CODE OF ETHICS

I. General Conduct Guidelines

a. Compliance with the Law

Compliance with the law and the legal system is a fundamental requirement for all members, participants and representatives of the Women in Technology: Hollywood Foundation, Inc. (“WiTH”). All members, participants and representatives must abide by the laws and regulations of the legal system within which they operate, and failure to comply with the law must be avoided in all circumstances. If a member, participant, r representative breaks the law, he or she will face revocation of their membership for violating the terms of their agreement with the WiTH, independently of the sanctions imposed by law.

b. Compliance with WiTH Policies and Guidelines

From time to time, WiTH will set forth guidelines, codes, policies and procedures (collectively, “Policies”) which are to govern work performed in WiTH. These Policies are intended to ensure the transparency, ethical integrity and lawfulness of this work. As a result, it is essential that WiTH members, participants and representatives comply with all WiTH Policies at all times. In the event that a WiTH member, participants or representative fails to abide by a WiTH Policy, they may be subject to immediate discipline determined at the sole discretion of WiTH, including: the suspension of their program participation; or the termination of their membership status. Further, in the event that a member, participant or representative’s non-compliance with WiTH Policies causes damages to WiTH or a third-party, the member, participant or representative may be responsible for indemnifying such party under the terms of their agreement(s) with WiTH.

c. Responsibility for WiTH’s Image

Every WiTH member, participant and representative plays a significant role in upholding the WiTH’s image through their appearance, actions and conduct. All WiTH members, participants and representatives are required to be aware of and to uphold the WiTH’s image in society at large.

d. Respect and Integrity

The WiTH respects the personal dignity, privacy and individual rights of all people, regardless of gender, nationality, culture, religion, sexual orientation, skin color or any other protected group. The WiTH does not tolerate any discrimination or any sexual or other personal harassment or offense. These principles apply both to our internal collaboration and to our conduct towards external partners.

e. Leadership and Responsibility

WiTH members, participants and representatives should set an outstanding example in terms of personal conduct, performance, openness, and social skills. Every WiTH member, participant or representative has organizational duties to fulfill and is responsible for ensuring that no infringements of the law occur within their sphere of responsibility. Even when individual tasks are delegated, the WiTH member, participants or representative retains this responsibility.

II. Relations with Business Partners and Third Parties

a. Fair Competition

Upholding the standards of fair competition in the free market is of ultimate importance to the WiTH. As such, all WiTH members, participants and representatives are duty-bound to observe the rules of fair competition. All WiTH members, participants and representatives shall avoid engaging in and/or the appearance of engaging in anticompetitive practices such as price fixing, bid rigging, boycotting, creation of monopolies, exclusive dealing agreements, tying arrangements, or any other activity that would tend to discourage or reduce market competition. It can be difficult in individual cases to assess the position relating to anti-trust and competition laws. In cases of doubt, therefore, the General Counsel should be consulted to provide guidance on the individual case.

b. Offering and Granting Benefits

WiTH members, participants and representatives shall compete for contracts on the basis of the quality and price of their services. No WiTH member, participants or representative may offer or grant unjustified benefits connected with business activities – directly or indirectly – in the form either of cash payments or of other benefits.

Promotional gifts should be carefully selected so as to ensure that no impression of dishonesty or impropriety is created. In cases of doubt, the recipient should be asked to obtain prior permission to accept the gift from his/her superior.

Gifts may not be offered to civil servants or other government officials in any circumstances. WiTH members, participants and representatives negotiating contracts with consultants, agents and similar third parties should ensure that these contracts do not offer or grant unjustified benefits.

c. Requesting and Accepting Benefits

WiTH members, participants and representatives may not use their professional position to request, accept, procure or be promised benefits that accrue to the individual.

d. Avoiding Conflict of Interest

WiTH members, participants and representatives must avoid both actual and potential conflicts of interest. The following rules in particular must be followed:

  • WiTH members, participants and representatives must adhere to WiTH’s Conflict of Interest Policy and disclose, annually, any potential conflict between personal or professional interests and the performance of their professional duties to any potentially impacted clients; and their superior, if applicable
  • A WiTH member, participants or representative shall not accept any gifts or social invitations (e.g. dinners, tickets to sporting events, etc.) from a vendor which would confer a material financial benefit – individually or in the aggregate – to the WiTH member, participants or representative. Further, in their relations with vendors, WiTH members, participants and representatives should, at all times, remain cognizant of, and take steps to curb, the appearance of impropriety.

III. Handling Information

a. Records and Reports

Accurate and truthful reporting is part of open and effective cooperation. All records and reports that are produced internally or communicated externally must be accurate and truthful. In accordance with proper accounting principles, data records and other reports must always be complete, accurate, timely and system compatible. The requirement of truthful reporting also applies in particular to expense accounts.

b. Confidentiality

Confidentiality must be maintained regarding internal WiTH matters that have not been made public. This includes details relating to the organization of WiTH and its operations, for example, as well as business, production, research and development transactions and internal accounting figures. The duty of maintaining confidentiality also applies after termination of the member, participants or representative’s

c. Data Protection and Data Security

Access to the intranet and the Internet, the global exchange of information and dialogue, electronic transactions – all play a key role in the effectiveness of each individual and for the success of the business as a whole. However, the benefits of electronic communication also entail risks in terms of personal rights and data security. Effective protection against these risks is an important aspect of IT management, management responsibilities and the conduct of WiTH.

Personal data may only be compiled, processed or used insofar as this is necessary for clearly defined and legitimate purposes. High standards must be maintained in terms of data quality and technical protection against unauthorized access. The use of personal data must be transparent for those affected, upholding their rights to information and amendment and to challenge, block or delete the information as necessary.

V. Managing complaints

Any WiTH member, participant or representative can lodge a personal complaint, or report a suspected violation of any Policy or Guideline(s), with WiTH’s General Counsel, or with a member of WiTH’s Executive Committee. The matter will then be thoroughly investigated and the necessary measures will be taken as appropriate.