Document information and change log

Document Information

Change log

Gender And Entity Neutrality

The masculine form is used solely for the sake of better readability. It always refers to persons of any gender identity (m/f/diverse). This document uses the abbreviation “Give” for all legal entities and subsidiaries.

Table of Contents

Preamble        3

Values        4

Complying with laws, regulations and standards        4

Focusing on quality        4

Fair and Ethical Competition        4

Commitment to Diversity and Inclusion        5

Harassment-Free Workplace        5

Office and Remote Work Guidelines        5

Conflict of Interest        6

Managing Conflicts of Interest        6

Gifts and Entertainment        6

Responsibilities        7

Responsibilities Of Employees        7

Leadership Responsibilities        7

Safeguarding Confidentiality and Cybersecurity        9

Confidential and Proprietary Information        9

Privacy        9

Employee Information        10

Training        10

Cybersecurity        10

Integrity and Ethical Conduct        11

Personal Conflicts of Interest        11

Bribery and corruption        11

Preamble

Give Corporation Inc. ("Give") is dedicated to fostering a culture characterized by the highest standards of integrity, transparency, and ethical conduct. This Code of Conduct and Ethics (the “Code”) serves as a foundational framework for all individuals associated with Give, outlining the expectations and values that guide our collective commitment to responsible business practices.

In alignment with our commitment to ethical behavior, Give recognizes the importance of cultivating an environment that promotes trust, respect, and accountability. The Code is intended to provide clear guidelines for the conduct of all employees, officers, directors, and stakeholders associated with Give. Additionally, we expect third parties, including contingent workers, to act consistently with the values outlined in our Code when conducting business with or on behalf of Give.

As representatives of Give, the employees acknowledge our responsibility to act in a manner that upholds the organization's reputation and contributes positively to the communities in which we operate. By adhering to the principles outlined in this Code, we strive to create a workplace that is inclusive, respectful, and aligned with legal and regulatory requirements.

Give is committed to continuous improvement in our ethical standards and requires all members of Give to actively contribute to this commitment. Through our collective dedication to these principles, we reinforce the values that define Give Corporation Inc. and guide us in achieving our mission with integrity and excellence.

Culture

GiveCorporation is committed to fostering a culture of integrity, transparency, and ethical conduct.        The culture of ethics is the tone from the top. We will interact ethically and fairly with stakeholders, customers and vendors. Give is an environment where adherence to laws, regulations, ethical standards, and internal policies is ingrained in the organization’s values, practices, and behaviors. This culture goes beyond merely following rules; it’s about fostering a sense of integrity, accountability, and responsibility across all levels of the organization. Commitment from leadership and encouraging open communication and reporting reflect Give’s commitment to reporting and enhancing this culture. Our  values, practices, and behaviors are integrated into daily operations.

Values

Complying with laws, regulations and standards

Give’s core values are the core principles and beliefs that guide our organization's actions, decision-making, and culture and serve as a foundation for how employees, contractors and vendors interact with each other, customers, and stakeholders. Our core values include integrity, responsibility, and compliance, innovation, collaboration, excellence, accountability, respect, and sustainability.

Give is unwavering in its commitment to strict adherence to all applicable laws, regulations, and professional standards governing our operations. Give is committed to a culture of ethics, honesty and integrity. Give will interact ethically and fairly with stakeholders, customers and vendors.  The tone from the top is commitment to a culture of ethics. Violation of the Code of Conduct and Ethics will result in disciplinary actions that may include termination of employment. Our pledge to compliance serves as the cornerstone of our business practices, ensuring that every aspect of our organization operates within the boundaries of the legal framework that governs our industry.

It is strictly prohibited for any person associated with Give to engage in the laundering of money or any activity associated with the funding of terrorist or other illegal activities; it is the policy of Give to actively prevent such activities. Give and its management are firmly committed to reporting and prosecuting any and all personnel who participate, or have any knowledge whatsoever, of any money laundering or terrorist funding activities. It is the responsibility of every person associated with this Company to IMMEDIATELY report any suspicious activity in a Customer account or suspicious activity of any registered, non-registered or affiliated person of this Company to the designated Chief Compliance Officer (“CCO”).

The environment and market in which Give operates is constantly changing and evolving. Our systems and controls must reflect the degree of risk associated with our business and Customers and Give will determine appropriate customer due diligence measures on a risk-sensitive, case-by-case basis.

Focusing on quality

Give is unwaveringly dedicated to providing a service of exceptional quality and upholding the highest professional standards. Give exclusively undertakes commitments that align with our stringent quality benchmarks, ensuring that every aspect of our service reflects the excellence we strive for.

Fair and Ethical Competition

Give places a strong emphasis on maintaining a culture of integrity among our team members. Our core values dictate that we engage with our clients, service providers, suppliers, competitors, and colleagues with fairness. It is strictly prohibited for anyone within the organization to pursue a competitive edge through illegal or unethical business methods. Exploiting others through manipulation, concealment, misuse of privileged information, misrepresentation of crucial facts, or any unfair business practices is considered a breach of our ethical code.

Commitment to Diversity and Inclusion

Give places a high value on the distinct talents, personalities, work experiences, perspectives, cultural backgrounds, races, genders, ethnicities, sexual orientations, and other differences that each team member contributes to the Company. In line with this commitment, it is incumbent upon all employees to interact with one another in a manner characterized by mutual respect and to actively contribute to the cultivation of an inclusive organizational culture.

Harassment-Free Workplace

Give is dedicated to cultivating a professional environment free from any form of discrimination, bullying, or harassment. We unequivocally prohibit behaviors that may lead to a hostile or uncomfortable workplace, encompassing physical, sexual, verbal, or online harassment. It is the responsibility of every individual to promptly report any incidents of bullying or harassment, and we are committed to providing a secure reporting environment without fear of retaliation. Harassment encompasses various forms, such as racial slurs, comments on sexual preferences, bullying, derogatory comments, and threatening behavior. This policy applies universally within our organization, regardless of individuals' roles or work locations.

Reports of  any form of discrimination, bullying, or harassment will be treated confidentially. Reports of discrimination, bullying, or harassment should be made to the Compliance Manager at kateryna@givecorporation.com or the Compliance Hotline at (800) 913-0163 or the CCO at loraine@givecorporation.com.

Violence Workplace

Give has a zero-tolerance policy for workplace violence. Any form of violence, threat, or harassment will be taken seriously and addressed promptly. Violations of this policy may lead to disciplinary action, up to and including termination of employment, and may also result in legal action. Workplace violence includes, but is not limited to, the following behaviors:

• Verbal threats or abuse: Using threatening language, shouting, or making intimidating gestures.
• Physical violence: Acts of physical aggression such as hitting, shoving, or throwing objects.
• Harassment or bullying: Persistent or severe actions intended to harm, intimidate, or coerce an individual, including cyberbullying.
• Threatening behavior: Actions that cause a reasonable person to fear for their safety, such as stalking or menacing gestures.
• Domestic violence: Incidents of violence involving an employee and their partner that can impact the workplace environment.

Mitigation Measures

Give fosters open communications and reporting of workplace violence. Report immediately to your manager or the Compliance Manager at kateryna@givecorporation.com or the Compliance Hotline at (800) 913-0163 or the CCO at loraine@givecorporation.com. In cases of immediate danger, call an emergency number, e.g., 911.

Investigation and Response

Upon receiving a report of workplace violence, Give will:

• Take Immediate Action: Evaluate the situation to ensure the safety of all employees, including the potential need for security measures or law enforcement intervention.
• Conduct a Thorough Investigation: The Compliance team or a designated team will investigate the incident promptly and confidentially, interviewing all involved parties and witnesses.
• Maintain Confidentiality: All reports and investigations will be handled discreetly, with information shared only on a need-to-know basis.
• Implement Corrective Actions: Based on the findings, appropriate actions will be taken, which may include mediation, disciplinary action, or referral to external resources.

Drug Free Workplace

A Drug-Free Workplace maintains a safe, healthy, and productive work environment by prohibiting the use of drugs and alcohol. The purpose of the Drug-Free Workplace Policy is to promote a safe, healthy, and productive work environment at Give. This policy aims to ensure that employees are not under the influence of drugs or alcohol while at work, thereby protecting the well-being of all staff and maintaining the organization’s integrity and performance standards. This policy applies to all employees, contractors, and temporary workers of Give, including those on company premises, offsite locations, and during work-related events, travel, or activities. This covers the use, possession, sale, or distribution of illegal drugs, controlled substances, and alcohol.

Prohibited Conduct

The following activities are strictly prohibited:

• Use, Possession, or Distribution: Being under the influence, using, possessing, distributing, selling, or manufacturing illegal drugs or controlled substances on company premises or while performing work duties.
• Alcohol Use: Consuming or being under the influence of alcohol during work hours, on company property, or at offsite work events, except when authorized for special company-sponsored events.
• Prescription Drugs: Misusing prescription medications or using them without a valid prescription. Each person must ensure that any prescribed medication does not impair their ability to perform their job safely.

Exceptions

The following exceptions may apply:

• Authorized Events: Alcohol consumption may be allowed at certain company-sponsored events, provided it is approved by management and consumed responsibly. Each person is expected to maintain professional behavior during such events.
• Prescribed Medication: Each person using prescribed medication that may affect their job performance or safety must inform their supervisor or Compliance. Give will work to accommodate such cases, in compliance with privacy regulations.

Office and Remote Work Guidelines

GiveCorporation provides the flexibility of remote work as part of work-life balance for our personnel. Everyone must adhere to the following expectations:

• Availability: Everyone must be available during their designated work hours and reachable via phone, email, or messaging platforms.
• Productivity: Everyone is expected to maintain the same level of productivity and quality of work when working remotely  as when working in the office.
• Communication: Regular check-ins with managers or teams must be maintained. This includes attending scheduled meetings and responding promptly to communication.
• Confidentiality and Data Security: Everyone must take all necessary precautions to protect company data and ensure confidentiality while working remotely. This includes using secure Wi-Fi networks, password-protected devices, and any additional cybersecurity measures required by the company.
• Work Environment: Everyone should establish a workspace conducive to productivity, free from distractions and equipped with the tools needed to perform their job effectively.

Conflict of Interest

Everyone is expected to act in the best interests of the company at all times. A conflict of interest occurs when someone’s personal, financial, or other outside interests interfere, or appear to interfere, with their ability to make impartial decisions or act in the best interest of GiveCorporation.

Managing Conflicts of Interest

If a conflict of interest is identified, GiveCorporation will work with the colleague to manage or eliminate the conflict. This may include:

• Removing the colleague  from decision-making processes related to the conflict.
• Requiring the colleague  to divest financial interests or cease outside activities that create the conflict.
• Termination of contracts or relationships with vendors or third parties that create a conflict of interest.

Gifts and Entertainment

Employees should avoid accepting gifts, favors, or entertainment from vendors, clients, or other business partners if it might influence, or appear to influence, their decisions on behalf of the company. Small, nominal gifts may be acceptable if they do not exceed a reasonable value (e.g., promotional items), but anything substantial must be disclosed and approved by HR or a supervisor.

Responsibilities

Responsibilities Of Employees

At Give, we hold our employees to the highest standards, expecting them to consistently exercise good judgment and act in strict accordance with our Code, company policies, and legal requirements to ensure unwavering compliance. The guidance provided in our Code and company policies equips you with the information needed to perform your duties ethically and responsibly while maintaining full compliance with the law.

As a valued member of our team, you are entrusted with the following expectations:

• Familiarize yourself with the Code and policies established by Give;
• Gain a comprehensive understanding of the relevant laws applicable to your role;
• Demonstrate unwavering honesty in all internal and external business dealings;
• Exercise sound judgment, consistently prioritizing the best interests of Give;
• Proactively seek guidance whenever questions or concerns arise;
• Report any suspected violations of the Code, company policies, or applicable laws;
• Foster an environment of open communication, free from the fear of retaliation.

Leadership Responsibilities

The Leadership carries additional responsibilities, serving as exemplars of ethical conduct. They lead by example, demonstrating an unwavering commitment to acting with integrity daily and fostering an environment where employees feel at ease seeking assistance and raising concerns.

The Leadership is tasked with promptly addressing suspected violations of the Code, Company policies, or the law. In the event of an employee reporting such concerns, the Leadership is obligated to be responsive, taking appropriate action and seeking assistance when necessary.

Our objective is to cultivate an environment that encourages all individuals to report concerns in good faith, free from the apprehension of retaliation.

As a member of the Leadership, you are entrusted with the following expectations:

1. Be an exemplary leader and cultivate an ethical culture

• Exemplify the highest ethical standards and consistently demonstrate quality work, setting a benchmark for those under your leadership.
• Foster an environment where team members feel at ease raising questions or concerns.
• Prohibit the creation or tolerance of an atmosphere where team members feel pressured to compromise on ethical standards.
• Dedicate efforts to innovation and market competitiveness, serving as a model for your team while reinforcing the unequivocal adherence to our Code, Company policies, and the law.

2. Listen and address issues

• Actively listen to team members, responding in a manner that instills a sense of security and encourages open communication about their concerns.
• Proactively take measures to prevent potential issues before they arise.

3. Prevent retaliation

• Uphold a zero-tolerance stance against retaliatory behavior.
• Ensure that employees reporting violations are safeguarded from any reprisals, fostering a culture where individuals can come forward without fear of retaliation.

Safeguarding Confidentiality and Cybersecurity

Confidential and Proprietary Information

In the course of conducting business, our team members often encounter confidential or proprietary information related to the Company, our clients, prospective clients, or other third parties. The success of our business and the preservation of our reputation hinge on the unwavering commitment of each individual to safeguarding this information. It is imperative to uphold the confidentiality of entrusted information, which includes strict adherence to information barrier procedures relevant to your business area. The only exception to maintaining confidentiality is when disclosure is duly authorized or legally mandated.

Confidential or proprietary information encompasses, among other things, any non-public details about the Company (including its businesses, financial performance, results, or prospects) and any non-public information provided by a third party with the understanding that the information will be held in confidence and used solely for the intended business purpose for which it was conveyed

Our intellectual property encompasses trademarks, brands, logos, copyrights, inventions, patents, and trade secrets. It is essential to recognize that any work you generate during your tenure with Give may be deemed intellectual property owned by the company.

Privacy

Our customers place their trust in us by sharing personal data, and it is our responsibility to uphold their privacy with the utmost diligence. Recognizing and respecting our customers' right to privacy, we adhere to stringent standards.

The collection, access, use, storage, transfer, and sharing of our customers' information are conducted solely for legitimate business purposes and consistently in alignment with our privacy and information security policies, as well as applicable laws.

For those in roles involving access to our customers' personal data, which may include contact details, financial account information, or transaction data, it is imperative to implement appropriate measures to secure such information. Unauthorized sharing of customer personal data, whether with external or internal parties lacking a legitimate business need, is strictly prohibited.

Employee Information

We are committed to upholding the responsibility of safeguarding the confidentiality of employee personal data, preventing any improper access, use, or disclosure. Give adheres to privacy and information security policies, as well as applicable laws, in the collection, utilization, storage, transfer, and sharing of employee personal data. Access to Give personnel records is restricted to authorized company employees and specific third-party vendors with valid work-related reasons.

All information related to the employment or employment history of any employee or former employee is treated as confidential, used solely for relevant and appropriate business purposes. Such information is not to be shared with individuals, whether internal or external to Give, who do not possess a business need to know.

Unless compelled by a legal or other obligation, Give typically refrains from furnishing detailed information about its employees to third parties for reference checks or employment verification purposes.

Training

Training helps employees succeed. Training also helps protect the organization because employees know the expectations. Employees and vendors are required to complete required and assigned training. Consequences of non-compliance with training include disciplinary action up to termination.

Cybersecurity

Give recognizes the crucial role of cybersecurity in protecting both our Company and our customers' information. Give's cybersecurity standards are crafted to ensure the confidentiality, integrity, and availability of our information systems. As we develop and enhance products, cybersecurity is seamlessly integrated into the design process.

Integrity and Ethical Conduct

Personal Conflicts of Interest

A personal conflict of interest arises when your individual interests inappropriately clash with the interests of the Company. Engaging in actions or relationships that create personal conflicts of interest is strictly prohibited, unless explicitly approved by the Company.

It is crucial that you thoroughly evaluate whether any of your activities or relationships, including those outside the Company, could potentially lead to a conflict or create the appearance of a conflict with the Company's interests.

Furthermore, personal gain or advantage should never take precedence over your obligations to the Company. You must refrain from using or attempting to use your position within the Company to gain any improper personal benefits, which includes seeking loans, guarantees of obligations, or gifts from any person or entity, for yourself, family member(s), or any other individual or group.

Bribery and corruption

Give strictly prohibits the act of bribing government officials, including employees of State-Owned Enterprises. Under no circumstances does Give engage in the payment of bribes or offer anything of value to gain an improper advantage. This encompasses refraining from providing payments or any valuable item with the intent to:

• Secure or retain business;
• Obtain a license or permit;
• Influence legislative or regulatory decisions;
• Influence outcomes related to customs, tax, or other administrative matters;
• Evade the enforcement of applicable laws for the Company; or
• Attain any form of business advantage.

The information contained herein is intended to provide a general overview of the Company’s policies and procedures relating to compliance with this Policy and does not constitute legal advice or a complete description of the laws and regulations relating to this Policy. The Company has made every effort to ensure the accuracy and completeness of this Policy.  This document is intended to provide guidance to employees of Company on how to comply with applicable laws and regulations related to this Policy. Employees should consult with the Legal or Compliance Department if they have any questions about the Policy or how to comply with it. Company reserves the right to modify or update this Policy at any time without notice. Employees are responsible for reviewing the Policy on a regular basis to ensure that they are aware of any changes. This Policy applies to all employees of Company, regardless of their position or location unless stated otherwise in the Policy. Employees are responsible for complying with the Policy and for reporting any suspected violations to their respective supervisor, the Legal Department, CCO or respective recipient of such violation as outlined in this Policy.