Sample Code of Conduct Policy (NVCA)

NVCA Sample Code of Conduct Policy for a Company/Firm to Adopt

COMPLIANCE WITH LAWS, RULES, AND REGULATIONS

Acting ethically and obeying the law, both in letter and spirit, are among [company name]’s core values. We expect employees and consultants to understand the legal and regulatory requirements applicable to their area of responsibility, including federal, state, and foreign laws, as well as the relevant regulatory schemes. All employees are also expected to act with integrity and to exercise good judgment and common sense in their efforts to comply with all applicable laws, rules, and regulations and are encouraged to ask [reporting channel] for advice when they are uncertain about them.

We also believe that every employee is responsible for becoming familiar with [company name]’s policies so that they may integrate them into every aspect of our business.

[company name] considers violation of the law, company/firm policies, and this Code of Conduct to be a serious matter. Any violation may subject an employee to disciplinary action, up to and including termination. Additionally, those who work with us, including founders, contractors, consultants, volunteers, and their representatives (collectively, “third parties”), are expected to maintain professional conduct and follow all applicable laws and regulations.

Certain violations may be referred to legal authorities for investigation and civil or criminal prosecution. If you become aware of the violation of any law by [company name], whether by its officers, employees, or any third party doing business on behalf of [company name], it is your responsibility to promptly report the matter to your [reporting channel]. While [company name] strives to address matters internally, nothing in this Code of Conduct should discourage you from reporting illegal activity, including any violation of the law whether federal, state, local, or foreign law, rule or regulation, to the appropriate regulatory authority. This Code of Conduct should not be construed to prohibit employees from testifying, participating, or otherwise assisting in any state or federal administrative, judicial or legislative proceeding or investigation.

ADDRESSING CONDUCT THAT IS HARMFUL TO OUR CULTURE AND VALUES

[company name] respects the rights of all employees to express themselves. We believe that open dialogue and free expression of ideas is critical to our business. However, [company name] will take all reasonable and appropriate steps to address situations where an employee’s conduct or speech endangers the safety of others, violates others’ rights to be free from harassment, discrimination, and retaliation, or otherwise conflicts with [company name]’s culture and values, up to and including termination of employment.

HONEST AND ETHICAL CONDUCT AND FAIR DEALING

[company name] employees should endeavor to act honestly, ethically, and fairly in both internal and external dealings, including interactions with co-workers, limited partners, portfolio companies, service providers, and any other third parties with which [company name] may conduct business. Statements regarding [company name]’s business must not be untrue, misleading, deceptive, or fraudulent. You must not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other unfair dealing practice. Employees are also prohibited from creating or submitting false, inaccurate, or misleading invoices, receipts, or other financial or business-related documents to [company name] or related businesses.

UNACCEPTABLE BEHAVIOR

The rules set forth below are intended to provide employees with notice of what is expected of them. However, such rules cannot possibly identify every type of unacceptable conduct and performance. Therefore, employees should be aware that conduct not specifically listed below but which adversely affects or is otherwise detrimental to the interests of the [company name], other employees, or customers, may also result in disciplinary action, up to and including immediate termination.

Employees may be disciplined for misconduct, including but not limited to the following:

Insubordination

Dishonesty

Theft

Misusing or destroying [company name] property or the property of another on [company name] premises

Violating conflict of interest rules

Disclosing or using confidential or proprietary information without authorization

Falsifying or altering [company name] records, including an application for employment or time records

Interfering with the work performance of others

Altercations

Harassment, including sexually harassing employees, customers, and third parties

Being under the influence of, manufacturing, dispensing, distributing, using, or possessing alcohol or illegal or controlled substances on [company name] property or while conducting [company name] business

Sleeping on the job or leaving your work location/work site without authorization

Violation of safety or health rules

Possessing a firearm or other dangerous weapon or materials on [company name] property or while conducting [company name] business

Being convicted of a crime that indicates unfitness for the job or raises a threat to the safety or well-being of the Company, its employees, customers, or property

Gambling on [company name] premises or while conducting [company name] business

Failure to call in or report for your scheduled shift of work. An absence of three (3) consecutive scheduled workdays without notifying your supervisor or his or her designee is job abandonment and is considered a voluntary resignation.

The [company name] reserves the right to proceed directly to a written warning, demotion, or termination for misconduct or performance deficiency, without resort to prior disciplinary steps, when the [company name] deems such action appropriate.

EMPLOYEE ACKNOWLEDGMENT

Please Sign and Return to [reporting channel]

I acknowledge that I have received and read a copy of the [company name]’s Code of Conduct Policy. I understand that I am responsible for complying with the policy during my employment with the [company name].

I HAVE CAREFULLY READ THIS ACKNOWLEDGEMENT.

Date: _________________________________________

Signature: _________________________________________

Printed Name: _________________________________________