Version Control

Aim

Review and Consultation Process

Assumptions & Definitions

Table of contents

Introduction

Legal Conflict or other Non-Conformities

Insurance

General Standards

Working Environment

Office Security - Access Control

Wi-Fi Access

Telephone/video conferencing booths

Additional Charges

Health and Safety Standards

Fire Protection & Emergency Response Planning

Safe System of Work

Electrical Safety

Occupational Injury and Illness

Ethics and Compliance

Bribery and Corruption

Compliance with Labour Laws

Human Rights

Discrimination

Freedom from Harassment and Bullying

Anti-Human Trafficking and Moden Slavery

Environment

Data Protection

Data Collection

Biometric Data

Reporting of Concerns

Further Information

The aim of this document is to clearly define the standards expected of all operators offering space to customers and users of the Desana Platform provided by Desana Network Limited (Desana) and to provide a reference tool for Employees, Customers, Users 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 Users to thousands of Operators across the world. This poses a number of cultural and regulatory challenges. Many of our Customers require that Work Spaces utilised by their employees (Users) meet a minimum level of Standard. This document, alongside our legal Terms and Conditions, sets out the minimum standard that all Operators must agree to provide to all Users.

Note: in the absence of this code of conduct, some of Desana’s Corporate customers would be required to audit individual Work Spaces before approving them for use by Users. This is simply not practical. Therefore, by agreeing to this Code of Conduct, Operators warrant that they will provide the minimum level of standards to Users and Customers as set out in this Code.

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 Operator MUST adhere to the law in their jurisdiction and notify Desana of such immediately by emailing [email protected].

Similarly, if Operators or spaces are not able to meet any/all of the standards set out within this Code of Conduct for any reason, they MUST notify Desana of such immediately by emailing [email protected].

Once notified, we will seek to arrive at a mutually acceptable resolution, where possible. While each case will be assessed individually, in the event that any standard cannot be met, the following may occur:

All spaces MUST have Public Liability Insurance which provides cover to all Desana Users and Customers for personal injury and business risks in line with the Desana Operator Terms and Conditions. Desana retains the right to ask for evidence of cover and may be required to provide that evidence to our Customers if requested.

Desana and its Users expect all spaces to meet specific basic standards for a usable, professional working environment. These include:

All Work Spaces must:

All Work Spaces must have appropriate security arrangements in place for their location including the level of risk associated with the location. In most countries, this will mean a receptionist controlling entry but in some locations, extra security may be required.

Where applicable, access control cards may be used and issued to Desana Users for the duration of their use. However, Desana Users MUST NOT be required to download third-party applications to a mobile device in order to gain access to any space listed on our platform.

All Work Spaces must provide a secure, fast and reliable wifi network for use by all Users. The Wi-Fi network MUST be fully compliant with the Wi-Fi Alliance Security Standards and best practices. The Wi-Fi network MUST also meet the following standards:

Telephone or video conferencing booths for Users to privately take calls or join Google Meet / Zoom / Microsoft Teams meetings or similar have become an essential part of coworking. Such booths are becoming an amenity that many Users expect to have access to and it is recommended that Operators provide this kind of quiet/private space. When in place, Operators may choose to set out fair use policies which must not be unreasonably restrictive.

Operators should be aware that one of the top recurring comments from Users is a lack of space to take private calls. It is important to note that this often drives demand to competitor Operators nearby. Therefore if Operators are not able to provide booths, they MUST notify Desana so that we can inform our Users about this limitation prior to booking.

Operators MUST not make any additional charges for any of the following amenities when providing the Work Space Service to Desana Users:

Health and Safety at work encompasses a wide range of duties and initiatives aimed at maintaining a safe working environment for all employees (Users). 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 and its Users and customers expect all Operator spaces to meet the highest standards of Health and Safety requirements in providing a professional and safe working environment. Our contract with you, the Operator, necessitates that you adhere to all legal requirements in your jurisdiction. However, given that Health and Safety law can vary significantly between jurisdictions, we will outline the minimum standards that we expect you, the Operator, to adhere to below within the Health and Safety Standards’ section.

All Work Spaces must have an interconnected fire detection system with audible and visual alarms, which automatically contact the fire authorities. This system MUST comply with an appropriate regular testing and maintenance regime informed by the law and best practice.

Emergency plans and response procedures must be in place to respond to any and all emergencies which may be reasonably foreseeable.

All spaces must have a documented Safe System of Work with detailed and documented policies and procedures for managing Health and Safety in their space.

All spaces must have a documented Health and Safety risk management process in their space detailing how they will assess and manage all Health and Safety risks in their Work Space(s), how they will avoid, reduce or mitigate risk, and how the aforementioned will be communicated to users and customers.

All Spaces MUST have electrical safety inspections completed at regular intervals and no less than every 5 years to ensure the safety of the fixed wire electrical installation and to ensure compliance with national best practices and safety standards.

Procedures and systems must be in place to prevent, manage, track and report occupational injury and illness, including provisions to: a) encourage reporting; b) classify and record injury and illness cases; c) investigate cases and implement corrective actions to eliminate their causes; d) provide necessary emergency first aid and arrange emergency medical treatment.

Everyone at Desana shares a commitment to integrity in all that we do. Winning and maintaining the trust of our global Users, Customers and Operators is important to us. We achieve that 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 our Operators and Suppliers to maintain.

We also expect Operators who choose to be listed on Desana to commit to working with honesty and integrity, observing the highest ethical principles. Operators 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. Operators will ensure that they have an ethics policy in place and that all of their employees follow that policy in addition to your organisation’s gift policies.

Operators will strictly comply with all applicable laws and regulations on bribery, corruption, and prohibited business practices. Operators will not corruptly offer, promise, or make or agree to make any payments or gifts of money or anything of value, directly or indirectly, to any User or Customer for the purpose of influencing decisions. Operator’s business dealings will be accurately reflected in the Operator's books and records and Operators will implement procedures designed to prevent bribery, corruption, kickbacks and embezzlement.

Operators will fully comply with all applicable labour laws in their jurisdiction and will ensure that all employees are treated fairly and legally, including being paid at least the minimum wage in their jurisdiction.

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

Operators will comply with all applicable laws and regulations governing working hours and compensation and will provide legally mandated benefits. Operators will not exceed prevailing local working hours and will appropriately compensate overtime in line with applicable law. Operators will not force their employees to work more than the time permitted by applicable law.

Operators will treat all people including our Users and your workers in a manner that is consistent with the United Nations Universal Declaration of Human Rights. Operators will support and respect the protection of internationally proclaimed Human Rights and will not tolerate any Human Rights abuses within your organization and your supply chain. Employees must not 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.

Operators must maintain a space free of discrimination on the grounds of race, religion, national or ethnic origin, colour, sex (including gender identity, sexual orientation, and pregnancy), age, marital status, veteran status, genetic information or disability.

Desana 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 professional environment and are therefore prohibited in all spaces.

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. Sadly, vulnerable people from overseas, as well as across the UK, are forced to work illegally against their will across many different sectors including agriculture, construction, hospitality, retail, manufacturing, and more.

Operators 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 they must be free to terminate employment at any time. Operators will not employ anyone if they have any concerns that said prospective employee may be a victim of human trafficking. Operators 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.

At a minimum, Operators 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. Operators will obtain and keep current all required environmental permits, approvals, and registrations and will comply with their reporting obligations. Operators will conduct themselves in a manner that is protective of the environment and will take potentially adverse effects on the environment and the communities in which they operate into consideration in their decision-making processes.

Whenever a User books a Work Space with you, Desana will provide you as an Operator with limited User data. Operators MUST treat this data in the strictest of confidence and have appropriate controls in place to ensure that this data is protected in accordance with your contractual obligations to Desana.

Desana obligates all Customers and Employers to verify the identity of Users. As a result, it is not necessary for Operators to do so.

Operators must not collect any additional information from Users beyond that which is required to comply with the Operator’s legal obligations.

Operators MUST NOT collect any additional data from Users for marketing purposes. Users MUST NOT be asked or required to provide email addresses or any other personal information for marketing purposes as a prerequisite to gain access to services. Operators must assume that Desana Users have opted out of ALL marketing communications and ALL marketing activities.

Under no circumstances whatsoever must ANY Biometric data be collected from any Users.

‘Biometric Data’ equates to personal data resulting from specific technical processing relating to the physical, physiological or behavioural characteristics of a natural person, which allow or confirm the unique identification of that natural person, such as facial images or dactyloscopic data. Biometric data includes but is not limited to: facial recognition, fingerprint verification, iris scanning, retinal analysis, voice recognition, ear shape recognition, keystroke analysis, handwritten signature analysis, gait analysis, and gaze analysis (eye-tracking).

For the avoidance of doubt, this also includes photographs and video images where utilised for facial recognition, which once used for this purpose are considered biometric data.

Nothing in the foregoing prevents Operators from using CCTV systems; in fact, the use of CCTV systems is to be encouraged for safety reasons. However, such systems must not utilise facial recognition systems.

If a User, an employee of Desana, or the Operator breaches any/all of the rules above or engages in harassment or otherwise inappropriate behaviour, Desana, the Operator and the Customer retain the right to take action in order to maintain a welcoming environment for other Users. This includes but is not limited to: warnings, expulsion from the space, or other measures deemed appropriate. Desana expects Operators to enforce these standards and for Users to follow these rules in all spaces including during any social activities.

If someone makes any person using a space or anyone else feel unsafe or unwelcome, we encourage the affected person to report it as soon as possible. Operator staff should be identifiable to Users and they should be instructed by the Operator 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, as detailed below.

Desana has created an online form where harassment can be reported HERE. We are committed to fully investigating and acting on 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 dashboard.

When taking a personal report, our staff will make sure that we discuss your issue privately and securely. They may involve other staff to ensure your report is managed properly. We may need to share the information you share with the Customer and law enforcement if appropriate, but we will handle it as respectfully as possible. We will never ask you to confront someone, and we will not relay your name or information to the accused.

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]