Code of Conduct

The Golden Rules

Be welcoming. We strive to be a company that welcomes and supports people of all backgrounds and identities. This includes, but is not limited to members of any race, ethnicity, culture, national origin, color, immigration status, social and economic class, educational level, sexual orientation, gender identity and expression, age, size, family status, political belief, religion, and mental and physical ability.

Be respectful. Not all of us will agree all the time, but we must always remember that disagreement is no excuse for poor behavior and poor manners. Although we may experience frustration from time to time, we are all responsible for ensuring that we deal with the frustration appropriately. Respect is absolutely fundamental to creating and maintaining a culture that is comfortable, pleasant and productive for all. Remember - disagreeing with one another is not a bad thing - in fact, it can often contribute to great ideas if we approach with a respectful and constructive mindset.

Be considerate. Your work will always affect others, as the work of your colleagues will affect you. It is important to consider the impact that your decisions will have. Keep your colleagues and the product in mind, and make sure that everyone is on the same page.

Acceptable and Expected Behavior

It is important to create a safe and welcoming environment for everyone. By adhering to these guidelines, we can ensure that all members of our community feel respected and valued.

The following behaviors are expected and requested of all persons:

• Participate in your role, team and wider company in an authentic and active way.

• Exercise consideration and respect in your speech and actions at all times.

• Attempt collaboration before conflict.

• Communicating in a positive, constructive and respectful way.

• Remember that TheyDo events may be shared with members of the public and customers; please be respectful to all patrons of these locations at all times

• Be considerate of your colleagues. Alert the People Team if you notice a dangerous situation, someone in distress, or violations of this Code of Conduct.

• Be respectful of external parties, including, but not limited to: customers, consultants, third-party providers, participants of events, patrons of locations (e.g. co-working spaces, hotels, workshops).

• Comply with the local and national laws of your working environment - whether at your remote work address, co-working spaces, onsites, or other business-related trips.

Responsibility

• It is the responsibility of the individual to ensure that they adhere to all facets of the Code of Conduct.

Intellectual Property Rights

• Respect for intellectual property rights is crucial in our business operations. Employees must not use or distribute copyrighted materials without proper authorization and they should report any potential infringements promptly.

Conflict of Interest

• Individuals are expected to steer clear of any personal, financial or other interest that could impede their ability or willingness to fulfill their job responsibilities. Should you encounter a situation where your interests conflict with TheyDo BV’s objectives, we promote open dialogue and encourage your collaboration to address any conflicts and uphold a positive work environment. If you are experiencing an ethical dilemma please reach out to the Head of People (or Senior People Operations Specialist, in their absence).

Anti-corruption and Bribery

• We are committed to maintaining a fair and transparent work environment. Any instances of corruption such as bribery or unethical behavior are prohibited.

  • ‘Bribe’ is anything of value that’s given or offered (directly or indirectly) in an attempt to secure a business advantage.

• We allow the exchange of gifts among private entities, but this policy does not extend to interactions involving governmental institutions or any other entities within the public sector.

Market Abuse

At TheyDo, we are committed to maintaining the integrity and fairness of financial markets. Market abuse, which encompasses activities such as insider trading, market manipulation, and unlawful disclosure of material non-public information, is strictly prohibited. This policy serves to ensure compliance with all applicable laws and regulations governing securities and financial markets, and to uphold the highest standards of ethical conduct in our business activities.

Prohibited Activities

1. Insider Trading: Individuals are prohibited from trading securities based on material non-public information obtained in the course of their employment or association with the company. This includes trading stocks, bonds, options, or any other financial instruments using information that has not been disclosed to the public and could reasonably be expected to impact the market price of those securities.

2. Market Manipulation: Engaging in any activity with the intent to artificially influence the price or volume of securities, or to create a false or misleading impression of market conditions, is strictly prohibited. This includes practices such as spoofing, layering, churning, and painting the tape, among others.

3. Unlawful Disclosure: Individuals must not disclose material non-public information about the company or any other entity to third parties, including family members, friends, or acquaintances, for the purpose of trading securities or gaining an unfair advantage in the market. Unauthorized disclosure of confidential or proprietary information may also violate contractual obligations and intellectual property rights.

Submitting a Formal Grievance

If any person wishes to submit a formal grievance regarding a perceived violation of the Code of Conduct, complete the following steps:

1. Submit your grievance in writing to the Head of People (or Senior People Operations Specialist, in their absence). The written grievance should include the following details:

• The date and time of the incident(s)

• The location(s) of the incident(s)

• The name(s) of the person(s) involved in the incident(s)

• A detailed description of the incident(s), including any supporting documentation or evidence

• Any witnesses to the incident(s)

1. The People Team will acknowledge receipt of your grievance within two business days.

2. The People Team will conduct an objective investigation into the claims of your grievance in a fair and impartial manner.

3. The People Team will provide you with a written response to your grievance within ten business days of receipt of your grievance.

All formal grievances will be handled with sincerity, respect, empathy, and confidentiality. No detrimental action will be taken against anyone who submits a formal grievance in good faith.

Unacceptable Behavior

The following behaviors are prohibited for all persons. Engaging in said behaviors would be considered a breach of conduct:

• Any offensive or inappropriate language related to race, ethnicity or national origin, sex or identity and expression, sexual orientation, disability, physical appearance, mental illness or neurotypicality, speech impediment, body size, caste, age, politics or religion.

• Language or imagery that encourages, glorifies, incites, or calls for emotional, or physical harm against an individual or a group of people.

• Any form of violence, physical or verbal, including threats, violent language or coercion.

• Any form of unwelcome sexual attention, language or imagery, including comments or jokes, inappropriate touching or groping, sexual advances, coercion, posting or displaying sexually explicit or violent material.

• Engaging in any form of inappropriate physical contact without consent, especially that of a sexual or violent nature.

• Reporting for work in an unsafe condition, including being under the influence of alcohol or drugs.

• Repeated harassment of others, especially that of a sexual or violent nature.

• Deliberate, continual disruption of work or speaking, including tasks, projects and presentations.

• Deliberately intimidating, stalking or following someone (whether online or in person).

• Taking inappropriate photographs or recording others without their consent.

• Posting or threatening to post other people's personally identifying information ("doxing").

• Possession of any weapons at any events, office locations, co-working spaces, or in other spaces utilized for company activities. Weapons are defined as any item carried or used for the purpose of causing injury, harm or fear to others.

• Intimidation or retaliation against any person making a complaint of unacceptable behavior, or against any person participating in the investigation of any such allegation.

• Any form of bullying, whether direct, indirect, blatant or subtle. Bullying can include any of the above behaviors, as well as aggression, intentional isolation, spreading rumors or slander or any other form of social aggression, and can be conducted in-person or virtually.

• Advocating for or encouraging any of the above behaviors.

• Any other conduct that could reasonably be considered inappropriate in a professional setting.

Confidentiality, Data Protection and Privacy

TheyDo BV classifies data and information systems in accordance with legal requirements, sensitivity, and business criticality in order to ensure that information is given the appropriate level of protection. Data owners are responsible for identifying any additional requirements for specific data or exceptions to standard handling requirements.

Information systems and applications shall be classified according to the highest classification of data that they store or process.

Please find and read through the full policy.

Competing Lawfully

• We recognize the importance of fair competition in the marketplace. This means that we compete on the basis of our product’s merits and the value we provide to our customers, rather than resorting to unethical or illegal practices to gain an advantage.

• When we talk about competing lawfully, we’re referring to adhering to all relevant laws, regulations and industry standards in our marketing, sales and business operations. This includes but is not limited to laws related to competition, data protection, intellectual property and consumer rights.

• We emphasize the importance of conducting ourselves with integrity in all competitive situations. We believe in conducting business through transparency, honesty and delivering exceptional value to our customers.

ESG Carbon Tracking

• Legal Compliance: We will comply with all applicable laws, regulations, and reporting requirements related to carbon emissions tracking, offsetting, and sustainability practices in the jurisdictions where we operate.

• Reducing Carbon Emissions: Our remote work model eliminates commuting and minimizes business travel, significantly reducing carbon emissions.

• Waste Reduction: Digital workflows and remote collaboration tools remove paper and material waste.

• Bi-annual Company Retreats: For our bi-annual company retreats, we will calculate the carbon emissions generated from travel, accommodation, meals, and other associated activities. Data will be collected using recognized methodologies and reported transparently to stakeholders.

• Offsetting Calculation: Carbon emissions data will be used to calculate the equivalent amount of carbon dioxide (CO2) emissions. We will utilize reputable carbon offsetting programs or projects to offset these emissions, ensuring that our activities contribute to verified emissions reductions and sustainable development initiatives.

Reporting Violations

• If you are subject to or witness any unacceptable behavior, or have any other concerns, please notify either the People Team, relevant manager(s) or leadership at the earliest opportunity. All reports will be handled with sincerity, respect, empathy and confidentiality.

Disciplinary Action

Employees who violate policy may face disciplinary consequences in proportion to their violation. TheyDo B.V. and any designated representatives may take any of the following actions, including, but not limited to:

• Submission of a formal grievance and subsequent investigation.

• A verbal warning to cease their behavior and that any further reports will result in further actions.

• A written warning to cease their behavior and that any further reports will result in further actions.

• A written reprimand.

• Disciplinary action.

• Suspension.

• Termination.

• Reporting incidents to the relevant authorities.