Raise Marketplace Code of Conduct Raise.com

CODE OF CONDUCT
Raise Marketplace Inc.
Table of Contents
CEO Letter
Raise Core Values
Our Commitments: What This Code is About
Making the Right Choices
Ethical Decision-Making
Responsibilities of Leaders
Our Commitments to the Raise Community
Respect For Our Colleagues
Avoiding Conflicts of Interest
Examples of Conflicts of Interest
Reporting and Remedying Conflicts
Protection and Use of Raise Assets
Fraud
Confidential Information
Information System Security and Integrity
Intellectual Property
Communications and Social Media
Our Commitments to Our Members
Keeping Our Promises to Members
Member Information and Privacy
Our Commitments to the Marketplace and the Public
Fair and Honest Dealing
Respect for Intellectual Property
Bribery and Corruption
Gifts and Entertainment
International Trade Sanctions and Controls
Governmental Investigations and Inquiries
Keeping Our Commitments
Seeking Guidance and Reporting Concerns
What We Will Do With Reports of Suspected Misconduct
We Do Not Tolerate Retaliation
Cooperation with Investigations
Discipline for Violations
Waivers of this Code
Amendments and No Rights Created
Signature and Acknowledgement
Signature
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Dear Colleagues,
While Raise is a relatively new company, it is never too early to establish clear conduct guidelines for us all
to live by. These guidelines are tied to our Core Values: Passion, Excellence, Integrity, Communication,
Respect and Family.
I think we can all agree that our conduct matters, as it’s important to do the right thing. Living with integrity
and following a clear code of ethics is good for our business and will ensure our future success. Whether
we’re collaborating in our beautiful space or out in the world during our daily lives, we represent Raise. Our
conduct has a direct impact on both our interaction with co-workers and the external perception of
our brand.
Our conduct as a team transcends all areas of our business, including how we treat each other internally
and how we treat members, partners, vendors and government bodies externally. This Code of Conduct sets
forth basic ethical standards and Core Values that are applicable to all of us. It is designed to guide us in our
work activities and everyday behavior at Raise.
All employees of Raise are responsible for understanding and complying with this Code of Conduct.
By upholding this code, you will support our success and embody the core values we strive to foster in
our workplace.
Sincerely,
George Bousis
Founder & CEO
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Raise Core Values
PASSION We dare to make an impact.
Our mission is compelling, one that can only be accomplished through sincere dedication. Day in and day
out, we truly believe in the promise we’ve made to our members. And that’s where passion comes in. The
passion to own what you do and inspire the people around you. Genuine passion is contagious—is yours?
EXCELLENCE We seize opportunities.
We create our own success by uncovering the opportunities that surround us. And we must think beyond
what is readily apparent to find them. Set high goals to challenge yourself and your team, and hold those
around you to an elevated level of execution. Make a commitment to continuous improvement and learning.
Surround yourself with smart, motivated people, and constantly strive to be your ideal self, the best you
can achieve.
INTEGRITY We make tough decisions.
Be true to your word and be humble. Give credit to those who deserve it and create a reputation that others
admire. Above all, take responsibility. We are at our best when we hold ourselves accountable for our own
actions. Be willing to speak up, even when it may be uncomfortable to do so. It’s remarkably satisfying, doing
what is right even when it’s not popular.
COMMUNICATION We get to the real why.
Sharing openly is powerful and meaningful. We believe that by encouraging a diversity of opinions,
we’re able to find the most valuable solution. And with collaboration at the forefront, we require an open
environment of transparency. As the foundation of our culture, this transparency creates alignment and
allows us all to work together toward the same goal.
RESPECT We make time for kindness.
Strong relationships are at the core of successful businesses. For us, it’s about creating connections with
our members, our partners, each other, and respecting ourselves. And this type of respect takes energy.
We have to make the choice to listen and at the same time, consider how we say what we say. It’s essential
that we see the good in people and be mindful of their effort and intent.
FAMILY We encourage each other.
At Raise, we are both a team and a family. In this environment we can feel safe taking informed risks,
knowing we’ll be supported. Trust is key. Everyone helps each other out because we are on this journey
together. We care. We have fun. We laugh. We cry. This level of admiration for each other stems from the
fact that we are all working together to fulfill our vision.
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Our Commitments - What This Code is About
This Code of Conduct is about what we aspire to be:
• A business that earns the trust of our members, business partners, and the public by consistently acting with honesty
and integrity
• A workplace that we take pride in, where everyone has the opportunity to realize their full potential
• An environment defined by mutual respect, open and constructive discussion of the challenges that confront us, and
unwavering ethics
These achievements don’t happen automatically. They require the commitment of the Raise leadership team
and from every employee. We must commit to:
• Awareness of our obligations to our stakeholders and fellow employees
• Honesty in everything we do
• Fairness and respect towards our colleagues
• Accountability for our decisions, our actions and their consequences
• Alertness for situations that may test our integrity, such as temptations to take the easy path instead of the right one,
pressures to achieve goals the wrong way and conflicts between our personal interests and those of the company
• Vigilance for conduct that may fall short of our standards or put the company’s reputation at risk
• Determination to ask questions about ethical or legal concerns, seek guidance and especially to speak up about
misconduct
This Code is your general guide to our commitments and how we must uphold them. Every person working
at Raise must comply with this Code, with the additional guidance in related policies and procedures and
with the legal obligations relevant to your job.
Individual success at Raise is judged not only on what we achieve, but how we achieve it. No individual or
business goal is more important than compliance with the law and with this Code, and business expediency
will never be accepted as justification for dishonest, illegal or unethical behavior. Being a part of the Raise
team means making these commitments, and keeping them.
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Making the Right Choices
It is everyone’s responsibility to be alert for gray areas or questionable situations, and to react appropriately.
Sometimes it is tempting to “go with the flow,” say nothing, seek no guidance, and take the shortest path to
our goal. But doing nothing is a choice, and one that can have serious consequences for Raise and for the
individual.
When you find yourself faced with a difficult issue, asking the right questions may clarify things. In the section,
“Keeping our Commitments”, you will find more information on getting expert help and reporting conduct that
may violate our standards.
ETHICAL DECISION-MAKING
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Responsibilities of Leaders
Our Commitments to the Raise Community
At every level of our organization, those in leadership roles have special responsibilities to promote our
culture of ethics and compliance. Executives and managers are expected to:
• Serve as exemplary role models of ethical behavior at all times
• Never give direction or advice that could be interpreted as encouraging or condoning violations of this Code
• Ensure their team understands their responsibilities under this Code and takes them seriously
• Consider ethical conduct and misconduct when evaluating performance
• Create a “speak up” atmosphere that encourages team members to raise issues without concern about retaliation
• Be attentive to signs or reports of suspected misconduct and escalate to seek help in resolving them
whenever appropriate
• Take decisive action to stop misconduct when it is discovered
In particular, where violations of the law, this Code, or our policies are concerned, we approach it with
the attitude, “If you know about it, you own it.” You have a responsibility to act, but that does not mean
you should try to deal with significant compliance issues alone. Your primary responsibility is to ensure
misconduct is dealt with appropriately and through the proper channels. You must use good judgment to
bring incidents of noncompliance with this Code to the attention of our General Counsel for further action
whenever appropriate. This includes when you believe an investigation, employee discipline, additional
training, or improvements to our compliance processes may be necessary.
RESPECT FOR OUR COLLEAGUES
At Raise, we strive to foster a culture of openness, constructive engagement and interactivity that enables
each of our colleagues to maximize their unique contribution to our success.
Fundamental to this goal is treating our coworkers with respect, dignity and fairness at all times.
We recognize that Raise benefits from the diversity of our colleagues’ experiences, backgrounds, talents
and perspectives.
We will not tolerate discrimination based on protected characteristics or harassment in any form. Each of us
must take personal responsibility for the quality of our work environment by committing to:
• Treat everyone in our workplace with fairness, dignity and respect
• Base all employment-related decisions on merit and performance, without regard to race, color, national origin, age,
sex, disability, pregnancy, marital or partnership status, sexual orientation, gender identity, veteran status or other
characteristics protected by law
• Speak up when we become aware of unlawful discrimination or harassment
For more guidance on these principles, please refer to our separate policies on “Equal Employment
Opportunity” and “Sexual and other Harassment or Discrimination”, or contact any of the people identified
under “Keeping Our Commitments – Getting Help and Reporting.”
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Avoiding Conflicts of Interest
When acting on behalf of Raise, we have an obligation of undivided loyalty and must act solely in the best
interests of the company. When our personal interests and the best interests of Raise are not aligned, this
“conflict of interest” may tempt us to place our own personal, financial, or social benefit or loyalties above our
duty of loyalty to the company. Even the appearance of a conflict can undermine confidence in our decisions
and damage our individual reputations and the company’s reputation.
EXAMPLES OF CONFLICTS OF INTEREST
Conflicts can arise for the following reasons: Personal interests, loyalty to close relatives, or loyalty to anyone
you have a close personal relationship with. Any person who might affect your objectivity can be considered
a potential conflict of interest. The following are some common examples of conflicts of interest that must be
reported and addressed.
• Outside Employment: Performing services for a Raise member, supplier, or competitor (whether as an employee,
consultant, board member, or in another capacity); or accepting any other job that interferes with your ability to do your
job at Raise
• Business Relationships with Family or Close Friends: Your family or a close friend works for a Raise member, supplier,
or business partner and you have direct or indirect influence over the business relationship with that company
• Investments: You, your family or a close friend have an investment in a Raise competitor, member, or supplier (other
than insignificant investments, such as an investment in a mutual fund that may hold shares in a competitor)
• Supervisory Relationships: Having a direct or indirect supervisory relationship at Raise with family or a close friend
• Corporate Opportunities: Taking personal advantage of, or diverting to someone else, a business opportunity that
you learn about through your work at Raise. This includes using Raise property, information, or your position at the
company for personal gain
• Gifts and Entertainment: Acceptance of inappropriate gifts or entertainment. For further guidance, see section “Gifts
and Entertainment”
REPORTING AND REMEDYING CONFLICTS
Conflicts of interest make it hard for the conflicted person to be completely objective about what is the
right thing to do. They also undermine the credibility of the decisions they make, even if the decisions are
objectively sound. Therefore, decisions about conflicts should always be made by someone who has no
personal stake in the matter.
Whenever you have a conflict, you must immediately report it to your manager so appropriate steps can
be taken to avoid any potential harm or the appearance of impropriety. Raise will work with you to find an
appropriate solution, and you will be expected to take any remedial actions requested by the company.
This could include having someone else make purchasing or spending decisions, changing reporting
relationships, or avoiding certain business opportunities or investments.
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Protection and Use of Raise Assets
Each of us has a responsibility for the property, resources, and funds that Raise entrusts us with. We must
use these resources appropriately in our work and do our best to protect them from loss, theft, damage,
waste and abuse. We must not use Raise assets for personal gain or other commercial activities aside from
incidental personal use of assets. This includes the use of telephones and computers as permitted by Raise
policies. If you learn of any misuse of company resources or funds, speak up and report it.
FRAUD
Intentionally concealing, falsifying, or altering information relevant to our business for your own benefit or that
of third parties is a misuse of Raise assets and may constitute fraud. Whether it is falsifying financial results,
transactional data, tax information, time records, or expense reports, it has no place at our company and is
strictly forbidden.
CONFIDENTIAL INFORMATION
Much of our value as a business is tied up in confidential information: The Raise software and technology
platform, plans and strategies, financial information, business partner information, personal information about
our members and employees, and any other information about our business that is not readily available to
the public. Maintaining the secrecy and security of this confidential information is a paramount duty of all
Raise associates.
You may not share any confidential company information, or confidential information entrusted to us by
others, with anyone (either within or outside Raise) who does not need to know the information and does not
have the proper authorization to receive it. In general, confidential information may be disclosed outside of
Raise only under an approved nondisclosure agreement, or to persons to whom there is a legal obligation
to disclose.
In order to fully maintain confidential information, please be sure to adhere to the following:
• Do not admit anyone to our offices unless you know they are authorized to be there
• Do not discuss confidential information in public places where others might be able to hear
• Safeguard confidential documents both inside and outside the office
• When using a computer outside the office, be attentive to whether others may be able to read the screen
• Comply with our information system security and integrity policies
INFORMATION SYSTEM SECURITY AND INTEGRITY
Our computer security policies are constantly evolving. Data security breaches are an existential threat to
every modern business, and Raise is no exception. We owe it to ourselves, our investors and our members to
safeguard the security and integrity of our information systems. To meet this threat, we must all adhere to our
information security policies without exception, even when it’s inconvenient to do so.
Aside from data security, it is important to understand that our business model and technology platform are
specifically designed to promote compliance with the law and to prevent transactions that are improper or
that could involve additional regulatory requirements. We rely on the integrity of these system controls. For
this reason, overriding, disabling, circumventing or modifying any of our system controls is strictly prohibited
without prior review and approval by senior executive management, including any necessary regulatory
review. This principle applies to all users, including those with system administrator status or similar technical
access privileges.
INTELLECTUAL PROPERTY
Besides confidential information, Raise has other valuable intellectual property like its trademarks, logos,
copyrighted materials and patents. We protect our intellectual property by restricting third party use without
an authorized license and limiting use that is not for Raise business purposes.
Any work product created by Raise employees during work or using any of our resources or assets is Raise
intellectual property and should be protected like any other valuable asset. Examples include inventions,
discoveries, business development ideas, software, and documents created in your work. In particular, if
you create a potentially patentable invention, such as a technology or business model improvement, it
is important to disclose it promptly to our General Counsel so that legal filing deadlines can be met or is
otherwise consistent with any existing patent disclosure processes the company has in place.
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COMMUNICATIONS AND SOCIAL MEDIA
In communicating about Raise, each of us is responsible for ensuring that our activities are consistent with
Raise policies and do not cause the company to be in violation of the law. This is especially important when
responding to the media or posting on social media. Although social media may seem like a place where
“anything goes,” it is surprisingly easy to inadvertently cross a legal line. Follow these guidelines when
using social:
• Unless your job assignment specifically authorizes you to speak on behalf of Raise, you should not respond to media
inquiries about our business. Instead, refer them to an authorized spokesperson
• When posting on social media in a context where your affiliation with Raise may be apparent (such as on LinkedIn),
always be clear that your writings and opinions are your own, and that you are not speaking on behalf of Raise
• If you post about Raise products or services anywhere online, this can be considered a “paid endorsement” and your
employment affiliation with Raise should be clearly disclosed as part of that communication
• Never disclose any confidential information about Raise, its business partners or our members online or in social media
• Avoid any use of Raise trademarks, logos, copyrighted materials, images or recordings from inside our offices in your
social media postings
• Do not correct any misinformation about Raise yourself. Instead, bring it to the attention of our management team, in
particular our head of medial relations or our General Counsel
Our Commitments to Our Members
KEEPING OUR PROMISES TO MEMBERS
Our future depends on our reputation. Every interaction we have with a member either strengthens or
weakens our reputation. Raise must always represent a promise of excellent service, quality and integrity.
The specific promises we make through our advertising and promotional activities must uphold these
principles. We must commit to:
• Follow the highest standards of honesty, accuracy and fairness in our advertising and promotions
• Be truthful and responsive in all of our communications with members
• Protect our reputation when considering promotional affiliations with third parties
• Never make unfair or misleading comments about competitors or their services
• Treat every member with courtesy and respect
• Deliver on our promises
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MEMBER INFORMATION AND PRIVACY
Personally identifiable information and business or financial information about our members (Customer
Member Information) is an especially sensitive kind of information that we are entrusted with. Besides the
obligation to honor our members’ trust, our use and disclosure of this information may be governed by many
different laws and contractual obligations. In addition to the principles listed under “Confidential Information,”
above, we must each commit to:
• Store and dispose of member information securely
• Be familiar with Raise policies governing the use of the member information we have access to
• Access and use member information only for legitimate business purposes
• Disclose member information only to other Raise associates with a business need to know, and to third parties who
have proper authorization or the member’s consent to receive it
• Immediately report any actual or suspected privacy breaches or security vulnerabilities to our General Counsel, Chief
Financial Officer or another senior executive
Our Commitments to the Marketplace
and the Public
FAIR AND HONEST DEALING
Our reputation for fair and honest dealing with suppliers, other business partners and competitors is essential
to our long-term success. We should treat other market participants as we expect to be treated. We earn trust
in the marketplace by never doing the following:
• Taking unfair advantage of others through false statements, theft, abuse or unauthorized release of
confidential information
• Making decisions about third-party relationships based on anything but legitimate business considerations such
as price, quality, reliability and trustworthiness
• Making misleading statements about competitors
• Pressuring members or suppliers to break binding contracts with competitors
• Gathering competitive information through unethical means such as deceit, intentional eavesdropping, trespassing,
bribery of or threats against their employees, or asking their former employees to violate confidentiality obligations
RESPECT FOR INTELLECTUAL PROPERTY
We respect the intellectual property rights of others. Our commitments include:
• Complying strictly with all licenses of software, data, other copyrighted materials, patents or trademarks owned by third
parties. This includes specifically obeying use restrictions and not making unauthorized copies of software
• Never intentionally violating others’ intellectual property rights.
• Never seeking or taking advantage of improper access to third-party confidential information
• Respecting our obligations under confidentiality and non-disclosure agreements
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BRIBERY AND CORRUPTION
Raise does not tolerate bribery, kickbacks, or other corrupt business methods. We never give, offer, request
or accept anything of value to improperly influence a business decision or a governmental action that affects
Raise or to induce an illegal or unethical act.
Corruption exploits conflicts of interest between an organization and its employees. This can take many
forms, including:
• Giving something of value to a business partner’s employee to obtain an advantage for Raise in a procurement, to
secure favorable terms, or to acquire confidential information
• Accepting any personal benefit in exchange for a favorable business decision involving a member, supplier, or other
business partner (whether before making the decision - a bribe - or afterwards - a kickback)
• Giving anything of value to a government official to influence official action, whether in a regulatory context or in
connection with a procurement
• Using a third party such as a consultant, a family member or a controlled entity to accomplish schemes of this kind
Bribes and kickbacks can be paid in many forms besides money, such as excessive gifts, lavish
entertainment, free travel, gift cards, promises of employment, separate business opportunities, investments
or transactions, use of vacation homes, free services, or even contributions to a charity that the recipient
controls or benefits from. A bribe in disguise is still a bribe.
To be clear, Raise will walk away from any business opportunity that requires any form of corruption, and
will fully support employees who refuse to participate in such schemes. Be alert to the fact that corrupt
schemes are usually first proposed using indirect or innocent-sounding words and descriptions. If you ever
feel that you may have been approached about giving or receiving a bribe or kickback, you should report it
immediately to our General Counsel.
GIFTS AND ENTERTAINMENT
Customary business courtesies such as modest gifts and reasonably priced entertainment (including
meals) are an accepted way to build goodwill and strengthen relationships. However, under the wrong
circumstances (or if excessive) these courtesies can create conflicts of interest, be perceived as bribes or
kickbacks, or damage our reputation in other ways. To avoid these hazards, we must never offer, provide or
accept any business gifts or entertainment in the following circumstances:
• In exchange for a promise to influence a business decision or to confer a benefit on the recipient and/or the
recipient’s company
• When it might appear to compromise the recipient’s objectivity or create an obligation
• When a gift is lavish, extravagant, or of substantial value
• When it is unlawful or could embarrass Raise, such as contraband goods or sexually-oriented entertainment.
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There are some additional rules when it comes to business gifts and entertainment. Employees at Raise
should never do the following:
• Request gifts, entertainment, or other favors from business associates
• Give or accept any cash or cash equivalents such as gift cards, gift certificates, loans or securities
• Provide gifts or entertainment to any government official or their family members without specific approval from
our General Counsel
• Provide gifts or entertainment in violation of the recipient’s company policies
If all of the above requirements are met, you may give or receive business gifts (including entertainment) that
are openly given, reasonable in cost, customary under the circumstances, and are not expected to influence
the recipient’s decisions or objectivity.
Gifts in excess of $100 in value and tickets to elite events—concerts, performances, or sporting events
to which tickets are not available to the general public at face value—are generally considered to be of
substantial value and may not be accepted without prior approval by our General Counsel, CFO, or CEO.
All business gifts and entertainment you provide are subject to our budget and expense policies and must
be properly identified as such and documented in our books.
If you are offered a gift or entertainment under circumstances where you feel it may be an attempted bribe,
you should immediately report it to our General Counsel.
INTERNATIONAL TRADE SANCTIONS AND CONTROLS
Raise is committed to compliance with United States and global trade controls applicable to our business.
The United States and many other nations impose strict controls on the import and export of goods, services,
and certain information, particularly with respect to “sanctioned” countries, organizations and individuals. If
you become involved with the proposed transfer of goods, services, or technology across national borders,
it is your responsibility to consult with our General Counsel and become familiar with the trade controls
compliance requirements associated with your work.
GOVERNMENTAL INVESTIGATIONS AND INQUIRIES
It is the company’s policy to cooperate with government investigations and inquiries. It is critically important
that information provided to government agencies be truthful and accurate, which requires a systematic,
managed response process. If you are contacted about a government investigation, a non-routine site visit,
a request for information, or a subpoena, you should:
• Immediately report the matter to the General Counsel and obtain guidance before responding
• Cooperate with any resulting internal investigation and with the General Counsel’s direction regarding
production of evidence
• Never give misleading information to government personnel
• Never destroy, conceal, or alter documents or business records in response to an inquiry or investigation
• Never advise or pressure anyone to hide information, destroy or alter documents or mislead the government
or internal investigators
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Keeping Our Commitments
SEEKING GUIDANCE AND REPORTING CONCERNS
No Code of Conduct can anticipate every situation, cover all of the complex legal obligations that govern
our business, or answer every ethical question. All members of the Raise community have a responsibility
to themselves and to each other to seek guidance when the right choice is unclear or when values and
goals seem to be in conflict. We are all guardians of our workplace culture and of the company’s reputation
for integrity.
We also have a duty to report to our General Counsel any known or suspected violations of this Code,
Raise policies, or the law by Raise personnel, contractors, agents, suppliers—and even members, if the
conduct relates to our business. Failure to report known violations is itself a violation of this Code. We can
only do something about misconduct if we know about it. If it goes unreported, it may not be detected at
all until great damage has been done. Never assume that others will report misconduct or that management
is already aware of it.
You can get advice and direction from, or report concerns about misconduct to:
• Your manager
• A higher level manager in your reporting line
• Our General Counsel
• Human Resources
• Any Raise senior executive officer, including the CEO and CFO
We have also provided the following additional mechanisms for confidential and anonymous reporting:
• Toll-Free Telephone: 844-670-0006
• Website: www.lighthouse-services.com/raise
• E-mail: reports@lighthouse-services.com
• Please include the company name within the email when making a report.
WHAT WE WILL DO WITH REPORTS OF SUSPECTED MISCONDUCT
All reports of suspected misconduct will be taken seriously and promptly investigated in a manner
appropriate to the nature of the issue. We will handle reports with discretion and, if requested, will strive to
maintain the confidentiality of persons making reports, consistent with legal obligations and with conducting
a thorough and fair investigation, resolution and follow-up. When feasible, we will advise the person making
the report when the investigation has been concluded. Please note, if you report misconduct anonymously,
we may not be able to contact you for follow-up or obtain additional information that might assist the
investigation. Furthermore, if you report misconduct anonymously, we ask that you provide sufficient detail
and information we can conduct a reasonable investigation.
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WE DO NOT TOLERATE RETALIATION
Raise has a zero-tolerance policy for any form of retaliation or retribution against any person for reporting
actual or suspected misconduct in good faith, or for cooperating truthfully and in good faith with an
investigation of suspected misconduct. Retaliation can take such forms as termination, demotion, suspension,
other discriminatory job action, or personal harassment or threats. Retaliation is a serious violation of
this Code of Conduct. If you or someone you know experiences retaliation for reporting misconduct or
cooperating with an investigation, please report it right away to the General Counsel or our CEO.
Good faith reporting simply means that you honestly believe the information you are providing is accurate;
you need not have definite proof of a violation. But knowingly providing false or inaccurate information is
itself a violation of this Code and will be addressed accordingly.
COOPERATE WITH INVESTIGATIONS
All of us are obligated to cooperate fully with any internal or external investigation of misconduct.
This includes providing complete, accurate, and truthful information within your knowledge, preserving
and providing documents or other evidence in your control that relates to the investigation, and never
concealing, destroying, or altering documents or other evidence.
Discipline for Violations
We are accountable for our business conduct. Raise employees or personnel, officers and directors who
violate the law or this Code in the course of their work are subject to discipline. This may include such
measures as written warnings, suspension without pay, demotion, loss or reduction of pay increases,
bonuses, or other incentive awards, and termination of employment. Disciplinary action in a given case
will depend on a number of circumstances, including the following:
• The nature and seriousness of the violation
• The nature of the individual’s involvement, including instructing others to violate the Code, condoning, concealing,
or failing to report violations by others, or failing to adequately monitor subordinates
• Whether the violation is intentional
• Whether the individual cooperates fully with the investigation
• Whether the individual participates in retaliation against those who reported the violation or cooperated in
their investigation
In addition to internal discipline, under some circumstances Raise may take legal action or refer violations to
appropriate enforcement authorities.
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Waivers of This Code
Amendments and No Rights Created
This Code is designed not to require waivers. Consents and authorizations required by this Code or
Raise policies (such as expense approvals) are not waivers of the Code, but implementations of it. If an
unanticipated event should arise that calls for consideration of a waiver of this Code, the waiver may be
considered and granted only as follows:
• For any executive officer of Raise, by the Board of Directors
• For any employee who is not an executive officer, by the Chief Executive Officer or a person designated by the
Chief Executive Officer
Any waivers will be granted only for future proposed actions, not for violations that have already occurred.
This Code is not a contract; accordingly, Raise may amend this Code at any time. The amended version
will be made available to all employees and personnel. This Code is a statement of certain fundamental
principles, policies and procedures that govern the company’s directors, officers and employee in the
conduct of the Company’s business. It is not intended to and does not create any rights in any employee,
member, vendor, partner, competitor, shareholder or any other person or entity.
SIGNATURE AND ACKNOWLEDGEMENT
All employees and personnel, officers and directors must sign an acknowledgment that they have received
and read this Code and agree to adhere to it. All directors, employees and personnel may also be
periodically required to make or reaffirm similar acknowledgments. Failing to read the code or to sign the
acknowledgment is no excuse for noncompliance.
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Raise Code of Conduct
ACKNOWLEDGMENT
Please review this Code of Conduct carefully, sign below and return this form in accordance with instructions
provided to you by the company. A copy will be placed in your Raise personnel file. You should also keep of
copy of this for your own work files.
I certify that I have received and read the Raise Code of Conduct. I agree to abide by the Code of Conduct.
To the extent I am employed or otherwise work at Raise, I understand that doing so is a condition of my
employment and/or engagement at Raise.
I also understand that I am encouraged to bring questions about the Code of Conduct, its interpretation or
my obligations under it to the attention of management, including the General Counsel. I understand that I
am obligated to report any known or suspected violations as directed in the Code.
Signature Printed Name
Today’s Date
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