Effective Date: 02 Feb 2024

Message from CEO

As members of Raindrop Inc, We play a pivotal role in an organization that boasts a global presence and enjoys the trust of shareholders, customers, partners, and governments worldwide. Our commitment to excellence, ethical business practices, and values that surpass minimum legal requirements has positioned us as  leaders in our industry.

At the heart of our commitment to integrity and ethical conduct lies the Raindrop Inc Code of Ethics and Business Conduct. This document encapsulates our core values and serves as a guiding light for all employees. It outlines key principles, rules,

and provides links to policies and resources essential for understanding our business values and individual responsibilities. I strongly encourage each of you to carefully read and reference the Code frequently, as it will serve as an invaluable resource in navigating the ethical landscape at Raindrop Inc.

Our goal is to assist you in making decisions that consistently prioritize what is right. While the Code offers clear guidance on your obligations, it’s important to acknowledge that it may not foresee every ethical dilemma you encounter. In such instances, seek guidance from your manager, regional Compliance and Ethics Officer, Chief Compliance Officer, Human Resources partner, or leverage our Integrity Helpline. Raindrop Inc is committed to prohibiting any form of retaliation against employees who, in good faith, raise compliance issues or concerns.

The reputation and success of Raindrop Inc hinge on the personal commitment each of us makes to comprehend and uphold our values. We must strive to act ethically in all our business dealings. Regardless of your employment level, position, or geographic location, each day presents an opportunity to reaffirm our dedication to the standards of business conduct outlined in our Code. Your continued support is vital in upholding Raindrop Inc’s commitment to being a stellar company.

Thank you for your ongoing commitment to ethical conduct and for contributing to making Raindrop Inc a beacon of integrity.

Ashok Neupane

 

 

Our Core Values

As members of Raindrop Inc., our collective success is rooted in the core business values that define who we are and guide our actions. These values are not just principles; they are the bedrock upon which our company thrives. Each of us is entrusted with the responsibility to embody these values daily, contributing to the long-term success of our organization and earning the trust of shareholders, customers, governments, and partners globally.

 

Our Fundamental Values Include:

Integrity: Upholding honesty and choosing the path of integrity in all our business transactions and interactions with others.

Ethics: Acting ethically in every business context, ensuring that our decisions align with the highest ethical standards.

Compliance: Adhering to all laws, regulations, and Raindrop Inc policies that govern our business and the actions of our employees.

Mutual Respect: Treating individuals with respect and dignity, fostering a workplace culture built on mutual regard.

Teamwork: Collaborating as a cohesive team to advance the collective goals and benefit Raindrop Inc.

Communication: Effectively sharing information within the team while also safeguarding the confidentiality of our proprietary information.

Innovation: Encouraging and embracing new and creative approaches to problem solving, fostering a culture of innovation.

Customer Satisfaction: Prioritizing customer satisfaction as a top commitment, understanding the importance of our customers’ experiences.

Quality: Embedding excellence and quality in our work, and continuously seeking opportunities for improvement.

Fairness: Ensuring fairness in our dealings with customers, suppliers, partners, and colleagues, promoting equity in all interactions.

By embracing these values, we collectively contribute to Raindrop Inc’s positive and ethical work environment. Let’s continue to uphold these principles in our daily actions, furthering the success of our company.

Our Code

The Raindrop Inc code forms the bedrock of our business, guiding us with the highest integrity and ethical standards. Applicable across all Raindrop Inc entities, this code exceeds legal requirements, aiming to ensure your success at work. Keeping pace with global standards is vital for Raindrop Inc’s ongoing success and your role in fostering trust with stakeholders.

Periodic updates to the Code will be communicated and it is your responsibility to stay informed. for the latest version, refer to the Raindrop Inc website. Questions about interpretation or compliance can be directed to the Raindrop Inc Compliance and Ethics team or Legal Department.

The Code applies to all personal, including employees, officers, temporary workers, and contractors. Local laws must be followed, but if local business practices conflict with our code, the code takes precedence. Raindrop Inc may interpret the Code at its discretion.

Importantly, only the Raindrop Inc Board of Directors can waive a provision of the Code, with any waiver promptly disclosed to stakeholders. Your commitment to this Code is essential to maintaining Raindrop Inc’s ethical standards and global success.

 

Your Role

Employee

Employees at Raindrop Inc are expected to prioritize compliance and ethics. All employees are required to:

  • Conduct all business dealings with a commitment to ethical behavior and integrity.
  • Familiarize themselves with and adhere to the Raindrop Inc Code and policies.
  • Comply with all relevant laws applicable to our business operations.
  • Report any alleged potential, or actual violations of Raindrop Inc’s Code, policies, or applicable laws through the designated reporting channels.
  • Fully cooperate with compliance investigations, including making devices available for inspection (where legally permissible) and providing truthful responses during investigations.
  • Successfully complete all mandatory compliance education courses and fulfill other Raindrop Inc Compliance and Ethics Program Requirements in a timely manner.

Managers

At Raindrop Inc., managers are exemplify leadership in compliance and ethics, setting a standard for understanding, interpreting, and upholding the rules while consistently demonstrating integrity. Managers play a crucial role in fostering an environment that encourages the reporting of compliance issues and ensures that employees feel confident in raising concerns without fear of retaliation. In line with this commitment:

  • Managers must understand and apply the Raindrop Inc. Code of Ethics in onboarding and routing team discussions.
  • Managers are role models, consistently choosing actions that reflect the highest standards of integrity.
  • Managers ensure their team completes mandatory compliance education courses promptly.
  • Managers maintain an open-door policy, encouraging employees to report compliance concerns without fear of retaliation.
  • Managers foster an environment where employees feel empowered to challenge and report questionable conduct.
  • Managers access employee promotions and compensation, considering completion of compliance training and ethical behavior. Managers approving expenses ensure events are reasonable, modest, justified by a legitimate business purpose, and not lavish or improperly influential.

 

Speak Up

Reporting and Ethics Policy:

Raindrop Inc. is dedicated to maintaining its status as a trusted and world-class company. To achieve this, we encourage all employees to promptly report any concerns related to personnel, business, or operations that may violate our Code of Ethics or legal and ethical obligations. Reporting options include:

  • Your Manager
  • Raindrop Inc. Human Resources
  • Legal Team: Contact a member of the legal team.
  • Regional Compliance and Ethics Officer
  • Chief Compliance and Ethics Officer
  • Employee Representative

 

 

Code Rules

Antitrust and Competition Compliance Statement

Raindrop Inc., in alignment with its commitment to ethical business practices, pledges to adhere to applicable antitrust and competition laws globally. These laws are in place to safeguard consumers, foster market fairness, and promote healthy competition. Raindrop Inc. recognizes the importance of compliance with antitrust and competition laws, understanding that violations can have severe consequences.

Key Commitments:

  1. Observance of Global Laws: Raindrop Inc. Commits to observing and complying with antitrust and competition laws in all countries where it operates.
  2. Prohibited Activities: Antitrust or competition laws typically forbid activities that negatively impact competition without benefiting consumers. Raindrop Inc. explicitly prohibits:            – Fixing or controlling prices, including those of resellers to their customers.- Orchestrating bids to direct contracts to specifics competitors or resellers (bid rigging).- Initiating or participating in supplier or customer boycotts.- Dividing or allocating markets or customers.- Restricting production or sales of products for anti-competitive purposes.
  3. Global Variations: Recognizing the variance in antitrust and competition laws across countries, Raindrop Inc. is committed to understanding and complying with these laws in each jurisdiction where it operates.

Consequences of Non- Compliance:

Raindrop Inc. takes violation of antitrust and competition laws seriously. Non-compliance may result in legal consequences and damage to the company’s reputation. Employees involved in violations may face disciplinary action, including termination.

Reporting Concerns:

Employees are encouraged to report any concerns and potential violations of antitrust and competition law through the established reporting channels outlined in the Raindrop Inc. Code of Ethics and Business Conduct.

By adhering to these principles, Raindrop Inc. seeks to maintain fair and competitive business practice, fostering trust among consumers and partners while complying with legal requirements worldwide.

 

Engaging Government and Public Sector Employees and Officials

Government contracts and procurement compliance policy

Raindrop Inc. upholds strict compliance standards in government contracts and procurement activities. We acknowledge the unique nature of engagements with governmental entities and emphasize the need for unwavering adherence to relevant laws and regulations. Non-compliance may lead to severe consequences, including fines and debarment. Employees engaged in government interactions must familiarize themselves with applicable rules, as outlined in our Supplemental Policy on Government Contracting. Mandatory training, “Dealing with Government: Government Contracts and Political Compliance,” is available on the Compliance and Ethics website. Non-compliance may result in disciplinary action, highlighting our commitment to transparency and ethical conduct. Employees are encouraged to report concerns through established channels in the Raindrop Inc. Code of Ethics and Business Conduct, ensuring trust and integrity in our dealings with governmental entities.

 

Government Procurement Information Compliance Policy

At Raindrop Inc., our commitment to complying with government procurement rules includes the responsible acquisition of relevant information. Employees are strictly prohibited from attempting to obtain the following information from any source:

  1. Procurement-Sensitive Government Information:
  2. Confidential Internal Government Information:
  3. Proprietary Competitor Information:

If, by any chance, such information is inadvertently communicated by another vendor, consultant, or government employee, employees are required to promptly contact the Raindrop Inc. Legal Department. This proactive approach is crucial in upholding our commitment to ethical conduct and compliance in all dealings with government entities, ensuring the integrity of our business operations.

 

Organizational Conflict of Interest (OCI) Policy

In the execution of government contracts, Raindrop Inc. is steadfast in preventing any actual or potential Organizational Conflict of Interest (OCI) that could grant us unequal access to nonpublic information, confer an unfair advantage in competitive procurements, or compromise our objectivity while providing assistance or advice to the government or performing contract work. It is incumbent upon all employees to ensure the avoidance of OCIs.

 

Post-Government Employment Restrictions Policy

Raindrop Inc. recognizes the legal requirements and restrictions related to post-government employment in the private sector. These regulations govern the activities of former government employees after they leave public service and accept employment with a private company. To ensure compliance and ethical conduct, all employees engaging in discussions related to potential employment or entering into business opportunities with a current or former government employee must obtain the necessary approvals by consulting the Raindrop Inc. Legal Department.

 

Government Interactions and Lobbying Compliance Policy

Raindrop Inc. acknowledges that our interactions with the government are subject to lobbying laws and regulations. Lobbying encompasses activities aimed at influencing laws, regulations, policies, and rules, and in some jurisdictions, may extend to sales and business development activities. These laws are applicable to elected officials, appointed officials, and government employees. The company, including its employees and external consultants or advisors engaged in government relations, may have an obligation to register and/or report lobbying activities under applicable law.

 

Global Trade Compliance Policy:

Raindrop Inc. shares  unwavering commitment to comply with all applicable global export, import, and economic sanctions laws and regulations. This commitment is integral to protecting our ability to conduct international business successfully. Non-compliance may lead to disciplinary action, severe supply chain disruptions, loss of business opportunities, monetary penalties, fines, imprisonment for individual employees, and potential revocation of our trade privileges.

Furthermore, Raindrop Inc. employees are prohibited from shipping commodities, including hardware, software, documentation, source code, technical data, or technology, without processing transactions through authorized Raindrop Inc. order entry, distribution, export request, and support processes. Additionally, the use of authorized Raindrop subsidiary channels may also be considered for transactions involving the export or import of Raindrop Inc. commodities. By strictly adhering to these policies, Raindrop Inc. aims to ensure compliance with global trade laws and maintain the integrity of international business operations, protecting the company’s reputation and business interests.

 

No Economic Boycotts

Raindrop Inc. is committed and does not participate in any economic boycott not sanctioned by the Nepal Government. Both Raindrop Inc. and its employees are strictly prohibited from engaging in discriminatory practices or refusing to do business with a country, its nationals, or companies that are the subject of an unsanctioned boycott.

Furthermore, Raindrop Inc. employees are prohibited from furnishing information regarding business relationships with boycotted countries or blacklisted companies. If any employee is requested to provide information, take specific actions, or refrain from certain activities to further or support a boycott of a country, immediate contact with the Raindrop Inc. Legal Department is required.

 

Securities and Insider Trading

Raindrop Inc. is committed to maintaining the highest standards of integrity and transparency in all financial matters, particularly concerning the trading of securities. This policy outlines our strict adherence to securities laws and regulations, prohibiting any form of insider trading. Employees with access to material nonpublic information are prohibited from trading in securities until such information is publicly disclosed. To prevent the appearance of impropriety, employees must refrain from sharing confidential information and follow the designated trading windows. Raindrop Inc. emphasizes the importance of ethical conduct and compliance with insider trading laws to preserve the trust of our stakeholders and safeguard the reputation of the company.

 

Intellectual Property

Raindrop Inc. recognizes the critical importance of intellectual property (IP) in driving innovation and maintaining a competitive edge. This policy outlines our commitment to the protection, proper use, and respect for intellectual property assets. All employees, contractors, and third parties engaged with Raindrop Inc. are expected to adhere to ethical standards and legal obligations concerning intellectual property. This encompasses patents, trademarks, copyrights, trade secrets, and any other proprietary information created or utilized in the course of business. Raindrop Inc. encourages the responsible use of intellectual property, respecting the rights of others and avoiding infringement. Employees are required to promptly disclose any inventions, creations, or innovations developed during their association with Raindrop Inc. to ensure appropriate protection measures. This policy underscores our dedication to fostering an environment that values and safeguards intellectual property, contributing to continued innovation and success at Raindrop Inc.

 

Confidential Information Protection

Safeguarding confidential information is paramount at Raindrop Inc. This policy establishes guidelines for the responsible handling, protection, and secure sharing of confidential information within our organization. Employees are entrusted with the responsibility of ensuring the confidentiality of non-public data, knowledge, or materials that could potentially benefit competitors or harm Raindrop Inc. if disclosed. Adherence to established protocols for secure handling and storage, along with a need-to-know principle, is expected. Collaboration with third parties involves the implementation of non-disclosure agreements to ensure legal protection. Employees are required to maintain strong passwords, promptly report any suspected breaches, and adhere to remote work protocols for the continued protection of confidential information. In cases of collaboration or termination, the return of company property and cessation of access to confidential information is mandatory. Raindrop Inc. aims to instill a culture of responsibility and vigilance, ensuring the security of sensitive data within our organization.

 

Security Policies and Practices

Security is a top priority at Raindrop Inc., and this policy underscores our commitment to maintaining a robust and comprehensive approach to safeguarding information and assets. Our security policies and practices cover a range of measures, including physical security, data protection, network security, and employee training. Access controls are implemented to ensure that only authorized personnel have access to sensitive information and systems. Regular security assessments and audits are conducted to identify and address vulnerabilities proactively. Employees undergo training to enhance their awareness of security best practices, emphasizing their role in maintaining a secure work environment. In the event of security incidents, a clear reporting and response protocol is in place to mitigate potential risks. Raindrop Inc. continually reviews and updates its security policies and practices to adapt to evolving threats and technologies, ensuring the ongoing protection of our information and assets.

 

Privacy Policy

Raindrop Inc. is committed to protecting the privacy of individuals and their data. This comprehensive privacy policy outlines our practices and principles for the collection, use, and safeguarding of personal information. We adhere to all relevant privacy laws and regulations, ensuring transparent communication about the purposes for which data is collected and processed. Raindrop Inc. implements robust security measures to protect personal information from unauthorized access, disclosure, alteration, and destruction. We provide individuals with control over their data and offer mechanisms for consent and opt-out. Data retention practices align with legal requirements and business needs. Our commitment to privacy extends to third-party interactions, requiring adherence to the same stringent privacy standards. Regular privacy assessments and compliance reviews are conducted to uphold the highest standards of data protection. Raindrop Inc. strives to foster a culture of respect for privacy, promoting trust and transparency in our interactions with individuals and stakeholders.

 

Social Media

Recognizing the impact of social media as a vital communication tool, Raindrop Inc. establishes this policy to guide employees in its responsible and professional use. The primary aim is to safeguard our brand reputation, protect confidential information, and ensure compliance with legal and ethical standards. When representing Raindrop Inc. on social media platforms, employees are expected to uphold professional conduct, reflecting the same standards expected in the workplace. Strict adherence to confidentiality is paramount, prohibiting the sharing of confidential or proprietary information about Raindrop Inc., its clients, or partners. Employees are encouraged to maintain a clear distinction between personal and professional social media accounts, ensuring transparency when expressing personal opinions. All social media posts must comply with applicable laws and regulations, including those related to copyright, trademark, and defamation. Respectful conduct towards others is essential, with employees refraining from engaging in any form of harassment, discrimination, or offensive behavior. Positive and inclusive online interactions are encouraged. In cases where employees engage in endorsements or sponsorships related to Raindrop Inc., clear disclosure of their affiliation is mandatory, aligning with applicable regulations. Raindrop Inc. provides social media training to ensure employees are well-versed in best practices and are aware of potential risks associated with their online presence. Employees are encouraged to report any concerns related to social media activities within the organization through established channels, fostering transparency and accountability. Through these guidelines, Raindrop Inc. aims to cultivate a positive and responsible online presence for its employees, safeguarding the company’s reputation and promoting a culture of integrity and professionalism.

 

Conflict of Interest

Raindrop Inc. is committed to maintaining the highest standards of integrity and ethical conduct in all aspects of business. This Conflicts of Interest Policy aims to guide employees, contractors, and stakeholders in identifying, addressing, and preventing conflicts that may compromise the best interests of Raindrop Inc. A conflict of interest arises when personal, financial, or other considerations may interfere with the ability to make impartial decisions in the course of business. All individuals associated with Raindrop Inc. are expected to disclose any potential conflicts promptly. The company will assess the disclosed conflicts and take appropriate measures to mitigate or eliminate them. Financial interests, outside employment, and relationships that may affect objectivity must be disclosed, and actions will be taken to prevent any adverse impact on Raindrop Inc. This policy reinforces our commitment to transparency, accountability, and ensuring that decisions are made with the sole focus on the best interests of Raindrop Inc. and its stakeholders.

 

Competitive Intelligence Policy

Raindrop Inc. recognizes the importance of gathering information about competitors and other third parties to remain informed and agile in the market. This Competitive Intelligence Policy outlines the principles and guidelines for conducting such activities ethically and legally. Employees engaging in competitive intelligence must adhere to all applicable laws and regulations, respecting the rights and privacy of competitors and third parties. Information gathering should focus on publicly available sources or those obtained through ethical means, avoiding deceptive practices or actions that may violate laws. All competitive intelligence activities should align with Raindrop Inc.’s values and ethical standards. Employees are prohibited from engaging in any activities that could harm the reputation or violate the legal rights of competitors or third parties. The responsible and lawful collection of information is essential for Raindrop Inc. to make informed business decisions and maintain a competitive edge while upholding the highest ethical standards.

 

Contracting

Raindrop Inc. is dedicated to fostering fair and transparent business relationships through this Contracting Policy. The purpose of this policy is to provide guidelines for the negotiation, execution, and management of contracts with external parties. All employees involved in the contracting process must adhere to ethical standards and ensure compliance with applicable laws and regulations. Contracts should accurately reflect the intentions of the parties involved and be clear, concise, and unambiguous. The negotiation process should prioritize fair and equitable terms, fostering positive long-term partnerships. Raindrop Inc. encourages the involvement of legal and procurement professionals in the contracting process to ensure legal compliance and risk mitigation. Confidentiality provisions must be upheld, and employees should avoid conflicts of interest during contract negotiations. This policy aims to maintain the integrity of Raindrop Inc.’s contractual relationships, promoting transparency, ethical conduct, and the achievement of mutually beneficial outcomes.

 

Use of Raindrop Resources

Raindrop Inc. is committed to optimizing the use of company resources in an efficient, responsible, and ethical manner. This policy provides guidelines for employees on the appropriate use of Raindrop Inc.’s resources, including but not limited to equipment, facilities, technology, and intellectual property. All resources are to be utilized for business purposes that align with Raindrop Inc.’s objectives and values. While incidental personal use may be permitted, it should not interfere with work responsibilities, and excessive or inappropriate personal use is discouraged. Employees are expected to exercise care in the use of company equipment, maintain the confidentiality of company information, and comply with all relevant policies and guidelines. Raindrop Inc. promotes a culture of responsibility and accountability in the use of its resources to ensure their longevity, security, and continued availability for business operations.

 

Financial Integrity

Raindrop Inc. upholds the highest standards of financial integrity to maintain trust, transparency, and compliance in all financial activities. This policy outlines the principles guiding the ethical and accurate handling of financial matters within the organization. Employees are expected to conduct financial transactions with honesty, accuracy, and in compliance with relevant laws and regulations. This includes the truthful recording of financial information, accurate reporting, and protection of sensitive financial data. Any potential conflicts of interest related to financial matters should be promptly disclosed. Raindrop Inc. is dedicated to preventing fraud, misappropriation, and any unethical financial behavior, with employees encouraged to report concerns through established channels. Adherence to this policy ensures the financial health of Raindrop Inc. and reinforces our commitment to ethical business practices.

 

Public Disclosures

Raindrop Inc. is committed to maintaining transparency and accountability in its public disclosures. This policy outlines the principles and practices guiding the accurate and timely communication of information to the public, including stakeholders, investors, and regulatory authorities. All public disclosures, including financial reports, press releases, and other communications, must be truthful, complete, and in compliance with applicable laws and regulations. Raindrop Inc. ensures that material information is disclosed promptly to avoid misleading stakeholders. The company conducts regular reviews to assess the accuracy and consistency of public disclosures, with responsible parties held accountable for their accuracy. In the event of uncertainties or material changes, employees are required to consult with designated personnel responsible for public disclosures to ensure the information’s appropriateness and clarity. Through this policy, Raindrop Inc. aims to instill confidence in its stakeholders and uphold the highest standards of transparency in its public communications.

 

Charitable Donations

Raindrop Inc. recognizes the importance of contributing to the well-being of communities and supporting charitable causes. This policy establishes guidelines for charitable donations, emphasizing our commitment to social responsibility. Charitable contributions made by Raindrop Inc. align with our core values and focus areas, aiming to create a positive impact. All donation decisions are made impartially, considering the potential benefits to the community and the alignment with our corporate values. Employees involved in recommending or approving charitable donations must adhere to ethical standards and avoid any personal conflicts of interest. This policy reflects Raindrop Inc.’s dedication to making meaningful contributions to society, fostering a culture of philanthropy, and ensuring transparency and accountability in our charitable endeavors.

 

Corporate Social Responsibility (CSR)

Raindrop Inc. is committed to corporate social responsibility as an integral part of our business philosophy. This policy outlines our dedication to making a positive impact on society, the environment, and the communities in which we operate. We strive to conduct our business ethically, sustainably, and with a focus on social and environmental considerations. Our CSR initiatives encompass environmental sustainability, diversity and inclusion, community engagement, and ethical business practices. Raindrop Inc. supports initiatives that promote environmental conservation, social justice, and community development. We actively seek to minimize our environmental footprint, foster diversity in our workforce, and contribute to the well-being of the communities we serve. Regular assessments and transparent reporting mechanisms are in place to measure and communicate the progress of our CSR initiatives. By adhering to this policy, Raindrop Inc. aims to contribute to a sustainable and inclusive future while maintaining the highest standards of ethical conduct and corporate citizenship.