THRIVE GLOBAL CODE OF BUSINESS CONDUCT AND ETHICS
Thrive Global Holdings, Inc. (“Thrive Global”) is committed to conducting its business in accordance with rigorous ethical standards and in compliance with legal requirements. This code guides us in our day to day interactions, both inside and outside the Company. This Code of Business Conduct and Ethics (the “Code of Conduct”) applies to all employees (including officers), consultants, vendors, business partners and members of Thrive Global’ Board of Directors and its subsidiaries. This Code of Conduct provides general guidelines on how to behave in order to promote honest and ethical conduct;
(ii) accurate and complete information in both internal and external Thrive Global communications;
(iii) compliance with applicable laws;
(iv) reporting of violations of this Code of Conduct to appropriate persons, among other goals.
1. Conflicts of Interest. Employees must not engage in any activity or have a personal interest that presents a “conflict of interest” and it is important to avoid even the appearance of a conflict of interest. A conflict of interest occurs when the employee personal interest interferes with the business interests of Thrive Global.
2. Confidentiality. Employees must maintain the confidentiality of information critical to Thrive Global business that could be of use to competitors or harmful to Thrive Global if disclosed (we refer to this as Confidential Information), except when disclosure is authorized or legally required. This obligation also applies to confidential information of our customers, suppliers, business partners, financial institutions and any other third-party partners.
3. Fair Dealing. Thrive Global makes it a priority to treat everyone fairly and requires all employees to do the same. This means employees must conduct themselves honestly and ethically when carrying out Thrive Global’ business, and to deal fairly with Thrive Global’ employees, customers, vendors and other third parties.
4. Accuracy of Books and Records. Thrive Global books, records and financial and other accounts must be kept accurately and in accordance with applicable regulations and standards and must accurately reflect the true nature of the transactions they record.
5. Discrimination and Harassment. Diversity and inclusion are important values of Thrive Global. Harassment or discrimination by any employee, director, or consultant based on race, color, creed, gender, sexual orientation, gender identity, religion, national origin, disability, familial status, or any other protected status is strictly prohibited.
6. Other Thrive Global Policies. Thrive Global has other policies that govern business conduct and you remain obligated to comply with those other policies. This Code of Conduct is meant to complement, but not replace, other Thrive Global policies. If another policy conflicts with this Code of Conduct, you should follow this Code of Conduct.
7. Questions; Reporting Violations. Thrive Global encourages you to consult the appropriate persons if you have any questions about how to comply with this Code of Conduct. If you ever think that there is violation of this Code of Conduct, you should report it to Thrive Global Hotline by submitting your question or concern
to [email protected] Thrive Global does not permit retaliation for good faith reports of actual or suspected violations of this Code of Conduct. Thrive Global takes this Code of Conduct seriously and any violation of this Code of Conduct may result in disciplinary or other action.
8. Amendment, Modification, or Waiver This Code of Conduct may be amended, modified, or waived from time to time by Thrive Global. Any amended version of this Code of Conduct will be posted with a new stated effective date.