Fortevento

Fortevento is a Microsoft Authorized Partner, and our partnership with Microsoft is fundamental to our business success. We highly value the principles of trust, integrity, and collaboration that define this relationship. In alignment with Microsoft’s Partner Code of Conduct, we recognize that our ability to serve customers and represent Microsoft depends on our shared commitment to ethical conduct and legal compliance.

Accordingly, Fortevento is committed to upholding Microsoft’s values in all aspects of its operations and expects the same from its suppliers. We seek to do business exclusively with suppliers who demonstrate a clear commitment to these values, comply with all applicable laws and regulations, and actively contribute to maintaining the reputation and image of both Microsoft and Fortevento. By doing so, we collectively reinforce a culture of accountability, transparency, and respect across the entire value chain.

As an authorized Microsoft Partner, Fortevento’s success is built on a foundation of trust, integrity, and ethical business conduct. We share and uphold Microsoft’s values, which guide our daily decisions and long-term partnerships. These values not only reflect who we are as a company but also form the basis for how we expect our suppliers to conduct business in collaboration with Fortevento and Microsoft.

Fortevento’s Supplier Code of Conduct is grounded in the principles of respect, accountability and integrity. Supplier Code of Conduct reinforces our collective commitment to ethical behaviour, legal compliance, and maintaining the highest standards of business integrity throughout our supply chain.

02 COMPLIANCE WITH THE SUPPLIER CODE OF CONDUCT

Suppliers and their employees, personnel, agents, subcontractors, and sub-tier suppliers (collectively referred to as “Suppliers”) are required to adhere to this Fortevento Supplier Code of Conduct (“Code”) while conducting business with or on behalf of Fortevento. As an authorized Microsoft Partner, Fortevento conducts part of its business in close alignment with Microsoft’s values and compliance standards. Therefore, Suppliers must also uphold these standards, especially in relation to any goods or services provided for Microsoft-related business.

Suppliers must ensure that their subcontractors and sub-tier suppliers also comply with this Code throughout their operations and supply chains where their work is related to Fortevento’s activities, particularly those involving Microsoft contracts or clients. Suppliers must promptly notify Fortevento if any circumstance arises that causes or may cause non-compliance with these standards.

In cases of conflicting standards between this Code and applicable law, Suppliers are expected to follow the more stringent requirement, provided it does not result in legal violation.

Suppliers who act unlawfully or in a manner that violates this Code or any applicable Microsoft policies may face corrective action, including the potential termination of their business relationship with Fortevento. Compliance with this Code is mandatory and is in addition to any other obligations under a Supplier’s contract with Fortevento.

03 BUSINESS PRACTICES, ETHICS AND COMPLIANCE

Fortevento expects all its Suppliers to conduct business activities lawfully, ethically, and with the highest standards of integrity, fairness, and respect when providing goods or services, including those, related to Microsoft customers or contracts. As Fortevento is a Microsoft Authorized Partner, these expectations are aligned with Microsoft’s own Partner Code of Conduct and are essential to maintaining mutual trust and reputation.

3.1. Anti-corruption: Suppliers must comply with all applicable anti-corruption and anti-money laundering laws. Any form of bribery, kickbacks, facilitation payments, or other corrupt practices is strictly prohibited.

No Supplier shall, under any circumstances, promise, offer, authorize, or provide anything of value—including, but not limited to, gifts, travel, hospitality, charitable contributions, or employment opportunities—to any Government Official or third party with the intent to improperly influence any act or decision, or to obtain an unfair business advantage in relation to Fortevento’s business interests.

Suppliers must prohibit any and all forms of bribery and corruption within their organization and throughout their supply chains. Any suspected unethical conduct, including bribery, kickbacks, or other corrupt acts by a Supplier’s personnel, representatives, or subcontractors, must be promptly reported to Fortevento.

3.2. Fair Competition: Suppliers will conduct their business in full compliance with all applicable fair competition and antitrust laws. Refrain, including, but not limited to, from entering into cartel agreements with competitors, such as market or customer sharing, price agreements, etc.

3.3. Public Procurement: when participating in public procurement procedures, Suppliers will support fair and open competition by complying with all laws and regulations related to government procurement, tenders, and bids. Supplier’s will refrain from participating in any form of unlawful agreements between public procurement participants or other mechanisms that restrict fair competition, infringes or may infringe principles of public procurement.

3.4. COMP with International Sanctions: Suppliers shall comply with all applicable international sanctions regimes, including those imposed by the United Nations, the European Union or its individual Member States, the United States of America, the United Kingdom, and any other relevant governmental or institutional authorities. This includes, but is not limited to, economic, financial, trade, and social sanctions that are in effect against the Russian Federation, the Republic of Belarus, or any other countries or entities, or physical persons subject to such measures.

Suppliers are responsible for ensuring that their operations, business relationships, and supply chains do not violate any applicable sanctions.

3.5. Accounting and Order Integrity: Suppliers shall maintain accurate, complete, and transparent business records in accordance with all applicable legal, regulatory, and accounting standards. All documentation related to transactions, billing, and reporting must truthfully reflect actual business operations and conditions.

Suppliers are strictly prohibited from placing orders to / through Fortevento for Microsoft technologies, products, services, or support without a valid, corresponding customer order or binding agreement in place. All transactions must be based on legitimate customer demand and properly documented to ensure transparency and traceability.

3.6. Technology Fraud and Deceptive Practices: Suppliers must not engage in any form of false, misleading, or deceptive business practices. This includes, but is not limited to, technology fraud or conduct that could mislead customers into purchasing or subscribing to unnecessary technical support, products, or services. To protect vulnerable consumers, Suppliers must not engage in unsolicited outreach or “cold-calling” aimed at promoting such services. All marketing and sales practices must be conducted transparently, ethically, and in full compliance with applicable consumer protection laws and regulations.

3.7. Conflicts of Interests: When advising a customer—particularly a public sector customer—on the selection or procurement of products or services, Suppliers acting on behalf of or in cooperation with Fortevento must act with transparency, integrity, and impartiality. Where a fiduciary or contractual obligation exists between the Supplier and the customer, the Supplier must avoid any business activity that constitutes, or could reasonably be perceived as, a conflict of interest. Suppliers are expected to disclose any actual or potential conflicts of interest to Fortevento promptly and take appropriate steps to mitigate such risks in accordance with applicable legal and ethical standards.

3.8. Gifts and Entertainment: only allowed within the limits under applicable law. Suppliers must exercise sound judgment and act with integrity when offering or accepting any form of business courtesy.

Gifts or courtesies that lack a legitimate background may be perceived as bribes or attempts to improperly influence business decisions. Even modest offerings may give rise to the appearance of a conflict of interest or compromised judgment.

Suppliers shall not offer anything of value—including gifts, entertainment, or favours—with the intent to obtain or retain business or secure an unfair advantage. Any courtesy extended to Fortevento employees must be modest in value, infrequent, appropriate to the business context, and in full compliance with applicable laws and internal company policies.

3.9. Advertising, Marketing and Customer Communication: Suppliers must ensure that all advertising, marketing, and customer communications related to Fortevento or Microsoft products and services are conducted in a truthful, accurate, and lawful manner. All representations made to customers must be clear, honest, and not misleading in any way.

Suppliers are responsible for complying with all applicable laws, regulations, and industry standards governing advertising and promotional activities. Marketing content must reflect the actual features, benefits, and capabilities of the products or services offered, and must not misrepresent facts or create false impressions.

3.10. Trusted Jurisdictions: Supplier’s shall reduce dependence on producers and suppliers that are not established or registered in a Member State of the European Union, a Member State of the North Atlantic Treaty Organization, or Member States of the European Economic Area, and/or the Organization for Economic Co-operation and Development, through various means.

3.11. Prohibition on Association with Aggressor States: Supplier’s must refrain from engaging in activities in countries that are carrying out military aggression against Ukraine. Do not be a member of a group of companies whose members are carrying out activities in countries that are carrying out military aggression against Ukraine. Do not participate in the activities of such a group of companies through your manager, members of another management or supervisory body, or other person(s) who have the right to represent or control the supplier, take a decision on his or her behalf, conclude a transaction, draw up and sign the supplier’s financial statements.

04 SOCIAL RESPONSIBILITY

Fortevento seeks to collaborate with Suppliers who demonstrate responsible behaviour from an economic, social, and environmental perspective. The supplier is encouraged to develop and enhance their practices in accordance with the recommendations outlined in this Code.

Fortevento anticipates that the Supplier will prioritize ethical conduct and professionalism in its operations. This entails establishing professional relationships founded on principles of tolerance and mutual respect, while simultaneously upholding the highest standards of professionalism in the activity. The supplier is committed to respecting human rights and creating safe and healthy working conditions

4.1. Respect for Human Rights, Equality, and Fair Labor Practices: Suppliers will treat all its employees fairly, respectfully, and will not infringe upon their dignity. Additionally, the Supplier shall: (1) ensure equal opportunities and equal treatment of workers in the professional field, irrespective of gender, age, marital or social status, nationality, race, sexual orientation, disability, pregnancy or maternity, political or religious beliefs, or other similar characteristics that are not directly related to work-related requirements; (2) refrain from employing compulsory or forced labor; (3) respect the dignity, privacy, and rights of every individual; (4) prohibit direct and indirect physical or verbal harassment, discrimination, psychological violence, or any other exploitative behaviour at work.

4.2. No Child Labor: directly or indirectly, not to employ children and not to use the work of children below the age provided for in the International Labor Organization Convention No. 138 on the Minimum Age for Employment (less than 15 years) and in the applicable legislation.

4.3. No Forced Labor: Supplier’s must prohibit corporal punishment and forced labor in their activities, as provided for in the Protocol No. 29 to the International Labor Organization Convention, including modern slavery and trafficking in human beings, as well as debt-forced labor and other forms of forced labor.

05 PROFESIONAL CONDUCT

Fortevento expects all Suppliers to conduct themselves with professionalism and integrity at all times. Suppliers play an important role in helping Fortevento—and by extension, Microsoft—maintain an inclusive, respectful, productive, and harassment-free working environment. Discrimination, harassment, or disrespectful conduct in any form will not be tolerated.

5.1. Use of Appropriate Language: Suppliers must refrain from using any language that could be considered discriminatory, harassing, intimidating, threatening, abusive, sexually explicit, or otherwise offensive or inappropriate in any professional context or interaction.

5.2. Fairness, Dignity, and Respect: Fortevento maintains a zero-tolerance policy for any form of harassment, including sexual harassment or harassment based on protected characteristics. Sexual harassment includes unwelcome verbal or physical behaviour based on sex or gender, such as inappropriate jokes or comments, unwanted romantic attention, offers of preferential treatment in exchange for sexual favours, or the display or sharing of sexually explicit content. Harassment also includes any degrading or offensive behaviour based on race, gender, sexual orientation, nationality, religion, age, disability, gender identity or expression, marital status, pregnancy, political views, union membership, veteran status, or any other legally protected status.

5.3. Behaviour at Events: At any event sponsored or organized by Fortevento whether on-site, off-site, virtual, or in-person, Suppliers are expected to behave in a professional and respectful manner at all times. This includes responsible consumption of alcohol and continued adherence to the principles outlined in this Code.

Suppliers who fail to comply with these expectations risk disciplinary measures, including the potential termination of their business relationship with Fortevento.

06 ENVIRONMENTAL PROTECTION AND COMPLIANCE

Fortevento is committed to minimizing negative environmental impacts related to the engaged business. This includes reducing contributions to climate change, pollution, waste generation, depletion of natural resources, and harm to ecosystems and their services.

Fortevento expects its suppliers to comply with all applicable environmental laws and regulations, maintain all required environmental permits and registrations relevant to their operations, and implement effective measures to conserve natural resources and reduce environmental impact.

Suppliers are encouraged to establish and implement procedures aimed at minimizing the environmental impact of their operations and to pursue continuous improvement in this area.

6.1. Environmental Protection: Suppliers are recommended and encouraged to:

1. take initiative in adopting and utilizing environmentally friendly technologies and materials, to actively reduce the negative environmental impact of their operations, and to conduct their business in a responsible and sustainable manner;
2. pursue responsible and environmentally sustainable sourcing of raw materials and, where applicable, to integrate environmental criteria into their purchase processes;
3. prioritize the use of energy generated from renewable sources wherever feasible.

6.2. Waste Management: Suppliers are recommended and encouraged to reduce the volume of waste generated by their operations  and to ensure proper waste management, including sorting and/or recycling of product packaging, and collaborate with authorized waste management providers to minimize environmental risks associated with waste.

6.3. Transportation: When delivering goods or providing services, suppliers are encouraged to prioritize the use of low-emission and/or environmentally friendly transportation methods to reduce their environmental footprint.

6.4. Sustainability Goals and Environmental Accountability: Suppliers are encouraged to establish responsible business and sustainable development goals, along with clear measures to achieve them, formalized through a policy, strategy, declaration, or other binding document.

Suppliers should assess the environmental risks associated with their operations and take proactive steps to minimize those risks.

Suppliers should evaluate and disclose environmental performance indicators related to their sustainability efforts in accordance with the requirements of the EU Regulation on the establishment of a framework to facilitate sustainable investment (Regulation (EU) 2020/852).