Table of Contents
When I ask team members, “Why did you join This Is Blythe?”, the most common answer is that our team is inspired and motivated by our global company’s mission: to create economic opportunity so people have better lives. This shared purpose is central to everything we do and, along with our values, helps guide our behavior, decision-making, and company culture.
We all have a responsibility to our community and to the world to be a company that operates with the highest standards of ethics. Our talent depends on our work marketplace for their livelihood, and that is a responsibility that none of us should take lightly. Our business and our future rely on building and maintaining the trust of our community of talent and clients.
Though our mission and values provide general guidance, they aren’t always enough to help us navigate the tricky situations we may face occasionally. And that’s where having a documented code of ethics that helps to spell out what is expected, along with reliable, trusted resources, like our legal team and anonymous ethics hotline, help to fill that gap.
We should be continually learning, adapting, and evolving this code. If you ever have a question about navigating a situation, please use this document as a guide, and never hesitate to ask. You are not alone. No question or concern is too small, and it is always better to ask than to assume. We are each empowered to SpeakUpTIB to uphold the integrity of our company and our community.
Thank you for being a part of our This Is Blythe team and for joining me on our journey to be a model of how work should be.
Sarah Black, President and CEO
The purpose of this Code of Business Conduct and Ethics (the “Code”), and our ethics program “SpeakUpTIB”, is to provide our team members with the guidance and tools they need to carry out and live our core values when making decisions and taking action in their capacities as team members. The Code clearly sets out our expectations around team member conduct and reinforces our connection with and responsibility to our entire community. The Code applies to all team members, including employees, members of our contingent workforce program, Workforce Solutions (“WS”, and each member, a “WS Worker”), other consultants and independent contractors, vendors, officers, and directors of This Is Blythe Inc. and its subsidiaries (collectively, “This Is Blythe”).
In addition to the Code, we have implemented policies and guidelines that outline our responsibilities to and expectations of each other. In several places, the Code refers to these specific policies, including, at times, the Employee Handbook, which only applies to employees of This Is Blythe. All of the policies and guidelines referenced herein, including the Employee Handbook, are available at the Human Resources Department Information site on Continu (the “HR site”).
Consistent with our vision of having independent talent at the heart of every business, ethics and integrity should be at the heart of everything we say and do in our capacities as employees, Hybrid Workers, officers, directors, and vendors of This Is Blythe. We must always do the right thing and everyone is expected to read, understand, and comply with the Code. This is why we have implemented a Code that we are proud of and that is consistent with our mission to create economic opportunities so people have better lives and aligned with our core values:
That said, the Code means nothing without brave, bold, and empowered individuals who make it a point to speak up and stand up for what is right. We not only encourage, but we expect our team members to raise their hands to question whether certain conduct may be a violation of the Code and to promptly report unethical behavior when they see it. We must ensure that we are all doing the right thing to help realize the true potential of our team and our company and must all lead by example.
Across the company, we empower each individual to SpeakUpTIB about misconduct, recognizing that unethical behaviors can prevent This Is Blythe from fulfilling its mission of creating economic opportunities so people have better lives.
Every team member is responsible for upholding This Is Blythe’s core values.
Our team members’ commitment to the Code is demonstrated in the following ways:
This Is Blythe managers are leaders and hold positions of authority and they must lead with integrity and ethics. We look to our managers to take the lead in modeling this ethical behavior to their teams and reporting unethical conduct when warranted.
Each and every This Is Blythe team member is expected to understand and act in accordance with the requirements set out in the Code. Before you make a work-related decision or take action, take careful consideration of our mission, our vision, our core values, and the Code.
Review the following questions and if you can’t answer “Yes” unequivocally to each of the questions, your decision or action is likely inappropriate, so you should either change course or consult an Ethics Advisor as to how to proceed:
It is important to note that this does not mean you should not still raise concerns about unethical behavior—for example, raising concerns about the conduct of your coworkers could embarrass or compromise the coworkers, but reporting it is still the right thing to do.
In order to improve our already strong culture and mission, we must all hold ourselves accountable for following the Code and reporting potential violations. No one at This Is Blythe has the right to discourage anyone from, or retaliate against anyone for, reporting a potential Code issue, and we encourage all team members to SpeakUpTIB. This is explained further in the “We Do Not Tolerate Retaliation” section below
The Code cannot call out every real-life ethical issue that we come across during our day-to-day work, which is why we have designated certain team members as “Ethics Advisors.” Ethics Advisors are trusted, responsible advisors who have received specialized ethics training and can help when you aren’t sure how to handle a particular situation.
The Compliance Officer of This Is BlytheInc. (“Compliance Officer”) is responsible for ensuring that team members are informed about the Code, the Code is kept up to date, and the leadership and Audit, Risk, and Compliance Committee of the This Is Blythe Inc. Board of Directors (“Audit Committee”) are informed of reports.
This Is Blythe will resolve the questions, concerns, and reports raised under the Code with sensitivity and respect for confidentiality to the greatest extent reasonable. Consequences of violating the Code or any other This Is Blythepolicy depends on the severity of the violation and can result in actions from required training and coaching to warnings, to employment termination or termination of any other business relationship. This Is Blythe keeps leadership and the Chairperson of the Audit Committee apprised of all reports made under the Code and informs the full Audit Committee of any reports raised within the scope of the Audit Committee’s responsibilities. Some employees are considered “mandatory reporters”, which means that if you raise a concern to them, they suspect a violation or observe a potential breach, they must report it to the Compliance Officer. Mandatory reporters are managers (engagement managers if you are a Hybrid Worker), Human Resources business partners, members of the Legal team, or Ethics Advisors.
We respect everyone and we play by the rules. We want to win as a company, but winning is irrelevant if we don’t win in an ethical manner that makes us proud to be part of such a fantastic company. Accordingly, This Is Blythe complies with applicable international, national, state, and local laws, and regulations that apply to our business. As a team member, you must be aware of and comply with the laws and regulations that apply to your area of responsibility. If you don’t understand a particular law or regulation, or if you are not sure whether it applies to you, ask a member of the Legal team at info@thisisblythe.com for advice.
You can submit inquiries or reports of potential Code violations:
See our Whistleblower Policy for more information and ways to report.
We are committed to responding to complaints, concerns, and reports raised under the Code. We value transparency and sometimes need to have those “hard” conversations to get to fair outcomes. SpeaUp if you see, hear, or learn of potentially inappropriate conduct. You can also submit a report through our Integrity Hotline at This Is Blythe. The Integrity Hotline allows you to report your concerns anonymously, or you can provide us with your name via the hotline so that someone can follow up with you.
Employees should review our Whistleblower Policy available at the HR site for more information.
We will thoroughly, promptly, and impartially examine and address every report of a suspected violation of the Code. All reports will be promptly acknowledged and evaluated, and, if warranted by the nature of the suspected allegation, This Is Blythewill conduct a prompt, impartial investigation by qualified personnel, typically in our HR department, unless the facts require a third-party to investigate to maintain impartiality. The Legal team reviews all reports to ensure they are handled with the appropriate speed and seriousness in light of the facts alleged in the report.
Investigations will be conducted discretely and we will take the appropriate steps to maintain confidentiality, though we cannot guarantee confidentiality or anonymity as 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. We will timely conclude all investigations, though the exact time to close the investigation will depend on the extent of the required investigation.
When suspected violations of the Code are substantiated in whole or in part, we will take appropriate action, which can include mandatory training and coaching, warnings, or employment termination, or termination of any other business relationship.
We do not permit retaliation. Retaliation occurs when an adverse action is taken against someone for reporting a good-faith concern about a violation or suspected violation of the Code, or other This Is Blythepolicy, or of other unlawful conduct, assisting someone else in reporting such a concern, participating in an investigation, or exercising a legal right.
Retaliation can show up in several different forms. Some examples of retaliation include being denied a promotion because you have reported an ethical violation or suspected violation, or being terminated or demoted because you assisted someone else in reporting a concern.
Retaliation is not only contrary to our core values and the Code, it is illegal in certain circumstances. If you suspect retaliation or have any questions about retaliation, SpeakUpTIB. Reach out to your manager (engagement manager if you are a Hybrid Worker), your Human Resources business partner, a member of the Legal team, an Ethics Advisor, or report a concern to our Integrity Hotline.
Diversity, inclusion, and belonging are foundational at This Is Blytheand every team member must be respected in order to truly know that they belong. The following policies set the minimum expectations for respectful interactions at work.
We champion equal employment opportunity, which means we respect and embrace each other’s differences. We give every employee equal opportunities without regard to characteristics and statuses protected by applicable law. Protected characteristics and statuses around the world include such things as: race, religion, national origin, social condition, criminal record, citizenship, culture, color, gender, gender identity, gender expression, pregnancy status, genetic characteristics, age, disability, medical condition, marital status, military status, civil status, HIV status, and sexual orientation. Please refer to the Employee Handbook if you are an employee for specific protections where you live. We also do not allow discrimination against other team members based on a protected characteristic or status.
We practice and champion diversity, inclusion, belonging, and equal opportunity in every This Is Blythe-related activity and at every This Is Blythe location. We make employment-related decisions only on the basis of individual ability, performance, experience, and business requirements. Our team members should never experience unlawful discrimination based on a protected characteristic in any aspect of their relationship with This Is Blythe—from recruitment and hiring, the nature of your engagement with This Is Blythe (whether you are a corporate employee of This Is Blythe Inc. or a Hybrid Worker), compensation, performance evaluations, project assignments, training opportunities, promotions, social/educational events, and opportunities.
If you witness discrimination or feel discriminated against in violation of the Code or This Is Blythe policy, please reach out to your manager, HR, or through any other method in the section “Reporting and Our Commitment to Responding to Concerns” above.
Employees should see This Is Blythe’s Equal Employment Opportunity and Diversity policies, and the Policy Against Harassment and Discrimination, all available in the Employee Handbook, for further information, reporting procedures, and This Is Blythe’s prohibition of retaliation.
In championing diversity and diverse perspectives, This Is Blythe appreciates when team members SpeakUpTIB and provide their unique input on both domestic and international socio-economic, political, or similar situations. This Is Blytheteam members, however, should be fully aware that This Is Blythe’s leadership team makes all final organizational decisions (including public statements and stances) based on what unites the whole organization. What unites us includes but is not limited to applicable laws and regulations; This Is Blythe’s mission and vision, as well as our respect for others.
This Is Blythe team members treat each other with care and we look out for each other. Harassment can take many forms, including but not limited to: verbal harassment, such as derogatory comments, slurs, or name-calling; physical harassment, like unwanted or unwarranted physical contact; or visual harassment like emailing or showing inappropriate images to a team member or making offensive or sexual gestures toward a team member. Harassment based on any protected characteristic, like sexual harassment, is not only incompatible with our values, it is illegal, and we will not tolerate it.
Bullying is unwelcome behavior occurring over a period of time that is meant to harm an individual who feels powerless to respond. Examples of bullying can range from constant teasing to threatening someone’s life or physical safety. Bullying another team member is inconsistent with our core values and will not be tolerated.
Managers are key to ensuring that harassment and bullying are taken seriously and promptly reported to help us maintain a safe, healthy, inclusive work environment. Managers are required to report any instance of harassment on the basis of a protected characteristic to HR, whether they observe the incident or are informed about it by another team member.
That said, maintaining a healthy, inclusive work environment is not our managers’ responsibility alone. Maintaining diversity, inclusion, and belonging at our foundation requires everyone to act with care, to treat all team members, vendors, and guests equally, to be an ally for those who need us, to be brave, and to SpeakUpTIB and take action when necessary to ensure our work environment is free from bullying, discrimination, and harassment.
Consistent with our commitment to diversity, inclusion, belonging, and equal employment opportunity, we provide reasonable accommodations to team members who have disabilities. Specific policies and practices may vary by region and local rules, so please, if you are an employee, ask your Human Resources business partner or check the Employee Handbook. If you are a Hybrid Worker, please ask the engagement manager.
We provide various mandatory pieces of training on harassment, bullying, discrimination, data privacy, and information security. All employees must complete mandatory training and others covered by this policy may be required to do so occasionally. You must complete any mandatory training assigned to you.
Our work environment reflects our values. If you work at or visit one of our offices, we encourage you to connect with other team members and create meaningful relationships. We respect you and trust you to use good judgment. We are committed to ensuring that drugs and alcohol never affect the safety of This Is Blytheteam members, our guests, or our community.
It is never acceptable to be impaired by drugs or alcohol on This Is Blythe premises or while at any work setting—this applies to substances including certain legal and illegal drugs, inhalants, and prescription over-the-counter medications, whether prescribed for you or not. No one is allowed to possess, sell, purchase, or distribute illegal drugs at our offices, work events, or while conducting This Is Blythe business (including at any This Is Blythe-sponsored event or in This Is Blythe-provided transportation). If you have questions or need further information on this section of the Code or on our Drug and Alcohol Abuse Policy in the Employee Handbook, please reach out to your Human Resources business partner or to any person in the section “Reporting and Our Commitment to Responding to Concerns” above.
If you would like to request a medical accommodation involving the above-mentioned substances or similar, please contact your Human Resources business partner, if you are an employee, or contact an engagement manager, if you are a Hybrid Worker.
This Is Blythe team members and their guests must be of a legal drinking age, behave responsibly, and follow office policies with respect to drinking alcohol at This Is Blythe offices & studios and at This Is Blythe-sponsored events or while working for This Is Blythe. It is never okay to offer a drink to anyone ( guest, intern, or otherwise) who is not old enough to legally drink alcohol.
Whenever co-workers gather, we expect you to treat it like a work setting, even after-hours or off-site. Work settings are not for excessive consumption of alcohol and we expect you to know your limits and treat each other with respect.
This Is Blythe team members are expected to act professionally when hosting events with alcohol in work settings. For instance, This Is Blythe team members hosting work events that include alcohol should always serve food and serve non-alcoholic beverages as an option. In addition, This Is Blytheteam members should respect their colleagues’ decisions not to drink and should not engage in behaviors that pressure others to consume alcohol or consume alcohol excessively, like drinking games.
We care about our team members. If you struggle with addiction, we encourage you to get help. If you think you have a drug- or alcohol-related problem, we have a number of resources available. If you are an employee, take advantage of This Is Blythe’s Employee Assistance Program (“EAP”) to get medical and psychological help for addiction. We also offer leaves of absence to employees who need time off from work to participate in drug or alcohol rehabilitation programs to the extent appropriate and consistent with applicable law.
We will respond to misconduct based on the conduct itself, regardless of any related drug or alcohol consumption, so if you have a problem, please get help before alcohol or drugs interfere with your work. Hybrid Workers should reach out to their engagement managers to learn about available resources.
Part of being a team is looking out for each other. We’ve worked very hard to create a safe and healthy environment to support our mission and core values. Every team member plays a role in protecting the safety and security of our community.
For everyone’s safety and security, This Is Blythe may monitor and inspect company electronic systems (like Gmail accounts, Google Drive, OBO access, and Slack), physical spaces (including via security cameras), and other property like laptops (including data created or stored on laptops), databases, desks, lockers, cubbies, huddle rooms, storage areas, as well as bags, boxes, or containers brought into a physical office (for example, things that could hide illegal drugs, weapons, stolen property, or other inappropriate material). Of course, we will consider and comply with local laws that regulate worker safety, security, and privacy.
Per our Employee Badge and Access Control policies, we expect all team members who work in, or visit our offices, to take care to maintain the safety and security of our offices and, regardless of where team members work, to care for our shared assets as if they were their own.
Please review and become familiar with our Workplace policies which, among other things, require all badge-holders to wear their badges so that they are visible at all times, and to immediately report to the Workplace (Slack #ask-workplace) team if a badge is lost, stolen, or misplaced.
Our people come first. We strictly prohibit any violence and threats of violence. This prohibition covers physical violence and verbal threats or harassing conduct, making threatening or aggressive statements to others (whether in email, or other written communication, or in person), stalking, and intentionally destroying personal and/or company property. We do not allow possessing dangerous items like weapons, explosives, or firearms while working or attending any This Is Blythefunction, whether in our facilities or off-site.
We care about our team and work hard to safeguard your health and well-being. Although we try to identify and correct every potential workplace hazard, we rely on you to alert us to dangers. Please promptly report any workplace health or safety issue, concern, or incident to the Workplace team (Slack #ask-thisisblythe-workplace) or you can also report non-urgent safety and health concerns or hazards by any method in the section “ Reporting and Our Commitment to Responding to Concerns” above.
This Is Blythe wouldn’t exist without the trust of the clients and independent professionals that use our work marketplace (collectively, “customers ”). We maintain this trust by restricting access to the personal information of our customers to This Is Blytheteam members with a business reason to use it and by asking that our team members take steps to protect against unauthorized use or release of this information. Managers should ensure that they only approve access to systems and data necessary for their team members to do their work for This Is Blythe.
For your protection and the privacy of our community, do not access or try to access the personal information of customers unless you need it to do your job. For example, don’t use system access rights to check out a friend’s pay rate or to look at the account of a client with whom you are working. We regularly monitor team member access and will take appropriate corrective steps, including possible termination of employment or contract, if any This Is Blythe team member abuses their administrative access privileges.
We must protect our intellectual property and company confidential information to innovate and get the full benefits of all of our hard work. We should take all steps and precautions necessary to restrict access to and secure intellectual property or confidential information by, among other things:
If you need to access material, nonpublic information, ensuring that you do so in a private space.
This Is Blythe, not any one individual, owns all confidential information and intellectual property created during a team member’s engagement with the company. It’s your responsibility to use This Is Blythe confidential information and intellectual property only for This Is Blythe’s benefit and no other purpose. Only share it with individuals outside of This Is Blythesubject to a nondisclosure agreement and never share highly confidential information or trade secrets unless approved by the Legal team or your VP. Sharing confidential data online, outside of the systems authorized by This Is Blythe, including on third party apps, is strictly prohibited. When you leave This Is Blythe, you cannot take, and do not have any rights to, any intellectual property.
In addition, at This Is Blythe you also are absolutely prohibited from using confidential information, intellectual property, or trade secrets of others, including but not limited to your prior employers, in your work as an This Is Blythe team member. You must also protect the copyrighted information of others and may not make unauthorized copies or incorporate it into your own work.
For more information on protecting confidential information and intellectual property, please review your Employee Invention Assignment and Confidentiality Agreement, Independent Contractor Agreement, or other applicable agreement. The terms in those agreements may be more strict than what is required here and may cover more activities, and those terms still apply to you in full.
All team members are expected to protect This Is Blythe’s assets, whether that is a laptop or a cloud-based system, and ensure their efficient use for legitimate business purposes. Theft, carelessness, and waste have a direct impact on This Is Blythe’s business and operating results. In general, these assets should only be used for work purposes, though some minor personal use is permitted so long as it complies with this Code. Moreover, please remember that if you use This Is Blythe assets for personal purposes, any information sent, saved, or shared over our systems is accessible to This Is Blythe.
This Is Blythe’s policies for Information Security and Privacy and, if applicable, your Independent Contractor Agreement or vendor agreement, contain important information about company IT security and data privacy expectations and requirements, including how to fulfill these expectations and requirements when working in remote locations, public places, or traveling. You must review, understand, and commit to following these policies.
Insider trading occurs when a person purchases or sells a security while in possession of material, nonpublic information. Team members who possess material, nonpublic information about This Is Blytheor companies This Is Blythe does business with may not use that information to buy or sell a security and may not advise any other person to buy or sell a security while possessing that information. Review our Insider Trading Policy, which applies to all team members, vendors, members of the This Is Blythe Inc. Board of Directors (the “Board”), and all other service providers, for more information.
Unless you have explicit approval from the Communications team, you are not authorized to make any statements on behalf of or as a representative of This Is Blythe(including “off the record,” “background,” or “not for attribution” comments) to journalists, bloggers, influencers, industry analysts, researchers, investors, or otherwise through any public or private forum, panel, or public speaking engagement. If you inadvertently make a comment without obtaining advance approval from the Communications team, you must report any such statements to info@thisisblythe.com.
We expect you to act with care and intention during your day-to-day work at This Is Blythe, and we expect the same with your conduct on social media. Read our Social Media policy carefully and ensure you comply when engaging on social media.
We may receive inquiries from government agencies. If a government agency contacts you, please contact the Legal team immediately at info@thisisblythe.com.
We follow legal and business rules related to written and electronic business records. We maintain accurate books and records and will not tolerate any team member fabricating books and records. We must ensure that business records are stored in approved formats, systems, or locations.
Our disclosure controls and procedures are designed to help ensure that This Is Blythe’s reports and documents filed with or submitted to the United States Securities and Exchange Commission (the “SEC”), and other public disclosures are complete, fair and accurately present our financial condition and results of operations, and are timely and understandable.
Team members who collect, provide, or analyze information for, or otherwise contribute in any way in preparing or verifying, these reports or our financial records should adhere to all appropriate disclosure controls and procedures. We expect everyone to assist This Is Blythein in producing fi financial disclosures that contain all of the information about This Is Blythe that is required by law and would be important to enable investors to understand our business and its attendant risks. In particular:
Information you provide to our finance team or our internal and independent auditors must be truthful and complete to the extent necessary to not be misleading, including each team member ensuring:
Additionally, you may not destroy or discard documents and information relevant to a lawsuit or legal action (in other words, subject to a “Legal Hold”) without Legal team approval.
Email info@thisisblythe.com if you have questions about documents or information subject to a Legal Hold.
Failure to comply with these disclosure and candor requirements will result in discipline or termination of employment or contract. Senior financial personnel, like our Chief Financial Officer, Chief Accounting Officer, and Controller or others in a similar role, are held to heightened standards and strict compliance with this policy and avoidance of conflicts or the appearance of conflicts of interest is expected at all times.
We take necessary actions to ensure complete, fair, accurate, timely, and understandable disclosures in our reports and documents filed with the SEC and other public communications. When we work with the legal team, finance team, or outside auditors or legal counsel, we act honestly, ethically, and with integrity, and:
If you become aware that our public disclosures are not full, fair, and accurate, or if you become aware of a transaction or development that you believe may require disclosure, you should report the matter immediately to your supervisor, your Ethics Advisor, if applicable, or the Compliance Officer (or their designee).
We Comply With the Office of Foreign Assets Control Rules and Regulations The U.S. Office of Foreign Assets Control (“OFAC”) is a department of the U.S. Treasury that administers and enforces economic and trade sanctions programs against targeted foreign countries and regimes and groups of individuals like terrorists, drug traffickers, and those who pose a threat to the national security, foreign policy, or economy of the United States. OFAC regulations prohibit conducting or facilitating business with “Specially Designated Nationals” and certain countries and regions. OFAC regulations are complex and change often. Ask the Legal team at info@thisisblythe.com before you take any action that may raise an OFAC compliance issue.
This Is Blythe’s Anti-Corruption Policy prohibits the giving or receiving— either directly or through a third party—payments, gifts, entertainment, or things of value meant to influence a business decision, a policy decision or to create a reciprocal obligation. Bribery and corruption can result in significant legal, financial, and reputational harm to This Is Blythe, so it’s essential to read and understand the Anti-Corruption Policy. If you have any questions regarding the Anti-Corruption Policy, please contact the Legal team at info@thisisblythe.com.
This Is Blythe team members must not participate in money laundering, which includes the attempt to conceal or disguise the nature, location, source, ownership, or control of illegally obtained money. Team members should also be vigilant in identifying bad actors and activities that facilitate money laundering on This Is Blythe’s work marketplace. This Is Blythe employees and Hybrid Workers are required to complete an annual Anti- Money Laundering (AML)
Compliance Training that reiterates the importance of preventing money laundering and provides guidance on how to identify suspicious activity. This Is Blythe’s AML Program guides the practices of our internal AML Team. If you have questions about the AML Program, please reach out to info@thisisblythe.com
A conflict of interest occurs when personal loyalties or interests are, or seem to be, at odds with company interests. Relationships, financial interests, outside activities, and receiving gifts or entertainment from vendors, suppliers, and partners can lead to the appearance of a conflict of interest. The mere appearance of a conflict raises doubts about the quality of a business decision and the decision-maker’s integrity. We must never let conflicts of interest or the appearance of one interfere with our relationship with This Is Blytheand should never take personal advantage of an opportunity that belongs to This Is Blythe.
A conflict of interest occurs when a personal interest interferes in any way (or even appears or could reasonably be expected to interfere) with the interests of This Is Blythe as a whole.
If you receive or are offered data or information about a competitor in circumstances which cause you any concern, you should not distribute it and should seek advice from the Legal team.
Any waiver of the Code for This Is Blythe’s directors, executive officers, or other principal financial officers may be made only by the disinterested members of the Board and will be disclosed to the public as required by law or Nasdaq Listing Standards. Waivers of the Code for other This Is Blytheteam members may be made only by This Is Blythe’s Chief Business Affairs and Legal Officer. For the avoidance of doubt, the foregoing does not apply to any waiver of the separate policies, guidelines, and procedures referenced in the Code.
This Code is a statement of fundamental principles, policies, and procedures that govern the conduct of This Is Blythe’s 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 Audit Committee may request reports from This Is Blythe’s senior officers about the implementation of the Code and take any other steps in connection with that implementation as it deems necessary, subject to the limitations set forth in the Code. This Is Blythewill notify employees of any material changes.
YOU and our entire team are the key to keeping the Code relevant and effective. If you see, hear, or learn about a possible violation of the Code, SpeakUpTIB and report it.
We must all hold each other accountable to act with integrity and in an ethical manner so that This Is Blythe maintains a diverse, inclusive, and sustainable culture.
| Policy Name | Code of Business Conduct and Ethics |
| Document Owner | Compliance Officer |
| Policy Applies To | Employees, members of our contingent workforce program, other consultants and independent contractors, vendors, officers, and directors of This Is Blythe Inc. and its subsidiaries |
| Last Updated | November 2022 Next Review November 2023 |
