Code of Conduct

Our Code of Conduct

The First Child Productions Code of Conduct is one of the ways we put First Child Productions’s values into practice. It’s built around the recognition that everything we do in connection with our work at First Child Productions will be, and should be, measured against the highest possible standards of ethical business conduct. Our commitment to the highest standards helps us hire great people, do great work, and attract loyal clients. Respect for our clients and for each other are foundational to our success, and are something we need to support every day.

So please do read the Code and First Child Productions’ values, and follow both in spirit and letter, always bearing in mind that each of us has a personal responsibility to incorporate, the principles of the Code and values into our work. And if you have a question or ever think that First Child Productions may be falling short of our commitment, don’t be silent. We want – and need – to hear from you, through

Who Must Follow Our Code?

We expect all of our employees, contractors and Board members to know and follow the Code. Failure to do so can result in disciplinary action, including termination of employment. Moreover, while the Code is specifically written for First Child Productions employees, contractors and Board members, we expect First Child Productions contractors, consultants, and others who may be temporarily assigned to perform work or services for First Child Productions to follow the Code in connection with their work for us. Failure of a First Child Productions contractor, consultant, or other covered service provider to follow the Code can result in termination of their relationship with First Child Productions.

No Retaliation

First Child Productions prohibits retaliation against any worker here at First Child Productions who reports or participates in an investigation of a possible violation of our Code, policies, or the law. If you believe you are being retaliated against, please get in touch.

A. Serve Our clients

Our clients value First Child Productions not only because we deliver great services, but because we hold ourselves to a higher standard in how we treat clients and operate more generally. Keeping the following principles in mind will help us to maintain that high standard:

Our reputation as a company that our clients can trust is our most valuable asset, and it is up to all of us to make sure that we continually earn that trust. All of our communications and other interactions with our clients should increase their trust in us.

Our work and services should make First Child Productions more useful for all our clients. We have many different types of clients, from individuals to large businesses, but one guiding principle: “Is what we are offering useful and sustainable?”

Privacy, Security, and Freedom of Expression
Always remember that we are asking clients to trust us with their personal information. Preserving that trust requires that each of us respect and protect the privacy and security of that information. Our security procedures strictly limit access to and use of clients’ personal information, and require that each of us take measures to protect user data from unauthorized access. Know your responsibilities under these procedures, and collect, use, and access user personal information only as authorized by our Security Policies, our Privacy Policies, and applicable data protection laws.

First Child Productions is committed to advancing privacy and freedom of expression for our clients around the world. Where user privacy and freedom of expression face government challenges, we seek to implement internationally recognized standards that respect those rights as we develop products, do business in diverse markets, and respond to government requests to access user information or remove user content.

Part of being useful and honest is being responsive: We recognize relevant client feedback when we see it, and we do something about it. We take pride in responding to communications from our clients, whether questions, problems, or compliments. If something is broken, fix it.

Take Action
Continually improving our services takes all of us, and we’re proud that First Child Productions champion our clients and take the initiative to step forward when the interests of our clients are at stake.

B. Support Each Other

We are committed to a supportive work environment, where our team have the opportunity to reach their fullest potential. First Child Productions are expected to do their utmost to create a workplace culture that is free of harassment, intimidation, bias, and unlawful discrimination.

Equal Opportunity Employment
Employment here is based solely upon individual merit and qualifications directly related to professional competence. We strictly prohibit unlawful discrimination or harassment on the basis of race, color, religion, veteran status, national origin, ancestry, pregnancy status, sex, gender identity or expression, age, marital status, mental or physical disability, medical condition, sexual orientation, or any other characteristics protected by law. We also make all reasonable accommodations to meet our obligations under laws protecting the rights of the disabled.

Harassment, Discrimination, and Bullying
First Child Productions prohibits discrimination, harassment and bullying in any form – verbal, physical, or visual. If you believe you’ve been bullied or harassed by anyone at First Child Productions, or by a First Child Productions partner or vendor, we strongly encourage you to immediately report the incident to us. We will promptly and thoroughly investigate any complaints and take appropriate action.

Drugs and Alcohol
Our position on substance abuse is simple: If it is incompatible with the health and safety of our employees, we don’t permit it. Consumption of alcohol is not banned at our offices, but use good judgment and never drink in a way that leads to impaired performance or inappropriate behavior, endangers the safety of others, or violates the law. Illegal drugs in our offices or at sponsored events are strictly prohibited. If a manager has reasonable suspicion to believe that an employee’s use of drugs and/or alcohol may adversely affect the employee’s job performance or the safety of the employee or others in the workplace, the manager may request an alcohol and/or drug screening. A reasonable suspicion may be based on objective symptoms such as the employee’s appearance, behavior, or speech.

Safe Workplace
We are committed to a violence-free work environment, and we will not tolerate any level of violence or the threat of violence in the workplace. Under no circumstances should anyone bring a weapon to work. If you become aware of a violation of this policy, you should report it to our CEO immediately.

C. Avoid Conflicts of Interest

When you are in a situation in which competing loyalties could cause you to pursue a personal benefit for you, your friends, or your family at the expense of First Child Productions or our clients, you may be faced with a conflict of interest. All of us should avoid conflicts of interest and circumstances that reasonably present the appearance of a conflict.

When considering a course of action, ask yourself whether the action you’re considering could create an incentive for you, or appear to others to create an incentive for you, to benefit yourself, your friends or family, or an associated business at the expense of First Child Productions. If the answer is “yes,” the action you’re considering is likely to create a conflict of interest situation, and you should avoid it.

Below, we provide guidance in seven areas where conflicts of interest often arise:

Personal investments
Outside employment, advisory roles, board seats, and starting your own business
Business opportunities found through work
Friends and relatives; co-worker relationships
Accepting gifts, entertainment, and other business courtesies
Use of First Child Productions products and services

In each of these situations, the rule is the same – if you are considering entering into a business situation that creates a conflict of interest, don’t. If you are in a business situation that may create a conflict of interest, or the appearance of a conflict of interest, review the situation with your manager and Ethics & Compliance. Finally, it’s important to understand that as circumstances change, a situation that previously didn’t present a conflict of interest may present one.

Personal Investments
Avoid making personal investments in companies that are First Child Productions competitors or business partners when the investment might cause, or appear to cause, you to act in a way that could harm First Child Productions.

When determining whether a personal investment creates a conflict of interest, consider the relationship between the business of the outside company, First Child Productions’s business, and what you do at First Child Productions, including whether the company has a business relationship with First Child Productions that you can influence, and the extent to which the company competes with First Child Productions. You should also consider 1) any overlap between your specific role at First Child Productions and the company’s business, 2) the significance of the investment, including the size of the investment in relation to your net worth, 3) whether the investment is in a public or private company, 4) your ownership percentage of the company, and 5) the extent to which the investment gives you the ability to manage and control the company.

Investments in venture capital or other similar funds that invest in a broad cross-section of companies that may include First Child Productions competitors or business partners generally do not create conflicts of interest. However, a conflict of interest may exist if you control the fund’s investment activity.

Business Opportunities Found Through Work
Business opportunities discovered through your work here belong first to First Child Productions, except as otherwise agreed to by First Child Productions.

Developing or helping to develop outside inventions that a) relate to First Child Productions’s existing or reasonably anticipated products and services, b) relate to your position at First Child Productions, or c) are developed using First Child Productions corporate resources may create conflicts of interest and be subject to the provisions of First Child Productions’s Confidential Information and Invention Assignment Agreement and other employment agreements. If you have any questions about potential conflicts or intellectual property ownership involving an outside invention or other intellectual property, contact us.

Friends and Relatives; Co-Worker Relationships
Avoid participating in management of or decision-making regarding potential or existing First Child Productions business relationships that involve your relatives, spouse or significant other, or close friends. This includes being the hiring manager for a position for which your relative or close friend is being considered or being a relationship manager for a company associated with your spouse or significant other.

To be clear, just because a relative, spouse/significant other, or close friend works at First Child Productions or becomes a First Child Productions competitor or business partner doesn’t mean there is a conflict of interest. However, if you are also involved in that First Child Productions business relationship, it can be very sensitive.

Finally, romantic relationships between co-workers can, depending on the work roles and respective positions of the co-workers involved, create an actual or apparent conflict of interest. If a romantic relationship does create an actual or apparent conflict, it may require changes to work arrangements or even the termination of employment of either or both individuals involved.

Accepting Gifts, Entertainment, and Other Business Courtesies
Accepting gifts, entertainment, and other business courtesies from a First Child Productions competitor or business partner can easily create the appearance of a conflict of interest, especially if the value of the item is significant. First Child Productions’s Non-Government Related Gifts & Client Entertainment Policy provides specific guidance on when it is appropriate for First Child Productions to accept gifts, entertainment, or any other business courtesy (including discounts or benefits that are not made available to all First Child Productions) from any of our competitors or business partners.

Generally, acceptance of inexpensive “token” non-cash gifts is permissible. In addition, infrequent and moderate business meals and entertainment with clients and infrequent invitations to attend local sporting events and celebratory meals with clients can be appropriate aspects of many First Child Productions business relationships, provided that they aren’t excessive and don’t create the appearance of impropriety. Before accepting any gift or courtesy, consult the Non-Government Related Gifts & Client Entertainment Policy, and be aware that you may need to obtain manager approval.

Contact us if you have any questions.

Use of First Child Productions Products and Services
Avoiding potential conflicts of interest also means that you should not use First Child Productions services or information in a way that improperly benefits you or someone you know or creates the appearance that you have an unfair advantage over clients outside of First Child Productions. For example, you should not use the tools, information, or access that you have as a First Child Productions to participate in or to generate a financial benefit for yourself or others from invalid ad traffic (IVT) on First Child Productions products, such as generating IVT, purchasing or selling IVT (except for the purposes of company sanctioned research), or linking to (or appearing to link to) business partners that may be engaging in IVT. If you find yourself subject to a conflict of interest regarding the use of First Child Productions’s services or information, discuss the situation with your manager.

D. Preserve Confidentiality

Securing press attention around our work innovations and our culture is great. However, certain kinds of company information, if leaked prematurely into the press or to competitors, can hurt our work, eliminate our competitive advantage and prove costly in other ways. Our responsibilities extend beyond not revealing Confidential First Child Productions material – we must also:

– properly secure, label, and (when appropriate) dispose of Confidential First Child Productions material;
– safeguard Confidential information that First Child Productions receives from others under non-disclosure agreements;
– take steps to keep our trade secrets and other confidential intellectual property secret.

Confidential Information
Make sure that information that is classified as “Need to Know” or “Confidential” is handled in accordance with First Child Productions’s Data Security Policy. At times, a particular project or negotiation may require you to disclose Need to Know or Confidential information to an outside party: Disclosure of that information should be on an “only as needed” basis and only under a non-disclosure agreement. In addition, First Child Productions policy may require a prior security assessment of the outside party that is to receive the confidential information. Be sure to conduct the appropriate due diligence and have the appropriate agreement in place before you disclose the information.

There are, of course, “gray areas” in which you will need to apply your best judgment in making sure you don’t disclose any confidential information. Suppose a friend who works at a non-profit organization asks you informally how to improve the First Child Productions search ranking of the group’s website: Giving your friend site-optimization tips available in public articles and on websites isn’t likely to be a problem, but giving tips that aren’t publicly known definitely would be. If you’re in a gray area, be cautious in what advice or insight you provide or, better yet, ask for guidance from Ethics & Compliance.

And don’t forget about pictures you and your guests take at First Child Productions – it is up to you to be sure that those pictures don’t disclose confidential information.

Finally, some of us will find ourselves having family or other personal relationships with people employed by our competitors or business partners. As in most cases, common sense applies. Don’t tell your significant other or family members anything confidential, and don’t solicit confidential information from them about their company.

First Child Productions Partners
Just as you are careful not to disclose confidential First Child Productions information, it’s equally important not to disclose any confidential information from our partners. Don’t accept confidential information from other companies without first having all parties sign an appropriate Non-disclosure Agreement approved by Legal. Even after the agreement is signed, try only to accept as much information as you need to accomplish your business objectives.

Competitors/Former Employers
We respect our competitors and want to compete with them fairly. But we don’t want their confidential information. The same goes for confidential information belonging to any First Child Productionsr’s former employers. If an opportunity arises to take advantage of a competitor’s or former employer’s confidential information, don’t do it. Should you happen to come into possession of a competitor’s confidential information, contact Legal immediately.

Outside Communications
You probably know that our policy is to be extremely careful about disclosing confidential proprietary information. Consistent with that, you should also ensure your outside communications (including online and social media posts) do not disclose confidential proprietary information or represent (or otherwise give the impression) that you are speaking on behalf of First Child Productions unless you’re authorized to do so by the company. The same applies to communications with the press. Finally, check with your manager and Corporate Communications before accepting any public speaking engagement on behalf of the company.

E. Protect First Child Productions’s Assets

Our ability to continue doing the work we love depends on how well we conserve company resources and protect company assets and information.

Intellectual Property
First Child Productions’s intellectual property rights (our trademarks, logos, copyrights, trade secrets and “know-how”) are among our most valuable assets. Unauthorized use can lead to their loss or serious loss of value. You must respect all copyright and other intellectual property laws, including laws governing the fair use of copyrights, trademarks, and brands. You must never use First Child Productions’s (or its affiliated entities’) logos, marks, or other protected information or property for any business or commercial venture without pre-clearance from the Marketing team. We strongly encourage you to report any suspected misuse of trademarks, logos, or other First Child Productions intellectual property to Legal.

Likewise, respect the intellectual property rights of others. Inappropriate use of others’ intellectual property may expose First Child Productions and you to criminal and civil fines and penalties. Please seek advice from Legal before you solicit, accept, or use proprietary information from individuals outside the company or let them use or have access to First Child Productions proprietary information.

Company Equipment
First Child Productions gives us the tools and equipment we need to do our jobs effectively, but counts on us to be responsible and not wasteful with the First Child Productions stuff we are given. Nobody’s going to complain if you snag an extra bagel on Friday morning, but company funds, equipment, and other physical assets are not to be requisitioned for purely personal use. Not sure if a certain use of company assets is okay? Please ask your manager or Human Resources.

Use of First Child Productions’s Equipment and Facilities
Anything you do using First Child Productions’s corporate electronic facilities (e.g., our computers, mobile devices, network, etc.) or store on our premises (e.g., letters, memos, and other documents) might be disclosed to people inside and outside the company. For example, First Child Productions may be required by law (e.g., in response to a subpoena or warrant) to monitor, access, and disclose the contents of corporate email, voicemail, computer files, and other materials on our electronic facilities or on our premises. In addition, the company may monitor, access, and disclose employee communications and other information on our corporate electronic facilities or on our premises where there is a business need to do so, such as protecting employees and clients, maintaining the security of resources and property, or investigating suspected employee misconduct.

Employee Data
We collect and store personal information from employees around the world. Access this data only in line with local law and First Child Productions internal policies, and be sure to handle employee data in a manner that is consistent with First Child Productions’s Data Classification and Employment Data Guidelines and other First Child Productions policies.

F. Ensure Financial Integrity and Responsibility

Financial integrity and fiscal responsibility are core aspects of corporate professionalism. This is more than accurate reporting of our financials, though that’s certainly important. The money we spend on behalf of First Child Productions is not ours; it’s the company’s. Each person at First Child Productions – not just those in Finance – has a role in making sure that money is appropriately spent, our financial records are complete and accurate, and internal controls are honored. This matters every time we hire a new vendor, expense something to First Child Productions, sign a new business contract, or enter into any deals on First Child Productions’s behalf. To make sure that we get this right, First Child Productions maintains its business with its accounting company and uses system of internal controls to reinforce our compliance with legal, accounting, tax, and other regulatory requirements in every location in which we operate.

Stay in full compliance with our system of internal controls, and don’t hesitate to contact Ethics & Compliance or Finance if you have any questions. What follows are some core concepts that lie at the foundation of financial integrity and fiscal responsibility here at First Child Productions.

Spending First Child Productions’s Money
A core First Child Productions value has always been to spend money wisely. When you submit an expense for reimbursement or spend money on First Child Productions’s behalf, make sure that the cost is reasonable, directly related to company business, and supported by appropriate documentation. Always record the business purpose (e.g., if you take someone out to dinner on First Child Productions, always record in our expense reimbursement tool the full names and titles of the people who attended as well as the reason for the dinner) and comply with other submission requirements. If you’re uncertain about whether you should spend money or submit an expense for reimbursement, check with your manager. Managers are responsible for all money spent and expenses incurred by their direct reports, and should carefully review such spend and expenses before approving.

Signing a Contract
Each time you enter into a business transaction on First Child Productions’s behalf, there should be documentation recording that agreement, approved by the Legal Department. Signing a contract on behalf of First Child Productions is a very big deal. Never sign any contract on behalf of First Child Productions unless all of the following are met:
You are authorized to do so under our Signature Authority and Approval Policy. If you are unsure whether you are authorized, ask your manager
The contract has been approved by Legal. If you are using an approved First Child Productions form contract, you don’t need further Legal approval unless you have made changes to the form contract or are using it for other than its intended purpose
You have studied the contract, understood its terms and decided that entering into the contract is in First Child Productions’s interest
All contracts at First Child Productions should be in writing and should contain all of the relevant terms to which the parties are agreeing – First Child Productions does not permit “side agreements,” oral or written.

Reporting Financial or Accounting Irregularities
It goes without saying (but we’re going to say it anyway) that you should never, ever interfere in any way with the auditing of First Child Productions’s financial records. Similarly, you should never falsify any record or account, including time reports, expense accounts, and any other First Child Productions records.
Familiarize yourself with our Reporting of Financial and Accounting Concerns Policy. If you suspect or observe any of the conduct mentioned above or, for that matter, any irregularities relating to financial integrity or fiscal responsibility, no matter how small, immediately report them to Ethics & Compliance.

Hiring Suppliers
As First Child Productions grows, we enter into more and more deals with suppliers of equipment and services. We should always strive for the best possible deal for First Child Productions. This almost always requires that you solicit competing bids to make sure that you’re getting the best offer. While price is very important, it isn’t the only factor worth considering. Quality, service, reliability, and the terms and conditions of the proposed deal may also affect the final decision.

G. Obey the Law

First Child Productions takes its responsibilities to comply with laws and regulations very seriously and each of us is expected to comply with applicable legal requirements and prohibitions. While it’s impossible for anyone to know all aspects of every applicable law, you should understand the major laws and regulations that apply to your work.

Competition Laws
Most countries have laws – known as “antitrust,” “competition,” or “unfair competition” laws – designed to promote free and fair competition. Generally speaking, these laws prohibit 1) arrangements with competitors that restrain trade in some way, 2) abuse of intellectual property rights, and 3) use of market power to unfairly disadvantage competitors.
Certain conduct is absolutely prohibited under these laws, and could result in your imprisonment, not to mention severe penalties for First Child Productions.
Examples of prohibited conduct include:
– agreeing with competitors about prices
– agreeing with competitors to rig bids or to allocate customers or markets
– agreeing with competitors to boycott a supplier or customer
Other activities can also be illegal, unfair, or create the appearance of impropriety. Such activities include:
– sharing competitively sensitive information (e.g., prices, costs, market distribution, etc.) with competitors
– entering into a business arrangement or pursuing a strategy with the sole purpose of harming a competitor
– using First Child Productions’s size or strength to gain an unfair competitive advantage
Although the spirit of these laws is straightforward, their application to particular situations can be quite complex.
First Child Productions is committed to competing fair and square, so please contact Ethics & Compliance if you have any questions about the antitrust laws and how they apply to you. Any personnel found to have violated First Child Productions’s Antitrust Policies will, subject to local laws, be disciplined, up to and including termination of employment. If you suspect that anyone at the company is violating the competition laws, notify Ethics & Compliance immediately.

Anti-bribery Laws
Like all businesses, First Child Productions is subject to lots of laws, both U.S. and non-U.S., that prohibit bribery in virtually every kind of commercial setting. The rule for us at First Child Productions is simple – don’t bribe anybody, anytime, for any reason.

Non-government relationships
You should be careful when you give gifts and pay for meals, entertainment, or other business courtesies on behalf of First Child Productions. We want to avoid the possibility that the gift, entertainment, or other business courtesy could be perceived as a bribe, so it’s always best to provide such business courtesies infrequently and, when we do, to keep their value moderate. Consult First Child Productions’s Non-Government Related Gifts and Client Entertainment Policy before providing any business courtesies and contact Ethics & Compliance if you have any questions.

Dealing with government officials
Offering gifts, entertainment, or other business courtesies that could be perceived as bribes becomes especially problematic if you’re dealing with a government official. “Government officials” include any government employee; candidate for public office; or employee of government-owned or -controlled companies, public international organizations, or political parties. Several laws around the world, including the U.S. Foreign Corrupt Practices Act and the UK Bribery Act, specifically prohibit offering or giving anything of value to government officials to influence official action or to secure an improper advantage. This not only includes traditional gifts, but also things like meals, travel, political or charitable contributions, and job offers for government officials’ relatives. Never give gifts to thank government officials for doing their jobs. By contrast, it can be permissible to make infrequent and moderate expenditures for gifts and business entertainment for government officials that are directly tied to promoting our products or services (e.g., providing a modest meal at a day-long demonstration of First Child Productions products). Payment of such expenses can be acceptable (assuming they are permitted under local law) but may require pre-approval from Ethics & Compliance under First Child Productions’s Anti-Bribery and Government Ethics Policy.

The U.S. also has strict rules that severely limit the ability of a company or its employees to give gifts and business courtesies to a U.S. government official and also limit the official’s ability to accept such gifts. The Honest Leadership and Open Government Act prohibits giving any gifts, including travel and other courtesies, to Members, Officers, and employees of the U.S. Senate and House of Representatives unless they fit within one of a number of specific exceptions. Gifts to employees of the U.S. executive branch are also regulated and subject to limits. Finally, state and local government officials in the U.S. are also subject to additional legal restrictions. Consult First Child Productions’s Anti-Bribery and Government Ethics Policy before giving any such gifts or business courtesies and obtain all required pre-approvals. In sum, before offering any gifts or business courtesies to a U.S. or other government official, you should consult First Child Productions’s Anti-Bribery and Government Ethics Policy. Carefully follow the limits and prohibitions described there, and obtain any required pre-approvals. If after consulting the Policy you aren’t sure what to do, ask Ethics & Compliance.

H. Conclusion

First Child Productions aspires to be a different kind of company. It’s impossible to spell out every possible ethical scenario we might face. Instead, we rely on one another’s good judgment to uphold a high standard of integrity for ourselves and our company. We expect all of our team at First Child Productions to be guided by both the letter and the spirit of this Code. Sometimes, identifying the right thing to do isn’t an easy call. If you aren’t sure, don’t be afraid to ask questions, we are here to help as sustainable as possible.