One-line summary: Launch's code of conduct and ethics — the standards we expect from every team member: legal compliance, integrity, prohibited conduct, confidentiality, AI usage, conflicts of interest, political activity, social media, IP ownership, drug/alcohol-free workplace, anti-bribery and whistleblower protections, relatives in the workplace, and our gossip-and-disparagement policy. All policies in this section are subject to the NLRA Section 7 disclaimer in §2.

Code of Conduct & Ethics

At Launch, we are committed to maintaining the highest ethical standards. This Code of Conduct and Ethics Policy sets clear expectations for professional behavior and decision-making across all levels of the organization.

Reminder: Per the NLRA Section 7 disclaimer in §2, none of the policies in this section will be interpreted or enforced in a way that interferes with employees' rights to discuss wages, hours, or working conditions, or to engage in other concerted activity protected by federal labor law.

Key principles

• Compliance with laws and regulations: Employees must adhere to all applicable local, state, federal, and international laws and regulations.
• Integrity and honesty: Employees are expected to act with integrity, be truthful in all interactions, and avoid any form of dishonesty.
• Conflicts of interest: Employees must avoid situations where personal interests conflict with the interests of Launch. Any potential conflicts must be disclosed promptly.
• Use of company resources: Employees must use company resources, including time, equipment, and information, responsibly and for business purposes only.
• Respect and professionalism: Employees are expected to treat colleagues, customers, and partners with respect and professionalism.

Violations of this policy may result in disciplinary action, up to and including termination.

Prohibited conduct policy

The following conduct is prohibited and may result in disciplinary action, up to and including immediate termination. This list is illustrative, not exhaustive, and other behaviors that threaten safety, security, employee welfare, or Company operations may also be prohibited:

• Falsifying records, including timecards or employment documents; stealing time, that is, recording work time for hours you did not work or recording time worked on personal projects.
• Theft of passwords, documents, or other property; violating confidentiality agreements or other policies outlined in this section.
• Reporting to work under the influence of drugs or alcohol.
• Possession, consumption, or sale of illegal drugs or unauthorized prescription drugs.
• Theft, damage, or unauthorized removal of Company or employee property.
• Unauthorized use of Company equipment, materials, or facilities.
• Fighting, abusive language, or insubordination.
• Possessing firearms or dangerous weapons on Company property.
• Criminal conduct, including downloading pirated content on Company Wi-Fi.
• Creating disruptions during work hours or on Company property.
• Failing to follow schedules, report absences, or notify a supervisor when unable to work.
• Unauthorized overtime or failure to attend mandatory meetings.
• Violating safety, health, or Company policies.
• Engaging in harassment, gossip, or unprofessional behavior.

Disciplinary actions may include warnings, probation, suspension, termination, or other measures deemed necessary. This policy does not affect the Company's at-will employment status, and either party may terminate employment at any time, with or without notice or cause.

Confidentiality and data protection policy

At Launch, safeguarding confidential and proprietary information and complying with data protection laws are top priorities. This policy outlines employees' responsibilities to protect company, customer, and employee information.

A more detailed technical-safeguards policy (PII handling, GLBA compliance, password rules, device-specific guidance) lives in §11 Confidentiality, Data Protection & Information Security.

Definition of confidential information

Confidential information includes:

• Business strategies, financial data, and marketing plans.
• Customer lists, contracts, and communications.
• Trade secrets, proprietary technology, and intellectual property.
• Employee and customer personal data protected by laws such as GDPR or CCPA.

Employee responsibilities

• Do not disclose confidential or proprietary information to unauthorized parties.
• Securely store and protect confidential information in physical and digital forms.
• Handle personal data in compliance with applicable laws (e.g., GDPR, CCPA).
• Immediately report any data breaches or suspected breaches to HR at hr@launchindustries.biz.

Prohibited actions

• Sharing confidential information outside authorized business purposes.
• Using proprietary information for personal gain or to benefit competitors.
• Failing to follow legal requirements for protecting personal data.

Termination of employment

Upon leaving the company, employees must:

• Return all confidential materials, including digital files, documents, and devices.
• Cease any use of confidential or proprietary information.

Breach of confidentiality

Violations of this policy will result in disciplinary action, up to and including termination, and may lead to legal consequences.

Artificial intelligence (AI) usage policy

To ensure responsible and secure use of AI tools, employees must follow these guidelines:

1. Approved tools. Employees may only use AI platforms and tools that have been approved and designated by the company for specific tasks.
2. Prohibited actions.
   • Employees must not input any company or client confidential information, sensitive data, or proprietary materials into public, unsecured, or non-approved AI systems.
   • Employees are prohibited from using AI tools in ways that violate data protection laws or company policies.
3. Training and compliance. Employees must complete any required training on the use of AI tools and adhere to company standards regarding their application.

Conflict of interest policy

Launch expects employees to act in the company's best interests and avoid situations where personal interests conflict with professional responsibilities.

What constitutes a conflict of interest

• Financial or personal relationships that could influence business decisions.
• Accepting gifts, services, or favors from vendors, clients, or competitors that may create a sense of obligation.
• Note that we do not generally prohibit outside employment, however, any such relationships, especially those that directly compete with Launch, must be disclosed per the requirements below for evaluation on a case-by-case basis.

Disclosure requirements

Employees must disclose any potential or actual conflicts of interest to HR at hr@launchindustries.biz. Launch will work to resolve conflicts in a manner that protects the integrity of the business.

Political activity and lobbying policy

The company maintains a neutral and professional workplace and prohibits employees from engaging in political activities or lobbying on behalf of the company.

Key guidelines

1. Employees may not use company time, resources, or their position to participate in or promote political campaigns, lobbying efforts, or causes.
2. Personal political activities must remain separate from the company, and employees must not represent their personal views as those of the company.
3. Social media posts and public statements must not imply company endorsement of any political party, candidate, or cause.
4. Any conflicts of interest arising from political activities must be disclosed to HR at hr@launchindustries.biz.

This policy ensures a respectful and inclusive workplace. Violations may result in disciplinary action, up to and including termination. For questions, please contact HR.

Social media and technology use policy

Launch is committed to maintaining professionalism, security, and compliance in the use of company technology and social media. This policy provides clear guidelines to protect the organization's reputation and meet contractual obligations.

Technology use guidelines

1. Work-related use only. Company devices, software, and tools are for work purposes only. Do not download unauthorized software or access inappropriate websites.
2. Professional communication. Use company email and tools professionally and respectfully, avoiding personal or sensitive non-work-related communication.
3. Data security. Safeguard company data by following IT security protocols, such as using strong passwords, logging out, and reporting security concerns promptly.

Social media guidelines

1. Launch representation. Do not represent Launch or speak on its behalf without prior approval. Posts referencing Launch must be professional and pre-approved.
2. Confidentiality. Never share confidential or proprietary information about Launch, its clients, or partners on social media.
3. Personal social media. Personal posts must not harm Launch's reputation. Exercise good judgment to ensure alignment with company values.

Special contractual provisions

1. Compliance with contractual requirements.
   • Launch may enter into contracts with external entities, such as government agencies (e.g., the WA Department of Commerce), that include specific provisions or requirements regarding marketing, advertising, or social media usage.
   • Employees, contractors, and representatives must adhere to these provisions as part of Launch's contractual obligations.
   • Any social media, marketing, or advertising activity that pertains to such contracts must be pre-approved by the appropriate contract manager or designated supervisor to ensure compliance.
2. Documentation and reporting.
   • Where required, employees must document marketing or social media activities and provide reports to management to meet auditing or compliance requirements.

Policy violations

Misuse of company technology or failure to follow social media guidelines may lead to disciplinary action, up to and including termination. Serious violations may result in legal consequences.

Intellectual property and ownership policy

Launch retains ownership of all intellectual property (IP) created by employees during their employment, including inventions, designs, and creative works produced using company resources.

Scope of intellectual property

• Includes written materials, software, processes, designs, and marketing assets developed for Launch.
• Applies to all work created during employment, whether on-site or remotely.

Employee obligations

• Employees must not use Launch's IP for personal gain or share it with unauthorized parties.
• Upon termination, employees must return all company materials and cease using company IP.

Failure to comply with this policy may result in legal action.

Drug- and alcohol-free workplace policy

Launch maintains a drug- and alcohol-free work environment to ensure safety, productivity, and professionalism.

Prohibited conduct

• The use, possession, sale, or distribution of illegal drugs or alcohol during work hours is strictly prohibited.
• Employees must not report to work under the influence of drugs or alcohol.

Exceptions

• Moderate alcohol consumption may be permitted at company-sponsored events with prior approval.

California-resident employees: see also the California Addendum — AB 2188 for additional protections regarding off-duty cannabis use.

Violations of this policy may lead to disciplinary action, up to and including termination.

Compliance with laws policy

Launch complies with all applicable local, state, federal, and international laws. Employees are expected to adhere to these laws and regulations in all aspects of their work.

Employee responsibilities

• Be familiar with and follow laws relevant to their role.
• Report any suspected illegal activity or non-compliance to HR at hr@launchindustries.biz.

Violations of this policy will be addressed promptly and may result in disciplinary action, including termination.

Anti-bribery and anti-corruption policy

As a contractor for City and State governments, Launch is committed to maintaining the highest standards of integrity and compliance with applicable anti-corruption and procurement laws. This Anti-Bribery and Anti-Corruption Policy ensures that all employees, contractors, and third parties acting on behalf of Launch understand their obligation to avoid bribery and corruption in all business dealings.

Prohibited conduct

Employees, contractors, and third parties acting on behalf of Launch are strictly prohibited from:

• Offering, promising, giving, or authorizing bribes, kickbacks, or improper payments to government officials, vendors, or other contractors to gain an unfair business advantage.
• Soliciting or accepting bribes, kickbacks, or improper payments in connection with their work at Launch.
• Failing to report any known or suspected incidents of bribery or corruption.

City and state contracting compliance

As contractors for City and State governments, Launch strictly adheres to all relevant laws, regulations, and ethical standards governing public procurement and government contracting. This includes:

• State and local anti-corruption laws: Launch complies with all applicable laws prohibiting bribery, corruption, and unethical conduct in dealings with City and State officials or agencies.
• Procurement guidelines: Employees involved in bidding, procurement, or contracting must comply with all applicable City and State procurement policies, ensuring transparency and fairness.
• Accurate reporting: Employees must ensure that all financial transactions, records, and submissions related to City and State contracts are accurate and comply with reporting requirements.

Reporting violations / whistleblower policy

Employees are required to report any suspected violations of this policy to HR at hr@launchindustries.biz immediately. Reports will be handled with confidentiality, and retaliation against whistleblowers is strictly prohibited. Additionally, our policy prohibits discrimination against anyone who reports company violations.

Violations of this policy may result in disciplinary action, up to and including termination of employment. In cases involving illegal activity, violations may also be reported to the appropriate City or State authorities.

Relatives and personal relationships in the workplace

Launch is committed to fostering a professional, fair, and equitable work environment. To uphold these principles, this policy ensures that personal relationships, including those with relatives, do not disrupt professionalism, employee performance, or business operations. Additionally, Launch maintains a strong stance against nepotism to ensure hiring, promotions, and other employment decisions are free from favoritism or bias.

Policy guidelines

Hiring relatives

• Relatives of current employees may only be considered for employment if:
  • They are the best-qualified candidates for the role.
  • Their employment does not result in a conflict of interest, favoritism, or the perception of preferential treatment.
• To avoid even the appearance of nepotism, hiring decisions involving relatives must be reviewed and approved by Human Resources and senior management.

Reporting structure

• Relatives are prohibited from working in positions where one has:
  • Supervisory authority over the other.
  • Influence over the other's performance evaluations, promotions, disciplinary actions, or compensation decisions.
• Employees must disclose any existing or potential reporting relationships involving a relative to Human Resources.

Personal relationships

• Employees who are engaged in romantic or close personal relationships must disclose the relationship if it creates a potential conflict of interest or has the potential to affect the work environment.
• Launch will take proactive measures to address any conflicts resulting from such relationships, such as reassigning duties, adjusting reporting lines, or other appropriate actions.

Anti-nepotism measures

• Launch does not allow favoritism or preferential treatment based on familial or personal relationships. All employment decisions, including hiring, promotions, and assignments, must be based on merit, qualifications, and organizational needs.
• Employees in decision-making roles are prohibited from influencing employment-related decisions involving their relatives or individuals with whom they have a personal relationship.

Conflict of interest

• If a conflict of interest arises due to a personal or familial relationship, Launch will take steps to address the situation. This may include:
  • Reassigning one or both parties to different teams or reporting structures.
  • Implementing additional oversight to ensure impartial decision-making.
• Failure to disclose a conflict of interest may result in disciplinary action, up to and including termination.

Gossip and disparagement policy

Launch is committed to fostering a professional and respectful workplace. Gossip, rumors, and disparaging comments undermine morale, productivity, and trust. This policy prohibits such behavior to maintain a positive work environment.

Prohibited conduct

• Gossip: Spreading unverified or personal information about coworkers, customers, or the company.
• Disparagement: Making negative or demeaning comments about coworkers, management, or the company's reputation.
• Social media: Employees must not use social media to spread gossip or disparage the company, its employees, or its customers.

NLRA carve-out (per §2): Nothing in this policy restricts employees' rights under Section 7 of the NLRA to discuss wages, hours, working conditions, or to engage in concerted activity for mutual aid or protection.

Expectations

• Employees are encouraged to communicate directly with colleagues or management to address concerns, rather than engaging in gossip.
• All employees are expected to contribute to a respectful and constructive workplace.

Consequences

Violations of this policy may result in disciplinary action, up to and including termination of employment.

If you notice any outdated information or typos, or need clarification on any policies, please email hr@launchindustries.biz.