GGA Code of Conduct

The GGA Code of Business Conduct establishes and promotes the company’s compliance with laws and ethical standards across all countries and jurisdictions where GGA conducts business. It sets the guidelines for conduct and clarifies the ethics and compliance expectations for everyone who works in the company. The Code of Conduct covers a wide range of business practices and procedures that GGA employees, suppliers, agents and representatives must follow. It is aligned with our mission and values and sets the standard to which we aspire. The Code of Conduct does not cover every issue that may arise, but it sets out basic principles to guide all employees and officers of GGA. All of our employees and officers must conduct themselves accordingly and seek to avoid even the appearance of improper behavior.

The Code of Business Conduct contains sections that cover compliance with laws, rules and regulations. It explains how GGA handles issues related to conflicts of interest, confidentiality, insider trading, corporate opportunities, competition and fair dealing, entertainment and gifts, bribes, political contributions, discrimination and harassment. Also, it specifies standards related to record keeping, reporting, and conduct for all employees of the company.

Any person, whether a GGA employee, affiliate, vendor, or client, may report any activities by a GGA employee that they believe may be in violation of GGA’s Code of Conduct. These reports will be treated confidentially at all times. Reports should be made via email to compliance-reports@ggasoftware.com or by telephone to +1.617.715.6915. GGA employees may also discuss concerns directly with their manager.

GGA Code of Business Conduct