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Terms & Policies

Intercom Code of Conduct

Effective day 1 April 2024

OUR CODE OF CONDUCT

Our Code of Conduct is an extension of our values. It provides an overview of the laws, regulations, and company policies that apply to each of us and the work we do. Following our Code builds trust with our customers, community, and stakeholders and honors our shared vision of who we are and how we work. When you think about how to follow our Code, imagine the people you like the most, from loved ones you respect to public figures you admire. Think about what values they embody, what actions they take, what behaviors they exhibit. Chances are, those three characteristics will be entirely consistent with one another. Our Code provides a model for every employee to live those values at Intercom.

SPEAK UP

We all feel a sense of ownership at Intercom. If we find something that’s broken, we help to fix it. If something can be better, we help to improve it. This sense of ownership is taught from day one. It’s in our DNA.

Sometimes it’s not easy to figure out the right thing to do. If you have questions about the Code, speak up. Make your voice heard, even if it’s just to ask a question or to get a second opinion. Intercom has a culture of inclusion and openness. If you have an issue that you feel uncomfortable sharing with your manager or HR, you may report your concern anonymously. The more detail you provide about a concern, the easier it will be for us to assess the problem and come up with a solution. Intercom takes all issues raised by employees seriously and addresses them fairly and promptly.

There are several reporting channels available:

Often your supervisor or manager may be able to help you. Other times, you may have a question and want to speak with an expert in Compliance. The important thing is to get help. For our culture to thrive, it is up to each of us to have the courage to raise our hand and speak up when something does not feel right.

Intercom does not tolerate any form of retaliation or negative reaction for raising concerns in good faith about violations of our Code or any applicable laws or regulations. We are one Intercom team, working towards the same goals.

POTENTIAL CONSEQUENCES OF CODE VIOLATIONS

Intercom may take disciplinary action, up to and including termination against any employee who violates our Code or applicable laws, regulations, or policies. Failure to report potential misconduct or intentionally reporting misleading information violates our Code and may also result in disciplinary action.

PROMOTE LABOR, EMPLOYMENT, AND IMMIGRATION COMPLIANCE

We respect human rights, including freedom of association, and comply with all labor, employment, and immigration laws in the countries in which we operate. We do not tolerate the use of child, forced, indentured, or involuntary labor anywhere we do business, and we only work with others that adhere to human rights and uphold labor and immigration laws. We also require all employment agencies, contractors, suppliers, and others doing business with us to fully comply with applicable labor and immigration laws. We are each responsible for our immigration and employment status in the countries where we work and live.

PREVENT HARASSMENT AND DISCRIMINATION

Intercom prohibits any form of harassment in our workplace and discrimination in employment, employment-related decisions, or in business dealings on the basis of an individual’s race, color, ancestry, age, sex, sexual orientation, gender identity or expression, religion, disability, ethnicity, national origin, veteran status, marital status, pregnancy, or any other category protected by law or local policy. This type of conduct hurts our fellow employees and impacts the success of our business.

We do not tolerate any form of harassment, bullying, or offensive conduct (including threats of violence) which diminishes anyone in our company in any way, our customers, or our other stakeholders.

Every employee plays a role in preventing sexual harassment through active awareness of what is going on around them. Sexual harassment may include unwanted touching or sharing of materials with sexual content, making uninvited remarks of a sexual nature, or continuing to make romantic advances after being refused. If you see this type of conduct, speak up and report it.

CONFLICTS OF INTEREST

Conflicts of interest undermine trust. Intercom wants every employee to succeed both inside and outside of the company. We respect the right of our employees to pursue activities outside of Intercom, provided that those opportunities do not harm Intercom’s business, our customers, or otherwise interfere with your duties as an Intercom employee.

Employees must avoid conflicts of interest with Intercom. A conflict of interest may exist when there is a conflict between a personal interest and the interest of Intercom or a customer, business partner or vendor. If you use your position at Intercom for personal gain that impacts Intercom’s business opportunities or relationships, that’s a conflict. If you conduct an activity outside of Intercom that may appear to conflict with Intercom or serving our customers—talk it through with Compliance.

Some other examples of potential conflicts include:

  • Supervising someone with whom you have or have had a close personal or family relationship;
  • Taking part in hiring or selection decisions involving a family member as an employee or Intercom supplier or vendor;
  • Working for or serving on the board of an Intercom competitor or other companies, while also working at Intercom;
  • Owning or investing in a company that may compete with Intercom or a vendor or partner that does business (or seeks to do business) with Intercom;
  • Receiving personal compensation from a supplier;
  • Seeking business from Intercom after leaving the company;
  • Taking advantage of corporate opportunities that belong to or are presented to Intercom;
  • Leveraging Intercom as a platform to endorse personal beliefs and associations (e.g., any political, religious, civic, social or other personal associations)
  • Using confidential information for personal gain; or
  • Accepting or offering gifts, hospitality, or other favors to or from a third party that does business (or wishes to do business) with Intercom.

The Compliance department (compliance@intercom.io) can help you resolve potential conflicts of interest provided that you disclose them. If you think you have a conflict of interest, talk to Compliance, and we will solve the problem together. If we do not address actual and potential conflicts, not only does it violate our Code and undermine our culture, but it also hurts the core mission of our company to make internet business personal.

KEEP CLEAR AND ACCURATE FINANCIAL RECORDS

Our shareholders expect us to maintain transparent financial records and report accurate information. Accurate record keeping is important in every transaction and our value depends on it. Intercom maintains controls to reinforce compliance with legal, accounting, tax, and other regulatory requirements in every location in which we operate. Each of us has a responsibility to spend money appropriately and to keep records that are clear, accurate, and complete. No one should ever falsify any record or account. Be candid and transparent with management, or anyone responsible for financial reporting, forecasts, or business information.

If you are ever involved in an external or internal audit or investigation, cooperate fully and provide complete, accurate, and timely responses to questions and document requests. If Compliance asks you to retain records, do so until they tell you retention is no longer necessary.

BUSINESS PARTNER RELATIONSHIPS

Good business partners remain critical to our value and success. We choose third parties fairly and based on merit. We always treat our business partners with respect and promote fairness and transparency in the contracting process. We only work with suppliers, vendors, and other external third parties that share our commitment to doing business ethically and in compliance with our Code of Conduct and applicable law. Ensure that we have the proper contracts and agreements in place with our business partners, and avoid entering into any side agreements. The Legal department can provide help if you have questions.

ZERO-TOLERANCE FOR CORRUPTION

We aspire to true greatness. We can’t get there if we don’t win business the right way. We never offer, promise, give, or accept money or anything of value to or from third parties to get an improper business advantage. Anti-corruption and anti-bribery laws apply in every country where Intercom operates. The criminal penalties for violating these laws are severe. Even small or minor improper gifts may be construed as bribes.

We have detailed processes to screen transactions and parties that pose greater risk for the company and detailed financial controls to maintain accurate and transparent books and records to document all payments properly. We have processes and procedures to screen carefully any third party or business partner that may interact with a foreign government official on Intercom’s behalf. We hold these third parties and business partners to the same standards that we hold ourselves and prohibit them from doing anything improper on our behalf.

AVOID IMPROPER GIFTS AND ENTERTAINMENT

Gifts and entertainment involving non-Intercom employees should never create the appearance of favoritism or a sense of obligation to act in a particular way. Always think about how others will perceive your actions. Gifts and entertainment should always be reasonable and have a legitimate business purpose. Employees must obtain prior approval from our Compliance department before giving any gift or entertainment involving a foreign government official and should consult our Anti-Corruption Policy for more information.

RESPECT TRADE CONTROLS

Intercom is subject to U.S. and international laws and restrictions based on economic sanctions against certain individuals and countries. When we import or export products (including software), we must always accurately classify, value, determine country of origin, and specify all facts reportable to customs authorities.

KEEP INTERCOM SECRETS SAFE

Our high standards include safeguarding Intercom information. Some of the information that we communicate internally is not public. We cannot share this information outside of the company. Although Intercom is not a public company, the federal securities laws in the U.S. impose requirements regarding how and when Intercom employees may share non-public information outside of the company that may impact trading in a public security. If we share non-public information outside the company that someone would consider important to making an investment decision, and that information is used in the purchase or sale of stock, this may constitute illegal “insider trading.”

You prevent insider trading by keeping Intercom’s secrets. Don’t share material non-public information with anyone, including family and friends. Within Intercom, only share information with colleagues when they need to know something to do their job. If you need to share confidential information with a third party as part of your job, make sure the party receiving the information has signed a non-disclosure agreement or is otherwise required to keep the information confidential consistent with our policies and legal requirements. And don’t talk about sensitive or non-public information in public places where someone may overhear your conversation.

Intercom’s confidential information and our intellectual property are important assets. Our intellectual property, business plans, sales data, and strategy represent hard work by our employee family and, in some cases, our competitive advantage. You should assume all Intercom information and intellectual property is confidential unless Intercom publicly discloses it.

PROTECT INTERCOM ASSETS AND PROMOTE OUR SOLUTIONS

We are extremely proud of what we have built at Intercom. Each of us should protect the tools the company gives us to help our customers. The same goes for company emails and web-based applications—we should all use these resources responsibly. Each of us has a responsibility to protect the company by following applicable information security policies, software licensing agreements, and document retention policies. Intercom accesses and monitors information stored and transmitted on Intercom devices and other equipment used for Intercom business. If you see theft, misappropriation, other waste or misuse of our resources or property, speak up.

PROTECT OUR EMPLOYEE AND CUSTOMER INFORMATION

Our customers and employees trust Intercom with their information. We must manage that data in appropriate and respectful ways that are consistent with our legal obligations and our mission to build trust with our customers and other stakeholders. We should collect data that we need to perform our jobs and keep it only as long as necessary for that purpose. We use data in the ways that we explained we would use it when we collected it. We are transparent and honor individual choice, and if we want to use data in a different way, we follow legal requirements for consent. And we never use anyone’s data for personal benefit. When we share data outside of the company, it is only with the understanding that whoever receives our data must share our commitment to privacy. Protecting our customers and employees is part of our brand. Customer loyalty drives our business. Data protection is a key ingredient of our success and maintaining our customers’ trust that we manage their data appropriately is everyone’s job.

FAIR COMPETITION

We compete fairly and comply with all applicable competition laws in the countries where we operate. Each of us should avoid discussing any of our business strategies or plans (including competitive intelligence) outside of Intercom, even informally. Be careful when speaking with third parties, including competitors and referral partners, at conferences or industry events. Exercise caution when making statements on social media and blogs, about our competitors or endorsements about our business partners, in a way that confuses or misleads customers and others. Avoid disclosing information obtained from former employers that are subject to non-disclosure, confidentiality, trade secret or proprietary agreements. Never enter into any agreements with competitors, unless specifically authorized to do so.

USE SOCIAL MEDIA RESPONSIBLY

Social media allows our internet business to stay connected to our customers. Employees use social media for expressive activity. But make smart decisions. Promoting Intercom’s brand and values online is part of our team culture, but do not discuss or promote anything that is not public. If you share your views about areas that impact our business, make sure to disclose that you work for Intercom and that your views are your own. If you see something negative about Intercom online that contains false information, don’t respond, but rather let your manager or leader know so that they and you can inform the right team for follow-up. If you receive any media inquiries, contact our Marketing and PR team who will help with the response. Only designated spokespersons may speak on behalf of our company. We speak with one voice in order to protect our brand.

PROMOTE SUSTAINABILITY

Intercom seeks to promote a shared-value approach to environmental issues. We are committed to operating in a sustainable way to better serve all our stakeholders for the long-term, including our commitments on carbon neutrality and building a robust program focused on protecting the future of our planet. Each of us should ensure Intercom is the type of sustainability-focused company we all want it to be.

PROTECT AND CELEBRATE OUR CULTURE

Our Code helps us ensure that our actions at work promote our values and culture for the future. What happens next is up to you and your employee teammates, working together. As we move fast, we want to ensure that our decisions represent the best of Intercom’s culture and we achieve our results by doing things the right way.

Remember, if you have a question about our Code, need advice on a topic, or are unsure about how to raise a concern, you can talk to your manager, the HR Team, or the Compliance department for help (compliance@intercom.io). You may also utilize our anonymous reporting channel (https://intercom.allvoices.co/) or helpline (+1-844-200-6084).