Our Code of Conduct

INTRODUCTION.

This Code of Conduct (“Code”) is designed to ensure that Lessen, LLC. (the “Company”) makes sound, responsible business decisions for our employees, customers, communities, and stakeholders in Lessen employees are responsible for understanding these expectations and must comply with all provisions in this Code.  Every individual plays an important role in ensuring that our company continues to operate in accordance with these guiding principles.

APPLICABILITY.

This Code applies to all Lessen employees in all locations and at all levels, all the way up to the executive suite and our board members.  Anyone who works on Lessen’s behalf (including suppliers, consultants and other business partners) must share our commitment to integrity and high ethical standards when providing goods and services to Lessen or our customers.  Suppliers (including our network of independent service providers or “Providers”) must also comply with our Provider Code of Conduct.

WE UPHOLD HIGH STANDARDS OF ETHICAL CONDUCT AND EXPECT OUR SUPPLIERS TO DO THE SAME.

Core Values. In accordance with Lessen’s core values, we expect all employees to hold themselves to high standards of ethical conduct. We strive to treat all customers in a fair, ethical, and non-discriminatory manner and aim to achieve a competitive position in the marketplace by providing superior services and not through unethical or illegal business practices. We listen carefully to any feedback received from our customers.

Reinforcing a strong sense of personal accountability and integrity is a priority and core value at Lessen. An employee’s action or inaction may harm our customers and Providers, undermine the Company’s reputation, or negatively impact our internal culture. Employees are encouraged to escalate concerns, regardless of whether the concern affects the employee’s work directly.

Ethical Decision Making. Doing what is right is our goal.Upon identifying an ethical problem, employees should determine the best approach to resolve it by asking the following questions:

• Is it consistent with Lessen’s core values, policies, and this Code?
• Is it legal?
• Would you be comfortable if your approach were published in the newspaper?
• Would you be comfortable with the example it sets for future decisions?

Seek input from others, if appropriate. If the answer to any of these is “no,” or if you are unsure of what to do in a situation, escalate the problem to your manager, Human Resources, or the Legal Department.  It is always better to ask before you act, especially if the right thing to do is unclear.

Upholding our commitment. We have tools in place to hold ourselves accountable for any action that does not align with our core value of integrity.

Lessen hosts a 24-hour ethics and compliance hotline, EthicsPoint. Customers, vendors, and others in a business relationship with Lessen can use this resource to report any possible illegal or unethical conduct. EthicsPoint is designed to protect your confidentiality—you can submit your report anonymously upon request. Make a report or follow up on a report.

Provider Code of Conduct. We expect our suppliers to comply with our Provider Code of Conduct.

WE COMPETE FAIRLY.

Fair Dealing. Lessen believes in competing fairly and within legal boundaries. We build market share and customer loyalty by delivering quality products and services, and we seek to avoid unfairly restricting a competitor’s ability to compete against us.

Lessen employees should never enter into any agreement or understanding, whether written or oral, with a competitor to:

• Set prices on our products and services (price fixing)
• Divide territories, markets, or customers (allocation schemes)
• Reduce or eliminate competition in a competitive bidding process (bid rigging)
• Prevent another company from entering the market or agree with competitors to boycott another company (group boycotts)

Avoid even the appearance that any of our pricing decisions are influenced by information exchanged with a competitor. Deal fairly and honestly with our customers. Never take advantage of anyone by manipulating or concealing information, misrepresenting material facts, abusing confidential information, or doing anything else that could be perceived as unfair or deceptive.

Competitive Intelligence. Gathering and using information about competitors, often called competitive intelligence, is a legitimate business practice. We like to know what our competitors are doing to help us compete and maintain our industry position, but obtaining such information must be done lawfully and ethically. Use public or other permitted sources and be honest about who you are and who you work for.  Respect another company’s right to protect its confidential information. For example, we shouldn’t ask new employees to reveal confidential information about a prior employer or to provide information that would cause them to violate any obligation of confidentiality or a non-disclosure agreement. If you have a question about appropriate receipt or use of competitive intelligence, contact your manager.

Honest Advertising and Marketing. We are responsible for accurately representing Lessen and our products and services in our marketing, advertising, and sales materials. Deliberately misleading communications, omissions of important facts, or false claims about our products and services or those of our competitors are inconsistent with our values. When it becomes necessary to compare our products to those of our competitors, we endeavor to make factual and accurate statements that can be easily verified or reasonably relied upon.

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WE PROHIBIT BRIBERY AND CORRUPTION.

Anti-Corruption and Anti-Bribery. We expect all employees to act ethically and we do not tolerate bribery.

The United States and many other countries have laws that prohibit bribery, kickbacks, and other improper payments. Commercial bribery involves a situation where anything of value is given to a current or prospective business partner with the intent to improperly obtain business or corruptly influence a business decision. “Anything of value” is not limited to a cash payment but can also include gifts, travel, excessive meals or entertainment, offers of employment, political contributions, and other similar items or offers involving an employee’s personal gain. This does not include normal business practices for the Company’s benefit, such as entering into referral agreements or offering volume-based discounts. Regardless of what laws may permit, no Lessen employee, officer, agent, or independent contractor acting on our behalf may offer, provide, or accept bribes or other improper benefits in order to obtain business or an unfair advantage.

What does that mean in practice?

• No public sector bribery. Don’t engage in any form of bribery of government officials. For example, don’t pay or offer to pay anything to someone who works for the government to improperly influence their actions, to, for example, give us favorable treatment in getting a permit, ignore regulatory issues, or award us government business.
• No private sector bribery. Don’t engage in commercial bribery, for instance, by paying “kickbacks” to customers to obtain business.
• No facilitation payments. Facilitation payments are small payments made to government officials at any level to speed up the performance of a routine government action, such as visa processing or customs clearance. Don’t offer facilitation payments, no matter where we are doing business.
• No accepting bribes. Refuse to accept any sorts of bribes or improper payments.

In short, never offer, pay, promise to pay or accept anything of value, either directly or indirectly, given in an attempt to sway a person’s actions or decisions. For example, if a third party suggests or implies that a bribe will be necessary to close a sale or maintain supplier or customer loyalty, don’t do it: stop the communications with the supplier or customer immediately and report the unethical conduct to your manager.

WE AVOID CONFLICTS OF INTEREST.

Conflicts of Interest. We believe business decisions should be made with integrity and not be influenced by a conflict of interest. All employees must conduct themselves in such a way as to avoid actual or potential conflicts of interest. This means that you should always act in the best interest of Lessen and not permit outside interests (for example, financial or personal interests) to interfere with your job duties. You are responsible for ensuring that your business decisions are based on how those decisions will benefit Lessen, not how they might benefit you personally.

A conflict of interest occurs when our outside interests interfere with our ability to make sound, unbiased decisions on behalf of the Company.  At Lessen, we seek to avoid even the appearance of a conflict of interest.

Examples of actual or potential conflicts of interest include, but are not limited to:

• Acting as a director, officer, consultant, agent or employee of a supplier, customer, competitor or any entity that engages in business with the Company;
• Owning a material interest in or being a creditor of or having other financial interest in a supplier, customer, competitor or any entity that engages in business with the Company;
• Receiving from or giving to any supplier, customer or competitor gifts, entertainment, gratuities, special allowances, discounts or other advantages not generally available to employees of the Company;
• Having any significant direct or indirect personal interest in a business transaction involving the Company;
• Conducting outside activities that materially detract from or interfere with the full and timely performance of your job duties for the Company;
• Influencing commercial transactions involving purchases, contracts or leases in a way that would have a negative impact on the Company or its business.

Many actual or potential conflicts of interest may be resolved. If you find that you have, or are considering the assumption of, a financial interest or outside employment relationship that might involve a conflict of interest, or if you are in doubt concerning the proper application of this policy, you should promptly discuss the matter with Human Resources and refrain from exercising responsibility on the Company’s behalf in any manner that might reasonably be considered to be affected by any adverse interest.

WE PREVENT MONEY LAUNDERING.

Anti-Money Laundering. Money laundering is the process of taking the funds generated from criminal activity – such as terrorism, drug or human trafficking, tax evasion, and fraud – and making them appear legitimate.  Lessen is committed to conducting business in a way that prevents the use of our transactions by people who might abuse them.  How you can help:

• Be proactive when it comes to spotting financial transactions or other conduct that might signal a problem and/or is outside of normal process.
• Report any unusual or suspicious activity to your manager.
• Complete all required training as requested by Lessen.

WE FOLLOW PRIVACY LAWS.

Privacy Policy. We respect the privacy of customer and subcontractor information obtained via our website in accordance with our General Website Privacy Statement and via our customer and provider portals in accordance with our Customer Portal Privacy Policy and Provider Portal Privacy Policy, respectively.

Staying Informed. Various Lessen departments, including our Product, Data, and Legal teams, meet regularly to discuss new databases or applications that may utilize personal data, if any, as well as developments in the law applicable to our business in order to ensure compliance with evolving privacy laws.

WE PROTECT NON-PUBLIC INFORMATION AND COMPANY RESOURCES.

Confidentiality. All Lessen employees are required to sign a Confidentiality Agreement upon hire and to complete a confidentiality training as part of new hire orientation. Pursuant to our Confidential Company Information Policy, employees shall not disclose or reveal any confidential information within or outside Lessen absent proper authorization or purpose. This includes a restriction on disclosure of any third party’s confidential information within Lessen that could expose you and Lessen to legal liabilities, including, but not limited to, Provider lists or pricing provided to us by our Providers.  Employees are expected to respect the rights of other companies to protect their own confidential information. This means that you should not reveal confidential information about a prior employer or other third party unless it has already been made public through no action of your own.

As part of the onboarding process for prospective Providers, Providers are also required to agree to confidentiality restrictions with respect to Lessen and customer data.

Company Assets. We require employees to use company assets for legitimate business purposes and to protect such assets against cyber-related attack, theft, damage, or loss.  Use care with any Company property that has been issued to you, such as keys or building access cards, to prevent unauthorized use our access to our facilities.

Protecting Information. Our Information Security Policy requires that employees follow all IT department protocols for the security of information, including protecting passwords and access methods at all times, and refraining from storing or removing any information from Lessen on any form of removable media. All information security incidents must be reported in accordance with our Information Security Incident Management Policy. We provide cybersecurity updates and training to employees on a regular basis.

Storage of Physical and Electronic Documents. Confidential Lessen electronic data is stored on secure network drives and by reputable cloud service providers. Lessen stores non-public physical records only in locked offices or in locked storage rooms accessible only by those with authorized keyed access. Lessen’s offices are secured by keycard access at multiple points of entry, including: (a) for access to the elevator bank, (b) within the elevator for floor access, and (c) at each floor’s entry doors. Further, video surveillance is present on Lessen’s office floors for added protection and monitoring. Any physical record (that would not be otherwise shredded per Lessen’s Document Retention Policy) that might contain highly confidential or personal information must be stored in a locked office or locked storage room accessible only by those with authorized keyed access.

Intellectual Property. Copyrights, patents, trademarks, and trade secrets are also valuable Company assets. You should take all necessary steps to ensure that Company intellectual property remains protected, including requesting a non-disclosure agreement from Legal prior to sharing any proprietary Company information with a potential vendor, customer, or any other third party.