Supplier Code of Conduct

Datachoice Solutions Limited t/a Geckoboard (“Geckoboard”) are committed to operating in an ethical and fair way. We expect suppliers and other business partners with whom we do business to act with the same high standards. In that regard, suppliers, business partners and other third-parties (“Suppliers”) must fully comply with this Supplier Code of Conduct (“Code”) and educate their employees and subcontractors so they understand and comply with this Code when doing business with or for Geckoboard.

The Code should be viewed as the minimum standards that we expect from our supplier community. It is not intended to reduce, replace or limit any other legal or contractual obligations that you have to Geckoboard.

Our Policy can be summarized as Conduct Business with integrity. Specifically, Suppliers must:

BE TRANSPARENT

Avoid giving the appearance of or engaging in actual conflicts of interests. Suppliers or their representatives must not deal directly with any Geckoboard staff member whose spouse, domestic partner, or other family member or relative is employed by or holds a significant financial interest in the Supplier (other than publicly traded securities). Suppliers must disclose any such relationship or other actual or potential conflict of interest to their Geckoboard business contact for review as soon as the conflict becomes known.

NOT GIVE GIFTS TO INFLUENCE GECKOBOARD

Respect Geckoboard’s Anti-Bribery and Anti-Corruption Policy. Do not offer, provide or solicit gifts or entertainment that might compromise or appear to compromise a Geckoboard staff member’s judgment or independence. That includes:

• Gifts individually or cumulatively valued at more than £40 in any one year;
• Any gift or charitable contribution solicited by a staff member;
• Entertainment that is lavish or that takes place in a location inconsistent with Geckoboard’s values; and
• Entertainment or gifts offered in close proximity to a significant business decision involving the Supplier.

If a Geckoboard staff member asks for any of the above, you must report it to suppliers@geckoboard.com.

BE ETHICAL

Never attempt to improperly influence Geckoboard business decisions. Never offer a bribe, kickback, bartering arrangement, change in terms outside of the contractual relationship, or other incentive to a Geckoboard staff member in order to obtain or retain Geckoboard business or preferential treatment.

BE SMART

Use and manage Geckoboard assets responsibly. Protect and responsibly use both the physical and non-physical assets of Geckoboard including property, supplies, consumables, equipment, information and other intellectual property when authorized by Geckoboard to use such assets. This includes:

• Using Geckoboard information technology and systems (including e-mail) only for authorized Geckoboard business purposes.
• Complying with Geckoboard requirements regarding password protection, confidentiality, and security.
• Respecting the intellectual property rights of Geckoboard and others, including but not limited to patents, copyrights, trademarks, and trade secrets.
• Respecting authorization limits. Suppliers must understand what they are and are not authorized to do on behalf of Geckoboard. Do not speak to the media about Geckoboard or on Geckoboard’s behalf unless expressly authorized in writing to do so by an authorized Geckoboard staff member.
• Avoid insider trading. Do not buy or sell the stock of Geckoboard or another company when in possession of information about Geckoboard or another company that is not available to the investing public and that could influence an investor’s decision to buy or sell stock.
• Respect end-user privacy. Maintain privacy and security policies that meet or exceed all applicable legal and regulatory requirements and that comply with Geckoboard’s privacy and confidentiality practices, including Geckoboard’s privacy policy available at geckoboard.com.

BE HUMAN. BE SAFE

Suppliers must share Geckoboard’s commitment to human rights and equal opportunity in the workplace and must conduct their employment practices in full compliance with all applicable laws and regulations. All Suppliers must:

• Conduct their activities in conformance with Geckoboard’s commitment to a workplace free of harassment and unlawful discrimination;
• Respect Geckoboard’s Anti-Slavery and Human Trafficking Policy, complying with international ethical standards, which include producing goods lawfully, without exploiting the people who made them and in decent working conditions;
• Comply with applicable safety and health laws, regulations and practices;
• Prohibit the use, possession, distribution, or sale of illegal drugs while on Geckoboard owned or leased property;
• Prohibit carrying or transporting handguns, firearms or other legally controlled or prohibited weapons of any kind that are not required for job performance on Geckoboard leased or owned property.

This Code does not confer any rights to any third-parties. In addition, no employees of any Supplier will have any rights against Geckoboard by virtue of this Code, nor will such employees have any rights to cause Geckoboard to enforce any provisions of this Code. We encourage open discussion. If you have questions or concerns about this Code or your business relationship with us, please raise them with your primary Geckoboard contact. In addition, Suppliers are strongly encouraged to raise any concerns or report suspected misconduct to Geckoboard through suppliers@geckoboard.com.