Jazzware Code of Conduct

Purpose

This Code of Conduct outlines the ethical standards and principles that guide Jazzware’s operations and the behavior of its employees, inspiring them to act with integrity, honesty, and respect. 

Scope

This Code of Conduct applies to all Jazzware employees, including full-time, part-time, temporary, contract workers, and anyone acting on behalf of Jazzware. It also extends to third-party contractors, vendors, and consultants who work with Jazzware.

Conflict of Interest

Employees must avoid any situation that could create a conflict of interest, including but not limited to gifts, favors, or other benefits from individuals or organizations that could influence their official duties.

Employees must disclose any potential conflict of interest to their supervisor or the appropriate compliance officer. If a conflict of interest arises, employees must take steps to mitigate or avoid it, as directed by Jazzware.

Bribery and Corruption

Bribery and corruption are strictly prohibited in all forms. Employees must not:

• Offer, accept, or solicit bribes, kickbacks, or other improper payments.
• Engage in extortion or other forms of unlawful coercion.
• Give or receive gifts that could be construed as bribes or attempts to influence official actions.

Employees must comply with all applicable anti-corruption laws and regulations, including the Foreign Corrupt Practices Act (FCPA). If an employee becomes aware of any suspected bribery or corruption, they must report it to their supervisor or the appropriate compliance officer.

Fraud and False Claims

Employees must be honest and truthful in all their dealings, both internally and externally. They must not make fraudulent or false claims, including but not limited to:

• Falsification of records or data.
• Theft or misuse of company assets.

Employees must report any suspected fraudulent activity to their supervisor or the appropriate compliance officer. Jazzware is committed to protecting employees who report violations in good faith.

Harassment-Free Workplace

Jazzware is committed to providing a workplace free from harassment, discrimination, and bullying. We have a zero-tolerance policy for any form of harassment, including but not limited to:

• Sexual harassment (e.g., unwelcome advances, inappropriate jokes or gestures, or any other conduct of a sexual nature).
• Discrimination based on race, color, religion, sex, national origin, age, disability, genetic information, or any other characteristic protected by law.

Employees are expected to treat each other with respect and dignity. Any form of harassment or discrimination, whether between employees, contractors, vendors, or customers, is strictly prohibited.

If you witness or experience any form of harassment or discrimination, you are encouraged to report it to your supervisor or the appropriate compliance officer. Jazzware will investigate all complaints promptly and ensure that anyone who reports harassment or discrimination is protected from retaliation. 

Protection of Proprietary Information

Employees must protect Jazzware’s proprietary information, including but not limited to:

• Trade secrets (e.g., formulas, processes, customer lists, business plans).
• Confidential information (e.g., financial data, employee records, customer data).
• Intellectual property (e.g., patents, copyrights, trademarks).

Employees must not disclose proprietary information to unauthorized individuals, including competitors, potential competitors, or anyone outside of Jazzware without proper authorization. Proprietary information must be used only for legitimate business purposes and not for personal gain.

Employees must take reasonable steps to protect proprietary information, such as:

• Confidentiality agreements with third parties.
• Secure storage of sensitive information.
• Access controls to limit access to proprietary information.

If an employee becomes aware of a breach of confidentiality or unauthorized disclosure of proprietary information, they must report it to their supervisor or the appropriate compliance officer.

Fair Competition

Jazzware is committed to fair competition and compliance with all applicable antitrust laws and regulations. Employees must not engage in any unfair competitive practices, including but not limited to:

• Price fixing (i.e., agreeing with competitors on prices or terms of sale).
• Bid rigging (i.e., coordinating bids to ensure a particular outcome).
• Market allocation (i.e., dividing up markets or customers among competitors).
• Boycotts or refusals to deal with competitors or customers.
• Predatory pricing (i.e., setting prices below cost to drive competitors out of business).

Employees must be aware of and comply with all relevant antitrust laws, such as the Sherman Antitrust Act, the Clayton Act, and the Federal Trade Commission Act. If an employee becomes aware of any suspected antitrust violations, they must report it to their supervisor or the appropriate compliance officer.

Labor Law Compliance

Jazzware is committed to fair labor practices and compliance with all applicable labor laws and regulations. Employees must comply with these laws and regulations. 

Employees must report any suspected violations of labor laws to their supervisor or the appropriate compliance officer. Jazzware will provide employees with training and resources to help them understand their rights and responsibilities under labor law.

Reporting of Violations

Employees who witness or suspect a violation of this Code of Conduct should report it to their supervisor or the appropriate compliance officer. Jazzware is committed to protecting employees who report violations in good faith and will take appropriate action to address any reported misconduct.

To encourage reporting, Jazzware will:

• Provide confidential reporting channels  
• Ensure that employees who report violations are protected from retaliation or other adverse actions.
• Investigate all reported violations promptly and thoroughly.
• Take appropriate disciplinary action against employees who violate the Code of Conduct.