Governance

Company Policies

Strong corporate governance principles combined with our commitment to being a socially responsible business lie at the heart of all our policies. Find out more about some of our key policies below.

Codes of Conduct

  • Code of Conduct

    At Micro Focus, how we do things is as important as what we do. Continued success depends on our working together and competing to win, while at all times acting with honesty, integrity, and respect.

    At Micro Focus, we are committed to maintaining the highest ethical standards in our business dealings around the world. Our Code of Conduct sets out the standards that guide our business practices and govern our behaviour.

    We require a culture of integrity and honesty in all our business dealings worldwide. In particular we take a zero-tolerance approach towards dishonesty, bribery or corruption of any type in all parts of our business operations and in every part of the Micro Focus group. We require the same standards from our third party business partners.

    It is essential that we work together to address any issues that arise under the Code of Conduct, any related policies or local legal requirements. This includes all of our employees taking action and reporting what does not seem right.

    It is the responsibility of each employee to apply the highest ethical standards in making business decisions including where there is no stated guideline in the Code of Conduct.

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  • Partner Code of Conduct

    At Micro Focus, we work collaboratively with our partners to conduct business with a focus on the needs of our customers and uncompromising integrity in our business relationships. Micro Focus expects our partners to uphold the highest standards of integrity in all business interactions. Micro Focus partners must comply with the requirements of the Partner Code of Conduct or their own requirements, which must be no less stringent. Micro Focus partners are responsible for ensuring that their employees (regular and temporary), officers, directors, agents, independent contractors and sub-contractors comply with the requirements of this Partner Code of Conduct or their own requirements, which must be no less stringent.

    Micro Focus requires that Micro Focus partners:

    • Implement effective business controls, policies and procedures that prevent and detect unlawful conduct;
    • Comply with and agree to contractual provisions that require strict adherence to all applicable anticorruption laws and other laws that are relevant to their Micro Focus partner status and their activities as Micro Focus partners;
    • Following a request by Micro Focus, grant Micro Focus access to audit their compliance with those laws described above, as well as the effectiveness of the Partner's compliance policies, procedures and controls;
    • Proactively report to Micro Focus actual or potential violations of the Partner Code of Conduct or applicable laws involving Micro Focus services, products or business by Partners' employees and representatives, or any Micro Focus' employees and representatives;
    • Provide certification of their compliance with laws referred to above; and
    • Complete all related Micro Focus training and due diligence as and when requested by Micro Focus.

    A breach of the Partner Code of Conduct is considered a breach of the partner's contract with Micro Focus and may lead to termination of the business relationship with Micro Focus.

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  • Supplier Code of Conduct

    At Micro Focus, we believe in the importance of ensuring that our business is conducted to the highest of ethical standards. We also expect our suppliers to uphold the highest of ethical standards over the course of their business operations by complying with the standards set out in our Supplier Code of Conduct, or their own equivalent standards suitable for their business, which must be no less stringent. Micro Focus suppliers are responsible for ensuring that their employees (regular and temporary), officers, directors, agents, independent contractors and sub-contractors comply with the requirements of the Supplier Code of Conduct, or their own equivalent standards, which must be no less stringent.

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Anti Bribery

  • Anti-Bribery and Corruption Policy

    The Anti-Bribery and Corruption Policy establishes Micro Focus' global approach to preventing bribery and other forms of corruption. The policy highlights the business circumstances that may give rise to the risk of corruption, and describes what to do in those situations. This is a critical area of compliance for Micro Focus as a company as well as for all of the people working for it individually. If Micro Focus engaged in any bribery or corrupt activity, or failed to prevent bribery by third parties with whom it deals, this could result in criminal liability for Micro Focus (and, in some cases, the individuals involved), for which penalties include imprisonment and/or unlimited fines. It could also result in significant reputational damage and loss of trust.

    The guiding principles of the Anti-Bribery and Corruption Policy are as set out below:

    • The giving or taking of bribes (including facilitation payments) are prohibited;
    • Adequate steps must be taken to prevent third parties bribing on Micro Focus’ behalf;
    • You must not engage in activities that create the appearance of impropriety;
    • You must maintain accurate books and records; and
    • You must comply with all anti-corruption laws, including those concerning money laundering.

  • Charitable and Political Donations Policy

    The purpose of Micro Focus’ Charitable and Political Donations Policy is to set out the principles and procedures that guide the decisions of the Micro Focus group when supporting projects that align with our corporate social responsibility program, Micro Focus INSPIRE. It also provides information about Micro Focus’ process for funding employee-volunteering projects to those applying for funding. Priority is given to projects that meet the social impact goals and criteria outlined in the Policy.

Privacy

  • Privacy Policies

    At Micro Focus we take our technology and data security requirements seriously. Our employees are required to conduct themselves and manage personal data in accordance with all applicable Data Protection Regulations.

    In order to ensure GDPR compliance, Micro Focus established a dedicated programme team which executed a GDPR compliance project over an extended period to address the requirements of the new Regulation.

    The programme team was comprised of internal and external project managers, IT and legal privacy specialists and included a dedicated, full-time team from Deloitte as well as external UK counsel, Travers Smith. The programme team engaged with all functions within Micro Focus to fully implement the compliance programme.

    Through the GDPR compliance programme, Micro Focus has reviewed and improved our processes for managing and protecting data and has established an operational framework to help ensure GDPR compliance when processing personal data. Micro Focus has sought to ensure this through an extensive range of measures, including:

    • Updating our privacy policies and statements, and establishing comprehensive Records of Data Processing activities to meet GDPR requirements;
    • Establishing new processes to ensure privacy by design and privacy by default is taken into account when designing new products and services by ensuing Privacy Impact Assessments are carried out in accordance with legal requirements;
    • Providing GDPR awareness training to all employees and specialised training for key internal functions, and this is regularly refreshed;
    • Updated contract terms with Suppliers and Customers to meet GDPR requirements;
    • Updated processes for facilitating data subject access requests;
    • Established a cross functional Security Incident Team to quickly respond to data incidents and records of any such incidents are logged in the Records of Processing;
    • Undertaking an extensive data mapping exercise to identify locations of data processing and third party processors engaged to provide products and services to customers

    These activities form part of a comprehensive programme of work designed to ensure compliance going forward, and is regularly monitored.

    In addition, Micro Focus has established a Privacy team to coordinate and advise on all aspects of GDPR compliance.

Environmental Health and Safety

  • Environmental, Health and Safety Policy (EHS) Policy Statement

    As one of the world’s leading providers of ‘digital transformation software’, Micro Focus’s mission is to provide the most dynamic, customer-centered innovations with the provision of safe and healthy working conditions for the prevention of work-related injury and ill-health. The elimination of hazards and reduction of EHS risks will always be central to this mission

    This policy statement embraces the organisation’s commitment to fulfilling legal requirements and other requirements, and continual improvement of the EHS management system to enhance the organisation’s overall EHS performance.

    Workers, and their representatives, will be involved in the organisation’s decision-making processes of the EHS management system; as cooperation and collaboration are expected norms within the organisation’s management. It is expected that a motivated workforce will embrace the organisation’s values, and complement the cooperation and collaboration needed to achieve the effective application of our processes for EHS performance improvement.

    The effective implementation of this EHS policy is expected to bring forward financial benefit through the effective application of improvement, consultation, participation, and operational processes. This EHS policy will be applied for effective control over the organisation’s outsourced processes and contractors, to ensure its EHS performance.

    This EHS policy statement will be communicated to workers within the organisation and be available to interested parties, as appropriate.

    A review of the EHS policy and statement will take place at least annually, to ensure it remains relevant and appropriate. This will be in conjunction with workers and their representatives, where they exist.

Governance

  • Auditor Independence Policy
  • Group Tax Policy
  • Whistleblowing Policy

    Micro Focus encourages a culture of openness and transparency across the organisation so that staff can speak up where they feel our people and customers are at risk, or where areas of wrongdoing have been identified or are suspected.

    In the Whistleblowing Policy, “wrongdoing” means any non-compliance with law, the Micro Focus Code of Conduct or other Micro Focus policies or procedures, and any other dishonest actions. Some examples of wrongdoing are set out in the list below:

    • Unprofessional treatment of a customer by staff members or intermediaries;
    • Criminal offences including bribery; • Defrauding any Micro Focus Group company;
    • A failure to comply with any legal or regulatory obligation;
    • Any abuse or misuse of company inside information including disclosure and/or dealing in Company shares or options while in possession of inside information;
    • A miscarriage of justice;
    • Endangering the health and safety of any individual;
    • Damage to the environment;
    • Breach of standing financial instructions;
    • A breach of the Micro Focus Code of Conduct;
    • Negligence; and
    • Deliberate concealment of any of the above.

    All staff members, business partners and suppliers (including distributors, channel partners, agents, contractors, senior managers, officers, directors, employees, consultants, contractors, homeworkers, part-time and fixed-term workers, casual and agency staff), are encouraged to report any actual or suspected wrongdoing (whether in the UK or elsewhere) by other staff members, business partners or suppliers. Any person raising a concern must also notify the Micro Focus Legal department at the outset if they have any personal interest in the matter.

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Human Resources

  • Anti-Harassment and Anti-Bullying Policy and Procedure

    Micro Focus seeks to provide a work environment where employees are treated with respect, dignity and consideration. This commitment is built upon a framework of policies and practices designed to ensure fairness in the recruitment, development and retention of employees. Micro Focus has formulated the Anti-Harassment and Anti-Bullying Policy and Procedure together with guidelines on its implementation and made it fully available to all employees.

    The Policy does not form part of any employee contract of employment and Micro Focus may amend it at any time or depart from it where considered appropriate. Harassment of people at work is a feature of discrimination and procedures to deal with harassment are an integral part of any equal opportunities strategy. The Policy establishes standards for Anti-Harassment & Anti-Bullying, which are applicable throughout the Micro Focus group of companies worldwide. These standards apply regardless of any lower standards as a result of local customs, cultures or laws. Where local law should apply a higher standard, that higher standard will apply. Any such prohibited conduct by non-Micro Focus employees, such as, clients, visitors, suppliers, contractors, or third parties will not be tolerated and prompt and appropriate action will be taken.

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Human Rights

  • Anti-Slavery and Human Trafficking Policy

    Modern slavery is a crime and a violation of fundamental human rights. It takes various forms such as slavery, servitude, forced or compulsory labour, child labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.

    Micro Focus has a zero-tolerance approach to modern slavery. Micro Focus is committed to acting ethically and with integrity in all of our business dealings and relationships. We are also committed to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or supply chains. Our commitment to respecting human rights is guided by the Universal Declaration of Human Rights and the United Nations Guiding Principles on Business and Human Rights.

    We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains.

    Micro Focus' latest Anti-Slavery Statement is available to download below and is consistent with our disclosure obligations under section 54(1) of the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children. We expect that our suppliers will hold their own suppliers to the same high standards.

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    Micro Focus’ Anti-Slavery and Human Trafficking Policy is also available to download below.

    Download PDF

  • Human Rights Policy

    Human rights are the fundamental rights, freedoms and standards of treatment to which all people are entitled. Respecting human rights is a core value at Micro Focus and is embedded in the way we do business. Micro Focus seeks to comply with all relevant legislation as well as upholding and respecting human rights as reflected in the United Nations Universal Declaration of Human Rights, the OECD Guidelines for Multinational Enterprises, the UN Global Compact and the UN Guiding Principles on Business and Human Rights, amongst others. These standards include ensuring that the rights of women and minority groups are protected and that employees are able to exercise their right to freedom of expression. We expect our employees, agents, suppliers and business partners to support and respect the protection of human rights in line with our own ethical values and apply the same high standards to all company operations, regardless of geographic location. The Human Rights Policy focuses on the areas that have been identified as priorities for our business and broadly defines how Micro Focus, employees, contractors, suppliers and business partners will respect human rights in relation to our operations.

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