Accurate Recordkeeping

Each StageGate employee is responsible for keeping complete, clear, and accurate records related to our work at StageGate.

Our records, and how we maintain them, are not only an indicator of our commitment to maintaining high professional standards but also to the respect with which we hold each and every one of our clients and partners.

We are proud to announce that effective October 3, 2022 StageGate began the process of certifying many of its policies and processes against ISO 9001: 2015; widely considered to be the most comprehensive international standard for quality management system design and implementation.

No Bribes or Corruption

StageGate expects to be successful because we have some of the best professionals delivering a valuable and credible service to our clients.  We do not game the system.  There is no place for bribery or corruption of any kind in our company.   Bribery and corruption are not limited to cash exchanges and can include gifts, travel expenses, meals, hospitality, giving a job to someone’s relative or close friend, or charitable contributions designed to influence.

We must all comply with laws such as the U.S. Foreign Corrupt Practices Act (FCPA), which prohibits giving bribes to non-U.S. government officials in exchange for favors.  While laws like the FCPA distinguish between bribing government officials and non-government officials, StageGate does not make such a distinction.  Bribery is always wrong, no matter who it involves.

We expect the same commitment to anti-corruption and fair dealing from our suppliers and other business partners.  Before engaging any party that may represent StageGate or its interests before government officials, our personnel are required to conduct proper due diligence as defined by StageGate’s Personnel Code of Conduct and Business Practices and are instructed to notify a member of our Senior Management Team directly if they see troubling signs (or red flags) that anyone might be engaging in bribery or other forms of corruption.

Gifts, Hospitality, and Donations                                                               

The exchange of gifts and hospitality involving those outside StageGate (such as suppliers and clients) can only be done where the purpose is to create goodwill and as a business courtesy.  It should never be done to create a feeling of return obligation.

Here are circumstances where the exchange of gifts and hospitality is never allowed:

1. It involves cash or cash equivalents, such as a gift card,
2. The gift or hospitality is not customary or tasteful,
3. It could be viewed as a bribe or attempt to secure improper influence,
4. It violates a policy or rule, either of StageGate or the other party’s organization; or
5. The value is excessive.

How do you know if the value is excessive?  The value should be modest, reasonable, and proportional to the business at issue. Before giving anything of value equal to or greater than $50 USD to an outside party, StageGate personnel must obtain written prior approval from a member of the Senior Management Team.

The same rules apply prior to any StageGate personnel member receiving anything of value equal to or greater than $50 USD from a non-StageGate party (such as a supplier.)  If a member of our personnel receive any such gifts, they are required to return it.

These rules apply on a per person per occasion basis.  However, recurrent or frequent exchanges of gifts or hospitality may still require written prior approval.

We must ensure that charitable contributions are made in the furtherance of StageGate official business (see our philanthropic endeavors) and never for purposes of securing an improper advantage.  Therefore, charitable contributions made either in StageGate’s name or with StageGate funds are only permissible when executed or directed in writing by a member of the Senior Management Team.  Political contributions made by StageGate are expressly prohibited under any circumstance however StageGate personnel are not barred from making such contributions in their own name utilizing personal funds.

Competition and Fair Dealing                                                                       

StageGate prides itself on being competitive but we equally take pride in playing by the rules.  We believe in free and open competition, which encourages innovation – our fundamental mission.

We therefore avoid any type of agreement or understanding that could reduce competition – including price fixing, bid rigging, market allocation, and agreements to restrict supply.  We do not share business plans or strategies with our competitors, even in casual conversation.

StageGate does not engage in abusive or manipulative behavior.  This applies to how we deal with everyone.  For clients, our goal is to meet or exceed their expectations of transparency and fairness.  We likewise aim to develop productive and trustworthy relationships with our partners (such as suppliers) that are grounded in a commitment to meeting one another’s obligations.

Money Laundering                                                                                 

Money laundering is the hiding of illegally obtained money by making it appear legitimate.  StageGate is committed to complying with all applicable anti-money laundering laws.

StageGate personnel are required to report any transactions that are structured in a way that could be viewed as concealing illegally obtained funds or illegal conduct.  Some examples may include:

1. Attempts to make large payments in cash,
2. Payments made in currencies other than those specified in the contract,
3. Requests for payment amounts that differ from what is required in the contract; or
4. Payment by someone who is not party to the contract.

Data Privacy and Security                                                                             

Our clients and personnel trust us with their data.  We maintain that trust by managing data responsibly and ethically.

We honor personal choice.  For example, clients can freely choose whether to share with StageGate certain business information about their business.  We only use data in the way(s) we mentioned when collecting it.  If we want or need to use it for a new purpose, we get new permission.  We collect and use only the data we need for the reason(s) we say.  And we never sell or rent data to outside entities for any purpose.

Likewise, StageGate only shares our intrinsic business data with others who share our commitment to managing data responsibly and ethically.  We follow all data protection and security laws within the countries where we do business.  Our personnel are required to follow all of StageGate’s policies when handling data, regardless of ownership, as failing to do so can result in severe consequences for both the employee and our company.  For questions, please contact us at privacy@stagegatelp.com.