Introduction
Lifted Solutions LLC is committed to maintaining a culture of integrity, respect, and accountability. This Code of Business Conduct and Ethics (the “Code”) provides guidance to help all of us make ethical decisions and uphold our values in our daily work. It applies to everyone at the Company, including all employees, contractors, vendors, service providers, officers, directors, and Hybrid Team Members, regardless of position or location. We expect everyone who works with or represents the Company to understand and follow these standards.
While this Code covers a wide range of business practices and workplace conduct, it cannot address every situation. We rely on each other’s good judgment to uphold the spirit of the Code. When in doubt, ask questions and raise concerns.
You are encouraged to seek advice from managers, Human Resources, the Legal team, or any Ethics Advisor whenever you face an ethical dilemma or are unsure about the proper course of action. Remember that no matter our role, we are all responsible for doing the right thing and maintaining the trust of our colleagues, clients, and community.
Our values
Trust
Excellence
Innovation
Ownership
Curiosity
Our working principles
Do what it takes to win.
Take ownership and follow through.
Be bold in curiosity.
Raise the bar together.
Lift others up.
Compliance with Laws
The Company operates in a highly regulated environment and in many different countries and communities. We must follow all applicable laws and regulations, both domestic and international, wherever we do business. This includes, but is not limited to, laws regarding employment and labor, data privacy, workplace safety, anti-corruption, insider trading, competition, antitrust, and trade sanctions. If you are ever unsure about a legal requirement or regulation, please consult the Legal team. Following the law is the minimum – we strive to go beyond mere compliance by always acting with honesty and integrity.
Violations of this Code or any applicable law or policy can have serious consequences. They may result in disciplinary action, up to and including termination of employment or contract, and even legal penalties. No one, regardless of their position, is exempt from these obligations or has authority to order someone else to violate the Code.
Raising Concerns and Reporting Misconduct
We foster a culture where everyone should feel safe and empowered to raise concerns or ask questions without fear. If you see or suspect any conduct that may violate this Code, Company policy, or the law, raise the issue promptly. Reporting issues helps the Company address problems early and protect our community.
You have several options for reporting a concern or seeking guidance:
Ethics team
Our Ethics Advisors and Compliance Officer. Email us, or reach out directly on Slack.
Ethics Hotline
Powered by Ethena. Report by name or anonymously, your choice.
Someone you trust
Any member of the Leadership Team, HR, or Legal.
By letter
Marked “Attention: Compliance Officer” and addressed to:
Lifted Solutions LLC, 201 W 5th St, #1600, Austin, TX 78701
The Company will take any concerns you report seriously. We will investigate all reports of suspected misconduct thoroughly, fairly, and as promptly as possible. We strive to keep reports and investigations confidential to the extent possible, sharing information only with those who need to know in order to address the issue. However, we cannot guarantee absolute confidentiality or anonymity as some disclosure may be required to complete a full investigation or as part of remediation efforts.
If you are involved in an investigation, we expect you to cooperate by providing truthful and complete responses to investigators. The Company’s investigators will conclude all investigations in a timely manner, though the exact time to close the investigation will depend on the extent of the required investigation.
Remember, there is no penalty for raising a concern in good faith, even if it turns out not to be an issue. The Company would rather you speak up about a potential problem than stay silent and allow possible misconduct to continue. See the Whistleblower Policy for more information on reporting channels and our commitment to protecting those who report issues.
No Retaliation
We do not tolerate retaliation against anyone who raises a concern, reports misconduct, or participates in an investigation in good faith. Retaliation means any form of adverse action taken against someone for doing the right thing, such as demotion, harassment, unfair discipline, or termination. Engaging in retaliation is a serious violation of this Code and will result in disciplinary action.
If you believe you or someone else has experienced retaliation, report it immediately through any of the channels above. All claims of retaliation will be investigated and, if substantiated, addressed promptly. We are committed to maintaining an environment where everyone feels safe to report concerns. Simply put: raising ethical or legal issues is a protected action, and the Company will protect and support those who do the right thing.
Diversity, Inclusion, and Equal Opportunity
We are proud to embrace diversity and promote a culture of inclusion and belonging. The Company provides equal opportunity in all aspects of employment and business dealings. This means we do not discriminate on the basis of any protected characteristic, such as an individual’s actual or perceived age, ancestry, race (including hair texture, hair type or protective hairstyles commonly or historically associated with race), color, national origin, sex, pregnancy (including childbirth or medical or common conditions related to pregnancy or childbirth, past pregnancy condition, and the potential or intention to become pregnant), gender, gender identity or expression, religion/religious creed, disability, medical condition, legally protected genetic information (including test results), marital status, protective order status, military or veteran status (including unfavorable discharge from military service), sexual orientation, citizenship status, certain arrest or criminal history records, homelessness (i.e., lack of a permanent mailing address or a mailing address that is a shelter or social services provider), or any other characteristic protected by applicable law. Decisions about hiring, promotions, compensation, and working conditions are based on qualifications, performance, merit, and business needs, never on bias or prejudice.
Each of us shares responsibility for creating a respectful and inclusive environment. Be mindful and respectful of each other’s differences and perspectives. Practice inclusion by ensuring colleagues and partners feel valued and heard. If you witness or experience any form of discrimination, speak up and report it to a manager, HR or the Legal team. The Company will promptly address such concerns. (For more detail, employees may refer to our Equal Employment Opportunity and Anti-Discrimination policies in the Employee Handbook.)
Harassment and Bullying
Everyone deserves to work in an environment that is free from harassment and bullying. Lifted Solutions strictly prohibits any form of harassment, whether verbal, physical, visual, or sexual, as well as any bullying behavior. Harassment can include unwelcome comments or jokes, slurs or offensive remarks, inappropriate touching or physical intimidation, displaying or sharing offensive material, or any conduct that creates a hostile or offensive work environment. Sexual harassment, such as unwanted advances, requests for sexual favors, or other unwelcome conduct of a sexual nature, is expressly forbidden. Bullying refers to repeated mistreatment, abuse of power, or any behavior intended to intimidate, humiliate, or demean another person.
We must all treat each other with professionalism, dignity, and respect. No matter the pressure or deadlines we face, there is never an excuse for harassment or bullying. Managers and leaders have a special responsibility to lead by example and to address any inappropriate behavior they observe or that is reported to them. If you feel harassed or bullied, or if you observe such behavior toward someone else, report it as soon as possible to HR, a manager, or a member of the Legal team. The Company will investigate and take appropriate action. And remember, the Company prohibits retaliation, so you can raise concerns without fear.
Accommodations and Accessibility
We are committed to providing a supportive workplace for everyone, including those with disabilities or special needs. The Company will provide reasonable accommodations to qualified individuals with disabilities, as well as to those with needs related to religion or other protected characteristics, in accordance with applicable laws. An accommodation is a change in the work environment or in the way things are normally done to help an individual perform their job or enjoy equal opportunities.
If you believe you need an accommodation, inform your manager or Human Resources representative. We will work with you to evaluate requests promptly and fairly. We respect the privacy of anyone requesting an accommodation and will handle such matters with sensitivity. No one will be treated unfavorably for requesting an accommodation. Policies and processes for accommodations may vary by region, but our commitment to an inclusive workplace is global and unwavering.
Safe and Healthy Workplace
Lifted Solutions is dedicated to maintaining a safe, secure, and healthy work environment. All of us share responsibility for following safety and security procedures and for watching out for one another’s well-being. This includes obeying all workplace health and safety laws and regulations, as well as any Company policies related to safety.
Violence or threatening behavior is not tolerated. This includes not just physical assaults, but also threats, intimidation, or any acts of aggression. Weapons are not allowed on Company premises or at Company events. If you ever feel unsafe or witness any violent or threatening situation, remove yourself from danger and report it immediately to Security, HR, or management.
As a fully remote company, we recognize that your home or chosen workspace is your primary office. No matter where you work, we are committed to ensuring every team member has a safe, healthy, and productive work environment. In a remote setting, “workplace safety” means paying attention to both your physical setup and your personal well-being.
Set up a safe & ergonomic workspace
A proper desk and chair, adjustable to your needs. Monitor at eye level, at a size and resolution that won’t strain your eyes. Walkways clear of tripping hazards, cords and equipment secured safely.
Prioritise your health & well-being
Working remotely doesn’t mean always being available. Take regular breaks, pace your workday, and use your vacation days. Mental health is a key part of a safe workspace.
Stay connected and raise concerns
Unsafe conditions, tech issues or well-being concerns — let your manager or HR know. Open communication keeps our remote work culture supportive and safe.
Your safety and well-being matter. By taking small, proactive steps, you help ensure your workspace is safe and your workday is sustainable – wherever you’re located. Remember: no project or deadline is worth compromising safety.
Alcohol and Drug Use
We expect everyone to be responsible with alcohol and drugs to ensure a safe and productive work environment. Working while impaired by alcohol or drugs is unsafe and unacceptable. Illegal drugs are never allowed on Company premises or at any work-related event. The use, sale, purchase, or distribution of illegal substances in connection with work is strictly prohibited.
Moderate and responsible alcohol consumption may be permitted at certain Company-sponsored events or social gatherings, but it is never okay to overindulge or to pressure others to drink. If alcohol is available at a work event, always ensure that only those of legal drinking age partake and that non-alcoholic options are also available. Use good judgment; intoxication at work or at a work event is not acceptable.
If you are taking prescription or over-the-counter medications that could impair your abilities, notify your manager or HR if you need a temporary adjustment to your duties. We want everyone to stay safe.
Lifted Solutions cares about the well-being of its team members. If you struggle with substance abuse or addiction, we encourage you to seek help. Asking for help will not be held against you. However, misconduct or unsafe behavior resulting from substance misuse will be addressed appropriately. If you suspect a colleague’s substance use is creating a safety risk, please speak up.
Human Rights and Fair Labor
We respect and uphold fundamental human rights in all our operations. Lifted Solutions is firmly opposed to human trafficking, forced labor, child labor, and any form of involuntary servitude. We only work with individuals and organizations who choose to work freely, and we expect the same commitment from our contractors, vendors, and suppliers. We comply with all applicable labor and employment laws, including wage and hour laws, and we strive to provide fair working conditions.
All team members must be of legal working age for their role and location. We do not tolerate exploitation or abuse of labor rights. If you become aware of any human rights abuse or unethical labor practice connected to the Company’s business, whether within our organization or in our supply chain, report it immediately. We are committed to doing business in a way that respects the dignity and worth of all people.
Conflicts of Interest
We must avoid conflicts of interest or even the appearance of a conflict. A conflict of interest arises when your personal interests, financial, familial, or otherwise, interfere, or could appear to interfere, with the interests of the Company. In other words, you should not allow any personal relationship or gain to influence your judgment in doing what’s best for the Company.
Common examples of potential conflicts include:
Outside employment or business ventures: Working for, consulting with, or aiding a competitor or business partner of the Company, especially during your employment with the Company, can pose a conflict. Always ensure any secondary job or business activity is approved and does not interfere with your duties here.
Personal relationships at work: A conflict may occur if you supervise, or have influence over, someone with whom you have a close personal relationship (such as a family member or romantic partner). Such situations should be disclosed to HR so we can adjust reporting lines or duties to avoid favoritism or bias.
Investments or financial interests: Having a significant financial interest in a competitor, customer, or supplier could affect your objectivity. You should disclose such situations to the Company. Owning small amounts of stock in large public companies is generally fine, but larger or influential interests are problematic.
Gifts and entertainment: Accepting or offering gifts, meals, or entertainment can create conflicts, especially if they are excessive or intended to influence a business decision. (We discuss guidelines on gifts in the next section).
When faced with a potential conflict of interest, disclose it to your manager, HR (hr@go-lifted.com), the Ethics team (ethics@go-lifted.com), or the Legal team (legal@go-lifted.com) so it can be reviewed and resolved. Often, simple steps can mitigate a conflict once it’s known. The key is transparency. Never let personal benefits for yourself, friends, or family compromise your objectivity or the trust others place in you. If you’re not sure whether something is a conflict, err on the side of openness and ask.
Gifts and Entertainment
Business gifts and hospitality can build goodwill, but they must be reasonable and never compromise our integrity. You should never offer, give, solicit, or accept any gift, favor, or entertainment if it is intended (or could appear intended) to improperly influence a business decision or reward someone for improper behavior.
What is acceptable? Modest tokens of appreciation, promotional items, or occasional business meals of reasonable value are generally fine, as long as they are infrequent and not extravagant. Lavish or frequent gifts, expensive trips or tickets, cash or cash equivalents, or anything that would embarrass the Company if made public are not okay. If you are unsure whether a gift or invitation is appropriate, seek guidance from HR or Legal team before giving or accepting it.
Soliciting or accepting payments, gifts, loans, favors, or preferential treatment (referred to here as a “thing of value”) for yourself, your family member, or anyone living in your home, from any person or entity that does or seeks to do business with us except as described in this bullet. You may never accept or offer a thing of value in exchange for preferential treatment of the entity or person.
In order to offer or accept a thing of value under the Code without prior approval, the thing of value must both:
No approval needed
Both of these must be true:
Worth less than $200
Consistent with customary U.S. business practice: a reasonable meal with a client or prospect
Written approval from an Ethics Advisor
Ask first if either of these applies:
Exceeds $200 in value
Not consistent with customary U.S. business practice
The $200 figure is cumulative
Combine it with the value of anything else offered to or received from the same person or entity in the prior 12 months.
Special care must be taken with government officials. Offering anything of value to a government official or their family members is often illegal and tightly regulated. Even a small gift or favor can be misconstrued. If your job involves interactions with government entities, make sure you know and follow the strict rules that apply, and always get Legal approval before providing any gift, meal, or entertainment to a public official.
Remember, even the appearance of a bribe or kickback can damage our reputation and violate the law. When in doubt, don’t proceed or consult Legal. By keeping gifts and hospitality reasonable and transparent, we avoid conflicts and uphold our reputation for fair dealing.
Protecting Confidential Information and Intellectual Property
Our ideas, innovations, and business information are valuable assets. Every team member has a duty to protect the Company’s confidential information and intellectual property (IP). Confidential information includes non-public information that might be useful to competitors or harmful to the Company or our clients if disclosed. This can include business plans, pricing data, financial results, customer or vendor lists, engineering designs, source code, marketing strategies, and any other sensitive or proprietary information.
Use confidential information only for Company purposes. Do not share it with anyone outside the Company unless they have a legitimate need to know and have signed an appropriate nondisclosure agreement (NDA).
Secure information properly. Follow Company security policies when handling sensitive data. For example, use strong passwords and approved tools, encrypt data if required, and be mindful of where and how you discuss Company business. Avoid discussing confidential matters in public places or on unsecured channels. Keep sensitive documents and devices secure, and dispose of confidential materials by shredding or using approved secure deletion methods.
No unauthorized disclosures. Within the Company, only discuss confidential matters with colleagues who need the information for their work. Do not gossip or share sensitive info with friends or family. Never post or share internal information on social media or public forums.
Company intellectual property: Any work product you create for the Company, such as inventions, code, designs, content, or trademarks, is the property of the Company. We respect and protect our IP rights. Similarly, we must not knowingly infringe on the IP rights of others. Do not bring any confidential or proprietary material from a former employer or another party to use at the Company, and do not use anyone else’s trademarks, copyrighted material, or patented ideas without permission.
If you leave the Company, you remain obligated to keep the Company’s confidential information confidential. You may not take Company confidential information or IP with you for use elsewhere. Likewise, if you join us from another company, we expect you to honor your obligations not to use or share your previous employer’s confidential information.
If you suspect that confidential information has been lost, stolen, or improperly disclosed (for example, a lost laptop or a possible data breach), report it immediately to the IT/security team or Legal. Protecting our information is everyone’s responsibility.
Employees should refer to their Invention Assignment and Confidentiality Agreement for more information on their obligations and responsibilities with respect to the Company’s Intellectual Property. HWS team members should refer to their Independent Contractor Agreements or Employment Agreements, as applicable, for more information about their obligations and responsibilities.
Privacy and Personal Data
In the course of our business, we often access or handle personal information about individuals, whether they are customers, users, freelancers, or fellow team members. We must respect privacy and protect personal data in accordance with the law and our policies. Personal data means any information that can identify a person or that is about an identifiable person (for example, names, contact details, accounts, identification numbers, financial information, or any sensitive personal details).
Only collect, access, use, or share personal data for legitimate Company business purposes and only if you are authorized to do so. Do not access personal data that you don’t need for your job. For example, curiosity is not a valid reason to look up a user’s account information; you must have a work-related need.
We have implemented policies and security measures to safeguard personal data (see the Privacy Policy and Information Security policies for details). You are expected to follow those rules closely. This includes using approved secure systems to store data, keeping personal data only as long as necessary, and sharing it externally only with authorized parties under proper agreements. Never transfer or disclose personal data to third parties without proper authorization.
If you become aware of a possible data breach or any loss, theft, or unauthorized disclosure of personal information, report it immediately to your manager, Information Security, or the Legal team. Quick reporting allows us to mitigate any harm and fulfill any legal notification requirements.
Maintaining privacy is essential to preserving trust. Each of us is responsible for handling personal information with care and in compliance with applicable data protection laws.
Insider Trading
It is absolutely critical that we uphold insider trading laws. Insider trading means buying or selling stocks or other securities while aware of material information that the public doesn’t have, or tipping others to trade based on such information. It is illegal and strictly against Company policy.
Material non-public information (often called “inside information”) could include, for example, unreleased financial results, important business deals or partnerships, product launches, changes in leadership, plans for mergers or acquisitions, or any other information that a reasonable investor would consider important when deciding to buy or sell a company’s stock. If you learn such information about any other company in the course of your work, you must not trade that company’s securities until the information has been made public and enough time has passed for the market to absorb it. Similarly, never give others tips or hints that enable them to trade on inside information.
All Company personnel must comply with insider trading laws and the Insider Trading Policy. If you are unsure whether information you have is “material” or whether a planned trade is allowed, stop and ask the Legal team before proceeding. For the avoidance of doubt, placing bets or wagers on prediction markets based on material non-public information may be considered insider trading and is prohibited under the Insider Trading Policy and this Code. The rules on insider trading apply to information about our parent company, clients, partners, or any other company you may learn about through your work. Violations can lead to severe civil and criminal penalties for both individuals and the Company, as well as internal disciplinary action.
In short: Never trade on confidential information or share it with others. Always play it safe and seek guidance if you have any doubts.
Anti-Bribery and Anti-Corruption
We conduct our business with honesty and integrity, and we never engage in bribery or corruption in any form. Anti-corruption laws, such as the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, and others, prohibit giving or receiving anything of value to improperly influence a decision or gain an unfair business advantage. This applies to dealings with government officials and with people in the private sector.
Do not offer, give, solicit, or accept bribes or kickbacks. A bribe can be more than just cash; it might be lavish gifts, excessive entertainment, inflated commissions, charitable donations directed by a customer, favors, or any benefit given with a corrupt purpose. Even so-called “facilitation payments” (small payments to speed up routine government actions) are generally prohibited. We win business based on the quality of our services, never through unethical payments.
Be especially cautious in interactions with government officials or agencies. Many countries have strict rules regarding providing even nominal gifts or hospitality to government employees and breaking those rules can carry severe penalties. If your work involves potentially giving gifts or anything of value to a government official, you must get approval from the Legal team beforehand. Strictly follow our policies on government interactions.
The Company’s stance is simple: zero tolerance for corruption. We also expect our vendors, contractors, and partners to uphold similar anti-corruption standards. If you are asked to pay a bribe, or if you suspect any form of corrupt activity related to the Company’s business, report it immediately to the Compliance or Legal team. (See the Anti-Corruption Policy for additional guidance, if available.) Remember that violating anti-bribery laws is a serious offense that can result in fines and even jail time, in addition to disciplinary action.
Fair Competition and Antitrust
We believe in competing fairly and complying with all antitrust and competition laws. These laws are designed to promote a healthy, competitive marketplace and to protect consumers. All team members must avoid any activities that improperly restrain trade or violate antitrust laws.
This means:
No anti-competitive agreements with competitors. Never agree with competitors, formally or informally, to fix prices, rig bids, divide markets or customers, limit production, or refuse to deal with certain suppliers or clients. Even casual conversations with competitors can be risky; avoid discussing sensitive topics like pricing, sales volumes, costs, marketing plans, or other non-public business strategy with them.
Treat customers and partners fairly. Do not engage in deceptive practices or unfair methods of competition. We should always compete on the merits of our services. Do not disparage competitors with false information or sabotage their business.
Gather competitive information lawfully. It’s acceptable to collect information from public sources like websites, published articles, or industry reports. However, do not steal trade secrets, misrepresent yourself, or induce current or former employees of other companies to divulge confidential information. If a third party offers confidential or proprietary info about a competitor, decline and let Legal know.
Be careful in trade association meetings or industry events. These can be legitimate forums for collaboration on industry issues, but they also pose antitrust risks if not managed properly. If a discussion at an industry meeting veers into anti-competitive territory (e.g. “Maybe we should all agree to charge the same fees”), you must object, leave the discussion, and report it to Legal.
Antitrust laws are complex, and violations can carry severe penalties for both the Company and individuals involved. When in doubt about whether a practice might be anti-competitive, seek guidance from the Legal team. Our goal is to win business ethically, never by breaking the rules of fair competition.
External Communications and Social Media
In our connected world, how we communicate publicly matters. To ensure our messaging is consistent and accurate, only authorized spokespeople should speak on behalf of the Company or any of its parents, affiliates, or subsidiaries, to the media, investors, or in any public forum. If you receive an inquiry from a journalist, analyst, or blogger, refer them to the Communications team rather than responding on your own, unless you are specifically authorized to do so.
When using social media or other public communication platforms, even on your personal accounts, use good judgment and follow our standards:
Be respectful and professional. Our commitment to respect, inclusion, and integrity applies online just as it does at work.
Make it clear when opinions are your own. If you discuss work or industry topics on social media, you should clarify that you’re speaking in a personal capacity, not on behalf of the Company. For example, you might use a disclaimer in your profile or posts (e.g., “Opinions are my own”).
Protect confidential information. Never share non-public Company information, sensitive business data, or personal information about colleagues or customers on social media or any public forum. Even if you think a forum is private, once information is online, it can spread.
Don’t use social platforms to engage in harassment, hate speech, or any unlawful activity. Also, avoid arguing with customers or former employees online in a way that escalates negativity. Instead, report significant issues to the appropriate team internally.
If you see misinformation or negative posts about the Company that concern you, alert the Communications team. Do not feel that you must respond on the Company’s behalf. By being thoughtful about our communications, we protect our reputation and avoid unintended errors.
Protecting Company Assets
Beyond information, we also must protect the Company’s assets and resources. This includes both physical assets like office facilities, equipment, computers, and supplies and intangible assets like funds, accounts, network access, and Company time.
Use Company assets for legitimate business purposes. Limited personal use of certain resources, such as email or phone, is permitted, but it should be minimal, lawful, and not interfere with your work. Never use Company assets for personal gain or any improper purpose.
Be vigilant to prevent theft, loss, damage, or misuse of Company property. Keep your computer and devices secure. Protect access credentials like badges and passwords and never share your passwords or leave sensitive systems unattended. Follow IT and security guidelines for using Company networks and equipment. For example, do not install unauthorized software or copy Company data to unapproved personal devices.
All Company funds and financial assets must be used and recorded appropriately. Never maintain off-the-books accounts or unrecorded funds for any reason. If your role involves spending Company money or managing budgets, ensure that every expense is proper, approved, and documented with accurate records and receipts.
Remember that any Company asset or resource you use is provided to help you do your job. Treat these assets with care and responsibility, and report any loss or misuse of assets to management. Wasting or abusing Company resources ultimately hurts all of us.
Accurate Record-Keeping and Financial Integrity
Honest and accurate record-keeping is essential to our credibility and success. We must ensure that all Company books, records, and financial reports are complete, timely, and accurate. This applies to all business records – including financial statements, expense reports, time sheets, contracts, invoices, and any other documents that reflect business activities.
Always record transactions in accordance with our accounting policies and legal requirements. Do not hide, alter, or falsify entries to make results look better (or worse) than they truly are. Misrepresenting facts or numbers in a report or record is a serious violation of our trust and may be illegal.
Key principles to follow:
No false or misleading entries. Never create records that are intentionally inaccurate or that mislead those who rely on them. For example, don’t record personal expenses as business expenses, don’t overstate or understate sales or revenues, and don’t defer or accelerate costs improperly.
Follow internal controls. The Company has internal controls, like approval processes and audit requirements, to help ensure accuracy. Understand the controls relevant to your role and follow them. If you’re supposed to obtain approval for a transaction or use a specific system to record data, do so.
Cooperate with audits and investigations. Provide both internal and external auditors and regulatory officials with full and truthful information. Do not withhold or tamper with information. If you are aware of an error or discrepancy, disclose it – don’t cover it up.
Retention of records. Keep and destroy records according to our record retention policies and applicable law. Never destroy documents that are relevant to an impending lawsuit, investigation, or audit. If you’re instructed via a “legal hold” to preserve certain records, you must do so.
By maintaining accurate records and financial integrity, we uphold the trust of our owners and stakeholders, comply with our legal obligations, and make informed business decisions. If you suspect any fraud, accounting irregularities, or other wrongdoing related to our financial records, report it immediately. Such issues are also covered under our Whistleblower Policy. The Company will not tolerate fraud or dishonesty in record-keeping.
Political Activities and Contributions
From time to time, Lifted may face political challenges and engage in the political process by making contributions to support candidates and supporting or opposing certain ballot measures. The laws regarding corporate political contributions are complex and vary by city, state, and country. To minimize the chance of a violation, only the Chief Legal Officer has, and certain individuals they designate have, the authority to approve political contributions on behalf of Lifted Solutions.
Political contributions are not limited to cash donations. Paying for a public official or candidate to attend an event or to use Upwork resources (e.g., computers, supplies, employee time, etc.) to support a campaign could also be considered improper political contributions.
Employee Rights and Protections
This Code is a statement of fundamental principles, policies, and procedures that govern the conduct of Lifted Solutions team members, other consultants and independent contractors, vendors, and service providers in the conduct of Company business. It is not intended to and does not create any legal rights for any user, partner, supplier, vendor, competitor, stockholder, or any other non-employee or entity.
The Code does not restrict employees’ rights to engage in concerted activities regarding wages, hours, or working conditions as protected under Section 7 of the National Labor Relations Act. It also does not prevent employees from reporting concerns, filing complaints, providing information, or participating in investigations with agencies like the EEOC, NLRB, SEC, or other federal, state, or local enforcement bodies.
Conclusion and Acknowledgment
Our Code of Business Conduct and Ethics is more than just a document. It’s a commitment we make to each other and to our stakeholders, including our users, customers, and communities, to conduct ourselves with integrity. Thank you for taking the time to read and understand this Code. Upholding these principles is essential to our success and to fostering a workplace we can all be proud of.
Living by this Code is an ongoing effort. If you have questions or face ethical dilemmas, remember the resources available. Talk to your colleagues, managers, HR, or the Legal team. We are all accountable for following the Code and for speaking up if something isn’t right.
By working at or with Lifted Solutions, you are agreeing to uphold these standards. Let’s all work together to keep our culture honest, inclusive, and respectful. By doing so, we protect each other, build trust with our clients and users, and ensure the long-term success and reputation of the Company.
Acknowledgment: You may be required to sign an acknowledgment confirming that you have read this Code, understand it, and agree to follow it. From time to time, you may also be asked to reaffirm your commitment and complete training related to the Code. These steps help reinforce our shared commitment to ethical conduct.
Waivers and Amendments
Normally, there should be no need for exceptions to the standards outlined in this Code. In rare circumstances, however, a waiver might be considered. Any waiver of this Code for a director or executive officer of the Company may be made only by the Company’s Board of Directors (or a committee of the Board comprised of disinterested directors) and will be documented as required by law. Waivers for any other employees or covered persons must be approved by the Company’s Chief Legal Officer, or their designee, and should be documented in writing.
The Company reserves the right to amend or update this Code as needed to address evolving business and legal requirements. We will inform team members of any material changes, and may ask for renewed acknowledgments when changes occur. Remember, even as this Code may be updated, our fundamental commitment to honesty, integrity, respect, and ethical behavior remains constant.