Code of Ethical Responsibility

The Code of Ethical Responsibility is divided into two parts. The Code of Ethical Responsibility for the Company, outlining Different by choice/InClub Magazines responsibilities and commitments as an organization, and The Code of Ethical Responsibility for the Employees, setting forth their responsibilities. These are statements of principle. For additional details about how the principles are applied or if you want to discuss a possible breach of the Code, you should consult with your supervisor, the Human Resources department in your company or your company President.

You may also communicate by sending a message to [email protected] where any issues will be treated with sensitivity and discretion.

Ethical Responsibilities of the Company

  1. Respect for the Law – The company will respect the law in the countries and in the legal jurisdictions where it operates.

  2. Honest and Ethical Business Conduct – The company will conduct its business in an honest, fair and ethical manner. This applies to its interaction with all those affected directly and indirectly by the company’s activities, including: employees, customers, readers, users, advertisers, business partners, suppliers and external organizations and agencies.

  3. Fairness to Employees – The company will treat its employees honestly, fairly and with respect and courtesy

  4. No Tolerance for Harassment – The company is committed to providing a workplace free of bullying and harassment, whether sexual harassment or any other type of abuse. Bullying and harassment will not be tolerated.

Harassment may involve conduct of a sexual nature (sexual harassment). This can include any unwanted physical (e.g. touching), verbal (e.g. sexual remarks or propositions, suggesting the submission to or rejection of sexual advances will influence employment related decisions) or non-verbal conduct (e.g. unwelcome sexual advances or the display of pornographic or obscene material). The company will investigate any claims of harassment or abuse and will take remedial measures if necessary.

  1. Equal Opportunities – The company will provide equal employment opportunities to employees and applicants without regard to race, color, religion, age, gender, sexual orientation, disability national origin, marital status or any other characteristic which is protected by the laws and regulations to which Different by Choice/InClub Magazine is subject.

  2. A Safe Workplace – The company will maintain a safe workplace. All relevant health, safety, environmental and labor laws will be observed.

  3. Employee Privacy – The company will respect the privacy and confidentiality of employees’ personal information, acquiring and retaining only the data which is necessary for the effective operation of the company or for legal purposes.

  4. Customer Data – Customer data will be employed correctly. The company will treat and use customer data in accordance with applicable laws and regulations and with accepted business practices.

  5. No Tolerance for Corruption – Bribery, kickbacks and corrupt practices will not be tolerated on any level. Guidelines relating to the giving of gifts are set forth in the Anti-Bribery Compliance Policy, which is available upon request at [email protected].

  6. Contribution to the Community – Different by choice/InClub Magazine will strive to make a positive contribution to the markets and communities which are served by its products and services.

  7. Intern Policy – The policy of treating employees honestly and fairly, and in a respectful and courteous manner, applies also to interns. Working conditions and compensation for interns must conform to the laws and regulations of the country or community where they are interning.


Ethical Responsibilities of the Employee

  1. Professional Responsibility – Employees shall carry out their professional responsibilities to the best of their abilities and making their best efforts.

  2. Conflict of Interest – Employees should avoid situations where their personal interests could come into conflict with the interests of Different by choice/InClub Magazine. If a conflict of interest arises, then it should be discussed with management and an effort made to eliminate the conflict.

  3. Improper Benefit – Employees should not use company property, information or their position in the organization for personal gain.

  4. Working a Second Job – Working at a second job or for an external organization — including other media, advertisers or suppliers — is not permitted without the permission of management, unless the country or local regulations prevent Different by choice/InClub Magazine from requiring such permission. In the latter case, the employee is expected to disclose the external job to company management.

  5. Risk to Reputation – Employees should not take any action or behave in a way which brings harm to the reputation of Different by Choice/ InClub Magazine.

  6. Journalistic Accuracy/Fact Checking – Employees, especially journalists and editors, should make all reasonable efforts to ensure that information and content is reported honestly, accurately and fairly.Reporters, Editors, Journalist and Writers must be precise with their words, headlines, and URLs. They must understand that words have power and act responsibly. In doing so, reporters must verify the information they gather. This includes identifying information such as names and positions, but also includes factual statements and accounts. Reporters, Editors, Journalist and Writers conduct their own fact checking using their own judgment guided by the ethics policy. Different by choice/ InClub Magazine will use fact checkers in certain circumstances it deems warranted.

  7. Respect for Property – Employees should protect company assets against theft, damage, carelessness, waste and misuse, and should respect the property of others.

  8. Confidentiality – Employees should only share confidential information with other employees or authorized persons who have a legitimate need to receive it. “Confidential information” includes not only information which has been explicitly designated as confidential but also information which one can reasonably expect should be regarded as confidential. Company management can decide and direct an employee to share information when it is appropriate to do so. The instruction not to share confidential information applies to sharing information even with one’s family and friends.

  9. Electronic Communication – Employees must adhere to their company’s policy regarding electronic communication and online activity on company-controlled systems.

These codes are a guide to ethical behavior by the company and by its employees. They should be regarded with seriousness and followed. These codes may not address every business, personal or ethical question which arises. When there is a question or doubt, the principles of honesty, fairness and respect for others can be considered a general underlying foundation for ethical policy.