Introduction

The Propel ICT Code of Conduct (the “Code”) is an important guide on how we do business and a reference to support day-to-day decision making. It details the behavior we expect our employees, directors, officers and partners to model – behavior that reflects our core values and the key operating principles of our business. Not only do these values and principles drive our behavior and decision-making, but they also

 establish the standards we expect our business partners, clients and the third parties that we deal with to follow.

 

Who Must Follow the Code

Our Code applies to all members of the Propel community. That means all employees, contractors, officers and directors of Propel must comply with its provisions. In addition, all the individuals and companies we engage as mentors, speakers, consultants or content providers to our accelerator program and the start-up companies and founders that participate in our programs must also comply with our Code and the related policies of Propel. Those who fail to abide by this Code face possible disciplinary action, up to and including removal from that community.

 

Our Core Values

There are three key values that shape the way we do business as Propel and we work to instill these values in the companies that we work with.

1. Radical Curiosity – we encourage and expect constructive insight;

2. Collective Ambition – we are driven by the greater good;

3. We are Scrappy – we are relentless and unapologetic in the pursuit of value creation.

 

 Our Key Operating Principles

Propel has five key operating principles that guide us in translating our values into operation. We conduct our business in accordance with these principles, and the workplace standards they represent, no matter where we operate.

 

1. Honesty – We only say what we believe to be true. We strive to be clear and transparent in our communications and do not intentionally omit relevant facts or information to deceive others. We foster a workplace that is open, responsible, law-abiding and accountable. We expect compliance with the rules, policies and practices we have put in place and with the laws and regulations of the geographies we operate in.

 2. Integrity – we seek to earn the trust of others through professionalism and doing what is right. We are accountable to the organizations and the people that we interact with for both our actions and our results. We respect requests for privacy and confidentiality. When we are entrusted with sensitive, confidential or personal information we use appropriate measures to secure it. We avoid conflicts of interest and maintain transparency in our business.

3. Respect – we listen to and learn from each other and are committed to a welcoming work environment free from harassment or violence. We support and celebrate differences, respect differing perspectives, foster an inclusive culture, and operate with openness and benefit of the doubt. We are respectful of each other’s time, are clear and focused in our requests, and respond and help when asked. We appreciate the contributions of our people, partners, mentors, suppliers and clients and openly acknowledge those contributions. We recognize that we create more value by working together and encourage and respect independent, innovative thinking.

4. Fairness – we manage our relationships inside the company and out, with fairness, decency and good citizenship. We ensure that we are reachable, responsive and open in our communication with others. We intervene when we witness violations of our principles and our Code and take appropriate action.

5. Excellence – We strive to lead and sustain excellence and give back to the eco-system that we support. We have an unwavering commitment to professional development and growth of our people and clients. We invest in programs that allow for continual development with a focus on innovation, growth, quality and risk management. We work collaboratively with our business partners and strive to deliver programs that exceed the expectations of our clients.

 

Principles of Business Conduct

Our Code provides an outline of prudent business principles and sets the standards of conduct to which you are expected to adhere. Ethical behavior is at the foundation of our Code and is a personal responsibility we all share. Basic to ethical conduct is the requirement to comply with the laws and regulations that govern our business, but ethical behavior goes beyond mere compliance with the law. It involves using good judgement in every situation and thinking through the impact of your decisions and behavior on others.

 

Although we cannot anticipate every ethical dilemma or set of circumstances you may encounter, there are a number of fundamental principles that will help guide and support ethical business conduct:

 

• Avoid conflicts of interest or situations where your personal interests, relationships or outside interests may impair your ability to make business decisions with integrity, objectivity or honesty;

 • Do not solicit, accept or give gifts, favours or unusual hospitality from the people you do business with that may compromise, or appear to compromise, your or their ability to make fair and objective business decisions;

• Protect the confidentiality, security and privacy of information that is provided to you, except when disclosure is authorized or legally mandated;

• Make sure the information you share with others is fair, factual and complete and only share information that you are authorized to disclose;

• Be honest, courteous and respectful when dealing with colleagues, clients, business partners and suppliers and avoid exerting improper influence over individuals or businesses providing services to, or receiving services from, Propel;

• Respect and honor the terms of our agreements with clients, suppliers, partners and other third parties and do not attempt to circumvent their intentions;

• Only enter into agreements on behalf of the company when you are authorized to do so, ensuring that all legal and procurement practices are properly followed;

• Be accountable for and safeguard the Propel assets – both tangible and intangible - that have been entrusted to you. Use them only for legitimate business purposes and protect them from loss or unauthorized use;

• Preserve, protect and enhance the value of Propel’s intellectual property including our know-how, business methods and processes, written materials, computer software, and program content, whether developed internally within Propel or obtained from others.

• Ensure that all documents, plans, books and records, and reports falling under your responsibility are accurate, complete and properly managed and that they reflect fairly, and in reasonable detail, our business transactions and activities;

• Uphold the right of people to work in an environment that fosters courtesy and mutual respect, free of any form of violence, harassment or discrimination (this applies in both the workplace and any work-related setting);

• Uphold Propel’s commitment to a safe, productive and drug-free environment and never be under the influence of illegal drugs or abuse alcohol or other substances when at work, attending work- related events or at a location where you are acting on behalf of Propel;

• Exercise caution when using social media networking sites to protect and enhance the reputation of Propel; do not give the appearance of speaking or acting on Propel’s behalf unless you are authorized to do so and never assume that anything you say or post on social media or other public websites is private.

 

Our Responsibilities under the Code

Propel is committed to conducting our business based on the Code we have established. Each of us must review this Code on a regular basis and undertake to apply these standards in our daily work. We must also remain alert to conduct that may conflict with the Code as well as situations that may lead to illegal, unethical or inappropriate conduct. If you observe any possible violations, you have a responsibility to promptly report what you know to the CEO. Efforts will be made to maintain confidentiality within legal and practical limits. Anyone who in good faith reports an issue will be protected from threats of retaliation or sanctions related to the disclosure of such issues. Making a report in good faith means that you have reasonable grounds for believing that a violation has occurred, is occurring or may occur in the future.

 

Violation of the Code 

Disciplinary action up to an including dismissal of an employee or termination of our agreement with a client, partner or third party, as well as possible civil or criminal prosecution, will be taken should any of the following occur:

• Violation of the Code or a Propel policy, or asking others to violate the Code or policy;

• Committing an illegal or fraudulent act;

• Committing an act of workplace violence, or threat of violence, or demonstrating threatening,

harassing or discriminatory behavior towards others in the workplace;

• Deliberately failing to promptly report a violation or withholding relevant information regarding a

violation;

• Failing to cooperate in the investigation of a known or suspected violation; or

• Taking retaliatory action against someone who has reported a violation or breach of the Code or a

policy.