Your career, our journey

Internal Rules – Employment Policies

Updated December 2023

These Internal Rules – Employment Policies (the ‘Internal Rules’) describes how all employees, regardless of their position, are expected to conduct when working at Horizons or its affiliated entities (the ‘Company’).

These Internal Rules should be used as a guideline on daily rules and ethics, confidentiality, internet, and general health and safety. It also includes information on how the Company processes its employees’ personal data.

All employees are encouraged to reach out to the Company Local Point of Contact (as listed at the bottom of the page) for any further question.

Section 1. Daily Rules and Business Ethics

Working Hours and Workplace

Attendance and Punctuality. Employees shall be regular and punctual in attendance. This means employees are required to be ready to begin work as scheduled and on time. Except for employees working from their home office, employees are required to be ready at their appointed workplace on time. In the event it is impossible to report for work as scheduled, employees must inform their line manager or the Company management at the earliest and before the starting time when possible.

Overtime. Employees shall not work any overtime hours without the prior written approval of their line manager. Upon specific or exceptional circumstances, employees who need to work overtime must apply in advance to their line manager or the Company management and obtain written approval before working the intended overtime. Due to operational needs, the Company may schedule overtime for its employees, in this case, employees are required to cooperate, and will be granted overtime benefits in accordance with the applicable laws and regulations.

Annual Leave: A decent work-life balance is the key to a healthy workforce, and the Company strongly encourages all its employees to take their annual leave and consume the balance of their leave during each annual leave cycle.
Employees’ leave entitlement is mentioned on their employment agreement. Before taking any annual leave, employees must obtain the prior written approval from their line manager. The Company reserves the right to forbid leave at rush periods of the year.

Company Property. Employees shall not damage documents, materials, or public facilities of the Company or its clients, including the photocopy machine, meeting room, safety facilities or any other equipment on purpose (upon applicability). Additionally, employees shall not damage the property of colleagues and other business partners on purpose.

Housekeeping. Except for employees working from their home office, work areas, including personal desks, shall be kept clean and tidy at all times. When working late or overtime, employees shall ensure that all lights, air-conditioners, and other equipment are turned off when leaving the workplace.

Work Ethics

Professionalism. The Company and its clients’ integrity are essential for maintaining trustworthiness and reputation. Employees shall work fairly and honestly, and act with integrity, comply with laws, maintain a professional work environment, and comply with these Internal Rules.

Protection of Business Interests. Any fake or misleading statements about the Company, its clients and services, or any publication on social media or public speech to media about business information without prior authorization from the Company or its clients, shall be considered as a disciplinary offense.

Section 2. General Health and Safety

Health

Prevention of Risks. Employees shall note that the Company is committed to preventing and reducing the risk of injury or occupational illnesses to all its employees and the accidental loss of any of its resources and physical assets. At any time needed, the Company will inform and instruct employees about hazards and dangers. Company management always does everything reasonable to protect its employees from being injured or contracting an occupational illness.

Report. Employees shall help create a positive and safety culture and help minimize accidents on worksites. In this regard, employees shall report any hazards or injuries to their line manager or Company management. Employees shall further follow all policies and procedures, prioritizing their own safety as well as the safety of all colleagues. Employees shall have the right to participate in solving workplace health and safety problems. Any accident, incident, harassment, or similar, no matter how minor would be the injury or damage, shall be reported immediately to their line manager or Company Local Contact Point (as listed below).

Tobacco-Free and Alcohol-Free Workplace. Tobacco-Free and Alcohol-Free Policy is dedicated to providing a healthy, comfortable, and productive work environment for the Company’s employees. When working onsite, at the Company or its client premises, smoking, including e-cigarettes, shall not be permitted indoors, unless otherwise agreed. Smoking breaks shall be kept to a reasonable level and shall not impact on your daily duties or tasks. Drinking alcohol shall not be permitted at work, except in exceptional circumstances.

Diversity

Equal Opportunities. The Company is an equal opportunity employer committed to building a team representing diverse backgrounds, perspectives and experiences, and welcome applications from everyone, without regard to race, color, religion, sexual orientation and identity, gender expression and sexual characteristics identity or expression, pregnancy, age, national origin, disability status, genetic information, protected veteran status, or any other characteristic protected by law.

Right to Disconnect

Disconnection. The Company takes seriously the issue of cognitive and emotional overload from “hyper-connectivity”. In this regard the Company is committed to ensuring a balance between work and private life.
Disconnecting from work means not engaging in work-related communications, including emails, telephone calls, video calls or the sending or reviewing of other messages, so as to be free from the performance of work.
The Company does not expect employees to read or respond to work-related communications outside of their normal working hours, subject to the following exceptions: (i) where operational or business needs require such communications and the employee has been given notice in advance; (ii) where such communications are required due to the nature of employees’ duties or due to employees’ managerial or supervisory role; or (iii) where employees have been authorized to work flexible hours.

Anti-Harassment

Harassment-free Workplace. Employees shall always conduct professionally and be respectful to others. Workplace harassment, including sexual harassment, is a form of workplace misconduct and can be unlawful discrimination: bullying, harassment, discrimination, and other exclusionary behavior are not tolerated. Such behaviors include, but are not limited to:

Direct or indirect unlawful discrimination, with the meaning of unfavorable treatment of a person on the basis of race, color, national or ethnic origin, gender, marital status, pregnancy, disability, age, sexual orientation, religious belief, political belief, industrial activity and personal association with a person identified by reference to any of the above attributes;
Harassment, with the meaning of any form of behavior (verbal, written, visual or physical) that intimidates, humiliates, vilifies or offends another staff member, or makes the workplace uncomfortable or unpleasant. It includes but is not limited to, offensive jokes, words or pranks, racial slurs, stereotypes, yelling and name-calling, mocking an employee’s religion or culture, bullying, inappropriate texts, emails or online posts, asking an employee about their sexual orientation, intimidation or violence, sabotaging or destroying someone’s work or work equipment, etc.;
Workplace bullying, with the meaning of repeated, unreasonable behavior directed towards an employee that creates a risk to health and safety. It includes, but is not limited to, verbal abuses, exclusion or isolation of an employee, and psychological harassment. Reasonable management actions (e.g. meeting to address underperformance or investigation of alleged misconduct), low level personality conflicts, and difference of opinion shall not constitute bullying;
Sexual harassment, with the meaning of an unwelcome conduct of a sexual nature in circumstances where a reasonable person having regard to all the circumstances, would anticipate the possibility that the person would be offended, humiliated or intimidated. Sexual harassment is one form of prohibited, unlawful harassment and a type of sex discrimination. It includes, but is not limited to, any verbal and physical harassment of a sexual nature, looking at offensive materials at work, indecent exposure, sexual advances or continual requests for dates, unwelcome comments about an employee’s sex life or physical appearance, etc. Consensual personal relationships shall not constitute sexual harassment.

If employees feel that they have been subjected to or have witness any form of the above-described behavior, they should raise your concern to their line manager or Company Local Contact Point (as listed below).

Section 3. Code of Conduct

Bribery and Corruption

Anti-Bribery and Corruption. Employees are excepted to act professionally, fairly and with integrity in all business dealings and relationships, and shall immediately notify their line manager or the Company management in case there is any suspicion of any offense involving bribery, corruption, fraud or dishonesty in relation to the services provided.
Employees shall never demand or accept from third parties any gifts, benefits or advantages offered or given to them or a member of their family by reason of their employment with the Company.

Modern Slavery

Context. Estimations provided by the International Labor Organization reveal that approximately 24.9 million individuals worldwide continue to endure various manifestations of modern slavery. Among the entirety of these victims, a significant 20.8 million (equivalent to 83%) suffer exploitation within the confines of the private economy, either at the hands of individuals or enterprises.

The Company strongly condemns all forms of slavery, child labor, and human trafficking, including forced labor, debt bondage labor, and will never condone such practices.

The Company’s commitment to human rights elaborates on its values and approach to these issues. When collaborating with business partners or vendors, the Company ensures their business operations are free from modern slavery and human trafficking practices, both internally and in their supply chains and other external business relationships.

Whistleblower Protection

Disclosure. Employees are encouraged to disclose information that they have reasonable grounds to suspect relates to misconduct or an improper state of affairs or circumstance in connection with the Company or indicates that the Company or a member of its personnel has engaged in conduct that poses a danger to the public or the financial system, or that violates applicable law.

How to report. Such disclosure can be made to their line manager, senior manager, or Company Local Contact Point (as listed below), or any other person authorized by the Company to receive such disclosure. Such disclosure can be made in person, by phone, by video call or in writing.

Investigation. The Company will facilitate an investigation into the disclosure. If the disclosure was made anonymously, the Company will carry out the investigation on the assumption that the disclosure is a protected disclosure, where the whistleblower is not required to identify themselves to the Company for protection reasons. The whistleblower must confirm in writing whether they consent to the disclosure of their identity to parties involved in the investigation. The investigation may be undertaken internally or through an external investigator and will gather all relevant evidence necessary to determine whether the disclosure is substantiated.

Protection. The Company will not exercise any contractual right or seek contractual remedy against the whistleblower on the basis that the whistleblower made the disclosure. The Company will further take all reasonable steps to protect the whistleblower from detriment. The Company will ensure the fair treatment of any personnel mentioned in the disclosure, by giving them an opportunity to respond to the allegations.

Section 4. Data, Internet and Confidentiality

Computer and Internet

Virus Protection. Employees shall prevent the introduction of virus contamination into the Company or its clients’ computer, software, or network by completing standard virus testing procedures before using software, USBs, internet downloads, external hard drives, etc.

Use of the Company’s Computer Network. Under no circumstances may the Company or its clients’ computer or office network be used to obtain, view or reach any inappropriate, unethical, immoral or illegal content or websites. Doing so can lead to disciplinary actions, including warnings, suspensions, and employment termination.

Intellectual Property

Intellectual Property Ownership. Except otherwise agreed with Company or its clients, employees shall undertake and agree that any and all intellectual property rights, titles and propriety interests, including but not limited to copyright and patent, design and trademark in any invention, documentation, information or work that they have developed, contributed to develop, prepared or performed as part of their employment with the Company, shall be considered as and remain the Company or its clients’ sole property.

Return & Destruction of Property. Employees shall make sure that any confidential information, notwithstanding the fact that they may have created, developed, or contributed to the creation of such confidential information during their employment, shall be returned to the Company or its clients, upon termination of employment or before upon request, unless otherwise agreed with the Company or its clients.

Data Protection Notice

Basic Information. “Personal Data” refers to any information relating to employees, that could be used – on its own or in combination with other information – to personally identify all employees of the Company, for example name of email address. All and any Personal Data collected by the Company are: (i) used lawfully, fairly and in a transparent way; (ii) collected only for valid and reasonable purposes; (iii) relevant to the purposes that have been told about and limited only to those purposes; (iv) accurate and kept up to date; (v) kept only as long as necessary for the purposes; (vi) kept securely.

Data Collection. The following types of Personal Data may be collected and stored by the Company; they include, but are not limited to, the following:

Contact: email address, postal address, phone number(s), etc.;
Identity: name, marital status, date of birth, photo, national ID or passport, etc.;
Financial: bank account details, transaction information, etc.;
Employment: job title, hire date, performance history, sick time, package, etc.;
Background: academic and professional qualifications, CV, transcripts, etc.

Depending on the country where employees are hired and their status, the Company may collect sensitive data, which refers to information revealing racial or ethnic origin, religion, political or philosophical beliefs, criminal records, health condition, disabilities, or sexual orientation.

All data, provided from employees, must be true, complete, and accurate; employees must notify the Company of any change to such information during their employment, otherwise it may prevent the Company from being able to carry out its tasks and comply with its legal obligations.

Purpose for Processing Personal Data. Processing may take place before, during and after employment with the Company; below are listed the main reasons for processing employees Personal Data:

Contact & Identity: general communication, human resources management;
Financial: manage and process payment transactions, fulfill the Company’s obligations toward its employees;
Employment: onboarding, mobility and relocation process, tax calculation, accounting and legal requirements, identification and report of fraud, money laundering and other crimes, fulfillment of the Company’s obligations with local tax and labor regulations.

Storage Duration. Employees information will be retained for as long as necessary to fulfill the contractual or statutory obligations for which they were collected, and especially for the following reasons:

To comply with legal obligations;
To respond to a request or complaint;
When a longer retention period is required or permitted by law (such as keeping records for specific tax, accounting, or legal purposes).

When there is no ongoing legal reason or business need to retain such information, the Company will proceed either to deletion or anonymization.

Data Processing. The Company may process its employees’ Personal Data if they have given specific consent to use their personal information for a specific purpose.

Data Transfer with Third Parties. The Company may share its employees’ Personal Data with third parties listed below, without further notice to its applicable employees, unless otherwise required by law:

Vendors and services providers, as bank and financial institutions, web hosting companies and customer management services, etc.;
Business partners and other affiliates, as insurance carriers, brokers, current and future entities that control or are controlled by the Company, etc.;
Government agencies and tax authorities, as immigration offices, ministry of manpower, regulatory agencies, and other official or governmental bodies, etc.,
Public authorities, if the Company believes that such action is necessary to comply with law, or when required by law to respond to legal process;
Audit or other necessary action, in the event the Company is involved in a merger, acquisition, bankruptcy, transfer to another provider, the Company may disclose, sell, or share part of its assets including its employees personal data in the due diligence process.

Security. The Company aims to protect all Personal Data it processes, especially from loss, misuse, unauthorized access, alteration, destruction, or disclosure to unauthorized third parties. Thus, the Company has implemented organizational, physical, and technical measures: online and internal access to Personal Data are strictly controlled to ensure that they remain protected against any alteration: passwords, access control list, measures authorizing or restricting the granting and use of access to personal data, authentication procedures are in place, efficiently implemented and regularly tested. Users’ access is granted on the principle of ‘strict need to know’, for all arriving staff according to their seniority and duties; such access and cancelled for all departing staff. In addition, all the Company staff and vendors (when any) are subject to a duty or confidentiality and non-disclosure.

GDPR Framework. Regardless of whether the Company’s employees are a citizen or resident of a country of the European Union (“EU”) or the European Economic Area (“EEA”), the Company processes Personal Data, when applicable, in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the Data Protection Act 2018.

California Residents. For employees who are resident of California, the California Civil Code Section 1798.83 enables them to enquire about categories of Personal Data (if any) the Company may have disclosed to third parties for direct marketing purpose, and the contact details of all such third parties with which the Company has shared personal information in the preceding 12 months. To make such request, see Company Local Contact Point (as listed below).

Rights. When it comes to Personal Data, all employees shall have the following individual rights:

Right to be informed about how the Company process Personal Data;
Right for employees to withdraw consent to process Personal Data, at any time, for the cases where the Company relies on its employees’ consent for processing. Note that withdrawing consent may impact the Company’s ability to fulfill its obligations;
Right to access to Personal Data and obtain copy of them;
Right to request rectification of Personal Data, if incorrect or obsolete;
Right to request erasure of Personal Data, as far as possible;
Right to restrict the processing of Personal Data;
Right to object to the processing of Personal Data if employees think it would impact on their individual rights and fundamental freedom.

Data Protection. When dealing with the Company’s clients’ Personal Data, all employees must follow the above-mentioned principles of Data Protection.

Section 5. Discipline and Grievance

Breach, Violation, Grievance

Disciplinary Measures. Employees shall note that breaching, violating, or not complying, whether intentionally or not, with these Internal Rules, shall be considered as a disciplinary offense. The Company will promptly, thoroughly, and fairly investigate any such offense, and may take appropriate and progressive disciplinary action actions against the offending employee, including reprimands, suspensions, demotion, and employment termination. An oral remark is not considered a disciplinary sanction. Furthermore, no fine or other financial penalties may be imposed. In any case, the Employee will be informed of the issue and given the opportunity to respond.

Disciplinary records. When taking such disciplinary action, the nature of the offense will be explained to the applicable employee, from their line manager or the Company management. Offenses and investigations will be documented and kept in the applicable employee’s file.

Grievance. If any employee has any concerns about their employment, or how they are treated at work, they should raise your concern to their line manager or the Company Local Contact Point (as listed below) so these can be resolved.
The Company takes every complaints from its employees very seriously, and generally offers informal and formal complaint resolutions options (for country specific grievance procedure, see Section 6. below).

Informal complaint procedures emphasize resolution and are conducted if there is no risk to employees’ health and safety. Possible action can include employees seeking advice from their line manager to deal with the situation by themselves, the perpetrator admitting the behavior and/or the complaint being resolved through conciliation.
Formal complaint procedure focuses on proving whether a complaint is substantiated. It can involve the appointment of an investigator, investigations of the allegations, hearing all parties involved, implementation of an appropriate outcome (e.g. disciplinary action, official warning, personal coaching) by the decision maker.

Section 6. Country Specifics

Canada

Safe and Healthy Workplace. Use, possession, distribution or sales of drugs is strictly forbidden during working hours. Employees are prohibited from reporting to work while under the influence of recreational cannabis and any other non-proscribed substances. Employees who are on medically approved medication must communicate to their line manager or the Company management any potential risk, limitation or restriction requiring modification of duties or temporary reassignment [Substance Abuse Policy (Drug and Alcohol) – In application of the Cannabis Act 2019].

Responsibilities. The Company undertakes to identify any situations that may cause concern regarding an employee’s ability to safely perform their job function, ensure that any employee who asks for help due to a drug or alcohol dependency is provided with the appropriate support (including accommodation) and is not disciplined for doing so and maintain confidentiality and employee privacy.

Suspicion of Impairment. If there is reasonable belief that an employee is impaired at work, the following procedure may be enacted: (1) the employee’s line manager shall first seek another supervisor’s opinion to confirm the suspicion of impairment, (2) the line manager shall consult privately with the applicable employee to determine whether substance abuse has occurred. If the employee is considered impaired and deemed “unfit for work” (decision not requiring a breathalyzer or blood test) that employee may be advised by the Company that a shuttle service has been arranged to transport them safely to their home address or a medical facility. A meeting may be scheduled on the following day to review the incident and determine a course of action.

Disciplinary action for not meeting prescribed safety standards may be subject to disciplinary action up to and including termination of employment.

France

Hearing. During a disciplinary procedure, if the Company is considering imposing a sanction that will have an impact (immediate or otherwise) on an employee’s employment, their position, career or remuneration, the Company shall first organize a hearing to summon the applicable employee and specify the purpose of the summons. During the hearing, the applicable employee shall have the opportunity to provide explanations. The Company will notify the employee within 1 month of the date of the hearing of the decision [Employee’s right of defense – In application of L. 1332-1 to L. 1332-3 of the Labor Code].

Prescription. The Company shall not initiate disciplinary proceedings against such applicable employee after the expiry of a period of 2 months after the Company became aware of the wrongful act (unless the act has given rise to criminal proceedings within the same period).

Workplace Harassment (‘Harcelèment Moral au Travail’). Bullying/harassing is an offense. It leads to deteriorating working conditions. In France, the Penal Code prohibits psychological harassment. The Company takes every complaints from its employees very seriously. In case of psychological harassment, employees should raise their concern to their line manager or the Company Local Contact Point (as listed below) so these can be resolved. The Company will offer informal and formal complaint resolutions options, with as first step a formal talk about the problem and possible outcomes and solutions, including mediation procedure and disciplinary sanctions.

New Zealand

Personal Grievance. For personal grievance, employees have 90 days from the time the problem occurred, or became known by them, to raise the grievance with the Company. In case such grievance is due to sexual harassment, such delay is extended from 90 days to 12 months. The Company will offer informal and formal complaint resolutions options, with as first step a formal talk about the problem and possible outcomes and solutions.

South Africa

Personal Grievance. The Company offers informal and formal complaint resolutions options, with as first step a formal talk about the problem and possible outcomes and solutions.

Thailand

Personal Grievance. Grievance can be defined as an issue, concern, problem, or claim (perceived or actual) that an employee would like to be addressed by their company in a formal manner. If any employee has any concerns about their employment, or how they are treated at work, they should raise your concern to their line manager or the Company Local Contact Point (as listed below) so these can be resolved. The Company will offer informal and formal complaint resolutions options, and will follow the following process: (1) receipt of grievance by written form by the Company Local Contact Point, (2) internal screening of grievance and acknowledgement of receipt (including summary of the grievance and possible outcomes and solutions, the Company may ask for further details and information), (3) investigation, (4) action (upon applicability), (5) close out.

United Kingdom

Monitoring of emails. The monitoring of emails and other electronic communications in the workplace, if it happens, must be done in a lawful, fair and transparent manner; and is only possible for a specific, explicit and legitimate purpose [Email monitoring – UK Data Protection Act 2018]. Such practice is governed by the Data Protection Act 2018 and the General Data Protection Regulation (GDPR), which was adopted by the European Union (EU) and applies in the UK.

Personal Grievance. The Company offers informal and formal complaint resolutions options, with as first step a formal talk about the problem and possible outcomes and solutions. Furthermore, the Company follows the guidelines from ACAS, the Advisory, Conciliation and Arbitration Service.