Code of Ethics
1. STATEMENT AND SCOPE
Leading by example and living our values means that all Hootsuite employees must conduct Hootsuite’s business in a way that is fair, ethical, and honest. Simply said, in every role and in every action, we expect our employees to do what is right.
This Code of Ethics (the “Code”) is one of the ways we put Hootsuite’s values into practice. It is meant to make our ethical expectations clear and to provide employees with guidance about how to navigate certain situations. Please read this Code carefully and follow it both in spirit and letter, always bearing in mind that each of us has a personal responsibility to incorporate, and to encourage other employees to incorporate, the principles of the Code into our work. If you have questions or ever think that one of your fellow employees, or Hootsuite as a whole, may be falling short of our commitment, please reach out to your manager, the People Partner team, or Team Legal.
This Code applies to all employees (including permanent, temporary, casual, contract, and students), officers, directors, and agents of Hootsuite Inc. or any of its subsidiaries anywhere in the world. Our employees are required to certify annually that they have read and will agree to abide by this Code.
2. CODE OF ETHICS
- The Fundamentals
This Code is a set of common-sense rules intended to guide our decision-making. 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. If you think the Code’s application to any situation is unclear, ask yourself:
- Is this fair?
- Is this legal?
- Would it be okay if this happened to me or a colleague?
- Would it be okay if this were published online?
- Would I feel comfortable describing this situation to a judge? What about a loved one?
While all employees must always act with integrity during the course of their work, each manager and leader at Hootsuite has the increased responsibility to lead by example and empower others to deliver by reinforcing the principles of this Code. If you are a leader or manager, you are expected to serve as a positive role model and inspire others to embrace our Code by:
- Demonstrating integrity
- Encouraging ethical decision-making
- Creating an open work environment where team members feel comfortable to voice opinions and raise concerns
- Preventing retaliation against those who speak up
- Seeking help in resolving and escalating issues when they arise
Hootsuite is committed to maintaining a work environment that is grounded in respect for each individual and their personal dignity. This includes creating a safe, inclusive, and supportive work environment, where everyone has the opportunity to reach their fullest potential.
Respectful Workplace. Treat everyone with respect. Take the time to listen and understand each other’s perspectives and remember that Hootsuite values individuality and diversity. Part of this means understanding that it is okay and supported to disagree with each other, as well as accepting that we bring different perspectives. Simply put, we don’t tolerate bullying, harassment, violence, or discrimination. #NoJerks
For more on Hootsuite’s expectations and commitments regarding bullying, harassment, violence and discrimination, please see Hootsuite’s Respectful Workplace Guidelines and similar rules set out under your employment agreement, local internal regulations, and/or regional policies.
Equal Opportunity. Hootsuite is committed to providing a work environment that is inclusive with equal opportunities and fair treatment of everyone (employees, customers, business partners and other stakeholders) regardless of race, ancestry, religion, place of origin, color, ethnic origin, citizenship, creed, gender identity, gender expression, culture, national origin, pregnancy, sexual orientation, age, marital status, family status, mental or physical disability, socio-economic or social conditions, or any other factor unrelated to job requirements or other basis protected by applicable laws. We believe that a diverse workforce leads to better decisions and also has significant positive results in attracting and retaining talent. And we expect our employees to foster a diverse, equitable and inclusive Hootsuite.
Accommodation. Hootsuite will make all reasonable accommodations to meet our obligations under laws protecting the rights of those with disabilities.
Health and Safety. We provide employees with a safe and healthy working environment, and we recognize that an effective health and safety program is an integral part of every job activity. Any concerns should be brought to the attention of your manager and/or a member of the local health and safety team.
Dos & Don'ts
- Be a cool and considerate colleague - ask yourself, “Am I treating people the way they wish to be treated”? And learn more about Hootsuite’s diversity, equity and inclusion (DEI) efforts.
- Show appreciation for what your colleagues do, post shout outs, say thanks, and recognize hustle
- Speak up if you see or experience bullying, harassment, violence, or discrimination
- Don’t be a jerk - like yelling at, belittling, or threatening a colleague, customer, or business partner
- Don’t be creepy - like making unwanted comments about a colleague’s appearance
- Don’t be a mean person - like spreading rumors and gossip about colleagues
Expect the best and assume the best, of yourself and each other. Use honesty and integrity to guide your behaviour, decision-making, and communication with others. And remember, our reputation as a company that our users can trust is one of our most valuable assets. It is up to all of us to make sure that we continually earn that trust.
Dos & Don'ts
- Keep it 💯(honest) - be honest with each other and with each of Hootsuite’s shareholders, customers, partners, vendors, and other stakeholders
- Exercise good judgment
- Ask for help if you are ever unsure of what to do
- Don’t be shady - like misleading customers
- Don’t be underhanded - like abusing a former employer’s confidential information
- Don’t be counterproductive - like undermining a colleague’s work
A conflict of interest refers to when your personal interests, or the interests of your friends or family or significant other, interfere or appear to interfere with Hootsuite’s interests or your work. What does this mean in practice? We expect our employees to do what is best for Hootsuite. We also expect you to ensure that your judgment and ability to make decisions are not compromised and that you don’t use your position at Hootsuite to serve your personal interests or relationships.
The following situations demonstrate conflicts of interest:
- You “moonlight” as a social media consultant and provide services to Hootsuite competitors or potential customers
- You create an invention for personal gain (i) on Hootsuite time, (ii) using Hootsuite assets, and/or (iii) which competes or reasonably could compete with Hootsuite
- You use your position with Hootsuite to influence the purchase of software licenses, which results in a family member receiving commissions
- You use Hootsuite assets and facilities, like printers/copiers and meeting spaces, for personal gain without approval
- You refer or hire a close friend or family member without disclosing your personal connection to them
- You serve as an employee/officer/director for an organization where there is potential interference with your job performance at Hootsuite or where there may be a business relationship between Hootsuite and the organization
Relationships in the office are a touchy subject and Hootsuite respects your right to privacy in your personal affairs. However, you are responsible to ensure you conduct yourself free from conflict. If you believe you have a conflict of interest or if you believe others may perceive that you have a conflict of interest, you are expected to discuss it with your manager or People Partner.
Dos & Don'ts
- Do what is best for Hootsuite
- Follow Hootsuite’s “Moonlighting” Guidelines and disclose any suspected or potential conflicts of interest
- Ask for permission before using Hootsuite tools/facilities for non-work purposes
- Don’t take for yourself opportunities that belong to Hootsuite or that are discovered using Hootsuite assets, information, or your position
- Don’t compete with Hootsuite
- Don’t hire your friends or family members without disclosing your personal ties
At Hootsuite, we value transparency and open discussion. However, a culture of openness must also be built on a foundation of trust - trust that when we frankly and honestly discuss our goals, challenges, and achievements, that the information will stay within Hootsuite’s (virtual) walls. Improper use or disclosure of Hootsuite confidential information can seriously damage our business and expose Hootsuite to reputational harm and/or legal claims. It is critical that all employees understand and follow the policies and protocols that Hootsuite has in place to protect our confidential information. Put simply, ‘keep it in the fam’!
We also understand that our employees may not always agree with a decision that Hootsuite makes, and we value and strive to foster a culture where employees can speak their minds. However, we expect everyone to remember that the way in which employees speak their minds must remain professional and respectful. Specifically, when discussing matters like company business decisions, including the choices we make about who we do business with, we expect our employees to:
- Carefully protect Hootsuite confidential and proprietary information;
- Avoid publicly disparaging Hootsuite, our customers/partners, and each other;
- Avoid personal attacks on each other and respect diversity of opinion (e.g. posts on Workplace or Slack that target other employees and/or that include inflammatory language like “get educated”, “you don’t know what you’re talking about”, “you are so wrong”, etc., are not okay); and
- Keep in mind the complex duties to investors, employees, customers, and partners that we, as a for-profit business, must always balance.
For more information on what constitutes “confidential information”, please refer to the requirements set out under your employment contract, applicable local internal regulations, and Hootsuite’s security policies. In general, anything relating to Hootsuite’s finances, business and marketing plans, employees, and customers should be treated as confidential by default.
Dos & Don'ts
- Disclose confidential information to colleagues only when it is necessary and permitted
- Disclose confidential information externally only when you have proper approval and a Non-Disclosure Agreement (“NDA”) is in place
- Follow Hootsuite’s Social Media Policy
- OMG don’t be so embarrassing - like discussing confidential Hootsuite business on social media or bad mouthing fellow employees
- Don’t discuss or share confidential information with colleagues unless they “need to know”
- Don’t forget to contact Team Legal for help with NDAs
As a technology company, Hootsuite’s intellectual property - our code, brand, trademarks, copyrights, inventions, patents, domain names, and “know how” - are, along with our employees, the life-blood of the company. So we expect you to use the utmost care in protecting Hootsuite’s IP and trade secrets. Misuse of our IP, like misuse of confidential information, can result in damage to Hootsuite, including loss of value, harm to our reputation, and legal claims.
Last, Hootsuite’s communication facilities (which include both our network and the hardware that uses it) 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 smartphone or think that your network password may have been compromised – please promptly report the incident to IT.
Dos & Don'ts
- Use Hootsuite IP for Hootsuite purposes only
- Follow information security best practices and policies
- Contact Team Legal for help with IP-related agreements/questions
- Don’t use open source without understanding the terms and implications
- Don’t share Hootsuite IP externally without having clear permission and agreements in place
- Don’t use customer or partner names/logos without consent
We expect everyone to act like an owner.
That means using working time and the resources Hootsuite provides to you responsibly and efficiently. That includes the equipment we provide you, as well as the information, facilities, and funds that Hootsuite may make available to you. Don’t do anything with Hootsuite property and resources that is illegal, unethical, or generally shady.
Acting like an owner also means being accountable. When we make a commitment, we keep it!
Dos and Don'ts
- Take care of the equipment Hootsuite provides to you and use it appropriately (see the Acceptable Use Policy for more)
- Spend company funds thoughtfully and carefully
- Get permission from your manager before using a Hootsuite asset to support a personal activity (such as a charitable or other professional activity)
- Don’t use your laptop in the bathtub or leave it in your vehicle or leave it unattended at a cafe
- Don’t forget to properly record your time off
- Don’t sign contracts on behalf of Hootsuite unless you know you have approval/authority to do so
It goes without saying that we must respect all laws applicable to our business. That includes laws and regulations that exist at the international, national, state and provincial, and even local level. Although the list below is not exhaustive, it provides an overview of the types of laws which we need to be aware in our day- to-day work at Hootsuite:
Similarly, social networks trust us to handle their data, and as good partners, we owe it to them to handle their data responsibly and in accordance with their limitations. Always comply with social network data use restrictions to ensure we keep the trust of our social network partners.
Corruption, Foreign Business Dealing, and Improper Payments. Do not pay, loan, or otherwise provide any funds or assets as bribes, kickbacks, or other payments designed to influence the conduct of the recipient or the outcome of any business transaction. Do not give anything of value to a government official, a political party or party official, a political candidate, or an official of a public organization for the purpose of influencing or inducing the recipient to obtain, retain, or direct business for or to any person or for the purpose of securing any improper advantage.
Giving or receiving certain gifts can be an acceptable business practice, but only if doing so neither gives rise to a conflict of interest nor violates laws or either party’s rules & policies. The purpose of giving gifts or entertaining business colleagues in a commercial setting is to create goodwill, build rapport and develop relationships, and not to gain unfair advantage with, or to take unfair advantage of, customers, prospects, partners, or vendors. You must not offer, give or provide any entertainment or gift unless it:
- is not a cash gift
- is consistent with customary business practices
- is worth less than US$150 per year
- is not in exchange for securing a business contract or providing favorable business terms, or that might create or give the appearance of creating a sense of obligation on your or Hootsuite's part with regard to the giver
- does not violate any laws, regulations, or rules
- does not reflect negatively on our brand
Before accepting a gift from a vendor, partner, customer, etc., ask yourself “Is this reasonable and appropriate? Or does this cross a line?” For example, accepting a moderately priced bottle of wine at the holidays? Not a big deal. An all expenses paid trip to a fabulous destination? Probably no bueno. Does Hootsuite have a specific form or process that needs to be filled out if you receive a gift? No, because we value treating our employees as adults and trusting you to do the right thing. Talk to your manager if you are unsure and use this Code as your guide.
For more, please see Hootsuite’s Anti-Corruption Policy and similar rules that may be set out under your employment agreement, local internal regulations, or regional policies.
Competition and Antitrust Laws. Hootsuite must abide by competition and antitrust laws which, among other things, prohibit the abuse of market power, predatory conduct intended to eliminate or exclude a competitor, and arrangements that inhibit competition or restrain trade. 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
Trade Controls. U.S. and international trade laws control where Hootsuite can send or receive its products and services. For example, Hootsuite is not permitted to do business with customers in countries like Cuba, Iran, and North Korea. If you are involved in making Hootsuite products or services available in a new market, 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 Team Legal.
Dos & Don'ts:
- Use good judgment and common sense in your efforts to comply with all applicable laws
- Ask for help when you are uncertain - Team Legal is available to answer questions
- Treat Personally Identifiable Information like gold
- Don’t accept a gift if you wouldn’t be comfortable telling your boss you received it
- Don’t sell Hootsuite products/services to Kim Jong-un (Supreme Leader of North Korea)
- Don’t talk about pricing with competitors
- Be Good Global Citizens
Hootsuite is committed to working toward sustainability in our operations and meeting the social and environmental expectations of our stakeholders.
Environment. Hootsuite strives to minimize the adverse impacts of our business activities on the local and global environment.
Anti-Human Trafficking. Hootsuite is committed to avoiding human trafficking, child labor and forced labor in our supply chain.
Human Rights. Human rights are the fundamental rights, freedoms and standards of treatment to which all people are entitled. Hootsuite is committed to treating all people with dignity and respect, enabling healthy and safe work environments, promoting ethical behavior, and respecting privacy.
Dos & Don'ts:
- Learn more about Hootsuite's corporate social responsibility (CSR) efforts
- Think about environmental impact when making decisions about suppliers and travel
- Check out the CSR and Supply Chain Management policies of vendors you are considering doing business with
- Don’t stay quiet if you see ways that we can improve
- Don’t ignore recycling and composting instructions in your Perch
- Don’t fly or drive if a video call will do the trick
We know that speaking up is never easy. However, our culture and the safety of our workplace depend on employees speaking up and looking out for each other. When faced with a choice between what is easy and what is right, choose right!
Violations, suspected violations, and questions about this Code should be brought to the attention of your manager, the People Team, or Team Legal.
3. CONSEQUENCE OF BREACH
We trust our employees to do what is right, but we also have to be clear that we take this seriously. Any breach of this Code of Ethics, including any action condoning such conduct, will be grounds for discipline, up to and including termination of employment. If you are aware of a breach of this Code, you are required to report it and a failure to do so may be treated as an action condoning. Concerns should be raised with your manager, the People Team, or Team Legal.
No Hootsuite Employee will face any discipline or repercussion for reporting, in good faith, a breach or suspected breach of this Code.
4. LEGAL STUFF
This Code will be reviewed every year. It may be amended at any time and for any reason. The most current version of this Code can be found on the wiki, on the policies landing page.
This Code is not an employment contract. The obligations set out in this Code are in addition to, and not in lieu of, any obligations set out in your employment agreement and any applicable internal regulations.
Hootsuite operates in a global environment. As such, there may be certain terms of this Code that are not in keeping with an aspect of local law or a term of a local collective agreement. It is Hootsuite’s intention to comply with all applicable local laws and collective agreements. This Code will be interpreted to achieve compliance with those requirements. If any term of this Code directly conflicts with a local law or collective agreement, the local law or collective agreement will be substituted for such provisions.