Code of Ethics & Business Conduct

This Code of Conduct documents Ulula’s commitment to ethical, legal conduct that is consistent with our values and mission. It provides a set of principles designed to promote a positive work environment which support our culture of strong governance, sound business practices and the highest ethical conduct, while advancing our mission of fuelling the growth of a purpose-driven economy.

The document provides general guidelines to Ulula employees, as well as contractors, partners and other stakeholders who work with us. It has been designed to ensure that all who are bound by this code, conduct themselves with dignity and respect towards one another, the organizations we serve, partner with and advocate for. It also seeks to ensure compliance with all pertinent legislation in the climates we serve, to ensure full disclosure and to maintain Ulula’s professional reputation.  

The key principles underpinning our Code of Conduct are as follows:

  • Our actions must be governed by the highest standards of humility, integrity and humanity
  • Our decisions must be made in accordance with the spirit and letter of the law
  • Our business must be conducted honestly and ethically, in a respectful and collaborative environment, using our best skills and judgment, for the benefit of our employees and partners
  • Our actions must be for the unambiguous benefit of Ulula and its beneficiary communities and individuals
  • Our actions should seek to enhance Ulula’s reputation and performance

While every Ulula employee is held to the high ethical standards set out in this Code, leaders have additional responsibilities. Our leaders are required to model expected behaviors; ensure that employees understand their obligations under this Code and create and sustain a culture where individuals are comfortable raising concerns and potential violations without fear of reprisal.

Legal Requirement

Employees and partners must adhere to all statutory acts, regulations or by-laws that govern and/or regulate the operations of Ulula, as well as all civil and criminal laws, regulations and statutes that apply. They must not knowingly or otherwise engage in or condone any activity or attempt to circumvent the clear intention of the law.

Adherence to Core Values

All employees, partners, contractors and stakeholders must behave in a manner consistent with Ulula’s core values, which are:

  • Trust 
  • Open Communication 
  • Empathy
  • Civility
  • Adaptability 
  • Balance

All individuals must seek to maintain and enhance Ulula’s reputation by being accountable for their professional and personal actions. No individual shall work under the influence of alcohol or use, or be in possession of, illegal substances on Ulula premises, within Ulula vehicles or accommodation. Individuals` shall also not exchange money, offers of employment, employment, goods or services for sex or sexual favours, nor any forms of humiliating, degrading or exploitative behaviour.

Protection of Company Property

Preserving and safeguarding Ulula’s property, whether material or intangible, is the responsibility of every employee. Equipment, materials, and supplies that are purchased with Ulula funds are the property of Ulula. They must be used only in Ulula’s interest and they must be protected from theft, misuse or damage.

You must take steps any reasonable person would use to protect these valuable assets. You must not disclose any trade secrets, confidential business information to unauthorized outside parties, use Ulula’s assets, for personal purposes, or take them with you if and when you leave the Company. You may not assert any ownership over any intellectual property you developed or helped develop while in Ulula’s employ.

Handling Information and Maintaining Confidentiality

At Ulula, our operations may generate the use of confidential information. Consequently, our employees are highly likely to deal with confidential information on a daily basis as part of their job functions. Additionally, a considerable amount of information is given to us on the premise of trust by our investors, partners, service providers and employees and the best practice when handling such information is to consider it confidential unless stated otherwise.

It is our collective and individual responsibility to protect confidential information from inadvertent, unauthorized or malicious dissemination, misuse, modification, loss or damage. Confidential information must be properly labeled, stored, access controlled and disposed in accordance with Ulula’s obligations. 

Examples of confidential information include, but are not limited to: 

(a) client information (e.g. contracts, financial information, personal information, etc.); 

(b) third-party information (e.g. technological information); 

(c) Ulula proprietary information (e.g. financials, development ideas, etc.); and, 

(d) employee personal information.

Employees have an obligation to preserve and protect Ulula’s confidential data, trade secrets and other confidential information as outlined in the Employment Agreement.

Conflict of Interest

Employees must either avoid or disclose a potential conflict of interest that might influence or be perceived to influence personal actions or judgments, while executing on Ulula responsibilities. 

Even when the giving and acceptance of gifts is normal cultural practice, employees must decline monetary gifts or inappropriate gifts from partners, governments, organizations, suppliers and other persons, which have been offered as a result of the employee’s  association or employment with Ulula. Where the giving and acceptance of gifts is normal cultural practice, the employee should ensure that such gifts are within the limits of reasonable judgements and in accordance with Ulula policies. Employees must also act against any form of corruption and not offer, promise, give or accept any bribes.

Respect in The Workplace

Ulula believes in providing and maintaining an environment characterized by mutual respect, integrity and dignity, and free from harassment and discrimination. Such actions are not tolerated, and where applicable, will be addressed immediately and accordingly. Employees must also ensure that their relationships and behavior are not exploitative, abusive or corrupt in any way. 


Ulula is committed to providing an environment free of harassment of any kind, sexual or otherwise, in which all individuals are treated with respect and dignity. Harassment of any kind will not be tolerated, condoned, or ignored. The right to freedom from harassment extends to all Ulula employees, including full-time, part-time, temporary and contract staff, as well as volunteers, contractors, partners, interns, apprentices.

It is unacceptable for workers or contractors working on Ulula’s behalf to engage in harassing behavior while carrying out official Ulula business in any location or when interacting with clients and others with whom they have professional dealings, such as  potential clients, suppliers, service providers, workers and community members using the Ulula platform. This policy also applies to digital work environments where Ulula work is conducted.

For the purposes of this policy:

“Harassment” means:

  • A course of comments or actions that are known, or ought reasonably to be known, to be unwelcome. It can involve words or actions that are known or should be known to be offensive, embarrassing, humiliating, demeaning, or unwelcome;
  • Engaging in a course of vexatious comment or conduct against an individual that is known or ought reasonably to be known to be unwelcome;
  • Psychological harassment or personal harassment, such as prolonged and repeated verbal abuse, teasing or hostile commentary; and/or
  • Sexual harassment.

“Sexual harassment” means:

  • Engaging in a course of vexatious comment or conduct against an individual because of sex, sexual orientation, gender identity or gender expression, where the course of comment or conduct is know or ought reasonably to be known to be unwelcome; and/or
  • Making a sexual solicitation or advance where the person making the solicitation or advance is in a position to confer, grant or deny a benefit or advancement to the worker and the person knows or ought reasonably to know that the solicitation or advance is unwelcome.

Differences of opinion or minor disagreements will not generally be considered to be harassment.

Anyone who believes that they are the victim of harassment should immediately report the incident to management, by emailing [email protected]. A report of harassment must include firsthand details about the alleged incident(s), including the date(s), time(s) and location(s), what happened, who was involved and the names of any witnesses.

Anyone who has good reason to believe that harassment is occurring or has occurred must immediately report the matter to Ulula management in the above manner. If an emergency exists and the situation is one of immediate danger, then it should be immediately reported to the police by dialing “9-1-1” as soon as it is safe to do so. A person in a situation of immediate danger must, at the same time, take whatever steps are necessary to ensure their own safety and to protect themselves against harm or injury. Once the individual or witness is safe, he or she can then report the matter to Ulula Management.

All Ulula Managers and supervisors have the additional duty to act immediately on observations or allegations of harassment. Managers and supervisors are responsible for addressing potential problems immediately and before they become serious.

All reports and incidents of harassment will be taken seriously and will be investigated promptly and thoroughly in accordance with the proper investigation procedures established at Ulula. Potentially dangerous situations and precautionary measures will be communicated to individuals who could be affected. Furthermore, the applicable investigation protocol may be altered if it is determined that it is necessary to do so, such as where there is a reasonable and imminent threat to an individual’s safety. Any incident involving harassment will be reported to the police if the Management deems it to be serious enough to require police intervention. 

Where an individual is considered to be at risk of harassment, a plan will be developed to minimize the risk and respond to any potential emergency situation. Should Ulula Management become aware of an actual or potential incident of harassment, every reasonable precaution will be taken in the circumstances to protect the affected individual. 

If Ulula Management determines that an employee or other affiliated individual has engaged in harassment, then appropriate corrective or disciplinary action will be taken, up to and including immediate dismissal for cause. In addition, an employee may be required to participate in an anger management program or other form of counseling, either voluntarily or as a condition of continued employment. 

If the harassing behavior is that of a non-employee, the Business will take appropriate action in an effort to ensure that such behavior is not repeated, and if necessary, take measures to prevent the person from returning to the workplace, up to termination of the business relationship.

Following the conclusion of an investigation, Ulula Management will, if necessary, conduct a review of the workplace conditions and reassess the risk of harassment, having regard for the circumstances that gave rise to the incident(s) in question. Where risks are identified, any corrective measures that are required to reduce or eliminate the identified risks will be implemented. The results of any assessment will be reported to the health and safety representative or joint health and safety committee, as the case may be (if applicable). 

Duty to Report

It is the responsibility of all Ulula employees, to promptly report suspected violations  of this Code of Conduct, workplace policies, and all applicable laws and regulations, to [email protected]. Examples of potential violations include but are not limited to:

  • Workplace violence, discrimination and sexual harassment
  • Confidentiality and privacy breaches
  • Fraud
  • Theft or destruction of property
  • Unethical business practices or operations in general
  • Relationships that create a conflict of interest
  • Questionable financial practices
  • Concealment of any of the above

In addition to specific reporting procedures, Ulula embraces an open-door policy and encourages employees, contractors, clients and users of its products to share questions, concerns, suggestions or complaints with the HR & Operations team or directly with any member of Ulula’s Leadership team. 

No Retaliation

It is contrary to the values of Ulula for anyone to retaliate against anyone  who in good faith reports suspected violation of this Code of Conduct. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment. Where an individual who retaliates against a good faith reporter is not an employee of Ulula, the Leadership may determine that such an individual suffers a termination of the business relationship.