Code of Conduct and Ethics

1. Purpose and scope

This Code sets out the professional, legal, and ethical standards that govern every Maven International assignment, and everyone who works on one.

It exists for two reasons. Institutional buyers, procurement teams, and donors need to see, in specific terms, what we hold ourselves to before they place sensitive work with us. And everyone delivering that work needs to know what is expected of them before they accept an assignment, not after something has gone wrong.

Who this applies to

This Code binds:

• Officers, directors, managers, and internal staff at every level
• Project managers and coordinators
• Third party vendors including but not limited to interpreters, translators, revisers, proofreaders, linguists and terminology specialists
• Temporary staff, consultants, and sub-contractors
• Partner agencies and technology vendors engaged on our assignments

We apply one standard across all of these groups. A freelance interpreter working a single asylum interview is bound by the same confidentiality and conduct requirements as a member of our permanent staff. Where local law, a client's own supplier code, or a professional body's rules set a higher bar than this Code, the higher bar applies.

Non-compliance is treated as misconduct and can result in termination of employment or contract, removal from our vendor database, and, where warranted, referral to the relevant authorities.

2. Conflicts of interest

Business decisions are made on objective assessment of merit, capability, and cost — never on personal relationships or private gain.

A conflict of interest arises where a personal interest, whether through family, friends, clients, competitors, or suppliers, interferes with the interests of Maven International or a client, or could reasonably be perceived to.

What we require

• Disclosure before acceptance. Interpreters and translators disclose any prior, current, or personal connection to a party, a case, or the subject matter before accepting an assignment — not after beginning work.
• Disclosure when uncertain. Anyone unsure whether a conflict exists raises it with their project manager before proceeding. Raising a possible conflict is never held against the person who raised it.
• Resolution on the record. Disclosed conflicts are resolved by reassignment, by screening the individual from the work, or by declining the assignment. The resolution is recorded on the project file.

A conflict that is not disclosed is itself a breach of this Code, independent of whether it affected the work.

3. Confidentiality

Everyone working on a Maven International assignment signs an NDA before any material is shared with them.

What is covered

• Source content and target output of all language projects
• Client identity, where anonymity is requested or contractually required
• Specialised terminology, proprietary glossaries, and reference material
• Project metadata, delivery schedules, and the identity of parties involved
• Anything learned during a live interpretation assignment, including the content of closed meetings, off-the-record exchanges, and participant identities

How access is controlled

• Need-to-know only. Project material is shared with the staff, linguists, and revisers directly required to execute the assignment. Project managers control who is assigned and what they can see.
• Project segregation. Client assets are segregated by project. Work is performed inside a controlled CAT and project-management environment with role-based, project-scoped access. See our Data Protection and Confidentiality Standards policies for the technical and organisational detail behind this control.
• No bulk extraction. Our CAT (Computer-Assisted Translation) tools are web-based, and downloading of source documents or complete translated documents is disabled for everyone by default. External vendors — interpreters, translators, revisers, proofreaders — can view project content only in the browser and cannot export a single source or fully translated document, in whole or in part. Bulk or mass export is restricted to a very limited number of full-time employees or senior managers with the highest level of platform access. The only exception is single-file downloads for desktop publishing (DTP) work, carried out internally or by approved external DTP managers, where the file format requires it.
• Revocation on completion. Access rights are withdrawn when the assignment closes or the engagement ends.

Duration

Confidentiality obligations survive indefinitely, or for the period specified in any separate NDA, whichever is longer. They do not lapse when a project closes, when a freelancer stops working with us, or for any other reason short of the obligation itself expiring under its own terms.

Required disclosure

Where disclosure is compelled by law, court order, or a regulatory authority, we disclose only what is required and, where legally permitted, notify the client first.

4. Data protection and information security

Suppliers and staff handle personal data and sensitive client content in compliance with applicable data protection law and with our published Privacy Notice, Data Protection, and Confidentiality Standards policies — see those pages for the full detail on lawful basis, retention, and technical safeguards; it is not repeated here.

• Work conducted within our secure CAT environment remains within that platform
• Client-owned language assets — translation memories, glossaries, and term bases — remain the client's property. We maintain them for reuse and return or delete them on request
• Personal data encountered in project material is processed only for the purpose of the assignment, never retained beyond it, and never used for any other purpose

Certification

Our CAT (Computer-Assisted Translation) tools and interpretation delivery platforms are provided by third-party vendors, not built in-house. XTRF, the platform attached to our translation project management workflows, holds ISO/IEC 27001 and ISO 9001 certification in its own name. Smartcat, used within our translation and localisation workflows, holds SOC 2 Type II certification in its own name. These certifications belong to the platform vendors, not to Maven International, and cover each platform's own information security management, not our organisation as a whole.

5. Anti-bribery and anti-corruption

We do not tolerate corruption in any form.

It is prohibited to offer, promise, give, request, solicit, or accept any unfair advantage — cash or cash equivalent, gifts, credit, discounts, accommodation, services, or personal favours — in order to obtain, retain, or accelerate business.

• Facilitation payments are prohibited without exception, including where they are locally customary or expected. This applies to payments to government officials and to private parties alike.
• Corruption includes misuse of position and creating the impression of improper influence over a decision-maker, whether or not influence was actually exercised.
• Offering or accepting a bribe, or knowingly allowing someone else to, is gross misconduct.

Gifts and hospitality

Permitted only where occasional, modest, and customary for the market — and never where they could reasonably be read as an inducement. Nothing is offered or accepted around a live tender or an open procurement decision. Where there is doubt, the answer is to decline and report it.

6. Fair dealing and accurate representation

• We compete on quality, capability, and price. We do not coordinate pricing or bidding with competitors, offer or solicit improper payments, or take part in unlawful boycotts.
• We describe our services accurately. Capability, turnaround, quality level, and the use of machine translation or AI are represented as they actually are, in proposals and in marketing.
• We name the correct contracting party. Where a project is delivered for an end user through an intermediary, we describe the relationship accurately rather than claiming the end user as our client.
• We comply with applicable trade controls, restrictions, sanctions, and export embargoes, and we decline engagements that conflict with them.
• We pay our suppliers and linguists in full and on schedule. Withholding payment as leverage is prohibited.

7. Professional conduct and delivery standards

Competence

Suppliers must hold the qualifications, language pairs, and subject-matter expertise they declared during onboarding. Accepting an assignment outside your demonstrated competence is a breach of this Code.

Delivery

Assignments are executed to the agreed scope, format, quality level, and deadline. Where something goes wrong — a missed deadline, an error discovered after delivery, an inability to complete — we say so promptly rather than conceal it. Late disclosure of a problem is treated more seriously than the problem itself.

No unauthorised sub-contracting

Sub-contracting or outsourcing any part of an assignment to a third party is prohibited without prior written approval. This protects the confidentiality chain and ensures the buyer knows who is handling their material.

Record accuracy

Records, quotes, invoices, word counts, and project documentation must be accurate and complete. Falsifying any of these, or misrepresenting who performed the work, is fraud and is treated as such.

Professional codes

Linguists follow the professional codes of the bodies they belong to — AIIC, ITI, ATA, and equivalents — alongside this Code: accuracy and impartiality, no addition, omission, or alteration of meaning, and no personal use of information obtained during an assignment.

Company assets

Company systems, accounts, and assets are for legitimate business use and are protected accordingly.

8. Treatment of people

Equal opportunity

We provide equal opportunity in employment and engagement, without discrimination on any basis, including but not limited to gender, nationality, ethnic origin, religion.

Harassment

Harassment, bullying, slander, and victimisation are prohibited in every form of verbal, written, and electronic communication. This applies between staff, between staff and freelancers, and in dealings with client personnel.

Labour standards

We oppose child labour, forced or compulsory labour, undeclared employment arrangements, and the withholding of wages, and we require our suppliers to do the same across their own supply chains. See our Modern Slavery Statement for how this is assessed and enforced.

Fair terms for linguists

Freelance linguists are contracted on clear written terms stating scope, deadline, rate, and payment schedule before work begins, and are paid at the agreed rate on the agreed schedule.

Working conditions for interpreters

Interpreters working in humanitarian, legal, and other high-pressure settings are briefed on context before the assignment. Their working conditions — team size, turn length, breaks, and security arrangements — are treated as a condition of the assignment rather than a courtesy, because interpretation quality degrades measurably without them and because the settings we work in carry real personal risk.

9. Raising a concern

Anyone — staff, linguist, supplier, or client — can raise a concern about a breach of this Code, with their project manager, directly with the Director, or by email to admin@maven-international.com.

Concerns are handled confidentially and shared only with the people who need to act on them. We acknowledge every report within 10 working days.

We do not tolerate retaliation of any kind against anyone who raises a concern in good faith. Retaliation is itself a breach of this Code and is treated as misconduct independent of the original report.

Confirmed breaches result in corrective action up to and including termination of employment or contract, removal from our vendor database, and, where warranted, referral to the relevant authorities.

10. Governance and review

• Policy owner: Director, on a company group level.
• Operational oversight: Project Management.
• Review cycle: every year, or sooner on a material change to our operating model, to client compliance requirements, or to applicable law.
• Related documents: Privacy Notice, Data Protection, Confidentiality Standards, Modern Slavery Statement, CSR / ESG Statement, Environmental Policy.

11. Information for institutional buyers

For procurement teams and institutional buyers — including UN agencies, IGOs, government bodies, and NGOs — we can provide:

• A signed copy of this Code
• Supplier onboarding and due-diligence records
• Project-specific confidentiality undertakings
• Information security documentation
• Completed vendor questionnaires and self-assessment forms
• Evidence of our supplier vetting checks

Last updated: 1 December 2024