Code of Conduct

A CULTURE OF EXCELLENCE

Our Core Values

At GRRI, we are committed to fostering and maintaining a culture based on our three core values: Respecting Others, Creating Enterprise Value and Delivering Excellence in Everything We Do

Living these values means, above all, conducting ourselves and our business activities in accordance with the letter and spirit of applicable laws and regulations and Company policies, and acting with integrity to deliver exceptional risk-adjusted value. As employees, we have a shared responsibility to maintain the highest standards of ethical behavior in our dealings with our investors, business partners, neighbors and one another.

Protecting GRRI’s Reputation

GRRI’s reputation for integrity and excellence is essential to the Company’s success. This reputation is grounded in our commitment to Respecting Others, Creating Enterprise Value and Delivering Excellence in Everything We Do

One irresponsible employee or inappropriate line of software could compromise the Company’s reputation. As a result, it is every employee’s professional and personal responsibility to assess the potential impact of their actions on the Enterprise’s value. You must exercise sound judgment before approving an advertisement, product development, business practice or business partner to ensure that you will not jeopardize your reputation or GRRI’s reputation.

Our risk policy provides a framework for addressing potential risks to GRRI’s value. Enterprise value risks may be triggered by the nature of a revenue sharing transaction, a licensing business practice or by the identity or reputation of an employee, contractor or counterparty. When considering whether a particular business practice, contractor, or counterparty poses enterprise value risk, you should ask yourself whether GRRI’s reputation could be compromised by the Company’s involvement with the practice or party. If so, you must promptly escalate your concerns for management and applicable executive committee review and approval before engaging in the business, relationship or activity. Examples of red flags that may indicate enterprise value risk include:

• a distribution channel alliance partner or counterparty that is linked to data or firmware vulnerability, malware or other improper activities 

• a transaction that lacks economic substance or business purpose

• a transaction that raises significant political issues

• a transaction that raises significant suitability concerns

• a transaction that raises significant conflict of interest concerns 

Potential Business Conflicts

Potential business conflicts can arise in a number of circumstances, including between GRRI and our Business partners or between two or more Business partners. Examples include when:

• we offer products or account types to a business partner for which the Company receives greater fees or compensation than for alternative products or account types 

• we perform multiple roles with respect to a business partner and/or transaction (for example, advertising manager, digital content producer or lender)

• two business partners are interested in acquiring the same asset

• we engage in interactions with business partners or potential business partners of the Company who may also be vendors or potential vendors of the Company

You are responsible for taking appropriate action in accordance with regulatory requirements and our policies when you become aware of an actual or potential conflict. You are also responsible for bringing a potential conflict to the attention of your supervisor or a member of LCT.

Potential Personal Conflicts

You must be sensitive to any activities or situations where your personal interests may be in conflict with the interests of GRRI or our business partners. In particular, potential personal conflicts may arise in relation to your outside activities or investments, for example:

• having a personal or family interest in a transaction involving GRRI where you or a family member may derive a benefit

• serving on a board of directors that could raise potential conflicts with a business partner or GRRI

• competing with GRRI for the purchase of services

• taking advantage of business opportunities that arise because of your position at GRRI or through the use of property or information belonging to the Company 

You must avoid any investment, activity or relationship that could, or could appear to, impair your judgment or interfere with your responsibilities on behalf of GRRI and our business partners. You are also responsible for promptly notifying your supervisor or a member of LCT if any personal investment, activity or relationship (including those that involve family members, and those that may have been previously approved through the Outside Business Interests System) could give rise to a conflict of interest or the appearance of a conflict. 

In addition, be aware that certain employee-to-employee relationships, such as engaging in personal financial arrangements or developing romantic relationships with other GRRI employees, may raise potential conflict issues. In addition, you must disclose certain personal relationships with another employee to your supervisor and your HR representative.

For a complete copy of our Code of Contact please contact us at INFO@GREENRABBITCO.COM