Code of Ethics

Letter from the Co-Founders

At Terakeet, we believe that doing the right thing is the foundation of our business success. We tell the truth. We prioritize ethics, integrity, and lawful conduct in every decision. We speak up when something isn’t right. We create a welcoming and inclusive environment. 

These are Terakeet’s highest values. It’s up to every one of us to make them an integral part of Terakeet’s culture. Terakeet implemented this Code of Ethics and Business Conduct as a guide to help every Terakeet stakeholder make decisions that we can all be proud of. 

Whenever the path forward is anything less than obvious, Terakeet encourages active discussion of how the principles in this Code apply to our day-to-day work. The more we discuss ethics, integrity, and doing what’s right – with our managers, with our service providers, and with each other – the more likely we are to keep these considerations top-of-mind when it really matters.

On behalf of Terakeet’s entire executive team, we are deeply grateful for your commitment to upholding Terakeet’s culture and values.

Thank you,

Mac and Pat

About this Code

At Terakeet, we believe that honest, ethical, and lawful conduct are critical to our business success. The behavior of each individual executive, officer, and employee is a direct reflection on Terakeet and sends a message to every person and company that interacts with us. It’s up to all of us to uphold Terakeet’s culture of ethics, integrity, and compliance with the law. 

Terakeet has adopted this Code to:

• help ensure that our actions align with Terakeet’s values;
• promote honest and ethical conduct in all of our work;
• ensure the ethical handling of conflicts of interest; 
• promote full, fair, accurate, timely, and understandable disclosure in reports and documents that we file with any government entity, and in all public communications made by Terakeet; 
• promote compliance with applicable governmental laws, rules and regulations, including compliance with their spirit so that we act ethically even when the law doesn’t require us to;
• promote the protection of Terakeet’s assets, including corporate opportunities and confidential information;
• promote fair dealing and fair competition;
• deter unlawful, unethical, and dishonest conduct and wrongdoing; and
• ensure that all of us are accountable for adherence to the Code.

With these goals as context, it’s also important to understand that this brief Code cannot include every Terakeet internal policy or every legal obligation that applies to your work, nor can it foresee every situation in which you may run into an ethical dilemma. 

The overarching purpose of this Code is to provide a principled framework by which all of us can make ethical, honest, and lawful decisions. It is also intended to encourage frequent and robust internal dialog about questions of ethics, integrity, and legal compliance. 

Simply put, the Code is intended to help us all do the right thing and encourage us to engage in frequent internal dialog about what it means to do the right thing. 

Every Terakeet executive, member, officer, director, and/or employee (“Stakeholder”), whether such position exists now or may exist in the future, is required to be familiar with this Code, comply with its provisions and its spirit, and promptly report any suspected violations of the Code as described in the Reporting and Enforcement section below. This Code also serves as a set of guidelines for every Terakeet contractor, service provider, and vendor (“Contractor”), who should receive the Code, familiarize themselves with it, and abide by its principles when interacting with Terakeet.¹

Honest and Ethical Conduct

All of us must act with integrity and observe the highest ethical standards when dealing with customers, suppliers, partners, competitors, Stakeholders, Contractors, and anyone else with whom we interact over the course of performing our jobs.

At Terakeet, we never prioritize business outcomes over doing what’s right. No manager can require you to act unethically, dishonestly, or otherwise in violation of this Code.  

Of course, our policies cannot foresee every ethical issue that will arise in the workplace, but we should all aspire to act in the spirit of Terakeet’s values and ethical culture even when internal policies and the law are silent. If a particular course of action is unethical, even if it’s technically allowed by the law or Terakeet policies, then it’s not a course of action that we should pursue. 

In Practice

Q: We’re putting together a sales pitch for a new client, and I’ve been put in charge of making the presentation. My manager asked me to add a few bullet points about our experience in the client’s industry. However, after speaking with a number of colleagues, I realized that this will be our very first client in this space – we’ve never done work in the client’s industry before. I don’t want to mess up our pitch. What should I do? 

A: You should never make claims in marketing materials that aren’t accurate. In this situation, you should inform your manager that you checked on Terakeet’s experience in the industry and determined that this is our first client in the space. You and your manager can then think about an appropriate way to modify the pitch and still make a strong business case for Terakeet while ensuring that everything we say is accurate and honest.

A Checklist for Ethical Decision-Making

All of us sometimes face circumstances in which the right thing to do is unclear. Terakeet has created a checklist to help guide us in these situations:

• Do my actions violate any law, regulation, or contractual obligation?
• Do my actions violate any Terakeet policy? 
• Do my actions violate any other policy, such as a vendor’s terms of service?
• Do my actions feel wrong or unethical? 
• Do my actions go against the spirit of this Code or Terakeet’s values?
• Are my actions dishonest?
• If a newspaper article were written about my actions, would it harm Terakeet’s reputation? Would it harm my own reputation?
• If I had to present my actions and reasoning process at a meeting of Terakeet staff, would my colleagues and managers be disappointed?

If the answer to every question is “No,” then you can proceed confidently with your decision.

In Practice 

Q: I’ve been struggling with an ethical dilemma and don’t know what to do. Is there someone I can talk to about it?

A: Please know that you never need to make difficult decisions alone. If you’re struggling with an ethical dilemma or any other question, then you can always reach out to your manager, speak with a colleague, connect with any member of the human resources team, or make your question the topic of a group discussion next time your team has a meeting. You can also just email [email protected] for advice and guidance.

Terakeet encourages active and robust discussion of how the principles in this Code apply to our day-to-day work. The more we discuss ethics, integrity, and doing what’s right, the more likely we are to keep these considerations top-of-mind when it really matters. 

Empowering Each Other to Speak Out

Terakeet believes that a single voice can have a big impact. This is why you should speak your mind early and often. We must work together to foster a culture in which all of our Terakeet colleagues are encouraged to share ideas and questions, and feel empowered to raise concerns in a receptive, responsive, and nonretaliatory workplace.

At Terakeet, we aspire to create an environment in which every member of the team—from the newest intern to the most senior manager—feels comfortable speaking their mind. By speaking out when something feels wrong, and by asking questions whenever we have doubts, we may prevent ethical lapses, unlawful conduct, and other violations of this Code and Terakeet’s values.

In Practice

Q: I’m in a team meeting and my manager just suggested a marketing strategy that seems unethical to me. I don’t think it violates a particular Terakeet policy, and I have no reason to think it’s unlawful, but it just doesn’t feel like the right thing to do. Should I raise my concern?

A: Yes, absolutely. By speaking your mind respectfully, you may help your manager realize that it’s not the right approach. You may also spark a team discussion about how Terakeet’s values and ethical principles apply to day-to-day decisions, which is one of the best ways to help further Terakeet’s ethical, values-based culture.

Respect for Others

Every person who interacts with Terakeet deserves to be treated with dignity and respect. We should actively solicit diverse opinions and viewpoints, be respectful and courteous in our communications, graciously accept feedback and questions (whether coming from a manager, direct report, or peer), and otherwise foster an inclusive and respectful work environment. Even during disagreements, which are inevitable in any professional setting, we must conduct ourselves respectfully and professionally.

Terakeet is an equal opportunity employer that strictly prohibits discrimination based on age, race, color, religion, creed, national origin, ancestry, ethnicity, sex, pregnancy, gender, gender identity, gender expression, transgender status, physical or mental disability, gender dysphoria, citizenship status, military status, genetic information, marital status, domestic violence victim status, familial status, sexual orientation, and/or any other characteristic protected by applicable federal, New York, or other state or local laws.

In Practice

Q: We’re in the process of interviewing candidates to fill a recent opening on our team. One of the candidates seems excellent and has the strongest professional background in the applicant pool, but my manager expressed some hesitation about moving forward because the applicant is pregnant and will be unavailable for a few months once the baby is born. What should I do?

A: If you’re comfortable doing so, you should remind your manager that we make hiring decisions based on merit, and never based on protected characteristics such as pregnancy. If that doesn’t address the issue, or if you feel more comfortable speaking with someone else, then you should promptly make a report as explained in the Reporting and Enforcement section below.

All Stakeholders and Contractors are prohibited from engaging in discriminatory, harassing, violent, abusive, bullying, intimidating, or offensive behavior, regardless of whether such behavior relates to a protected characteristic. Any person who feels discriminated against, harassed, abused, intimidated, or otherwise mistreated, or who has observed such mistreatment of another person, should report their concerns using the process explained in the Reporting and Enforcement section below. You are also encouraged to speak out in the moment to stop such behavior before it continues. 

In Practice

Q: I recently saw an employee yell at a colleague during a team meeting. What should I do?

A: Terakeet prohibits abusive and intimidating behavior. Yelling has no place at Terakeet. You should tell that employee’s manager or make a report using the process described in the Reporting and Enforcement section below.

Personal Conflicts of Interest

A conflict of interest occurs when your private interests, or the interests of a member of your family, interfere or appear to interfere with the interests of Terakeet. For example, a conflict of interest can arise when:

• you or a member of your family has an interest that may make it difficult to perform your work for Terakeet objectively and effectively; 
• you or a member of your family receive improper personal benefits as a result of your position with Terakeet;
• you send Terakeet business to a service provider that’s owned by you or a member of your family;
• you are engaged as a consultant to a competitor of Terakeet while also working at Terakeet; or
• you hire a family member to work for your team at Terakeet.

Loans by Terakeet to employees or their family members are of special concern and could constitute improper personal benefits to the recipients, depending on the facts and circumstances. Loans by Terakeet to any executive, officer, director, or their family members are expressly prohibited. Guarantees of loans by Terakeet raise the same concerns as actual loans.

Conflicts of interest should be avoided unless specifically authorized using the following process.

• If you have questions about a potential conflict of interest or become aware of an actual or potential conflict, then you should contact the conflicts team by emailing [email protected]. Terakeet may provide approval of the proposed course of action or, alternatively, determine that a problematic conflict exists.  
• If the conflicts team has any questions about a particular conflict of interest determination, then they can consult with the executive team to help make a final determination.
• If a conflict of interest determination concerns a member of the executive team, leadership team, or a person in a similarly-senior position, then the conflicts team must present the relevant facts and circumstances to the executive team, which shall make the final determination. The person with the conflict shall recuse themself from the discussion and decision. 
• If a member of the conflicts team is the subject of an inquiry regarding a potential or actual conflict of interest, then the matter should instead be discussed with the other members of the conflicts team or directly with the executive team. The person with the conflict shall recuse themself from the discussion and decision.

In Practice

Q: My manager asked me to identify and hire a service provider for a particular project. It so happens that the company where my spouse works provides the exact service we need and charges lower rates than many similar providers. Can Terakeet hire the company?

A: Maybe. The starting point is disclosing to the conflicts team at [email protected] that your spouse works at the potential service provider. Once you make that disclosure, the conflicts team will determine appropriate next steps, which may involve hiring a different service provider, having a neutral person with no potential conflict decide which service provider to hire (including your spouse’s company among the options), or simply clearing the conflict. The key is to disclose the potential conflict early, before making any decisions on your own.

Client Conflicts of Interest

A client conflict of interest occurs when the interests of one Terakeet client interfere with the interests of another Terakeet client. When Terakeet’s work for one client may have a detrimental impact on another client because the clients have opposing interests, then you should contact the conflicts team at [email protected], which will provide guidance about how to proceed.

Legal Compliance

All of us must comply, both in letter and spirit, with all applicable laws, rules, and regulations in every location in which Terakeet does business. You may not know the details of all applicable laws, rules, and regulations that govern your work, but it is important to know enough to determine when to seek advice and counsel.

In Practice

Q: What happens if this Code is stricter than applicable law?

A: You should always follow the strictest rule that applies to your actions. For example, if the Code does not allow a particular course of conduct even though the law allows it, then you should follow the stricter requirements of the Code. By contrast, if you run into a situation when the law requires something that the Code or another Terakeet policy does not, then you should follow the law. 

Legal questions can get complicated. Questions about compliance with laws and regulations should be addressed to [email protected]. You will receive a response with appropriate guidance.

Corporate Opportunities

All Stakeholders owe a duty to Terakeet to advance its interests when the opportunity arises. Stakeholders and Contractors are prohibited from taking for themselves personally (or for the benefit of friends or family members) opportunities that are discovered through their position with Terakeet, or the use of Terakeet’s assets, property, or information. Stakeholders and Contractors may not use Terakeet’s assets, property, or information, or their position with Terakeet, for personal gain (including gain of friends or family members).

In Practice   

Q: I’m responsible for reaching out to potential clients that express interest in Terakeet’s services. I just spoke to a startup that asked about a discrete project. The startup is smaller than most of our clients and may not be able to pay our rate, so I’m not sure if it’s the right fit for Terakeet. My cousin works for a smaller firm that offers some of the same services as Terakeet. This client would be much more significant to my cousin’s firm than to us. Can I send them the potential client?

A: No. We are prohibited from taking opportunities for our family members that we discovered through our work for Terakeet. This situation also raises a potential conflict of interest – you may not be able to objectively assess whether the client is a fit for Terakeet because of the incentive to send the client to a family member’s firm.

Inside Information

Over the course of your work, you may have access to material nonpublic information about Terakeet and its clients. You may not purchase or sell another company’s securities while in possession of material nonpublic information regarding that company. You also may not purchase or sell future or current Terakeet securities while in possession of material nonpublic information regarding Terakeet. 

Moreover, it is against Terakeet policies and illegal for any Stakeholder or Contractor to use material nonpublic information regarding Terakeet or any other company to obtain profit for themselves, or directly or indirectly “tip” others who might make an investment decision on the basis of that information.

Financial Reports and Government Filings

Any documents or reports that Terakeet files with a government entity, and all of Terakeet’s public communications, must be accurate and comply with all applicable laws and regulations. 

If you contribute to the preparation or verification of Terakeet’s financial statements and/or other financial information, then you must ensure that Terakeet’s books, records, and accounts are accurately maintained. All of us must cooperate fully with Terakeet’s accountants, auditors, and legal counsel.

If you are involved in a government filing or public communication, then you must take all necessary steps to ensure that the information about the financial and business condition of Terakeet is full, fair, accurate, timely, and written in understandable language.

Protecting and Respecting Information and Privacy

Terakeet Assets

We must all protect Terakeet’s assets. What are Terakeet’s assets? Just like you have personal assets, like your cell phone, home, and bank account, Terakeet has assets, like your work computer, Terakeet’s bank accounts and company charge cards, our email and phone system, and all other Terakeet resources. 

As a general rule, you should treat Terakeet assets using the same care with which you treat your own assets. We never steal Terakeet assets, treat them with carelessness, or waste them. 

The obligation to protect Terakeet assets also applies to Terakeet’s proprietary information, which includes intellectual property (such as trade secrets, patents, trademarks, and copyrights), business and marketing plans, current and future business strategies, databases, records, and any nonpublic financial data or reports. Unauthorized use or distribution of this information is prohibited and could also be illegal and result in civil or criminal penalties.

Terakeet assets should be used only for legitimate business purposes (though incidental personal use may be permitted). If you have a Terakeet charge card, you should only use it for approved business purposes and never for personal expenses. If you accidentally put a personal expense on your Terakeet card, please let your manager know and pay it back immediately.

In Practice 

Q: My friend started a new job at XYZ Corp doing similar work to what I do at Terakeet. She asked me to share a few of the different types of reports that we send to clients because she has to create similar reports at her new company and would like some good templates. What should I do?

A: You should not share the reports. All of us must protect Terakeet’s proprietary information.

Third Party Assets 

At Terakeet, we do not infringe on the assets of others. This means that you may never attempt to obtain a competitor’s or other entity’s proprietary information by improper or unlawful means. We can gather publicly available information about our competitors and their clients, but we would never gather information in an unethical or unlawful way. We also do not engage in any unauthorized use of a third party’s proprietary information or intellectual property.

In Practice

Q: I’m having dinner with a colleague who just left his employment with a competitor of Terakeet. He told me that, just before leaving, he printed an overview of his former employer’s confidential sales strategy. He offered to email it to me. What should I do?

A: You should refuse to look at the sales strategy and tell him not to email it to you. We always compete fairly and respect third party assets.

Terakeet prohibits plagiarism and using the work of others without acknowledgment. We do not present another person’s or entity’s work as our own and must give appropriate attribution when presenting work that isn’t our own.

Confidential and Personal Data

We must maintain the confidentiality of information entrusted to us by clients, service providers, suppliers, partners, Stakeholders and Contractors, except when disclosure is expressly authorized or required by law. 

Confidential information includes all nonpublic information (regardless of its source) that might be of use to Terakeet’s competitors or harmful to Terakeet or its clients, service providers, suppliers, or partners if disclosed. Confidential information also includes the personal data in our possession, including personal data about our employees and clients. We must protect such confidential and personal information, and only store, use, and disclose it if we have a business reason or legal obligation for doing so. Legal questions about the use and storage of data can be complicated, so don’t hesitate to contact [email protected] if you have any questions.

Bribery and Corruption

Terakeet Stakeholders and Contractors may never engage in bribery or any other type of corruption. This means you may never give anything of value (such as cash, gifts, favors, job offers, and travel reimbursements) to gain business advantages that Terakeet did not earn on its own merits. We always clearly enter payments using Terakeet’s expense-tracking processes so that the purpose of any payment is apparent. 

Just as we never give bribes, we also never accept them. If a vendor or service provider attempts to give you anything of value to gain business advantages, then you should not accept the gift and report the attempted gift using the process in the Reporting and Enforcement section below.

The prohibition on bribery includes giving cash, gifts, or favors to government officials, private employees, or other individuals in their personal capacity to achieve a particular business outcome outside of formal channels and service offerings. For example, Terakeet may pay a formal “expedited processing” or similar fee, for which we receive an invoice and receipt, to a government or private entity when the fee is paid for the entity’s formal services and offerings. By contrast, we never give a cash gift to a government or private employee in their personal capacity to help expedite their work.

In Practice

Q: We’ve had internet issues on our floor for the past few days. An outside IT provider has come twice but hasn’t resolved the issue. The first time she came, she got called to an emergency job and had to leave. The second time she came, she said she was missing a part and would come back the next day. She’s coming back today for the third time. Can I just give her some cash so she does us a favor and feels motivated to see the project through completion?

A: No. We do not give cash gifts to individuals in order to expedite their work.

Gifts

We never give or accept gifts, favors, meals, or entertainment that are, or may be perceived to be, an inappropriate incentive to make or influence business decisions. We also never give or accept gifts, favors, meals, or entertainment that would: violate any law or internal policy (including policies of the recipient); contain inappropriate content; or would be embarrassing to Terakeet or harm its reputation.

Accepting Gifts

We make business decisions based on the best interests of Terakeet and the merits of our business partners. We never solicit or accept gifts, favors, meals, or entertainment that influence, or even appear to influence, any business decision we make on behalf of Terakeet. We never accept a gift of cash, nor do we accept any gift that may create the appearance that it was given to influence a Terakeet business decision.

You may accept an unsolicited gift of nominal value that promotes friendly working relationships and good will with business partners. In general, gifts such as cookies, fruit, pens, mugs, baseball hats, and similar branded items are acceptable. You may also accept an occasional invitation to a meal or other entertainment paid for by the person who invites you. 

Any gift with a value over $75 should be approved by your manager before you accept it.

Giving Gifts

Terakeet competes in the marketplace based on its merits, its reputation, and the quality of its work. We never: give gifts that influence, or even appear to influence, business decisions regarding Terakeet; use gifts in an attempt to gain business advantages that Terakeet did not earn on its own merits; give monetary gifts; or give gifts in violation of any laws, regulations, or internal policies of other entities. Special rules apply to government employees, so we do not give gifts to government employees without specific legal guidance and approval. 

Subject to the approval of your manager, you may occasionally give nominal gifts and tokens of appreciation to Terakeet’s clients, service providers, and business partners, as long as such gifts are not, and cannot be reasonably interpreted to be, an attempt to achieve business advantages based on factors other than Terakeet’s merits. 

Appropriate gifts include things like cookies, fruit, pens, mugs, baseball hats, and similar branded items. You may also invite a client or business partner to a reasonable meal or reasonably-priced entertainment activity, again subject to your manager’s advance approval. Outside of special circumstances, gifts should not have a value higher than $75.

In Practice  

Q: One of Terakeet’s vendors offered to pay for my flight and hotel expenses to attend a conference in Florida. What should I do?

A: You should turn down the gift, and then tell a manager or make a report using the process in the Reporting and Enforcement section below. The vendor is offering something far beyond a nominal gift and significantly in excess of $75. That type of gift would be likely to influence business decisions and is prohibited.

Fair Dealing

We must deal fairly with Terakeet’s customers, suppliers, partners, service providers, competitors, employees, and anyone else with whom we have contact in the course of performing our jobs. We never take unfair advantage of any person or entity through manipulation, concealment, abuse of privileged or confidential information, misrepresentation of facts, or any other unfair dealing practice.

When we enter into contracts, we only agree to take on work that we have the skills and resources to competently complete. We do not promise services or outcomes on which we cannot deliver, and we always act in good faith to adhere to our contractual commitments.

In Practice

Q: I’m engaged in the sales process with a potential client that has a difficult goal in mind. After discussing the project at length, my team estimated that there’s a 30% chance that we won’t be able to achieve the client’s goal due to various factors outside of our control. However, the client has asked me to guarantee their desired outcome. I’m afraid that unless I agree, the client will bring their business to a competitor. What should I do?

A: At Terakeet, we never prioritize business outcomes over integrity. In this situation, you should explain to the client that, despite Terakeet’s very best efforts, there are certain external circumstances that may stand in the way of achieving the client’s desired outcome.

Fair Competition

We compete fairly based on the high quality of the work we do for clients. We recruit new clients based on our reputation and work product, and never through unlawful, unethical, or dishonest means. 

We comply with all applicable antitrust and competition laws. We never enter into agreements with competitors to restrict competition or:

• set or fix prices for our work;
• manipulate a bidding process by discussing or agreeing to the terms of bids;
• allocate clients, markets, or territories; 
• refuse to work with certain clients, competitors, or service providers; 
• exclude competitors from entering the market; 
• limit services offered; or
•  provide confidential information to a competitor.

Antitrust and competition laws are complicated, so it’s important to ask questions if you ever have any doubts or concerns. You can always contact [email protected] for guidance.   

Reporting and Enforcement

If you have experienced or observed a violation or potential violation of this Code, please report it promptly. If you don’t report a concern, then Terakeet may never find out about it. And if Terakeet doesn’t know about a violation of the Code, then it will not be in a position to take appropriate corrective action and help ensure that it doesn’t happen again in the future.

How Can I Make a Report?

Actions prohibited by this Code can be reported by emailing [email protected] or visiting terakeet.com/report-a-concern. Reporters have the option to make an anonymous report. 

How Can I Ask a Question?

If you have a legal question, then you can contact [email protected].

If you have a conflict of interest question, then you can contact [email protected]. 

If you’re struggling with an ethical dilemma, then you can contact [email protected].

Alternatively, if you feel more comfortable bringing your concern or question to a manager, a member of the human resources team with whom you already have a relationship, or another member of Terakeet’s leadership, then it will become their responsibility to address your question or concern directly, bring in a subject matter expert to assist, or escalate it as needed by making a report of the concern as described above.

After receiving a report of an alleged violation of this Code, Terakeet shall promptly take appropriate steps to investigate and/or otherwise address the report. 

All of us are expected to cooperate in any internal investigation of misconduct. It would be a violation of this Code not to cooperate in an investigation.

Terakeet will take prompt and consistent action against violations of this Code. If, after investigating a report of an alleged violation of this Code, the investigator determines that a violation has in fact occurred, then appropriate preventative or disciplinary action shall be taken. 

Depending on the nature of the violation, preventative or disciplinary action may include, but is not limited to, issuing a: verbal warning; written warning; formal coaching; reassignment; demotion; dismissal; and/or in the event of criminal conduct or other serious violations of the law, notification of appropriate governmental authorities.

The executive team may, in its discretion, waive any violation of this Code, subject to any applicable disclosure requirements that may apply now or in the future; provided that the subject of the concern shall recuse themself from the discussion and waiver decision. 

Preventing Retaliation

Terakeet protects employees who speak their minds. If you raise a concern in good faith—either by using the process described in the Reporting and Enforcement section below or by speaking to a manager or member of human resources—then your concern will be addressed confidentially, only shared with others on a need-to-know basis, and will not lead to any adverse action against you. 

Terakeet does not tolerate retaliation against any person who makes a good faith report of known or suspected violations of this Code, whether such report is made internally or externally, and strictly prohibits any form of discipline, reprisal, intimidation, or adverse action for such good faith reports. Anyone who retaliates in any way against a person who raises a good faith report is in violation of this Code.

In Practice

Q: I’d like to raise a concern to my manager about something I saw a couple days ago that may be a violation of the Code, but I’m concerned that my whole team will find out and I’ll be treated differently by them after raising my concern.

A: It’s up to all of us to speak up when we see ethical lapses, unlawful conduct, or other violations of this Code. Terakeet has a strict policy against all forms of retaliation. Concerns are always handled confidentially. Information about the concern, and the person who raised it, is only shared on a need-to-know basis. Also, any form of retaliation for raising a concern is in itself a violation of this Code and strictly prohibited. You should always feel safe raising good faith concerns.