Employee Handbook: Code of Conduct Template

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Northwind Traders

Code of Conduct

Updated January 6, 2025

Code of Conduct

CompanyNorthwind Traders

Policy OwnerPeople team

Conflicts ContactGeneral Counsel

Our Commitment

Northwind Traders (the "Company") is committed to building a workplace where every employee is treated with respect, our customers can trust us, and our decisions reflect our values. Every employee is expected to read, understand, and follow this Code. Contractors and Board members are expected to follow the parts of it that apply to their role.

Anti-Harassment

We do not tolerate harassment, discrimination, or retaliation based on race, color, religion, sex (including pregnancy, childbirth, and related medical conditions), gender identity or expression, sexual orientation, national origin, ancestry, citizenship status, age, disability, genetic information, marital status, military or veteran status, or any other characteristic protected by applicable federal, state, or local law. This summary supplements the Company's full Anti-Harassment Policy, which describes how complaints are made and investigated. Report harassment through any channel listed un

Conflicts of Interest

Promptly disclose any actual, potential, or perceived conflict of interest to General Counsel. Examples include outside employment or business activity that competes with the Company or interferes with your duties, financial interests in vendors or competitors, and gifts or entertainment of more than nominal value.

Use of Company Resources

Company property and information systems are provided for business purposes. Protect the Company's confidential business information, such as trade secrets, non-public financial results, customer data, and source code, from unauthorized access or disclosure. Confidential business information does not include information about your own wages, hours, benefits, or other working conditions.

Reporting Concerns

We rely on every employee to speak up when something looks wrong. You may raise concerns:

To your manager

To the People team at people+northwind@propper.ai

Anonymously through the Ethics Hotline at (800) 555-0142

All reports are taken seriously and investigated promptly and impartially, and are kept confidential to the extent consistent with a thorough investigation and applicable law. Retaliation against anyone who reports a concern in good faith, takes part in an investigation, or files a complaint with a government agency is prohibited and is itself a violation of this Code. If your concern involves your manager, report it to the People team or through the anonymous channel instead.

Your Rights

Nothing in this Code prohibits an employee from (a) filing a charge or complaint with, communicating with, or providing information to the Equal Employment Opportunity Commission, the National Labor Relations Board, the Securities and Exchange Commission, the Occupational Safety and Health Administration, or any other government agency, or receiving an award for information provided to a government agency; (b) discussing or disclosing wages, hours, or other terms and conditions of employment; or (c) exercising rights under Section 7 of the National Labor Relations Act. Nothing in this Code pre

Notice under the Defend Trade Secrets Act (18 U.S.C. 1833(b)). An individual shall not be held criminally or civilly liable under any federal or state trade secret law for the disclosure of a trade secret that (a) is made in confidence to a federal, state, or local government official, either directly or indirectly, or to an attorney, solely for the purpose of reporting or investigating a suspected violation of law, or (b) is made in a complaint or other document filed in a lawsuit or other proceeding, if such filing is made under seal. An individual who files a lawsuit for retaliation by an e

Employment Relationship

This Code describes what Northwind Traders expects of its people. It is not a contract of employment, does not create contractual rights, and does not promise employment for any specific period. Employment with Northwind Traders is at-will: you or the Company may end the employment relationship at any time, with or without cause or notice, except where applicable law or a written agreement signed by an authorized officer of the Company provides otherwise. The Company may revise, supplement, or rescind this Code at any time, subject to applicable law.

Acknowledgment

I have received and read this Code of Conduct and agree to follow it. I understand that violations may result in discipline, up to and including termination of employment. I also understand that this Code is not a contract of employment and does not change the at-will nature of my employment.

Employee

Taylor Brooks

Received by the People team

Morgan Yu

Head of People, Northwind Traders