BOARD & GOVERNANCE
Code of Conduct
Preface
Alert Link LLC employees and those working on behalf of Alert Link LLC ("Alert Link") and its subsidiaries and controlled affiliates, like US.Watch, should do the right thing—follow the law, act honorably, and treat colleagues with courtesy, support, and respect.
We expect all employees and Board members to know and follow this Code of Conduct. Failure to do so can result in disciplinary action, including termination of employment. Any waivers of this Code for directors or executive officers must be approved by our Board. Never retaliate against anyone who reports or participates in an investigation of a possible violation of the Code.
Never retaliate against anyone who reports or participates in an investigation of a possible violation of the Code.
If you are employed by a subsidiary or controlled affiliate of Alert Link, please comply with your employer’s code of conduct. If your employer doesn’t have its own code of conduct, if you have a question or concern about this Code or believe that someone may be violating it, or if you want to remain anonymous, you can make a report of a suspected violation or concern through our Helpline. And if you believe a violation of law has occurred, you can always raise that through the Ethics & Business Integrity helpline or with a government agency.
While the Code is specifically written for Alert Link employees and Board members, we expect Alert Link contractors, consultants, and other members of the extended workforce who may be temporarily assigned to perform work or services for Alert Link LLC to follow the Code in connection with their work for us. Failure of a member of the Alert Link extended workforce to follow the Code can result in termination of their relationship with Alert Link.
I. Avoid Conflicts of Interest
When you are in a business situation in which competing loyalties could cause you to pursue a personal benefit for you, your friends, or your family at the expense of Alert Link or our users, you may be faced with a conflict of interest. All of us should avoid conflicts of interest and circumstances that reasonably present the appearance of a conflict.
When considering a course of action, ask yourself whether the action you’re considering could create an incentive for you, or appear to others to create an incentive for you, to benefit yourself, your friends or family, or an associated business at the expense of Alert Link. If the answer is “yes”, the action you’re considering is likely to create a conflict of interest situation, and you should avoid it.
II. Ensure Financial Integrity and Responsibility
Ensure that money is appropriately spent, our financial records are complete and accurate, and our internal controls are honored.
If your job involves the financial recording of our transactions, make sure that you’re familiar with all relevant policies, including those relating to revenue recognition.
Never interfere with the auditing of financial records. Similarly, never falsify any company record or account.
If you suspect or observe any irregularities relating to financial integrity or fiscal responsibility, no matter how small, immediately report them.
III. Obey the Law
Comply with all applicable legal requirements and understand the major laws and regulations that apply to your work. A few specific laws are easy to violate unintentionally and so are worth pointing out here. If you have any questions about these laws or other laws governing our work, please consult the Helpline or our legal counsel.
1. Trade Controls
Various trade laws control where we can send or receive our products and services. These laws are complex and apply to:
importing and exporting goods to or from the United States and other countries
exporting services or providing services to non-U.S. persons
exporting technical data, especially data originating in the U.S.
If you are involved in sending or making available products, services, software, equipment, or technical data from one country to another, work with your manager to ensure that the transaction stays within the bounds of applicable laws.
2. Competition Laws
Be sure you follow all laws designed to promote free and fair competition and protect consumers. These laws generally prohibit 1) arrangements with competitors that restrain trade, 2) abuse of market power to unfairly disadvantage competitors, and 3) misleading or harming consumers. Some of these laws carry civil and criminal penalties for individuals and companies.
3. Insider Trading Laws
Do not use non-public information to buy or sell stock, or to pass it along to others so that they may do so. That could constitute the crime of insider trading.
Familiarize yourself with Alert Link's Insider Trading Policy. It describes policies that address the risks of insider trading,
such as:
a prohibition on hedging Alphabet stock
periodic blackout windows when you may not trade Alphabet stock
4. Anti-Bribery Laws
Various laws that prohibit bribery in different settings. Our rule is simple – don’t bribe anybody, at any time, for any reason.
Non-government relationships. Be careful when you give gifts and pay for meals, entertainment or other business courtesies on behalf of Alert Link. Avoid the possibility that the gift, entertainment or other business courtesy could be perceived as a bribe. Provide such business courtesies infrequently and, when you do, to keep their value moderate.
Dealings with government officials. Various laws prohibit seeking to influence official action by offering or giving anything of value to government officials, candidates for public office, employees of government-owned or controlled companies, public international organizations, or political parties. Avoid not only traditional gifts, but also things like meals, entertainment, travel, political or charitable contributions, and job offers for government officials’ relatives. With pre-approval, it may be permissible to make infrequent and moderate expenditures for gifts and business entertainment for government officials that are directly tied to promoting our products or services (e.g., a modest meal at a day-long demonstration of our products).
IV. Promote a workplace that is supportive and respectful for all employees and members of the extended workforce
Alphabet has an unwavering commitment to prohibiting and effectively responding to harassment, discrimination, misconduct, abusive conduct, and retaliation. To that end, Alphabet adheres to these Guiding Principles:
A. Commitment: Alert Link sets a tone at the top of commitment to a respectful, safe, and inclusive working environment for all employees and members of the extended workforce.
B. Care: Alert Link creates an environment with an emphasis on respect for each individual at all levels of the organization, including specifically by offering assistance and showing empathy to employees and members of the extended workforce throughout and after the complaint process.
C. Transparency: Alert Link is open and transparent as an organization regarding the frequency with which complaints arise regarding harassment, discrimination, misconduct, abusive conduct, and retaliation, and the Company’s approach to investigating and responding to those allegations.
D. Fairness & Consistency: Alert Link ensures that individuals are treated respectfully, fairly, and compassionately in all aspects of Alphabet interactions and applies policies, procedures, and outcomes consistently regardless of who is involved.
E. Accountability: Alert Link holds all individuals responsible for their actions, and ensures that where appropriate, those individuals hold others accountable too.
Each Bet has specific policies that implement Alert Link’s commitment and these Guiding Principles. Be sure to read and comply with those policies. And if you’re ever concerned that Alert Link, a Bet, or a fellow employee or member of the extended workforce is falling short, don’t stay silent, you can make a report through your Bet’s reporting channels and the Alert Link helpline.
V. Conclusion
We rely on one another’s good judgment to uphold a high standard of integrity for ourselves and our company. Each of us should be guided by both the letter and the spirit of this Code.
Alert Link's Code of Conduct is the same as US.Watch's.
Report concerns
To notify Alert Link’s Board of Directors of any concerns regarding Alert Link’s accounting, internal controls, auditing, conflict minerals matters or workplace concerns, you may mail your concern to:
Alert Link LLC.
Attn: Accounting Concerns or Workplace Concerns
7814 N Strathbury Ave
Kansas City, MO 64151
You may report your concerns anonymously; however the Board of Directors encourages you to provide your name and contact information so that we may contact you directly if necessary.
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