Code of Conduct

SECTIONS

The work of Charles and Lynn Schusterman Family Philanthropies and related entities (“us” or “we”) is grounded in our founders’ commitment to Jewish values and ethics, including the pursuit of justice (tzedek), repairing the world (tikkun olam), and treating all people with civility and humanity (derekh eretz).

These beliefs inform our core organizational values of equity, impact, optimism, humility, and collaboration. Inspired by these values, we are committed to creating a safe, respectful, equitable, and inclusive environment for all individuals, regardless of age, race, ethnicity, ability, religion, national origin, physical appearance, sexual orientation, gender identity, or gender expression.

We recognize that no community, including our own, is immune from instances of misconduct, so we crafted this Code of Conduct (“Code”) as part of our effort to create environments that honor the dignity and promote the safety of all people.

Our Code is a general guideline of our expectations. At any time, we may amend this Code, add new expectations, or impose other consequences. If you have any questions, please contact our Chief Talent Officer, Abby Saloma, at [email protected].

Who This Code Applies to:

This Code applies to “you” in connection with our “Activities,” where:

“you” means all our employees, vendors, participants, volunteers, community members, and guests; and
“Activities” means all our work/employment activities as well as any events, communities, communication platforms, or other activities that we organize or operate.

You are both bound to comply with our Code and are also afforded the protections of our Code with respect to all our Activities. Note: We may limit or cease our association with you based on actual or alleged conduct that violates this Code in ways inconsistent with our values, even if such conduct is not associated with our Activities.

What Conduct is Prohibited:

We expect you to use good judgment to uphold the highest professional, ethical, and respectful standards. In particular, you will violate our Code if you . . .

Do anything that violates the law, such as:

Cause any activity that is illegal or inflicts personal injury or property damage.
Post or distribute material infringing or violating the rights of a third party or any law.
Impersonate any person or entity, or falsely misrepresent your affiliation with them.
Cause a person to consume any drug, alcohol, or other substance without their knowledge and consent.

Do anything that creates an unsafe, harassing, or discriminatory environment such as:

Engage in any sexual contact without expressed affirmative and voluntary agreement (only “yes” means yes). It is a violation of this Code for any employee or vendor to engage in sexual contact with a participant during any Activity (even with consent).
Defame, abuse, harass, harm, or threaten others or make any discriminatory, bigoted, hateful, or racially or sexually offensive statements.

Engage in harassment, including but not limited to:

Offensive or hurtful comments regarding age, race, ethnicity, ability, religion, national origin, physical appearance, sexual orientation, gender identity, or gender expression.
Intimidation or stalking.
Unwelcome physical contact or sexual attention.
Harassing photography or recording of another person.
Distribution of any image or language that is vulgar, obscene, discourteous, defamatory, or indecent.
Distribution of any image that involves a person without their consent if a reasonable person would not want it distributed.
Sustained disruption of talks or other events.
Threats of physical harm.
Advocating for, or encouraging, any of the above behavior.

Do (or fail to do) anything that impacts your participation in our Activities, such as:

Deviate from planned group programming and itinerary without permission.
Not truthfully follow any Activity application/registration requirements.
Not follow any applicable policies, procedures, or instructions.
Engage in the excessive use of alcohol or other mind/body-altering substances.
Allow an unauthorized person to access our Activities or any private or confidential info.
Use information about our community members for any reason except as a part of our Activity or to contact a member.
Excessively use our community for the benefit of your business/venture.
Fail to speak up if you see or suspect a violation of this Code or other misconduct.
Fail to cooperate with an investigation or make a false statement regarding a violation of this Code.
Retaliate against a person who in good faith reports or provides information about a violation of this Code.

How to Report Misconduct:

We recognize that reporting an incident may be upsetting or uncomfortable, but you need to report violations of this Code with our assurance that you will not be asked to return to an unsafe or unwelcoming environment and that we will maintain the level of confidentiality as is appropriate for the circumstances. Anyone who experiences, becomes aware of, or suspects harmful acts, harassment, or other violations of our Code should report the incident immediately.

There are several ways to report misconduct, and you should choose the reporting channel(s) that feels right for you. The report may be made to any one or more of:

Your immediate supervisor (employees only)
Your team’s director (employees only)
Our onsite lead staff member(s) or the person designated for the particular Activity.
Abby Saloma, Chief Talent Officer, at [email protected]
Mike Redman, Assistant General Counsel, at [email protected]
Anonymously to Lighthouse Services, our third-party, 24/7/365, reporting hotline by:
- Email at [email protected]
- Telephone in the USA or Canada at 866-220-0005, para Español 800-216-1288
- Telephone in all other countries at 800-603-2869 (dial country access code first)
- Website portal at www.lighthouse-services.com/schusterman

When making a report, please provide as much detail as possible, and to the best of your knowledge, include the following information:

Names of the individuals involved
Names of any witnesses
When and where the incident occurred
A description of what happened
Any other information that will help us understand and address the incident

If you have reported misconduct and feel the matter is not being adequately addressed—or if you believe you have suffered retaliation for reporting a violation of this Code—please report the matter to Abby Saloma at [email protected] and/or Mike Redman at [email protected].

Any employee becoming aware of an actual or potential threat to the personal safety of anyone associated with our Activities should immediately take reasonable action to protect such person’s safety. If the situation requires additional security, the employee should enlist local law enforcement or other services to ensure the safety and wellbeing of all involved (including the victim as well as the responding employee). All employees receiving a report of misconduct (whether credible or not) must report the matter to [email protected] and [email protected].

What We Will Do If We Receive a Report:

We are committed to take all reports seriously and to:

Not tolerate violations of this Code, false accusations, or retaliation. For employee-related matters, the Talent & HR Team will be responsible for overseeing the process.
Conduct a preliminary investigation into the matter.
Scale any investigation into the circumstances based on the nature of the matter and availability of evidence, which may include the use of an external investigator.
Provide as much confidentiality as appropriate for the circumstances.
Make a reasonable evaluation of the allegation(s) based on the information obtained, including the credibility of witnesses.
To the extent we deem appropriate, in our sole discretion, inform the reporting person or other involved persons of any action we may take.

What Happens If This Code Is Violated:

Anyone asked to stop unacceptable behavior must comply immediately. Violation of this Code by anyone will not be tolerated. If we determine that this Code has been violated, we may take some or all of the following actions:

Require training related to the violation (employees and vendors only).
Impose disciplinary actions up to and including termination of employment or contracts (employees and vendors only).
Direct the offender to cease the behavior and warn that we’ll sanction
further violation.
Require the offender to avoid any interaction with or proximity to the complainant.
Require the offender to immediately leave the Activity and not return (without a refund).
Ban the offender from some or all our Activities and communication platforms.
Remove the offender from our communities.