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The Improvado Code of Conduct (“Code”) is built around our belief that everything we do will be measured against the highest possible standards of ethical business conduct. Our commitment to high standards helps us hire great people, build great products, and attract loyal customers.
As an employee, you are responsible to behave appropriately at work. We’ve outlined our expectations here. We can’t cover every single case of conduct, but we trust you to always use your best judgement. Reach out to your manager or HR if you face any issues or have any questions. We expect all employees to know and follow the Code. Failure to do so can result in disciplinary action, up to and including termination. We also expect our contractors, consultants, and others who may be temporarily assigned to perform work or services for Improvado to follow the Code when they work with us. Failure of a Improvado contractor, consultant, or other service provider, to follow the Code can result in termination of their relationship with Improvado.
If you have a question or concern about the Code, be proactive and contact your manager. Y ou can also submit a question or raise a concern regarding a suspected violation of our Code (or any other Improvado policy) to your manager.
Improvado prohibits retaliation against anyone who reports, or participates in an investigation of, a possible violation of our Code, our policies, or the law. Please contact a member of senior management if you believe that you are the subject of retaliation within Improvado.
As a Improvado employee, you’re expected to be honest, act ethically , and demonstrate integrity in all situations. You have a duty to follow policies and procedures found in this Code of Conduct, as well as those that are specific to your job. You must also comply with all laws that apply to our business. Most of the time, common sense and good judgment provide excellent guideposts. If you’re unsure about the right thing to do, ask someone on the management team.
Before you act, ask yourself:
If your answer to any of these questions raises doubts, talk with your supervisor, anyone in management, or the Improvado Compliance Officer. If you’re a supervisor or a manager, you’re responsible for knowing the rules and reviewing the Code of Conduct with the people who report to you to make sure they’re familiar with its contents. You’re also responsible for preventing violations of the Code, as well as detecting violations that may occur and reporting them appropriately .
You’re expected to:
We are committed to a supportive work environment, where our employees have the opportunity to reach their fullest potential. Members of our Improvado team are expected to do their utmost to create a workplace culture that is free of harassment, intimidation, bias, and unlawful discrimination. Please read the Employee Handbook for greater detail about how we should conduct ourselves at work.
Employment at Improvado is based solely upon individual merit and qualifications directly related to professional competence. We strictly prohibit unlawful discrimination or harassment on the basis of race, color, religion, veteran status, national origin, ancestry , pregnancy status, sex, gender identity or expression, age, marital status, mental or physical disability , medical condition, sexual orientation, or any other characteristics protected by law. We also make reasonable accommodations to meet our obligations under laws protecting the rights of the disabled.
Improvado strictly prohibits discrimination, harassment, and bullying in any form – verbal, physical, or visual. If you believe that you’ve been bullied or harassed by anyone at Improvado, or anyone connected to Improvado (such as a partner or vendor), please immediately report the incident to your manager or the HR team. HR will promptly and thoroughly investigate any complaints and take appropriate action.
Substance abuse is incompatible with the health and safety of our employees, and we don’t permit it. Consumption of alcohol is allowed at our office on special occasions, but we ask everyone to use good judgment and never drink in a way that: (i) leads to impaired performance or inappropriate behavior, (ii) endangers the safety of others, or (iii) violates the law. Illegal drugs in our offices or at work-related events are strictly prohibited.
We are committed to a violence-free work environment. We will not tolerate any level of violence or the threat of violence in the workplace. No one should bring a weapon to work under any circumstances. If you become aware of a violation of this policy, report it to a member of senior management immediately .
When you are experiencing a conflict of interest, your personal goals are no longer aligned with your responsibilities towards us. For example, owning stocks of one of our competitors is a conflict of interest. In other cases, you may be faced with an ethical issue. For example, accepting a bribe may benefit you financially , but it is illegal and against our business code of ethics. If we become aware of such behaviour, you will lose your job and may face legal trouble. For this reason, conflicts of interest is a serious issue for all of us. We expect you to be vigilant to spot circumstances that create conflicts of interest, either to yourself or for your direct reports. Follow our policies and always act in our company’s best interests. Whenever possible, do not let personal or financial interests get in the way of your job. If you are experiencing an ethical dilemma, talk to your manager or HR and we will try to help you resolve it. As Improvado employees, we should avoid conflicts of interest and circumstances that reasonably present the appearance of a conflict of interest, especially if it would create an incentive for you or present the appearance of an incentive for you, (whether directly or indirectly).
Here is list of areas where conflicts of interest often arise:
If you are unsure if there is a conflict of interest, contact the Compliance or Legal teams to discuss.
Our company’s official dress code is Casual. However, an employee’s position may also inform how they should dress. If you frequently meet with clients or prospects, please conform to a more formal dress code. As long as you conform with our guidelines above, we don’t have specific expectations about what types of clothes or
accessories you should wear. We also respect and permit grooming styles, clothing and accessories that are dictated by religious beliefs, ethnicity or disability .
Throughout its lifecycle, all nonpublic information that is processed, transmitted, and/ or stored by Improvado must be protected in a manner that is consistent with our contractual and legal requirements and reasonable and appropriate for the level of sensitivity, value, and risk associated with Nonpublic information (please see the Data Classification Policy). Information that contains data elements from multiple classifications must be protected at the highest level of information represented. For example, a document that contains Nonpublic and Public information must be treated as Nonpublic information. Nonpublic information must be secured against disclosure, modification, and access by unauthorized individuals. Therefore, the information must be:
You’re responsible for using Improvado’s computer resources properly – especially with regard to information security – and you need to be thoroughly familiar with Improvado’s Information Security policies and procedures. These steps can go a long way in preventing unauthorized access:
Human error is the leading cause of cyber breaches. Each employee should finish the mandatory learning program to protect the data, systems and communications of organizations from being exposed due to human error - but also to safeguard their reputation and trust among customers, clients, and partners.
These solutions are all brought together by Risk Score, which provides an overall evaluation of the organization's current and past human cyber risk.
Our corporate internet connection is primarily for business. But, you can occasionally use our connection for personal purposes as long as they don’t interfere with your job responsibilities. Also, we expect you to temporarily halt personal activities that slow down our internet connection (e.g. uploading photos, streaming videos) if you’re asked to.
You must not use our internet connection to:
We allow use of cell phones at work. But, we also want to ensure that your devices won’t distract you from your work or disrupt our workplace. We ask you to follow a few simple rules:
Email is essential to our work. You should use your company email primarily for work, but we allow some uses of your company email for personal reasons.
No matter how you use your corporate email, we expect you to avoid:
In general, use strong passwords and be vigilant in catching emails that carry malware or phishing attempts. If you are not sure that an email you received is safe, ask our Security Specialists.
You are permitted to access your personal accounts at work. But, we expect you to act responsibly , according to our policies and ensure that you stay productive. Specifically , we ask you to:
If you handle our social media accounts or speak on our company’s behalf, we expect you to protect our company’s image and reputation. Specifically, you should:
The goal of this policy is to make sure that everyone is taking part in creating a respectful and safe working environment, which won’t harm or offend anyone.
We, Improvado, are an international and therefore multicultural team. We are growing, our ranks are constantly replenished with employees all over the world. We all have different views on many things: politics, culture, religion, relationships, we have different mentalities, and we belong to different cultures.
Some things can feel or look very different to us, but still, we have to interact in the same environment where everyone should feel comfortable and safe.
Communication is an integral and very important part of our work, that’s why we decided to remind you about some general rules:
WE ARE DIFFERENT, BUT STILL, WE ARE ONE.
Please, remember about our differences and respect this fact.
Male and female, people of different ages, gender identities, and sexual orientations, people of different races and nationalities — we are all Improvado.
We are an Equal Opportunity Employer and do not discriminate against any employee or applicant for employment because of race, color, sex, age, national origin, religion, sexual orientation, gender identity and/or expression, status as a veteran, and basis of disability or any other federal, state or local protected class.
BE FRIENDLY, WELCOMING, AND RESPECTFUL TO ALL TEAMMA TES, REGARDLESS OF THEIR BACKGROUND.
We are one team.
We’re all on the same ship.
We work together.
We make money together.
We must fight with entropy together.
WE UNDERSTAND THAT IMPROVADO IS AN INTERNATIONAL COMPANY AND INCLUDES PEOPLE OF DIFFERENT CULTURES.
Some things ordinary for Russia may be unacceptable in the US, and vice versa.
That’s why it’s even more important to take care of your colleague’s feelings even more while communicating between different offices or in General chat.
DO NOT USE SWEAR WORDS IN BUSINESS COMMUNICATIONS.
Please avoid it in Quip, documents, and chats which include people of other cultures, and especially with contractors, partners, and customers.
RESPECT YOUR COLLEAGUE’S PERSONAL BOUNDARIES.
Do not violate their personal space and — especially — bodily boundaries.
IT’S UNACCEPTABLE TO MAKE THINGS PERSONAL AND ATTACK OR JOKE INSULTINGLY ABOUT ANY PERSONAL CHARACTERISTICS OF OTHER EMPLOYEES.
This includes topics like race, color, religion, sex, pregnancy , sexual orientation, gender identity, age, national origin or ancestry , physical or mental disability , genetic information (including testing and characteristics), etc.
IT’S UNACCEPTABLE TO SEXUALLY HARASS OTHER EMPLOYEES.
This includes unwanted sexual advances, requests for sexual favors or visual, verbal or physical conduct of a sexual nature.
Sexual jokes can also be considered inappropriate as they may cross an individual’s personal boundaries and make them uncomfortable without being a sexual advance directly towards an individual.
Be respectful, mindful and professional. In most professional settings, sexual jokes are not appropriate.
DO NOT SUPPORT OTHER’S INEXCUSABLE BEHAVIOR, NEITHER BY ENCOURAGING IT NOR BY STAYING SILENT.
Speak up.
If someone does something to make you uncomfortable, verbally or physically, let them know right away but also know that you always have the option to report such behaviors to your supervisor, HR, regional director, officers or even owners.
We will investigate all reported cases from both sides and take appropriate disciplinary action. If you see something inappropriate happening, don't hesitate to correct each other.
We are with you.
We hope such things will never be needed, but in case a violation occurs, you must know: you are not alone, we will support you and protect you.
We want to ensure that relationships between employees are appropriate and harmonious. We outline our guidelines and we
ask you to always behave professionally .
Fraternization refers to dating or being friends with your colleagues. In this policy, “dating” equals consensual romantic relationships and sexual relations. Non-consensual relationships constitute sexual harassment and we prohibit them explicitly .
If you start dating a colleague, we expect you to maintain professionalism and keep personal discussions outside of our workplace. You are also obliged to respect your colleagues who date each other.
We won’t tolerate sexual jokes, malicious gossip and improper comments. If you witness this kind of behavior, please report it to HR.
To avoid accusations of favoritism, abuse of authority and sexual harassment, supervisors must not date their direct reports. This restriction extends to every manager above an employee.
Also, if you act as a hiring manager, you aren’t allowed to hire your partner to your team. You can refer them for employment to other teams or departments where you don’t have any managerial or hiring authority .
Employees who work together may naturally form friendships either in or outside of the workplace. We encourage this relationship between peers, as it can help you communicate and collaborate. But, we expect you to focus on your work and keep personal disputes outside of our workplace.
If you want to invite a visitor to our offices, please ask for permission from our HR Manager/Office Manager first. Also, inform our reception of your visitor’s arrival. Visitors should sign in and show identification. They will receive passes and will be asked to return them to reception once their visit is complete.
When you have office visitors, you also have responsibilities. You should:
Anyone who delivers orders, mail or packages for employees should remain at our building’s reception or gate. If you are expecting a delivery , front office employees will notify you so you may collect it.
Solicitation is any form of requesting money , support or participation for products, groups, organizations or causes which are unrelated to our company (e.g. religious proselytism, asking for petition signatures.) Distribution means disseminating literature or material for commercial or political purposes.
We don’t allow solicitation and distribution by non-employees in our workplace. As an employee, you may solicit from your colleagues only when you want to:
In all cases, we ask that you do not disturb or distract colleagues from their work.
Improvado’s intellectual property rights (e.g. patents, trademarks, copyrights, trade secrets, and “know-how”) are valuable assets. Unauthorized use can lead to their loss or serious loss of value. You must comply with all intellectual property laws,including laws governing the fair use of copyrights and trademarks. You must never use Improvado’s trademarks or other protected information or property for any business or commercial venture without pre-clearance from the Marketing team. Report any suspected misuse of trademarks or other Improvado intellectual property to the Legal or compliance team. Likewise, respect the intellectual property rights of others. Inappropriate use of others’ intellectual property may expose
Improvado and you to criminal and civil fines and penalties. Seek advice from the Legal team before you solicit, accept, or use proprietary information from individuals outside the company or allow them to obtain access to Improvado proprietary information. You should also check with the Legal team if developing a product feature that uses content not belonging to
Improvado.
Improvado gives us the tools and equipment that we need to do our jobs effectively , but counts on us to be responsible and not wasteful. Uncertain whether personal use of company assets is okay? Ask your manager.
Improvado’s network, software, and computing hardware are critical aspects of our company’s physical property and intellectual property . Follow all security policies diligently . If you have any reason to believe that our network security has been violated – for example, you lose your laptop or think that your network password may have been compromised – promptly report the incident to your manager.
Bad actors may steal company assets. Always secure your laptop, important equipment, and your personal belongings, even while on company premises. Promptly report any suspicious activity to your manager.
Ensure financial integrity and responsibility
Financial integrity and fiscal responsibility are core aspects of corporate professionalism. Each
person at Improvado has a role in making sure that money is appropriately spent, our financial records are complete and accurate, and internal controls are honored. This is applicable every time that we hire a new vendor, expense something to Improvado, or sign a new business contract. It’s important that we also keep records for an appropriate length of time. Improvado’s Data Retention Policy suggests minimum record retention periods for certain types of records. These guidelines help keep in mind applicable legal requirements, accounting rules, and other external requirements. Contractual obligations may sometimes specify longer retention periods for certain types of records. In addition, if you are asked by the Legal team to retain records relevant to a litigation, audit, or investigation, do so until Legal tells you that retention is no longer necessary . If you have any questions regarding the correct length of time to retain a record, contact the Compliance or Legal teams.
Obey the law
Improvado takes its responsibilities to comply with laws very seriously . Every employee is expected to comply with applicable legal requirements and restrictions. You should understand the laws and regulations that apply to your work. Contact the Compliance or Legal teams if you have any questions.
Any Improvado personnel found in violation of this policy may be subject to disciplinary action, up to and including termination of employment. Any third-party partner company found in violation may have their network connection terminated.
The Compliance team will verify compliance with this Code through various methods (e.g. periodic manager reviews, tool reports, internal and external audits, and employee feedback).
Any exception to this Code must be approved by the Compliance team in writing.
Any employee who violates this Code may be subject to disciplinary action, up to and including termination of employment in addition to any civil and criminal liability .
Once each year, as a condition of your employment, you’re required to acknowledge that you have received the Code of Conduct and understand its rules. New employees will sign an acknowledgement when they start with the company . Basically, your annual acknowledgment confirms that:
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