Balderton Capital: Complaints Procedure

If you become aware of any instance involving a Balderton partner or employee that might be in breach of the Balderton Code of Conduct, whether internally at Balderton or as we interact with the wider community in which we operate, please bring the matter to the attention of the appropriate person promptly using the complaints reporting procedure below. Any incident will be investigated according to these rules.

If you ever have a question on these topics or would like to discuss an issue in confidence, you can contact either the Operating Partner or the Managing Partner direct.

Reporting

If you believe you have been subjected to or have witnessed any behaviour that violates the Balderton Code of Conduct you should immediately report the incident (even if you are unsure about any situation) using the following procedures:

1. Report the matter to the Operating Partner or Managing Partner or both; or
2. if, for any reason, you do not feel comfortable discussing the matter directly with the Operating Partner or the Managing Partner and wish to remain anonymous report the matter by

• sending an anonymous email to [email protected]
• complete the following anonymous form https://goo.gl/forms/zpDWUu9cdaLVLR4D3; or
• sending an anonymous letter addressed to the Operating Partner or Managing Partner at the firm’s address

If you make an anonymous report, please provide as much detail as possible, including copies of any documents that you believe may be relevant to the issue

Confidentiality

Even when reports are not made anonymously, you can still ask that information is supplied in confidence and we will always work to keep that information, including your identity, confidential.

Investigation and remedial action

All complaints will be promptly and thoroughly investigated in a fair and impartial manner and the investigation will be properly documented and tracked. At the conclusion of its investigation, if the firm determines a breach of its Code of Conduct has occurred, it will take effective remedial action in line with the severity of the incident (including, verbal or written warning, adverse performance evaluation, suspension and dismissal). We will follow up to ensure that any remedial action is properly enforced and that the behaviour has stopped. Throughout the process, we will always endeavour to discuss and agree any investigative or remedial steps with the victim and to respect the choice of the victim. At the end of the process, a report will be produced setting out the details of the investigation that was conducted, the findings and any remedial actions.

No retaliation

Retaliation against any person for reporting any incidents of harassment, discrimination or misconduct, or perceived harassment, discrimination or misconduct, for making any complaints or participating in any investigation of such incidents, is strictly prohibited. Any report of retaliation will also be promptly and thoroughly investigated. If a complaint of retaliation is substantiated, appropriate disciplinary action will be taken.