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Code of Conduct

 

The pepelwerk Code of Conduct is one of the ways that we put pepelwerk's values and hopeful ideals about humanity and business into practice. We believe that everything we do in connection with our work at pepelwerk should be on the up-and-up when it comes to our ethics and how we conduct business. Yes, we are over achievers and set high standards, but we think the results are well worth it- for the people who work for, with and benefit from the things we get to do through pepelwerk.

 

After reading our Code you might just be so inspired by our emphatic accountability to create the world we want to live in, that you realize your own individual awesomeness and turn away from the dark side. We all have a responsibility for creating the world we want to live in. If you have a question or ever think that the company is slacking on its commitments- speak up. We can't fix what you don't know about it,

 

Who Must Follow Our Code?

We expect all our hires, investors, members, users, service and business partners to know and follow the Code. Failure to do so can result in termination of working relationship.

 

What If I Have a Code-Related Question or Concern?

If you have a question or concern, don't just keep it to yourself. Don't wait until a curiosity, suspicion or guess turns into a problem. Inform us at info@pepelwerk.com. If you believe a violation of law has occurred, contact your local law enforcement.

 

No Retaliation

Pepelwerk prohibits retaliation internally against any person who reasonably, proactively and with good intentions reports or participates in an investigation of a possible violation of our Code, policies, or the law. If you believe you are being retaliated against, please contact info@pepelwerk.com.

 

I. Serve Our Users

Our users value pepelwerk not only because we deliver great products and services, but because we hold ourselves to a higher standard in how we treat users and operate more generally. Keeping the following principles in mind will help us to maintain that high standard:

 

Integrity

Our reputation as a company that our users can trust is our most asset, and it is up to all of us to make sure that we continually earn that trust. All our communications and other interactions with our users should increase their trust in us.

 

Usefulness

Our products, features, and services should make pepelwerk more useful for all our users. We have many different types of users, from individuals to large businesses, but one guiding principle: "Is what we are doing improving work lives?

 

Privacy, Security, and Freedom of Expression

Always remember that we are asking users to trust us with their personal information. Preserving that trust requires that each of us respect and protect the privacy and security of that information. Our security procedures strictly limit access to and use of users personal information and require that each of us take measures to protect user data from unauthorized access. Know your responsibilities under these procedures, and collect, use, and access user personal information only as authorized by our Privacy Policies, and applicable data protection laws.

 

Pepelwerk is committed to advancing privacy and freedom of expression for our users around the world. Where user privacy and freedom of expression face government challenges, we seek to implement internationally recognized standards that respect those rights as we develop products, do business in diverse markets, and respond to government requests to access user information or remove user content. Contact info@pepelwerk.com if you have questions on implementing these standards in connection with what you do at pepelwerk.

 

Responsiveness

Part of being useful and honest is being responsive: We recognize relevant user feedback when we see it, and we do something about it. We take pride in responding to communications from our users, whether questions, problems, or compliments. If something is broken, fix it.

 

Act

Any time you feel our users aren't being well-served, speak up- let someone in the company know about it. Delivering on a better user experience and staying relevant for our users is everyone's responsibility.

 

II. Be Authentic and Respectful to Each Other

We are committed to creating an authentic and respectful working world. Where we all have an opportunity to reach our fullest potential for good. While we want you to be you, and all the wonderful and complicated things that come with you, we recognize that we are not much by ourselves but as a collection of people we have the potential to accomplish great things. To accomplish those great things through pepelwerk we won't tolerate fakers, jerk-wads or being hateful just to be hateful.

 

Equal Opportunity Employment

Working here is based solely upon individual merit and qualifications directly related to professional competence. We strictly prohibit unlawful discrimination or harassment based on 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 all reasonable accommodations to meet our obligations under laws protecting the rights of the disabled.

 

Harassment, Discrimination, and Bullying

pepelwerk prohibits discrimination, harassment and bullying in any form – verbal, physical, or visual. If you believe you or someone else been bullied or harassed by anyone at pepelwerk, or by a pepelwerk partner or vendor, we strongly encourage you to immediately report the incident to info@pepelwerk.com.

 

Drugs and Alcohol

Pepelwerk takes the position that the use of any substance that causes your behavior to inflict harm to others, yourself or pepelwerk is prohibited while conducting business with, for or on behalf of pepelwerk. If there is a reasonable suspicion of such behavior, pepelwerk has the right to terminate any working or business relationship immediately at our own discretion. If you see someone who is impaired or has the potential to cause themselves or others harm, please take reasonable action to prevent such harm while maintaining your own safety.

 

Safe Workplace

We are committed to a violence-free work environment, and we will not tolerate any level of violence or the threat of violence in the workplace. If you become aware of a violation of this policy, you should report it to info@pepelwerk.com immediately. In case of potential violence, contact law enforcement.

 

III. Avoid Conflicts of Interest

When you are in a situation in which competing loyalties could cause you to pursue a personal benefit for you, your friends, or your family at the expense of pepelwerk or our users, you may be faced with a conflict of interest. All of us should avoid conflicts of interest and circumstances that reasonably present the appearance of a conflict.

When considering a course of action, ask yourself whether the action you're considering could create an incentive for you, or appear to others to create an incentive for you, to benefit yourself, your friends or family, or an associated business at the expense of pepelwerk. If the answer is "yes," the action you're considering is likely to create a conflict of interest situation, and you should avoid it.

 

Below, we provide guidance in seven areas where conflicts of interest often arise:

  • Personal investments
  • Outside employment, side-gigs/jobs, advisory roles, board seats, and starting your own business
  • Business opportunities found through work
  • Inventions
  • Friends and relatives; co-worker relationships
  • Accepting gifts, entertainment, and other business courtesies
  • Use of pepelwerk products and services

 

In each of these situations, the rule is the same – if you are considering entering a business situation that creates a conflict of interest, don't. If you are in a business situation that may create a conflict of interest, or the appearance of a conflict of interest, schedule time to review the situation with someone at pepelwerk by sending a request to info@pepelwerk.com. Finally, it's important to understand that as circumstances change, a situation that previously didn't present a conflict of interest may present one.

 

Personal Investments

Avoid making personal investments in companies that are pepelwerk competitors or business partners when the investment might cause, or appear to cause, you to act in a way that could harm pepelwerk.

When determining whether a personal investment creates a conflict of interest, consider the relationship between the business of the outside company, pepelwerk' s business, and what you do at pepelwerk, including whether the company has a business relationship with pepelwerk that you can influence, and the extent to which the company competes with pepelwerk. You should also consider 1) any overlap between your specific role at pepelwerk and the company's business, 2) the significance of the investment, including the size of the investment in relation to your net worth, 3) whether the investment is in a public or private company, 4) your ownership percentage of the company, and 5) the extent to which the investment gives you the ability to manage and control the company.

 

Investments in venture capital or other similar funds that invest in a broad cross-section of companies that may include pepelwerk competitors or business partners generally do not create conflicts of interest. However, a conflict of interest may exist if you control the fund's investment activity.

Outside Employment, Side-gigs/Jobs, Advisory Roles, Board Seats, and Starting Your Own Business

Avoid accepting employment, work, advisory positions, or board seats with pepelwerk competitors or business partners when your judgment could be, or could appear to be, influenced in a way that could harm pepelwerk. Additionally, because board seats come with fiduciary obligations that can make them particularly tricky from a conflict of interest perspective, you should notify pepelwerk before accepting a board seat with any outside company. Do not start your own business if it will compete with pepelwerk. Do not accept or conduct side-gigs, consulting work or jobs that compete with your obligations to pepelwerk or with companies that compete with pepelwerk.

 

Business Opportunities Found Through Work

Business opportunities discovered through your work here belong first to pepelwerk, except as otherwise agreed to by pepelwerk.

 

Inventions

Developing or helping to develop outside inventions that a) relate to pepelwerk' s existing or reasonably anticipated products and services, b) relate to your position at pepelwerk, or c) are developed using pepelwerk corporate resources, service partners or training provided by pepelwerk may create conflicts of interest and be subject to the provisions of pepelwerk' s Confidential Information and Invention Assignment Agreement and other employment or work agreements. If you have any questions about potential conflicts or intellectual property ownership involving an outside invention or other intellectual property, contact info@pepelwerk.com.

 

Friends and Relatives; Co-Worker Relationships

Avoid participating in management of or decision-making regarding potential or existing pepelwerk business relationships that involve your relatives, spouse or significant other, or close friends. This includes being the hiring manager for a position for which your relative or close friend is being considered or being a relationship manager for a company associated with your spouse or significant other.

To be clear, just because a relative, spouse/significant other, or close friend works at pepelwerk or becomes a pepelwerk competitor or business partner doesn't mean there is a conflict of interest. However, if you are also involved in that pepelwerk business relationship, it can be very sensitive. The right thing to do in that situation is to remove yourself.

Finally, romantic relationships between people who work together, depending on the work roles and respective positions of the workers involved, create an actual or apparent conflict of interest. If a romantic relationship does create an actual or apparent conflict, it may require changes to work arrangements. If you are feeling the warm and fuzzies towards another person, and its welcomed and reciprocated, both parties need to be proactive and act in the best interest of pepelwerk to make the romance work and not cause conflict of interest. pepelwerk is not the matchmaker of the dating world, just the working world and we don't want to have any perception that we cross that line.

 

Accepting Gifts, Entertainment, and Other Business Courtesies

Accepting gifts, bribes, entertainment, and other business courtesies from a pepelwerk competitor, business partner, government official or office or any other person's, entity or group that was given with the intention to influence your decision making that would benefit the providing party and impact pepelwerk adversely in anyway is prohibit. We take pride in providing our users with solutions and services that enhance their working experiences. Any behavior that creates the perception that we were playing politics, got bought or just enjoyed a 3-day vacation as a gift to influence our decision making is simply not acceptable.

 

Use of pepelwerk Products and Services

Avoiding potential conflicts of interest also means that you should not use pepelwerk products, services, internal tools, or information in a way that improperly benefits you or someone you know or creates the appearance that you have an unfair advantage over users outside of pepelwerk. For example, you should never approve pepelwerk accounts, services, or credits for yourself, your friends, or family members. Similarly, you should not use the tools, information, or access that you have as someone who works with or for pepelwerk to participate in or to generate a financial benefit for yourself or others. Do not use any service provider accounts, platforms or tools for your own personal gain.

 

Reporting

All queries reported to info@pepelwerk.com are reviewed by the executive leadership of pepelwerk and responses are determined on a case-by-case basis.

 

IV. Preserve Confidentiality

Unless specifically given permission to speak on the company's behalf by the CEO, we expect all details, exchanges, information and communication with pepelwerk to be kept confidential. Information that is leaked to external sources that do not have a working relationship with pepelwerk can hurt our product launches, eliminate our competitive advantage and prove costly in other ways. Essentially we want you to treat your working relationship like your code name is 007 and keep things that are pepelwerk's – pepelwerks

 

This also includes:

  • properly secure, label, and (when appropriate) dispose of Confidential pepelwerk material;
  • safeguard Confidential information that pepelwerk receives from others under non-disclosure agreements;
  • take steps to keep our trade secrets and other confidential intellectual property secret.

 

Confidential Information

Make sure that information that is classified and labeled as "Need to Know" or "Confidential" is handled as such. Do not share, forward, copy, or distribute under any circumstances. This includes be aware of your environment, the people that you are with and the pictures that you are in and ensuring that you are not disclosing confidential information. This includes keeping things confidential when winding down or having conversation with a friend, significant other or acquaintance that work for competitors. Use common sense- don't share information that would cause harm to pepelwerk and don't solicit information that could potentially gain pepelwerk

 

Pepelwerk Partners

Just as you are careful not to disclose confidential pepelwerk information, it's equally important not to disclose any confidential information from our partners. Don't accept confidential information from other companies without first having all parties sign an appropriate Non-disclosure Agreement approved by Legal. Even after the agreement is signed, try only to accept as much information as you need to accomplish your business objectives.

 

Pepelwerk data

Be sure to protect confidential information of pepelwerk or of any subsidiary or affiliate ("pepelwerk companies"). You may have access to confidential information through collaborations, rotations, 20% projects with another pepelwerk company, access to pepelwerk buildings or networks, or simply through casual interactions. Don't access or use confidential information of other pepelwerk companies except when authorized and reasonably necessary for valid business purposes within the scope of your work at or with pepelwerk. Take all reasonable steps to maintain the confidentiality of any such information just as you would for pepelwerk confidential information.

Don't disclose any confidential information about any pepelwerk company, including financial, partner, business, technical, or IP information, before obtaining appropriate sign-off from Legal, which may include getting consent from affected pepelwerk companies.

 

Competitors/Former Employers

We respect our competitors and want to compete with them fairly. But we don't want their confidential information. The same goes for confidential information belonging to any pepelwerk's former employers. If an opportunity arises to take advantage of a competitor's or former employer's confidential information, don't do it. Should you happen to come into possession of a competitor's confidential information, contact Legal immediately.

 

Outside Communications

You probably know that our policy is to be extremely careful about disclosing confidential proprietary information. Consistent with that, you should also ensure your outside communications (including online and social media posts) do not disclose confidential proprietary information or represent (or otherwise give the impression) that you are speaking on behalf of pepelwerk unless you're authorized to do so by the company. The same applies to communications with the press.

 

V. Protect pepelwerk's Assets

Intellectual Property

pepelwerk's intellectual property rights (our trademarks, logos, copyrights, trade secrets, "know-how", and patents) are among our most valuable assets. Unauthorized use can lead to their loss or serious loss of value. You must respect all copyright and other intellectual property laws, including laws governing the fair use of copyrights, trademarks, and brands. You must never use pepelwerk's (or its affiliated entities') logos, marks, or other protected information or property for any business or commercial venture without pre-clearance from the CEO. We strongly encourage you to report any suspected misuse of trademarks, logos, or other intellectual property to info@pepelwerk.com.

Likewise, respect the intellectual property rights of others. Inappropriate use of others' intellectual property may expose pepelwerk and you to criminal and civil fines and penalties. Please seek advice from Legal before you solicit, accept, or use proprietary information from individuals outside the company or let them use or have access to pepelwerk proprietary information. You should also check with Legal if developing a product that uses content not belonging to pepelwerk.

Consistent with our policy of respecting the valid intellectual property rights of others, we strictly comply with the license requirements under which open source software is distributed. Failing to do so may lead to legal claims against pepelwerk, as well as significant damage to the company's reputation.

 

Company Equipment

pepelwerk gives us the tools and equipment we need to do our jobs effectively but counts on us to be responsible and not wasteful with the pepelwerk stuff we are given. Don't be wasteful, excessive or access use or play with company resources and tools in a way that is abusive in nature. The big things like messing with company funds, equipment, and other physical assets are not to be requisitioned for purely personal use.

 

The Network

pepelwerk's communication facilities (which include both our network and the hardware that uses it, like computers and mobile devices) are a critical aspect of our company's property, both physical and intellectual. Be sure to follow all security processes. If you have any reason to believe that our network security has been violated – for example, you lose your laptop or smart phone or think that your network password may have been compromised – please promptly report the incident to info@pepelwerk.com.

 

Physical Security

If you're not careful, people may steal your stuff. Keep your head on a swivel. Always secure your laptop, important equipment, and your personal belongings, even while at a pepelwerk location. Don't tamper with or disable security and safety devices.

 

Use of pepelwerk's Equipment and Facilities

Anything you do using pepelwerk's corporate electronic facilities (e.g., our computers, mobile devices, network, etc.) or store on our premises (e.g., letters, memos, and other documents) might be disclosed to people inside and outside the company. For example, pepelwerk may be required by law (e.g., in response to a subpoena or warrant) to monitor, access, and disclose the contents of corporate email, voicemail, computer files, and other materials on our electronic facilities or on our premises. In addition, the company may monitor, access, and disclose communications and other information on our corporate electronic facilities or on our premises where there is a business need to do so, such as protecting pepelwerk and its users, maintaining the security of resources and property, or investigating suspected misconduct.

 

Individual Data

We collect and store personal information from individuals around the world. Access this data only in line with local law and pepelwerk internal policies and be sure to handle individual data in a manner that is consistent with local governing laws and pepelwerk's privacy policy.

 

VI. Ensure Financial Integrity and Responsibility

Spending pepelwerk's Money

A core business principle of pepelwerk is to spend money wisely and to earn money responsibly. When you spend money on pepelwerk's behalf, make sure that the cost is reasonable, directly related to company business, and provides value to the business, the quality of the work we do or enhances our user experience.

 

Working with Suppliers and Business Partners

As pepelwerk grows, we enter more and more deals with suppliers of equipment and services. We should always strive for the best possible deal for pepelwerk and our users. This almost always requires that you solicit competing bids to make sure that you're getting the best offer. While price is very important, it isn't the only factor worth considering. Quality, service, reliability, and the terms and conditions of the proposed deal may also affect the final decision.

 

VII. Obey the Law

pepelwerk takes its responsibilities to comply with laws and regulations very seriously and each of us is expected to comply with applicable legal requirements and prohibitions. While it's impossible for anyone to know all aspects of every applicable law, you should understand the major laws and regulations that apply to your work. You are responsible for being a subject matter expert in the work you do and that includes knowing when you are doing things outside the law.

 

Trade Controls

U.S. and international trade laws control where pepelwerk can send or receive its products and/or services. These laws are complex, and apply to:

  • imports and exports from or into the U.S.
  • imports and exports of products from or into other countries, with additional concerns when those products contain components or technology of U.S. origin
  • exports of services or providing services to non-U.S. persons
  • exports of technical data, especially when the technical data is of U.S. origin

 

What constitutes an "import" or "export" under the law is broad. For example:

  • exposing or allowing access by non-U.S. persons to U.S. technical data can be an "export", regardless of what country the exposure occurred in
  • sending a server from one country ("country X") into another country ("country Y") is an export from country X and an import into country Y
  • permitting the download of software from one country ("country X") into another country ("country Y") is an export from country X
  • transporting technical data or software on your laptop, or tools or equipment in your luggage, may be an export and import

The bottom line: If you are in any way involved in sending or making available pepelwerk products, services, software, equipment, or any form of technical data from one country to another, work with your manager to be sure that the transaction stays well within the bounds of applicable laws. If you are not sure, research it with the governing agency. If you are unsure how or if the law applies to your work with, for or on behalf of pepelwerk, send your question to info@pepelwerk.com

 

Competition Laws

Most countries have laws - known as "antitrust," "competition," or "unfair competition" laws – designed to promote free and fair competition. These laws prohibit 1) arrangements with competitors that restrain trade in some way, 2) abuse of intellectual property rights, and 3) use of market power to unfairly disadvantage competitors.

Certain conduct is absolutely prohibited under these laws, and could result in your imprisonment, not to mention severe penalties for pepelwerk.

 

Examples of prohibited conduct include:

  • agreeing with competitors about prices
  • agreeing with competitors to rig bids or to allocate customers or markets
  • agreeing with competitors to boycott a supplier or customer
  • Other activities can also be illegal, unfair, or create the appearance of impropriety.

 

Such activities include:

  • sharing competitively sensitive information (e.g., prices, costs, market distribution, etc.) with competitors
  • entering into a business arrangement or pursuing a strategy with the sole purpose of harming a competitor
  • using pepelwerk's size or strength to gain an unfair competitive advantage

 

Although the spirit of these laws is straightforward, their application to situations can be quite complex.

pepelwerk is committed to competing fair and square. Any persons working with, for or on behalf of pepelwerk found to have violated these policies will, subject to local laws, be disciplined, up to and including terminating the working relationship. If you suspect that anyone at the company is violating the competition laws, send suspicions to info@pepelwerk.com

 

Insider Trading Laws

Internally we share information, including non-public information, about pepelwerk's business operations openly. In addition, you may overhear a conversation or come across a memo at a copy machine, either of which might involve confidential information. To use this non-public information to buy or sell stock, or to pass it along to others so that they may do so, could constitute insider trading. Insider trading not only violates this Code, it violates the law. Don't do it.

 

Anti-bribery Laws

Don't bribe anybody, anytime, for any reason.

Non-government relationships

You should be careful when you give gifts and pay for meals, entertainment, or other business courtesies on behalf of pepelwerk. We want to avoid the possibility that the gift, entertainment, or other business courtesy could be perceived as a bribe, so it's always best to provide such business courtesies infrequently and, when we do, to keep their value moderate.

 

Dealing with government officials

Offering gifts, entertainment, or other business courtesies that could be perceived as bribes becomes especially problematic if you're dealing with a government official. "Government officials" include any government employee; candidate for public office; or employee of government-owned or -controlled companies, public international organizations, or political parties. Several laws around the world, including the U.S. Foreign Corrupt Practices Act and the UK Bribery Act, specifically prohibit offering or giving anything of value to government officials to influence official action or to secure an improper advantage. This not only includes traditional gifts, but also things like meals, travel, political or charitable contributions, and job offers for government officials' relatives. Never give gifts to thank government officials for doing their jobs. By contrast, it can be permissible to make infrequent and moderate expenditures for gifts and business entertainment for government officials that are directly tied to promoting our products or services (e.g., providing a modest meal at a day-long demonstration of pepelwerk products). Payment of such expenses can be acceptable, assuming they are permitted under local law.

The U.S. also has strict rules that severely limit the ability of a company or its employees to give gifts and business courtesies to a U.S. government official and limit the official's ability to accept such gifts. The Honest Leadership and Open Government Act prohibits giving any gifts, including travel and other courtesies, to Members, Officers, and employees of the U.S. Senate and House of Representatives unless they fit within one of several specific exceptions. Gifts to employees of the U.S. executive branch are also regulated and subject to limits. Finally, state and local government officials in the U.S. are also subject to additional legal restrictions. If you don't know, look it up on your local governing bodies web page.

 

VIII. Conclusion

pepelwerk aspires to be a company that walks the talk and tries every effort to create the changes that we believe enhance our working world. This document isn't meant to spell out every scenario, that would be unnecessary and a little ridiculous. Instead, we expect that you use good judgement and consider our Code when representing yourself in the work you do, with for or in connection to pepelwerk.