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Ethics and Compliance: The CtrlS Promise

Trust. Integrity. Quality. Excellence.

CtrlS conducts its business ethically, honestly, and in full compliance with the laws. We believe that how we conduct ourselves is as critical to CtrlS success as providing the best services in the world. At CtrlS, we don’t just talk about a culture of ethical behavior and compliance with the law. We live it.

Our Commitment

As a responsible and sustainable organisation, our business practices are underlined by an utmost commitment to ethics and compliance. We have implemented a robust corporate governance framework and globally-compliant ethical standards that guide our business processes and define how we conduct business with our partners and customers.

Driven by Unwavering Values

Our Business Ethics

We have adopted a well-defined Code of Ethics and Business Policy that sets out the basic principles to guide all stakeholders in carrying out their business duties. The code is designed to be consistent with the legal and regulatory framework that governs our industry. It is guided by our organisational values and principles that form the core of our culture, along with our commitment of fair business practices to our stakeholders.
Our Business Ethics

Leading with Integrity

At CtrlS, we are committed to conduct business honestly, fairly, and with integrity and the highest ethical standards. In line with this, we have adopted a “zero-tolerance approach” to malpractices, which is reflected in our Anti-bribery and Anti-Corruption Policy. Consistent with our business ethics and compliance, the policy defines the rules and guidelines to ensure that business is conducted according to the highest ethical standards.

Empowering People to Uphold Ethics

Any concern related to malpractice or impropriety is treated by CtrlS with utmost seriousness. Our Whistle-blower Policy enables our people to voice their concerns responsibly and effectively. The purpose of this policy is to provide a framework to report any code violation without any fear of retaliation, victimisation, or unfair treatment.
Empowering People to Uphold Ethics
Reporting Framework Redressal

1. Report confidentially

The Whistle-blower can choose to report confidentially. Their identity will only be known to those who handle the case in confidence, and their identity will appear anonymous and confidential to others in case processing.

2. Report anonymously

The Whistle-blower can choose to report anonymously if they prefer not to provide their identity to anyone in the process.

The Chairman and Managing Director (CMD) shall review the functioning of the Whistleblower mechanism, at least once in a financial year.

Know More About Policies at CtrlS

This policy lays down the principles and guidelines to secure the accuracy and reliability of CtrlS’s accounting data and promote operational efficiency. It standardizes the way Finance and accounting activities are carried to ensure consistency, and provides a guidance to all staff of Accounts and Finance for smooth execution of their duties.  Stakeholders are encouraged to be conversant with this policy whilst dealing with CtrlS. The aim is to enable decision-makers to make informed decisions, through timely access to accurate data – financial or otherwise.

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This policy sets out the standards to identify and deal with the potential conflict of interests which occurs when an individual’s personal interests could compromise his or her judgment, decisions, or actions in the workplace. In order to ensure the highest degree of ethical conduct, we, at all times, endeavor to avoid the existence of actual and/or potential against conflicts of interest and have accordingly established this policy which outlines how CtrlS approaches any such situations.

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This policy sets the conditions under which you may use the registered and unregistered trademarks, service marks, logos, slogans or other CtrlS or its affiliated entities identifiers (“CtrlS Marks/ Marks”), in promotional, advertising, instructional, or reference materials. All CtrlS partners. customers,
consultants and other concerned parties (including employees) are expected to follow these guidelines for using the CtrlS Marks and brands properly in all communications, documents, and electronic messages.

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This policy outlines the requirements and processes that must be followed for CtrlS, its group companies, subsidiaries, and affiliates to work with third-party business partners. It sets out due diligence procedures for carrying out business with third parties to ensure commitments to establishing long-term relationships set on a strong foundation. The aim is to enable CtrlS to make informed decisions about who they associate with to avoid potential problems affecting its business ethics, values, and compliance.

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This Policy delineates the set of standards that CtrlS and its suppliers agree to ensure that a set level of legal, ethical, environmental and social practices are met. CtrlS expects its suppliers engage in legal, ethical social and environmental practices that are aligned with its brand values. In selecting suppliers, CtrlS seeks to do business with reputable business partners who are committed to ethical standards and business practices compatible with those of CtrlS. This Code applies to all suppliers of CtrlS including all of the CtrlS Suppliers’ facilities. CtrlS strongly encourages suppliers to exceed the requirements of this Code and promote best practices and continuous improvement throughout their operations.

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CtrlS is committed to acting legally in all of its business dealings wherever it operates. The Sanctions Policy outlines the actions that are required to ensure that the Company complies with Sanctions and that it does not contract or engage with countries, regions, industries, organizations or individuals which are the target of such sanctions. CtrlS complies with and expects all the Stakeholders to comply with the economic and trade sanctions laws and regulations, anti-money laundering laws and regulations, the trade sanctions laws of the United Nations (UN), European Union (EU), United States of America (US), as well as all applicable sanctions laws and regulations (including import and export control regulations) in the jurisdictions which we operate.  CtrlS expects all its Stakeholders to be compliant with the Sanctions Policy.

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This policy aims to establish principles for regulating the practice of offering and/or receiving gifts, entertainment, hospitality and/or other business courtesies. It sets out the minimum guidelines on the conduct expected from CtrlS employees, stakeholders and third parties acting on its behalf. It also aims to present internal control mechanisms for preventing and detecting any situations that could be interpreted as noncompliance.

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Vendor Code of Conduct:
Trademark Usage Guidelines
Third Party Due Diligence
Conflict of Interest
Finance and Accounts Governance

Note: The standards envisaged hereunder are applicable to CtrlS Datacenters Limited, its group companies, subsidiaries, and affiliates which includes all the employees, staff, Directors/KMP, contractors, sub-contractors, consultants, customers and other stakeholders, as appropriate for application.