Code of Conduct

I. Purpose

At Change Ventures (the “Fund”) we are committed to building an environment where everyone is empowered to develop, to contribute, and to succeed.  As a Fund, we see diversity and inclusion as the right thing to do.  We strive to attract, invest in, and develop the talents of diverse people who reflect the society and community in which we live and do business.  Creating an inclusive environment where all employees are engaged and performing at high levels, and where differences in outlook, perspective and background are seen as adding value, is a core element of our strategy.

Enhanced business relationships, greater innovation, increased productivity, profitability and enhanced portfolio company relationships are among the benefits of the diverse and inclusive culture we are building at our Fund.

II. Non-Discrimination Policy

We are committed to maintaining a professional environment in which all individuals are treated with respect and dignity.  Each individual has the right to work in a professional atmosphere that promotes equal employment opportunities in all aspects of employment and personnel matters (including, without limitation, recruiting and hiring, job assignment, compensation, opportunities for advancement (including promotion and transfers), evaluation, benefits, training, discipline, and termination), and prohibits discriminatory practices, including harassment.  This policy applies to unlawful conduct by supervisors, co-workers, and third parties.

We expect that all relationships among persons in the workplace will be free of unlawful bias, prejudice and harassment.  Therefore, it is the Fund’s policy to ensure equal employment opportunity without discrimination or harassment on the basis of race; color; religion or creed; sex (with or without sexual conduct); gender (including pregnancy, childbirth, breastfeeding or related medical conditions); age; physical or mental disability; medical condition; military or veteran status; national origin or ancestry; citizenship status; genetic information; or any other characteristic protected by applicable laws.  We also do not allow discrimination based on the perception that anyone has any of those characteristics, or is associated with a person who has or is perceived as having any of those characteristics.

III. Recruitment and Investment Policy

We believe in treating each applicant for investment and/or employment fairly and with dignity, and are committed to actualizing our mission described above in our investment and recruitment strategy.

The right way to attract, retain, and develop the best talent in our industry and who share our passion is to base our decisions on skills and experience, without regard to race; color; religion or creed; sex; gender (including pregnancy, childbirth, breastfeeding or related medical conditions); age; physical or mental disability; medical condition; military or veteran status; national origin or ancestry; citizenship status; genetic information; or any other characteristic protected by applicable law, and we pledge to do so.

IV. Reporting

Anyone who feel that they have been harassed or discriminated against, or who witness any harassment or discrimination by a partner, employee, contract worker, customer, vendor, or anyone else who does business with the Fund, should immediately do the following:

1. If you feel comfortable enough to do so, tell the person engaging in the harassing and/or discriminating behavior that his or her actions are not welcome and they must stop.

2. Report the incident verbally or in writing to the Fund’s diversity partner Yrjö Ojasaar (yrjo@changeventures.com), your supervisor, and/or another individual with whom you feel comfortable (including the Managing Partner of the Fund Andris Berzins andris@changeventures.com).

You can make a report either personally or anonymously.

V. Violations of Policy

Any reported incident will be investigated by qualified personnel in a fair, impartial, timely, and thorough manner that provides all relevant parties with the opportunity to be heard and to present any information he or she thinks is relevant or important for consideration, and that allows the Fund to reach reasonable conclusions based on the information collected.

Any partner, employee or contract worker who violates this policy will be subject to disciplinary action, up to and including termination of his or her employment or engagement. To the extent a customer, vendor, or other person with whom the Fund does business engages in unlawful harassment or discrimination, the Fund will take appropriate corrective action to address that situation.