InklusivComm's
Code of Ethics

Our Code of Ethics

By collaborating with InklusivComm, you are hereby agreeing to the following code of ethics and business conduct.

Build Trust and Credibility

The success of our business is dependent on the trust and confidence we earn from our partners, customers, and stakeholders. We gain credibility by adhering to our commitments, displaying honesty and integrity, and reaching company goals solely through honorable conduct. It is easy to say what we must do, but the proof is in our actions. Ultimately, we will be judged on what we do.

When considering any action, it is wise to ask: will this build trust and credibility for InklusivComm? Will it help create a working environment in which InklusivComm can succeed over the long term? Is the commitment I am making one I can follow through with? The only way we will maximize trust and credibility is by answering “yes” to those questions, and by working every day to build our trust and credibility.

Respect for the Individual

We all deserve to work in an environment where we are treated with dignity and respect. InklusivComm is committed to creating such an environment because it brings out the full potential in each of us, which, in turn, contributes directly to our business success. We cannot afford to let anyone’s talents go to waste.

InklusivComm is committed to providing a workplace that is free of discrimination of all types and from abusive, offensive, or harassing behavior. Any team member who feels harassed or discriminated against should report the incident to their manager.

All InklusivComm team members and partners are also expected to support an inclusive workplace by adhering to the following conduct standards:

• Treat others with dignity and respect at all times.
• Address and report inappropriate behavior and comments that are discriminatory, harassing, abusive, offensive or unwelcome.
• Foster teamwork and participation, encouraging the representation of different perspectives.
• Seek out insights from people with different experiences, perspectives, and backgrounds.
• Avoid slang or idioms that might not translate across cultures.
• Support flexible work arrangements for co-workers with different needs, abilities and/or obligations.
• Confront the decisions or behaviors of others that are based on conscious or unconscious biases.
• Be open-minded and listen when given constructive feedback regarding others’ perception of your conduct.

InklusivComm will not tolerate discrimination, harassment or any behavior or language that is abusive, offensive or unwelcome.

Create a Culture of Open and Honest Communication

At InklusivComm, everyone should feel comfortable to speak their mind, particularly with respect to ethics concerns. We all have a responsibility to create an open and supportive environment where everyone feels comfortable raising such questions. We all benefit tremendously when everyone exercises their power to prevent mistakes or wrongdoing by asking the right questions at the right times.

InklusivComm will investigate all reported instances of questionable or unethical behavior. In every instance where improper behavior is found to have occurred, the company will take appropriate action. We will not tolerate retaliation against anyone who raises genuine ethics concerns in good faith.

Team members and partners are encouraged to address such issues with their managers as most problems can be resolved swiftly.

Set Tone at the Top

Management has the added responsibility for demonstrating, through their actions, the importance of this Code. In any business, ethical behavior does not simply happen; it is the product of clear and direct communication of behavioral expectations, modeled from the top and demonstrated by example. Again, ultimately, our actions are what matters.

To make our Code work, managers must be responsible for promptly addressing ethical questions or concerns raised by any partner and for taking the appropriate steps to deal with such issues. Managers should not consider a person’s ethics concerns as threats or challenges to their authority, but rather as another encouraged form of business communication. At InklusivComm, we want the ethics dialogue to become a natural part of daily work.

Uphold the Law

InklusivComm’s commitment to integrity begins with complying with laws, rules, and regulations where we do business. Further, each of us must have an understanding of the company policies, laws, rules, and regulations that apply to our specific roles. If we are unsure of whether a contemplated action is permitted by law or InklusivComm policy, we should seek advice from resource experts. We are all collectively responsible for preventing violations of law and for speaking up if we see possible violations.

Competition – We are dedicated to ethical, fair, and vigorous competition. We will sell InklusivComm products and services based on their merit, superior 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 in connection with the purchase of goods or services for InklusivComm or the sales of its products or services, nor will we engage or assist in unlawful boycotts of particular customers.

Proprietary Information – It is important that we respect the property rights of others. We will not acquire or seek to acquire improper means of a competitor’s trade secrets or other proprietary or confidential information. Nor will we engage in unauthorized use, copying, distribution, or alteration of software or other intellectual property.

Selective Disclosure – We will not selectively disclose (whether in one-on-one or small discussions, meetings, presentations, proposals, or otherwise) any material nonpublic information with respect to InklusivComm, its securities, business operations, plans, financial condition, results of operations or any development plan. We should be particularly vigilant when making presentations or proposals to customers to ensure that our presentations do not contain material nonpublic information.

Avoid Conflicts of Interest

Conflicts of Interest – We must avoid any relationship or activity that might impair, or even appear to impair, our ability to make objective and fair decisions when performing our jobs. At times, we may be faced with situations where the business actions we take on behalf of InklusivComm may conflict with our own personal or family interests. We owe a duty to InklusivComm to advance its legitimate interests when the opportunity to do so arises. We must never use InklusivComm property or information for personal gain or personally take for ourselves any opportunity that is discovered through our position with InklusivComm.

Here are some other ways in which conflicts of interest could arise:

• Being employed (you or a close family member) by, or acting as a consultant to, a competitor or potential competitor, supplier or contractor, regardless of the nature of the employment, while you are working with InklusivComm.
• Hiring or supervising family members or closely related persons.
• Serving as a board member for an outside commercial company or organization.
• Owning or having a substantial interest in a competitor, supplier, or contractor.
• Having a personal interest, financial interest, or potential gain in any InklusivComm transaction.
• Placing company business with a firm owned or controlled by an InklusivComm team member, partner, or their family.
• Accepting gifts, discounts, favors, or services from a customer/potential customer, competitor or supplier, unless equally available to all InklusivComm team members and partners.

Determining whether a conflict of interest exists is not always easy to do. Team members and partners with a conflict of interest question should seek advice from management. Before engaging in any activity, transaction, or relationship that might give rise to a conflict of interest, team members and partners must seek review from their managers.

Gifts, Gratuities, and Business Courtesies – InklusivComm is committed to competing solely on the merit of our products and services. We should avoid any actions that create a perception that favorable treatment of outside entities by InklusivComm was sought, received, or given in exchange for personal business courtesies. Business courtesies include gifts, gratuities, meals, refreshments, entertainment or other benefits from persons or companies with whom InklusivComm does or may do business. We will neither give nor accept business courtesies that constitute or could reasonably be perceived as constituting, unfair business inducements that would violate law, regulation or policies of InklusivComm or its customers or would cause embarrassment or reflect negatively on InklusivComm’s reputation.

Accepting Business Courtesies – Most business courtesies offered to us in the course of our employment are offered because of our positions at InklusivComm. We should not feel any entitlement to accept and keep a business courtesy. Although we may not use our position at InklusivComm to obtain business courtesies, and we must never ask for them, we may accept unsolicited business courtesies that promote successful working relationships and goodwill with the firms that InklusivComm maintains or may establish a business relationship with.

Anyone who awards contracts or who can influence the allocation of business, who creates specifications that result in the placement of business, or who participates in contracts negotiations must be particularly careful to avoid actions that create the appearance of favoritism, or that may adversely affect the company’s reputation for impartiality and fair dealing. The prudent course is to refuse a courtesy from a supplier when InklusivComm is involved in choosing or reconfirming a supplier or under circumstances that would create an impression that offering courtesies are the way to obtain InklusivComm business.

Meals, Refreshments, and Entertainment – We may accept occasional meals, refreshments, entertainment, and similar business courtesies that are shared with the person who has offered to pay for the meal or entertainment, provided that:

• They are not inappropriately lavish or excessive.
• The courtesies are not frequent and do not reflect a pattern of frequent acceptance of courtesies from the same person or entity.
• The courtesy does not create the appearance of an attempt to influence business decisions, such as accepting courtesies or entertainment from a supplier whose contract is expiring in the near future.
• The team member or partner accepting the business courtesy would not feel uncomfortable discussing the courtesy with his or her manager or co-worker or having the courtesies known by the public.

Gifts – Team members may accept unsolicited gifts, other than money, that conform to the reasonable ethical practices of the marketplace, including:

• Flowers, fruit baskets, and other modest presents that commemorate a special occasion.
• Gifts of nominal value, such as calendars, pens, mugs, caps, and t-shirts (or other novelty, advertising, or promotional items).

Generally, team members and partners may not accept compensation, honoraria, or money of any amount from entities with whom InklusivComm does or may do business. Tangible gifts (including tickets to a sporting or entertainment event) that have a market value greater than $100 may not be accepted unless approval is obtained from management. Team members with questions about accepting business courtesies should talk to their managers.

Offering Business Courtesies – Any team member who offers a business courtesy must assure that it cannot reasonably be interpreted as an attempt to gain an unfair business advantage or otherwise reflect negatively upon InklusivComm. A team member may never use personal funds or resources to do something that cannot be done with InklusivComm resources. Accounting for business courtesies must be done in accordance with approved company procedures.

Other than to our government customers, for whom special rules apply, we may provide nonmonetary gifts (i.e., company logo apparel or similar promotional items) to our customers. Further, management may approve other courtesies, including meals, refreshments, or entertainment of reasonable value, provided that:

• The practice does not violate any law or regulation or the standards of conduct of the recipient’s organization.
• The business courtesy is consistent with industry practice, is infrequent in nature, and is not lavish.
• The business courtesy is properly reflected on the books and records of InklusivComm.

Set Metrics and Report Results Accurately

Accurate Public Disclosures – We will make certain that all disclosures made in financial reports and public documents are full, fair, accurate, timely, and understandable. This obligation applies to all team members and partners, including all financial executives, with any responsibility for the preparation of such reports, including drafting, reviewing, and signing or certifying the information contained therein. No business goal of any kind is ever an excuse for misrepresenting facts or falsifying records.

Team members and partners should inform Executive Management if they learn that information in any filing or public communication was untrue or misleading at the time it was made or if subsequent information would affect a similar future filing or public communication.

Corporate Recordkeeping – We create, retain and dispose of our company records as part of our normal course of business in compliance with all InklusivComm policies and guidelines, as well as all regulatory and legal requirements.

All corporate records must be true, accurate and complete, and company data must be promptly and accurately entered in our books in accordance with InklusivComm’s and other applicable accounting principles.

We must not improperly influence, manipulate or mislead any unauthorized audit, nor interfere with any auditor engaged to perform an internal independent audit of InklusivComm books, records, processes or internal controls.

Promote Substance Over Form

At times, we are all faced with decisions we would rather not have to make and issues we would prefer to avoid. Sometimes, we hope that if we avoid confronting a problem, it will simply go away.

At InklusivComm, we must have the courage to tackle the tough decisions and make difficult choices, secure in the knowledge that InklusivComm is committed to doing the right thing. At times this will mean doing more than simply what the law requires. Merely because we can pursue a course of action does not mean we should do so.

Although InklusivComm’s guiding principles cannot address every issue or provide answers to every dilemma, they can define the spirit in which we intend to do business and should guide us in our daily conduct.

Accountability – Each of us is responsible for knowing and adhering to the values and standards set forth in this Code and for raising questions if we are uncertain about company policy. If we are concerned whether the standards are being met or are aware of violations of the Code, we must contact the HR department.

InklusivComm takes seriously the standards set forth in the Code, and violations are cause for disciplinary action up to and including termination of collaboration.

Be Loyal

Confidential and Proprietary Information – Integral to InklusivComm’s business success is our protection of confidential company information, as well as nonpublic information entrusted to us by team members and partners, customers, and other business partners. Confidential and proprietary information includes such things as pricing and financial data, customer names/addresses, or nonpublic information about other companies, including current or potential suppliers and vendors. We will not disclose confidential and nonpublic information without a valid business purpose and proper authorization.

Use of Company Resources – Company resources, including time, material, equipment and information, are provided for company business use. Nonetheless, occasional personal use is permissible as long as it does not affect job performance or cause a disruption to the workplace.

team members and partners and those who represent InklusivComm are trusted to behave responsibly and use good judgment to conserve company resources. Managers are responsible for the resources assigned to their departments and are empowered to resolve issues concerning their proper use.

Generally, we will not use company equipment such as computers in the conduct of an outside business or in support of any religious, political, or other outside daily activity, except for company-requested support to nonprofit organizations. We will not solicit contributions nor distribute non-work-related materials during work hours.

In order to protect the interests of the InklusivComm network and our fellow team members and partners, InklusivComm reserves the right to monitor or review all data and information contained on a team member’s or partner’s company-issued computer or electronic device, the use of the Internet or InklusivComm’s intranet. We will not tolerate the use of company resources to create, access, store, print, solicit or send any materials that are harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate.

Questions about the proper use of company resources should be directed to your manager.

Media Inquiries

InklusivComm is a high-profile company in our community, and from time to time, team members and partners may be approached by reporters and other members of the media. In order to ensure that we speak with one voice and provide accurate information about the company, we should direct all media inquiries to the founder (Denis Boudreau). Likewise, no one may issue a press release without first consulting with Denis Boudreau.

Do the Right Thing

Several key questions can help identify situations that may be unethical, inappropriate, or illegal. Ask yourself:

• Does what I am doing comply with the InklusivComm guiding principles, Code of Conduct, and company policies?
• Have I been asked to misrepresent information or deviate from normal procedure?
• Would I feel comfortable describing my decision at a staff meeting?
• How would it look if it made the headlines?
• Am I being loyal to my family, my company, and myself?
• What would I tell my child to do?
• Is this the right thing to do?