1.3 Code of Conduct

Purpose and Scope

This Code of Conduct outlines the companies expectations measured against the highest possible standards of ethical business conduct. Committing to the highest standards helps Sord hire great people, build great products, and attract loyal customers.

From time to time, Sord may update this Code of Conduct. This policy is guided by requirements specific to Sord including applicable laws and regulations.

We expect all Sord personnel (Team Members) to know and follow this Code of Conduct in all matters related to Sord.

Respect in the Workplace

Be careful with the words that you choose. All Team Members should respect their colleagues. Sord won’t allow any kind of discriminatory behavior, harassment, or victimization.

Sord prohibits retaliation against any Team Member who reports or participates in an investigation of a possible violation of our Code of Conduct, policies, or the law. If you believe you are being retaliated against, please contact Jonathan Gautsch, another senior manager or anonymously at [email protected].

All Sord assets should be treated with respect and care. Team Members shouldn’t misuse company assets or use them frivolously. This includes trademarks, copyright and other property (information, reports, etc.).

Safe Workplace

Sord is committed to a violence-free work environment, and we will not tolerate any level of violence or the threat of violence in the workplace. Under no circumstances should anyone bring any type of weapon to work including guns, explosives, or knives. If you become aware of a violation of this policy, you should report it to a member of management immediately. In the case of potential physical violence, contact the authorities immediately.

Workplace Visitors

Workplace safety is very important to us. As Sord receives visitors on the premises, we want to ensure that visitors are not a threat to the workplace and are not exposed to danger.

Equal Opportunity Employment

Sord is an equal opportunity employer. We thrive on diversity and are committed to creating an inclusive environment for all Team Members.

Professionalism

All employees must show integrity and professionalism in the workplace.

Job Duties and Authority

All Team Members should fulfill their job duties with integrity and respect toward customers, stakeholders and the community. Supervisors and managers must not abuse their authority.

We encourage mentorship throughout Sord.

Communication and Collaboration

All Team Members should be responsive and open for communication with their colleagues, supervisors or team members. Employees should be friendly and collaborative. They should try not to disrupt the workplace or present obstacles to their colleagues’ work.

Benefits

Sord expects employees to not abuse their employment benefits.

Compliance with Law

Team Members must comply with all applicable laws including environmental, safety and fair dealing laws. We expect everyone to be ethical and responsible during Sord business dealings.

Conflict of Interest

Conflicts of interest occur when an employee, contractor, or job applicant’s personal interests may not align with company needs or interests. We expect you to avoid any personal, financial, or other interests that might hinder your capability or willingness to perform your job duties. If you believe that a conflict may occur, please contact your manager immediately.

Types of conflicts of interest may include:

• Personal investments

• Outside employment, advisory roles, board seats, and starting your own business

• Business opportunities found through work

• Inventions

• Accepting gifts, entertainment, and other business courtesies

Internet and Social Media

Employees should never share any intellectual property or the status of any of their assignments on social media.

When representing the company, employees should always be respectful and avoid speaking in specifics about their work. Employees should never post discriminatory, offensive, or other illegal language on social media.

Exceptions

Sord business needs, local situations, laws, and regulations may occasionally call for an exception to this policy or any other Sord policy. If an exception is needed, Sord management will determine an acceptable alternative approach.

Enforcement

Any violation of this policy or any other Sord policy or procedure may result in disciplinary action, up to and including termination of employment. Sord reserves the right to notify the appropriate law enforcement authorities of any unlawful activity and to cooperate in any investigation of such activity. Sord does not consider conduct in violation of this policy to be within an employee’s or contractor’s course and scope of work.

Any employee or contractor who is requested to undertake an activity that he or she believes is in violation of this policy must provide a written or verbal complaint to his or her manager or any other manager of Sord as soon as possible.

​The disciplinary process should also be used as a deterrent to prevent employees and contractors in violating organizational security policies and procedures, and any other security breaches.

Responsibility, Review, and Audit

Sord reviews and updates its security policies and plans to maintain organizational security objectives and meet regulatory requirements at least annually. The results are shared with appropriate parties internally and findings are tracked to resolution. Any changes are communicated across the organization.

This document is maintained by Jonathan Gautsch.

This document was last updated on 03/27/2024.