Code of conduct

Introduction

“Open, honest and transparent” are our watchwords. The team at Connected generally apply those words to how we serve our clients. But “Open, honest and transparent” is so much more than that. It’s a mindset and a philosophy that aims to generate the highest levels of corporate and personal trust. It also includes us being honest about our shortfalls and knowing how and when to say sorry if we’ve made a mistake.

The Connected Code of Conduct is one of the ways we put this approach into practice. It’s built around the recognition that everything we do in connection with our work at Connected will be, and should be, measured against the highest possible standards of ethical business conduct. We set the bar that high for practical as well as aspirational reasons: Our commitment to the highest standards helps us hire great people, who then build great products, which in turn attract loyal users. Trust and mutual respect among employees and users are the foundation of our success, and they are something we need to earn every day.

This Code of Conduct was heavily inspired by Google’s “Do no evil” approach and their corresponding Code of Conduct. We make no apology for incorporating large elements of this in our own Code of Conduct – this is done as a mark of respect for the great company we believe Google is.

Who does this apply to?

Everyone. That includes our staff, directors, suppliers, contractors and client co-suppliers.

Serve our clients business needs

Our clients value us not only because we deliver great applications 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:

1. Integrity

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

2. Usefulness

   Our products, features, services and applications should make Connected more useful for all our clients, whether they’re they’re large corporations or small businesses. We have many different types of clients, but one guiding principle: ‘Is what we are offering useful?’

3. Privacy

   In our business relationships we are asking clients and their customers to trust us with their corporate and personal information. Keeping that trust requires that each of us respect and protect the privacy of that information. Know your responsibilities and access data only as authorized by them, our privacy policy and EU law.

4. Being attentive and responsive

   Part of being transparent and honest is being responsive. We should recognize feedback when we see it and do something about it. We take pride in responding to issues and problems from our clients and if something is broken then we should fix it and communicate this clearly and openly with the client.

5. Taking the lead

   Any time you feel our clients could be better-served, tell someone in the company about it. Continually improving our applications and services is a cornerstone of our Kaizen approach and this extends out of our “contracted sphere” to any other area of our clients’ business. Take the lead, find a solution and help the client meet their corporate goals.

Respect

We are committed to a supportive and collaborative work environment, where employees have the opportunity to reach their fullest potential. Each and every Connected employee is expected to do his or her utmost to create a respectful workplace culture that is free of harassment, intimidation, bias and unlawful discrimination of any kind.

1. Equal opportunity employment

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

2. Positive environment

   Connected prohibits unlawful harassment in any form — verbal, physical or visual.

   If you believe you’ve been harassed by anyone at Connected, you should immediately report the incident to your line manager or the CEO or both. Similarly, managers who learn of any such incident should immediately report it to the CEO, who will promptly and thoroughly investigate any complaints and take appropriate action.

3. Alcohol and drugs

   Our position on substance abuse is simple: It is usually illegal and certainly incompatible with the health and safety of our all employees. Consumption of alcohol is discouraged at our offices and we expect good judgment to be used at all times. Never drink in a way that leads to impaired performance or inappropriate behaviour, endangers the safety of others or breaks the law.

   Illegal drugs in our offices or at any event supported or formally attended by Connected is not allowed. If a manager has reasonable suspicion to believe that an employee’s use of drugs and/or alcohol may adversely affect the employee’s job performance or the safety of the employee or others in the workplace, the manager may request an alcohol and/or drug screening.

4. Safe environment

   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 the CEO immediately.

Avoid conflict of interest

In working at Connected, we have an obligation to always do what’s best for the company and our clients. When you are in a situation where competing loyalties could cause you to pursue a personal benefit for you or your friends or family at the expense of Connected or our clients, you may be subject to a conflict of interest. All of us should avoid circumstances that present even the appearance of such a conflict.

When faced with a potential conflict of interest, ask yourself:

• Would this relationship or situation embarrass me or Connected if it showed up on the front page of a newspaper, a blog or a social network?
• Am I uncomfortable to disclose the relationship or situation to my manager or the CEO?
• Could the potential relationship or situation create an incentive for me, or be perceived by others to create an incentive for me, to benefit myself, my friends or family or an associated business, at the expense of Connected?

If the answer to any of these questions is ‘yes,’ the relationship or situation is likely to create a conflict of interest, and you should avoid it.

Preserve confidentiality

Connected develops market-leading products and services and these sometimes receive press and/or community attention. This is good. However, confidential company information that leaks into the press or to competitors can hurt our product sales, competitive advantage and may prove very expensive in other ways. Our responsibilities extend beyond not revealing confidential Connected material so we must take steps to protect the confidentiality of information received by us under NDA or standard confidentiality contracts.

1. Confidential information

   Connected’s “confidential information” includes financial, product, application, client and user information. Make sure that confidential company material stays that way; don’t disclose it outside of Connected without authorisation. At times, a particular project or negotiation may require you to disclose confidential information to another party: Disclosure of this information should be on a “need to know” basis and only under a nondisclosure agreement. Be sure to get the appropriate agreement in place before you disclose the information.

   There are, of course, “gray areas” in which you will need to apply your best judgment in making sure you don’t disclose any confidential information. Suppose a friend who works at a non-profit organization asks you informally how to improve their web-site. Giving your friend conversion tips available in the public domain isn’t likely to be a problem, but giving tips that aren’t widely known definitely would be. If you’re in a gray area, be cautious in what advice or insight you provide or, better yet, ask for guidance from our CEO.

   And don’t forget about pictures you and your guests take at Connected — it is up to you to be sure that those pictures don’t disclose confidential information.

   Finally, some of us will find ourselves having family or other personal relationships with people employed by our competitors, customers, suppliers or partners. As in most cases, common sense applies. Don’t tell your significant other or family members anything confidential, and don’t solicit confidential information from them about their company.

2. Connected partners

   Just as you are careful not to disclose confidential Connected 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 our CEO. Even after the agreement is signed, try only to accept as much information as you need to accomplish your business objectives.

3. 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 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 our CEO immediately.

4. Communications and research

   Our policy is to be extremely careful about disclosing company information, and never to disclose any confidential information without authorisation. It’s also a bad idea to post your opinions or information about Connected on the Internet, even if not confidential, unless you’re authorised to do so as part of your job. Your comments may be attributed to Connected, even though you didn’t mean it that way. And never discuss the company with the press unless you’ve been explicitly authorised to do so. Finally, check with our CEO before accepting any public speaking engagement.

Protect Connected’s assets

Connected has a well-earned reputation for generosity with our employee benefits and openness with confidential information shared within the company. Our ability to continue these practices depends on how well we conserve company resources and protect company assets and information.

1. Intellectual Property

   Connected’s intellectual property rights (our trademarks, logos, copyrights, trade secrets, “know-how” and patents) are among our most valuable assets. Unauthorised use can lead to their loss or serious loss of value. Any use of Connected’s trademarks and logos must be cleared in advance by the Marketing team. Report any suspected misuse of trademarks, logos or other Connected intellectual property to our CEO.

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

   Connected is committed to open source software development. 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.

2. Company Equipment

   Connected gives us the tools and equipment we need to do our jobs effectively, but counts on us to be responsible and not wasteful with it. Company funds, equipment and other physical assets are not to be requisitioned for purely personal use.

3. The Connected Network

   Connected’s communication facilities (including Basecamp, Backpack, Highrise, Google Apps, Capistrano, Git etc) are a critical aspect of our company’s property, both physical and intellectual. Be sure to follow all security policies. If you have any reason to believe that our network security has been violated please promptly report the incident to Tim Lingard, our Systems Manager.

4. Physical security

   Sadly, theft can and will occur. Always secure your laptop, important equipment and your personal belongings, even while on company premises and certainly in and around company and private vehicles. Connected property held at an employee’s home for whatever reason must have suitable safeguards in place to protect both it’s physical and intellectual value.

5. Use of Connected’s equipment and services

   Anything you do using Connected’s corporate electronic services or store on our premises might be disclosed to people inside and outside the company. For example, Connected 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 employee 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 employees and users or maintaining the security of resources and property.

6. Employee data

   We collect and store personal information from employees around the world. Access this data only in line with EU law, and keep it secure according to those standards.

Ensure financial integrity and responsibility

Financial integrity and fiscal responsibility are core aspects of corporate professionalism. The money we spend on behalf of Connected is not ours; it’s the company’s and, ultimately, our owners’. Each person at Connected has a role in making sure that money is appropriately spent, our financial records are complete and accurate and internal controls are honoured. This matters every time we hire a new employee, expense something to the company, sign a new business contract or enter into any deals on Connected’s behalf.

Stay in full compliance with our system of internal controls, and don’t hesitate to contact our CEO or Head of Finance if you have any questions. What follows are some core concepts that lie at the foundation of financial integrity and fiscal responsibility here at Connected.

1. Spending Connected’s money

   A core Connected value has always been to spend money wisely. When you submit an expense for reimbursement or spend money on Connected’s behalf, make sure that the cost is reasonable, directly related to company business and supported by appropriate documentation. Always record the business purpose (e.g., if you take someone out to dinner on Connected, always record in your expenses the full names and titles of the people who attended as well as the reason for the dinner) and comply with other submission requirements. If you’re uncertain about whether you should spend money or submit an expense for reimbursement, check with your manager. Managers are responsible for all money spent and expenses incurred by their direct reports, and should carefully review such spend and expenses before approving.

2. Signing a contract

   Each time you enter into a business transaction on Connected’s behalf, there should be documentation recording that agreement approved by our lawyers. Never sign any contract on behalf of Connected unless all of the following are met:

   • You are authorized to do so. If you are unsure whether you are authorized, ask your manager;
   • The contract has been approved by our lawyers. If you are using an approved Connected form contract, you don’t need further approval unless you have made changes to the form contract or are using it for other than its intended purpose; and
   • You have studied the contract, understood its terms and decided that entering into the contract is in Connected’s interest.

   All contracts at Connected should be in writing and should contain all of the relevant terms to which the parties are agreeing. Connected does not permit “side agreements,” oral or written.

3. Recording transactions

   If your job involves the financial recording of our transactions, make sure that you’re fully familiar with all of the Connected policies that apply, including our revenue recognition policy and our purchasing policy.

   Immediately report to Head of Finance any transactions that you think are not being recorded correctly.

4. Reporting financial or accounting irregularities

   You should never, ever interfere in any way with the auditing of Connected’s financial records. Similarly, you should never falsify any record or account, including time reports, expense accounts and any other Connected records.

   If you suspect or observe any of the conduct mentioned above or, for that matter, any irregularities relating to financial integrity or fiscal responsibility, no matter how small, immediately report them to Head of Finance.

5. Hiring suppliers

   As Connected grows, we enter into more and more deals with suppliers of equipment and services. We should always strive for the best possible deal for Connected. 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.

Obey the law

Connected 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. A few specific laws are easy to violate unintentionally and so are worth pointing out here:

1. Competition laws

   Most countries have laws designed to encourage and protect free and fair competition. Generally speaking, 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 engage in unfair price discrimination and other forms of unfair practices.

   Although the spirit of these laws — known as “antitrust,” “competition,” or “unfair competition” laws — is straightforward, their application to particular situations can be quite complex. To ensure that Connected complies fully with these laws, each of us should have a basic knowledge of how they apply to our work. Some real life things to be cautious about include:

   • sharing of competitively sensitive information (e.g., prices, costs, market distribution, etc.) with competitors at trade and industry conferences; and
   • making statements (in emails, IMs, presentations, memos or anyplace else) that wrongly suggest that Connected has few or no competitors or that we seek to harm our competitors or improperly exploit our success.

2. Anti-bribery laws

   Like all businesses, Connected is subject to lots of laws that prohibit bribery in virtually every kind of commercial setting. The rule here is simple – don’t bribe anybody, anytime, for any reason. You should also be careful when you give gifts and pay for entertainment or other business courtesies on behalf of Connected. 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.

Conclusion

Connected aspires to be a really special company. One where everyone is valued, rewarded and respected by everyone else. We rely on one another’s good judgement to uphold a high standard of integrity for ourselves and our company. We expect all staff to be guided by both the letter and the spirit of this Code.