Introduction
AutoSmart Audit is an audit platform that automotive dealer networks use to run audits, track compliance and follow up on what they find. Because our customers trust us with their compliance and their data, our reputation for integrity matters as much as our software.
This Code of Conduct and Ethics (the “Code”) sets out the standards that guide how we do business. It follows the expectations of enterprise customers, including the UK Bribery Act 2010 and global best practice, so that integrity, trust and accountability run through everything we do. Every AutoSmart employee, contractor and partner is expected to understand and follow these principles.
Purpose and scope
This Code exists to prevent wrongdoing and to 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 line with our values and our legal obligations, and by following this Code we show customers that our values match their own compliance requirements.
The Code covers compliance with laws, anti-bribery, conflicts of interest, fair competition, data protection, accurate records, fair workplace practices, environmental and social responsibility, and how to report concerns. Each section includes real-world examples of how these principles apply day to day.
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 deceit, fraud or misrepresentation of any kind. All communications, marketing materials and audit reports must be accurate and honest. We honour our commitments and hold ourselves to the highest ethical standards to keep the trust our customers place in us.
Every team member is expected 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
- UK Bribery Act 2010
- U.S. Foreign Corrupt Practices Act (FCPA)
Our principle AutoSmart complies with all applicable laws and regulations in every country where we operate.
This includes anti-corruption laws such as the UK Bribery Act 2010 and the U.S. Foreign Corrupt Practices Act (FCPA). We strictly prohibit bribery and corruption in any form, whether in dealings with private customers, 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 makes offering or accepting a bribe, directly or indirectly, a crime in both the public and private sectors, and we follow both the letter and the spirit of that law.
We also reject facilitation payments and hidden forms of bribery, such as excessive gifts, lavish hospitality or charitable donations made to win favour. Every business decision at AutoSmart must be based on merit and legitimate factors, never on an improper advantage.
In practice A client’s executive hints during contract negotiations that a cash “incentive” would secure the deal. Our representative declines immediately and reports the request.
In practice A procurement officer at a potential client suggests that a personal “consulting fee” paid to them will guarantee that AutoSmart is selected. Our team refuses, ends the discussion and informs our Compliance Officer.
These actions uphold our zero-tolerance policy on bribery. Employees must never offer anything of value, such as money, gifts or lavish entertainment, to a customer or official to influence an audit outcome or a buying decision.
Best practice
We maintain internal anti-bribery policies and training in line with the “adequate procedures” guidance under the UK Bribery Act, so that we have robust controls to prevent corruption. Our rules on gifts and hospitality are clear: any business gift or entertainment offered or received must be modest, infrequent and transparently recorded. Anything extravagant that could be seen as an attempt to influence a decision is forbidden.
Third-party due diligence
We carry out due diligence on our agents, suppliers and partners to make sure they share our stance on bribery. If a third party acting on our behalf engaged in bribery, AutoSmart could be held liable, so we require every associated person to uphold the same standards. Our contracts with partners require compliance with anti-corruption laws and allow termination if a violation occurs.
3. Conflicts of interest
Our principle AutoSmart people must avoid situations where personal interests conflict with the interests of the company or our customers.
A conflict of interest arises when personal relationships or financial considerations could improperly influence someone’s professional judgement. All decisions at AutoSmart should be made in the best interest of the business and our customers, never for personal gain. Examples of conflicts to avoid:
- Personal relationships: an employee should not be in a position to influence the hiring, contracting or evaluation of a family member or close friend. If a manager’s sibling works for a dealership that uses AutoSmart Audit, the manager discloses the relationship and steps back from any decisions about that customer.
- Outside employment: team members should not take on outside work that competes with AutoSmart Audit or affects their objectivity. An AutoSmart software engineer, for example, should not work for a competitor or build a competing audit tool on the side.
- Gifts and favours: do not accept or give any gift, favour or entertainment that might compromise your objectivity or create an obligation. Expensive or lavish gifts are inappropriate. If a supplier offers an employee a luxury trip or an expensive watch in the hope of preferential treatment, the employee declines. Anything beyond a nominal value is cleared with management and recorded. We never offer or accept anything of value where doing so could compromise the company’s interests or influence an impartial decision.
All potential conflicts of interest must be disclosed to a manager or the HR or compliance team, so the situation can be reviewed and managed, for example by reassigning a project. When in doubt, disclose.
In practice An AutoSmart compliance auditor assigned to review a dealership discovers that a college friend is the dealership’s finance director. The auditor informs their supervisor and is reassigned, so there is no question of bias. Impartiality in our audits and services is essential to our credibility.
4. Fair competition and business practices
Our principle AutoSmart competes fairly and lawfully, on the merits of our products and services: quality, innovation and price.
We comply with antitrust and competition laws. We do not collude with competitors, fix prices, rig bids or divide markets. We gather business intelligence ethically and lawfully, and we never use industrial espionage or misuse confidential information. All marketing and sales practices must be truthful and must not mislead customers or unfairly disparage competitors.
In practice When bidding to supply audit software to a large automotive group, we never agree secretly with a competitor to divide the market or fix prices. If a competitor’s former employee offers us their previous employer’s confidential client list or trade secrets, we refuse it. At meetings and trade shows, our people avoid any discussion of pricing or customers with competitors that could be seen as undermining competition.
Fair dealing
Every employee treats customers, partners and competitors fairly. No AutoSmart representative takes unfair advantage of anyone through manipulation, concealment, abuse of privileged information or misrepresentation. In sales, we never promise functionality we cannot deliver or leave out material facts about our product.
5. Data protection, privacy and confidentiality
- EU General Data Protection Regulation (GDPR)
Our principle We protect all personal data and confidential information entrusted to us by our customers, users and employees.
Our customers’ audit data is sensitive, so data protection and confidentiality come first. We comply with data privacy laws such as the EU General Data Protection Regulation (GDPR) and all other applicable privacy and cybersecurity regulations. Unauthorised use, disclosure or mishandling of sensitive information is strictly prohibited.
Customer data confidentiality
Our customers, including automotive manufacturers and dealerships, rely on us to keep their audit results, financial information and operational details secure. Employees access customer data only on a need-to-know basis and follow every security protocol of the platform. Never share customer data or system credentials with unauthorised people. Within the company, confidential information is shared only with those who are authorised and need it for their work. We also expect customers and partners to respect our confidential information, such as our software code, pricing and plans.
Personal data and privacy
Any personal data, such as the contact details of dealer staff or customer information seen during an audit, is handled in line with our Privacy Policy and the law: used only for authorised purposes, protected from breaches, and kept only as long as necessary. Never move personal data to unauthorised devices or accounts, and report any suspected data breach immediately to the IT security team.
In practice An employee working on a dealer compliance project needs dealership records on a laptop: the laptop is encrypted and secure, and the data is never copied to a personal device or cloud drive. If an email that seems to come from the customer asks for sensitive files, the employee checks the request through official channels first. Customer matters, such as upcoming audit results, are never discussed in public places.
Cybersecurity
Strong security is part of our ethical duty. All staff follow our IT security policies: strong passwords, respecting access controls and staying alert to phishing. We keep our systems up to date and undergo security audits, because data integrity and confidentiality are critical to our credibility.
6. Accurate record-keeping and transparency
Our principle We keep honest, accurate and complete records, and report transparently.
Whether financial records, audit logs, project documentation or communications with customers, AutoSmart’s records are kept honestly and in line with applicable standards. No false or misleading entries are made in any record. Every financial transaction is properly authorised and recorded, and we report transparently to stakeholders and regulators as required.
Audit integrity
Our core product is about auditing and compliance reporting, so the integrity of those reports is non-negotiable. Our software and services reflect actual findings and data. Employees never alter audit outcomes out of favouritism or under outside pressure. If we find an error in a report or data set, we correct it promptly and tell the customer.
Financial integrity
Our accounting complies with applicable standards and regulations. We keep no off-the-books accounts and engage in no financial fraud. All expenses, invoices and financial dealings are documented truthfully: an expense claim covers legitimate business costs with accurate receipts. Inflating figures or misclassifying costs breaks this Code and may be illegal.
In practice A performance report for a customer’s dealer network shows weak compliance scores, and a salesperson suggests softening the negative findings to keep the customer happy. We present the data as it is, with constructive recommendations. When an implementation project misses a deadline, we record the delay and the reason honestly instead of adjusting the timeline afterwards.
If a regulator or a customer’s auditor asks about our security controls, we give a truthful, factual account of our controls and any incidents, without obscuring anything.
Speak-up culture
Transparency also means speaking up. If an employee notices an irregularity, such as a colleague getting round a control or a discrepancy in data, they report it (see section 9) so it can be put right. We would rather confront problems honestly and fix them than hide them.
7. Respect, diversity and fair workplace practices
- Modern Slavery Act (where applicable)
- Americans with Disabilities Act
Our principle AutoSmart is a respectful, inclusive workplace that complies fully with labour and employment laws.
We value diversity and give equal opportunity to all employees and applicants regardless of race, colour, religion, gender, sexual orientation, gender identity, age, national origin, disability, veteran status or any other protected characteristic. Harassment, bullying and discrimination of any kind are strictly prohibited, in our offices, at customer sites and anywhere we represent AutoSmart.
Fair employment
Hiring, promotion, evaluation and reward at AutoSmart are based on merit, qualifications and performance. We comply with all wage and working-time laws, pay fairly, and respect employees’ rights to leave, rest and a safe workplace. We do not tolerate forced labour, child labour or human trafficking in our operations or supply chain, and we expect our vendors and partners to uphold fair labour standards, including laws such as the Modern Slavery Act where they apply.
A workplace free from harassment
Everyone has the right to work free from harassment, including sexual harassment, offensive remarks, intimidation or any behaviour that creates a hostile atmosphere. Unwelcome advances or derogatory jokes about someone’s background are not acceptable. Anyone who experiences or witnesses harassment should report it to HR or management straight away. Retaliation against anyone who raises a concern in good faith is forbidden (see section 9).
Safety and health
We are committed to a safe and healthy workplace. Employees follow all safety guidelines and report hazards and incidents. Most of our work is office or remote based, but we still look after ergonomics, mental well-being and a supportive culture. At customer sites such as dealerships, our team follows every safety and security procedure in place.
In practice A team member hears a colleague repeatedly belittle a junior colleague’s technical skills in meetings. This goes against our values of teamwork and respect, so they speak up or report it, and we deal with it promptly. If a highly skilled candidate has a disability, we provide reasonable adjustments during hiring and at work, in line with our commitment to inclusion.
8. Environmental and social responsibility
Our principle Our ethical responsibility extends to our community and the environment.
We are committed to sustainable and socially responsible practices. As a software business our environmental footprint is relatively small, but we keep looking for ways to reduce waste, save energy and make environmentally conscious choices. We comply with all applicable environmental laws and support the automotive industry’s own sustainability goals.
Environmental practices
Cloud infrastructure and digital workflows cut the paper used in audits. Our data centres and cloud services are chosen with energy efficiency in mind and, where possible, run on renewable energy. In our offices we encourage recycling, efficient energy use and eco-friendly purchasing. When visiting customer sites, we avoid unnecessary travel by using virtual meetings and efficient scheduling.
Social responsibility
We aim to be a positive presence in society. We support initiatives and charitable activities, particularly in compliance, education and community development. Employees are encouraged to volunteer, and we sometimes organise company volunteer days, such as mentoring students in technology or local environmental clean-ups. We uphold human rights within our sphere of influence and hold our suppliers to ethical standards, including labour rights and anti-corruption, through our procurement policies and vendor agreements.
In practice When we implement AutoSmart Audit for a customer still relying on paper records, we help them digitise their audits for efficiency and point out the environmental benefit of less paper. When we replace office equipment, old electronics go to certified e-waste recyclers.
9. Reporting concerns and enforcement
Our principle Anyone can raise a concern without fear, and every report is taken seriously.
Speaking up
If you see behaviour that you believe breaks this Code, our policies or the law, you have a duty to speak up. You can raise a concern with your manager, HR, the Compliance Officer or through an anonymous helpline. Customers and third parties are also welcome to report any ethical concern they meet in their dealings with us. All reports are investigated promptly.
No retaliation
We strictly prohibit retaliation against anyone who raises a concern in good faith or takes part in an investigation. Retaliation is itself a serious breach of this Code, and anyone who retaliates against a whistleblower will face disciplinary action. We also expect honesty: knowingly false allegations are not acceptable and may lead to discipline.
How to report
To report an ethics or compliance concern, email contact@autosmarts.co. This address is monitored by our compliance team. You can also use it to ask questions about the Code or for guidance when you are unsure; it is always better to ask before acting.
Investigation and enforcement
Every report is investigated confidentially and thoroughly, and employees are expected to cooperate fully with internal or external investigations. Confirmed breaches of this Code or the law can lead to disciplinary action up to and including termination of employment or contracts, and may be referred to law enforcement. Enforcement is fair and consistent, taking into account how serious a breach is, whether it was intentional and whether it was repeated.
In practice An employee suspects a colleague of taking personal payments from a customer to overlook issues. They report it to contact@autosmarts.co. We investigate discreetly and, if the allegation is confirmed, act swiftly, which may include dismissing the person responsible and informing the affected customer. The reporting employee’s identity is protected as far as possible, and they face no retaliation for coming forward.
Continuous improvement
Ethics and compliance are an ongoing commitment. AutoSmart’s management and compliance team review and update this Code and our policies regularly so they keep pace with changing laws and expectations, and we train our team on these principles and refresh that training periodically.
Conclusion
This Code reflects our commitment to doing business the right way: with integrity, accountability and respect. These principles guide every decision, from how we design our product to how we treat a single customer or colleague. By following this Code, we protect our reputation, comply with the law and create lasting value for everyone we work with.
For questions about this Code, or to report a possible breach, contact contact@autosmarts.co. Thank you for upholding these standards.