Alkami Code of Ethics and Conduct (the “Code”)--the Gold Standard
The Foundation (or “Core”)
At Alkami, we strive to embrace our Essential Culture Compounds in all that we do. This includes trusted-accountability by “doing the right thing always” and transparent-communication by “communicating with integrity.” We believe that our Essential Culture Compounds are foundational for fulfilling our vision of inspiring and empowering financial institutions to grow confidently and adapt quickly to build thriving digital banking experiences. They also are fundamental to us in being good stewards of the resources provided to us by our investors and to being good corporate citizens that follow the law, contribute to our communities and respect the ideas and opinions of each other.
When we say that we should always “do the right thing,” it means that we will hold ourselves to the highest standard regardless of the consequences. And it means not only following the law—but “doing the right thing” when the law is not clear or may allow for alternative behavior. We believe that every decision we make and every action we undertake should be measured against the highest possible standards of ethical business conduct. We believe that “doing the right thing” will yield benefits beyond staying out of legal trouble. We believe that “doing the right thing” will better enable us to fulfill our vision
by hiring and retaining the best people, building the best digital banking solutions and attracting the most innovative and respected clients. In other words, “doing the right thing” is how we succeed and truly embody the Gold Standard.
As an employee (an Alkamist) of the Company, if you have a question or ever think that we may be falling short of our commitment, please let us know by contacting your manager, Human Resources, the Legal or Compliance Department, a member of the OCE or, if applicable, a member of the Board of Directors. If it is preferred to raise a concern anonymously, we would encourage you to utilize the anonymous reporting line by calling 844-296-4068 or by visiting http://www.alkami.ethicspoint.com.
Who must follow our Code?
We expect all of our Alkamists (employees), contractors and Board members to know and follow the Code. Failure of an individual to do so can result in disciplinary action, up to and including termination of their employment and/or relationship with Alkami.
We do not permit retaliation
We must not be afraid to “do the right thing.” This means that we will prohibit retaliation against any Alkamist who reports, or participates in an investigation of a possible violation of our Code, policies, or the law. If you believe you are being retaliated against, please contact Human Resources, the Legal Department or, if appropriate, a member of the Board of Directors. You may also utilize the anonymous reporting line to report retaliation.
I. Our Relationships with our Clients
Our clients are trusting us with their most important data—the personal financial information of the institution and of their customers. Our reputation as a company is dependent on maintaining that trust. This is why we must have systems and procedures in place that allow us to appropriately protect end user data. These procedures strictly limit access to and use of users’ personal information. They also require each of us to take measures to protect user data from unauthorized access. We must think of this data as our own—and treat it as we would want our own personal information to be treated. To help us protect end user information, we have instituted the Master Information Security Policy (the “MISP”), which every Alkamist is required to follow.
We strive for our products and services to provide an extraordinary digital banking experience for our clients and their end-users. In order to remain the leading provider of digital banking solutions, we must continue to innovate beyond the capacity of our competitors. Maintaining this level of service requires the diligent efforts of each of us—whether it is in engineering, support, services or any other area within Alkami. Any time you feel our clients are not being well-served, please let someone with authority in the company know about it.
II. Our Relationships With Each Other
We are committed to a supportive work environment, where employees have the opportunity to reach their fullest potential. Alkamists are expected to do their utmost to create a workplace culture that is free of harassment, intimidation, bullying, bias, and unlawful discrimination. We have described these expectations in our Employee Handbook—which Alkamists are required to acknowledge every year. The following areas are of particular importance:
1. Harassment, Discrimination and Bullying
Alkami prohibits discrimination, harassment and bullying in any form – verbal, physical, or visual. If you believe you have been bullied or harassed by anyone at Alkami, or by an Alkami partner or vendor, we strongly encourage you to immediately report the incident to your supervisor, Human Resources, or both. Similarly, supervisors and managers who learn of any such incident should immediately report it to Human Resources. Human Resources will promptly and thoroughly investigate any complaints and take appropriate action.
2. Drugs and Alcohol
Our position on substance abuse is simple: It is incompatible with the health and safety of our employees, and we do not permit it. Consumption of alcohol is not banned at our offices, but use good judgment, and never drink in a way that could lead to impaired performance or inappropriate behavior, endanger the safety of others, or violate the law. Illegal drugs in our offices, or at sponsored events, are strictly prohibited.
3. Safe Workplace
We are committed to a violence-free work environment, and we will not tolerate even the threat of violence in the workplace. Under no circumstances should anyone bring a weapon to work. If you become aware of a violation of this policy, you should report it to Human Resources immediately.
III. Avoid Conflicts of Interest
When you are in a situation in which competing loyalties could cause you to pursue a personal benefit for you, your friends, or your family at the expense of Alkami or our clients, you may be faced with a conflict of interest. All of us should avoid conflicts of interest and circumstances that reasonably present the appearance of a conflict.
1. Outside Engagements, Starting Your Own Business, and Business Opportunities
Avoid accepting employment, advisory positions, or board seats with Alkami competitors or business partners when your judgment could be, or could appear to be, influenced in a way that could harm Alkami. In addition, do not start your own business if it will compete with Alkami. Finally, business opportunities discovered through your work here belong first to Alkami, except as otherwise agreed to by Alkami.
Developing or helping to develop outside inventions that a) relate to Alkami’s existing or reasonably anticipated products and services, b) relate to your position at Alkami, or c) are developed using Alkami corporate resources may create conflicts of interest and be subject to the provisions of Alkami’s Employee Proprietary Information Agreement. If you have any questions about potential conflicts or intellectual property ownership involving an outside invention or other intellectual property, consult Human Resources, or the Legal Department.
3. Friends and Relatives; Co-Worker Relationships
Avoid participating in management of, or decision-making, regarding potential or existing Alkami business relationships that involve your relatives, spouse or significant other, or close friends. This includes being the hiring manager for a position for which your relative or close friend is being considered or being a relationship manager for a company associated with your spouse or significant other.
If a relative, spouse/significant other, or close friend works at Alkami or becomes an Alkami competitor or business partner, this, in and of itself, does not constitute a conflict of interest. However, if you are also involved in that Alkami business relationship, it can be very sensitive. The right thing to do in such a situation is to discuss the relationship with your manager.
Finally, romantic relationships between co-workers can, depending on the work roles and respective positions of the co-workers involved, create an actual or apparent conflict of interest. If a romantic relationship does create an actual or apparent conflict, it may require changes to work arrangements. Contact Human Resources if you have any questions as to this type of office relationship.
4. Accepting Gifts, Entertainment, and Other Business Courtesies
Accepting gifts, entertainment, and other business courtesies from an Alkami competitor or business partner can easily create the appearance of a conflict of interest, especially if the value of the item is significant. Generally, acceptance of inexpensive “token” non-cash gifts is permissible. In addition, infrequent and moderate business meals and entertainment with clients and infrequent invitations to attend local sporting events and celebratory meals with clients can be appropriate aspects of many Alkami business relationships, provided that they are not excessive, and do not create the appearance of impropriety. If you are uncertain about a particular gift or courtesy, please check with your manager.
IV. Preserve Confidentiality
Each of us has a duty to protect the confidential information of Alkami. This is why we all sign Employee Proprietary Information Agreements (EPIAs). Certain Alkami information, if it were to become public, could impact our competitive product advantage or could provide our competitors with insights that they could use against us. In addition, we have a responsibility to safeguard confidential information that Alkami receives from others under non-disclosure agreements.
1. Confidential Information
We utilize non-disclosure agreements (NDAs) to protect Alkami information in our dealings with third parties. At times, a particular project or negotiation may require you to disclose confidential information to an outside party. Any such disclosure of that information should be on an “as needed” basis and only after an NDA has been executed by the Legal Department. In addition, Alkami policy may require a prior security assessment of the outside party that is to receive the confidential information. Be sure to conduct the appropriate due diligence and have the appropriate agreement in place before you disclose the information. If you have any questions about this, please contact the Legal Department.
In addition, some of us will find ourselves having family or other personal relationships with people employed by our competitors or business partners. As in most cases, common sense applies. Do not tell your significant other or family members anything confidential, and do not solicit confidential information from them about their company.
2. Alkami Partners
Just as you are careful not to disclose confidential Alkami information, it is equally important not to disclose any confidential information we have received from our partners. Do not accept confidential information from other companies without first having all parties sign an NDA approved by the Legal Department. Even after the NDA is signed, try only to accept as much information as you need to accomplish your business objectives.
3. Competitors/Former Employers
We respect our competitors, and want to compete with them fairly. As such, we do not want their confidential information. This is inclusive of confidential information belonging to any Alkamist’s former employer(s). If an opportunity arises to take advantage of a competitor’s or former employer’s confidential information, do not take advantage of it. Should you happen to come into possession of a competitor’s confidential information, contact the Legal Department immediately.
4. Outside Communications
Our policy is to be extremely careful about disclosing confidential and proprietary information. Consistent with that, you should ensure that your outside communications (including online and social media posts) do not disclose confidential or proprietary information or represent (or otherwise give the impression) that you are speaking on behalf of Alkami, unless you are authorized to do so by the company. The same applies to communications with the press. Additionally, check with your manager before accepting any public speaking engagement on behalf of the company.
V. Protect Alkami’s Assets
We have a duty to our stockholders to use the company’s assets wisely. As such, we need to protect them from individuals with competing interests.
1. Intellectual Property
Alkami’s intellectual property rights (our trademarks, logos, trade secrets and “know-how”) are among our most valuable assets. Unauthorized use can lead to their loss, or serious loss of value. You must respect all copyright and other intellectual property laws, including laws governing the fair use of copyrights, trademarks, and brands. We strongly encourage you to report any suspected misuse of trademarks, logos, or other Alkami intellectual property to the Legal Department.
Likewise, we must respect the intellectual property rights of others. Inappropriate use of others’ intellectual property may expose Alkami, and you, to criminal and civil fines and penalties. Please seek advice from the Legal Department before you solicit, accept, or use proprietary information from individuals outside the company, or let them use or have access to Alkami’s proprietary information. You should also check with the Legal Department if you are developing a product that uses content or code to which Alkami does not yet have a license.
Alkami is not against the proper use of open source as part of the development process. But we must strictly comply with the license requirements under which open source software is distributed. Failing to do so may lead to legal claims against Alkami. Please seek guidance from the Legal Department prior to utilizing any open source software distributed pursuant to an unapproved license. Note that this applies whether the development is “customer facing” or “internally-facing.”
2. Company Equipment
We want every employee to have the software and equipment needed to do our jobs effectively. But we have to be responsible and not wasteful with the equipment we are given. We need to take care of the equipment entrusted to us.
3. The Network
Alkami’s communication facilities (which include both our network and the hardware that uses it, like computers and mobile devices) are a critical aspect of our company’s property, both physical and intellectual. Be sure to follow all applicable security policies. If you have any reason to believe that our network security has been compromised–for example, you lose your laptop or smartphone, or think that your network password may have been compromised – please promptly report the incident to Information Security. For more information, consult Alkami’s MISP.
4. Physical Security
Always secure your laptop, important equipment, and your personal belongings, even while on Alkami’s premises. Always wear your badge visibly while on site. Do not tamper with, or disable, security and safety devices. Watch people who “tailgate” behind you through our doors. If you do not know them, nor see an Alkami badge, please ask for it (and, as appropriate, direct the person to a receptionist for assistance). Promptly report any suspicious activity. For more information, review Alkami’s MISP.
5. Use of Alkami’s Equipment and Facilities
Anything you do using Alkami’s equipment (e.g., our computers, mobile devices, network, etc.) or store on our premises (e.g., letters, memos, and other documents) might be disclosed to people inside and outside the company. For example, Alkami may be required by law (e.g., in response to a subpoena or warrant) to monitor, access, and disclose the contents of corporate email, voicemail, computer files, and other materials on our equipment or on our premises. In addition, the company may monitor, access, and disclose employee communications and other information,on our equipment or on our premises, where there is a business need to do so, such as protecting employees and users, maintaining the security of resources and property, or investigating suspected employee misconduct.
VI. Ensure Financial Integrity and Responsibility
Financial integrity and fiscal responsibility are core aspects of corporate professionalism. This is more than accurate reporting of our financial position, though that is certainly important. The money we spend on behalf of Alkami is not ours; it is the company’s and, ultimately, our stockholders’. Each person at Alkami–not just those in the Finance Group–has a role in making sure that money is appropriately spent, our financial records are complete and accurate, and internal controls are respected. This matters every time we hire a new vendor, expense something to Alkami, sign a new business contract, or enter into any deals on Alkami’s behalf.
To make sure that we are doing the right thing, Alkami maintains a system of internal control to reinforce our compliance with legal, accounting, tax, and other regulatory requirements.
Please endeavor to support our system of internal control, and do not hesitate to contact the Legal Department or the Finance & Accounting Group, if you have any questions. What follows are some core concepts that lie at the foundation of financial integrity and fiscal responsibility here at Alkami. Because we take our financial reporting systems so seriously, you may also utilize our anonymous reporting line to report any such concerns directly to a non-management member of the Board of Directors.
1. Spending Alkami’s Money
We believe that we need to spend money wisely. When you submit an expense for reimbursement, or spend money on Alkami’s behalf, please make sure that the cost is reasonable, directly related to company business, and supported by appropriate documentation. Always record the business purpose (e.g., if you take someone out to dinner with Alkami funds, always record in our expense reimbursement tool the people who attended as well as the reason for the dinner) and comply with other submission requirements. If you are uncertain about whether you should spend money or submit an expense for reimbursement, check with your manager. Managers are responsible for all money spent and expenses incurred by their direct reports, and should carefully review such expenditures before approving. Always remember that requests for reimbursement of Alkami expenses must be submitted in accordance with our Travel and Expense Reimbursement Policy.
2. Hiring Suppliers
As Alkami grows, we enter into more and more deals with suppliers of equipment and services. We should always strive for the best possible deal for Alkami. This almost always requires that you solicit competing bids to make sure that you are getting the best offer. At the same time, we realize that while price is very important, it is not the only consideration. Quality, service, reliability, and the terms and conditions of the proposed deal may also affect the final decision. Finally, all arrangements with suppliers must be documented and approved by the Legal Department.
It is not possible to provide examples for every ethical scenario we may face. We have, however, provided below an example of an ethical framework that you can use to help guide your decision-making process. As always, if you have questions, please feel free to contact Human Resources or the Legal Department.