Code of Conduct Policy of Zappix, Inc.

This Code of Conduct (the “Code”) of Zappix, Inc. (the “Company” or “Zappix”) outlines requirements for how we conduct business at Zappix and around the world. It also helps us understand how our values impact the way we do business. Legal, ethical, and socially responsible choices and actions are fundamental to our values, and this Code defines the standards in meeting those goals.

This Code has been adopted by our Board of Directors (the “Board”) and applies to every director, officer, employee, and independent contractor of Zappix. Although Zappix operates in many countries around the world and our colleagues are citizens of nations with varying laws, regulations, and customs, Zappix’s commitment to conducting business according to the highest standards of ethical conduct applies across national boundaries. Therefore, all Zappix employees, directors, and officers are required to read and comply with this Code. In addition, other persons performing services for Zappix may be subject to this Code by agreement. This Code is not a contract of employment and it does not convey any specific employment rights or guarantee employment for a specific time. Zappix reserves the right in its sole discretion to modify or eliminate any of the contents of this Code without prior notice.

To summarize the code in one sentence:

Doing the right thing is more important than winning while risking our reputation or the trust of our customers, partners, and friends.

The Code is intended to be a very practical guide to handling situations that arise at Zappix. The Code is not intended to and cannot address every situation or issue that you might encounter here. Inevitably there will be questions about how to apply and interpret the Code. Please read on for the ways you can get answers to questions about the Code or other situations at Zappix. The Code is interpreted on a case-by-case basis, and every set of facts and circumstances is unique.

Every person can make a big difference, so it is vital to act with integrity and in accordance with local laws. Zappix requires its global employees, independent contractors, consultants, and others who do business with Zappix to comply with all applicable laws, rules and regulations when performing work.

It is always important to do the right thing. Referring to this Code and following Company policies, applicable laws, rules and regulations at all times will help enable you to make the right choices. However, if you ever have questions or concerns about a section of this Code, a Company policy, a law, rule, or regulation, you should contact Zappix’s legal team (“Legal”).
Above all, this Code helps employees maintain the trust Zappix has built with its customers, employees, and others who have a stake in the Company’s success. That trust is what helps Zappix succeed every day.

Code Certification

Depending on your position at Zappix, we may ask you to certify your knowledge of various facts each quarter, or on another periodic basis. Zappix relies on certifications to record transactions, make legal and accounting determinations, and comply with laws. If you do not provide a certification or completely, honestly, and accurately complete a certification, you may be in violation of this Code. This might result in disciplinary action, which may include termination of your employment.

Waiver of Code Provisions

It is rare for anyone to be exempted from any part of this Code, regardless of seniority or position. Waivers may only be granted in a manner permitted by law, with review and approval by the Board or a committee of the Board, with public disclosure of any waiver to the extent required by applicable regulations.

Diversity and Non-Discrimination

Zappix is committed to the principles of equal employment. We are committed to complying with all applicable laws providing equal employment opportunities, and all other applicable employment laws and regulations. In compliance with those laws and ordinances, it is our intent to maintain a work environment free from unlawful discrimination and harassment against employees, applicants for employment, individuals providing services in the workplace pursuant to a contract, unpaid interns and volunteers, based on their actual or perceived race, religious creed, national origin, ancestry, physical or mental ability, medical condition, genetic information, marital status (including registered domestic partnership status), sex (including pregnancy, childbirth, lactation and related medical conditions), gender (including gender identity and expression), age, sexual orientation, AIDs/HIV status, weight and height, military and veteran status and any other consideration protected by law (collectively referred to as “protected characteristics”).

Zappix is dedicated to the fulfillment of this policy regarding all aspects of employment, including but not limited to recruiting, hiring, placement, transfer, training, promotion, rates of pay, and other compensation, termination, and all other terms, conditions, and privileges of employment. We will not tolerate discrimination or harassment based upon these protected characteristics or any other characteristic protected by applicable law.

Prevention of Involuntary Labor and Human Trafficking

Zappix and the companies with which it does business shall ensure that all work is voluntary. Zappix is vehemently opposed to the trafficking of persons or use of any form of slave, forced, bonded, indentured, or prison labor. Involuntary labor includes the transportation, harboring, recruitment, transfer, receipt, or employment of persons by means of threat, force, coercion, abduction, fraud, or payments to any person having control over another person for the purpose of exploitation.

Workplace Health and Safety

Zappix is committed to providing the safest work environment possible. Our programs focus on general safety awareness and incident response. Follow all safety rules and report unsafe situations.

Criminal Activity/Arrests

Your safety is important to Zappix. As a result, employee involvement in criminal activity during employment, whether on or off Company property, may result in disciplinary action including suspension or termination of employment, subject to the requirements of applicable law. Disciplinary action depends upon a review of all factors involved, including whether or not the employee’s action was work-related, the nature of the act, or circumstances that adversely affect attendance or performance. Any disciplinary action taken will be based on information reasonably available. This information may come from witnesses, police, or any other source as long as management has reason to view the source as credible. Disciplinary actions taken by Zappix will not depend upon the disposition of any case in court.

Alcohol Use/Distribution/Possession/Impairment

Reporting to work or performing work while impaired as a result of alcohol consumption is prohibited. Lawful off-duty alcohol use, while generally not prohibited by this policy, must be moderate and reasonable and must not interfere with an employee’s job performance. Please be especially mindful of this during Company-sponsored parties and events.

Standards of Conduct

We want to ensure that Zappix is a place where workers can thrive. In order to assure the safety and security of our people and provide the best possible work environment, we expect workers to follow basic, common-sense rules of conduct that will protect everyone’s interests. It is not possible to list all the forms of behavior that are considered unacceptable in the workplace, but we have provided the following examples of prohibited conduct to assist you:

  • Falsification of employment records, employment information or other records;
  • Recording the work time of another employee, allowing any employee to record another employee’s work time, or allowing falsification of any time record, whether yours or another employee’s;
  • Theft or the deliberate or careless damage of any Company property or the property of any employee or customer;
  • Use of Company materials, supplies, tools or products for personal reasons without prior permission from Company management;
  • Abuse of Zappix’s electronic resources (as more fully explained in the “Using Company, Funds, Assets, and Technology Appropriately” Policy);
  • Possessing, distributing, selling, transferring or using or being under the influence of illegal drugs in the workplace;
  • Use of alcohol in a matter which violates the “Alcohol Use/Distribution/Possession/Impairment” Policy;
  • Provoking a physical fight or engaging in physical fighting during working hours or on premises occupied by Zappix;
  • Carrying firearms, weapons or dangerous substances at any time, on premises owned or occupied by Zappix;
  • Using abusive, violent, or threatening language at any time during working hours or while on premises owned or occupied by Zappix;
  • Failing to observe working schedules, including meal and rest breaks;
  • Violating any safety, health or security policy, rule or procedure of Zappix; and
  • Committing a fraudulent act or intentional breach of trust under any circumstances.

    Although employees and/or Zappix may choose to end their employment relationship at any time and for any reason, without following any formal system of discipline or warning, we may exercise discretion to utilize forms of discipline that are less severe than separation for conduct violations. Examples of less severe forms of discipline include verbal warnings, written warnings, demotions and suspensions. Although one or more of these forms of discipline may be taken, no formal order or procedures are necessary. Zappix reserves the right to determine which type of disciplinary action to issue in response to any type of performance issue or rule violation.

Business Practices

Recognizing Conflicts of Interest

A conflict of interest is a situation where an opportunity for personal gain may be contrary to the Company’s best interests.
Avoid even the appearance of a potential conflict of interest. If you believe that you may have a potential conflict of interest, discuss it with your manager right away. Your manager and Legal can help you work out a way to manage the conflict. Remember, it is your responsibility to act appropriately until the situation has been addressed.

Question: Can you give an example of conflicts of interest or potential divided loyalty?
Answer: Your niece needs a summer internship and you decide to hire her into your department, or your brother-inlaw owns a business that is being considered as a vendor for Zappix, and you are one of the decision makers.

Working with Family Members and Others with Whom you have a Personal Relationship

Zappix believes that a work environment where employees maintain clear boundaries between their personal and business interactions is most effective for conducting business and enhancing productivity. Notably, this policy does not prevent the development of friendships or romantic relationships between co-workers. However, it does establish boundaries as to how intimate and family relationships are conducted during working hours and within the work environment.

A familial or intimate relationship among employees can—under certain circumstances— create an actual or at least potential or perceived conflict of interest in the employment setting, especially where one relative, spouse, partner, or member of such a relationship supervises another relative, spouse, partner, or member. We will not take any adverse employment action against any employee for engaging in intimate relationships during non-working hours away from Company premises. However, we will consider such intimate relationships when they affect an employee’s job performance, occur during working time or on Company premises, or pose a danger of a conflict of interest; familial relationships will receive the same consideration.

Thus, Zappix employees are not permitted to report to someone who is a family member, or someone with whom they are intimately involved. If two employees marry, become related, or enter into an intimate relationship, they may not remain in a reporting relationship or in positions where one individual may affect the compensation or other terms or conditions of employment of the other individual. Zappix will attempt to identify other available positions. If no reasonable alternative position is available or satisfactory to both Zappix and the employees, one employee may be required to resign.

In other cases where a conflict or the danger of a conflict arises, even if there is no supervisory relationship involved, the parties may be separated from employment or reassigned, at the discretion of Zappix. To further avoid any conflicts of interest, Zappix may refuse to hire or place a relative or other intimately associated individual in a position where the potential for favoritism or a conflict exists. All Zappix employees in a romantic, sexual, or familial relationship with another Zappix employee must disclose the existence of the relationship to an appropriate representative of Zappix.

For the purposes of this policy, a relative or familial relationship refers to any person who is related by blood or marriage, or whose relationship with the employee is similar to that of persons who are related by blood or marriage (e.g., parent, sibling, spouse, child, inlaw, grandparent, grandchild, step-relative, or domestic partner). An intimate relationship refers to a relationship between people who are romantically involved.

Outside Work

You are the most important resource that we have at Zappix. Your time and energy impact the value we have as an organization, and your colleagues depend on you to work as hard as they do.
You are expected to devote your full professional energies to your work at Zappix, and any outside activities cannot interfere with your job at Zappix.

Do not:

  • Use any work time, equipment, or materials for any non-Zappix job, business, or inventions. This includes using Zappix workspace, computers, Internet access, copy machines, and any other Zappix assets or services.
  • Use your position at Zappix to solicit work for your outside business or other employer, to obtain favored treatment, or to pressure others to assist you in working on your business .
  • Participate in an outside employment activity that could have an adverse effect on your ability to perform your duties at Zappix.
  • Use confidential Zappix information to benefit your other employer, outside business, or invention.
    You must inform your manager and Legal before you take on any outside employment that might cause a potential conflict.

Outside Advisory or Board Service

Zappix encourages everyone to participate in non-profit activities, consistent with our commitment to giving back to our communities.
For any non-profit activities that do not involve board membership, but that would conflict with or could conflict with Zappix’s business, Zappix employees must obtain approval from their manager and Legal.
If you have been asked to sit on the Board of Directors of such a non-profit organization, you might also need to get approval from our Board, as further explained in the adjacent example.

Question: May I serve on the board of directors of an outside enterprise or organization?
Answer: (1) Before accepting board positions at nonprofit organizations that do not relate to Zappix’s present or reasonably anticipated business, employees must obtain written permission from their manager. (2) Before accepting board positions on non-profit organizations that do relate to Zappix’s present or reasonably anticipated business, employees, employees must obtain written permission from their manager and Legal. (3) Before accepting board positions at for-profit organizations that do or do not relate to Zappix’s present or reasonably anticipated business, employees must obtain written permission from their manager and the Zappix Board. Executive Team members must obtain permission from the President or the Board before accepting such positions.

Investments and Business Interests

Many Zappix employees have investments in publicly-traded stock or privately-held businesses. In general, these are fine, but investments might give rise to a conflict of interest if you are involved in or attempt to influence transactions between Zappix and the business at issue. Financial interests that pose a potential conflict of interest require approval from your manager and our Board. If a real or apparent conflict arises, disclose the conflict to your manager.
If you, a relative, or a member of your household (including a roommate) is considering investing in a Zappix supplier, customer, or competitor, take great care to make sure that the investment does not compromise your obligations as a Zappix employee. Things to consider in determining whether there is a real or seeming conflict:

  • The size and nature of your investment;
  • Your ability to influence Zappix’s decision;
  • Your access to Zappix’s confidential information; and
  • The nature of the relationship between Zappix and the other company.

Gifts and Entertainment

This policy applies to both giving and receiving gifts or other things of value as part of your job at Zappix. Gifts are usually goods or services, but can be any item of value, including entertainment (such as tickets or invitations to concerts, sporting events, etc.). Exchanging gifts and entertainment can help build strong working relationships with customers and other business partners. In some cases, however, gifts and entertainment may create a conflict of interest or unfair bias that could influence business decisions or be seen asbribes. Employees may not give or receive gifts or entertainment to or from current or potential vendors, suppliers, customers, or other business associates unless all of the following conditions are met:

  • Customary — The item is a customary business gift and would not embarrass Zappix if publicly disclosed. Cash is never an acceptable gift. Giving or receiving cash is viewed as a bribe or kickback and is always against Zappix policy.
  • No favored treatment — The purpose of the gift is not to obtain special or favored treatment.
  • Legal — Giving or accepting the gift is legal in the location and under the circumstances where given.
  • De Minimis Value — Generally, if your gift does not involve a government official, a gift whose value is de minimis is permissible.
  • Recipient is not a government official — Never provide a gift, including meals, entertainment, or other items of value, to a U.S. or foreign government official without obtaining approval from Legal in advance. See the Relationships With Government Officials Policy below.

    Make sure you know the Company’s policies in this area.

Side Deals or Side Letters

All the terms and conditions of agreements entered into by Zappix must be formally documented. Contract terms and conditions define the key attributes of Zappix’s rights, obligations, and liabilities and can also dictate the accounting treatment given to a transaction. Making business commitments outside of the formal contracting process, through side deals, side letters, or otherwise, is unacceptable. You should not make any oral or written commitments that create a new agreement or modify an existing agreement without approval through the formal contracting process.

Question: What is an example of a side deal?
Answer: In a sales environment, a side deal may involve a special guarantee or agreement to encourage certain customers to place larger orders, such as the promise of not-yet released product functionality or better terms on a contract renewal. Such a side deal, whether written or oral, can have an impact on Zappix’s potential liability with respect to that transaction and may make it inappropriate for Zappix to recognize revenue on the products sold, affecting the accuracy of Zappix’s books and records. Side deals or side letters made outside of Zappix’s formal contracting and approvals are strictly prohibited.

Compliance With The Law

Anti-Corruption, Bribery and Kickbacks

Never resort to bribery, facilitation payments, kickbacks or other corrupt practices. There is no potential benefit that can justify damaging our integrity and reputation or the trust others place in us. All bribery is prohibited. All Zappix employees and our business partners must fully comply with the Foreign Corrupt Practices Act (“FCPA”) and other applicable laws prohibiting the bribing of public officials or individuals in the private sector (such as the U.K. Bribery Act). Even though the FCPA is a U.S. law, it applies to our actions everywhere.

  • Bribery is offering or giving something of value in order to improperly influence the recipient’s actions. Bribery is illegal in every jurisdiction in which Zappix does business and the consequences can be severe, including prison time.
  • A facilitation payment is a tip or small payment made to a government official in order to expedite a routine government action, such as issuing a permit or providing utility service. This is illegal in most jurisdictions and not allowed by Zappix.
  • A kickback is the return of a sum paid (or due to be paid) as a reward for fostering a business arrangement. Accepting or offering a kickback violates this Code.

    Please refer to the Anti-Corruption Compliance Policy for additional information.

Relationships with Government Officials

If you interact with government officials on Zappix’s behalf, be particularly careful about gifts, meals, and entertainment. Laws and regulations governing what companies can give to government officials are very strict, including in the U.S. Be sure you know what the rules are. Contact Legal before offering or providing any gifts, meals or entertainment to government officials. All interactions with government officials that are not sales-related require the oversight of Legal.

A government official is any officer or employee of a government or any department, agency, instrumentality or public international organization, or any person acting in an official capacity for or on behalf of such person. Government officials also include any: (i) officer, employee or person acting in an official capacity on behalf of a political party; (ii) a candidate for political office; (iii) an officer or employee of a state-owned or statecontrolled company, regardless of the officer’s or employee’s rank or title; (iv) uncompensated honorary officials who have influence in the award of business; (v) members of royal families; (vi) any entity hired to review or accept bids for a government agency; (vii) officials, whether elected, appointed or under a contract, permanent or temporary, who hold a legislative, administrative, or judicial position of any kind in a country or territory; (viii) any person who performs public functions in any branch of the national, local, or municipal governments of a country or territory or who exercises a public function for any public agency or public enterprise of such country or territory; and (ix) spouses and other immediate family members of any of the persons listed above.

Handling Imports and Exports

When working with international customers, keep in mind that there may be additional steps required before delivering products or services internationally. Many countries periodically impose restrictions on exports and other dealings with certain countries, persons, or groups. Export laws may control trading of commodities or technologies. Laws may cover travel to or from a sanctioned country, imports or exports, new investments, and other related topics. Certain laws also prohibit support of boycott activities.

Zappix employees are responsible for knowing and following the appropriate rules and procedures for imports and exports. If you are involved in international transactions, you must know what is expected of the Company, including any requirements related to taxes, verification, licensing and permits.

Competing Fairly

Agreements with competitors are subject to rigorous scrutiny in all countries. Competitors are expected to compete, and compete aggressively, on all terms. Agreements with our customers and suppliers can also give rise to scrutiny, particularly if Zappix has a leading position in the market. Laws prohibit agreements that would restrain trade. A few common—and illegal—examples include:

  • Price fixing, where competitors or partners agree to charge a certain price for certain products or services.
  • Bid rigging, where competitors agree among themselves to bid in a way that allows a certain bidder to win.
  • Dividing or allocating markets, where competitors agree to limit their sales presence so that each company can be the only available choice for buyers in a given market.
  • Boycotting, where competitors agree to avoid a particular customer or supplier.

    Keep in mind that agreements do not have to be signed contracts to be illegal. An informal understanding between you and a competitor, or even a conversation that implies an understanding, may be a problem. If any of these topics come up while you are talking with a competitor, stop the conversation immediately and report it to the Legal team.

Fair Dealing

Zappix is committed to being honest and truthful with all of its customers, vendors, and other business partners. Never misrepresent the quality, features or availability of our products, and never do anything illegal or unethical to win business.

Trying to obtain information by lying or pretending to be someone you are not is unethical and could be illegal. Do not do it. And if you receive another company’s confidential or proprietary information by mistake, return or destroy it. You may also reach out to the Legal team if you have questions.

Third Parties

Zappix engages with third parties such as agents, consultants, suppliers, resellers, or distributors, only after they have passed a legal due diligence process. In the course of performing your job, you might need to disclose confidential Zappix information to such third parties. Such disclosure should only occur after you ensure that there is a nondisclosure agreement (“NDA”) in place which has been approved by the Legal team.

Financial Integrity, Records and Accounting

Zappix’s books, records, accounts and financial statements must be maintained in appropriate detail so that they properly reflect the Company’s business activities. Doing so is required both by law and by the Company’s internal controls. Our financial, accounting and legal groups are responsible for procedures designed to assure properinternal and disclosure controls, and everyone must cooperate with these procedures to ensure the integrity of the Company’s books, records, accounts and financial statements.
All information must be recorded accurately, whether it is tracking work hours, expenses (including your expense reports) or sales contracts. When these are timely and accurate, we are able to make informed decisions about how to run our business and plan for the future. Our records, including disclosures and filings, must be accurate, complete and timely, so that Zappix fulfills its obligations to external stakeholders.

Document Management and Retention

When deciding which documents or data to save, archive or delete, always use good business judgment and comply with applicable Company retention policies.

You may be notified that “legal hold” has been placed on documents or data in your possession or in various locations managed by Zappix. If this happens, please review the legal hold notice carefully. If you have any questions about the notice and what you should do, please contact Legal. Importantly, never alter, conceal or destroy any documents or data subject to a legal hold.

Outside Audits and Investigations

From time to time, Zappix employees may encounter internal and external auditors, attorneys, or investigators who request information from you as authorized by Zappix. You are required to provide these individuals with timely and accurate information. Never mislead or attempt to influence any investigation, audit or inquiry.
Like every company, Zappix sometimes receives requests for information from national or local government officials. If they contact you, be sure to notify Legal for assistance in handling the request promptly, accurately and completely.

Wage and Hour Laws

Zappix is committed to following all applicable wage and hours laws and regulations. To help ensure that all work performed for us is compensated correctly, employees who are compensated on the basis of hours worked must report and record time accurately in accordance with Company procedure.

Zappix Assets, Systems, & Facilities

Company Information

Many details about how we operate need to be kept confidential in order for us to remain competitive and successful.
Employees are responsible for safeguarding all confidential and sensitive data such as:

  • Business plans and strategies
  • Financial results
  • Product designs and concepts
  • Sales goals and marketing plans
  • Terms and conditions and fees paid by customers
  • Financial data
  • Other non-public data that might be of use to competitors

Intellectual Property

Zappix depends on good ideas, so it is important to protect those ideas through legal tools such as copyrights and patents. Collectively, this intangible property is called intellectual property (“IP”), and it includes all copyrights, patents, trademarks, trade secrets, design rights, logos and brands. Keep in mind that Zappix owns the rights to all IP created with Company materials or on Company time. Please refer to your respective contractual obligations with Zappix concerning IP, including but not limited to a proprietary information and inventions agreement.

Third Parties’ and Previous Employers’ Information

In some cases, employees may be responsible for protecting information that belongs to other people or companies.

  • Third parties: In the course of doing business, sometimes employees will learn confidential information about customers, suppliers and other business partners. Protecting and keeping strictly confidential the data of these third parties is one of Zappix’s most important duties. In addition, you are not permitted to accept or use any third party’s confidential information.
  • Former employers: You are not permitted to bring any materials or information from a prior employer to Zappix. When a new team member joins Zappix, employees must respect that this person cannot share confidential information about previous employers. Similarly, you are still responsible for protecting Zappix’s information if you leave the Company.

Personal Employee Information

Personal information provided to the Company must be protected.

If your job enables you to have access to employees’ personal information (data like home addresses, medical information, Social Security numbers, compensation), you are responsible for helping to protect it and keeping it strictly confidential. That means using the information only for legitimate business purposes and never sharing it with anyone who does not have a work-related reason to see it.

Using Technology and Other Tools

We trust our employees with a wide range of technology and other tools that make it possible to do their jobs effectively, and these tools must be used wisely.

Using Company Funds, Assets, and Technology Appropriately

Any computers and other devices that Zappix provides are Company property. The same is true of our Zappix instance, our email system and Internet access. A certain amount of personal use is permitted, but Company technology should mainly be used for business purposes.
Since all of these tools and technology belong to the Company, employees should not have any expectation of privacy in their use. Zappix may monitor anything created, stored, sent or received on Company technology, to the extent allowed by law. Do not use Company technology to violate the law or Zappix policies or to create, store or send content that others might find offensive.
It is also important to carefully avoid any usage that might lead to loss or damage, such as a breach of the Company’s IT security protocols.
Company property also includes Zappix’s brand and reputation, funds, facilities and employee work time.

Question: May I occasionally use my Zappix email address for my outside business?
Answer: You may never use your Zappix email for an outside business.

Question: What if my veterinarian emails me with an update about my pet, and I need to respond utilizing work internet access.
Answer: Non-excessive use of Zappix email for personal purposes is fine.

Security: See Something, Say Something

You are Zappix’s first line of defense. If you see something suspicious, say something by reporting safety and security concerns to your manager. Suspicious network activity or emails should be reported to your manager. Reporting helps Zappix keep our people and our brand safe while defeating attacks faster to minimize or prevent damage.


External Communications

Zappix has an open and transparent culture, and our communication policies govern how we communicate to the public responsibly.

Investors and the Media

All inquiries from the media must be directed to the Public Relations Team. If you have any questions, contact Similarly, inquiries from investors or the investment community must always be directed to there.

Social Media

In general, remember that the Internet is a public place and never forgets anything, so handle yourself accordingly. Some dos and don’ts for employee include:

  • Protect Zappix’s proprietary information.

  • Do not comment on legal matters, trade secrets or disclose confidential information.

  • If you are discussing Zappix or our products, be open about the fact that you work for us.

  • Be very mindful when mentioning customers or prospects, because they may be listening and associate your comments with Zappix.

  • Be clear that your statements are your own opinion, not those of Zappix, but be mindful that people may associate what you say with Zappix because you work here.

  • Generally represent yourself well and use your best judgment at alltimes.

Speaking Events

If you are an employee, and you have been invited to speak or present at an event and are representing Zappix when you do so, you must notify the Public Relations Team before accepting and have them review and approve any materials you present or discuss. Before accepting free travel or accommodations, check that the proposed gift is within the gift rules or ask Legal for approval.


Question: If I am an employee and I make a presentation on my own time, may I accept a payment?

Answer: That depends. If you are representing Zappix, you may not accept payment. If you are on your own time and are not representing Zappix, you may be allowed to accept payment. Before accepting this type of opportunity check with your manager.


Political Activities

Zappix does not make political contributions to individual candidates or parties. However, Zappix employees are encouraged to be involved in the political activities of their choice. Zappix employees should be clear in such activities that their participation is their own choice and that the views they advocate are their own not necessarily those of Zappix.

  • Zappix has historically allowed limited political activity in internal Zappix communication, but the use of Company time, facilities or resources for personal political activities is subject to revocation if abused or if it becomes too much of a distraction for employees or the Company.

  • If you are involved in lobbying, make sure you know the rules.

  • Contact Legal if you anticipate making a large political contribution as employee, even as an individual, to ensure compliance with disclosure laws relevant to the Company.

Zappix’s workforce is a community made up of individuals with diverse beliefs and viewpoints. You should respect everyone’s opinion, especially when you disagree with it. You are not permitted to attempt to impose your personal beliefs or opinions on others.

Employees may keep their personal activities outside of Zappix confidential, but always keep in mind that you are a representative of Zappix. Your conduct can affect the perception of Zappix. You cannot have personal activities that conflict with or interfere with your job duties at Zappix.

How to Raise Questions & Report Concerns

We promote an environment that fosters honest, good faith communications about matters of conduct related to our business activities, whether that conduct occurs within Zappix, involves one of Zappix’s contractors, suppliers, consultants, or customers, or involves any other party with a business relationship to Zappix. Consistent with our commitment to ethics, compliance, and the law, we welcome your good faith questions and concerns about any conduct you believe may violate our Code, especially conduct that may be illegal, fraudulent, unethical, or retaliatory.

If you are not sure how to handle something, or if you think there is a problem, speak up! No matter how small the issue is, we want to hear from you. We cannot fix issues we do not know about.

Your Responsibilities

Zappix’s Code of Conduct and its principles apply to our global employees, independent contractors, consultants, and others who do business with Zappix. You are required to:

  • Follow the Code. Comply with Zappix’s Code of Conduct, principles, and review any applicable legal requirements with counsel.

  • Speak up. If you have knowledge of a possible violation of Zappix’s Code of Conduct or its principles, other Zappix policies, or legal or regulatory requirements, you must notify Zappix. Zappix employees may make such reports through their manager (provided their manager is not involved in the violation), Legal, or any other mechanism appropriate for such a use. Anyone (including employees, independent contractors, consultants, and others who do business with Zappix) may also report Code violations through Zappix’s Ethics Manager. Reports may be made by email ing the Ethics Manager at Please note that you may be able to submit any reports to the Ethics Manager anonymously, if the laws of your jurisdiction permit.

  • Use good judgment. Apply Zappix’s principles of business conduct, review our policies, review legal requirements, and then decide what to do.

  • Ask questions. When in doubt about how to proceed, discuss it with a Zappix manager, or Legal.

Failure to comply with Zappix’s Code of Conduct, or failure to report a violation, may result in disciplinary action up to and including termination of employment or the end of your working relationship with Zappix.

Retaliation is Not Tolerated

Zappix will not retaliate — and will not tolerate retaliation — against any individual for filing any good-faith complaint with Zappix or through the Ethics Manager, or for participating in the investigation of any such complaint.

Expectations for Zappix Managers

While this Code applies to everyone at Zappix equally, employees in a managerial role have extra responsibilities.

Most specifically, you must report matters that may indicate a violation of the Code or any other Company policy to Legal.

If you are a manager, you are in the best position to set the right tone for your team, including by doing the following:

  • Lead by example, always choosing the right course ofaction.

  • Speak up when you see a problem and encourage others to do the same.

  • Make sure your direct reports understand the Code and what is expected of them.

  • Always be receptive to questions, concerns or comments, and make sure that issues are directed to the people at Zappix who can help.

Cooperating with Investigations

Zappix will conduct investigations of all alleged or actual violations of our policies, procedures, and laws. All employees and business partners are required to cooperate with any Zappix investigation. You must take your participation in any investigation seriously. The following actions will result in disciplinary action, including possible termination of employment:

  • Failing to provide evidence when requested;

  • Providing false or misleading information in an investigation;

  • Not fully cooperating with an investigation; or

  • Not following instructions related to an investigation (for example, discussing the investigation with other employees if you are instructed not to).