Our Policy Against Discrimination, Harassment, and Retaliation

Standards of Conduct, including Policy Against Discrimination, Harassment and Retaliation

 

Key Terms

The following terms in this Policy are defined as follows:

1.   “Firebrand” or the “Firm” means Firebrand Ventures, LP and its U.S.-based affiliated entities.

2.   “Firebrand Representatives” means each of the Firm’s partners, employees, consultants, interns, and other persons authorized to act on its behalf or otherwise representing the Firm.

3.   “Firebrand Business Partners” means the portfolio companies of the Firm’s affiliated investment funds (including funds sponsored by the Company) and all individuals acting on behalf of those entities (including such entities’ board members, founders, executives, and employees); the limited partners of the Firm’s affiliated investment funds; as well as all other persons or entities with whom the Firm conducts business or might reasonably be expected to conduct business.  “Firebrand Business Partners” also includes prospective portfolio companies and all individuals acting on behalf of such companies.

4.   “Personal Relationship” means a family, sexually intimate, or other close personal relationship between a Firebrand Representative and another person.  For this purpose, a “family” relationship is construed to be a relationship by blood, domestic partnership or marriage.

5.   A “Protected Characteristic” is a characteristic on the basis of which an employee, contractor or intern cannot be discriminated against by law, and includes race, color, religion, age (40-69), sex, disability, genetic information, military and veteran status, national origin or ancestry, citizenship status, and any other characteristic protected under applicable law.

 

General Standard of Conduct

 

Firebrand Representatives who violate this Policy, including the provisions regarding discrimination, harassment and retaliation, are subject to disciplinary action, up to and including termination of their employment.  The Firm will take other appropriate action if the offending party is a Firebrand Business Partner, with the focus on remedying the situation and preventing reoccurrence (including by potentially terminating a third party engagement or relationship).

 

Notwithstanding any other provision of this Policy, the Firm may take disciplinary action against a Firebrand Representative, up to and including termination of employment, for engaging in any conduct that the Firm determines reasonably likely to injure the Firm’s reputation or business interests, regardless of whether the conduct occurred in a setting or under circumstances directly related to Firm activities.

 

Professionalism & Ethics

 

Firebrand is committed to maintaining a working environment characterized by mutual respect.  The Firm expects all Firebrand Representatives to share this commitment and to demonstrate the highest degree of professionalism and integrity in all of their activities on behalf of or related to the Firm, including interactions with other Firebrand Representatives, Firebrand Business Partners, and others outside the Firm.

 

The Firm encourages and supports diverse perspectives, and is committed to maintaining an environment that supports the success and development of Firebrand Representatives as well as Firebrand Business Partners.  The Firm expects all Firebrand Representatives to respect diverse perspectives both within the Firm and in our broader business community.

 

Non-Discrimination Commitment

 

Firebrand is an equal opportunity employer.  Employment and other business decisions are based on legitimate business concerns and individual merit.  The Firm does not discriminate on the basis of any Protected Characteristic.

 

Firebrand Representatives are expected to act in a nondiscriminatory and professionally respectful manner consistent with this Policy when interacting with other Firebrand Representatives or with Firebrand Business Partners on behalf of the Firm.  Likewise, the Firm is committed to ensuring that Firebrand Representatives enjoy a safe and healthy working environment, and are not subjected to offensive or inappropriate conduct by other Firebrand Representatives or Firebrand Business Partners.  In that regard, the Firm expects and encourages Firebrand Business Partners to adhere to the same anti-discrimination and anti-harassment principles that apply to Firebrand Representatives as set forth in this Policy.

 

Prohibition on Harassment

 

The Firm strictly prohibits any form of harassment by Firebrand Representatives, including sexual harassment (as more fully described below).

 

A list of examples of harassing conduct, including conduct relating to sexual harassment, is set forth below. That list is not comprehensive.  To be clear, the Firm prohibits all harassing conduct at all times (whether identified below or not), regardless of whether the harassing conduct occurs on Firm premises or offsite, in any of the Firm’s business dealings or in circumstances unrelated to the Firm, when engaging in any form of Firebrand-related business activity or when representing Firebrand in any manner (including at industry events, whether or not sponsored by the Firm, or in other circumstances where the Firebrand Representative may be reasonably viewed as representing Firebrand in any way). 

 

Firebrand Representatives are expected to avoid any conduct that could reasonably be interpreted as violating this Policy.  This includes improper or unprofessional conduct by any Firebrand Representative toward another Firebrand Representative or a Firebrand Business Partner.

 

The Firm is also committed to providing Firebrand Representatives with protection from harassing conduct by any Firebrand Business Partner.  If a Firebrand Representative is concerned about the occurrence of such conduct, they should inform the Firm’s Managing Partner so that Firebrand has an opportunity to respond appropriately.

 

Sexual Harassment

 

Sexual harassment occurs when submission to or rejection of unwelcome sexual conduct is used as a basis for an employment or other business decision, including when submission to sexual harassment is a condition for receiving employment or other business benefits (such as promotions, compensation or specific assignments).  Sexual harassment may occur between members of the opposite sex (including harassment of women by men, and of men by women), and between members of the same sex, regardless of sexual orientation.

Sexual harassment also occurs when unwelcome sexual conduct unreasonably interferes with job performance or creates an intimidating, hostile or offensive working environment, even if it does not lead to tangible or economic job consequences. 

The following is a partial list of examples of conduct prohibited by this policy:

  • Unwanted sexual advances (physical or verbal);

  • Making or threatening reprisals after a negative response to sexual advances;

  • Visual conduct such as leering, making sexual gestures, displaying of sexually suggestive objects or pictures, cartoons, posters or computer graphics;

  • Verbal conduct such as derogatory comments, epithets, slurs, or inappropriate or offensive jokes;

  • Verbal abuse of a sexual nature, graphic verbal commentaries about an individual’s body, sexually degrading words used to describe an individual, or suggestive or obscene letters, notes, emails, texts, social media posts, or invitations.

Other Harassing Conduct

In addition to sexual harassment, this Policy also prohibits harassment directed against Firebrand Representatives and Firebrand Business Partners because of a Protected Characteristic.   Conduct that may constitute sexual harassment and/or harassment because of a Protected Characteristic includes, but is not limited to, the following:

  • Physical conduct such as touching, assaulting, or impeding or blocking movements, or damage to a person’s work area or property; 

  • Socially or physically excluding or disregarding a person in work-related activities, or engaging in similar bullying tactics or efforts to isolate and embarrass such person; 

  • Retaliation for having reported conduct that violates this Policy, assisting another in making a report, or participating in an investigation of a potential violation of this Policy.

In addition, derogatory, hostile, abusive or offensive comments or conduct directed at or towards another person because of a Protected Characteristic are similarly prohibited under this Policy and are subject to the same complaint, investigation and disciplinary measures applicable to sexual harassment.

Reporting Procedures

Early reporting and intervention are the most effective methods of resolving actual or perceived incidents of discrimination, harassment or retaliation.  Therefore, all Firebrand Representatives are required to promptly report complaints or concerns of potential violations of this Policy so that constructive action can be taken.

Specifically, all Firebrand Representatives must promptly report any such complaints or concerns (including violations that the individual personally experiences or witnesses) to the Firm’s Managing Partner.  Reports should provide details of the incident(s), date(s), names of the individuals involved and names of any witnesses.  It is preferable that complaints be communicated in writing, but it is not mandatory to do so.

The Firm will not retaliate against anyone for taking any of the following actions in good faith: reporting violations of this Policy, assisting another in making a report, or participating in an investigation under this Policy; and the Firm will not tolerate retaliation by others.  Any Firebrand Representative who knowingly makes a false report in connection with this Policy will be subject to disciplinary action, up to and including termination of employment.

The Firm encourages employees to address unwelcome conduct directly with the person they believe is engaging in such unwelcome conduct, in addition to following the complaint procedures above.  However, addressing the conduct with the other person is not required, particularly if the employee feels unsafe or uncomfortable doing so.  Nevertheless, the Firm expects and encourages personnel to work together cooperatively, to share concerns in a constructive and respectful way, and to support the Firm’s efforts to respond to such concerns and maintain a workplace free of harassment and discrimination.

Investigation & Response

 

After Firebrand receives a report pursuant to this Policy, the Firm will conduct an investigation.  The investigation will be conducted by qualified in-house personnel or an outside investigator, as determined by the Firm in consultation with outside legal counsel as appropriate.  Any investigation will be fair, prompt and thorough, and will provide all parties an appropriate opportunity to provide information regarding the concerns raised in order to allow the Firm to reach reasonable conclusions and take informed actions, based on the evidence collected. 

All investigations will be conducted in a discreet manner.  Information disclosed during the course of the investigation will remain confidential except to the extent reasonably necessary to conduct the investigation and to take any remedial action, or as otherwise required by law.

The Firm may exercise its discretion to put certain interim measures in place, such as suspension or a leave of absence, while an investigation proceeds.  At the conclusion of the investigation, if the Firm determines a Policy violation has occurred, it will take appropriate remedial action, up to and including termination of employment (or termination of the applicable business engagement or relationship).  If a person found to have violated this Policy is not employed or otherwise directly engaged by Firebrand, the Firm will take whatever corrective action it determines reasonable and appropriate under the circumstances, with the aim of protecting Firebrand Representatives and Firebrand Business Partners.

Because the Firm is committed to avoiding even the appearance of impropriety with respect to harassment or discrimination, it may take corrective action for inappropriate conduct learned during the course of any investigation, regardless of whether the conduct amounts to a violation of law or even a material violation of this Policy.

Firebrand Representatives who violate this Policy against harassment, discrimination and retaliation will be subject to disciplinary action, up to and including termination of employment (or other administrative or contractual sanctions).

Non-Retaliation

 

Firebrand will not tolerate retaliation or retribution against any Firebrand Representative or Firebrand Business Partner for making a good faith report regarding violations of law or Firebrand policies.  Retaliation includes, but is not limited to, any adverse job action taken because of a retaliatory motive.

 

Firebrand Representatives must report any retaliation of which they are aware to the Firm’s Managing Partner.  Firebrand will investigate reports of retaliation in the same manner as it investigates claims of harassment or discrimination (discussed above), and will take appropriate remedial action based on the findings of its investigation.

 

Other Guidelines

 

This Policy should not, and may not, be used as a basis for excluding or separating individuals of a particular sex or gender, or any other protected characteristic, from participating in business or work-related social activities or discussions in order to avoid allegations of harassment.

 

This Policy, as well as other Firm policies or practices, is not an express or implied contract, bargain or agreement, nor does it confer or amend any contractual rights whatsoever or guarantee your employment with the Firm for any specific duration.

 

Other Resources

If a Firebrand Representative reports a complaint and the result of the internal investigation is not satisfactory to him or her, the individual may file a charge with the Kansas Department of Labor or notify the Equal Employment Opportunity Commission (EEOC).  These agencies can provide more information about their rules and procedures.