Argyle Code of Conduct
Last Updated: April 15th 2020
Who Must Follow Our Code? We expect all stakeholders (contractor, employee, board members, etc.) 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 Argyle employees and Board members, we expect Argyle contractors, consultants, and others who may be temporarily assigned to perform work or services for Argyle to follow the Code in connection with their work for us. Failure of an Argyle contractor, consultant, or other covered service provider to follow the Code can result in termination of their relationship with Argyle.
What If I Have a Code-Related Question or Concern? If you have a question or concern, don’t just sit there. You can contact your manager or any member of the executive team. You can also submit a question or raise a concern of a suspected violation of our Code or any other Argyle policy through Argyle Internal Support. Finally, if you believe a violation of law has occurred, you can always raise that directly to the executive team or with a government agency.
No Retaliation Argyle prohibits retaliation against any worker here at Argyle 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 contact the executive team.
I. Serve Our Users
Our users value Argyle not only because we deliver great products and services, but because we hold ourselves to a higher standard in how we treat users and operate more generally. Keeping the following principles in mind will help us to maintain that high standard
1. Integrity Our reputation as a company that our users 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 users should increase their trust in us.
2. Usefulness Our products, features, and services should make Argyle more useful for all our users. We have many different types of users, from individuals to large businesses, but one guiding principle: “Is what we are offering useful?”
3. Privacy, Security, and Freedom of Expression Always remember that we are asking users to trust us with their personal information. Preserving that trust requires that each of us respect and protect the privacy and security of that information. Our security procedures strictly limit access to and use of users’ personal information and require that each of us take measures to protect user data from unauthorized access. Know your responsibilities under these procedures, and collect, use, and access user personal information only as authorized by our Security Policies, our Privacy Policies, and applicable data protection laws.
Argyle is committed to advancing privacy and freedom of expression for our users around the world. Where user privacy and freedom of expression face government challenges, we seek to implement internationally recognized standards that respect those rights as we develop products, do business in diverse markets, and respond to government requests to access user information or remove user content.
Responsiveness Part of being useful and honest is being responsive: We recognize relevant user feedback when we see it, and we do something about it. We take pride in responding to communications from our users, whether questions, problems, or compliments. If something is broken, fix it.
Take Action Any time you feel our users aren’t being well-served, don’t be bashful - let someone in the company know about it. Continually improving our products and services takes all of us, and we’re proud that Argylers champion our users and take the initiative to step forward when the interests of our users 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. Argylers are expected to do their utmost to create a workplace culture that is free of harassment, intimidation, bias, and unlawful discrimination.
Please read the Argyle Guidebook. Located in the HR section of Notion, the Guidebook covers in greater detail how we should conduct ourselves at work.
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 Argyle 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 Argyle, or by an Argyle partner or vendor, we strongly encourage you to immediately report the incident to your supervisor, the Executive Team, or both. Similarly, supervisors and managers who learn of any such incident should immediately report it to the Executive Team. They will promptly and thoroughly investigate any complaints and take appropriate action.
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 the Executive Team immediately. In the event there is a dangerous situation, use your instincts and contact the local police authorities if needed.
**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 Argyle or our users, 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 Argyle. 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
  • Business opportunities found through work
  • Inventions
  • Friends and relatives; co-worker relationships
  • Accepting gifts, entertainment, and other business courtesies
  • Use of Argyle 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 the executive team. 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 Argyle competitors or business partners when the investment might cause, or appear to cause, you to act in a way that could harm Argyle.
When determining whether a personal investment creates a conflict of interest, consider the relationship between the business of the outside company, Argyle's business, and what you do at Argyle, including whether the company has a business relationship with Argyle that you can influence, and the extent to which the company competes with Argyle. You should also consider 1) any overlap between your specific role at Argyle 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 Argyle 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.
Inventions Developing or helping to develop outside inventions that a) relate to Argyle's existing or reasonably anticipated products and services, b) relate to your position at Argyle, or c) are developed using Argyle corporate resources may create conflicts of interest and be subject to the provisions of Argyle'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 the executive team or Legal.
Friends and Relatives; Co-Worker Relationships Avoid participating in the management of or decision-making regarding potential or existing Argyle 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 Argyle or becomes an Argyle competitor or business partner doesn’t mean there is a conflict of interest. However, if you are also involved in that Argyle business relationship, it can be very sensitive. The right thing to do in that situation is to discuss the relationship with your manager and the executive team.
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. Consult Argyle's Guidebook for additional guidance on this issue.
Accepting Gifts, Entertainment, and Other Business Courtesies Accepting gifts, entertainment, and other business courtesies from an Argyle competitor or business partner can easily create the appearance of a conflict of interest, especially if the value of the item is significant. Argyle's Non-Government Related Gifts & Client Entertainment Policy provides specific guidance on when it is appropriate for Argylers to accept gifts, entertainment, or any other business courtesy (including discounts or benefits that are not made available to all Argylers) 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 Argyle business relationships, provided that they aren’t excessive and don’t create the appearance of impropriety. Before accepting any gift or courtesy, be aware that you may need to obtain manager approval. Contact the executive team if you have any questions.
Use of Argyle Products and Services Avoiding potential conflicts of interest also means that you should not use Argyle 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 users outside of Argyle. For example, you should never approve Argyle 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 an Argyler 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 Argyle's products, services, tools, or information, discuss the situation with your manager, Legal, or the executive team.
Reporting The executive team will periodically report all matters involving Argyle officers - VPs and above - approved under this section of the Code, and will periodically report all matters including executive officers approved under this section.
**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 Argyle material – we must also:
  • Properly secure, label, and (when appropriate) dispose of Confidential Argyle material;
  • Safeguard Confidential information that Argyle receives from others under non-disclosure agreements;
  • Take steps to keep our trade secrets and other confidential intellectual property secrets.
Confidential Information Make sure that information that is classified as “Need to Know” or “Confidential” in Argyle's Data Classification Guidelines is handled in accordance with those Guidelines and Argyle's general data practices. 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, Argyle 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 from the executive team.
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.
Argyle Partners Just as you are careful not to disclose confidential Argyle 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.
Argyle Data Be sure to protect the confidential information of Argyle. You may have access to confidential information through collaborations, rotations, access to Argyle buildings or networks, or simply through casual interactions. Don’t access or use confidential information of Argyle except when authorized and reasonably necessary for valid business purposes within the scope of your work at Argyle. Take all reasonable steps to maintain the confidentiality of any such information.
Don’t disclose any confidential information about any Argyle company, including financial, partner, business, technical, or IP information, before obtaining appropriate sign-off from the Legal and executive team.
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 Argyler'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 Legal 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 Argyle unless you’re authorized to do so by the company. The same applies to communications with the press.
**V. Protect Argyle's Assets** Argyle 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 Argyle'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 Argyle's (or its affiliated entities’) logos, marks, or other protected information or property for any business or commercial venture without pre-clearance from the executive team. We strongly encourage you to report any suspected misuse of trademarks, logos, or other Argyle intellectual property to the executive team.
Likewise, respect the intellectual property rights of others. Inappropriate use of others’ intellectual property may expose Argyle and you to criminal and civil fines and penalties. Please seek advice from the executive team before you solicit, accept, or use proprietary information from individuals outside the company or let them use or have access to Argyle proprietary information. You should also check with the executive team if developing a product that uses content not belonging to Argyle.
Company Equipment Argyle 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 Argyle 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 or the executive team.
The Network Be sure to follow all security policies. If you have any reason to believe that your 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 the executive team.
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 Argyle's premises. Don’t tamper with or disable security and safety devices. Watch people who “tailgate” behind you through our doors. Promptly report any suspicious activity to the executive team.
Employee Data We collect and store personal information from employees around the world. Access this data only in line with local law and Argyle internal policies, and be sure to handle employee data in a manner that is consistent with Argyle's data practices and other Argyle 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 Argyle is not ours; it’s the company’s and, ultimately, our shareholders’. Each person at Argyle – not just those in Finance – 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 Argyle, sign a new business contract, or enter into any deals on Argyle's behalf.
To make sure that we get this right, Argyle's executive team 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 the executive team if you have any questions. What follows are some core concepts that lie at the foundation of financial integrity and fiscal responsibility here at Argyle.
Spending Argyle's Money A core Argyle value has always been to spend money wisely. When you submit an expense for reimbursement or spend money on Argyle'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 Argyle, 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 spending and expenses before approving.
Signing a Contract Each time you enter into a business transaction on Argyle's behalf, there should be documentation recording that agreement, approved by the Legal Department. Signing a contract on behalf of Argyle is a very big deal. Never sign any contract on behalf of Argyle 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 Argyle 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 Argyle's interest
All contracts at Argyle should be in writing and should contain all of the relevant terms to which the parties are agreeing – Argyle 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 Argyle policies that apply, including our Revenue Recognition Policy and our Purchasing Policy. Immediately report to the executive team 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 Argyle's financial records. Similarly, you should never falsify any record or account, including time reports, expense accounts, and any other Argyle 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 to the executive team.
Hiring Suppliers As Argyle grows, we enter into more and more deals with suppliers of equipment and services. We should always strive for the best possible deal for Argyle. This almost always requires that you solicit competing bids to make sure that you’re getting the best offer. While the 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 contact the executive team 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. Keep in mind that legal requirements, accounting rules, and other external sources sometimes specify retention periods for certain types of records, and this controls where applicable. In addition, if asked by legal or the executive team to retain records relevant to a litigation, audit, or investigation, do so until legal or the executive team tells you retention is no longer necessary. If you have any questions regarding the correct length of time to retain a record, contact the executive team.
**VII. Obey the Law** Argyle 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. A few specific laws are easy to violate unintentionally and so are worth pointing out here:
The bottom line: If you are in any way involved in sending or making available Argyle 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 the executive team.
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 Argyle. 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
Other activities can also be illegal, unfair, or create the appearance of impropriety. Such activities include:
  • 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 Argyle'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.
Argyle is committed to competing fair and square, so please contact the executive team if you have any questions about the antitrust laws and how they apply to you. Any personnel found to have violated Argyle's Antitrust 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 the executive team immediately.
Anti-bribery Laws Like all businesses, Argyle 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 Argyle 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 Argyle. 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. Contact the executive team if you have any questions.
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 Argyle products). Payment of such expenses can be acceptable (assuming they are permitted under local law) but may require pre-approval from the executive team.
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 the executive team before giving any such gifts or business courtesies and obtain all required pre-approvals.