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Code of Business Conduct and Ethics

Kajola Ventures Holding BV (Kajola International Hospitality Consultants). is dedicated to conducting its business consistent with the highest standards of business ethics. We have an obligation to our employees, shareholders, customers, suppliers, community representatives and other business contacts to be honest, fair and forthright in all of our business activities. The guidelines set out in this Code of Business Conduct and Ethics (the “Code”) are to be followed at all levels of this organization by our directors, officers and employees. We rely on them to uphold our core values and conduct our business honestly, fairly and with integrity.

CODE OF BUSINESS CONDUCT AND ETHICS

(Adopted as of March, 2020)

Preamble

Kajola International Hospitality Consultants is driven by its mission, vision and values.

Our Mission:

Kajola International Hospitality Consultants is dedicated to creating solutions for international hospitality, food and beverage start-ups, scale-ups and corporate industry.

Our Vision:

At Kajola International Hospitality Consultants we believe in people and aim to nurture innovation, develop talent and devise key strategies for success. We do this by incorporating a few of our methodologies – Understand – Shape – Deliver along with the K.C.S.S. (First comes knowledge, knowledge brings confidence, confidence builds skill, once you have the skill you then begin to do things with speed). This vision goes hand in hand with our style of work. We promote teamwork, participatory decision-making processes, purpose-driven leadership and trust in our client relationship management, among others.

Our Values:

We’re devoted to making the hospitality, food and beverage scenes richer, more diverse and more rewarding for food and beverage lovers and experience seekers everywhere. Being a black-owned company with diversity and inclusiveness is our default setting whilst building an international outlook that allows us to always live in the now with an eye on tomorrow and beyond. collaboration, honesty, integrity, inclusion, diversity, innovation, responsibility, accountability and transparency.

Purpose

The Kajola Code of Business Conduct & Ethics serves four main purposes:

  1. The Code sets forth the ethical commitments of Kajola team & community members – partners, consultants, employees, visiting professionals and interns.
  2. The Code clarifies the nature of ethical commitments that Kajola team & community members hold. It also sets standards for the professional practice of social consultancy at Kajola International Hospitality Consultants.
  3. The Code serves as an ethical guide to our behaviours and decision-making process and establishes guidelines of conduct.
  4. Its principles and standards serve as the basis for eventual inquiries and ethical debates and/or dilemmas and reflections concerning our team & community members’ professional practice.

The Kajola Code of Business Conduct & Ethics contains six main sections that address the following areas:

  1. Consultancy Business
  2. Consultancy Relationship
  3. Confidentiality
  4. Corporate Responsibility
  5. Professional Responsibility
  6. Resolving Ethical Issues

The nature of Kajola’s work – a broad range of areas of expertise and work carried out in collaboration with a wide array of company’s around the globe – means we may be faced with ethical dilemmas that can be complex to resolve.

The professional actions held by Kajola team members must be consistent with both the spirit and terms of this Code of Business Conduct & Ethics. The Kajola Code of Business Conduct & Ethics provides a framework for developing an ethical and values-based professional practice and should be the first guide to deal with arising situations.

At Kajola we know that resolving ethical issues is a process. Our team members are expected to engage in a carefully considered ethical decision-making process and evaluate the context of each situation. They are also expected to work in collaboration with people, organisations and communities and make decisions that strengthen and empower them.

Kajola holds the responsibility to introduce the Code of Business Conduct & Ethics to new Kajola team members and to communicate it openly. Kajola team & community members have a responsibility to read, understand, sign, and follow the Kajola Code of Business Conduct & Ethics and adhere to applicable laws and regulations. A breach of the standards and principles provided herein does not necessarily constitute legal liability or violation of the law; such action is established in legal and judicial proceedings.

Kajola Code of Business Conduct & Ethics

Consultancy Business

Kajola is a hospitality-driven international consultancy business. We work with several types of organisations that want to boost their hospitality value, while empowering a team & community of professionals eager to achieve it. We seek to cooperate and collaborate with others to secure the best possible solutions that address our client needs. Our team seeks opportunities to collaborate with other organisations from all sectors on issues of common concern to contribute to a responsible and sustainable business transformation, realisation and implementation. A social purpose has been integrated into Kajola’s core business since its foundation. This social purpose drives us to constantly innovate and maximize our impact on people, communities and the environment. We promote ethics, best practices and collective intelligence to accelerate our clients transformation towards contributing towards a better world.

Focus on social and environmental impact

We regard our social, cultural, economic and environmental impact as a primary measure of success for our business and prioritize it at the same level as the economic viability of the company. Kajola monitors and evaluates its on-going social and environmental performance and solicits specific feedback from its internal and external stakeholders. We prioritize our effort to understand our own impact and use our learnings to improve our work. Kajola works in consultancy projects with a clear social purpose and does not favour or engage in activities that are or could be considered “brandwashing”.

Honesty reporting

At Kajola, we are honest about our impact: the positive, the lack of it and the impact that we did not intent to generate. To do so, we seek to increase accountability and transparency at all levels of the company. From 2021 we will publicly share information on our social and environmental performance by publishing our periodical Honesty Report, which also includes financials that are reviewed by an independent auditor.

Healthy and fair competition

We aim to develop both an ethical climate and fair deal with clients, consultants, employees, visiting professionals, interns, trainees, competitors, suppliers, public institutions, media and the general public, while fostering a robust business environment. Kajola’s team & community members respect the work and dignity of other professionals and will not submit service proposals to potential clients that may be seeking to secure pre-approved services through unethical public tendering. Our members proactively communicate the company’s ethical standards on fair competition to its stakeholders. Kajola International Hospitality Consultants purpose to contribute to the fulfilment of its social impact is compatible with a transparent, open and complementary role with competitors striving to achieve the same social transformation goal.

Recruitment

We follow ethical recruiting practices designed to respect diversity and equal opportunity, without any type of unjustifiable discrimination. Kajola is a non-exclusive company and thus we guarantee free and open competition for the best talent and we encourage professionals to work freely in the market, even with a competitor, by jointly addressing potential conflicts of interest.

Fees and payment practices

We apply consultancy fees and payment schemes to service providers, clients and that are respectful of their local legislation, contexts, needs and conditions of dignity.

Fiscal responsibility

Kajola does not engage in the practice of reducing or minimizing taxes through illegitimate finance practices (e.g. invoices related to false expenses) or the use of corporate shells.

Corruption

Kajola commits to the fight against corruption and proactively communicates the company’s ethical standards. Kajola does not offer, promise to offer or collaborate in payment schemes to providers, clients or any other third party that uses its authority and status in unethical ways to promote the company’s interests.

Consultancy Relationship

A firm believer in the richness of collective processes, Kajola International Hospitality Consultants builds and nurtures consultancy relationships where our clients take an active role. Acting in partnership rather than in a purely advisory role, we apply shared processes to strategy creation and implementation in order to build individual and institutional capacities and to ensure ownership by the client. Kajola team members not only offer their knowledge as experts but also build capacity and facilitate the generation of new knowledge. We do this through an action-learning approach. We also develop customised solutions, innovative methodologies with an emphasis on creating tools and practices that organisations can apply in the future. Our team members actively attempt to understand the diverse contexts, cultural backgrounds, circumstances and interests of the clients, organisations and other professionals they work with. We respect diversity, local cultures, traditions and economic differences.

Conflicts of interest

Kajola team members are loyal to Kajola’s mission and respectful of the agreements and relationship of trust that the company has built with other organizations. All members of the Kajola Team act with transparency when participating in activities related to the company. In cases where there is a potential conflict of interest, before proceeding further, the concerned party submits needed information about the situation to consultation by the Kajola Ethics Commission, composed of partners and consultants equally represented, and complemented by a council of external independent experts.

Consultancy data and documentation

Kajola creates, safeguards, and maintains necessary documentation for rendering professional services, such as proposals or contracts. Our team members take reasonable steps to ensure that the documentation accurately reflects the services we provide. In addition, they also update the documents with any changes or amendments. All sensitive and confidential information is maintained as such, in fulfilment of international and national law. The European Union General Data Protection Regulation on data protection and privacy is applied by Kajola regardless of where its activities are developed or where data is collected or processed.

Consultancy plans

Kajola works together with its clients in devising consultancy plans that are consistent with their needs, expectations, context and circumstances. We do not impose a particular plan or methodology because it is more convenient to Kajola. Kajola and clients regularly review consultancy plans to assess their continued viability and effectiveness, respecting the clients’ interests, preferences and priorities.

Consultancy and advocacy

When appropriate, our team members can engage in advocacy efforts on behalf of an identifiable client or project to enhance social impact. They can also work towards the removal of systemic barriers or obstacles that inhibit the client’s growth and the capacity to develop the agreed solutions. Prior to engaging in advocacy work requested by a client, Kajola obtains the client’s consent and clients are included in every step of the process.

Receiving gifts

We understand the challenges of accepting gifts and recognize that small gifts may be a token of respect and gratitude. When determining whether to accept a gift from a third party, we consider the monetary value of the gift and whether it puts us in debt to someone. We ensure that gifts are nominal, legal, and exceptional. No luxury or high value gifts are accepted, and all monetary gifts are prohibited. Confidentiality

Kajola team members aspire to earn the trust of other members and of third parties, namely clients, by creating an ongoing partnership, establishing and upholding appropriate boundaries, and maintaining confidentiality. Our team members have the responsibility to respect and protect the confidentiality and privacy rights of other team members, clients and suppliers by safeguarding confidential information. Information sharing and confidentiality Kajola strongly supports knowledge and expertise sharing among its team members in order to learn and promote best practices. However, when necessary we understand the need to protect privileged, confidential, and internal information gained from a client or organisation. In these cases, we make every effort to ensure that the confidentiality of other members and clients is maintained by all the team, service providers and corporate partners. Inter organisational project teams When the services provided to the client involve the cooperation between Kajola and another organisation, the client will be informed of the team’s composition, the shared information and the purposes of such cooperation. Kajola’s consultancy project partner will ensure respect for the client’s confidentiality rights. Permission to observe and record We obtain written permission from the client or any other person and /or organisation prior to allowing any person to observe activities or work sessions, recording sound and images at meetings or work sessions through electronic or alternative means. We jointly agree with relevant parties on the use and dissemination of any data or recordings and deliver relevant or agreed documents. Disclosure or transfer Unless any exceptions to confidentiality exist, we obtain written permission from clients to disclose or transfer documents to third parties. Storage and disposal after termination Kajola maintains the necessary documentation for developing its activity and rendering professional services. We ensure that either files on paper or their electronic versions are kept in a secure place and that access is granted only to authorised people. We store documentation following termination of services to ensure reasonable future access. We archive the client’s documents and any sensitive material in a manner that protects the client’s confidentiality.Corporate Responsibility

Kajola International Hospitality Consultants is committed to meeting its social, environmental, economic, cultural, legal and ethical corporate responsibilities. Our social commitment drives us to place our human capital – Kajola team members – at the centre of our social responsibility, through the collaborative development of inclusive, fair and transparent management practices, namely in the recruitment and selection of community and project team members, the social distribution of participation in contracts, the participation in performance assessment processes and in strategic thinking and definition. We seek to apply practices and give preference to suppliers whose practices go beyond what is required by regulations – excellent working conditions, inclusive value chains, respect for international human rights conventions and covenants, respect for the environment and engagement with its stakeholders.

As a socially leaning business, all our dividends have, since our foundation, been reinvested in our mission. We have not re-distributed them amongst shareholders and our social pact foresees a maximum 5% distribution in the future. Kajola International Hospitality Consultants also contributes actively to community services and pro bono initiatives in every country where its partners and consultants or employees are located.

We aspire to maintain open relationships based on an honest communication with all of our stakeholders, colleagues, professionals and other consultancy firms. We set, manage and monitor concrete objectives and targets to improve our performance and responsibilities and stewardship, and we communicate our practices and impact openly through the media and several communication and network platforms.

Advertising and soliciting clients

When advertising or representing the company’s services to the public, Kajola team members identify the company’s credentials in an accurate way that is not false, misleading, deceptive, or fraudulent.

Services and training advertisements

We develop services and products, conduct workshops, trainings and events and ensure that the advertisements concerning these services are accurate and complete.

Public responsibility

Reports to third parties: our team members are accurate, honest, and objective in reporting their activities and views to appropriate third parties. These include current and prospective clients, other consultancy firms, funding agencies or those who are the recipients of evaluation reports. Media presentations: Whenever representing Kajola, our team members provide advice or comment by means of public presentations, articles, recordings, technologybased applications, mailed material, radio or television programmes. They take reasonable precautions to ensure that their statements are based on appropriate literature, practice and/or evidence and are consistent with this Code of Business Conduct & Ethics.Non-discrimination and exploitation

We do not engage in discrimination against prospective or current clients, students, employees, visiting professionals, interns, trainees or consultancy project participants based on age, culture, disability, ethnicity, race, religion/spirituality, sex, gender identity, sexual orientation, marital/ partnership status, language preference, socioeconomic status, immigration status, any other specific diversity characteristics or any basis proscribed by law. We do not cooperate or enter in any form of exploitation in business practices and consultancy relationships.Professional Responsibility

Kajola team members have the responsibility to engage in consultancy practices that are based on rigorous methodologies and apply ethical standards. Kajola team members behave in an ethical and legal manner and are aware that our client’s welfare and trust depends on a high level of professional conduct. Kajola team members abide by the Kajola Code of Business Conduct & Ethics.

Professional Competence

Our team members continuously acquire specialised knowledge and experience and use it responsibly. They monitor their performance and strive for personal and professional development to improve their effectiveness and ability to generate social value. They recognise the need for continued professional development, research, and education to acquire and maintain the required level of technical and professional information in their fields of activity. They also remain informed regarding best practices and work methodologies and do not misrepresent or oversell their capabilities.

Consultations on ethical obligations

We take reasonable steps to consult with other members of the community or related professionals when we have questions regarding our ethical standards and principles or professional practice. Recruiting through independent consultancy Kajola community members do not use their collaboration with Kajola to recruit clients for their own independent work, consultancy firm or competitors with whom they collaborate. If a work opportunity with a Kajola current or former client arises, community members should notify Kajola’s partners immediately and inform the client of their collaboration with Kajola (or of his/her changed situation if the community member is not part of Kajola anymore) before accepting to discuss the work.

Promoting to those advised

Kajola community members do not use consultancy or training activities to promote other services or training events in a manner that is deceptive or that disregards the client’s needs and circumstances.

Professional qualifications

Kajola community members truthfully represent their professional qualifications. In the same way, our members clearly distinguish between paid and volunteer work experience and accurately describe their continuing education and specialised training. Kajola community members state clearly their educational degrees, using the correct terminology.

Independence

Kajola is committed to promoting political freedom and autonomy as well as respect and appreciation for the religions, beliefs and customs of its diverse team members and the people with whom they interact. Kajola respects its team members’ beliefs and preferences, while not adhering to any religious confession and being independent from all political parties. Kajola team members apply objective and specialised knowledge and experience to meet the client’s expectations and seek to minimize influence any personal beliefs have on their work. Resolving Ethical Issues

Kajola team members strive to resolve their ethical dilemmas through a direct and open communication among all the involved parties and can seek consultation with other community members when necessary. We also hold our team members to high ethical standards and are willing to take appropriate action to ensure they remain upheld.

Standards and the Law

In order to ensure the application of this Code, our team members must know, understand and become familiar with it, as well as with other applicable ethical standards from certifications and organisations of which they and Kajola are members. Lack of knowledge or misunderstanding of an ethical commitment is not an acceptable argument to defend a behaviour that is not in line with these ethical principles and standards. Our team members make their commitment to the Kajola Code of Business Conduct & Ethics. In case of conflict with national and international law that set less strict standards than the ones set by Kajola, this Code of Business Conduct & Ethics shall prevail.

Ethical decision making

When facing an ethical dilemma, Kajola team members follow a multistep process, including: identification and communication to the Kajola Ethics Commission; joint analyses and consideration of relevant ethical standards, principles, and laws; generation of potential courses of action; deliberation of risks and benefits; and selection of an objective decision based on the circumstances and welfare of all those involved. The Kajola Ethics Commission oversees internal management of eventualities and supervises the enforcement of the Code. In addition, other team members can also collaborate in enforcing and updating it.

Suspected violations

If we have reason to suspect that a Kajola team member is violating or has violated an ethical standard, we attempt to first clarify and try to resolve the issue informally – provided that such action does not violate any confidentiality rights or laws.

If a violation of our ethical standards is proved and cannot be resolved informally, our team members will take further action depending on the situation and will always respect our clients’ confidentiality rights.

If any of our members is affiliated to or collaborates with an organisation that poses a conflict with this Code of Business Conduct & Ethics, he/she will be required to specify the nature of such conflict, express his/her commitment to the Kajola Code of Business Conduct & Ethics, and address the situation through the appropriate channels.

If Kajola is working with a client or project that applies ethical standards that conflict with the Kajola Code of Business Conduct & Ethics, Kajola will actively promote a joint assessment and the adoption of the corrections deemed necessary but may terminate the relationship if the conflict persists.

If a third party identifies a situation where Kajola violated the Code of Business Conduct & Ethics, Kajola will carry out the necessary investigation, require independent auditing and collaborate with all parties to resolve the suspected violation.The Kajola Code of Business Conduct & Ethics Pledge

By signing this Code of Business Conduct & Ethics, I hereby certify that:

I am aware of and have read the Kajola Code of Business Conduct & Ethics.

I understand the conduct guidelines, obligations and prohibitions set forth therein.

I commit to conduct myself in accordance with Kajola values and comply with the Kajola Code of Business Conduct & Ethics provisions thereof.

I collaborate with the Kajola group of partners in applying the Code of Business Conduct & Ethics.

I am aware that Kajola has a procedure in place for reporting non-compliance and that it is my obligation to report through this procedure any instances of non-compliance that come to my attention.

I understand and accept that there is a consequence for misconduct, up to and including revocation of my employment, collaboration or partnership with Kajola.

And, I understand that those who have been or are sanctioned by a government agency or convicted in a court of law of an action that violates the Kajola Code of Business Conduct & Ethics may be barred from employment or expelled from the Kajola community.

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