Notabene Code of Conduct

Message from CEO & CO-Founder, Pelle Braendgaard.

Our commitment to ethical behavior and the solid ethical foundations are one of the most essential components of our operations at Notabene. We are committed to doing business, building software and managing our customers’ data the right way, based on a culture of ethics and compliance. As a testament to this commitment, we have introduced these principles from early on into our operating values as a business.

In the long term, we can successfully face the challenges of a competitive market environment by accepting the imperatives of moral responsibility, both as individuals and as a company. In performing the job duties at Notabene, the employees should always act lawfully, ethically and in the best interests of Notabene and society.

Thank you for upholding our values and helping us do things right. It does not only mean that we provide well-built, innovative and of exceptional quality products and services, but it also means that ethics and integrity are always kept in mind.

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Purpose and scope

The primary goal of Notabene’s Code of Conduct is to serve as our ethical commitment and as a guide to proper business conduct for all of our stakeholders. We, at Notabene, are committed to doing business legally, ethically and in a transparent manner.

This document applies to all staff who work for Notabene (including officers, directors, managers, team leaders, employees, temporary, agency, interim, sub-contractor or consultant staff), and also includes other organizations who do business with us.

Notabene expects its staff to be impartial and honest in all affairs relating to their job. All staff bear a responsibility, in general, to be of good faith and do nothing to destroy the trust necessary for employment.

The success of our business is based on the trust we earn from our employees, customers and investors. We gain credibility by adhering to our commitment to fairness and reaching our goals solely through ethical conduct. All staff are expected to adhere to this Code in their professional, as well as personal conduct, treat everyone with respect, honesty and fairness.

Notabene is open to any questions at any time and will not allow punishment or retaliation against anyone for reporting misconduct in good faith.

Managers and leaders have a higher responsibility for demonstrating, also through their actions, the importance of this Code. Managers and leaders are responsible for promptly addressing every raised ethical question or concern. Employees must cooperate in investigations of potential or alleged misconduct.

Non-compliance with this Code is considered as misconduct that could warrant disciplinary action, including termination of employment or other contract in deserving cases.

We are committed to making efforts to apply our values and norms also throughout the entire business and stakeholders.

Notabene will foster inclusive, collaborative, and safe working conditions. As such, we are committed to providing a friendly, safe, and welcoming environment for all staff, regardless of gender, sexual orientation, ability, ethnicity, socioeconomic status, and religion (or lack thereof).

This Code of Conduct also applies to unacceptable behavior occurring outside the scope of business activities when such behavior has the potential to adversely affect the safety and well-being of Notabene staff and clients.

This Code of Conduct outlines our expectations for all Notabene staff, as well as the consequences for unacceptable behavior.

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Culture & citizenship

A supplemental goal of this Code of Conduct is to increase open citizenship by encouraging participants to recognize the relationships between our actions and their effects within Notabene culture.

• Be welcoming. We strive to be a company that welcomes and supports people of all backgrounds and identities. This includes, but is not limited to members of any race, ethnicity, culture, national origin, color, immigration status, social and economic class, educational level, sexual orientation, gender identity and expression, age, size, family status, political belief, religion, and mental and physical ability.
• Be considerate. Your work at Notabene will be used by other people, and you in turn will depend on the work of others. Any decision you take will affect users and colleagues, and you should take those consequences into account when making decisions.
• Be respectful. Not all of us will agree all the time, but disagreement is no excuse for poor behavior and poor manners. We might all experience some frustration now and then, but we cannot allow that frustration to turn into a personal attack. It’s important to remember that a company where people feel uncomfortable or threatened is neither productive nor pleasant. Notabene staff should always be respectful when dealing with other personnel as well as with people outside of Notabene employment.
• Compliance with laws and regulations. Our commitment to integrity begins with complying with laws, rules and regulations. We understand and comply with the legal requirements and commercial practices of lawful business. We are committed to adhere to every valid and binding contractual agreement that we conclude, and we do not abuse our rights. Our staff must follow applicable laws and regulations, including this Code of Conduct at all times and must ensure compliant operations.

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Acceptable and expected behavior

The following behaviors are expected and requested of all Notabene staff:

• Participate in an authentic and active way. In doing so, you contribute to the health and longevity of Notabene.
• Exercise consideration and respect in your speech and actions at all times.
• Attempt collaboration before conflict.
• Refrain from demeaning, discriminatory, or harassing behavior and speech.
• Be mindful of your surroundings and of your fellow participants. Alert Notabene leaders if you notice a dangerous situation, someone in distress, or violations of this Code of Conduct, even if they seem inconsequential.
• Remember that Notabene events may be shared with members of the public and Notabene customers; please be respectful to all patrons of these locations at all times.

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Unacceptable behavior

The following behaviors are considered harassment and are unacceptable within our community:

• Violence, threats of violence, or violent language directed against another person.
• Sexist, racist, homophobic, transphobic, ableist, or otherwise discriminatory jokes and language.
• Posting or displaying sexually explicit or violent material.
• Posting or threatening to post other people’s personally identifying information ("doxing").
• Personal insults, particularly those related to gender, sexual orientation, race, religion, or disability.
• Inappropriate photography or recording.
• Inappropriate physical contact. You should have someone’s consent before touching them in any manner.
• Unwelcome sexual attention. This includes sexualized comments or jokes; inappropriate touching, groping, and unwelcome sexual advances.
• Deliberate intimidation, stalking, or following (online or in person).
• Advocating for, or encouraging, any of the above behavior.
• Repeated harassment of others. In general, if someone asks you to stop, then stop.
• Other conduct which could reasonably be considered inappropriate in a professional setting.

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Human Rights

We are committed to respecting human dignity and the rights of each individual and community with whom we interact during the course of our work. We shall not, in any way, cause or contribute to the violation of human rights. Our staff shall treat everybody with dignity, respect, and care and uphold human rights.

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Fair Labor Practices and Working Conditions

We are committed to promoting equality in our employment practices and to fair employment and remuneration policy in compliance with applicable laws. We are firmly opposed to employing or contracting child labor, slave labor, or any form of forced or compulsory or bonded labor. We condemn all forms of illegal, unfair, unethical labor practice that exploits the workforce, destroys social security, or serves as tax evasion, including but not limited to undeclared and “gray” work or withholding wages. Our staff shall act with integrity and treat their colleagues and others they work with full respect.

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Discrimination and Harassment

We provide equal opportunity in employment and we do not tolerate any discrimination or harassment of any type from abuse. No direct or indirect discrimination shall take place based on any professionally non-relevant trait or circumstance, like gender, marital status, age, national or social or ethnic origin, color, religion and political opinion, disability, sexual orientation, employee representation, property, birth, or other status. Any kind of discriminatory behavior, harassment, bullying, or victimization is prohibited. All staff are expected to follow the highest standards of conduct in all verbal and written communication based on mutual respect, and must refrain from any form of harassment, slander, or any behavior that could be taken as offensive, intimidating, humiliating, malicious, or insulting.

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Health, Safety, and Environment

We provide clean, safe, and healthy work conditions and are dedicated to maintaining a healthy environment. We are committed to minimizing the impact on the natural environment of our operations. We make efforts to reduce the use of finite resources, like energy or water, and harmful emissions, like waste. All staff must follow and comply with every relevant health, safety, and environmental protection law, regulation, and rule at all times.

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Fair Competition and Business Conduct

Our relationships with business partners are built upon trust and mutual benefits compliant with competition law. We are dedicated to ethical and fair competition, selling products and services based on their quality, functionality, and competitive pricing. We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors. We will not offer or solicit improper payments or gratuities, nor will we engage or assist in unlawful boycotts of particular customers. We commit to comply with all applicable trade controls, restrictions, sanctions, and import-export embargoes.

We do not allow any violation of the fairness of any tendering process in any way. We refrain from damaging competition and the reputation of any business partners and from any behavior that harms competitors' credibility.

We do not withhold maliciously, unlawfully, or unduly payments toward our partners.

Our staff is responsible for ensuring fair business during their job and adhering to every competition, consumer protection, and fair marketing rule. Customers and business partners shall be treated fairly and equally. Products and services shall be displayed in a manner that is fair and accurate (fair marketing and advertising) and that discloses all relevant information.

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Anti-Bribery and Corruption

We firmly condemn and do not tolerate all forms of corruption. It is prohibited directly or indirectly offering, promising, giving, asking, soliciting, or accepting any unfair advantage or benefit, in order to obtain, retain, or facilitate in any way the business. An unfair advantage or benefit may include cash, any cash equivalent (e.g., voucher), gift, credit, discount, travel, personal advantage, accommodation, or services. We do not permit facilitation (or “grease”) payments to government officials or private businesses in order to secure or speed up routine actions. Corruption also covers the misuse of function or position when someone makes the false appearance that they improperly influence a decision-maker.

Corruption to either obtain or retain business, or to obtain or retain an advantage in the conduct of business is considered gross misconduct. Similarly, accepting or allowing another person to accept a bribe is considered gross misconduct. Our staff has to account for all benefits received in the course of doing business and must not give or receive bribes or otherwise act corruptly.

We shall avoid any actions that create a perception that favorable treatment was sought, received, or given in exchange for personal benefits.

Business courtesies or benefits include gifts, gratuities, meals, refreshments, entertainment, or other advantages from persons or companies with whom we do or may do business. We will neither give nor accept such benefits that constitute, or could reasonably be perceived as constituting, unfair business inducements that would violate law, regulation, or policies, or would cause embarrassment. Our staff may never use personal funds or resources to do something that cannot be done with our resources.

We may accept and offer occasional gifts and hospitality that are customary and conform to reasonable ethical practices of the market, provided that they are not inappropriately excessive, not frequent, do not reflect a pattern of frequent acceptance, and do not create the appearance of an attempt to influence business decisions. Only trivial gifts with low value can be accepted. All other gifts must be politely refused or, if received through post, returned to the donor. If return is not possible, it shall be offered for charity or community purposes. It is the responsibility of the person offering, providing, receiving, or accepting the gift to decide whether the gift is appropriate.

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Security, Protection, and Proper Use of Company Assets

We are responsible for the security, protection, and economic use of company resources. Our resources, including time, material, equipment, and information, are provided for legitimate business use only. Occasional personal use is permissible as long as it is lawful, does not affect job performance, or disrupt workplace morale.

All staff are obliged to follow our security policies and treat company property, whether material or intangible, with respect and should not misuse company assets or use them carelessly.

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Confidentiality, Information Security, Proprietary Information, and Intellectual Property

We are committed to business information confidentiality, integrity, and accessibility. We implement proper technical security measures, and it is our staff’s obligation to uphold this. Proprietary information includes all non-public information that might be harmful to the company or its customers or business partners if disclosed to unauthorized parties. All staff must handle any such information as secret. It also covers that no one is entitled to trade with securities while in possession of non-public information or deliver non-public information to others that could have an impact on the securities. Every rule ensuring information security must be followed at all times.

We respect the property rights of others. We will not acquire or seek to acquire trade secrets or other proprietary or confidential information by improper means. We will not engage in unauthorized use, copying, distribution, or alteration of software or other protected intellectual property.

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Bookkeeping, Reporting, and Financial Integrity

Our books, records, accounts, and financial statements must be maintained in appropriate detail, and must truly and properly reflect our transactions. We condemn all forms of money laundering and commit to doing business with partners involved in legitimate business activities with funds derived from legitimate sources.

We commit ourselves to fair taxation and to avoid all tax evasion practices, including failing to issue receipts or accounting fake expense invoices.

All staff must follow accounting procedures, ensure that business transactions are recorded and documented appropriately, and make certain that all disclosures made in financial reports are full, honest, accurate, timely, and understandable. All staff must not improperly influence, manipulate, or mislead any audit.

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Anti-Fraud

Fraud—the act or intent to cheat, steal, deceive, or lie—is both unethical and, in most cases, criminal. Fraud in every form (including submitting false expense reports, forging or altering financial documents or certifications, misappropriation of assets, or misusing company property; making any untrue financial or non-financial entry on records or statements) is prohibited.

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Conflict of Interests

Our decisions shall be based on objective and fair assessments, avoiding the possibility of any improper influence. A "conflict of interest" exists when an employee's personal interest (which can be linked to, e.g., friends, family, or customer, competitor, supplier, contractor entity, as well) interferes or potentially interferes with the best interests of Notabene. Determining whether a conflict of interest exists is not always easy; thus, anyone with a conflict of interest question should seek advice from management.

Conflicts of interest could arise:

• Being employed (you or a close family member) by, or being in an economic relation with, an actual or potential customer, competitor, supplier, or contractor.
• Hiring or supervising family members or closely related persons.
• Serving as a board member for another company or organization.
• Owning or having a substantial interest in a customer, competitor, supplier, or contractor.
• Having a personal interest, financial interest, or potential personal gain in any company transaction.

If co-workers become involved in personal relations with each other, the onus is on the senior employee concerned to bring this to the attention of his or her manager to confirm that there is no conflict of interest, nor will a conflict of interest arise.

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Privacy, Personal Data Protection

We respect people’s privacy and acknowledge customers, employees, and other natural persons’ need to feel confident that their personal data is processed appropriately and for a legitimate business purpose. We are committed to complying with all personal data protection laws. We only acquire and keep personal information that is necessary, and we give proper information on these activities to data owners. We implement proper security measures to ensure the confidentiality, integrity, and availability of personal information.

Our staff must observe the legal requirements, apply compliant practices, and follow related procedures as specified in our company policies to ensure the legality of personal data handling and processing activities.

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Weapons Policy

No weapons will be allowed at Notabene events, office locations, or in other spaces covered by the scope of this Code of Conduct. Weapons include, but are not limited to, guns, explosives (including fireworks), and large knives such as those used for hunting or display, as well as any other item used for the purpose of causing injury or harm to others.

Anyone seen in possession of one of these items will be asked to leave immediately and will be subject to punitive action up to and including termination and involvement of law enforcement authorities. Notabene staff are further expected to comply with all state and local laws on this matter.

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Consequences of Unacceptable Behavior

Unacceptable behavior from any Notabene staff, including those with decision-making authority, will not be tolerated.

Anyone asked to stop unacceptable behavior is expected to comply immediately.

If a staff member engages in unacceptable behavior, Notabene leadership may take any action deemed appropriate, up to and including suspension or termination.

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Reporting Violations

If you are subject to or witness unacceptable behavior, or have any other concerns, please notify an appropriate member of Notabene leadership as soon as possible.

It is a violation of this policy to retaliate against any person making a complaint of Unacceptable Behavior or against any person participating in the investigation of (including testifying as a witness to) any such allegation. Any retaliation or intimidation may be subject to punitive action up to and including termination.

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Disciplinary Action

Employees who violate this policy may face disciplinary consequences in proportion to their violation. Notabene management will determine how serious an employee’s offense is and take the appropriate action.

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Responsibility

It is the CEO's responsibility to ensure this policy is followed.

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Credits

Policy created from the following Open Source Codes of Conduct text and guidance:

• Django Code of Conduct: https://www.djangoproject.com/conduct/
• Contributor Covenant: https://www.contributor-covenant.org/version/1/4/code-of-conduct
• Citizen Code of Conduct: http://citizencodeofconduct.org
• Open Source Code of Conduct: https://opensource.guide/code-of-conduct/

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