LogicMonitor Code of Conduct

Our approach to compliance, ethical business practices and transparency within LogicMonitor

LogicMonitor is built upon a foundation of strong corporate values and business practices. We view our Code of Conduct as an important resource for all employees supporting decision-making consistent with our core values. Our Code of Conduct encompasses a number of different areas:

If any LMer has questions about the Code, don’t hesitate to discuss them with your manager, Legal department, or our Human Resources department.

A Note from LogicMonitor’s CEO

Hi LM Team!

We’ve always focused on building things the right way here at LogicMonitor. Together we build great products and deliver an excellent customer experience! Equally important is that this business has been built on a foundation of integrity. I’ve always said that integrity is binary — you either have it or you don’t.

As we continue to grow and to expand our global footprint, I expect that each and every one of us LMers will continue to do the right thing by our customers, partners, prospects and LM team members each and every day.

Part of working at LogicMonitor is making a personal commitment to hold yourself accountable to the highest ethical standards. Integrity is just as important as our other company values of acting as One Team, remaining Customer Obsessed, and becoming Better Every Day

Thank you for all the great work that you do for LogicMonitor, and thank you for taking personal responsibility to live up to the expectations outlined in our Code of Conduct!


Kevin McGibben
Kevin McGibben
CEO
LogicMonitor

We’re committed to honest and ethical decision making

At LogicMonitor, we expect everyone employed by our company and its subsidiaries to make honest and ethical decisions. The same high ethical standards apply to everyone, regardless of job or level in the organization – from entry level through out Board of Directors and its officers. In certain circumstances, our Code also applies to contractors and temporary employees.

As LMers, we are all expected to follow both the letter and the spirit of our Code in order to prioritize honest and ethical decision making. Make sure you understand and follow all of our policies, laws, and regulations that apply to daily work, even if you feel pressured to do otherwise. Seek guidance if you have questions or concerns. We’re counting on LMers to report and fully cooperate in any investigation of suspected violations of the Code that may happen during employment, so we maintain our high ethical standards. Periodically, we’ll ask all LMers to review and acknowledge LogicMonitor’s Code of Conduct. Pledge to live up to our Code and its expectations, and to quickly raise concerns about any situation that you think may violate our Code. If you violate our Code you put yourself, all of your fellow LMers, and our company at risk.

We’re committed to reporting code violations

Any LMer or worker providing services to LogicMonitor who becomes concerned about misconduct, improper action, or wrongdoing should speak up and report the matter. We expect every LMer to work to prevent the violation of our Code as well as the violation of any applicable laws. Our managers have the added responsibility of preventing violations by anyone who reports to them. If an actual or potential violation is detected, please report details of the violations to your manager or General Counsel without delay.  If you are not comfortable reporting a violation to your manager or General Counsel, we’ve made it easy to report a violation anonymously via our employee anonymous hotline.

Have questions or concerns about reporting responsibilities? Discuss them with your supervisor, any member of the management team, the Legal Department, a People Operations team member, or through the anonymous hotline. The bottom line is that improper actions won’t be tolerated, and it’s everyone’s duty to report wrongdoing.

LogicMonitor’s hotline is available to employees 24 hours a day, every day. It is managed by an external, third-party service provider so that any LMer wishing to submit an anonymous report can do so without fear of retaliation by other LogicMonitor employees or management.

LMers are encouraged to use the hotline service in cases where they do not wish to be associated with a report and prefer to remain anonymous. If you are willing to provide your identity, to the extent possible, your disclosure will still be confidential. When possible and appropriate, please provide your identity as it makes it easier to ask follow-up questions and conduct a thorough investigation.

Retaliation for disclosure of incidents that are inconsistent with LogicMonitor’s Code of Conduct, Employee Handbook, and other policies or laws is never permitted for reports filed in good faith. Allegations made in bad faith may result in disciplinary action.

In addition to using the hotline, LMers can always report possible violations of federal law or regulation to any governmental agency or entity and are allowed to make disclosures that are protected under the whistleblower provisions of federal or state laws or regulations.

Hotline Reporting Information

In continuing to work to ensure that LogicMonitor embodies integrity and respect, we have established a mechanism that facilitates reporting of possible illegal, unethical, or improper conduct when the normal channels of communication have proven ineffective, are impractical under the circumstances, or you merely want to report a concern confidentially and anonymously.

Our Integrity & Compliance Hotline is available to all LMers, our customers, contractor, vendors and others who have genuine concerns or observe actions that appear to be inconsistent with LogicMonitor’s values or the law. If you are unsure about where to go with your concerns, or you feel uncomfortable reporting through normal communication channels, or wish to raise your concern anonymously, we invite you to access our Integrity & Compliance Hotline.

The Integrity & Compliance Hotline operates 24 hours a day, seven days a week, and is operated by an independent, third party. It is designed to protect your confidentiality, and your anonymity, if requested.

Regardless of how your report is made, LogicMonitor prohibits retaliation against anyone who in good faith reports a possible concern. LogicMonitor will take appropriate action against any individual who engages in such retaliation though any LMer who honestly raises a concern will not be adversely impacted for raising that matter. We believe it is essential to create an environment where individuals feel able to raise any matters of genuine concern.

Listed here are the various options you can use should you decide to use Lighthouse Services to report your concern:

  • Website: https://www.lighthouse-services.com/logicmonitor
  • Toll-Free Telephone:
    • Direct Dial
      • English speaking USA and Canada: 888-811-0006
      • Spanish speaking USA and Canada: 800-216-1288
      • French speaking Canada: 855-725-0002
      • Spanish speaking Mexico: 01-800-681-5340
    • AT&T USADirect
      • All other countries: 800-603-2869 (must dial country access code first, click here for access codes and dialing instructions)
  • Email: [email protected] (must include company name with report)
  • Fax: (215) 689-3885 (must include company name with report)

NOTE: Any LMer working in a jurisdiction that knowingly limits or restricts the use of the hotline reporting service should address their conflict / concerns with their manager or People Operations representative.

We protect employees from retaliation

LogicMonitor believes it’s essential to create an environment in where employees are able to raise matters of concern internally without fear of retaliation for speaking up. We take employee concerns seriously. All reported matters will be investigated appropriately, and whenever possible will be kept confidential.

Rest assured, employees who report a violation will not be disciplined or retaliated against for reporting their concerns. LogicMonitor also prohibits retaliation against anyone who provides information or cooperates during an investigation. This includes raising concerns around conduct that may constitute a violation of applicable laws or regulations, our Code of Conduct, or LogicMonitor’s related handbook and policies .

An employee raising a concern honestly, or taking part in an investigation, is protected from adverse employment action. This includes separation, demotion, suspension, loss of benefits, threats, harassment, or discrimination.

Remember, if you work with someone who has raised a concern or provided information in an investigation, always continue to treat the person with courtesy and respect. If you believe someone has retaliated against you, speak up and report the retaliation to our Chief People Officer, LogicMonitor’s General Counsel, or via the hotline.

We comply with all applicable rules, regulations and laws

To maintain the highest standards of integrity, LMers need to be aware of and follow all relevant laws and regulations. Violating relevant laws, regulations, our Code of Conduct, or encouraging others to do so, exposes LogicMonitor to risk and could result in disciplinary action, including termination of employment.

Violating laws may have serious consequences for LogicMonitor overall as well as for the individuals involved, so make sure to act with integrity to avoid unlawful or unethical conduct.

We avoid conflicts of interest

Smart business decisions should never be influenced by a conflict of interest. We require all employees to avoid conflicts of interest—or even the appearance of conflicts of interest—to ensure we maintain the trust of our customers, partners and suppliers. Plus, avoiding conflicts of interest is simply the right thing to do.

Wondering what exactly qualifies as a conflict of interest? A conflict of interest exists when personal, social, or financial interests, duties, obligations, or activities, or those of a family member are in conflict or incompatible with the interests of our company. Conflicts of interest undermine our company’s credibility and the trust that others place in us.

We expect LMers to let us know immediately about any situation that may involve an actual or potential conflict of interest. Contact your managers, the People Operations team, or our Legal Department if a situation arises that may be a conflict of interest.

Here are some examples of conflicts of interest:

  • Financial Interest: Owning, directly or indirectly, a significant financial interest in any entity that does business, seeks to do business, or competes with our company.
  • Outside Employment: Holding a second job that interferes with your ability to do your regular job. This isn’t allowed under our Code of Conduct.
  • Board Memberships: Employing, consulting, or serving on the board of a competitor, customer, supplier, or other service provider.
  • Employment of Relatives & Friends: Hiring a supplier, distributor, or other agent managed or owned by a relative or close friend.
  • Gifts & Entertainment: Soliciting or accepting any cash, gifts, entertainment, or benefits that are unreasonable in value from any competitor, supplier, or customer.
  • Corporate Opportunities: Taking personal advantage of corporate opportunities.

We’re committed to diversity, inclusion, and non-discrimination

At LogicMonitor, each and every employee is responsible for contributing to a culture of trust and respect that promotes a positive work environment. This means treating one another with fairness and courtesy and respecting diverse points of view. As a company, we are deeply committed to the principles of equal employment opportunity, inclusion and respect.

This also means that we prohibit discrimination in employment, employment-related decisions or in business dealings. This includes discrimination based on an individual’s race, color, ancestry, age, sex, sexual orientation, gender identity, religion, disability, ethnicity, national origin, veteran status, marital status, pregnancy, or any other status protected by law or local policy. Discrimination against any associates, customers, members, or suppliers is also never okay and will result in serious consequences.

We maintain a safe, harassment-free workplace for all

Every LMer has a right to a safe and healthy, harassment-free workplace. In fact, harassment in the workplace is against the law.

Have questions about harassment and what type of activities qualify as harassment? Harassment encompasses conduct which inappropriately or unreasonably interferes with work performance, diminishes the dignity of any person, or creates an intimidating, hostile, or otherwise offensive work environment based on an individual’s legally protected status. Verbal, visual, or physical conduct of a sexual nature is never acceptable, and may be deemed sexual harassment – which is also against the law.

Examples of sexual harrassment include:

  • Sexual advances, requests for sexual favors, sexually explicit language, off-color jokes, remarks about a person’s body or sexual activities
  • Displaying sexually suggestive pictures or objects, suggestive looks, leering, or suggestive communication in any form
  • Inappropriate touching, both welcome and unwelcome

LogicMonitor also prohibits other forms of harassment based on an individual’s legally protected status, such as:

  • Using slurs or negative stereotyping
  • Intimidating acts, such as bullying or threatening
  • Any other conduct that shows hostility toward, disrespect for, or mistreatment of an individual based on the individual’s legally protected status

Harassing conduct in the workplace is prohibited regardless of whether it is welcome or unwelcome, and regardless of whether the individuals involved are of the same or different sex, sexual orientation, race, or other status. We’re aiming for a workplace that is full of energy, collaboration and helps us stay customer obsessed – and we operate on a zero-tolerance policy when it comes to harassment.

Our goal is to always provide a safe and healthy workplace for all LMers, customers, and visitors to our offices. This also includes implementing safe practices when working in remote locations or at home.

Threats, acts of violence, and physical intimidation are never allowed in the workplace—or on Zoom calls. Talk of violence or jokes about violence will not be tolerated, either. To preserve employee safety and security, weapons, firearms, ammunition, explosives, and incendiary devices are forbidden on our company premises unless contrary to law.

Remember, it’s your responsibility to report any unsafe behavior or condition regardless of whether you were directly involved or a witness so that we can keep the workplace safe for everyone.

LogicMonitor Management is committed to abiding by all health and safety standards in all areas as they relate to employees, including ergonomics and workplace safety. Please do your part by observing all safety and health rules, practices, and laws that apply to your job, and take the precautions necessary to protect yourself, your co-workers, and visitors. Report any accidents, injuries, occupational illnesses, and unsafe practices or conditions to your supervisor or the People Operations team as soon as they occur to ensure a safe and healthy workplace for all.

We don’t let political activity interfere with anyone’s work

Everyone at LogicMonitor has a right to their own political beliefs. However, please remember that your statements at work could have a divisive impact in our diverse workplace, whether you intend or not; your politics can’t interfere with your or your co-workers’ getting the job done. You can support the political process and the political causes of your choice through personal contributions or by volunteering your time to candidates or organizations of your choice, but these activities need to take place outside of your working time and using your own resources. Also remember that you are not allowed to make any political contributions, such as to candidates, parties, political action committees or political causes, on behalf of LogicMonitor. If you decide to express a political view in a public forum (such as a letter to a newspaper), please don’t use LogicMonitor letterhead, your company e-mail address, or reference your business address or title. If you are one of our leaders, remember that even after removing all of these identifiers, readers may mistakenly perceive your comments as made on LogicMonitor’s behalf.

As a reminder of our guidelines around political activity:

  • LogicMonitor will never reimburse LMers for personal political activity.
  • Don’t let your or your co-workers’ job performance be affected by your personal political views or choice in political contributions.
  • Avoid using LogicMonitor, its assets or your working time to further your own political activities or causes.
  • If you plan to seek or accept a public office, you must obtain prior approval from LogicMonitor’s Legal team – but remember that your duties to our company come first and our policies regarding outside employment and conflicts of interest still apply.

We treat customers, suppliers, government contractors and competitors fairly

At LogicMonitor, we believe in ethical business transactions. To ensure we always act with integrity, we have policies in place to prevent corruption, bribery, money laundering, antitrust violations and illegal competitive intelligence gathering practices.

LogicMonitor has strict anti-corruption and anti-bribery policies we expect all employees to comply with around the world.

In all aspects of our business, we are committed to conducting business in an ethical manner in full compliance with laws and regulations. This includes compliance with the Foreign Corrupt Practices Act, 15 USC §§78dd-1, et seq. (“FCPA”), as well as other laws that prohibit bribery, kickbacks, or other improper payments. No LogicMonitor employee, officer, agent, or independent contractor acting on our behalf should ever offer or provide bribes to obtain business or an unfair advantage.

What qualifies as a bribe? Well, a bribe is defined as directly or indirectly offering anything of value (e.g., gifts, money, or promises) to influence action or to secure an improper advantage. The FCPA, the U.K. Bribery Act 2010 (UKBA) and other laws prohibit payment of money or anything of value to a foreign official, foreign political party or official, or any candidate for foreign political office for the purposes of obtaining, keeping, or directing of business.

The UK and other nations have even stricter laws that prohibit improper payments to private persons. It’s important to keep in mind that for areas of anti-bribery and anti-corruption, LogicMonitor can be held responsible for the activities of employees like you, as well as the actions of associated third parties. Therefore, we expect all LMers, officers, agents, consultants, distributors, resellers, independent contractors, and anyone acting on behalf of LogicMonitor to strictly abide by all anti-corruption and anti-bribery laws.

CURIOUS ABOUT WHAT A VIOLATION LOOKS LIKE?

In 2019, a Microsoft subsidiary in Hungary paid more than $25 million to the US Department of Justice (DOJ) and the US Securities and Exchange Commission (SEC) to resolve allegations that it participated in a bribery scheme in connection with the sale of Microsoft software licenses to Hungarian government agencies. The subsidiary provided “discounts” on software licenses to its resellers, distributors, and other third parties, but instead of passing those discounts along to its government customers, the subsidiary used those excess funds to make improper payments (bribes) to government officials to secure the software license sales.

In 2016, Massachusetts software company PTC Inc. and two of its foreign subsidiaries paid more than $28 million to the DOJ and SEC to resolve allegations that the companies improperly provided recreational travel to Chinese government officials in violation of the FCPA. The software company arranged and paid for employees of various Chinese state-owned enterprises to travel to the US, ostensibly for training at PTC Inc.’s headquarters in Massachusetts, but primarily for recreational travel to other parts of the United States. PTC China admitted that the costs of the trips (the bribes) were routinely hidden within the price of its software sales to the Chinese state-owned entities whose employees received the trips. The FCPA allows companies to pay reasonable and bona fide expenses related directly to “the promotion, demonstration, or explanation of products or services,” but excessive and recreational travel doesn’t meet that standard.

 

Money laundering is a global problem with far-reaching and serious consequences. Money laundering is defined as the process of converting illegal proceeds so that those funds are made to appear legitimate. Complex commercial transactions are used in money laundering to hide financing for criminal activities such as terrorism, illegal narcotics trade, bribery, and fraud. Any involvement in such activities would severely undermine our integrity, would damage our reputation, and could expose LogicMonitor and individuals to severe sanctions. LMers must avoid participating in any activities that would facilitate money laundering or result in unlawful financial diversion.

As an organization, we already take numerous steps to detect and prevent unacceptable or illegal forms of payment and financial transactions. Existing anti-money laundering laws in the United States and other countries and international organizations require transparency of payments and the identity of all parties for each transaction. We pledge full compliance with anti-money laundering laws throughout the world and will conduct business only with reputable customers involved in legitimate business activities and transactions.

As an organization, LogicMonitor also believes in free and open competition. This means we comply with all antitrust and fair competition laws. In addition, in most of the countries where we operate, there are strict laws in force similar to the antitrust laws of the United States and the European Union competition laws. These laws prohibit collusive or unfair business behavior that restricts free competition. The United States’ antitrust and other countries’ competition laws are pretty complicated, and failure to adhere to these laws comes with severe consequences.

Follow the below tips to ensure that you remain in compliance with antitrust and fair competition laws at all times:

  • Never share confidential pricing or customer information with competitors. If you are in a situation or are at a conference where such discussions arise, leave the discussion right away and make your objection known.
  • It’s illegal to enter agreements with competitors to fix prices, bids, terms of sale, production output, or to divide markets or customers. In addition, it may be illegal to restrict the freedom of our customers to compete. Legal issues may also arise if we refuse to deal with certain customers or competitors.

If you have any questions if something may be considered a violation of antitrust laws, get in touch with your manager or the Legal department.

When it comes to our suppliers, we require all LMers to engage in open and fair procurement activities regardless of nationality or the size of the transaction. Make sure to select suppliers on a competitive basis based on total value, which includes quality, suitability, performance, service, technology, and price. Always establish mutually beneficial relationships with our suppliers based on close cooperation and open communication, and don’t forget to establish a written agreement that has been approved by our Finance team before any work begins.

Finally, let’s talk about competitors. Gathering information about our competitors (“competitive intelligence”) is a legitimate business practice. Doing so helps businesses like ours remain competitive in the marketplace. That being said, it’s against the law to use illegal or unethical means to get information about other companies.

If you’re confused about what qualifies as a legitimate source of competitive information, here are some examples: publicly available information gleaned from news accounts, industry surveys, competitors’ displays at conferences and trade shows, and information publicly available on the Internet. You may also gain competitive information appropriately from customers and suppliers (unless they are prohibited from sharing the information) or by obtaining a license to use the information or buying the ownership of the information. When working with consultants, vendors, and other partners, make sure that they also understand and follow LogicMonitor policy on gathering competitive information.

Finally, when doing business with federal, state, local, or foreign governments, ensure that all statements and representations you make to government procurement officials are completely accurate and truthful. If your sales prospect directly involves the government or if you are responsible for someone working with the government on behalf of LogicMonitor, be alert to the special rules and regulations applicable to our government customers and make sure you are acting in compliance.

Take extra precautions to avoid any conduct that could appear improper when dealing with government officials and employees. Payments, gifts, or other favors given to a government official or employee are strictly prohibited as it may appear to be a means of influence or a bribe. Failure to avoid these activities may expose the government agency, the government employee, LogicMonitor and you to substantial fines and penalties.  For these reasons, any sale of our services to any government entity needs to be signed off on by Legal and Finance and must be fully compliant.

We adhere to a clearly defined corporate gift policy

Modest gifts, favors, and entertainment are often used to strengthen business relationships. However, never give or accept a gift, favor, or entertainment if it obligates, or appears to obligate, you in some way—or if it might be perceived as an attempt to influence fair judgment. Of course, normal courtesies such as lunches or dinners often take place—and these are fine, so long as they are transparent, proper, and consistent with regular business practice.

When it comes to corporate gifts, always use good judgment and common sense.  If you are unsure of the appropriateness of a particular courtesy and whether it is in line with LogicMonitor’s integrity standards, please discuss your situation with the executive team member for your function, our Chief Financial Officer, or Legal. A good common-sense rule of thumb to follow is that you should not provide any gift or entertainment to customers, suppliers, or others that you would not feel comfortable publicly accepting yourself and reporting to your own manager.

Here are some specific reminders when it comes to corporate gifts. LMers, officers, directors, family members, agents, or agent’s family members are prohibited from offering, accepting, or receiving a gift or entertainment if it:

  • Is in cash,
  • Is not consistent with customary business practices,
  • Is extravagant in value,
  • Can be construed as a kickback, bribe, or payoff in violation of any law including, without limitation, a bribe to a government official in violation of the FCPA or the UKBA,
  • Violates any other laws or regulations, or
  • Could cause embarrassment to or discredit LogicMonitor if disclosed.

There are additional laws that apply to interactions with government officials and employees. For example, the U.S. and other countries have strict laws that prevent giving anything, including food or beverages, to a government employee. When doing business with government agents, employees, or officials, do not extend courtesies of any kind and do not permit any company agents such as resellers or distributors to do so either.  If you become aware that a reseller or distributor is doing so, inform your executive leader, our Chief Financial Officer, or LogicMonitor’s Legal department.

One final point of clarification: There is a big difference between a common business courtesy, such as paying for a customer’s lunch, and offering someone a bribe. Bribes are illegal and are unethical. Have more questions? Please review our anti-bribery and anti-corruption policies here.

We respect and protect company assets

LogicMonitor’s assets are the resources we use to conduct our business. These include physical assets, confidential information, intellectual property, records, and accounting documents. Every LMer is expected to respect and protect LogicMonitor assets at all times, in compliance with the law and with the written commitments you made in your confidentiality agreements upon joining LogicMonitor.

By protecting our assets, you’re helping protect our competitive advantage in the marketplace. Every LMer also has a responsibility to our customers, partners, and suppliers to protect any assets they entrust to LogicMonitor. Use LogicMonitor assets only for legitimate company business and appropriately safeguard them against cyber-related attack, theft, loss, waste, or abuse.

Wondering exactly what company assets include? Company assets can be defined as:

  • Physical assets, such as office furnishings, equipment, and supplies
  • Technology assets, such as computer hardware, software, and information systems
  • Financial assets, such as cash, securities, and credit cards
  • LogicMonitor’s name, its brand, and our customer relationships
  • Information assets, such as intellectual property including, without limitation, information about our customers, products, prices, services, systems, product roadmaps, marketing strategies, and other data

All physical and technology assets provided by LogicMonitor, whether used inside or outside the LogicMonitor workplace, are company property and are for your business use only. Never sell, lend, or give company assets away, regardless of their condition or value, unless you are authorized to do so. Remember that it is never acceptable to take part in any activity that involves theft, fraud, embezzlement, extortion, or misappropriation of company assets and property.

We also have policies specific to confidential information. In carrying out LogicMonitor business, LMers, officers, and directors may learn confidential or proprietary information about our company, its customers, prospective customers, or other third parties. LMers, officers, and directors must keep such information confidential, except when disclosure is authorized or legally mandated.

Confused about what confidential or proprietary information includes? Well, among other things, any non-public information concerning LogicMonitor. This includes our businesses, financial performance, results or prospects, product road maps, our software, and any nonpublic information provided by a third party, with the expectation that the information will be kept confidential and used solely for the business purpose for which it was conveyed. 

When it comes to other types of assets beyond physical property, LogicMonitor’s intellectual property is among our most valuable assets. “Intellectual property” refers to unique creations of the human mind that are protected by various national laws and international treaties. In our industry, intellectual property might include copyrights, patents, trademarks, trade secrets within our software and algorithms, design rights, logos, expertise, or other intangible industrial or commercial property.

Make sure to protect and, when appropriate, alert Legal to any infringement or taking of our intellectual property rights. And when it comes to intellectual property belonging to third parties, respect their IP too! Do not knowingly infringe upon or misuse the intellectual property rights of others.

Records

When we mention records in the context of LogicMonitor, we aren’t talking about the musical kind. Records are LogicMonitor’s corporate memory. They provide evidence of actions and decisions we have made, and contain data and information critical to the continuity of our business.

Records consist of all forms of information created or received by LogicMonitor, whether originals or copies, regardless of media. Some familiar examples of company records include paper documents, e-mail, electronic files stored on hard drive, disk, or any other medium (CD, DVD, USB data storage devices, etc.) that has information about our company or our business activities.

All of our records are the property of LogicMonitor and should be kept following your department’s records retention rules. Each LMer is responsible for properly labeling and carefully handling confidential, sensitive, and proprietary information and securing it when not in use. Make sure not to destroy any official company documents or records before the appropriate and applicable retention time expires.

Accurate and reliable financial and accounting records are particularly crucial to our business. LogicMonitor is committed to keeping accurate company records and accounts to ensure that we always adhere to legal and ethical business practices and to prevent fraudulent activities. All LMers are tasked with helping ensure that the information recorded, processed, and analyzed is accurate, and recorded following applicable legal or accounting principles.

We also need to make sure that our records are secure and readily available to those with a need to know the information on a timely basis. Company records include, without limitation, booking information, payroll, timecards, travel and expense reports, e-mails, accounting and financial data, invoices, purchase orders, development logs and notes, measurement and performance records, electronic data files, and all other records kept in the ordinary course of our business. All company records must be complete, accurate, and reliable in all material respects. Remember that there is never a reason to make false or misleading entries. Keep things simple and transparent and always steer clear of undisclosed or unrecorded funds, payments or receipts.

We prioritize privacy and security

At LogicMonitor, we never take shortcuts when it comes to data security and privacy. LogicMonitor respects the privacy of all LMers, business partners, and end users. But that also means that every LMer must handle personal data responsibly and in compliance with all applicable privacy laws and company policies – and the legal commitments we make to our customers regarding their data.

Specific rules and regulations exist around personal data that everyone needs to be aware of. “Personal data” is defined as information that can directly or indirectly identify an individual, such as name, contact information, and health-related information, or as otherwise defined under applicable law. Access to personal information is only authorized when there is a legitimate and lawful reason, and access is only granted to appropriate personnel.

So what does it mean when a security incident occurs? Well, a security incident is defined as an event that compromises the personal data that we hold about LMers, customers, or any other person; other information in our possession or control; or our own intellectual property.

Security incidents are not limited to events that pose a threat to personal data, however. Security incidents come in many forms, including phishing attacks, theft of data, emailing personal data to the wrong person, and malware. If you become aware of a security incident, report it by emailing security[at]logicmonitor.com or through the slack channel #security.

Have additional questions around data or privacy? Refer to LogicMonitor’s Privacy Policy for more detailed guidance on the handling of personal data or for a more in-depth description of protected information.

We abide by global trade and anti-boycott laws

LogicMonitor is a global business. When it comes to global laws, we are all responsible for following U.S. import and export laws, trade sanction regulations, and all other applicable laws that govern international trade. These laws can be complex and may change quickly as governments adjust to political and security issues, however, so stay vigilant. If your work involves the importation or exportation of any products, services or technology, it is your responsibility to contact the Legal team to ensure that LogicMonitor complies with all applicable laws. Also make sure that any vendors you work with know, understand, and abide by all import/export and trade sanction laws that apply to their products.

CONFUSED ABOUT WHAT A SANCTION VIOLATION MIGHT LOOK LIKE?

In November 2019, Apple paid more than $460,000 to resolve allegations that it violated U.S. sanctions regulations when Apple entered into an app development agreement with a Slovenia software company called SIS. The U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) had designated SIS and its majority owner as foreign narcotics traffickers and identified them on OFAC’s List of Specially Designated Nationals and Blocked Persons (the “SDN List”). Apple’s sanction screening tool failed to identify SIS and the owner as blocked parties, and as a result, Apple continued to host apps owned by SIS on the App Store for almost two years. 

When it comes to global trade, one last note: please do not comply with foreign boycotts that are not approved by the U.S. government. If you receive a request related to any boycott, contact LogicMonitor’s Legal department and do not respond to the request yourself.

We’re all about clear, consistent communication

At LogicMonitor, what we say reflects who we are and what our company stands for. Every LMer needs to communicate (both internally and externally) in a way that is consistent with our reputation and brand. This means communicating clearly and consistently in a professional and ethical manner—and of course, without disclosing confidential information.

Having trouble remembering what’s what when it comes to confidential information? Refer to the LogicMonitor Employee Handbook or your Employee Restrictive Covenants Agreement with LogicMonitor for specific guidelines.

Don’t forget: When it comes to official external communications, LMers are not authorized to speak with the media, investors, and analysts on behalf of the company unless permitted to do so by the Brand & Corporate Communications  team within Marketing. To ensure professional handling, all media requests, approvals of press releases prepared by third-parties, or questions around award submissions or interviews should be directed to press[at]logicmonitor.com. Unless authorized, do not give the impression that you are speaking on behalf of LogicMonitor in any communication that may become public. This includes posts to online forums, social media sites, blogs, chat rooms, and bulletin boards, and applies to comments to journalists about specific matters that relate to our businesses, as well as letters to the editor and endorsements of products or services. All LMers must abide by LogicMonitor’s Social Media Policy as well, whether or not their personal account is linked to their corporate identity or not. What employees do online in their own time still reflects back on the company as a whole, so please be smart about online activities and interactions with the media.

We build up the community while building our business

We pride ourselves on being a company that operates with integrity, makes good choices, and does the right thing in every aspect of our business—including within our community. LogicMonitor continually challenges itself to redefine what being a responsible company means. We’re a company that seeks to align social and environmental efforts with company goals by building up the community around us as we grow our business.

One such community building program is LM Cares. This program encourages LMers across all parts of the world to take part in events that support community involvement. Beyond LMCares, LogicMonitor is deeply committed to upholding fundamental human rights.

All human beings around the world should be treated with dignity, fairness, and respect. We ask suppliers and direct contractors to demonstrate a serious commitment to the health and safety of their workers and operate in compliance with human rights laws. LogicMonitor does not use or condone the use of slave, forced or child labor, or human trafficking, and denounces any degrading treatment of individuals, or unsafe or unhealthy working conditions. LogicMonitor always follows all applicable wage and hour laws and regulations. Please see our UK Modern Slavery Act statement here.