Strong Leadership

At Looker, all employees are expected to lead and foster a culture of ethical and compliant behavior. Looker has an Ethics and Compliance Team (ECT), which focuses on the development and enhancement of our compliance program. Our Ethics and Compliance Team is led by our HR Director, who is a member of our senior management and makes regular reports regarding compliance matters to the Chief Executive Officer, other senior-level leaders and Looker’s Board of Directors. The Ethics and Compliance Team staff provides dedicated support to Looker’s leaders, employees and businesses.

Clear Written Standards

The Code of Business Conduct, published in print and online, sets forth core guidelines and requirements for ethical behavior. Looker employees read and certify adherence to our Code annually. Our Code states clearly that Looker does not tolerate illegal or unethical behavior in any aspect of our business. It emphasizes the importance of ethical and honest conduct, adhering to Looker’s policies and procedures, treating confidential information appropriately, avoiding conflicts of interest and maintaining Looker’s books and records with accuracy and integrity. Further, it requires our employees to ask questions about or report any concerns regarding compliance matters.

Looker also complies with legal, industry and relevant institutions’ requirements regarding the interaction of our employees with our clients and suppliers. We comply with national, regional and other requirements regarding transparency about our relationships with our clients and suppliers. As required, we track and report payments and transfers of value (such as meals) provided to our clients and suppliers.

Effective Lines of Communication

Creating an environment where employees can raise questions and concerns helps us advance our commitment to ethical behavior. We have established systems and processes for employees and others to ask questions, raise concerns and report suspected or actual violations of our Code, policies and procedures, or laws and regulations, without fear of retribution or retaliation. We offer a number of resources to employees, such as our Ethics and Compliance Helpline (+86 21 60103021), a telephone- and web-based hotline available 24 hours a day, seven days a week. Employees also may contact the Ethics and Compliance Team or the HR Director directly. For more information, visit our Ethics and Compliance Helpline Privacy Notice.

All allegations are analyzed and corrective actions are taken where necessary, including terminating employees or supplier relationships. In accordance with our internal or legal obligations, we report information about actual or potential violations to senior management, the Board and the government(s), as appropriate. The Ethics and Compliance Team also creates opportunities to engage in face-to-face interactions with employees by participating in national, regional and local meetings. Issues also are highlighted on our Ethics and Compliance Team intranet site and through other targeted communications vehicles.

Relevant Training

Training and education programs for employees and other relevant personnel increase their awareness of our Code’s precepts and the legal and ethical implications of their actions and behaviors. Looker’s ethics and compliance staff work with our local commercial teams throughout China to help them conduct trainings and education programs that help ensure compliance and strengthen Looker’s reputation as a responsible corporate citizen while enhancing relationships with customers and other stakeholders.

For example, Looker employees in China participate in our Ethics and Compliance Resource Training program, a web-based training system in collaboration with Quantum University, designed to increase awareness of policies and procedures, as well as the legal and ethical implications of business decisions. Another successful approach has been the use of interactive ethics challenge games, in which local employees meet face-to-face with Ethics and Compliance representatives to ask questions and discuss company policies.

Accountability

Looker employees and other relevant personnel are expected to adhere to our Code as a condition of their continued employment. Anyone who violates our Code, or any policy or procedure, is subject to appropriate disciplinary action. Any Looker employee who fails to report a violation of Looker policy or procedure of which he or she is or should have been aware may also be subject to disciplinary action. Looker does not tolerate retaliation against anyone who makes a good-faith report regarding a violation or potential violation of our Code, policies or procedures, or laws or regulations. These guidelines are well publicized and enforced.

Forthright Assessment

The Ethics and Compliance Team utilizes results from internal investigations, internal audits and internal monitoring programs to assess the effectiveness of, and identify areas for improvement in, the compliance program and relevant business practices. In addition, we consider the external environment, including industry codes and government guidance to identify new opportunities to enhance the compliance program.

Remediation

Results of investigations, audits and monitoring are communicated to the appropriate Ethics and Compliance Team staff and business leaders. When an area for improvement is identified, the Ethics and Compliance Team and other Looker functions partner to implement corrective actions.