Code of Ethics

1.Introduction and Scope of Policy

Our professional code of ethics policy aims to give our employees guidelines on our business ethics and stance on various controversial matters. We trust you to use your better judgment, but we want to provide you with a concrete guide you can fall back on if you’re unsure about how you should act (e.g. in cases of conflict of interest). We will also use this policy to outline the consequences of violating our business code of ethics. This policy applies to everyone we employ or have business relations with. This includes individual people such as employees, interns, volunteers, but also business entities, such as vendors, enterprise customers or venture capital companies. Note that our code of ethics refers to legally or morally charged issues and should be read in conjunction with our Employee Handbook.

2. Components of our code of professional ethics

We base our business code of ethics on common principles of ethics;

1. Respect for others . Treat people as you want to be treated.

2. Integrity and honesty . Tell the truth and avoid any wrongdoing to the best of your ability.

3. Justice . Make sure you’re objective and fair and don’t disadvantage others.

4. Lawfulness . Know and follow the law – always.

5. Competence and accountability . Work hard and be responsible for your work.

6. Teamwork . Collaborate and ask for help.

2.1 Respect for Others

It’s mandatory to respect everyone you interact with. Be kind, polite and understanding. You must respect others’ personal space, opinions and privacy. Any kind of violence, harassment or victimization is strictly prohibited and disciplinary is likely to be taken. If someone, be it customer, colleague or stakeholder, is offensive, demeaning or threatening toward you or someone you know, report them immediately to HR. You can also report rudeness and dismissiveness if they become excessive or frequent.

2.2 Integrity and Honesty

We all work together to achieve specific outcomes. Your behavior should contribute to our goals, whether financial or organizational. Be honest and transparent when you act in ways that impact other people (e.g. taking strategic decisions or deciding on layoffs). We don’t tolerate malicious, deceitful or petty conduct. Lies and cheating are huge red flags. Stealing from the company or individuals is illegal. If you are discovered, it is likely that you will face disciplinary action.

2.3 Conflict of Interest

The company has a detailed Conflicts of Interest Policy that should be adhered to at all times.

2.4 Justice

Don’t act in a way that exploits others, their hard work or their mistakes. Give everyone equal opportunity and speak up when someone else doesn’t. Be objective when making decisions that can impact other people. Be sure that you can justify any decision with written records or examples. Seek and use the most objective methods in any case; for example, when interviewing candidates, ask the same interview questions to all of them and avoid judging non-job-related criteria, like dress, appearance, etc. Do not discriminate against people with protected characteristics. If you suspect you may have an unconscious bias that influences your decisions ask for help from HR. When exercising authority, be fair. Don’t show favoritism toward specific employees and be transparent when you decide to praise or reward an employee.

2.5 Lawfulness

You are obliged to follow all laws which apply to our organization. Depending on your role and profession, there might be various laws you need to observe. When you’re preparing contracts, clauses, disclaimers or online copy that may be governed by law (such as consent forms), legal counsel should be consulted. Refer to confidentiality and data protection policy and guidance notes. If you’re not sure what the law is in a specific instance, don’t hesitate to ask HR or our legal counsel.

2.6 Competence and accountability

We all need to put a healthy amount of effort in our work. We are all responsible for the organization’s success. Incomplete or slow working might hinder other people’s work or cause them to shoulder the burden themselves. This comes in direct conflict with our respect and integrity principles. Opportunities for learning and development, either on-the-job or via educational material or training should be taken. If you are unsure how you can achieve this, have an open discussion with your manager.

2.7 Teamwork

Working well with others is a virtue, rather than an obligation. You will certainly get to work autonomously and be focused on your own projects and responsibilities. But, you should also be ready to collaborate with and help others. Be generous with your expertise and knowledge. Be open to learning and evolving. If days go by without you consulting or brainstorming with anyone, you are missing out on opportunities for excellence. Instead, work with others and don’t hesitate to ask for help when you need it.