Code of Conduct

PANDO CLUB'S CODE OF CONDUCT

Updated: August 1, 2025

√ Disclaimer. The rules and policies included in Pando Club’s Code of Conduct are not intended to be contractual, nor should they be interpreted as strict rules for how Pando Club responds to individual activity. The appropriate response to each unique situation may differ. Some circumstances may call for immediate action while others may take some time for Pando Club to work through. The rules are subject to change at any time as business conditions and other factors may require. Pando Club reserves the right to modify, rescind, delete, or add to the policies in its sole and absolute discretion consistent with applicable law.

INTRODUCTION

This Code of Conduct (Code) is designed to provide those participating with Pando Club an easy-to-follow guide to the expectations of Pando Club. This Code is not intended to answer every question or address every situation that may arise, but it covers some of the most important ones, including where to go when you have questions or wish to report a concern. Please take time to read and understand this Code, and when you have questions then ask. All participants are responsible for knowing and adhering to the values and standards set forth in this Code and for raising questions if there’s uncertainty.

PURPOSE

Pando Club relies on everyone participating with Pando Club, including Members, to adhere to the rules set forth in the Code. The business practices and actions of each participant may significantly impact the reputation and brand of Pando Club. Pando Club expects that each participant act in a manner consistent with this Code and all applicable local, city, state, federal and international laws, rules, and regulations (applicable laws). This means that each participant agrees to behave in a respectful and civil manner when interacting with each other or with other third parties. Each participant is expected to educate their employees, agents, and subcontractors to adhere to this Code while attending events at Pando Club. This Code, effective as of August 1, 2025, supersedes all policies and codes of conduct previously issued by Pando Club.

Pando Club reserves the right to modify, rescind, delete, or add to the provisions of this Code from time to time in its sole and absolute discretion consistent with applicable law. Nothing in this Code nor any other communication by anyone other than an “Officer” of Pando Club, whether oral or written, is intended to in any way create contractual obligations with participant. If a participant has a written agreement signed by an Officer (Contract), that has any terms that conflict with this Code, then the terms of the Contract will prevail. You acknowledge that this Code incorporates Pando Club’s website terms and conditions found here: https://pandoclub.com/terms-and-conditions/. Pando Club reserves the right to interpret the rules in this Code in its discretion.

ABOUT PANDO CLUB

Pando Club is an innovative shared workspace concept founded between four business and civic leaders. A collaborative space like Pando Club brings decades of experience and support to its members. See https://pandoclub.com/ for more information.

PANDO CLUB ENVIRONMENT

Pando Club expects ALL participants to take all steps necessary to maintain an environment free from unlawful discrimination, harassment, retaliation, and threats of violence (including actual).

We all deserve to spend time in an environment where we are treated with dignity and respect. Pando Club is committed to creating such an environment because it brings out the full potential in each of us, which, in turn, contributes directly to our business success. This commitment is embodied in the way we do business at Pando Club and is an important principle of sound business management. If a participant believes that a violation of rule has occurred, they should report as set forth below under “Reporting a Complaint.”

Non-Discrimination Policy. It is the policy of Pando Club to provide an environment free of discrimination. Pando Club expects each participant to not discriminate based on race, color, religion or creed, gender identity, sex, including pregnancy, sexual orientation, national origin or ancestry, ethnicity, citizenship status, genetic information, military or veteran status, age, and physical or mental disability, or any other classification (characteristic), or to an individual’s disability protected by any applicable laws. Pando Club understands that in certain situations, it may need to make exceptions to certain policies based on a certain characteristic.

Non-Harassment Policy. Pando Club expressly prohibits any form of intentional and unintentional harassment based on a characteristic protected by applicable laws, including but not limited to sexual harassment or hostile environment. Hostile Environment harassment is conduct that has the purpose or effect of creating an intimidating, a hostile, or an offensive environment and includes, but is not limited to, epithets, slurs and derogatory remarks, stereotypes, jokes, pranks, innuendo, comments, written or graphic material, stereotyping, or other threatening, hostile, or intimidating acts based on any characteristic protected by applicable law, not just sexual harassment.

This list is illustrative only, and not exhaustive. No form of harassment will be tolerated. Harassment is prohibited while participating with Pando Club and while attending Pando Club sponsored events.

Sexual Harassment. While all forms of harassment are prohibited, special attention should be paid to sexual harassment. Sexual harassment may include all the above actions, as well as other unwelcome conduct, and is generally defined by applicable law as unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature that may involve individuals of the same or different gender. Other sexually oriented conduct, whether intended or not, that is unwelcome and has the effect of creating a work environment that is hostile, offensive, intimidating or humiliating to an individual may

Non-Violence Policy. Pando Club expects all participants to be courteous and respectful with the treatment of each other and with the treatment of the clients, vendors, and others with whom Pando Club does business with or its Members. All threats of (or actual) violence, both direct and indirect, that may affect a participant while at Pando Club should be reported to Pando Club as soon as possible. If more immediate action is needed, they should call 911.

Pando Club will promptly and thoroughly investigate all reports of threats of (or actual) violence and suspicious individuals or activities. Pando Club will use discretion and take all reasonable steps to protect the confidentiality of the individual making a report. Pando Club is eager to assist in the resolution of disputes before the situation escalates into potential violence.

Reporting a Complaint. If a participant is subjected to any conduct or observes acts of unlawful discrimination, including sexual or other forms of unlawful harassment, or other inappropriate conduct, including retaliation and threats or acts of violence (offending conduct), they are requested and encouraged to promptly make a complaint. Such individuals may complain directly to a Founder of Pando Club with whom they feel comfortable bringing such a compliant (Pando Club Management). Promptly means as soon as possible following the offending conduct.

In response to every complaint, Pando Club will investigate and if Pando Club concludes that improper conduct occurred, Pando Club will take appropriate action that Pando Club deems appropriate. The steps followed to investigate will be at the discretion of Pando Club. Confidentiality will be protected to the extent possible. Due to the nature of such an investigation such confidentiality CANNOT be guaranteed. Pando Club will make every effort to respond timely and communicate its conclusion to the individuals involved.

Solutions Policy. In an organization as dynamic and creative as Pando Club, disagreements between participants will occasionally arise. Pando Club believes that participants can generally resolve their own disputes through open and respectful communication. For individuals directly involved in a disagreement, proceed with the Solution Focused Steps below that is an effective path towards resolution for most disagreements.

√ Disagreements are NOT the same as Offending Conduct.

Solution Focused Steps:

Informal Discussion. An individual who has a concern or a disagreement (concern) should first address the concern with the other individual involved and work reasonably and in good faith to resolve the concern.
Bring to a Third Party. If the informal discussion with directly involved parties does not resolve the concern, then the individual will discuss the concern with a Pando Club Founder or another appropriate individual.
Formal Notification. If the concern continues, then the individual will formally notify, IN WRITING, Pando Club Management by EMAIL (formal notification). Even if the individual has verbally discussed the issue with Pando Club Management, the individual is still required to send an email to comply with the formal notification requirement. The email should:
1. Describe the incident, participants, background, and any attempts the individual has made to solve the problem with the other individual involved. List any relevant dates, times, and places.
2. Describe the resolution or remedy the individual is seeking.
Pando Club Decision. Pando Club will review and may interview individuals involved. Pando Club will take whatever action they deem appropriate.

This procedure should not be construed as preventing, limiting, or delaying Pando Club from taking appropriate action against any individual, up to and including termination of membership or any other participation with Pando Club, in circumstances where Pando Club deems such action appropriate.

STANDARDS OF CONDUCT

Every organization must have certain standards of conduct to guide the behavior of individuals. Although there is no possible way to identify every rule of conduct, the following is an illustrative list. Pando Club does not intend this list to be comprehensive or to limit Pando Club from taking action it deems appropriate.

Pando Club expects participants to support an inclusive community by adhering to the following conduct standards:

Treat others with dignity and respect always.
Address and report inappropriate behavior and comments that are discriminatory, harassing, abusive, offensive, or unwelcome.
Foster teamwork and participation, encouraging the representation of different perspectives.
Seek out insights from individuals with different experiences, perspectives, and backgrounds.
Avoid slang or idioms that might not translate across cultures.
Support flexible arrangements for individuals with different needs, abilities, or obligations.
Confront the decisions or behaviors of others that are based on conscious or unconscious biases.
Be open-minded and listen when given constructive feedback regarding others’ perception of your conduct.

√ Pando Club will not tolerate discrimination, harassment or any behavior or language that is abusive, offensive, or unwelcome.

At Pando Club everyone should feel comfortable to speak their mind, particularly with respect to ethics concerns. Pando Club Management has a responsibility to create an open and supportive environment where individuals feel comfortable raising such questions. We all benefit tremendously when individuals exercise their power to prevent mistakes or wrongdoing by asking the right questions at the right times. Pando Club will investigate all reported instances of questionable or unethical behavior. In every instance where improper behavior is found to have occurred, Pando Club will take appropriate action. Pando Club will not tolerate retaliation against those who raise genuine ethics concerns in good faith.

Professionalism Policy. Participants are expected to always conduct themselves in a professional manner. Pando Club participants are expected to set a high standard of professional conduct at Pando Club events. For this reason, participants are prohibited from social interaction with others that is or might be perceived as inappropriate. Members agree to engage in activity that supports the Pando Club community by refraining from:

Disparaging remarks about Pando Club or its Members;
Using foul language;
Disruptive comments; and
Promoting political ideology.

Ethical Standards Policy. Licensed professionals adhere to recognized ethical standards and rules of professional responsibility. Participants understand the ethical obligations and agree to adhere to the standards, rules, and policies. Participants agree and understand that failure to comply with these standards, rules, and policies jeopardize the community for Pando Club to operate.

CODE OF OPERATIONS

Pando Club requires reasonable measures to reduce liability risk with its operations that cover conflicts of interest, confidential and proprietary information, and use of Pando Club and personal resources.

Accepting Business Courtesies. Most business courtesies offered to Pando Club participants are offered because of the work certain individuals do for Pando Club. No individual should feel any entitlement to accept and keep a business courtesy. Although individuals may not use their position with Pando Club to obtain business courtesies, individuals may accept unsolicited business courtesies that promote successful working relationships and good will with the Members or others that Pando Club maintains or may establish a business relationship with.

Offering Business Courtesies Policy. Any individual who offers a business courtesy must assure that it cannot reasonably be interpreted as an attempt to gain an unfair business advantage or otherwise reflect negatively upon Pando Club. Accounting for business courtesies must be done in accordance with approved company procedures as follows:

The practice does not violate any law or regulation or the standards of conduct of the recipient’s organization.
The business courtesy is consistent with industry practice, is infrequent in nature and is not lavish.
The business courtesy is properly reflected on the books and records of Pando Club or its Members.

Confidential and Proprietary Information Policy. Integral to the business success of Pando Club and its Members is the protection of confidential company information, as well as nonpublic information entrusted to each Member and participants. Confidential and Proprietary Information includes such things as pricing and financial data, client names and addresses or nonpublic information about other companies, including current or potential supplier and vendors, and each Member’s contact information (Confidential Information). Pando Club requires nondisclosure of confidential and nonpublic information without a valid business purpose and proper authorization.

Pando Club Membership Directory. All Members will be included in the Pando Club Membership Directory (Directory). The Directory may include the following “Contact Information”: first and last name, headshot image, promotional information, name of Member’s business, email address, mailing address, and telephone number. Each Member acknowledges and waives all rights to opt out of the collection and distribution of the Member’s Contact Information that is in the Directory and Pando Club has no liability for providing the Contact Information to the Members. The Directory is considered Confidential Information and Members are prohibited from distributing the Directory without written permission from Pando Club or without express permission from the applicable Member. Members agree to not disclose or compile lists of participants or other Members, either for profit or for free.

Etiquette. Proper business etiquette should be maintained when communicating via email and text messaging. When writing a business email, be as clear and concise as possible. Sarcasm, poor language, inappropriate comments, attempts at humor, and so on, should be avoided. When communicating via email or instant messages, there are no facial expressions and voice tones to assist in determining the meaning or intent behind a certain comment. This leaves too much room for misinterpretation. Email communications should resemble typical professional and respectful business correspondence.

Social Media. Pando Club recognizes that internet-provided social media can be a highly effective tool for sharing ideas and exchanging information. However, Pando Club also seeks to ensure that social media usage serves its need to maintain its brand identity and integrity while minimizing actual or potential legal risks. The following are some examples of steps that, if followed, may protect the brand and the participants, and minimize legal risk. An individual should:

Not represent that any Pando Club participants have authorized them to speak on behalf of such participant or has approved the message unless they receive prior written authorization to do so from such participant.
Not make maliciously false statements about the products, services, or vendors or competitors of Pando Club participants.
Not advertise or sell participants products via social media without the prior written approval from such participant.
Respect the laws regarding copyrights, trademarks, rights of publicity and refer to the source information and accurately cite copyrighted works.
Not infringe on other company’s logos, brand names, taglines, slogans, or other trademarks.
Not use participant’s logos, brand names, taglines, slogans, or other trademarks without written authorization from such participant.
Not display or post video or other images of, or material about, the participants that are libelous, proprietary, harassing, bullying, discriminatory, retaliatory, or that can create a hostile work environment.