Code of Business Conduct and Ethics
Amended and Restated on:
July 6, 2018
At Leaseable, we believe in hiring great people to provide the highest levels of service to our customers. It has always been our practice to conduct ourselves with the highest standards of ethical behavior when it comes to taking care of our customers, interacting with each other and protecting our company's interests.
This document, the Leaseable Code of Business Conduct and Ethics or ‘Code of Conduct,' covers a wide range of business practices and procedures. It serves as a framework to help you understand the core philosophies of Leaseable business and to guide you as you make on-the-job decisions.
As a Leaseable employee, you are expected to comply with the Code of Conduct and any other applicable laws, regulations, expectations, policies, procedures and guidelines that apply to your position. Failure to do so may result in disciplinary action up to and including termination of employment.
USE GOOD JUDGMENT IN ALL SITUATIONS
We expect you to use good judgment when it comes to taking care of our customers and in your interactions with other Leaseable employees and partners. The following pages contain important information and guidelines we have created to help you use good judgment. When we talk about using good judgment, it's really about how we treat our customers, how we treat each other and how we do business. If you have questions about what using good judgment means, talk with a manager.
OUR DOOR IS ALWAYS OPEN
We value and encourage open and honest discussion, which is why our Open-Door philosophy is such an important part of our culture. Clear, open, honest, and respectful communication is essential.
We want you to feel confident in discussing any issue with the person or people directly involved.
The following individuals are among those who can help you with any questions or concerns you may have:
- A manager (does not have to be your own)
- Chief of Staff
You can find contact information for these individuals through Slack or email.
In the event you become aware of illegal or unethical behavior, immediately report it to one of the above individuals. Please keep in mind that while you have the option to make your report anonymously, we will need sufficient details about your concern in order to adequately investigate it and take any appropriate action.
RETALIATION IS NOT PERMITTED
We do not permit any retaliation of any kind against employees who report possible misconduct, raise a concern regarding a violation of this Code of Conduct, participate in an investigation or otherwise engage in legally protected activity. Anyone who retaliates will be subject to disciplinary action, up to and including termination of employment.
If you feel you have been subject to retaliation, immediately contact a manager.
WE TAKE CARE OF OUR CUSTOMERS
OUR CUSTOMER SERVICE COMMITMENT
We have a commitment to provide our customers with the best possible service every time they interact with us. Our focus is and always will be to provide our customers with a great experience and to continually maintain a strong and lasting relationship with them.
We ask that you always use good judgment and treat customers in the manner that you would like to be treated.
Personal information includes names, mailing and email addresses, phone numbers, dates of birth, Social Security numbers, billing information, and cardholder or other account data or other customer lists.
It's Important for You to Remember To:
- Access and use personal information only when appropriate for authorized Leaseable-related purposes.
- Ensure you capture and record customer information accurately once you have the customer's permission.
- Return all customer information in any format that you have in your possession should your employment with Leaseable end for any reason. You may not retain or use any customer information you gained while employed at Leaseable for any purpose.
- Comply with all Leaseable policies and procedures for handling personal information and accessing systems to ensure that we meet our legal obligations, protect our reputation and protect our investment in proprietary information.
You Need to Remember Not To:
- Enter customer information into any unauthorized personal address book, physical or electronic document or list, cell phone or other device.
- Download or remove any customer information from Leaseable applications, developer Apps, or Leaseable enabled systems.
- Share or release any customer information to unauthorized third parties (via social media apps, partners, insurance companies, investigators, friends or family members of the customer).
If you witness, become aware of, or suspect a situation where sensitive, personal or confidential information is or may be lost, stolen or disclosed outside the company in an unauthorized manner — whether it's deliberate or accidental — immediately notify a manager.
We’re a tech company so we don’t just encourage, we necessitate that employees leverage available tech. You are expected to use good judgment when using Leaseable-provided technology, including but not limited to:
• Access to the Internet
• Social networking/media tools
• Software and software tools such as developer tools and mobile applications
• Communication methods such as email, texting, secure e-mail and voice mail
• Approved personal or company issued devices, including smart phones and other mobile devices that access the Leaseable network
• Private web-based email accounts such as Hotmail, Gmail, Yahoo, etc. that you may access through company-provided technologies
• Information that is retrieved and stored in company-owned hard drives or in temporary intranet files
We have a legitimate business need (including to ensure compliance with Leaseable policies, including this Code of Conduct) to access, review, copy, move or delete the content and information carried by these technologies at any time and without notice, and by using these technologies, you understand and agree that Leaseable retains the right to do so.
All Leaseable guidelines apply to the use of technology. These include, but are not limited to our expectations regarding harassment, discrimination, retaliation, sexual harassment, violence in the workplace, privacy and non-public, proprietary company information. Discriminatory, unethical and/or inappropriate behavior when using these technologies or social media will not be tolerated.
Leaseable manages our business records and information, both written and electronic, as part of our normal course of business in compliance with Leaseable’s policies and applicable regulatory and legal requirements.
SOCIAL MEDIA AND BLOGGING
We recognize that many of our employees use social media tools as another way to connect with customers and share information about Leaseable.
Whether or not you are acting on behalf of Leaseable, or using your personal social media accounts or blogs to talk about our products or our business (e.g., projects, promotions, sales, events and initiatives), always use good judgment and follow these guidelines:
- Don’t post sensitive, private or confidential company information (e.g. unannounced product launches and promotions, internal sales results, company strategy, pricing information or comparisons).
- Respect customer privacy. Never give out personal customer information (e.g. personal addresses, phone numbers, or credit card information) or add information you receive from social networking to Leaseable tools.
- Don’t post photos of or make negative comments about our customers and do not share details about customer visits — both private and public figures — without their permission (unless it is a marketed personal appearance for the Company).
- Don’t post comments about a coworker, customer or partner that could be perceived as harassing, threatening, retaliatory, or discriminatory.
- You may be legally responsible for the content you post so respect brands, trademarks and copyrights.
- Follow terms and conditions for Social Networking sites.
· Ensure your posts do not create a real or perceived conflict of interest. A conflict of interest exists if you have an interest outside of your work at Leaseable that interferes with your job responsibilities or affects your judgment on behalf of Leaseable. For example, accepting direct advertising or any type of compensation (including products, samples or experiences with value) from a competitor for your blog or other social media site, including other software companies, can influence how you work with that partner, thus creating a real or perceived conflict of interest. Please consult your manager with questions.
Failure to comply may result in disciplinary action up to and including termination of employment.
WE TREAT EACH OTHER WITH RESPECT
EQUAL EMPLOYMENT OPPORTUNITY PHILOSOPHY
Our people are the foundation of who we are as a company. Attracting, hiring and retaining diverse talent enables us to be more innovative and better serve our employees, customers and communities.
We uphold our tradition of valuing our employees and are an equal opportunity employer committed to recruiting, hiring, training and promoting qualified people of all backgrounds, regardless of actual or perceived sex; race; color; religious creed; national origin; ancestry; age; marital status; pregnancy; nursing mother status; physical, mental or sensory disability; medical condition; genetic information; sexual orientation; gender (including gender identity or expression); military or veteran status; or any other basis protected by federal, state and/or local laws.
Please contact the Chief of Staff if your ability to perform the expectations of your job is impacted by your pregnancy, disability, or religion. We will partner with you to determine if there is a reasonable accommodation we can provide, such as an accommodation to enable you to perform the essential functions of your job. If you are unable to perform the essential functions of the job, even with a reasonable accommodation, we encourage you to ask for support in identifying other available positions at Leaseable for which you may be qualified or any other reasonable accommodation options such as a leave of absence.
You have an obligation to assist and cooperate in the accommodation process. The process has the best chance of success if you advise management of your need for accommodation and continue to work collaboratively and in good faith with us during the accommodation process. As part of this obligation, you are expected to have ongoing communication with Leaseable, including during absences, and provide and facilitate timely responses to Leaseable’s requests for relevant information about your accommodation needs.
CREATE A POSITIVE WORK ENVIRONMENT
WE DO NOT PERMIT HARASSMENT OR DISCRIMINATION
At Leaseable we strive to create an inclusive, supportive environment. To that end, we do not permit discrimination or harassment of any kind by any supervisor, manager, coworker and/or third parties that are working in our stores. This includes, but is not limited to, discrimination or harassment based on actual or perceived sex; race; color; religious creed; national origin; ancestry; age; marital status; pregnancy; nursing mother status; physical, mental or sensory disability; medical condition; genetic information; sexual orientation; gender (including gender identity or expression); military or veteran status; or any other basis protected by federal, state and/or local laws. Any unwanted and/or unwelcome behavior — whether it is physical, verbal, in person, written, or through email, social media, or other technological means — that creates an intimidating, hostile or offensive environment is prohibited.
If you experience or observe any behavior you believe is discriminatory or harassing, you should report it immediately to any manager. In addition, managers and supervisors must report any such complaints so that they can be addressed immediately. Complaints, written or verbal, will be investigated as promptly and as confidentially as is reasonable. Leaseable prohibits retaliation for reporting or participating in an investigation of harassment or discrimination. Leaseable will take corrective action when appropriate, up to and including termination of employment. Leaseable will inform the complaining employee either verbally or in writing of the outcomes of its investigation when appropriate.
Sexual Harassment is a Serious Matter
We do not permit harassment of any kind and that includes sexual harassment by or against employees, partners or customers. Sexual harassment may include threats or insinuations that an employee's refusal to submit to sexual advances will adversely affect that person's employment, evaluation, wages, advancement opportunities, assigned duties or any other conditions of employment or career development.
Sexual harassment can also be sexual advances, requests for sex, or unwelcome verbal or physical conduct based on sex that interferes with an employee's work performance or creates an intimidating, hostile, humiliating, or sexually offensive work environment. Sexual harassment can include conduct that was not motivated by sexual desire and can include harassment of a person of the same sex as the harasser. While it is impossible to list all types of behavior that could be sexual harassment, some examples are:
- Unwanted and/or unwelcome sexual comments, advances, flirtations or propositions.
- Verbal abuse of a sexual nature, including sexually oriented jokes or comments or questions regarding one's sexual experience, activity or prowess.
- Comments about an individual's sexual attractiveness.
- Display of sexually suggestive objects or pictures or making sexually suggestive gestures.
Leaseable prohibits these acts and any other acts that constitute sexual harassment.
KEEP OUR WORKPLACE FREE FROM VIOLENCE
As part of our goal to provide a safe environment for our employees and customers, Leaseable prohibits any kind of threat, intimidation or act of violence in the workplace.
Threats — either direct or implied — may include words, gestures, phone calls, emails, text messages, social networking/media messages or posts and drawings.
Intimidation, threats and violence may also arise out of non-work situations, for example, domestic abuse or relationship breakups. These situations may impact our workplace, including your safety or the safety of coworkers, customers or partners. Leaseable is committed to working with employees who are victims of domestic violence to prevent abuse and harassment from occurring in the workplace. Leaesable is also committed to managing the risk these situations may pose to other employees and customers.
As an employee, you play a critical role in maintaining a culture of safety. You must immediately notify a manager of any threats, intimidation and/or acts of violence (including threats to harm oneself) as soon as possible so that we can evaluate and implement appropriate safety procedures to help ensure a safe and secure workplace. Leaseable will address any threats or concerns as promptly and confidentially as is reasonable. Remember, we cannot take steps to help create a violence-free workplace unless we are aware of situations that could lead to the risk of violence in the workplace. You are also responsible for:
• Cooperating with an investigation into any risk of violence in the workplace.
• Providing Leaseable with a copy of any temporary or permanent restraining/protection orders that identify you, any Leaseable employee or any Leaseable location as protected.
• Not bringing potentially dangerous items — including weapons — into the workplace with you. Weapons of any kind are not allowed in our workplace for any reason.
Leaseable cares about the well-being and safety of our employees.
We all share responsibility for our own safety and the safety of our coworkers and customers.
You are responsible for making safety a priority and performing your duties according to general safety practices. You are also responsible for complying with all job-specific safety best practices. We will communicate safety performance openly with you, and we expect you to inform a manager anytime you come across a situation or condition you believe might jeopardize your safety or the safety of others. Failure to follow safety practices or to report safety violations may result in discipline up to and including termination of employment.
DRUGS, ALCOHOL AND TOBACCO LIMITATIONS IN THE WORKPLACE
We believe Leaseable should be a safe, efficient and productive place to work. For that reason, employees must work free from the effects of drugs and alcohol.
Leaseable prohibits having, using, or being under the influence of drugs (including drug paraphernalia) while you work (including meal and rest periods), while attending company events, or while otherwise representing the company. For the purposes of this policy, 'drugs' includes: (1) any illegal drug; (2) any over-the-counter or prescription medication that is obtained illegally or is used contrary to its prescribed dosage or purpose; and (3) marijuana.
Leaseable also prohibits employees from consuming or being under the influence of alcohol during their work (including meal and rest periods), while attending customer events, or while otherwise representing the company.
If Leaseable determines that an employee has violated this policy or if an employee is perceived to be under the influence of drugs or alcohol during work (including meal and rest periods), while attending customer events, or while otherwise representing the company, Leaeable may take disciplinary action, up to and including termination of employment.
THEFT, FRAUD, AND OTHER CRIMINAL BEHAVIOR
Criminal behavior, theft of Leaseable merchandise, money, sales or other property, and fraudulent transactions are prohibited. They affect us all by diminishing our ability to meet our customers' needs and reducing our profitability.
Leaseable is committed to respecting your privacy.
We take great care to protect your personal information and require that you do the same by not misusing the personal information of other employees. Personal information about employees includes information such as Social Security numbers, dates of birth and health information. We have safeguards in place to limit access to your personal and health information.
The federal privacy regulation under the Health Insurance Portability and Accountability Act (HIPAA) controls the use and disclosure of protected health information. We take these privacy standards seriously, to ensure your rights regarding your health information, and comply with this regulation.
WE DO BUSINESS WITH INTEGRITY
PROTECT LEASEABLE, ITS INTERESTS AND PROPERTY
To protect Leaseable, its interests and its property, you must comply with all applicable governmental laws, rules and regulations when you are conducting business on behalf of Leaseable. You also must avoid engaging in conduct that, even though legal, is inconsistent with Leaseable’s policies or ethical principles. This means that you must ensure that you do not use Leaseable’s property, funds, personnel, time, facilities or equipment for your own personal use or gain. This also means that you must return to Leaseable at the end of your employment any Leaseable property, equipment or sensitive, personal or confidential information as defined in these guidelines that is in your possession or control.
Information about company performance that has not been made public must also be kept confidential. Be especially alert if someone asks you about the current pace of business, sales, our profitability or our strategies. Participating in these discussions can result in an inadvertent but nevertheless damaging, disparaging or illegal disclosure of information.
AVOID CONFLICTS OF INTEREST
Leaseable values fair and honest dealings with our customers, coworkers, partners, competitors and other business partners.
We expect you to uphold these values by avoiding conflicts of interest.
A conflict of interest can include activities, investments or associations that compete with Leaseable, that interfere with your judgment on behalf of Leaseable or exploit your position with Leaseable for personal gain. For example, a conflict of interest may exist if a member of your family is associated with a partner or you work for a competitor within the CRE sector — this could affect your independent judgment on behalf of Leaseable. A conflict of interest may also exist if you or a member of your family is associated with one of Leaseable's institutional investors or a financial analyst covering Leaseable stock.
You may work for another employer as long as it does not cause a conflict of interest or interfere with your job performance at Leaseable. This applies to use of social media as well. For example, if you are asked by a direct competitor to advertise or post their product information on your blog in exchange for compensation, this is a conflict of interest.
You must report any actual, perceived or potential conflicts of interest to your manager, Human Resources or store manager. Officers should report actual, perceived or potential conflicts of interest to the Corporate Secretary, and members of the Board of Directors should report actual, perceived or portential conflicts of interest to the Corporate Governance and Nominating Committee.
You should avoid relationships or behaviors that create a real or perceived conflict of interest with your job performance or judgment at Leaseable.
Any employee who has a close, personal relationship with an employee they supervise, or any relationship that could create a real or perceived conflict of interest, must immediately disclose the relationship to Human Resources or the store manager so that appropriate action may be taken, which may include transfer to a different department or location. Failure to promptly disclose such relationships or other related poor judgment may lead to disciplinary action up to and including termination of employment.
Store managers, Human Resources and Loss Prevention employees may not work in or support a store that employs any of their immediate family members or those with whom they have a romantic/sexual relationship, except in limited circumstances, which must be approved by the Executive Vice President of Human Resources or an approved designee.
IMPROPER GIFTS AND PAYMENTS
Accepting gifts, loans, trips or other items of value from a customer, partner, competitor or others with whom we do business — or may potentially do business — could create the impression that the gift improperly influenced our decision to do business with the gift giver.
As a result, neither you nor your family members may accept gifts from customers, partners or a competitor except for non-cash gifts of nominal value. You may accept a gift or prize as long as it is considered to be an authorized promotional prize provided by a partner to stimulate business.
Participating in business-related functions, including meals with a partner, customer or competitor is an acceptable form of entertainment and is generally allowed. This also includes accepting partner-sponsored business trips with prior supervisor approval. In all of these situations, use good judgment and ensure that the value and frequency of these functions do not become excessive.
Offering or giving money or anything else of value, directly or indirectly, to foreign government officials, parties or candidates for the purpose of obtaining or retaining business or to secure any improper advantage is illegal. You must not offer or accept bribes or use other inappropriate means to obtain an undue or improper advantage or engage in any other actions that violate U.S. or international anticorruption laws and regulations.
We are firmly committed to competing fairly and ethically in the marketplace. We do not enter into or try to enter into agreements, understandings or communications with competitors on matters such as prices, markups, markdowns and any other terms or conditions on which we do business.
TALKING ABOUT WAGES, HOURS AND WORKING CONDITIONS AND OTHER CONDITIONS OF EMPLOYMENT
You are free to discuss, debate, criticize and share with others information about your and other employees’ wages, hours, working conditions, conditions of employment and other personal information in support of your rights or as part of efforts under Section 7 of the NLRA and federal, state and/or local laws. Leaseable will also not take any action to impede an employee from communicating with any regulatory or self-regulatory organization or agency such as the Securities and Exchange Commission or OSHA. Nothing in this Code of Conduct is intended to impact or restrict these rights. Leaseable will not discipline, retaliate, or terminate your employment for exercising these rights.
Nothing in this information constitutes an employment contract. Your employment with Leaseable remains at-will, which means that both you and Leaseable reserve the right to end the employment relationship at any time, with or without notice, with or without reason.
IN CLOSING …
You are part of a group of talented individuals who work together to provide the highest level of software as a service. Throughout your career at Leaseable, you'll face many new challenges and opportunities. As you rise to meet the challenges and take advantage of the opportunities, we ask that you follow the philosophy Leaseable was founded upon: use good judgment in all situations. Doing so will empower you to provide outstanding service every day, one customer at a time. Use the information included in the Code of Conduct and other position-specific expectations to guide your decisions. You are expected to comply with the Code of Conduct and all other Leaseable policies. Because Leaseable is constantly growing and changing, this Code of Conduct may be revised from time to time without notice. For this reason, employees should access the Code of Conduct from /leaseablerules to ensure they are receiving the most current information about the Code of Conduct. And if you are ever in doubt or see something that doesn't look like good judgment, reach out to your resources, including your manager - we are here to help.