Code of Conduct

Our Code is how we put the FundApps values into practice. As a business, we set ourselves high standards both in what we aspire to achieve and how we behave. It reminds us of the personal responsibility we all play in ensure FundApps is, and remains an awesome place to work and a trusted partner to our clients and the community.

We don't want to (nor could we) enumerate every thing people should or should not do in Our Code, nor all of the possible scenarios that might arise. Instead, we prefer to assume everyone at FundApps is a responsible, respectful adult, and trust people to understand it, act accordingly and be able to work through differences as they arise.

Please read this document, and follow both in spirit and letter, bearing in mind each of us has a personal responsibility to live by our values in everything we do at FundApps.

We all play a part

Our role

No matter what job we do or where we do it, we are FundApps. We must keep this in mind in every business relationship, transaction and interaction to ensure our actions always reflect our values, Our Code, and the laws and regulations where we operate.

If you see or suspect anything illegal or unethical, it may seem easier to look the other way or let someone else take the lead—but misconduct affects all of us. No concern is too minor to report. Share your concerns promptly and cooperate fully and honestly as we investigate. We expect all FundAppers to know and follow Our Code. Failure to do so can result in disciplinary action, including termination of employment.

If you manage people, you have an even greater responsibility. Lead by example, making sure your team members know this is a resource for them and that there is no difference between what you do and what you expect from others. Create the kind of workplace where employees feel comfortable coming forward with questions and concerns, and support them when they raise issues. Never retaliate against employees for sharing concerns in good faith, and prevent retaliation by others.

Where to go for help

Whilst we hope nothing ever goes wrong, there are a number of things you can do to address problems and situations with your fellow FundAppers or with our People Ops. We know that you'll do your best work if you're happy and comfortable in your surroundings, so we take concerns about this stuff seriously. Depending on your comfort level and the severity of the situation, here are some things you can do to address it:

• Address it directly. If you're comfortable bringing up the incident with the person who instigated it, pull them aside to discuss how it affected you. Be sure to approach these conversations in a forgiving spirit: an angry or tense conversation will not do either of you any good. If you're unsure how to go about that, try discussing with your manager or with People Ops first—they might have some advice about how to make this conversation happen. If you're too frustrated to have a direct conversation, there are a number of alternate routes you can take.

• Talk to a peer or mentor. Your colleagues are likely to have personal and professional experience on which to draw that could be of use to you. If you have someone you're comfortable approaching, reach out and discuss the situation with them. They may be able to advise on how they would handle it, or direct you to someone who can. The flip side of this, of course, is that you should also be available when your colleagues reach out to you.

• Talk to your manager. Your manager probably knows quite a lot about the dynamics of your team, which makes them a good person to look to for advice. They may also be able to talk directly to the colleague in question if you feel uncomfortable or unsafe doing so yourself. Finally, your manager will be able to help you figure out how to ensure that any conflict with a colleague doesn't interfere with your work.

• Talk to People Ops. People Ops are happy to talk to you in person or remotely about the problem and help figure out what steps to take, from small challenges through to situations where more significant action needs to be taken. People Ops will make every effort to stay in clear communication with anyone who reports a problem, maintain confidentiality whenever possible. There may be instances where People Ops are required to escalate or inform others (e.g. CEO, legal advisors etc) about matters.

A safe space to speak up

We don't tolerate retaliation. We know it takes courage to come forward and share concerns. We won't retaliate or permit retaliation against anyone who raises questions or concerns relating to Our Code. Regardless of who you contact, you can be confident that you're doing the right thing and that your concern will be handled promptly and appropriately. We investigate reports of misconduct thoroughly, and will only disclose information to those who need it.

We create our workplace

We're one team, but we represent many ideas, experiences and backgrounds. Essential to our ability to advance our objectives and growth plans is for all FundAppers to have an equal chance to succeed. It is through the diversity and talents of our people that we are successful, so keeping our positive and inclusive work environment

Equal Opportunity

Employment at FundApps is based solely upon individual merit and qualifications directly related to professional competence. We strictly prohibit unlawful discrimination or harassment on the basis of race, color, religion, veteran status, national origin, ancestry, pregnancy status, sex, gender identity or expression, age, marital status, mental or physical disability, medical condition, sexual orientation, or any other characteristics protected by law. We also make all reasonable accommodations to meet our obligations under laws protecting the rights of people with a disability.

Harassment & Bullying

FundApps prohibits harassment and bullying in any form. Harassment is an action, conduct or behaviour that is viewed as unwelcome, humiliating, intimidating or offensive by the recipient. Bullying is repeated verbal, physical, social or psychological abuse by a person or group of people at work.

The test for what is considered unwelcome, humiliating, intimidating or offensive is what a reasonable person in society (ie. If you walk outside a grab a random person and tell them about the situation, what would they think?).

Workplace harassment and bullying should not be confused with constructive feedback or coaching on work performance or work-related behaviour of an individual or group for development purposes.

Microaggressions

Much exclusionary behavior takes the form of subtle-isms, or microaggressions – small things that make others feel unwelcome. For example, saying "It's so easy my grandmother could do it" is a subtle-ism with tones of both sexism and ageism. Regardless of intent, these comments can have a significant demeaning impact on teammates.

If you see a microaggression, you can point it out to the relevant person, either publicly or privately, or you can ask your Manager or People Ops to say something.

Standing up for inclusion

If a situation occurs where you believe you have been present for a behaviour or microaggression that doesn't align with Our Code, FundAppers are encouraged to speak up within the moment in order to let that person know that what has happened is not inclusive behaviour. This makes for a situation from which all parties can learn, and is one which promotes understanding. Additionally it makes it possible for that someone to de-escalate the situation by correcting themselves and apologising. This does not ensure, there will be no consequences, it however will greatly reduce the chance of escalation and has the potential to return a situation to once again become comfortable and inclusive.

We do the right thing

Anti-bribery & corruption

Like most global businesses, we are subject to laws that prohibit bribery in basically every kind of commercial setting. The rule for FundApps is simple - don't bribe anybody, anytime, for any reason. This includes pure bribes, kickbacks, illegal payments and any other offer of items of value that may influence behaviour directly or through a third party.

Whistleblowing

Whistleblowing is generally defined as the reporting of certain types of wrongdoing that are in the public interest (ie it must affect others such as the general public). We encourage all of our employees and others who have serious concerns about any aspect of FundApps work to come forward and voice those concerns. The types of whistleblowing covered under legislation include:

• a criminal offence, eg fraud

• someone's health and safety is in danger

• risk or actual damage to the environment

• a miscarriage of justice

• the company is breaking the law, eg doesn't have the right insurance

• you believe someone is covering up wrongdoing

In the first instance, concerns can be raised in writing with the People Ops Manager or CEO. Concerns can also be raised to relevant prescribed bodies under national whistleblowing legislation.

Child Labour & Modern Slavery

We have zero tolerance for suppliers of goods and services, including in relation to child labour, inhumane treatment of employees and forced or compulsory labour.

We protect FundApps

Gifts

It is the nature of global business that we may give or receive gifts as part of maintaining relationships with our clients, suppliers and partners. Employees are to:

• Use sound judgment and comply with the law, regarding gifts and other benefits

• Never allow gifts, entertainment or other personal benefits to influence decisions or undermine the integrity of business relationships

• Never accept gifts or entertainment that are illegal, immoral or would reflect negatively on the company

• Never accept cash, cash equivalents, stocks or other securities

Employees may accept occasional unsolicited personal gifts of nominal value such as promotional items and may provide the same to customers and business partners.

Conflict of Interest

When you are in a situation in which competing loyalties could cause you to pursue a personal benefit for you, your friends, or your family at the expense of FundApps or our clients, 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 FundApps. If the answer is "yes," the action you're considering is likely to create a conflict of interest situation, and you should avoid it.

There are seven common areas where conflicts of interest can arise:

• Personal investments

• Outside employment, advisory roles, board seats, and starting your own business

• Business opportunities found through work

• Inventions

• Friends and relatives; co-worker relationships

• Accepting gifts, entertainment, and other business courtesies

• Use of Google products and services

In each of these situations, the rule is the same – if you are considering entering into a business situation that creates a conflict of interest, don't. If you are in a business situation that may create a conflict of interest, or the appearance of a conflict of interest, review the situation with your manager and People Ops. In most cases, a plan can be put in place to mitigate any actual or perceived conflict of interest. Finally, it's important to understand that as circumstances change, a situation that previously didn't present a conflict of interest may present one.

Confidentiality & Privacy

We respect the privacy of our clients, employees and others with whom we conduct business, and we handle their personal information with care. "Personal information" is any information that could be used to identify someone, either directly or indirectly, such as a name, email address or phone number. There are data privacy laws that prescribe how to responsibly collect, store, use, share, transfer and dispose of personal information, and we strive to comply with those laws everywhere we operate.

Please familiarise yourself with the FundApps Privacy Policy and our Information Security Policies and ensure you follow our policies and protect any personal information that is entrusted to you. Use it only in the way it's meant to be used, don't share it with anyone inside or outside of the company in an unauthorised manner, and ensure our networks, equipment, programs and data are protected from attack, damage or unauthorised access. The individual and business consequences of data and security breaches can be severe and we all have a responsibility to protect FundApps, our clients and the data we process.

We do good

Environment

Goodness matters! In everything we do, we strive to do it in an environmentally responsible manner and hold ourselves accountable for compliance with all applicable environmental laws and regulations. Whilst our environmental footprint is not big, we all have a role to play and we are committed to actions that minimise our environmental footprint by reducing energy use in our offices, decreasing waste, only using water when we absolutely have to, and avoiding one-time plastic usage and printing like the plague!

Consider this commitment in everything you do, from how you dispose of waste, to purchasing environmentally friendly products in our physical and home offices. Where there is an opportunity to minimise our footprint as a company, or your own as an employee of FundApps, please take it.

Purchasing

Whilst we may be a small company, FundApps believes in purchasing any items it requires for day-to-day operations of our business from local suppliers or suppliers owned by people from minority backgrounds. This forms part of our commitment to our local communities and doing good as a company beyond the profits we make.

It's what we stand for

FundApps is committed to being a company that does good by our people, our clients and our community. We rely on one another's good judgment to uphold a high standard of integrity for ourselves in everything we do, and we expect all FundAppers to be guided by both the letter and the spirit of Our Code. Sometimes, identifying the right thing to do isn't an easy call. If you aren't sure, don't be afraid to ask questions of your manager or People Ops.

And remember… if you see something that you think isn't right – speak up!