CODE OF CONDUCT

INTRODUCTION

Employers of Serena Von Romvesen, Members of her Website (“www.serenavonromvesen.com”), or any of her affiliates or subsidiaries (“Serena Von Romvesen”), and others performing work for Serena Von Romvesen or on her behalf, collectively referred to in this code as “Serena Von Romvesen Personnel”, are expected to act lawfully, honestly, ethically, and in the best interests of Serena Von Romvesen while performing duties on her behalf. This code provides some guidelines for business conduct required of Serena Von Romvesen Personnel. Persons who are unsure whether their conduct or the conduct of other Serena Von Romvesen Personnel complies with this code should contact Serena Von Romvesen directly. This code applies to all Serena Von Romvesen Personnel, including but not limited to Photographers and Brand Ambassadors (in connection with their work for Serena Von Romvesen), members of her website (“www.serenavonromvesen.com”), and others working on Serena Von Romvesen’s behalf. This code is subject to change and may be amended, supplemented, or superseded by one or more separate policies.

If any part of this code conflicts with local laws or regulations, only the sections of this code permitted by applicable laws and regulations will apply. Any policies that are specifically applicable to your jurisdiction will take precedence to the extent they conflict with this code.

HARASSMENT

Serena Von Romvesen does not tolerate any form of harassment or any mistreatment by or of Serena Von Romvesen Personnel (including but not limited to individual contributors, employers, and contingent workers), guests, clients, or sponsors on her website (“www.serenavonromvesen.com”), in the workplace, or in a work-related situation on the basis of sex, race, color, nationality, ethnic or national origin, ancestry, citizenship, religion (or belief, where applicable), age, physical or mental disability, medical condition, sexual orientation, veteran status, marital status, genetic information or characteristics (or those of a family member), or any other category protected under applicable federal, state, or local law. If you suspect harassment, discrimination, or retaliation (as described below in my Harassment Policy) has occurred, you are encouraged, and Serena Von Romvesen Personnel are required, to promptly provide a written or oral complaint to Serena Von Romvesen directly. Please refer to our full Harassment Policy below for further description.

HARASSMENT POLICY & COMMUNITY STANDARDS

Introduction to Harassment Policy:

The conversations that happen on Serena Von Romvesen’s website (“www.serenavonromvesen.com”) and in work-related situations reflect the diversity of a community from all over the world, with people communicating across countries and cultures and in dozens of languages, posting everything from text to photos and videos.

We recognize how important it is for Serena Von Romvesen’s website (“www.serenavonromvesen.com”) to be a place where people feel empowered to communicate, and we take our role in keeping abuse off our service seriously. That’s why we have developed a set of Community Standards that outline what is and is not allowed on Serena Von Romvesen’s website (“www.serenavonromvesen.com”). Our Standards apply around the world to all types of content. They’re designed to be comprehensive – for example, content that might not be considered hate speech may still be removed for violating our bullying policies.

The goal of our Community Standards is to encourage expression and create a safe environment.

Our policies are also rooted in the following principles:

Safety: People need to feel safe in order to build community. We are committed to removing content that encourages real-world harm, including (but not limited to) physical, financial, and emotional injury.

Voice: Our mission is all about embracing diverse views. We are on the side of allowing content, even when some find it objectionable, unless removing that content can prevent a specific harm. Moreover, at times we will allow content that might otherwise violate our standards if we feel that it is newsworthy, significant, or important to the public interest. We do this only after weighing the public interest value of the content against the risk of real-world harm.

Equity: Our community is global and diverse. Our policies may seem broad, but that is because we apply them consistently and fairly to a community that transcends regions, cultures, and languages. As a result, our Community Standards can sometimes appear less nuanced than we would like, leading to an outcome that is at odds with their underlying purpose. For that reason, in some cases, and when we are provided with additional context, we make a decision based on the spirit, rather than the letter, of the policy.

Everyone on Serena Von Romvesen’s website (“www.serenavonromvesen.com”) plays a part in keeping the platform safe and respectful. We ask people to share responsibly and to let Serena Von Romvesen know when they see something that may violate our Community Standards. The consequences for violating our Community Standards vary depending on the severity of the violation and a person's history on the platform. For instance, we may warn someone for a first violation, but if they continue to violate our policies, we may restrict their ability to post on Serena Von Romvesen’s website (“www.serenavonromvesen.com”) or disable their profile. We also may notify law enforcement when we believe there is a genuine risk of physical harm or a direct threat to public safety.

Our Community Standards, which we will continue to develop over time, serve as a guide for how to communicate on Serena Von Romvesen’s website (“www.serenavonromvesen.com”). It is in this spirit that we ask members of the community to follow these guidelines.

1. Violence and Incitement

-Policy Rationale

We aim to prevent potential offline harm that may be related to content on Serena Von Romvesen’s website (“www.serenavonromvesen.com”). While we understand that people commonly express disdain or disagreement by threatening or calling for violence in non-serious ways, we remove language that incites or facilitates serious violence. We remove content, disable accounts, and work with law enforcement when we believe there is a genuine risk of physical harm or direct threats to public safety. We also try to consider the language and context in order to distinguish casual statements from content that constitutes a credible threat to public or personal safety. In determining whether a threat is credible, we may also consider additional information like a person's public visibility and vulnerability.

-Do not post:

Threats that could lead to death (and other forms of high-severity violence) of any target(s) where threat is defined as any of the following:

Statements of intent to commit high-severity violence; or
Calls for high-severity violence
Including content where no target is specified but a symbol represents the target and/or includes a visual of an armament to represent violence; or
Statements advocating for high-severity violence; or
Aspirational or conditional statements to commit high-severity violence

Threats that lead to serious injury (mid-severity violence) towards private individuals, minor public figures, vulnerable persons, or vulnerable groups where threat is defined as any of the following:

• Statements of intent to commit violence; or
  Statements advocating violence; or
  Calls for mid-severity violence including content where no target is specified but a symbol represents the target; or
  Aspirational or conditional statements to commit violence; or
  Other target(s) apart from private individuals, minor public figures, vulnerable persons, or vulnerable groups and any credible:

Statements of intent to commit violence; or
Calls for action of violence; or
Statements advocating for violence; or
Aspirational or conditional statements to commit violence

Threats that lead to physical harm (or other forms of lower-severity violence) towards private individuals (self-reporting required) or minor public figures where threat is defined as any of the following:

• Private individuals (name and/or face match are required) or minor public figures that includes:

Statements of intent, calls for action, advocating, aspirational or conditional statements to commit low-severity violence

Imagery of private individuals or minor public figures that has been manipulated to include threats of violence either in text or pictorial (adding bulls eye, dart, gun to head, etc.)

Any content created for the express purpose of outing an individual as a member of a designated and recognizable at-risk group

Instructions on how to make or use weapons if there’s evidence of a goal to seriously injure or kill people, through:

Language explicitly stating that goal, or
Photos or videos that show or simulate the end result (serious injury or death) as part of the instruction
Unless the aforementioned content is shared as part of recreational self defense, for military training purposes, commercial video games, or news coverage (posted by Page or with news logo)

Providing instructions on how to make or use explosives:

Unless there is clear context that the content is for a non-violent purpose (for example part of commercial video games, clear scientific/educational purpose, fireworks, or specifically for fishing)

Any content containing statements of intent, calls for action, or advocating for high or mid-severity violence due to voting, voter registration, or the outcome of an election.

2. Promoting or Publicizing Crime

-Policy Rationale

We prohibit people from promoting or publicizing violent crime, theft, and/or fraud because we do not want to condone this activity and because there is a risk of copycat behavior. We also do not allow people to depict criminal activity or admit to crimes they or their associates have committed. We do, however, allow people to debate or advocate for the legality of criminal activities, as well as address them in a rhetorical or satirical way.

-Do not post:

Content depicting, admitting, or promoting the following criminal acts committed by you or your associates

Acts of physical harm committed against people
Acts of physical harm committed against animals except in cases of hunting, fishing, religious sacrifice, or food preparation/processing
Poaching or selling endangered species or their parts
Staged animal vs. animal fights
Theft
Vandalism or property damage
Fraud
Trafficking
Sexual violence or sexual exploitation, including sexual assault

3. Coordinating Harm

-Policy Rationale

In an effort to prevent and disrupt real-world harm, we prohibit people from facilitating or coordinating future activity, criminal or otherwise, that is intended or likely to cause harm to people, businesses, or animals. People can draw attention to harmful activity that they may witness or experience as long as they do not advocate for or coordinate harm.

-Do not post:

Statements of intent, calls to action, or advocating for the following:

• Acts of physical harm committed against people
  Acts of physical harm committed against animals except in cases of hunting, fishing, religious sacrifice, or food preparation/processing
  Staged animal vs. animal fights
  Theft
  Vandalism/property damage
  Swatting
  Fraud, defined as the deliberate deception to take advantage of another, secure an unfair gain, or deprive another of money, property, or legal right. Examples of fraud include, but are not limited to:

• Bribery
  Embezzlement
  Money Laundering (concealment of the origins of criminally obtained money)
  Supporting and/or facilitating the misuse of payment cards
  Voter fraud, defined as any offers to buy or sell votes with cash or gifts
  Voter suppression, defined as:

Misrepresentation of the dates, locations, and times, and methods for voting or voter registration
Misrepresentation of who can vote, qualifications for voting, whether a vote will be counted, and what information and/or materials must be provided in order to vote.
Other misrepresentations related to voting in an official election may be subject to false news standards
Arranged marriages with refugees or internally displaced persons
Trafficking
Sexual violence or sexual exploitation, including sexual assault

Offers of services to smuggle or assist in smuggling people.

Content that depicts, promotes, advocates for or encourages participation in a high risk viral challenge, including content with no caption or one that expresses a neutral sentiment.

4. Regulated Goods

-Policy Rationale

To encourage safety and compliance with common legal restrictions, we prohibit attempts by individuals, manufacturers, and retailers to purchase, sell, or trade non-medical drugs, pharmaceutical drugs, and marijuana. We also prohibit the purchase, sale, gifting, exchange, and transfer of firearms, including firearm parts or ammunition, between private individuals on Serena Von Romvesen’s website (“www.serenavonromvesen.com”). Some of these items are not regulated everywhere; however, because of the borderless nature of our community, we try to enforce our policies as consistently as possible. Firearm stores and online retailers may promote items available for sale off of our services as long as those retailers comply with all applicable laws and regulations. We allow discussions about sales of firearms and firearm parts in stores or by online retailers and advocating for changes to firearm regulations. Regulated goods that are not prohibited by our Community Standards may be subject to our more stringent Commerce Policies.

-Do not post:

Content about non-medical drugs (other than alcohol or tobacco) that

Coordinates or encourages others to sell non-medical drugs
Depicts, admits to, attempts to purchase, or promotes sales of non-medical drugs by the poster of the content or their associates
Promotes, encourages, coordinates, or provides instructions for use or make of non-medical drugs
Admits, either in writing or verbally, to personal use of non-medical drugs unless posted in a recovery context

Content that depicts the sale or attempt to purchase marijuana and pharmaceutical drugs. This includes content that

• Mentions or depicts marijuana or pharmaceutical drugs
  Makes an attempt to sell or trade, by which we mean any of the following:

  • Explicitly mentioning the product is for sale or trade or delivery
    Asking the audience to buy
    Listing the price
    Encouraging contact about the product either by explicitly asking to be contacted or including any type of contact information
    Attempting to solicit the product, defined as:

Stating interest in buying the product, or
Asking if anyone has the product for sale/trade
This applies to both individual pieces of content and Pages and Groups primarily dedicated to the sale of marijuana or pharmaceutical drugs

Content that attempts to sell, gift, exchange, or transfer firearms, firearm parts, ammunition, or explosives between private individuals. This includes content that

• Mentions or depicts firearms, firearm parts, ammunition, or explosives and a product unrelated to firearms, and
  Makes an attempt to sell or transfer including any of the following, unless posted by an entity representing a brick-and-mortar store, legitimate website, or brand:

  • Explicitly mentioning the product is for sale or trade or delivery
    Asking the audience to buy
    Listing the price or noting that the product is free
    Encouraging contact about the product either by

  • Explicitly asking to be contacted
    Including any type of contact information
    Making an attempt to solicit the item for sale, defined as

Stating that they are interested in buying the good, or
Asking if anyone else has the good for sale/trade

Content that attempts to sell, gift, exchange, transfer, promote or otherwise provide access to instructions for 3D printing or computer-aided manufacturing of firearms or firearm parts.

Content that depicts the trade (buying or selling) of human organs and/or blood where trade is defined as:

Mentioning or depicting the human organs and/or blood, and
Indicating that human organs and/or blood are available for selling or buying, or
Listing a price or expressing willingness to discuss price

Content that encourages contact to facilitate the trade of human organs and/or blood

Content that attempts to sell live animals between private individuals.

Content that coordinates or supports the poaching or selling of endangered species and their parts

For the following content, we restrict visibility to adults twenty-one years of age and older:

Content posted by or promoting a brick-and-mortar store, legitimate website, or brand, which coordinates or promotes the sale or transfer of firearms, firearm parts, ammunition, or explosives. This includes content that

• Explicitly mentions the product is for sale or transfer and

-Asks the audience to buy the product, or
-Lists the price or notes that the product is free, or
-Encourages contact about the product either by explicitly asking to be contacted or including any type of contact information

Commerce Policies:

Prohibited Content:

The sale of the following is prohibited on Serena Von Romvesen’s website (“www.serenavonromvesen.com”) Commerce Products:

1. Community Standards

-Commerce posts must not violate our Community Standards.

2. Illegal, Prescription, or Recreational Drugs

-Posts may not promote the sale of illegal, prescription or recreational drugs.

3. Tobacco Products and Related Paraphernalia

-Posts may not promote the sale of tobacco products or tobacco paraphernalia.

4. Unsafe Supplements

-Posts may not promote the sale of unsafe supplements, as determined by Serena Von Romvesen’s website (“www.serenavonromvesen.com”) in its sole discretion.

5. Weapons, Ammunition or Explosives

-Posts may not promote the sale or use of weapons, ammunition, or explosives.

6. Animals

-Posts may not promote the sale of any animals.

7. Adult Products or Services

-Posts may not promote the sale or use of adult products or services.

8. Alcohol

-Posts may not promote the sale of alcohol.

9. Healthcare Products

-Posts may not promote certain healthcare products and services, including medical devices, smoking cessation products containing nicotine, body parts or fluids, or posts that contain "before and after" images.

10. Real Money Gambling Services

-Posts may not promote or facilitate online gambling, games of skill or lotteries, including online casinos, sports books, bingo, or poker if it costs money.

11. Fraudulent, Misleading, Deceptive Or Offensive

-Posts may not contain deceptive, false, misleading or offensive offers or products.

12. Products With Overtly Sexualized Positioning

-Posts may not position products or services in a sexually suggestive manner.

13. Subscriptions Or Digital Products

-Posts may not promote the sale of downloadable digital content, digital subscriptions or digital accounts.

14. Digital Media and Electronic Devices

-Posts may not promote the sale of devices that facilitate or encourage streaming digital content in an unauthorized manner or interfering with the functionality of electronic devices.

15. Real, Virtual Or Fake Currency

-Posts may not promote the sale of real, virtual or fake currency.

16. No Commercial Intent

-Posts may not promote news, humor or other content that has no intention to buy or sell products or services.

17. Third-Party Infringement

-Posts may not contain content that infringes upon or violates the intellectual property rights of any third party, including copyright or trademark. This includes, but is not limited to, the promotion or sale of counterfeits, such as goods that copy the trademark (name or logo) and/or distinctive features of another company’s products to imitate a genuine product.

18. Discrimination

-Posts must not wrongfully discriminate or suggest a preference for or against people because of a personal characteristic, included but not limited to, race, ethnicity, color, national origin, citizenship, religion, age, sex, sexual orientation, gender identity, family status, marital status, disability, or medical or genetic condition. Posts must comply with all applicable laws prohibiting discrimination. This includes but is not limited to discrimination for housing posts.

Restricted Content:

The sale of the following is restricted on Serena Von Romvesen’s website (“www.serenavonromvesen.com”) Commerce Products:

1. Events Or Admission Tickets

-Posts may not promote the sale of tickets, except with the prior written permission from Serena Von Romvesen’s website (“www.serenavonromvesen.com”).

2. Services on Marketplace

-Home services may only be posted with Serena Von Romvesen's written permission.

3. Gift Cards

-Posts may not promote the sale of gift cards, except with the prior written permission from Serena Von Romvesen.

5. Safety

1. Suicide and Self-Injury

In an effort to promote a safe environment on Serena Von Romvesen’s website (“www.serenavonromvesen.com”), we remove content that encourages suicide or self-injury, including certain graphic imagery and real-time depictions that experts tell us might lead others to engage in similar behavior. Self-injury is defined as the intentional and direct injuring of the body, including self-mutilation and eating disorders. We want Serena Von Romvesen’s website (“www.serenavonromvesen.com”) to be a space where people can share their experiences, raise awareness about these issues, and seek support from one another, which is why we allow people to discuss suicide and self-injury.

We remove any content that identifies and negatively targets victims or survivors of self-injury or suicide seriously, humorously, or rhetorically.

2. Child Nudity and Sexual Exploitation of Children

We do not allow content that sexually exploits or endangers children. When we become aware of apparent child exploitation, we report it to the National Center for Missing and Exploited Children (NCMEC), in compliance with applicable law. We know that sometimes people share nude images of their own children with good intentions; however, we generally remove these images because of the potential for abuse by others and to help avoid the possibility of other people reusing or misappropriating the images.

3. Sexual Exploitation of Adults

We recognize the importance of Serena Von Romvesen’s website (“www.serenavonromvesen.com”) as a place to discuss and draw attention to sexual violence and exploitation. We believe this is an important part of building common understanding and community. In an effort to create space for this conversation while promoting a safe environment, we remove content that depicts, threatens or promotes sexual violence, sexual assault, or sexual exploitation, while also allowing space for victims to share their experiences. We remove content that displays, advocates for, or coordinates sexual acts with non-consenting parties. We do this to avoid facilitating transactions that may involve trafficking, coercion, and non-consensual sexual acts.

To protect victims and survivors, we also remove images that depict incidents of sexual violence and intimate images shared without permission from the people pictured.

4. Bullying and Harassment

Bullying and harassment happen in many places and come in many different forms, from making threats to releasing personally identifiable information, to sending threatening messages, and making unwanted malicious contact. We do not tolerate this kind of behavior because it prevents people from feeling safe and respected on Serena Von Romvesen’s website (“www.serenavonromvesen.com”).

We remove content that's meant to degrade or shame, including, for example, claims about someone's sexual activity. We recognize that bullying and harassment can have a negative emotional impact on people.

We allow people to share and reshare posts if it is clear that something was shared in order to condemn or draw attention to bullying and harassment.

5. Privacy Violations and Image Privacy Rights

Privacy and the protection of personal information are fundamentally important values for Serena Von Romvesen’s website (“www.serenavonromvesen.com”). We work hard to keep your account secure and safeguard your personal information in order to protect you from potential physical or financial harm. You should not post personal or confidential information about others without first getting their consent. We also provide people ways to report imagery that they believe to be in violation of their privacy rights.

6. Objectionable Content

1. Hate Speech

We do not allow hate speech on Serena Von Romvesen’s website (“www.serenavonromvesen.com”) because it creates an environment of intimidation and exclusion and in some cases may promote real-world violence.

We define hate speech as a direct attack on people based on what we call protected characteristics — race, ethnicity, national origin, religious affiliation, sexual orientation, caste, sex, gender, gender identity, and serious disease or disability. We also provide protections for immigration status. We define attack as violent or dehumanizing speech, statements of inferiority, or calls for exclusion or segregation. We separate attacks into three tiers of severity, as described below.

Sometimes people share content containing someone else’s hate speech for the purpose of raising awareness or educating others. In some cases, words or terms that might otherwise violate our standards are used self-referentially or in an empowering way. Other times, they use gender-exclusive language to control membership in a health or positive support group, such as a breastfeeding group for women only. In all of these cases, we allow the content but expect people to clearly indicate their intent, which helps us better understand why they shared it. Where the intention is unclear, we may remove the content.

We allow humor and social commentary related to these topics. In addition, we believe that people are more responsible when they share this kind of commentary using their authentic identity.

2. Violence and Graphic Content

We remove content that glorifies violence or celebrates the suffering or humiliation of others because it may create an environment that discourages participation. We allow graphic content (with some limitations) to help people raise awareness about issues. We know that people value the ability to discuss important issues like human rights abuses or acts of terrorism.

3. Cruel and Insensitive

We believe that people share and connect more freely when they do not feel targeted based on their vulnerabilities. As such, we have higher expectations for content that we call cruel and insensitive, which we define as content that targets victims of serious physical or emotional harm.

7. Integrity and Authenticity

1. Spam

We work hard to limit the spread of commercial spam to prevent false advertising, fraud, and security breaches, all of which detract from people's ability to share and connect. We do not allow people to use misleading or inaccurate information to collect likes, followers, or shares.

2. Misrepresentation

Authenticity is the cornerstone of our community. We believe that people are more accountable for their statements and actions when they use their authentic identities. Our authenticity policies are intended to create a safe environment where people can trust and hold one another accountable.

3. False News

Reducing the spread of false news on Serena Von Romvesen’s website (“www.serenavonromvesen.com”) is a responsibility that we take seriously. We also recognize that this is a challenging and sensitive issue. We want to help people stay informed without stifling productive public discourse. There is also a fine line between false news and satire or opinion. For these reasons, we may remove false news from Serena Von Romvesen’s website (“www.serenavonromvesen.com”).

8. Respecting Intellectual Property

1. Intellectual Property

Serena Von Romvesen’s website (“www.serenavonromvesen.com”) takes intellectual property rights seriously and believes they are important to promoting expression, creativity, and innovation in our community. You own all of the content and information you post on Serena Von Romvesen’s website (“www.serenavonromvesen.com”). However, before sharing content on Serena Von Romvesen’s website (“www.serenavonromvesen.com”), please be sure you have the right to do so. We ask that you respect other people’s copyrights, trademarks, and other legal rights. We are committed to helping people and organizations promote and protect their intellectual property rights. Serena Von Romvesen’s website (“www.serenavonromvesen.com”) does not allow people to post content that violates someone else’s intellectual property rights, including copyright and trademark.

9. Content-Related Requests

1. User Requests

We comply with:

• User requests for removal of their own account

• Requests for removal of a deceased user’s account from a verified immediate family member or executor

• Requests for removal of an incapacitated user’s account from an authorized representative

• Requests for removal of a photo of themselves

2. Additional Protection of Minors

We comply with:

• Requests for removal of an underage account

• Government requests for removal of child abuse imagery

CONFIDENTIAL INFORMATION

Serena Von Romvesen’s confidential business information is a valuable asset that everyone must protect. Serena Von Romvesen’s Personnel are required to use confidential information of Serena Von Romvesen for business purposes only and must always keep such information in strict confidence. This responsibility extends to confidential information of third parties that we have received under non-disclosure agreements. Confidential information includes, without limitation, proprietary data, trade secrets and know-how such as software and product designs, product plans, inventions, laboratory notebooks, processes, designs, drawings, engineering, customer lists, employee data (other than your own), financial information, budgets, pricing, business plans, or other business information.
Your obligation to maintain the confidentiality of this information means that you may not share any such information outside of Serena Von Romvesen’s website (“www.serenavonromvesen.com”) or with Serena Von Romvesen directly unless Serena Von Romvesen has appropriate non-disclosure agreements in place. For help in establishing such an agreement, if you have questions about provisions of a non-disclosure agreement already in place, or if you have questions about whether certain information can be disclosed, please contact Serena Von Romvesen directly. Serena Von Romvesen’s Personnel should also refrain from sharing confidential information internally beyond those persons who legitimately need to know it for purposes of their job. We have an open and transparent culture, and this is not intended to stifle the ongoing conversation and sharing that has facilitated so much of our success. Rather, you should use your judgment to share what is appropriate inside of Serena Von Romvesen’s website (“www.serenavonromvesen.com”) in furtherance of your and others’ jobs. Please always keep in mind that improper use or disclosure of confidential business information could seriously damage Serena Von Romvesen’s reputation with users, business partners and the community, expose us to liability, and cause harm to our business.
In addition, you are not to bring with you to Serena Von Romvesen’s website (“www.serenavonromvesen.com”), or use or disclose to any person associated with Serena Von Romvesen, any confidential or proprietary information belonging to any former employer or other person or entity to which you owe an obligation of confidentiality under any agreement or otherwise. Serena Von Romvesen does not need and will not use such information, and we will assist you in any way possible to preserve and protect the confidentiality of proprietary information belonging to third parties.
Note that this code is not intended to restrict an employee’s legal right to discuss the terms and conditions of his/her employment.

PROTECTION OF USER DATA AND PERSONNEL DATA

Depending on your role with Serena Von Romvesen, you may have access to information systems or tools that enable you to view certain information relating to users and other individuals (including your co-workers, as well as registered and non-registered individuals), which would otherwise not be visible to you. These tools are important and necessary to enable you to perform your work effectively. However, it is of the utmost importance that all Serena Von Romvesen’s Personnel treat this data access with extreme sensitivity and caution. You are only authorized to access this data to the extent it is required for you to do your job. This data is confidential and subject to the privacy protections. Serena Von Romvesen's brand and the trust users put in us depend on your responsible use of tools that allow you to view user information that would otherwise not be visible to you. Please read the User Data Access Policy, available on the wiki, which governs your use of and access to user data. In your role with Serena Von Romvesen, you may have access to information systems or tools that enable you to view personal information relating to Serena Von Romvesen’s Personnel. These tools are important and necessary to enable you to perform your work effectively. However, this data is confidential and subject to the privacy protections.

Compliance with Laws

Serena Von Romvesen’s Personnel are expected to act within the bounds of applicable laws, rules, and regulations of the countries where we do business. The application of these and other laws can be complex and fact-dependent.

Here are some of the legal areas to keep in mind:

• Data Privacy

Serena Von Romvesen’s Personnel must comply with all applicable data privacy laws and legal requirements. These include laws governing the collection, access, and use of data.

• Anti-Corruption

Serena Von Romvesen’s Personnel must comply with all anti-corruption laws of the countries in which we do business, including the U.S. Foreign Corrupt Practices Act (FCPA), which applies globally.

• International Trade

Serena Von Romvesen’s Personnel must also comply with all applicable international trade laws and regulations. These laws and regulations apply to the import and export of goods and technical data to and from the U.S. and other countries, transactions or dealings with sanctioned countries and restricted parties, and anti-boycott requests.

• Lobbying and Campaign Finance

Serena Von Romvesen’s Personnel must also comply with applicable lobbying and campaign finance laws. These laws vary across jurisdictions and apply generally when Serena Von Romvesen makes political contributions or engages on policy issues with government entities, elected officials, and candidates for public office.

• Competition

Serena Von Romvesen is committed to competing in a fair and vigorous manner, in compliance with all applicable antitrust and competition laws. Antitrust laws protect consumers by prohibiting anti competitive conduct that can restrict free competition. In accordance with these laws and regulations, Serena Von Romvesen’s Personnel must never agree, either directly or indirectly, with competitors: (1) to set prices or other terms related to our products; (2) to allocate customers, advertisers, territories, or product markets; or (3) not to deal with a particular company (called a “group boycott”). Further, some conduct may be considered unfair or illegal in certain circumstances, including:

• Sharing competitively sensitive information with competitors;

• Leveraging market power to gain an unfair competitive advantage;

• Requiring a purchaser to resell a product at or above a particular price;

• Entering into agreements with suppliers or customers that impose exclusivity obligations; and

• Requiring customers to purchase one product to get access to another product (also called “tying”).

• Insider Trading

Under the federal securities laws, it is generally illegal to trade in securities while in possession of material nonpublic information about Serena Von Romvesen. It is also generally illegal to provide material nonpublic information about Serena Von Romvesen to others who then trade on the basis of that information.

• Environmental Health and Safety

Serena Von Romvesen is committed to complying with environmental, health, and safety (EHS) laws and regulations in the workplace and in the communities where we operate. Our EHS programs are designed to protect the environment, maintain a secure workplace, and provide Serena Von Romvesen’s Personnel with the necessary resources to comply with EHS laws and Serena Von Romvesen’s values and standards.

REPORTING VIOLATIONS

If you learn about or suspect a violation of this code, another policy, or any law, you shall promptly report it to Serena Von Romvesen directly. If you are uncomfortable making such a report, you may do so anonymously if permitted by applicable law.

In cases in which an individual reports a suspected violation of policy or law in good faith and is not engaged in the reported conduct, Serena Von Romvesen will attempt to keep its discussions and actions confidential to the greatest extent possible and in compliance with applicable laws and regulations governing privacy. Serena Von Romvesen will not retaliate against anyone making a good-faith report of a potential violation. Serena Von Romvesen will appropriately investigate any report of a violation. You must cooperate fully with any investigation, but should not investigate independently, as alleged violations may involve complex legal issues, and you may risk compromising the integrity of a formal investigation.

Conduct that violates the law or company policies is grounds for prompt disciplinary or remedial action. In addition, your failure to report a known violation of law or company policy by someone else may result in disciplinary action for employees and termination of employment/your relationship with Serena Von Romvesen. Discipline for a violation of these policies or applicable law may range from a warning up to and including summary termination of employment/your relationship with Serena Von Romvesen (in accordance with applicable law). Serena Von Romvesen’s response to reports of possible violations of law may involve disclosure to and cooperation with the appropriate authorities.

POLICY PROHIBITING RETALIATION

It is against Serena Von Romvesen’s policy (and may be unlawful) for any of Serena Von Romvesen’s Personnel to retaliate against any person for reporting what he or she believed in good faith to be a violation of this code, expressing an intent to report what he or she believed in good faith to be a violation of this code, assisting other Serena Von Romvesen Personnel to report a violation of this code, or participating in any investigation pursuant to this code.