Diversity & Inclusion

500 Startups (the “Company”) is committed to fostering, cultivating and preserving a culture of diversity and inclusion.  This is a core value at 500.

We value our people! The collective sum of the individual differences, life experiences, knowledge, inventiveness, innovation, self-expression, unique capabilities and talent that our employees invest in their work represents a significant part of not only our culture, but our reputation and company’s achievement as well.

We embrace our employees’ differences in age, color, disability, ethnicity, family or marital status, gender identity or expression, language, national origin, physical and mental ability, political affiliation, race, religion, sexual orientation, socio-economic status, veteran status, and other characteristics that make our employees unique.

500’s diversity initiatives are applicable—but not limited—to our practices on investment decisions; recruitment and selection; compensation and benefits; professional development and training; promotions; and the ongoing development of a work environment built on the premise of gender and diversity equity.

All staff of 500 have a responsibility to treat others with dignity and respect at all times. All employees are expected to conduct themselves in a respectful and appropriate manner at all times during work, at work functions on or off the worksite, and at all other company-sponsored and participative events.

Any employee who engages in any inappropriate conduct or behavior against other employees or applicants or any persons outside of the Company such as portfolio company personnel, entrepreneurs, contractors, other outside investors, vendors, clients or volunteers (collectively referred to as “Third Parties”), will be subject to disciplinary action, up to and including immediate termination of employment.

Employees who believe they have been subjected to any kind of discrimination, harassment or retaliation or any other conduct that conflicts with the Company’s diversity, anti-harassment, anti-discrimination or any other policy should immediately report the matter to a manager or an HR representative.

Note: Where the following policies refer to “employees”, the Company means all employees and other personnel of the Company, to include those persons who serve as members, managers, officers or employees or contractors of the Company and the direct and indirect individual constituent partners, members, officers, contractors and directors of not only the Company but also each entity Affiliated with the Company  that serves as the general partner or management company (or in a similar capacity) to any of the Company’s family of investment Funds, regardless of whether such person is technically an employee of the Company or such entity for the purposes of federal, state or local law.

 

Equal Employment Opportunity and Anti-harassment

It is the policy of the Company to base all employment-related decisions on principles of equal employment opportunity.  In particular, it is the policy of the Company:

  •   to recruit, hire, promote, reassign, compensate, train and otherwise employ highly qualified persons without regard to race, color, religion (including religious dress practices and religious grooming practices), national origin, sex, gender, gender identity and/or expression, genetic predisposition or carrier status, ancestry, age, physical or mental disability, medical condition (including pregnancy, childbirth, breastfeeding and related medical conditions), marital, parental, registered domestic partnership or military or veteran status, sexual orientation, citizenship status, victim of domestic violence status, or any other basis prohibited by applicable laws;
  •   to provide reasonable accommodations where necessary and feasible for, and otherwise treat equally, qualified individuals with disabilities; and
  •   to provide a workplace free of prohibited harassment, including, but not limited to, sexual harassment.

The Company is committed to complying with all applicable laws providing equal employment opportunities.  This commitment applies to all persons involved in the operation of the Company and prohibits unlawful discrimination, harassment or retaliation by any employee of the Company, including managers, co-workers and any partner of the Company.

Reasonable Accommodation

If you have a disability for which a reasonable accommodation would enable you to better perform the essential functions of your job, you are expected to discuss the accommodation with your immediate manager and/or the Human Resources Manager.  The Company will work with you to determine whether it can provide a reasonable accommodation without undue hardship to the Company.  Any information you provide regarding your disability will be kept confidential, except that:

  •   your manager and other appropriate personnel may be informed of any restrictions on your work or duties and the necessary, reasonable accommodation(s) needed;
  •   first aid, fire and life safety personnel may be informed when and to the extent appropriate; and
  •   government officials investigating compliance with applicable laws and regulations may be informed to the extent required for the Company to comply with its obligations.

The Company’s policy on providing reasonable accommodations includes reasonably accommodating those employees whose needs are related to pregnancy, childbirth or a related medical condition. Employees who desire an accommodation related to their pregnancy, childbirth or a related medical condition are expected to follow the same process as employees who have requested an accommodation related to a disability, as discussed above.

Prohibited Harassment

The Company maintains a strict policy prohibiting sexual harassment and harassment because of race, color, religion (including religious dress practices and religious grooming practices), national origin, sex, gender, gender identity and/or expression, genetic predisposition or carrier status, ancestry, age, physical or mental disability, medical condition (including pregnancy, childbirth, breastfeeding and related medical conditions), marital, parental, registered domestic partnership or military or veteran status, sexual orientation, citizenship status, victim of domestic violence status, participation in discrimination complaint-related activities or any other basis prohibited by applicable laws.  All such harassment is prohibited.  Anyone who violates this policy will be subject to disciplinary action, up to and including immediate termination of employment or other prompt remedial measures, including termination of any business relationship between the offending Third Party and the Company.

The Company’s harassment policy applies to not only to employees and applicants, but to all persons involved in the operations of the Company and prohibits (i) harassment by Company personnel of not only other Company personnel, but also of Third Parties and (ii) harassment of employees and applicants by interns and Third Parties.  While the Company may not have direct control over Third Parties, the Company is committed to a policy of influencing Third Parties to act consistently with the Company’s anti-harassment policy, both as applied to prohibit harassment of Company personnel but also harassment of Third Parties.  If harassment occurs on the job by someone not employed by the Company, the procedures in the policy should be followed as if the harasser were an employee of the Company.

Harassment Defined

Harassing conduct may be verbal (including oral, electronic or written communications), physical or visual and includes, but is not limited to, derogatory comments, unwelcome and/or inappropriate jokes, posters, objects, inappropriate language, written communication including email messages, gestures, physical conduct, assault, battery and/or unwelcome sexual or romantic advances that create a hostile or offensive working environment.

Sexual Harassment

Applicable state and federal law defines sexual harassment as unwanted sexual advances, requests for sexual favors, or visual, verbal or physical conduct of a sexual nature when:  (1) submission to the conduct is made a term or condition of employment; or (2) submission to or rejection of the conduct is used as a basis for employment decisions affecting the individual; or (3) the conduct has the purpose or effect of unreasonably interfering with the employee’s work performance or creating an intimidating, hostile or offensive working environment.  This definition includes many forms of offensive behavior.  The following is a non-exhaustive list of the types of behaviors that are prohibited under this policy:

  •   Unwanted or inappropriate sexual or romantic advances;
  •   Offering employment benefits in exchange for sexual favors;
  •   Making or threatening reprisals after a negative response to sexual advances;
  •   Visual conduct such as leering, staring, making sexual or inappropriate gestures, or displaying sexually suggestive objects, pictures, cartoons or posters;
  •   Verbal conduct such as making or using suggestive or derogatory comments, epithets, slurs, sexually explicit jokes, whistling or comments about any employee’s body or dress;
  •   Verbal sexual or romantic advances or propositions;
  •   Inquiries into one’s sexual experiences or discussion of one’s sexual activities;
  •   Verbal abuse of a sexual nature, graphic verbal commentary about an individual’s body, sexually degrading words to describe an individual, or suggestive or obscene letters, notes or invitations;
  •   Verbal or written references to sexual conduct, gossip regarding one’s sex life, or comments about one’s sexual activities, deficiencies, or prowess;
  •   Physical conduct such as touching, brushing up against one’s body, rubbing, assault, or impeding or blocking movements; and
  •   Retaliation for reporting harassment or threatening to report harassment.

It is unlawful for males to sexually harass females, other males, transgender individuals or gender neutral individuals, and for females to sexually harass males, other females, transgender individuals or gender neutral individuals.  It is also unlawful for a transgender individual or gender neutral individual to harass anyone of the same or other sex.  Sexual harassment is unlawful whether it involves co-worker harassment or harassment by a manager, partner or persons doing business with or for the Company.

Other Types of Harassment

Other types of prohibited harassment include harassment on the basis of race, color, religion (including religious dress practices and religious grooming practices), national origin, sex, gender, gender identity and/or expression, genetic predisposition or carrier status, ancestry, age, physical or mental disability, medical condition (including pregnancy, childbirth, breastfeeding and related medical conditions), marital, parental, registered domestic partnership or military or veteran status, sexual orientation, citizenship status, victim of domestic violence status, participation in discrimination complaint-related activities or any other basis prohibited by applicable laws.  Such harassment includes behavior similar to those described above under sexual harassment, such as:

  •   Verbal conduct such as threats, epithets, derogatory comments or slurs;
  •   Visual conduct such as derogatory posters, photographs, cartoons, drawings or gestures;
  •   Physical conduct such as assault, unwanted touching or blocking normal movement; and
  •   Retaliation for reporting harassment or threatening to report harassment.

Reporting Harassment, Discrimination or Retaliation

If you believe you or anyone else at the Company or at a Third Party has been subjected to any form of prohibited harassment, discrimination, or retaliation, you should immediately report the matter to your manager, the Human Resources Manager, or any other management personnel or partner with whom you feel comfortable discussing the matter.  Your complaint should be as thorough as possible and include the names of any potential witnesses.  Supervisors and managers must report all complaints of prohibited harassment, discrimination, or retaliation, including of any employee, applicant or Third Party, to either the Human Resources Manager or any Company partner.

You may also report a matter through the 500 Startups ethics hotline:
www.500startups.ethicspoint.com

Reports through this hotline will be directed to the appropriate responder within the company.

It is unlawful to retaliate against an employee for filing a complaint of discrimination or harassment or for cooperating with an investigation of discrimination or harassment.  Retaliation against an employee, applicant or Third Party for making a complaint of discrimination or harassment, for cooperating with an investigation of discrimination or harassment, or for supporting another employee, applicant or Third Party in making a complaint of discrimination or harassment is also a violation of this policy.  The Company will not retaliate against you for filing a complaint, supporting another in filing a complaint or participating in an investigation and will not knowingly permit retaliation by management employees, partners, or your co-workers.

The Company will conduct a fair, timely and thorough investigation of the complaint and reach a conclusion based on the information gathered during the investigation. During the investigation, the claim will be documented and tracked for reasonable progress.  If the Company determines that prohibited harassment, discrimination, retaliation or other conduct in violation of Company policy has occurred, appropriate action will be taken to resolve the matter.  The Company will strive to keep such investigations confidential provided doing so will not compromise the Company’s ability to conduct a thorough and fair investigation.  Participants in investigations of this nature may be required to keep the investigation confidential to the extent such confidentiality is in accordance with applicable laws when the Company concludes that confidentiality is necessary to maintain the integrity of the investigation (for example, where confidentiality is necessary to prevent a cover-up, collusion, fabrication of information, copycat testimony or evidence, retaliation against the accused, accuser, or witness, damage to the reputation of any employee, witness, accused, accuser, or the Company, destruction or manipulation of evidence, or theft or misappropriation of trade secrets, confidential information, or privileged information, or where there is a potential for future criminal charges arising out of the matters under investigation).  Failure to do so may result in disciplinary action.  Appropriate action will also be taken to deter any future harassment, discrimination or retaliation.

Any person who is found to have engaged in prohibited harassment, discrimination, retaliation or other conduct that violates any Company policy is subject to disciplinary action, up to and including immediate termination of employment or other prompt remedial measures, including termination of any business relationship between the offending party and the Company.  Any employee who engages in prohibited harassment may be held personally liable for monetary damages.  The Company does not consider conduct in violation of this policy to be within the course and scope of employment or the direct consequence of the performance of one’s duties.  Accordingly, to the extent permitted by law, the Company reserves the right not to provide a defense or pay damages assessed against employees for conduct in violation of this policy.

The responsibility to investigate complaints of discrimination, harassment and retaliation has been assigned to Monica Matison, the Human Resources Director.  The Human Resources Director can be reached at (650) 743-5758, monica@500startups.com, or at the following address:  444 Castro Street, 12th Fl, Mountain View, CA 94041.  Any employee who believes that he or she has been subject to harassment, discrimination or retaliation should report the alleged act to the Human Resources as soon as possible.  Supervisors and managers must report all complaints of prohibited harassment, discrimination, or retaliation to either the Human Resources Manager or any Company partner. State and federal agencies also address unlawful harassment, discrimination and retaliation.  If an employee, applicant or Third Party believes that he or she has been subjected to harassment, discrimination or retaliation, he or she may file a formal complaint with the appropriate government agencies (to the extent Third Parties can bring such claims before these agencies).  If, after an investigation and hearing, any of these agencies finds that unlawful discrimination has occurred, depending on the circumstances, you may be entitled to reinstatement or promotion, with or without back pay, and/or a cease and desist order.

You may also report a matter through the 500 Startups ethics hotline:
www.500startups.ethicspoint.com

Reports through this hotline will be directed to the appropriate responder within the company.

The Equal Employment Opportunity Commission (“EEOC”) is the federal agency that investigates discrimination and harassment claims, including claims of sexual harassment.  The addresses and telephone numbers for the EEOC’s local branches that are closest to the Company’s offices is provided below.  The contact information for the comparable state agencies is also provided below.

California

Equal Employment Opportunity Commission
350 The Embarcadero
Suite 500
San Francisco, CA

The California state agency responsible for complaints of discrimination and harassment, including sexual harassment, is the California Department of Fair Employment and Housing.  This agency can be contacted by calling 1-800-884-1684 or by visiting its website at www.dfeh.ca.gov.

 

Bullying

Bullying consists of repeated unnecessary and rude behavior towards a co-worker, applicant or Third Party that is intended to be offensive and cause emotional distress, whether verbal, physical or otherwise, conducted by one or more persons against one or more co-workers, applicants or Third Parties, at the place of work and/or in the course of employment.  It is Company policy that all employees, applicants and Third Parties will be treated with dignity and respect by their co-workers and the Company.  Bullying violates that policy.

The Company considers the following types of behavior examples of bullying:

  •    Verbal conduct such as screaming or yelling, inappropriate threats, epithets, or slurs;
  •    Visual conduct such as insulting posters, photography, cartoons, drawings or gestures directed towards an individual; and
  •    Physical conduct such as assault, unwanted touching or blocking normal movement.

Retaliation for reporting bullying, supporting another employee, applicant or Third Party in reporting bullying, threatening to report bullying or participating in an investigation into an incident of bullying is a violation of this policy.

An individual subjected to what he/she believes is bullying or retaliation for reporting bullying, supporting another employee, applicant or Third Party in reporting bullying, threatening to report bullying or participating in an investigation into an incident of bullying should immediately report that behavior, preferably in writing, to Human Resources or any Company executive.  If any further incident(s) of bullying or retaliation occur, the incident(s) must be immediately reported.