Code of Conduct

Why a Code of conduct?

The Code of Conduct defines how we conduct ourselves at HeadMining, and it has played a critical role in helping us earn our reputation. Every HeadMining employee or contractors (who have signed a subcontracting agreement) in every location, and at every level, including board members, directors, and officers alike, is bound to live up to the letter and the spirit of the Code even if it means losing an important contract or missing a business target. The Code of Conduct is more than an acknowledgment of the rules. It reflects a personal commitment to take responsibility for our actions and always to work with integrity.


Economic success and sustainable business are not contradictory but go hand in hand, better together. 

The HeadMining Code of Conduct outlines the minimum requirements to be met by our employees and suppliers regarding fair business practices and ethics, labor practices, impact on the environment and health and safety performance. 

Main principles

1. Fair business practices and ethics
Any HeadMining employees and supplier will uphold the highest standards of fair business practices and ethics, including: 

1.1 HeadMining employees and suppliers shall not engage in any form of corruption, extortion, embezzlement or bribery. They shall comply with all applicable anti-corruption laws and regulations of the countries in which they operate, and all applicable international anti-corruption conventions. Any HeadMining employees and supplier is obliged to foster fair and impartial competition. HeadMining employees and suppliers shall adhere to international trade regulations and export control regulations. 

Any HeadMining supplier shall avoid conflict of interest situations in relationships with HeadMining employees. Any supplier of HeadMining shall maintain an unquestionable standard of integrity, which includes that no excessive gifts and entertainment, travel, accommodation or other gratuities will be offered to HeadMining employees.

HeadMining shall not support suppliers in evading tax, or let their owners or employees benefit from price settlements that are not in line with ethical business practices and with tax and other legal requirements 

1.2 Protection of intellectual property
All employees and suppliers of HeadMining shall respect intellectual property rights and shall manage the existence of and information on technology and know-how in such a manner that the HeadMining intellectual property rights be adequately protected. 

Also, the HeadMining brand and logo is an example of property rights. Employees and suppliers shall not use the HeadMining logo or publish HeadMining as a reference customer in their online or printed communication tools without prior consent from HeadMining. Such requests can be sent to HeadMining maintains the right to cancel a given approval when the relationship with the employees and supplier would be ended. 

1.3 Confidentiality of information and disclosure of information
Information is an asset. All employees and employees and suppliers of HeadMining shall treat the information obtained from HeadMining strictly confidential. Information regarding the employees and suppliers’ business activities, structure, financial situation and performance should be disclosed in accordance with applicable regulations. It may also include information that suppliers, customers or partners may have entrusted to HeadMining.

Mark information appropriately, keep it secure and limit access to those who need to know in order to do their jobs. Avoid discussing information in areas where you may be overheard, such as airports, public transport, restaurants and bars, elevators, restrooms and cafeterias.

1.4 Secure Business 
All employees and suppliers of HeadMining shall conduct their business in a secure manner and will implement reasonable measures for minimizing their exposure to security threats. 

1.5 We focus on quality
We strive to help our customers gain competitive advantage by adding value through the performance and quality of our consultancy services.

1.6 We win trust by being honest
Trust is built through transparency and honesty. To be successful on a sustainable basis, we have to build each customer’s trust through the integrity of our words and actions. We don’t promise what we can’t deliver and strive to ensure that customers, shareholders and colleagues trust us to keep our word.

2. Labor practices 
The HeadMining employees and suppliers should support the ‘United Nations Universal Declaration of Human Rights’ and the conventions and the recommendations of its International Labor Organization. 

2.1 Compliance with legislation
Employees and suppliers of HeadMining shall comply with the laws and the collective labor agreements in the countries in which they operate. The employees and suppliers’ Code of Conduct and all respective practices should therefore be compliant with the related laws and regulations. 

2.2 Non-Discrimination 
HeadMining employees and suppliers should recognize and appreciate the existence of different values and cultural standards. Each employees and supplier should commit to provide equal opportunity in employment and should not discriminate on the basis of age, race, nationality, social or ethnic descent, gender, physical disability, sexual preference, religion, political reference, or union membership. Only professional qualifications matter. 

2.3 Fair labor conditions contracts, wages and working hours
A HeadMining employees and supplier should be compliant with all applicable international, national and local laws and/or collective agreements relating to wages, benefits, working hours and working condition 

3. Environmental stewardship
HeadMining expects its employees and suppliers to comply with all applicable environment regulations and legislations. 

4. Health and Safety
We seek to work with suppliers that provide a safe and healthy workplace for all of their employees. As a HeadMining supplier, you and your employees are committed to operate in a safe way whereby you are continuously working towards a goal of zero incidents. You provide your employees with all the necessary training and personal protection means. 

5. Employees and suppliers
A HeadMining supplier with employees is expected to implement an Employees and supplier Code of Conduct in its upstream supply chain or implement the HeadMining Code of Conduct for its employees.

6. Documentation and Monitoring
In order to ensure and demonstrate compliance with the Employees and supplier Code of Conduct, you shall keep record of all relevant documentation, and provide to us supporting documentation upon request. This Code forms an integral part of HeadMining’s employees and supplier relationship management and evaluation procedure. HeadMining will take a risk based approach in assessing employees and supplier’s compliance with the requirements of this Code. Monitoring may take the form of self-assessments, site visits and follow up on remediation plans. HeadMining will work with its employees and suppliers in addressing gaps identified 

Corrective Actions

HeadMining reserves the right to disengage from employees and suppliers that do not meet the requirements of this HeadMining employees and supplier Code of Conduct or who cannot provide or commit to an improvement plan.