360Learning Ethics, Social, and Environmental Responsibility Charter

Summary

360Learning exists as part of a larger system, made up of people, values, and obligations. We take these values and obligations seriously, which is why we maintain the highest standards when it comes to social and environmental responsibility and ethical conduct.

Our Ethics, Social and Environmental Responsibility Charter describes how 360Learning and all 360Learners conduct business, and outlines the fundamental values we share as a group, wherever we operate in the world.

Preamble

At 360Learning, we operate according to a clearly-defined set of values and commitments. 

Our “Convexity” culture is at the heart of our operations, in our ongoing will to respect ethics and responsible commitments. Through the application of its values, Convexity guides us on a daily basis, in the way we work as a team, empowering each individual with a high degree of autonomy.

Statement

"Convexity allows us to set ambitious goals, to work in a flexible environment, to grow and to learn, in full transparency. We are determined to establish a culture of integrity, ethics and compliance within the 360Learning Group, knowing that our growth can only be sustainable if it is rooted in social, ethical and environmental responsibility.

As the Group's CEO, I will ensure that this line of conduct is upheld and that we mobilize appropriate means for our scale and activities, in order to prevent and detect breaches of the commitments made in our Charter.

These commitments are fundamental, which is why I expect each member of the management team and every 360Learner to ensure that these commitments are applied to all of our business and strategic decisions."

Nicolas Hernandez, 

CEO and Co-founder

Convexity is not only what we believe to be the ideal framework for our day-to-day work; it is also our secret weapon, which enables us to achieve our greatest aspirations, and to completely rethink the way we learn from each other.

Convexity is made up of 13 pillars which are reflected in each of our values:

• Impact: To achieve greatness, we set ambitious goals, then define the quickest path to hitting them. We speak, think and act with ambition.
• Low Authority: Leaders lead without giving orders. Every 360Learner in a team can be the leader of the team.
• High Accountability: With Low Authority comes High Accountability. We fully own our scopes, achievements, and mistakes. We create one-year roadmaps and quarterly OKRs.
• Rational Thinking: Solid foundations are built with data, facts & reason.
• Transparency: So that everyone has the necessary context to make the right decisions for the business, we make information available to everyone.
• Repeatable Solutions: Repeatable business, repeatable solutions.
• Hiring Up: We hire world-class players.
• Continuous Feedback: Asking for, giving, receiving, and using strong feedback.
• Benevolence: We go the extra mile to help others and make them feel awesome. We stay aligned with each other and win as a team.
• Your Life, Your Way: We are free to choose where and when we work, to find our balance and deliver the best results.
• Personal Growth: We all want to be 1% better today than yesterday.
• Simplicity: Only the simplest things will be understood at a broad scale, will endure, and will deliver great outcomes.
• Prosperity: We believe that all who are involved in building great things should reap the rewards.

Our growth must be viable, sustainable and respectful of ethical, social and environmental responsibility

Transparency | Impact | Low Authority | Prosperity | Repeatable solutions

We incorporate the principles of social and environmental responsibility into our strategy to build sustainable growth and trusting partnerships with all stakeholders in our business.

Our corporate governance

We focus on performance and results and we are convinced that how, where and even when employees work is ultimately irrelevant. We distribute responsibility amongst all employees and avoid any form of micro-management. True leaders do not give orders from the top down, each individual must be in control of their own actions. 

Our objectives are clearly defined, and as such, each individual is tasked with achieving them however they see fit, all whilst maintaining transparency, and showing respect to ethics as well as all stakeholders. We must question ourselves, analyze the impact our decisions have and identify what went wrong.

We follow the law and respect Human Rights

Our business is conducted in compliance with applicable laws and regulations, with integrity, respect for Human Rights and professional ethics.

We follow:

• the principles of the UN Universal Declaration of Human Rights;  
• the fundamental conventions of the International Labour Organisation (ILO), particularly with regard to forced labour and child labour; and
• the principles of the UN Global Compact.

We prohibit human trafficking and all forms of human slavery in accordance with the UN Additional Protocol to Prevent, Suppress and Punish Trafficking in Persons and the UN Slavery Convention. 

We are committed to sustainable development, environmental responsibility and protecting our planet

We are aware of our impact on the environment and climate and the responsibility this entails.

We are aware that offering SaaS model products (via an online platform) and working from our offices requires a lot of energy. For these reasons, in early 2020, we joined Leaders for Climate Action and we are committed to reducing our emissions and contributing to collective carbon neutrality. 

Means are being put in place to analyze our impact and to further limit our consumption of energy and natural resources. We are working on this by calculating our emissions, reducing them as much as possible and offsetting them through climate projects. 

We strive to reduce our waste and consume resources sensibly and sparingly.

A workplace and teamwork that respects individuals: A focus on people

Benevolence | Personal Growth | “Your Life, Your Way” | Hiring up

We respect the rights and dignity of each of our employees, customers and partners, and oppose all forms of violence and abuse.  We are committed to treating people with fairness, respect and dignity.

The health, safety and comfort of our employees is our primary concern 

We are aware of the impact our actions can have, and we do not tolerate any form of abuse, bullying or harassment in the workplace. 

These commitments are reflected in our HR policies which provide work-life balance, in a positive teamwork environment, where the values of trust, transparency and care for one another are central.  

We expect our partners to also provide safe working conditions, to treat their employees with dignity and respect, and to act fairly. 

If our partners do not meet these expectations, we reserve the right to reassess our relationship with them.

We support diversity, equity and inclusion (DE&I) from our recruitment processes, to our compensation policy, and with our choice of suppliers and business partners.

As an international company, our teams are made up of individuals from different cultures and backgrounds. We put our people first and are proud of our differences. 

We offer an equal opportunity working environment and believe that learning should include everyone.

We believe that we are all responsible when it comes to creating an inclusive workplace that promotes equity, and attracts a diverse workforce. 

We have strengthened our DE&I commitment by joining the “Mission French Tech Engagements Parité”. As part of this mission, we commit to providing practical training, gender-neutral job offers, equitable representation of women and men in the company, promoting female presence in our governance, and also provide support plans for employees returning from parental leave. 

We are committed to closing the gender pay gap, increasing the number of women in leadership positions at 360Learning, and supporting the maternity, paternity and second parent leave that 360Learners need.

We are implementing means to measure our progress, such as tracking job applicants via an anonymous and voluntary survey at the time of application.

Convexity provides us with a framework to hone in on, and encourage the diverse skills, experiences and backgrounds that people bring with them when they join us. We use communication channels to create support communities and amplify minority voices.

Our business relations are built through fair and law-abiding business practices that respect our partners

Simplicity | Transparency | High Accountability

Our growth is based solely on the value we bring to our clients in the environment shaped by Convexity.

We champion the protection of our customers’, partners’ and employees’ Personal Data.

We are firmly committed to a policy on protecting Personal Data processed as part of our activities.

Our business and growth in the digital space relies upon Personal Data processing. As a data controller and a data processor, we are required to collect, process and store Personal Data in order to provide well adapted services, and to enable the continuous improvement of our service offering. 

We are aware of the importance that staying in control of our Personal Data represents for each of us . We state our commitment to be responsible and exemplary as a Data Processor and as a Data Controller, in accordance with the local regulations of regions in which we operate.

We include this commitment in our general data protection policy.

We protect our assets and those of our customers and partners with care

We take appropriate security measures as well as any other necessary precautions to protect our information, data and property, as well as those with which we are entrusted with.

Notably, data and information systems are managed and hosted with appropriate levels of required security, in compliance with applicable Personal Data Protection Regulations.

We strive to protect the secrecy of our confidential information and that entrusted to us

We have adopted and implemented  Privacy Policies, including the classification of information.

Each 360Learner who has access to confidential information is only authorized to use or share that information in order to conduct 360Learning's business, solely in accordance with obligations we have undertaken in this regard.

We respect the confidentiality commitments of our employees and our partners. We will not request the disclosure of confidential information in violation of these commitments.

We must respect the rights of our competitors and those with whom we do business

No 360Learner shall take unfair advantage of anyone through illegal conduct, manipulation, concealment, abuse of proprietary information, misrepresentation of material facts or any other intentional unfair practice. 

Nor shall any 360Learner act in a manner that would be anti-competitive under any applicable antitrust law. 

All 360Learning employees are expected to act in the best interests of 360Learning, and must strive to avoid any situations that create (or appear to create) a conflict of interest between their personal interests and the interests of 360Learning.  

If a 360Learner believes that they have a potential conflict of interest, they should speak to their coach or manager, and seek advice from the Legal Department on how to manage this potential conflict.

We can only grow with a zero tolerance policy towards corruption and influence peddling.

We do not tolerate any form of personal gain, corruption or influence peddling.

We implement policies and measures at our level to tackle such behavior. 

Our commitment to ethics also includes a zero-tolerance policy in regard to any acts that involve financial crimes, in particular money laundering.

We are aware that our presence in various countries means that we are subject to a number of national and international laws and regulations pertaining to the import and export of services or licenses. 

At our level, we implement the necessary procedures to comply with these regulations.

We require our partners to act in a fair and ethical manner and to use environmentally friendly practices. 

If a partner of ours was found not to meet these expectations, we reserve the right to reassess our relationship with them.

Implementation of this charter and consequences for any breaches

Transparency | Continuous Feedback | Rational Thinking

 Questions? Comments? 

We are committed to raising awareness around ethical behavior amongst all the 360Learners and the Group’s partners.

If you have any questions or concerns about any provision of this Charter, please contact our legal team at ethics@360learning.com   

Any violation of the Charter may result in disciplinary action in accordance with local applicable disciplinary policies. 

Any concerns? Speak up!

The procedure is available to anyone who wishes to make an alert.

360Learning shall not impose any sanction, any measure of reprisal or discrimination against a whistleblower, provided that they have acted without direct financial compensation and in good faith. Even if the facts that are the subject of the alert are found to be inaccurate or do not give rise to any follow-up.