Code of Conduct

Updated December 4, 2020

Introduction

The BlueZoo Code of Conduct is one of the ways we put BlueZoo’s values into practice. It is built around the recognition that everything we do in connection with our work at and with BlueZoo 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, build great products, provide great services, and attract loyal clients and partners. Respect for our clients and partners, for the consumers that are exposed to our products and services, and for each other are foundational to our success, and are something we need to support in our everyday life.

So please do read the Code and respect BlueZoo’s values both in spirit and letter. Each of us has a personal responsibility to incorporate the principles of the Code and values into our work and our business relationships. 

Who must follow our code?

We expect all of our employees and Board members to know and follow the Code. Failure to do so can result in disciplinary action, including termination of employment. Moreover, while the Code is specifically written for BlueZoo employees, managers, executives and Board members, we expect members of our extended workforce (temps, vendors, and independent contractors) and others who may be temporarily assigned to perform work or services for BlueZoo to follow the Code in connection with their work for us. This code also applies to our partners and suppliers. Failure of a member of our extended workforce or other covered service provider to follow the Code can result in termination of their relationship with BlueZoo. 

Ethical principles and core values

Making ethical choices and good decisions builds trust between each of us and the people we interact with. But not all situations you encounter are straightforward—how do you make the best choice when facing difficult or unclear circumstances? While this Code of Conduct will not tell you exactly what to do in every situation, it serves as a guide to help you make good decisions and navigate complex situations where the answer might not always be clear. 

Our core values of Trustworthiness, Privacy and Respect govern everything we do.

Trustworthiness – When making decisions, ask yourself: does this build or harm trust with our customers? Our ability to meet people and organizations where they are, with what they want and need is our path to success. Our customers must be at the center of everything we do. Look for ways to engage our customers, advocate for them, and empower them to achieve more.

Privacy – At BlueZoo, we honor Privacy as a human right. We value the personal data entrusted to us and we are committed to collecting, using, retaining and disclosing personal data in a fair, transparent and secure way. We are successful when our customers trust us to protect their Privacy and committed to use their data in the ways that they permit us. We must comply with all data privacy and associated laws applicable to the countries in which we gather and hold Personal Data.

Respect for Each Other – Respect for Each Other is another core value for BlueZoo and a cornerstone of our collective principles. Respect for Each Other means listening to each other. Respect for Each Other goes hand in hand with honesty and it also means honoring the contracts and agreements we sign. Respect for Each Other means making people the core focus of our collective undertaking, valuing diversity and paying attention to the quality of employee dialogue within the company and our dialogue with our partners, clients, providers and consumers affected by our products and services. 

Decision making and the code of conduct

Making good decisions and ethical choices builds trust between each of us and the people we interact with. But not all situations you encounter are straightforward—how do you make the best choice when facing difficult or unclear circumstances? When you are confronted with a difficult decision, ask yourself why the situation makes you uneasy. Can you identify the issue? Is your answer to this conflict based on BlueZoo’s core values, does it reflect our company’s values and ethics? Do not sacrifice long-term reputation and trust for a short-term benefit. If you are unsure what to do, ask your manager or another manager. If you are not satisfied with their answers, ask your C-Level Management. You are never alone with your decisions.

Reporting/speaking up

Part of building a culture of trust and respect is learning to speak up when something is not right, so that we can address the problem. BlueZoo encourages all employees to ask questions and raise issues without fear of retaliation and is committed to treating reports seriously and investigating them thoroughly.

Employees must report suspected unethical, illegal or suspicious behavior immediately. The company does not tolerate retaliation against anyone who makes a good faith report of suspected misconduct or otherwise assists with an investigation or audit. 

To report a concern, talk to your manager or if you feel uncomfortable with this, talk to the C-level executive of your choice. If you still do not feel comfortable, please deliver an anonymous report to the CEO by postal mail to our headquarters:  325 Sharon Park Drive, Suite 940, Menlo Park, California 94025, USA.

No retaliation

It takes courage to speak up when something is not right. We understand that you might be uncomfortable or anxious. That is why BlueZoo does not tolerate retaliation. Know that Employees who report a concern in good faith cannot be subjected to any adverse employment action including unfair dismissal, demotion or suspension, unfair denial of a promotion, transfer or other employment benefit, bullying and harassment, either in person or online as well as any other behavior that singles out the person unfairly. 

Equal opportunity

At BlueZoo, we know that we work better together because of our differences, not despite them. We believe that we best serve everyone on the planet and enrich our own culture through the diverse skills, experiences, and backgrounds that each of us brings to the company. BlueZoo will not tolerate discrimination or bullying based on race, color, religion, gender, age, national origin, sexual orientation, marital status, disability or any other protected class. 

Harassment and bullying

We treat all fellow employees, customers, business partners and other stakeholders with dignity and respect at all times. We resolve problems respectfully, and never resort to acts or threats of violence.

Any type of harassment, including physical, sexual, verbal or other, is prohibited and can result in disciplinary action up to, and including, termination. Harassment can include actions, language, written words or objects that create an intimidating or hostile work environment, such as yelling at or humiliating someone, physical violence or intimidation, unwanted sexual advances, invitations or comments, visual displays such as derogatory or sexually-oriented pictures or gestures, physical conduct including assault or unwanted touching, threats or demands to submit to sexual requests as a condition of employment or to avoid negative consequences.

As well as any type of harassment, bullying does not have its place at BlueZoo. Any type of bullying is prohibited and can result in disciplinary action. We are committed to ensuring that our employees, our contractors and our customers work in a safe and respectful environment that is free of bullying. Bullying can include spreading malicious rumor or gossip, excluding or isolating someone socially, withholding necessary information or purposefully giving the wrong information, intimidating someone, unfairly denying training, leave or promotion, sending offensive jokes or emails, criticizing or belittling someone constantly or tampering with a person’s personal belongings or work equipment.

Conflicts of interest

A conflict of interest can occur when an employee’s personal activities, investments or associations compromises their judgment or ability to act in the company’s best interests. Employees should avoid the types of situations that can give rise to conflicts of interest.

It is important for employees to disclose any relationships, associations or activities that could create actual, potential, or even perceived, conflict of interest to their manager or the Human Resources Department.

Privacy

Honoring privacy is one of the core values of BlueZoo. The company complies with the requirements of the country’s and international privacy laws. All employees sign an agreement that contains provisions for information confidentiality and non-disclosure. The company and its employees do not disclose any personal information of employees, customers, suppliers, competitors and any other third party. Employees store all personal information securely, mark it as confidential and store it only for as long as it is needed for the purpose for which it was collected.

When providing personal information, employees limit access to only those with a clear business need for the information.

Employees are required to report any breaches of privacy, including the loss, theft of or unauthorized access to personal information, immediately to the Data Privacy Officer.

Competition and fair dealings

While the company competes aggressively for new business, relationships with business partners are built upon trust and mutual benefits and are compliant with competition/antitrust laws.

Employees are required to communicate information about the company’s products and services in a manner that is fair and accurate, and that discloses all relevant information. Anti-competitive activities like bid rigging are prohibited.  BlueZoo never misrepresents  the company or its products in discussions with customers, partners, and suppliers.  BlueZoo uses only publicly available information to understand regulatory proposals and developments. If you become aware of possible violations of fair competition practices, advise your manager. 

Gifts and entertainment

While gifts and entertainment among business associates can be appropriate ways to strengthen ties and build goodwill, they also have the potential to create the perception that business decisions are influenced by them. The company is committed to winning business only on the merits of its products, services and people and complies with all legal requirements for giving and receiving gifts and entertainment. Use sound judgment and comply with the law, regarding gifts and other benefits and make sure that those gifts do not influence decisions or undermine the integrity of business relationships. Employees may accept occasional unsolicited personal gifts of nominal value such as promotional items and may provide the same to customers and business partners. When in doubt, employees should check with their manager before giving or receiving anything of value.

Political contributions

The company does not make political contributions. Employees are free to support any political party or entity on a personal level. However, this must be kept separate from company business.

Record keeping

BlueZoo keeps its books, records, accounts and financial statements in a complete, fair, accurate, understandable, detailed and timely manner. All documents, databases, voice messages, mobile device messages, computer documents, files and photos are records. Employees are required to maintain these records and protect their integrity for as long as required. Never destroy documents in response to, or in anticipation of, an investigation or audit.

Protection and proper use of company assets

BlueZoo requires all employees to protect its assets. All assets should be used for legitimate purposes, efficiently, and for company business only. Assets include facilities, equipment, computers and information systems, telephones, employee time, confidential and proprietary information, corporate opportunities and company funds. Suspected incidents of fraud, theft, negligence, and waste should be reported to the CFO.

Money laundering

The company complies with anti-money laundering laws. Money laundering is the process of concealing illicit funds by moving them through legitimate businesses to hide their criminal origin.

Employees must never knowingly facilitate money laundering or terrorist financing, and must take steps to prevent inadvertent use of the company’s business activities for these purposes. Employees are required to immediately report any unusual or suspicious activities or transactions such as attempted payments in cash or from an unusual financing source, arrangements that involve the transfer of funds to or from countries or entities not related to the transaction or customer, unusually complex deals that do not reflect a real business purpose and attempts to evade record-keeping or reporting requirements. 

Health and safety

The physical and mental health of our employees is a priority for us. BlueZoo conducts business in accordance with applicable health and safety requirements and strives for continuous improvement in its health and safety policies and procedures. All employees are expected to perform their work in compliance with applicable health and safety laws, regulations, policies and procedures and apply safe work practices at all times in all locations. Applicable safety and health requirements must be communicated to visitors, customers or contractors at any company location. Employees are required to immediately report workplace injuries, illnesses or unsafe conditions, including “near-misses.”

Environment

BlueZoo is committed to operating in an environmentally responsible manner, from the provision of products and services, to the operation of its offices and facilities, selection of suppliers and other business activities. We comply with all applicable environmental laws and regulations as well as self-directed commitments to sustainable practices and environmental protection. Please keep in mind environmental matters in your everyday business life. It starts with small things like using recycled paper and printing as little as possible.

Corporate social responsibility

Corporate social responsibility extends to our entire supply chain. This encompasses not only the products and services supplied but also the human rights, ethics and social practices of our company and its suppliers.

In its everyday business, BlueZoo is seeking partnerships with like-minded organizations by actively seeking out business partners who are the most environmentally and workforce friendly.

BlueZoo and its suppliers shall employ all employees under their own free will with no one being subjected to bonded or forced labor. This policy applies to not only the supplier’s business operations but also those of their supplier network with which the company conducts its business. We and our suppliers shall not employ any people under the minimum legal working age of the country in which they work.

Upholding these standards

As a BlueZoo employee, you are expected to uphold the standards outlined in this Code of Conduct. This means you must:

  • Read, understand, and comply with the entire Code of Conduct and understand your responsibilities related to it. If you have any questions, please ask your manager. 
  • Speak up when you see possible violations of the Standards, 
  • Be truthful, and cooperate fully in any internal investigations. Do not conceal or destroy information. 

Failing to read the Standards does not excuse you from these responsibilities.