ETHICS POLICY

 

This ethics framework underpins and is applied to the technology and data science services carried out by Cognassist UK Limited (“Cognassist”). Cognassist conducts its business transparently, ethically and compliant with all applicable laws. This is applicable to all company decisions in all areas of the business. Cognassist is innovative technology that strives to provide a system and output that better serves society.

EQUALITY STATEMENT

Cognassist is committed to promoting equality and as such we are committed to ensuring equality and non-discrimination, irrespective of age, gender, disability (including learning), gender reassignment,
marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex (gender) or sexual orientation. In carrying out its services, Cognassist will have due regard to the different needs of
protected equality groups, in line with the Equality Act 2010. This applies to all activities for which we are responsible, including but not limited to, policy development, review and implementation.

We abide by the following core principles:

Serve our users and learners: We do this via integrity, respecting privacy and data protection laws, being responsive and acting in a quick and effective manner.

Confidentiality: The protection and security of Cognassist confidential information and the information of our customers, learners, partners, suppliers and employees.

Compliance: Ensuring that all business decisions are compliant with any applicable laws, including but not limited to competition laws and anti-bribery laws.

Ensuring legal and financial integrity and responsibility: we do this via the review and signing of contracts, we record all transactions, we report all financial or accounting irregularities, we retain records, and we perform due diligence checks on our supply chain.

Honesty and Transparency: The demonstration of open and honest transparency and collaboration to ensure the highest of ethical standards in all business dealings and transactions.

People First: We prioritise people, we put people first and treat all our customers, learners, partners, suppliers and employees with respect.

Impactful Equality: We believe, and it is integral to Cognassist the premise that everyone matters. We understand and celebrate diversity and neurodiversity.

Cognassist require that its suppliers, contractors, consultants, and business partners abide by these core principles when providing goods or services to Cognassist or acting on behalf of Cognassist.

This Ethics Policy applies to all employees of Cognassist, both full and part time and is deemed to be the standard that is required from everyone at Cognassist. Failure to comply can result in disciplinary
action, including termination of employment.

RESPONSIBILITY TO TAKE ACTION

You are expected to:

Follow this policy: Comply with the letter and spirit of this policy, Cognassist business values and all applicable legal requirements.

Speak up: In the event you become aware or reasonably suspect violation of this policy or other Cognassist policies or legal requirements, you must notify your manager or your legal team.

Use good judgment: Apply this policy to all decision making within your role, review all of our policies and legal requirements. If ever in doubt about how to proceed always discuss with your manager and/or the legal team who will be able to assist.

You are also required to fully cooperate in any Cognassist investigation, and keep any information shared with you confidential to safeguard the integrity of the investigation.

REPORTING A CONCERN

To report a concern or ask any questions about this policy you can contact legal counsel at DPO@cognassist.com.

Your information will only be shared with those who directly are assisting in the answering of your questions, investigation of your concerns, ensuring compliance with this policy determining disciplinary action (if appropriate) and/or any other department or body as required by applicable laws.

USE OF THE COGNASSIST PLATFORM

We do not condone or permit the use of Cognassist’s (1) assessment; (2) other data; or (3) any subsequent data analysis, being used for any purpose that gates access to opportunities for an
individual. Examples of this kind of gating would be:

(a) deciding to hire person A over person B, because they have scored higher on our cognitive assessment; or

(b) deciding to enrol learner A over learner B, or restrict access to their preferred course, based on the outputs from our product.

Psychological differences, also known as neurodiversity’s or formally diagnosed neurodiversity, such as (but not limited to) specific learning difficulties (dyslexia, dyscalculia etc), ADHD/ADD,
Autism/Autism Spectrum, Schizophrenia and others commonly involve cognitive differences. As such any organisation using cognitive data to restrict access to opportunities for an individual may be (wittingly or unwittingly) discriminating against that person in a way that involves legally protected characteristics. Even if cognitive differences are not related to a diagnosable psychological difference such as those listed, we see it as unethical to restrict access to opportunities based on this information because it does not take into account all of the many other rich and valuable human attributes that may be relevant to the role/course under consideration.

Simply put: using cognitive assessments for recruitment decisions increases discrimination and decreases cognitive diversity within an organisation or course.

Instead, we support our product being used as an inclusion tool, as it supports individuals who may have cognitive differences after recruitment or enrolment and create a comfortable space to talk about our differences. We want workplaces and education spaces to become more tolerant and adaptive to cognitive differences, to increase inclusion and support for those of us that think differently.

YOUR RIGHTS AS AN EMPLOYEE

Whilst we expect full compliance with this policy, nothing herein is intended to be restrictive upon your rights to speak freely about your working conditions, hours of work or salary. Further no employee shall be disciplined for reporting a concern in good faith, however we will not tolerate false reporting.

HUMAN RIGHTS

Cognassist is highly committed to respecting and protecting human rights. Cognassist’s approach to respecting human rights is based upon the Human Rights Act 1998.

WORKPLACE BEHAVIOURS

Whilst Cognassist is a remote first business, even when operating from your own workplace environment you are expected to comply with the below behaviours.

HARRASSMENT AND DISCRIMINATION

Cognassist will not tolerate any harassment (including sexual) or discrimination based on a personal trait. Personal traits include race, national origin, ancestry creed, age, mental or physical disability,
sex, gender or any other characteristic protected by law.

At Cognassist we are proud and fly the flag for neurodiversity, and this also extends to maintaining a culturally diverse, inclusive and supportive work environment. If you have been harassed or
discriminated against or have witnessed such behaviour report the incident immediately to our HR team or your manager.

ENVIRONMENT HEALTH AND SAFETY

Cognassist want to ensure the protection of the environment, health and safety of our employees.

Cognassist health and safety policy provides required guidance on how to conduct your role whilst meeting or exceeding all applicable environmental, health and safety requirements. Use good judgment and collaborate openly with your manager and HR to anticipate and manage any environment health and safety risks in a prompt manner.

PROTECT COGNASSIST

You play a fundamental role in protecting Cognassist assets such as proprietary information (such as intellectual property, confidential information business plans, unannounced product and/or service
plans, sales and marketing strategies and other trade secrets.

COGNASSIST CONFIDENTIAL INFORMATION

One of the biggest assets of the business is the information about our products, services and future products and service offerings. It is imperative that you never discuss confidential, operational,
financial, trade-secret or other business information without verifying with your manager that such disclosure is appropriate. Cognassist is purposefully selective as to disclosing this information to vendors, suppliers or other third parties and may require that a confidentiality agreement is in place between the parties prior to the disclosure of information.

CUSTOMER AND LEARNER INFORMATION

Customers, partners suppliers and other third-parties will disclose confidential information to Cognassist during the performance of our services. We are ALL responsible for protecting and maintaining the confidentiality of any information entrusted to us by our partners. We do not want to compromise trust and damage relationships with our partners including prevention of any legal liability for the same.

ACCURACY OF RECORDS AND REPORTS

Accurate and transparent reports are essential to meeting our legal, financial and management obligations. You should ensure that all records and reports including public communications are complete, understandable, accurate, fair and timely.

Cognassist will not tolerate misstated facts, modifications of reports to mislead others or the omission of critical information. Intentional manipulation of records may be a form of fraud.

CONTRACTING WITH THIRD PARTIES

Cognassist formally documents all agreements into which it is a party to. We do not accept any business commitments outside of the current contracting process, as managed by our legal department. Oral agreements, modification of our terms and conditions or any other informal agreement or informal contractual documentation cannot be created by employees, a request for formal contractual documentation should be requested, drafted and signed off by legal before execution.

THIRD PARTY INTELLECTUAL PROPERTY

Cognassist respects third-party intellectual property. Never use the intellectual property of any third party without permission or legal right. If you suspect or believe that Cognassist may be infringing on
third-party intellectual property, contact the legal department.

BUSINESS INTEGRITY

GIFTS

Giving or accepting gifts can create a real or perceived conflict of interest and can lead to a perception of favouritism or bribery.

A gift is considered as anything of value including a meal, entertainment or travel (including tickets). Gifts that are cash or cash alternatives are never permitted. Gifts given for the purpose of influencing a decision are also never permitted. We expect all employees to fully comply with our anti-bribery policy which further dictates our gift process and restrictions.

BRIBERY AND CORRUPTION

Cognassist do not tolerate corruption in connection with any of our business dealings. Corruption can take numerous forms but most frequently occurs via bribery. A bribe is offering or giving anything of
value, including cash, cash equivalents, meals, entertainment and transport to any person or company with the intention of obtaining or retaining business or receiving an unfair and improper advantage.

We expect all employees to comply with our anti-bribery and corruption policy without exception.

PRIVATE EMPLOYEE INFORMATION

You should never share a co-worker or prospective employees’ personal information. This includes any information regarding their employment history, personal contact information, salary, health
information, or performance and disciplinary matters. Any legal or business need-to-know exceptions should be authorised by your manager and our legal department.