Version Control

Aim

Review and Consultation Process

Assumptions & Definitions

Introduction

Legal Conflict or Other Non-conformities

General Standards

House Rules

Working Environment

Office Security - Access Control

Wi-Fi Access

Telephone / Video Conferencing Booths

Health and Safety Standards

Ethics and Compliance

Ethical Dealings

Bribery and Corruption

Anti-Human Trafficking and Modern Slavery

Human Rights

Freedom from Harassment, Bullying and Discrimination

Environment

Reporting of Concerns

Further Information

The aim of this document is to clearly define the standards expected of all Users of the Desana Platform provided by Desana Network Limited (Desana) and to provide a reference tool for Employees, Customers, Users, Work Space Operators, community managers and others working with Desana or using Desana Services to ensure expectations of service and standards are agreed upon and followed at all times.

This Policy should be read in conjunction with Desana Terms and Conditions as published here.

Review: To be reviewed at least every 24 months. Periodic review to be carried out in line with the business risks identified, changes in regulatory requirements and global landscape.

Reviews to be completed by: Stephen Ramsay, Compliance

Policy sign off by: Steven Jeans, COO

Responsibility for Implementation and Training: Shared responsibility between Steven Jeans, COO, and Stephen Ramsay, Compliance.

Desana is an international company connecting thousands of Operators across the world. This poses a number of cultural and regulatory challenges. This document, alongside our legal Terms and Conditions, sets out the minimum standards of conduct that all Users must agree to.

Given that laws and regulations vary significantly across jurisdictions, it is important to note that where the law in any country or jurisdiction conflicts with either this Code of Conduct or Desana’s Terms and Conditions, the User MUST adhere to the law in their jurisdiction and notify Desana of any such conflict immediately by emailing: [email protected].

Desana, our Customers (employers) and our Operators (Work Space providers) all expect professional working conduct that is appropriate for a professional working environment from all users. All users MUST comply fully with this policy, their employer’s policies and Codes of Conduct and the space’s house rules at all times.

Each Operator and each Work Space may have its own Code of Conduct or similar document setting out expectations of conduct in the workplace. All users MUST adhere to these rules at all times.

Users MUST NOT do anything which may compromise any of the following Work Space requirements, where Work Spaces must:

Users MUST NOT do anything to compromise the safety and security of any Work Space. Users MUST not invite visitors into a space without first properly completing whatever signing process the Work Space has in place. This does not apply to other Users of Desana who have made a Booking.

Where applicable, access control cards may be issued to you whilst attending a Booking in a Work Space. Users MUST NOT be required to download third-party applications to a mobile device in order to gain access to any Work Space listed on our platform. Users MUST return access cards to operators at the end of their booking. Access control cards (or equivalents) must not be copied.

All Work Spaces must provide a secure, fast and reliable Wi-Fi network for the use of all Users. The Wi-Fi network MUST be fully compliant with the Wi-Fi Alliance Security Standards and best practices. Users must not use the Wi-Fi network to:

Telephone or video conferencing booths may be available for Users to privately take calls or join Google Meet / Zoom / Microsoft Teams meetings or similar. Not all Work Spaces offer these. However, the spaces which do may choose to operate fair use policies in the interests of equitable access to all Users or individuals within the Work Space. Users must abide by such policies and treat this resource with respect and be mindful of other Users or individuals in the Work Space.

Health and Safety at work encompass a wide range of duties and initiatives aimed at maintaining a safe working environment for all employees. There are many relevant pieces of legislation and case law which impose legal duties on matters ranging from providing insurance and written policies on Health and Safety to education and training for staff, risk assessments and monitoring.

Desana, our Users and Customers each expect all Operator Work Spaces to meet the highest standards of Health and Safety requirements in providing a professional and safe working environment.

However, Health and Safety Law also places a significant duty of self-care on You, the User, to take reasonable steps to protect yourself. You must:

At Desana, we are committed to acting with integrity in all that we do. Earning and maintaining the trust of our Global Users, Customers and Operators is important to us. We achieve this by consistently demonstrating honesty, professionalism and ethical integrity. Employees of Desana act in accordance with the highest ethical standards and in compliance with all applicable laws and regulations. Please see our policies below for a more detailed picture of our approach to Ethics and Compliance in addition to the standards we expect all Users, Operators and Suppliers to maintain.

Users must commit to working with honesty and integrity and will observe the highest ethical principles. Users will avoid conflicts of interest and will be especially careful about extending business courtesies, remembering that it is never appropriate to give a gift or gratuity with the intent to influence a business or governmental decision or outcome. Users will ensure that they follow the Ethics Policy of their employer and that they follow both the letter and the spirit of that policy.

Users will strictly comply with all applicable laws and regulations on bribery, corruption, and prohibited business practices. Users will not corruptly offer, promise, make or agree to make any payments or gifts of money or anything of value, directly or indirectly, to anyone for the purpose of influencing decisions. Users will follow all of their employer’s procedures designed to prevent bribery, corruption, kickbacks and embezzlement.

Desana is committed to preventing human trafficking and modern slavery in our business and is committed to the principles of the UK Modern Slavery Act 2015 and the abolition of all modern slavery and human trafficking. Desana’s recruitment and people management processes are designed to ensure that all prospective employees are legally entitled to work in the region where they are being hired and to safeguard employees from any abuse or coercion.

Desana does not enter into business with any organisation, in the UK or abroad, which knowingly supports or is found to be involved in slavery, servitude and forced or compulsory labour.

Modern slavery is an international crime affecting millions of people around the world - a growing global issue that transcends age, gender and ethnicities. Vulnerable individuals are forced to work illegally against their will across many different sectors including agriculture, construction, hospitality, retail, manufacturing, and more.

Operators, Customers and Users MUST commit to preventing human trafficking and modern slavery in their organization and must not use forced or involuntary labour of any kind, including but not limited to: slave, bonded indentured or involuntary prison labour.

All work arrangements between you and your employees must be voluntary, and employees must be free to terminate employment at any time. Desana, Operators, Customers and Users will not employ anyone if they have any concerns that said prospective employee may be a victim of human trafficking. Desana, Operators, Customers and Users will not use child labour. “Child” refers to any person under the minimum age for employment in your jurisdiction or any other jurisdiction where you do business. Desana supports the use of legitimate workplace apprenticeship programs which comply with all the laws and regulations applicable to such apprenticeship programs in all locations where you do business.

Users will treat all people including individuals within Work Spaces, Desana employees and Operator employees in a manner that is consistent with the United Nations Universal Declaration of Human Rights. Users will support and respect the protection of internationally proclaimed Human Rights. No one should be subjected to harsh or inhumane treatment, including but not limited to: sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers; nor is there to be any threat of any of the aforementioned.

Desana is committed to providing a welcoming experience for everyone, regardless of gender, gender identity and expression, sexual orientation, disability, physical appearance, body size, race, age, caste, social status, religious affiliation or marital or parental status. We do not tolerate discrimination in any form.

Desana and Operators seek to create an environment free from all forms of harassment and bullying. This includes, but is not limited to:

Bullying is the repetitive, intentional hurting of one person or group by another person or group where the relationship involves an imbalance of power. It can happen face-to-face or online.

These behaviours, as well as others described herein, are not conducive to a welcoming and professional environment and are therefore prohibited in all Work Spaces. Users and Operators violating these rules may face consequences including, but not limited to, removal from the Desana Platform and/or expulsion from Work Spaces without a refund. Such actions will also be shared with the Customer / the User's Employer.

Users will respect the legal rights of all persons to join or to refrain from joining worker organisations, including trade unions, and to bargain collectively.

At a minimum, Users will comply with all applicable environmental laws, regulations and standards, including but not limited to: requirements regarding chemical and waste management and disposal, recycling, industrial wastewater treatment and discharge, and air emissions controls. Users will use our services in a manner that is protective of the environment and will take potential adverse effects on the environment and the communities in which you operate into consideration in your decision-making processes.

If another User, an employee of Desana, or an Operator breaches the rules above or engages in harassing or otherwise inappropriate behaviour, Desana, the Operator and the User’s employer (Customer) reserve the right to take action to maintain a welcoming environment for other Users. This includes warnings, expulsion from the space without a refund, or other measures deemed appropriate. We expect Users to follow these rules in all spaces including during any social activities.

If someone makes you or anyone else feel unsafe or unwelcome, we encourage you to report it as soon as possible. Operator staff will be identifiable and they will be instructed on how to respond to harassment. All claims are taken seriously and will be handled by the Operator's dedicated staff and our team at Desana. You can make a report either personally or anonymously, both detailed below.

Desana has created an online form where you can report harassment HERE. We are committed to fully investigating and acting upon the information we receive through anonymous reporting. You can make a personal report by emailing us at [email protected] or contacting us via the support function in the Desana app.

When it comes to recording a personal report, our staff will ensure that your case is handled privately and securely. This may require the involvement of other staff members in order to ensure that your case report is managed properly. We may need to share the information you provide with your Employer, the space Operator and law enforcement if deemed appropriate. We will handle your case as respectfully as possible. We will never ask you to confront someone. We will not relay your name or information to the accused.

Our team will be prepared to put you in touch with security, law enforcement, or any other local services you request. We want you to feel safe and comfortable. Your protection is important to us.

Further information and advice on this policy can be obtained from the Desana Compliance team. Comments and suggestions to improve security are always welcome. If you have any questions or concerns regarding any item in this policy, please contact: [email protected]