LocalGlobe Code of Conduct

A. Standards of Conduct

LocalGlobe strives for a work environment that promotes respect, openness, responsibility, integrity and value for all of our employees, companies and investors. We are focused on creating an environment with shared values and behaviours:

Core Values

• We never forget that we BACK founders. The business we back is their business. Like their other team members, we are part of the support team.
• We like to be thought of as “quasi-founders” and we behave like founders i.e. with passion, honesty, enthusiasm and belief.
• We try to be easy to deal with. This means we give quick, coherent answers to questions.
• We share freely and openly.
• We do what we undertake to do i.e. we deliver.
• We are always courteous and respectful, even when we disagree. We understand that many decisions have an emotional component and we do not neglect that in any position we take.
• We aim to be super efficient, hate waste and try to use the best tools available to uphold this standard.
• We do have egos but we never allow them to get in the way of effective communication and collaboration.
• We do what we do because we genuinely love doing it, not because we think it’s the best way to “make a buck.”
• We enjoy doing things differently from the conventional.

B. Misconduct in the Workplace

While it is impossible to list every item that could be considered misconduct in the workplace, outlined below are common-sense instances of inappropriate conduct.

This policy is not intended to limit LocalGlobe’s right to discipline or discharge employees for any reason permitted by law.

General Misconduct

• Violation of the policies and procedures set forth in this document.
• Knowingly providing inaccurate, incomplete or misleading information when speaking on behalf of LocalGlobe.
• Disclosure of LocalGlobe and/or LocalGlobe portfolio company trade secrets and proprietary and confidential or commercially-sensitive information.
• Taking or destroying LocalGlobe property.

Discrimination & Harassment

Discrimination is unfair treatment of a person or persons from others. Harassment is unwanted or unwelcome words, actions, or behaviours towards a person that cause discomfort.

LocalGlobe has a strict policy against all types of workplace harassment, including sexual harassment and other forms of workplace harassment based upon an individual’s age, race, colour, physical or mental disability, gender, sexual orientation or any other status. This policy also applies with respect to LocalGlobe portfolio companies, in meetings with entrepreneurs, or at any conferences where you are representing LocalGlobe.

Examples of inappropriate conduct include:

• Harassment of anyone, whether in or out of the workplace or online;
• Statements or remarks that are derogatory or demeaning;
• Obscene or abusive language;
• Unwelcome sexual jokes, language, propositions, or advances;
• Degrading images portraying stereotypes of a person or persons;
• Material that insults an individual or individuals;
• Limiting opportunities to work on assignments, impact earnings, or career progression based on race, color, gender, age, religion, nationality, disability or sexual orientation;
• Display of sexually suggestive objects or images;
• Unwelcome comments about an individual’s body;
• Questions about sexual conduct;
• Unwelcome touching, leering, flirtation or physical contact;
• Requests for sexual favours in exchange for favourable treatment and other verbal or physical conduct of a sexual nature when:
• submission to such conduct is made either explicitly or implicitly as a term or condition of an individual’s employment and/or investment;
• submission to, or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual;
• such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile, or uncomfortable work environment.
• Retaliation for reporting or threatening to report harassment; and
• Communication via electronic media of any type that is prohibited by LocalGlobe policy.

These examples are illustrative but not exhaustive. Nothing in this policy is intended to limit employee rights.

Venture Capital-Founder Relationships

Relationships between founders and venture capitalists tend to be friendly and collegial, with business meetings often occurring in informal settings. It is important to remember that, while LocalGlobe is committed to supporting and maintaining healthy relationships with founders, romantic relationships could represent a conflict of interest in the investing process and threaten the health of the relationship between a founder and the firm. Any relationships with founders extending beyond the boundary of professional or friendship should be disclosed as a conflict of interest.

To minimise the risk of conflicts of interest and promote fairness, if an employee enters into a consensual relationship with another LocalGlobe employee or portfolio company employee, they must notify Moira Benigson.

C. Formal & Informal Resolution Processes

Problem-Solving Procedure

We strive to provide a comfortable, productive, legal and ethical work environment. To this end, we want you to bring any problems, concerns, or grievances you have about the workplace to the attention of any of the partners.

If you believe there is inappropriate conduct or activity on the part of LocalGlobe, its management, employees or any other persons or entities related to us, bring your concerns to the attention of Robin Klein at a time and place that will allow us to properly listen to your concern. We adhere to a graduated response model and understand that while there are many problems that can be resolved informally through dialogue, there should also be a formal channel for issues that require a more escalated response. In this case, Moira Benigson will be the initial point of contact and will work with you to resolve the issue.

Reporting Harassment

Any employee who feels that he or she has witnessed, or been subject to, any form of harassment should immediately notify Robin Klein.

We will promptly and thoroughly investigate, with recognition that in some instances this may require a 3rd party professional, and will take appropriate action based on the findings of the investigation. Discipline for violation of this policy may include, but is not limited to, reprimand, suspension and discharge. If we determine that harassment has occurred, corrective action will be taken to effectively end the harassment. As necessary, we may monitor any incident of harassment to ensure the inappropriate behaviour has stopped. In all cases, we will follow up as necessary to ensure there is no retaliation for making a complaint or cooperating with an investigation.

Formal action

Following a formal disciplinary hearing, employees may be issued with the following:

• A first written warning for misconduct if your conduct falls below acceptable standards. This will outline the nature of the misconduct, any change in behaviour required and the right of appeal. The warning will also explain to the individual that further disciplinary action may be taken (up to and including a final written warning) if there is repeated misconduct of a similar nature.
• A final written warning may be given to an employee if the offence is sufficiently serious, or if there is further misconduct during the timeline covered by a previous written warning. This final warning will outline the nature of the misconduct, any change in behaviour required and the right of appeal. It will also warn that any repeated misconduct of a similar nature may lead to further disciplinary action, up to and including dismissal (or some other disciplinary action) and will refer to the individual’s right of appeal.

Dismissal

If the employee has committed an act of gross misconduct, or has demonstrated a continued failure to improve conduct to an acceptable standard, the final step in the procedure may be dismissal. Dismissal decisions will be taken by a General Partner and the individual will be provided (in writing) with reasons for dismissal and the right of appeal.

LocalGlobe reserves the right to begin with or move to (or omit) any particular stage of the procedure where appropriate.

D. Resources

Reporting Contacts

• For entrepreneurs to report harassment/discrimination issues: Robin Klein, Co-Founder, robin@localglobe.vc
• External point of contact: Moira Benigson, Venture Partner, moira@thembsgroup.co.uk
• General questions related to diversity, inclusion and harassment: Suzanne Ashman, Partner, suzanne@localglobe.vc

This policy was created in collaboration with #MovingForward. #MovingForward is a volunteer-run, open-source directory for VCs. It consists of a public database of inclusion, diversity and anti-harassment policies and commitments from VCs. The initiative aims to set standards for the industry and drive positive change by making these policies available and more inclusive. Participating VCs include Andreessen Horowitz, Benchmark, First Round Capital, Greylock, Y Combinator, and over 100 others in the US. On March 8th, 2019 the initiative will launch in Europe and LocalGlobe will participate alongside Atomico, Balderton, Change Ventures, Capital 300, and Entrepreneur First.