Employee Code of Conduct

Our Code of Conduct

Our Pelion Code of conduct supports how we manage our business in a responsible way. It’s our guide to help us make the right decisions and preserve our reputation, while living and breathing our core beliefs – every day. Our Code applies to everyone, including all employees, directors, contractors, and agents of Pelion.

It is everyone’s obligation to uphold our Code of Conduct, and to report concerns or raise questions if and when we see behaviour that is not in line with our expectations of how we operate. Pelion encourages an open, supportive environment for raising concerns and does not permit any form of retaliation for raising an issue.

Pelion’s reputation is one of our most valuable business assets, and legal and ethical conduct at all levels is essential to our continued success.

We expect everyone to act with the highest standards of ethical behaviour in everything that we do, and in doing so, we protect Pelion’s reputation and promote integrity and trust.

Asking Questions and Resources for Assistance

There are many resources at Pelion we can contact, including:

We Follow the Law

We take responsibility for our impact and always act with integrity. We make sure that we understand and follow all applicable laws, rules and regulations. We also support and inspire each other by encouraging everyone to follow the rules and act with integrity. When we have questions about an applicable law, rule or regulation, or wish to report any practice that raises questions, we speak up and contact any of the resources detailed in our Code, including those listed in the We Speak Up section below.

Persons involved in any misconduct will be subject to discipline. Further, if criminal activity has taken place, the matter will be reported to the appropriate authorities.

We Speak Up

We do the right thing and stick with it, even when it is difficult. We will sometimes find ourselves in situations that are difficult, complex or confusing.

When Do We Speak Up?

We should ask questions and report concerns whenever appropriate, but some specific examples when you might want to seek help include:

Our first line of support is our managers. Managers keep an open-door policy and are the primary resource for answering questions and providing support. Seek out their help when you have questions.

We all must be familiar with all applicable company policies. We have several other resources to ask questions or report concerns including People Team

Or you may use two secure and trusted options via the Whistleblowing Helpline to report concerns confidentially and anonymously where allowed by local law:

When you contact these resources, your reports will be treated with confidentiality to the extent possible, and the company will properly and promptly address any questions or issues you report.

When we make a report, ask a question or participate in any investigation, we can do so without fear of retaliation. Pelion has a zero-tolerance policy for any retaliation. If you feel you have been retaliated against, or are aware of possible acts of retaliation, you should immediately contact the People Team.

What Happens After We Speak Up?

We Respect Each Other

Making trust our default position means that we do not engage in any form of physical or verbal harassment. We must treat one another with respect and consider how fellow employees might feel. Empathy allows us to recognize potential issues and avoid situations where our core beliefs are not guiding our behaviour.

‘Harassment’ is unwelcome behaviour that creates a hostile or offensive work environment. Examples of harassment include unwanted sexual advances, offensive comments or jokes, or threats of any kind.

We must report any situation involving harassment immediately to our Manager, the People Team or any other resource we are comfortable with. We have many resources available to help and if we ever feel that something is wrong, or feel the need to speak out, we should do so. You may always contact People Team with concerns.

We Support Diversity and Inclusion (D&I)

Diversity and inclusion (D&I) plays a big role in building a thriving community. We stand for a workplace that is inclusive by default—where every idea is assessed on merit and without any bias. Pelion welcomes different perspectives and values all perspectives equally. We want to take advantage of our collective brilliance and, therefore, D&I at Pelion is at the heart of everything that we do and permeates at every level and in all places. By providing opportunities for everyone to be heard and understood, we are open to new ideas and we leverage these differences to make the biggest impact. We do not make employment-related decisions nor discriminate based on any legally protected class or status.

Safe Working Environments

We take responsibility for safety and the environment, and we make sure we are aware of, and in compliance with, all applicable health and safety laws and regulations, as well as all health, safety and security notices. We recognize that safety cannot be compromised. For more information please review our Health and Safety Policy. Our Health and Safety Policy details our accident and near miss reporting system and the roles each of us has in establishing and maintaining a safe and healthy environment. If you have any questions, contact People Team.

We also are committed to the highest standards for the environment and avoid adverse impacts to the environment and communities where we conduct our business.

We do not possess illegal drugs or abuse alcohol at company facilities or Pelion sponsored events, nor do we work under the influence of illegal drugs or alcohol. Further, we do not possess firearms or any offensive weapon while working.

We report any injury or accident at work as described in our Health and Safety Policy.

We Avoid Conflicts of Interest

Our commitment to make the Pelion community thrive and to do so collectively means we never put our own financial interests above our duty to Pelion and each other. Even the mere appearance of a conflict of interest can be damaging.

A ‘conflict of interest’ is when an employee has a competing interest that interferes with the interests of our company. Conflicts arise when we use our role at the company, or information to which we have access, to personally benefit from business or opportunities.

Conflicts can arise in many situations including but not limited to: outside employment with a competitor, customer or supplier; accepting improper benefits or opportunities such as gifts, loans or investment opportunities; competing against the company for the purchase or sale of products, services, property or other interests; or directing contracting opportunities and other transactions to yourself or those related to you.

We do not take for ourselves business opportunities that arise from the use of company property, information or our position with Pelion. We simply do not compete with our company or ever attempt to take opportunities meant for Pelion.

From time to time Pelion employees may be asked to serve on a board of a different organization. While these opportunities can help both us and our company progress and improve, we must make sure such positions do not cause a conflict and that we have received the proper approval and followed all Pelion procedures before we accept.

Additionally, a conflict is potentially created when you embark on a relationship with someone at work or if you work with members of your family or extended family. When a personal or family relationship may impact our decision-making or hiring, or might lead to the appearance of a conflict of interest, we should come forward and contact the People Team. You must declare personal or family relationships during the hiring process and be sure to discuss any relationships that could be seen as conflict of interest or having ethical implications with your manager or the People Team.

We avoid even the mere appearance that we are not committed to our company’s interests. Should you have any questions or need to report potential conflicts, you should contact the People Team regarding any material transaction or relationship that may violate these standards.

We Keep Data and Assets Safe

While we want to share information and collaborate effectively, we must also be mindful of keeping data and resources safe. Data that we use in our daily activities can include confidential information and proprietary company data that we should always protect from disclosure to anyone who is not explicitly authorized to access such data. Some examples of such data we much protect include:

Trade Secrets

Patent Research

Trademark & Copyright Development

Business Plan & Strategy

Research Plans

New Product Plans

Salary & Benefit Plan Data

Databases

Employee & Medical Data

Customer Data & Specification

Supplier Data

Pricing Information

Financial Data

Costs

Technical Data

Design Information

IT System Details & Software

Technical Drawings

Marketing Strategies

Bid Information

We must protect our systems and networks and avoid unauthorized access to our systems, networks and other electronic resources. We take care not to reveal any passwords or accidentally allow access to any of these resources.

While our business requires that we work with and share information, we must keep security of our valuable data in mind. We have specific procedures for sharing and handling our information that each of us should be familiar with, as detailed in our Information Security Policy. If you have any questions or need to report an information security issue, please contact the Security Team.

We must all take responsibility for our impact, which means using our company resources with care and doing our best to avoid loss, theft and misuse of company assets such as equipment, supplies, electronic resources (including hardware and software), vehicles and facilities. We use our company assets to make an impact and further Pelion’s goals, never for our own purposes or for the purposes of other organizations or individuals.

If we feel there might be an issue, or need to report any loss, theft or misuse of company assets, we contact our Security Team.

We Protect Personal Data

We respect our fellow employees and contractors and their right to privacy and data protection by keeping personal information and data private. Completing our work may require that personal data, including private health data, be collected, processed and stored. When that is the case, we only provide access to those who have a specific business purpose and have been provided authorization.

We have strict policies on how we obtain, record, hold, use, disclose and destroy personal data. If you have any questions, please contact the Legal Team.

We Manage Our Data with Care

Taking responsibility and having integrity means that we accurately and completely record all data. We have a duty to provide our stakeholders with correct and complete information in a timely manner. Our records should always accurately reflect our business activities and include accurate accounting, financial controls, internal reporting and taxation records.

We have a strict policy on how we obtain, record, hold, use, disclose and destroy personal data. Please refer to We Protect Personal Data in our Code for further information.

We only keep data for as long as we need it, for the purpose we collected it, and we will protect it from unauthorized access while we keep it. Please refer to We Keep Data and Assets Safe in our Code for further information.

We all must follow the applicable policies and procedures for preparing our records. If you are aware of any inaccurate or incomplete record, or have any questions about data management, you should contact our Security Team or the Legal Team.

We Deal Fairly

We lead globally from within, not above, and all of us take responsibility for our company. That means that we all must deal honestly and fairly with all third parties when we are representing Pelion. Whether it’s our customers, our suppliers, our competitors or the public, we act with integrity and fairness. We do not take advantage through manipulation, concealment, misrepresentation or any unfair practice. Our continued ethical reputation depends on all of us competing with better products and services in an ethical manner.

We Protect Our Partners’ Data and Property

Just as we protect Pelion’s data and assets, we must also protect data, intellectual property and any other assets belonging to our partners and other third parties. We never disclose any non-public data (including personal data regarding partner employees) to any other third party except as authorized by our partner. Data is shared only with those who need to know.

We Give and Receive Hospitality, Entertainment and Gifts Responsibly

Our passion for progress must be balanced by operating ethically and fairly. Offering, giving or receiving gifts to or from our partners, customers and suppliers is a common part of business practice. Giving and receiving modest hospitality, entertainment or gifts is not against our policy as long as the hospitality, entertainment or gift is not meant to improperly influence us, our partner or our customer and is reasonable and proportionate to the circumstances of the relationship. Generally, there should be a clear business purpose and the hospitality, entertainment or gift should be infrequent.

We have a clear bar on offering, giving or receiving hospitality, entertainment and gifts over 200 GBP in value unless approved by a manager.

Any hospitality, entertainment and gifts involving a foreign public official are not permitted except with prior approval.

If you have any questions or concerns, you should consult the People Team before giving or receiving any hospitality, entertainment or gifts.

Doing Business with the Government

Doing Business with the Government is not always the same as doing business with private parties. Activities that might be appropriate when working with private sector customers may be improper—or even illegal— when a national or local government is our customer. For example, business courtesies or entertainment that might be acceptable when dealing with private parties— like paying for meals or drinks—may not be appropriate when working with government officials. In addition, due to complex legal requirements, some types of bid-related information, which might be proper in a transaction with a private party, may not be requested or received when dealing with governments or their officials. When conducting business with government officials, it is each person’s responsibility to know and comply with all applicable laws, rules, and regulations. Any hospitality, entertainment and gifts involving a foreign public official are not permitted except with prior approval.

We Do Not Misuse Information for Personal Financial Gain

We never buy or sell the stock of any company, including our parent company, its other subsidiaries or our business partners, while in possession of material, non-public information—known as ‘inside information’—about the company in question. We never ‘tip’ others nor share inside information in casual conversations, as the misuse of inside information is a serious and potentially illegal matter, even if we do not intend for ourselves or others to profit from it.

Inside information is information of a precise nature about a company and/or its listed securities that is not generally available but which would, if made generally available, be likely to have a significant effect on the price of a company’s securities.

We Help Prevent Money Laundering

When dealing with our customers and other partners, we must be aware of the signs of money laundering and make sure we do not aid covering up the source of illicit or illegal funds through our legitimate business.

Money laundering is the attempt to hide the source of illicit or illegal funds through transactions that appear to be legitimate. We should watch for requests to:

While conducting business with a customer, supplier or any business partner, should you notice something strange or become concerned about any transactions, you should immediately report such concerns to the Finance Team.

We Communicate Responsibly

As we continue to push forward with our passion for progress and promote our company and our mission, there are certain reminders to keep at the forefront. If contacted by an outside analyst or a member of the media, we refer those requests immediately to the People Team.

We should not make any external statements about our company’s performance, initiatives or any other internal matter to any investors or others, and instead direct them to the People Team.

Many of us like to participate in online communities, blogs, forums and social media networks. Done in a smart way, participating in social media will help us cement our position as a technical and thought leader. Please lead with common sense—do not post any business-related, confidential, undisclosed financial or internal-use-only information obtained or learned as part of Pelion job duties.

Keep in mind what is shared is public and often permanent. If we have any questions, we can email the social media team or review our Public Relations and Social Media Policy.
Some good guidelines for posting or contributing online include:

Working with Suppliers and Other Partners Responsibly

We expect all suppliers and other partners we work with to share our commitment to integrity by following the law, our Supplier Code of Conduct, all applicable policies, and by acting in an ethical manner. We also treat our suppliers and other partners fairly and keep our commitments to these partners. We work with our suppliers and partners to ensure quality and value for our customers.

Additionally, we require that our suppliers and partners exhibit our same commitment to fundamental standards for employment, health and safety, the environment, confidential and proprietary information and our fundamental ethical values.

We Do Not Bribe

We lead globally by example. The decisions that each of us make can have a significant impact. Bribery and corruption are serious international issues and there are many laws, including the UK Bribery Act and the U.S. Foreign Corrupt Practices Act, that prohibit corrupt conduct and create offenses with serious penalties for both companies and individuals who break those laws.

We do not offer, give, accept or agree to accept bribes under any circumstances, nor do we tolerate anyone acting on behalf of Pelion engaging in such behaviour.

Specifically, we never offer, promise or provide anything of value to anyone, whether commercial partners or public officials, to secure any advantage, obtain or keep customer business or influence any commercial decisions. Neither do we accept or demand anything of value to influence our decision-making on behalf of Pelion.

‘Anything of value’ is very broad and can include cash, cash equivalents (gift cards), gifts, favours, food, entertainment and opportunities.

When contemplating any of these actions, you should consult our Anti-Bribery and Corruption Policy. Make sure you are complying with our policy and procedures and seek assistance by contacting the People Team with any questions or concerns you might have.
If you are aware of any potential instance of bribery, no matter how small, you should report these concerns to the People Team immediately.

We Follow Trade and Sanction Rules

We have many important pieces of intellectual property and tangible goods that we use in our business daily. Moving these items around the world means paying close attention to our obligation to comply with all applicable export and sanctions laws and regulations. There are many laws that govern exports in the United States, United Kingdom, Europe and worldwide.
It is important to realize that an ‘export’ is not always obvious. An export can include cross-border sharing of technical information, services, technology or goods not only electronically and physically, but also verbally or by simply handing it off to a person (colleague, customer, or partner) who may not be able to receive it without export authorization.

When we develop proposed technologies and products, they must be classified for export control prior to any cross border sharing, export or release of the technology. Classification is key to determining whether export licenses are required or other restrictions apply. We must seek assistance early in the development cycle, before sharing and before any potential violation of our policy or the law.

Compliance with export rules is a shared responsibility. These rules apply whenever anyone is working with or accessing technical information, services, technology or goods. We must not share anything without first ensuring we are adhering to such rules. For further guidance, contact the Legal Team. Violations of export rules can have serious consequences. If you believe or suspect a potential breach of our policy or the law, you must report your concerns to the Legal Team.

We Compete Fairly and Ethically

In order to maintain our reputation for trust, we must avoid any behaviours or business practices that are, or even appear to be, anti-competitive. We compete with passion and vigour, and we recognize that competition leads to innovation and better products and services for our customers. Competition law violations carry significant fines and sanctions, and we cannot afford the damage a violation can bring both our company and the individuals involved.

For these reasons, we must never agree with competitors to fix prices, share markets or customers, rig bids in the context of a tender or engage in anticompetitive practices. If you have questions about these activities, please contact the Legal Team.

When we meet with competitors, we must be vigilant that our discussions remain on legitimate topics and that we do not share competitively sensitive information. If you ever have a concern that inappropriate discussions are taking place at a meeting, state your objection clearly, make sure it is reflected in the minutes and leave the meeting if the inappropriate discussion doesn’t stop; and when back in the office, report any issue or concern immediately to the Legal Team.

Competitively sensitive information is information that we would not normally share with competitors, such as, but not limited to:

Competition laws can be complex, and we should always ask questions and report concerns to the Legal Team if we are unsure about any issue or incident.

We Keep Accurate Tax Records

We always accurately document our tax obligations and comply with all required procedures to ensure any possible gaps or issues are prevented or quickly resolved. We are committed at all levels of Pelion to ensure proper care in monitoring and communicating these responsibilities to all concerned.

Additionally, we must avoid transactions where goods, intellectual property or funds are transferred outside of a normal, documented contractual relationship and not properly recorded in our records. We are committed to and take reasonable steps in preventing persons associated with us from engaging in criminal facilitation of tax evasion. Our management fosters a culture in which activity intended to facilitate tax evasion is never acceptable. If you believe or suspect a potential breach of our policy or the law, you must report these concerns to the Finance Team immediately.

We Respect Human Rights

A key to what connects us is the idea that we only succeed when we all succeed. We do not thrive at the expense of others. This means we keep human rights and fair labour practices in mind when we operate our business and expect the same of our suppliers and partners. Specifically, we do not support, whether directly or indirectly, slavery or trafficking in any form.

Employees are never forced to work, nor forced to work hours in excess of local law, and we never employ child labour. If you have any questions about this subject, please contact the Legal Team.