Xago Europe SA – Ethical Code

How to use our Ethical Code?

Our Ethical Code helps all team members understand how to behave and act in the right way. It is a framework for support if we are unclear. It is impossible for us to envision and prepare for every single business situation that may pose an ethical dilemma.

Accordingly, we do not claim that this document is definitive or exhaustive.

Our Ethical Code does not rule out the need to exercise good judgment, but rather helps us to do the right thing. When in doubt, you should ask yourself the following questions:

  • Does it feel right?
  • Is it in line with the Company Values and Ethical Code.
  • Would I be comfortable explaining it to fellow team members, team managers, clients, family or, externally, to the press?
  • Is it legal?

If the answer to even one of these questions is “no”, it is probably not the right thing to do.

Open a dialogue with your team manager, to make the appropriate decision, and to be sure we continue “doing the right thing”.

What is our Ethical Code?

Our Ethical Code encapsulates our respect for the law and for individuals, and our responsibilities to our clients and stakeholders. It provides the basis for our ethical culture.

We respect international, national and local laws and regulations in the countries in which we work, and we undertake all necessary commitments to adhere to them.

Our Ethical Code sets out, explains and formalizes the Values, rules of conduct and behavior, and the principles of action that we expect from ourselves and that are required

of us in our relationships with stakeholders. It prevails over any business-level policy or procedure.

In the following sections of this Ethical Code, we aim to provide clarity and guidance, especially in fields that can pose ethical dilemmas. In such areas, exercising good judgment can be complex because you are in a gray area and there is a risk of breaking the law, sometimes even unknowingly.

In these situations, any misconduct could compromise our ethical culture, damage the Company’s reputation and potentially lead to significant sanctions.

We must follow our Ethical Code no matter where we operate and whatever the economic circumstances.

Who is it for and what are our roles?

Our Ethical Code is for all team members of the Company.

It applies to all of us, both team managers and team members, at every level of the Company. If you are in a leadership position or in a team manager role, you need to understand that these positions imply additional responsibilities to uphold our ethical behavior.

It is Company policy that no one will be retaliated against for raising any concerns in good faith regarding practices that may violate this Ethical Code.


  • Know and understand our Ethical Code;
  • Act consistently with our Ethical Code, and if in doubt seek guidance from my team manager;
  • Demonstrate and live our Values, rules of conduct and behavior, and principles of action.


  • Lead by example and maintain, promote, and live our Ethical Code in my daily work;
  • Ensure that our Ethical Code is alive within my team;
  • Ensure that I am familiar with the Ethical Code, since my team members may come to me for advice and guidance on certain issues in our Ethical Code;
  • Identify compliance risks and make the appropriate decisions regarding issues relevant to my area of responsibility.