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Code of Conduct


FreeBalance is committed to Ethics

FreeBalance, like many successful organizations, bases its success on trust – trust that we will uphold the highest ethical standards when providing quality services to our government clients. FreeBalance products and services are designed to improve governance and reduce corruption. As a result, it is imperative that FreeBalance operates with a level of integrity that is beyond reproach.

To help advance and preserve this trust, FreeBalance has developed this Code of Conduct designed to serve as a guide and reference for our behavior.

Because the global business climate is so dynamic and complex, it is difficult to cover everything in one document. This Code of Conduct is designed to outline the behaviors that employees, partners and customers can expect from any employee of FreeBalance but is not meant to be an exhaustive list of all legal or ethical matters. However, this framework will be used when considering legal and ethical requirements for any country.

The fundamental principles of the FreeBalance Code of Conduct can be easily summed up as honesty, integrity, transparency and a commitment to “doing the right thing.” The FreeBalance Code of Conduct is publicly available.

What we believe in


Our vision is to make the world a better place by transforming government through technology.


The FreeBalance Mission is to help governments across the world leverage robust government financial management technology to accelerate country growth.


FreeBalance values are:

  • For Profit Social Enterprise focused on global customer-sustainable systems for public financial management
  • Customer-centric organization to ensure long-term sustainable “customers for life”
  • Increase the global understanding of public financial management good practices to improve global stability and reduce poverty
  • Sustainable differentiation through laser focus on the public sector to improve products and processes are optimized for government

The result of these values for conduct is:

As a For Profit Social Enterprise

  • Ensure the financial sustainability of government customer implementations by reducing long-term costs or the Total Cost of Ownership (TCO) through reducing implementation and maintenance costs
  • Operate within Corporate Social Responsibility practices by building human capacity within the government and by hiring locally and regionally.

As a customer-centric organization

  • Provide avenues for customer communication to improve products, processes and services to meet needs particularly of developing countries
  • Maintenance of a governance structure, the FreeBalance International Steering Committee, as a formal oversight organization, to drive product and service requirements
  • Provide methods of on-line, telephone, VoIP and in-person communication to adjust the company products and services to meet changing needs
  • Formalize processes as part of the IS0-9001 process
  • Provide methods to adjust the product roadmap to meet customer needs rather than impose product preferences
  • Provide transparency on the customer-centric processes through publicizing, customer satisfaction surveys and documenting non-confidential information coming via the FreeBalance International Steering Committee (FISC)

As an advocate of public financial management provider

  • Participate in on-line and in-person conferences on public financial management
  • Share good practices learned from research, events and customer experience with the broader PFM community
  • Develop processes to enable developing nations to better sequence reform and achieve good governance

As a provider of products and services exclusively for government

  • Develop processes that reduce risk of failure such as committing to customer requirements and reducing the burden of custom development
  • Adapt good practices in project management to the government domain by updating the ISO-9001/2008 certified process known as i3+qM that covers product development, implementation services, support, partners and procurement
  • Ensure high integrity in dealing with governments and partners including eliminating conflicts of interest, mitigating external risks of graft and fraud, accepting contracts only for which we have expertise, accurate billing and ensuring fair pricing

Other Principles

Agents: FreeBalance does not engage third party sales agents or “marketing representatives”.

Business interests: No FreeBalance employee can be engaged in an outside business with government public officials of any country.

Charitable activities: FreeBalance makes no charitable contributions that could be interpreted as influencing government officials. All FreeBalance charitable contributions and Corporate Social Responsibility (CSR) activities are related to children charities through Non-Governmental Organizations that are unaffiliated with government organizations.

Confidentiality: FreeBalance is committed to maintaining the highest degree of integrity with potential, current and past government clients. Confidentiality is extended to agreements with partners and suppliers. As a Canadian company, FreeBalance follows the Government of Canada Personal Information Protection and Electronic Document Act (PIPEDA) regardless of country origin. Proprietary information, non-disclosure and contract agreements will be respected.

Conflicts of Interest: FreeBalance will not engage in business that has an obvious conflict of interest. In particular, FreeBalance will not use personal relationships or existing commitments to leverage preferential treatment. There will always be a disconnection of all personal potential perceived conflicts of interest by disallowing those employees who may have personal influence in countries through friendship or family from participating in business in that country.

Cooperation: FreeBalance cooperates fully with any official investigations or audits into company business practices within the bounds of the Laws of Canada.

Discrimination: Canadian laws related to discrimination based on gender, sexual orientation, marital status, disability, age, race and religion will be respected. Discrimination will not be tolerated and respect for individuals will be respected.

Ethics: FreeBalance will give the best possible advice to governments and treat customers, contractors, partners and suppliers with integrity.

Facilitation Payments: FreeBalance does not make facilitation payments.

Partnership Considerations: FreeBalance makes no partnership agreements with organizations owned by government officials or family members of government officials.

Political Contributions: FreeBalance makes no political contributions.

Public Officials Recruitment: FreeBalance does not recruit or hire public officials (civil servants or appointees) from government departments or International Financial Institutions, or politicians from governments, with which the company does business (“influencers”). FreeBalance does not recruit or hire the business associates or close relatives (children, parents, spouse(s), siblings) of influencers. In the event that an existing FreeBalance employee is related to a person who subsequently becomes an influencer, that employee will not participate in any business with the relevant government or International Financial Institution. Any request by an influencer to hire any person or firm will be reported immediately to the Chief Compliance Officer.

Records Management: FreeBalance retains electronic and physical records based on the legal requirements from the Laws of Canada. No records that document possible violations of the Code of Conduct can be destroyed during the retention period specified by law.

Timelines: There will be prompt internal reporting and processing of Code of Conduct violations

Transparency: Although a privately-held company with no obligation to expose unique business practices, FreeBalance must be transparent in government relations that do not compromise confidentiality. The FreeBalance customer-centric processes such as enhancement gathering, FISC and product successes must be presented to potential customers during the proposal stage.


FreeBalance conduct must be above reproach and follow applicable laws:

  • Laws and ethics of Canada are to be used in all countries
  • Where the FreeBalance Code of Conduct exceeds the law of Canada or any country in which business is conducted, the FreeBalance Code of Conduct will take precedence
  • Where the law of any country exceeds the FreeBalance Code of Conduct, the law of that country will take precedence


Every employee share use best efforts to ensure that company communication is in line with the Code of Conduct, both internally in FreeBalance and externally to all stakeholders. All FreeBalance employees are bound by the conditions of the Code of Conduct and it forms part of each employee’s employment contract. Exceptions to the Code of Conduct will be identified in any case where provisions are outside the labour laws of the country of hiring.


FreeBalance management, employees, board members and business partners must respect non-disclosure agreements, and can provide internal FreeBalance employees with third-party confidential information only when there is a legitimate need to know for conducting business. Information learned about the practices of any FreeBalance government customer can only be exposed outside of the internal FreeBalance need to know network when that information is publicly known, when FreeBalance has express permission to present the information (such as for official publicity purposes) or when the information exposes corrupt practices or is otherwise required to be disclosed at law.


All transactions conducted by FreeBalance including employee expenses are vetted. Any ethical misconduct for presenting expenses that were not incurred or expenses fraudulently intended to be things of value to a government official or partner will result in immediate termination.

Ethical Behaviour

FreeBalance and FreeBalance employees are prohibited from offering or accepting bribes and from engaging in the following Prohibited Practices:

  • “corrupt practice” is the offering, giving, receiving or soliciting, directly or indirectly, of anything of value to influence improperly the actions of another party;
  • “fraudulent practice” is any act or omission, including a misrepresentation, that knowingly or recklessly misleads, or attempts to mislead, a party to obtain a financial or other benefit or to avoid an obligation;
  • “collusive practice” is an arrangement between two or more parties designed to achieve an improper purpose, including to influence improperly the actions of another party;
  • “coercive practice” is impairing or harming, or threatening to impair or harm, directly or indirectly, any party or the property of the party to influence improperly the actions of a party.

FreeBalance International Steering Committee (FISC)

FISC includes quarterly company updates and a yearly conference to set product priorities and improve processes. FreeBalance government customers come from many countries across most continents. To ensure reasonable ethics and the perception of ethics, FISC has the following provisions:

  • Governance and FISC procedures are approved by the FISC Chair who is elected by FISC members
  • FreeBalance has no control over the persons who attend FISC, this is determined by the country government
  • Costs for flights, meals, accommodation and entertainment will be provided through Product Support and Maintenance (PSM) payments to ensure that country participation is not cost-prohibitive
  • PSM is used as a method to balance costs so that representatives from one country do not have to pay more in a year by virtue of distance
  • Flights and other factors will be governed by FreeBalance cost policies of lowest cost economy flights
  • FISC events in every even numbered year, when Ministers of Finance are invited, will be hosted by a FreeBalance government customer to facilitate visa processes
  • FISC events in every odd numbered year, when Ministers of Finance are not invited, will be hosted in a country that has a FreeBalance office
  • FISC attendees present about lessons learned in PFM reform and technology adoption, participate in discussions and workshop, vote on the product roadmap and complete detailed customer satisfaction surveys
  • Accommodations, meals and cultural events as part of FISC meet ethical standards for hosting foreign guests


Government employees and international organizations are governed by laws and regulations concerning acceptance of gifts including entertainment, meals, gifts, and gratuities. There are situations within the general course of events where it is ethically, legally and culturally acceptable to provide limited things of limited value to partners, customers or potential customers. The following considerations must be used:

Gifts must not exceed the monetary value acceptable by Government of Canada regulations or the country where the gift was provided

  • Gifts must not be lavish or excessive and must not create the appearance of an attempt to influence business decisions
  • Do not influence any decision of the government customer or partner
  • Must be consistent with the business practices and customs of the country
  • Must not be arbitrary provided to one person or representatives of one country


FreeBalance management will provide training on the Code of Conduct during employee orientation. Management will update employees on Code of Conduct changes during yearly business plan updates. The Code of Conduct, Vision and Mission will be reinforced during annual updates and through management communications through all media. Managers are expected to communicate the company Code of Conduct to employees whenever appropriate.

Reporting Violations

Violations of the Code of Conduct will be managed through Human Resources. All employees have a positive duty to report a violation of the Code of Conduct. Violations can be reported in confidence by calling 1-800-263-4031 and leaving their name and message, or an anonymous message, for the Chief Compliance Officer or by emailing Any allegation of misconduct will be handled in a confidential manner, where possible. Retaliation against any employee who reports a concern in good faith will not be tolerated.

Zero Tolerance

There is no tolerance for employees or business partners who receive, offer, promise, authorize, direct, or make any bribes, kickbacks, or payments of money or anything of value. Employee and partnership contracts will be immediately suspended or terminated without notice or pay in lieu of notice should there be evidence of unethical, illegal or improper behavior.

Periodic Procedures

The FreeBalance Code of Conduct will be updated to adjust for changes in governance, risk management and compliance procedures. All changes will be communicated to employees via e-mail, internal newsletter and the updated Code of Conduct will be posted to the FreeBalance web site and Employee Handbook.
Confirmation of the Code of Conduct regardless of whether any changes have been added will be communicated annually to employees via e-mail and internal newsletters.