Speaking Up: AutoSmart is committed to an environment where employees and stakeholders can report violations or concerns without fear. If you observe any behavior that you believe violates this Code, our policies, or the law, you have a duty to speak up. We provide multiple channels to raise concerns, including your manager, HR, the Compliance Officer, or an anonymous helpline. We also welcome clients or third parties to report any ethical concerns they encounter in their dealings with us. All reports will be taken seriously and investigated promptly. No Retaliation: We strictly prohibit any form of retaliation against anyone who raises a concern in good faith or participates in an investigation. Retaliation itself is a serious violation of this Code. As guidance from anti-bribery best practices notes, a strong speak-up culture with no-retaliation is essential to an effective compliance program. AutoSmart embraces this: anyone retaliating against a whistleblower will face disciplinary action. Conversely, we do expect honesty in reporting; knowingly false allegations are not acceptable and may be subject to discipline. Contact for Reporting: To report any ethics or compliance concerns, you can email contact@autosmarts.co. This dedicated contact is monitored by our compliance team. You may also use it to ask questions about the Code or seek guidance if you are unsure about a situation. We encourage an open dialogue about ethical dilemmas – better to ask before acting if you are uncertain. Remember that timely reporting can prevent issues from escalating and help us resolve problems before they cause harm. Investigation and Enforcement: When a report is made, AutoSmart will investigate the matter confidentially and thoroughly. Employees are expected to cooperate fully with any internal or external investigations. We will take appropriate corrective action based on investigation findings. Confirmed violations of this Code or applicable laws can result in disciplinary measures up to and including termination of employment or contracts. In cases of legal violations, we may also involve law enforcement or pursue legal action. Our approach to enforcement is fair and consistent – taking into account the severity of the violation, whether it was intentional, and any repeat nature. Example: If an employee suspects that a colleague is accepting kickbacks from a client (e.g., an auditor getting personal payments to overlook issues), the employee should report this through contact@autosmarts.co or another channel. The company will then discreetly investigate, and if the allegation is substantiated, swift action will be taken (such as terminating the offending employee and disclosing the issue to the affected client, as appropriate). Throughout the process, the reporting employee’s identity will be protected to the extent possible, and they will not face retaliation for coming forward. Continuous Improvement: Compliance and ethics is not a one-time effort but an ongoing commitment. AutoSmart’s management, with oversight from our compliance team, will regularly review and update this Code and our policies to ensure they remain effective and up-to-date with evolving laws and societal expectations. We also provide training to our team on these principles and update training periodically. By enforcing this Code and keeping the conversation about ethics active, we ensure that AutoSmart remains not only a provider of audit management systems but also a role model for integrity in the automotive audit software industry. Conclusion:
AutoSmart’s Code of Conduct and Ethics embodies our dedication to doing business the right way – with integrity, accountability, and respect. These principles guide our every decision and action, from how we design our compliance automation features to how we interact with a single customer or coworker. By following this Code, we protect our reputation, comply with the law, and create lasting value for all stakeholders. We expect every member of our organization to internalize these values and be an ambassador of AutoSmart’s ethics. Together, we will continue to build a company that enterprise clients trust for both its innovative audit platform and its unwavering ethical compass. 

For questions about this Code or to report a potential violation, please contact contact@autosmarts.co. We appreciate your commitment to upholding the highest standards of conduct – it is essential to our mission of delivering an ethical SaaS solution that our customers can rely on with confidence.

Updated on May 2025