Code of Conduct
Hoops College Code of Conduct
The Hoops College Code of Conduct is one of the ways we put Hoops College’s values into practice. It’s built around the recognition that everything we do in connection with our work at Hoops College will be, and should be, measured against the highest possible standards of ethical business conduct. We set the bar that high for practical as well as aspirational reasons: Our commitment to the highest standards helps us hire great people, provide great services, and attract loyal Clients. Respect for our clients, for the opportunity, and for each other are foundational to our success, and are something we need to support every day.
So please do read the Code and Hoops College’s values, and follow both in spirit and letter, always bearing in mind that each of us has a personal responsibility to incorporate, and to encourage other to incorporate, the principles of the Code and values into our work. And if you have a question or ever think that someone or the company as a whole may be falling short of our commitment, speak up. We want – and need – to hear from you.
Who Must Follow Our Code?
We expect all of our employees to know and follow the Code. Failure to do so can result in disciplinary action, including termination of employment. Moreover, while the Code is specifically written for Hoops College employees and Board members, we expect Hoops College contractors, consultants, and others who may be temporarily assigned to perform work or services for Hoops College to follow the Code in connection with their work for us. Failure of a Hoops College contractor, consultant, or other covered service provider to follow the Code can result in termination of their relationship with Hoops College.
What If I Have a Code-Related Question or Concern?
If you have a question or concern, speak up. You can also submit a question or raise a concern of a suspected violation of our Code or any other Hoops College policy via text, email, or the website. Finally, if you believe a violation of law has occurred, you can always raise that through text, email, or the website or with a government agency.
Hoops College prohibits retaliation against any worker here at Hoops College who reports or participates in an investigation of a possible violation of our Code, policies, or the law. If you believe you are being retaliated against, please speak up.
I. Serve Our Clients
Our Clients value Hoops College not only because we deliver great products and services, but because we hold ourselves to a higher standard in how we treat Clients and operate more generally. Keeping the following principles in mind will help us to maintain that high standard:
Our reputation as a company that our Clients can trust is our most valuable asset, and it is up to all of us to make sure that we continually earn that trust. All of our communications and other interactions with our Clients should increase their trust in us.
Our features and services should make Hoops College more beneficial for all our Clients. We have many different types of Clients, but one guiding principle: “Is what we are offering useful?”
- Servant Leadership
We will serve Hoops College, its Clients, and each other. We must check our egos at the door. It is not whether we are better or worse than anyone. We must always ask what we can do to make things better for the company, its clients, and each other.
Part of being useful and honest is being responsive: We recognize relevant client feedback when we see it, and we do something about it. We take pride in responding to communications from our Clients, whether questions, problems, or compliments. If something is broken, fix it.
- Take Action
Any time you feel our Clients aren’t being well-served, don’t be bashful – let someone in the company know about it. Continually improving our service takes all of us, and we’re proud that Hoops College employees champion our Clients and take the initiative to step forward when the interests of our Clients are at stake.
II. Support Each Other
We are committed to a supportive work environment, where employees have the opportunity to reach their fullest potential. Hoops College employees are expected to do their utmost to create a workplace culture that is free of harassment, intimidation, bias, and unlawful discrimination.
- Equal Opportunity Employment
Employment here 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 the disabled.
- Harassment, Discrimination, and Bullying
Hoops College prohibits discrimination, harassment and bullying in any form – verbal, physical, or visual, as discussed more fully in our Policy Against Discrimination, Harassment and Retaliation. If you believe you’ve been bullied or harassed by anyone at Hoops College, or by a Hoops College partner or vendor, we strongly encourage you to immediately report the incident to management. Similarly, supervisors and managers who learn of any such incident should immediately report it. Hoops College will promptly and thoroughly investigate any complaints and take appropriate action.
- Drugs and Alcohol
Our position on substance abuse is simple: It is incompatible with the health and safety of our employees and our clients, and we don’t permit it. Consumption of alcohol is banned at our offices. Illegal drugs in our offices or at sponsored events are strictly prohibited. If a manager has reasonable suspicion to believe that an employee’s use of drugs and/or alcohol may adversely affect the employee’s job performance or the safety of the employee or others in the workplace, the manager may request an alcohol and/or drug screening. A reasonable suspicion may be based on objective symptoms such as the employee’s appearance, behavior, or speech.
- Safe Workplace
We are committed to a violence-free work environment, and we will not tolerate any level of violence or the threat of violence in the workplace. Under no circumstances should anyone bring a weapon to work. If you become aware of a violation of this policy, you should report it to immediately. In case of potential violence, contact Hoops College or a government agency.
- Dog Policy
Hoops College’s affection for our canine friends is an integral facet of our corporate culture. We like cats, but we’re a dog company, so as a general rule we feel cats visiting our offices would be fairly stressed out. However, before bringing your canine companion to the office, please make sure you review our Dog Policy.
III. Avoid Conflicts 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 Hoops College 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 Hoops College.If the answer is “yes,” the action you’re considering is likely to create a conflict of interest situation, and you should avoid it.
Below, we provide guidance in seven areas where conflicts of interest often arise:
- Personal investments
- Outside employment, advisory roles, board seats, and starting your own business
- Business opportunities found through work
- Friends and relatives; co-worker relationships
- Accepting gifts, entertainment, and other business courtesies
- Use of Hoops College 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 Ethics & Compliance. Finally, it’s important to understand that as circumstances change, a situation that previously didn’t present a conflict of interest may present one.
- Personal Investments
Avoid making personal investments in companies that are Hoops College competitors or business partners when the investment might cause, or appear to cause, you to act in a way that could harm Hoops College.
When determining whether a personal investment creates a conflict of interest, consider the relationship between the business of the outside company, Hoops College’s business, and what you do at Hoops College, including whether the company has a business relationship with Hoops College that you can influence, and the extent to which the company competes with Hoops College. You should also consider 1) any overlap between your specific role at Hoops College and the company’s business, 2) the significance of the investment, including the size of the investment in relation to your net worth, 3) whether the investment is in a public or private company, 4) your ownership percentage of the company, and 5) the extent to which the investment gives you the ability to manage and control the company.
Investments in venture capital or other similar funds that invest in a broad cross-section of companies that may include Hoops College competitors or business partners generally do not create conflicts of interest. However, a conflict of interest may exist if you control the fund’s investment activity.
- Outside Employment, Advisory Roles, Board Seats, and Starting Your Own Business
Avoid accepting employment, advisory positions, or board seats with Hoops College competitors or business partners when your judgment could be, or could appear to be, influenced in a way that could harm Hoops College. Additionally, because board seats come with fiduciary obligations that can make them particularly tricky from a conflict of interest perspective, you should notify your manager before accepting a board seat with any outside company. Hoops College board members and employees who are VP and above should also notify Ethics & Compliance. Finally, do not start your own business if it will compete with Hoops College.
- Business Opportunities Found Through Work
Business opportunities discovered through your work here belong first to Hoops College, except as otherwise agreed to by Hoops College.
Developing or helping to develop outside inventions that a) relate to Hoops College’s existing or reasonably anticipated products and services, b) relate to your position at Hoops College, or c) are developed using Hoops College corporate resources may create conflicts of interest and be subject to the provisions of Hoops College’s Confidential Information and Invention Assignment Agreement and other employment agreements. If you have any questions about potential conflicts or intellectual property ownership involving an outside invention or other intellectual property, consult Ethics & Compliance or Legal.
- Friends and Relatives; Co-Worker Relationships
Avoid participating in the management of or decision-making regarding potential or existing Hoops College business relationships that involve your relatives, spouse or significant other, or close friends. This includes being the hiring manager for a position for which your relative or close friend is being considered or being a relationship manager for a company associated with your spouse or significant other.
To be clear, just because a relative, spouse/significant other, or close friend works at Hoops College or becomes a Hoops College competitor or business partner doesn’t mean there is a conflict of interest. However, if you are also involved in that Hoops College business relationship, it can be very sensitive.
Finally, romantic relationships between co-workers can, depending on the work roles and respective positions of the co-workers involved, create an actual or apparent conflict of interest. If a romantic relationship does create an actual or apparent conflict, it may require changes to work arrangements or even the termination of employment of either or both individuals involved.
- Accepting Gifts, Entertainment, and Other Business Courtesies
Accepting gifts, entertainment, and other business courtesies from a Hoops College competitor or business partner can easily create the appearance of a conflict of interest, especially if the value of the item is significant. Hoops College can provide specific guidance on when it is appropriate for Hoops College employees to accept gifts, entertainment, or any other business courtesy (including discounts or benefits that are not made available to all Hoops College employees) from any of our competitors or business partners.
Generally, acceptance of inexpensive “token” non-cash gifts is permissible. In addition, infrequent and moderate business meals and entertainment with clients and infrequent invitations to attend local sporting events and celebratory meals with clients can be appropriate aspects of many Hoops College business relationships, provided that they aren’t excessive and don’t create the appearance of impropriety. Before accepting any gift or courtesy, consult Hoops College management, and be aware that you may need to obtain manager approval.
See the discussion of Anti-Bribery Laws in Section VII(d) for guidance on when it is appropriate to give gifts and business courtesies in the course of doing Hoops College business.
- Use of Hoops College Products and Services
Avoiding potential conflicts of interest also means that you should not use Hoops College products, services, internal tools, or information in a way that improperly benefits you or someone you know or creates the appearance that you have an unfair advantage over Clients outside of Hoops College. For example, you should never approve Hoops College accounts, services, or credits for yourself, your friends, or family members. Similarly, you should not use the tools, information, or access that you have as a Hoops College employee to participate in or to generate a financial benefit for yourself or others. If you find yourself subject to a conflict of interest regarding the use of Hoops College’s products, services, tools, or information, discuss the situation with your manager.
IV. Preserve Confidentiality
We get a lot of press attention around our innovations and our culture, and that’s usually fine. However, certain kinds of company information, if leaked prematurely into the press or to competitors, can hurt our product launches, eliminate our competitive advantage and prove costly in other ways. Our responsibilities extend beyond not revealing Confidential Hoops College material – we must also:
- properly secure, label, and (when appropriate) dispose of Confidential Hoops College material;
- safeguard Confidential information that Hoops College receives from others under non-disclosure agreements;
- take steps to keep our trade secrets and other confidential intellectual property secret.
- Confidential Information
Make sure that information that is classified as “Need to Know” or “Confidential” is handled in carefully. At times, a particular project or negotiation may require you to disclose Need to Know or Confidential information to an outside party: Disclosure of that information should be on an “only as needed” basis and only under a non-disclosure agreement. In addition, Hoops College policy may require a prior security assessment of the outside party that is to receive the confidential information. Be sure to conduct the appropriate due diligence and have the appropriate agreement in place before you disclose the information.
There are, of course, “gray areas” in which you will need to apply your best judgment in making sure you don’t disclose any confidential information. If you’re in a gray area, be cautious in what advice or insight you provide or, better yet, ask for guidance.
And don’t forget about pictures you and your guests take at Hoops College – it is up to you to be sure that those pictures don’t disclose confidential information.
Finally, some of us will find ourselves having family or other personal relationships with people employed by our competitors or business partners. As in most cases, common sense applies. Don’t tell your significant other or family members anything confidential, and don’t solicit confidential information from them about their company.
- Hoops College Partners
Just as you are careful not to disclose confidential Hoops College information, it’s equally important not to disclose any confidential information from our partners. Don’t accept confidential information from other companies without first having all parties sign an appropriate Non-disclosure Agreement approved by Legal. Even after the agreement is signed, try only to accept as much information as you need to accomplish your business objectives.
- Hoops College Data
Be sure to protect the confidential information of any Hoops College subsidiary or affiliate. Don’t access or use confidential information of other companies except when authorized and reasonably necessary for valid business purposes within the scope of your work at Hoops College. Take all reasonable steps to maintain the confidentiality of any such information just as you would for Hoops College confidential information.
Don’t disclose any confidential information about any Hoops College company, including financial, partner, business, technical, or IP information, before obtaining appropriate sign-off from Legal, which may include getting consent from affected Hoops College companies.
- Competitors/Former Employers
We respect our competitors and want to compete with them fairly. But we don’t want their confidential information. The same goes for confidential information belonging to any Hoops College’s former employers. If an opportunity arises to take advantage of a competitor’s or former employer’s confidential information, don’t do it. Should you happen to come into possession of a competitor’s confidential information, contact Hoops College immediately.
- Outside Communications
You probably know that our policy is to be extremely careful about disclosing confidential proprietary information. Consistent with that, you should also ensure your outside communications (including online and social media posts) do not disclose confidential proprietary information or represent (or otherwise give the impression) that you are speaking on behalf of Hoops College unless you’re authorized to do so by the company. The same applies to communications with the press. In general, before making any external communication or disclosure, you should consult Hoops College management.
V. Protect Hoops College’s Assets
Hoops College has a well-earned reputation for generosity with our employee benefits and openness with confidential information shared within the company. Our ability to continue these practices depends on how well we conserve company resources and protect company assets and information.
- Intellectual Property
Hoops College’s intellectual property rights (our trademarks, logos, copyrights, trade secrets, “know-how”, and patents) are among our most valuable assets. Unauthorized use can lead to their loss or serious loss of value. You must respect all copyright and other intellectual property laws, including laws governing the fair use of copyrights, trademarks, and brands. You must never use Hoops College’s (or its affiliated entities’) logos, marks, or other protected information or property for any business or commercial venture without pre-clearance from Hoops College. We strongly encourage you to report any suspected misuse of trademarks, logos, or other Hoops College intellectual property immediately.
Likewise, respect the intellectual property rights of others. Inappropriate use of others’ intellectual property may expose Hoops College and you to criminal and civil fines and penalties. Please seek advice from Hoops College before you solicit, accept, or use proprietary information from individuals outside the company or let them use or have access to Hoops College proprietary information. You should also check with Hoops College if developing a product that uses content not belonging to Hoops College.
Hoops College gives us the tools and equipment we need to do our jobs effectively, but counts on us to be responsible and not wasteful with the Hoops College stuff we are given. Nobody’s going to complain if you snag an extra bagel on Friday morning, but company funds, equipment, and other physical assets are not to be requisitioned for purely personal use. Not sure if a certain use of company assets is okay? Please ask your manager.
- The Website and Network
Hoops College’s communication facilities (which include both our network and the hardware that uses it, like computers and mobile devices) are a critical aspect of our company’s property, both physical and intellectual. Be sure to follow all security policies. If you have any reason to believe that our network security has been violated – for example, you lose your laptop or smart phone or think that your network password may have been compromised – please promptly report the incident to Hoops College.
- Physical Security
If you’re not careful, people may steal your stuff. Always secure your laptop, important equipment, and your personal belongings, even while on Hoops College’s premises. Don’t tamper with or disable security and safety devices.
- Use of Hoops College’s Equipment and Facilities
Anything you do using Hoops College’s corporate electronic facilities (e.g., our computers, mobile devices, network, etc.) or store on our premises (e.g., letters, memos, and other documents) might be disclosed to people inside and outside the company. For example, Hoops College may be required by law (e.g., in response to a subpoena or warrant) to monitor, access, and disclose the contents of corporate email, voicemail, computer files, and other materials on our electronic facilities or on our premises. In addition, the company may monitor, access, and disclose employee communications and other information on our corporate electronic facilities or on our premises where there is a business need to do so, such as protecting employees and Clients, maintaining the security of resources and property, or investigating suspected employee misconduct.
- Employee Data
We collect and store personal information from employees around the world. Access this data only in line with local law and Hoops College policies, and be sure to handle employee data in a manner that is consistent with Hoops College policies.
VI. Ensure Financial Integrity and Responsibility
Financial integrity and fiscal responsibility are core aspects of corporate professionalism. This is more than accurate reporting of our financials, though that’s certainly important. The money we spend on behalf of Hoops College is not ours; it’s the company’s and, ultimately, our shareholders’. Each person at Hoops College has a role in making sure that money is appropriately spent, our financial records are complete and accurate, and internal controls are honored. This matters every time we hire a new vendor, expense something to Hoops College, sign a new business contract, or enter into any deals on Hoops College’s behalf.
To make sure that we get this right, Hoops College maintains a system of internal controls to reinforce our compliance with legal, accounting, tax, and other regulatory requirements in every location in which we operate.
Stay in full compliance with our system of internal controls, and don’t hesitate to contact Hoops College if you have any questions. What follows are some core concepts that lie at the foundation of financial integrity and fiscal responsibility here at Hoops College.
- Spending Hoops College’s Money
A core Hoops College value has always been to spend money wisely. When you submit an expense for reimbursement or spend money on Hoops College’s behalf, make sure that the cost is reasonable, directly related to company business, and supported by appropriate documentation. Always record the business purpose (e.g., if you take someone out to dinner on Hoops College, always record in our expense reimbursement tool the full names and titles of the people who attended as well as the reason for the dinner) and comply with other submission requirements. If you’re uncertain about whether you should spend money or submit an expense for reimbursement, check with your manager. Managers are responsible for all money spent and expenses incurred by their direct reports, and should carefully review such spend and expenses before approving.
- Signing a Contract
Each time you enter into a business transaction on Hoops College’s behalf, there should be documentation recording that agreement, approved by Hoops College. Signing a contract on behalf of Hoops College is a very big deal. Never sign any contract on behalf of Hoops College unless all of the following are met:
- You are authorized to do so. If you are unsure whether you are authorized, ask your manager,
- The contract has been approved by Legal. If you are using an approved Hoops College form contract, you don’t need further Legal approval unless you have made changes to the form contract or are using it for other than its intended purpose
- You have studied the contract, understood its terms and decided that entering into the contract is in Hoops College’s interest
- All contracts at Hoops College should be in writing and should contain all of the relevant terms to which the parties are agreeing – Hoops College does not permit “side agreements,” oral or written.
- Recording Transactions
If your job involves the financial recording of our transactions, make sure that you’re fully familiar with all of the Hoops College policies that apply, including our Revenue Recognition Policy and our Purchasing Policy.
Immediately report to Finance any transactions that you think are not being recorded correctly.
- Reporting Financial or Accounting Irregularities
It goes without saying (but we’re going to say it anyway) that you should never, ever interfere in any way with the auditing of Hoops College’s financial records. Similarly, you should never falsify any record or account, including time reports, expense accounts, and any other Hoops College records.
If you suspect or observe any of the conduct mentioned above or, for that matter, any irregularities relating to financial integrity or fiscal responsibility, no matter how small, immediately report them.
- Hiring Suppliers
As Hoops College grows, we enter into more and more deals with suppliers of equipment and services. We should always strive for the best possible deal for Hoops College. This almost always requires that you solicit competing bids to make sure that you’re getting the best offer. While price is very important, it isn’t the only factor worth considering. Quality, service, reliability, and the terms and conditions of the proposed deal may also affect the final decision. Please do not hesitate to ask for help if you have any questions regarding how to procure equipment or services.
- Retaining Records
It’s important that we keep records for an appropriate length of time. If you have any questions regarding the correct length of time to retain a record, contact us.
VII. Obey the Law
Hoops College takes its responsibilities to comply with laws and regulations very seriously and each of us is expected to comply with applicable legal requirements and prohibitions. While it’s impossible for anyone to know all aspects of every applicable law, you should understand the major laws and regulations that apply to your work.
- The bottom line: If you are in any way involved in sending or making available Hoops College products, services, software, equipment, or any form of technical data from one country to another, work with your manager to be absolutely sure that the transaction stays well within the bounds of applicable laws. If you or your manager are not sure, please contact Ethics & Compliance.
- Competition Laws
Most countries have laws – known as “antitrust,” “competition,” or “unfair competition” laws – designed to promote free and fair competition. Generally speaking, these laws prohibit 1) arrangements with competitors that restrain trade in some way, 2) abuse of intellectual property rights, and 3) use of market power to unfairly disadvantage competitors.
Certain conduct is absolutely prohibited under these laws, and could result in your imprisonment, not to mention severe penalties for Hoops College.
Examples of prohibited conduct include:
- agreeing with competitors about prices
- agreeing with competitors to rig bids or to allocate customers or markets
- agreeing with competitors to boycott a supplier or customer
- illegal, unfair, or create the appearance of impropriety.
- sharing competitively sensitive information (e.g., prices, costs, market distribution, etc.) with competitors
- entering into a business arrangement or pursuing a strategy with the sole purpose of harming a competitor
- using Hoops College’s size or strength to gain an unfair competitive advantage
- Although the spirit of these laws is straightforward, their application to particular situations can be quite complex.
Hoops College is committed to competing fair and square, so please contact Hoops College if you have any questions about the antitrust laws and how they apply to you. Any personnel found to have violated Hoops College Policies will, subject to local laws, be disciplined, up to, and including termination of employment. If you suspect that anyone at the company is violating the competition laws, notify Ethics & Compliance immediately.
- Anti-bribery Laws
Like all businesses, Hoops College is subject to lots of laws, both U.S. and non-U.S., that prohibit bribery in virtually every kind of commercial setting. The rule for us at Hoops College is simple – don’t bribe anybody, anytime, for any reason.
- Non-government relationships
You should be careful when you give gifts and pay for meals, entertainment, or other business courtesies on behalf of Hoops College. We want to avoid the possibility that the gift, entertainment, or other business courtesy could be perceived as a bribe, so it’s always best to provide such business courtesies infrequently and, when we do, to keep their value moderate.
- Dealing with government officials
Offering gifts, entertainment, or other business courtesies that could be perceived as bribes becomes especially problematic if you’re dealing with a government official. “Government officials” include any government employee; candidate for public office; or employee of government-owned or -controlled companies, public international organizations, or political parties. Several laws around the world, including the U.S. Foreign Corrupt Practices Act and the UK Bribery Act, specifically prohibit offering or giving anything of value to government officials to influence official action or to secure an improper advantage. This not only includes traditional gifts, but also things like meals, travel, political or charitable contributions, and job offers for government officials’ relatives. Never give gifts to thank government officials for doing their jobs. By contrast, it can be permissible to make infrequent and moderate expenditures for gifts and business entertainment for government officials that are directly tied to promoting our products or services (e.g., providing a modest meal at a day-long demonstration of Hoops College products). Payment of such expenses can be acceptable (assuming they are permitted under local law) but may require pre-approval from Ethics & Compliance under Hoops College’s Anti-Bribery and Government Ethics Policy.
The U.S. also has strict rules that severely limit the ability of a company or its employees to give gifts and business courtesies to a U.S. government official and also limit the official’s ability to accept such gifts. The Honest Leadership and Open Government Act prohibits giving any gifts, including travel and other courtesies, to Members, Officers, and employees of the U.S. Senate and House of Representatives unless they fit within one of a number of specific exceptions. Gifts to employees of the U.S. executive branch are also regulated and subject to limits. Finally, state and local government officials in the U.S. are also subject to additional legal restrictions. Consult Hoops College before giving any such gifts or business courtesies and obtain all required pre-approvals. In sum, before offering any gifts or business courtesies to a U.S. or other government official, you should consult Hoops College. Carefully follow the limits and prohibitions described there, and obtain any required pre-approvals.
Hoops College aspires to be a different kind of company. It’s impossible to spell out every possible ethical scenario we might face. Instead, we rely on one another’s good judgment to uphold a high standard of integrity for ourselves and our company. We expect all Hoops College employees to be guided by both the letter and the spirit of this Code. Sometimes, identifying the right thing to do isn’t an easy call. If you aren’t sure, speak up or ask questions.