Legal information

Last updated: February 16, 2022

Privacy Notice

Context and Purpose of this Privacy Notice

The company operating the website http://www.viamo.io and the newsletter ViaMoments is Viamo Inc, 111 Research Drive, Unit 302, Saskatoon – Saskatchewan, S7N 3R2, Canada (“Viamo”, “we”, “us”, “our”). 

As a global organization, Viamo must comply with privacy and data regulations in multiple jurisdictions. The Canadian parent company must comply with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA). Viamo subsidiaries need to comply with all local regulations and laws in their operating markets across North America, Africa, Asia, Latin America and the Caribbean. Although Viamo does not frequently process Personal Data of residents in the European Union (EU), the European Economic Area (EEA) or the United Kingdom (UK), EEA/UK Clients have contractual requirements for Viamo to comply with the principles of the General Data Protection Regulation (GDPR) when delivering services outside the EEA/UK. 

This Privacy Notice describes how Viamo obtains, processes and shares your Personal Data when we are Data Controllers and what rights you have, in line with Art. 12, 13 and 14, GDPR. It applies to Personal Data you provide to us, or which we collect when you visit our website, request information about our services and products, subscribe to our newsletter or apply for a job. Following PIPEDA and GDPR definitions, we define Personal Data as data that relates to a specific individual that can be identified. 

For any questions you might have about this Privacy Notice, how Viamo handles your Personal Data or if you wish to exercise your Data Subject Rights (DSRs), please contact us at security@viamo.io. To exercise your DSRs, you can alternatively contact our Data Protection Officer (DPO): Silvan Jongerius, TechGDPR DPC GmbH, Heinrich-Roller Str. 15, 10405 Berlin, Germany, Email: viamo.dpo@techgdpr.com. 

What Personal Data do we collect and for what purposes?

Website visitors

We automatically collect information about visitors of our website, including information about when and how they use our website and technical information like referring URLs, their IP address, device and browser characteristics, language settings and location. We keep this data in log files for up to two weeks for our legitimate interest in preventing fraud, abuse and security incidents as laid out in Art. 6(1)(f), GDPR. 

We also collect information through cookies and we process this data for the purpose of optimizing our online presence and for marketing purposes. Cookie preferences can be changed and consent can be withdrawn at any time. See the section on cookies below for more information.

Prospective clients and partners

We collect information via our website and by email and information that is publicly available from prospective clients and partners who want to learn more about Viamo and our products and services. The information we collect includes the first name, last name, email address, telephone number, company or organization, country, language, and the type of request we received. We process this information in the preparatory stage of entering into a contract as laid out in Art. 6(1)(b), GDPR or to provide you with general information about our service in our legitimate interests per Art. 6(1)(f), GDPR. 

As prospective clients and partners actively request Viamo to contact them for more information about our products and services, we record this data to effectively communicate with them. Personal Data of prospective clients and partners will be deleted two years after the last contact we had with them unless they become a client of Viamo.

Newsletter subscribers

Any Data Subject can sign up for our newsletter through our website or other communication. We only add new subscribers to our mailing list once they subscribed to the newsletter and passed the double-opt-in sent to them via email. For this purpose, we collect the first name, last name, email address, language and industry. When sending the newsletter via a third-party provider, we collect information on when and how visitors use our newsletter and technical information like referring URLs, device and browser characteristics and location. 

We rely on consent per Art. 6(1)(a), GDPR, which can be revoked at any time by clicking the unsubscribe link in the footer of our newsletter or by contacting Viamo at security@viamo.io. We process the Personal Data of our newsletter subscribers for two years and refresh their consent again.

Job applicants

We collect information via our website and by email and information that is publicly available from candidates who apply for the vacancies we regularly advertise. This collection serves the purpose of selecting the right candidate for job offers based on education, work experience and skill set. This may include information such as your name, surname, email address, phone number, birth date, identification number, address, CV, photo, cover letter, work history, experience, academic records and references. Job applications are usually submitted through the Careers section on our website and additional information can be collected throughout the recruitment process. The legal basis for collecting Personal Data from job applicants is the performance of a contract as laid out in Art. 6(1)(b), GDPR.

Personal Data of job applicants is stored and processed for two years under our legitimate interest per Art. 6(1)(f), GDPR to get in touch with you for relevant job openings in the future or defend ourselves against legal claims.

Do we use cookies and other tracking technologies?

Our website uses cookies and other related technologies and cookies are also placed by third parties we rely on. We process this data for the purpose of optimizing our online presence and for marketing and sales. 

When you visit our website for the first time, we will show you a cookie banner and ask for your consent to place non-essential cookies. The non-essential cookies are placed on our behalf by HubSpot, a third-party marketing software provider, by the content management system WordPress and by reCAPTCHA, a Google service that helps protect our site against spam enquiries on contact forms. As soon as you click the accept button, you consent to us collecting the following cookies:

The cookies on your device will be stored and processed for up to 13 months from your last visit. You can change your cookie settings anytime in the cookie banner. If you do delete the cookies in your browser and visit our website again, you may again be asked for consent.

Why am I required to provide Personal Data?

This Privacy Notice applies to Personal Data you provide to Viamo, or which we collect when you visit our website, request information about our services and products, subscribe to our newsletter or apply for a job. As a general principle, when you provide Viamo with your Personal Data based on consent, you do this entirely on a voluntary basis. Choosing not to consent or not to provide Personal Data is generally not detrimental. However, there are circumstances in which we cannot take action without specific data, for example, when Personal Data is required to fulfill a contact request, deliver a service or provide you with our newsletter.

How do you protect my Personal Data? 

Viamo’s website servers are located in Canada, which is recognized as providing an adequate level of protection for Personal Data as determined by the European Commission. To protect your Personal Data, we maintain Technical and Organizational Measures (TOMs) in compliance with Art. 32, GDPR around the processing of your Personal Data and we enter into Data Processing Agreements (DPAs) with third-party providers that we engage

Do you transfer Personal Data internationally?

Viamo operates subsidiaries outside the EEA and we also use third-party providers across several countries. Personal Data may therefore be transferred to countries outside the EEA, including to countries not recognized as providing an adequate level of protection for Personal Data as determined by the European Commission. 

Our website servers are located in Canada, which is recognized as providing an adequate level of protection for Personal Data as determined by the European Commission. When you access our website or related services outside of the EEA, your Personal Data may be transferred to Canada or the EEA. 

When we transfer personal data to countries outside of the EEA and not on the European Commission’s adequacy list, we may use the European Commission’s Standard Contractual Clauses (SCCs) to safeguard their privacy as per Art. 46, GDPR.

Do you share Personal Data with third parties?

Viamo may share your Personal Data with Viamo subsidiaries and consultants and third-party providers that work for us in connection with the aforementioned data processing purposes. We only share and disclose your Personal Data with Viamo subsidiaries and consultants and other third parties if this is necessary and permitted by law or if you have explicitly given your prior consent for the Personal Data to be transferred.

We may share and disclose Personal Data with the following categories of third parties:

• Viamo subsidiaries and consultants
• Website Hosting Service Providers
• Sales & Marketing Tools
• CRM & Recruiting Tools
• Cloud Computing Services
• Data Analytics Services and Visualization Tools
• Communication & Collaboration Tools
• Design & Product Engineering Tools

Per the DPAs we have in place with Viamo subsidiaries and consultants and third-party providers, they must secure the Personal Data we share with them in compliance with GDPR and they are not allowed to use any Personal Data we share with them for any purposes other than what we have instructed them to. A list of our third-party providers can be provided upon request by reaching out to security@viamo.io.

What rights do I have in relation to my Personal Data?

At any time, you can request from Viamo to receive information about which Personal Data we process about you, as well as to provide you (in any case) or a third party (if the Personal Data is processed based on Art. 6(1)(a) or (b), GDPR) with a copy of this Personal Data. You can also request the correction or deletion of such data. Please note, however, that Viamo can delete your Personal Data only if there is no statutory obligation or prevailing obligation on Viamo to retain it.

Where Viamo processes your Personal Data based on consent, you can revoke it at any time. For newsletter subscribers, the easiest way to unsubscribe from our newsletter is by clicking the unsubscribe link in the footer of our newsletter. Also, if Viamo processes your Personal Data based on consent or the performance of a contract, you may request a copy of the Personal Data that you have provided to us. 

Furthermore, you can request that Viamo restricts your Personal Data from any further processing if:

• You are contesting the accuracy of the data we hold about you, for as long as we need to verify this claim.
• If you believe the processing of the data is unlawful, but you oppose the erasure of the data and request restriction of processing instead.
• If we no longer need your data for the original purpose, but you need them for the establishment, exercise or defence of legal claims.
• If you have objected to the use of your data, while we evaluate if our legitimate grounds for processing your data override yours, as required by Art. 21, GDPR.

Finally, where your Personal Data is processed based on our legitimate interests under Art. 6(1)(f), GDPR, you have the right to object against our use of your data. 

If you wish to exercise any of these DSRs, please contact us at security@viamo.io and specify the processing activities to which your request relates. To exercise your DSRs, you can alternatively contact our DPO: Silvan Jongerius, TechGDPR DPC GmbH, Heinrich-Roller Str. 15, 10405 Berlin, Germany, Email: viamo.dpo@techgdpr.com.

Your right to lodge a complaint

If you have a concern about how Viamo handles your Personal Data, we encourage you to first contact us at security@viamo.io. Should you disapprove of our response and if you are a resident of Canada, the EEA or the UK, you have the right to lodge a complaint with the data protection authorities in Canada, Berlin/ Germany or in the UK. See below for their contact details:

Office of the Privacy Commissioner of Canada
30, Victoria Street
Gatineau, Quebec
K1A 1H3
Canada
Phone: +1 (0) 819 994 5444
https://www.priv.gc.ca/en 

Berliner Beauftragte für Datenschutz und Informationsfreiheit
Friedrichstr. 219
10969 Berlin
Germany
Phone: +49 (0) 30 138 890
http://www.datenschutz-berlin.de

Information Commissioner’s Office
Wycliffe House, Water Lane
Wilmslow, Cheshire
SK9 5AF
United Kingdom
Phone: +44 (0) 303 123 1113
http://www.ico.org.uk/ 

If you are a resident of the EEA, you can alternatively contact the data protection authority of the EEA country you live or work in. See here for a list of all data protection authorities in the EEA: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

Use of this website by children

Neither this website nor any related services are intended for anyone under the age of 18 years. If you are younger than 18, you may neither register with nor use this website nor any related services.

Links to external websites

This website may contain links to external websites not operated or managed by Viamo and Viamo is not responsible for the privacy practices or the content of those websites. We, therefore, recommend that you familiarize yourself with the privacy practices of these websites by reading their privacy notices.

Changes to this Privacy Notice

We may modify this Privacy Notice to comply with legal requirements as well as developments within our organization. When we do, we will revise the date and version at the top of this page, and each website visit or interaction with our services will be subject to the newest version of the Privacy Notice. We encourage you to regularly review our Privacy Notice to stay informed. Unless we implement profound changes that we proactively notify you about, you acknowledge that it is your responsibility to review our Privacy Notice to be aware of modifications.

Last updated: July 28, 2017

Terms and Conditions

These Terms and Conditions (“Terms”, “Terms and Conditions”) govern your relationship with https://viamo.io website (the “Service”) operated by Viamo (“us”, “we”, or “our”).

Please read these Terms and Conditions carefully before using the Service.

Your access to and use of the Service is based on your acceptance of and compliance with these Terms. These Terms apply to all visitors, users and others who access or use the Service.

By accessing or using the Service you agree to be bound by these Terms and accept all legal consequences. If you do not agree to these terms and conditions, in whole or in part, please do not use the Service.

Intellectual property

The Service and all contents, including but not limited to text, images, graphics or code are the property of Viamo and are protected by copyright, trademarks, database and other intellectual property rights. You may display and copy, download or print portions of the material from the different areas of the Service only for your own non-commercial use. Any other use is strictly prohibited and may violate copyright, trademark and other laws. These Terms do not grant you a license to use any trademark of Viamo or its affiliates. You further agree not to use, change or delete any proprietary notices from materials downloaded from the Service.

Links to other websites

The Service may contain links to third-party websites or services that are not owned or controlled by Viamo.

Viamo has no control over, and assumes no responsibility for, the content, privacy policies, or practices of any third party websites or services. You further acknowledge and agree that Viamo shall not be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such websites or services.

We strongly advise you to read the terms and conditions and privacy policies of any third-party websites or services that you visit.

Governing law

These Terms shall be governed by, and interpreted and enforced in accordance with, the laws in the Province of Saskatchewan and the laws of Canada, as applicable.

If any provision of these Terms is held to be invalid or unenforceable by a court of competent jurisdiction, then any remaining provisions of these Terms will remain in effect. These Terms constitute the entire agreement between us regarding our Service, and supersede and replace any prior agreements, oral or otherwise, regarding the Service.

Changes

We reserve the right, at our sole discretion, to modify or replace these Terms at any time. If a revision is material we will make reasonable efforts to provide at least 30 days’ notice prior to any new terms taking effect. What constitutes a material change will be determined at our sole discretion.

By continuing to access or use our Service after those revisions become effective, you agree to be bound by the revised terms. If you do not agree to the new terms, in whole or in part, please stop using the website and the Service.

Contact us

If you have any questions about these Terms, please contact us.

Last Updated: April 2021

Safeguarding Policy

Policy statement

Viamo has a zero-tolerance approach to all acts of abuse and exploitation involving Viamo team members in their interactions with other team members, partners and end users.

Viamo is committed to the safety and protection of children and vulnerable adults in the discharge of our work.

Viamo commits to take all complaints about incidents of abuse, or incidents where the safety of children or vulnerable adults is put in jeopardy, seriously. Viamo initiates rigorous investigation of complaints that indicate possible violations and takes appropriate disciplinary action, as warranted.

Purpose and scope

This policy reaffirms Viamo’s commitment to protect our team members, partners and end-users from abusive behaviour, including unwanted and inappropriate sexual attention. The policy also aims to ensure the safety of children and vulnerable adults in the discharge of our work.

This policy applies to complaints of abuse and exploitation involving Viamo team members. Throughout this document, the term abuse includes sexual abuse. The policy is also relevant in the interaction of Viamo team members with children and vulnerable adults in both a direct and/or unsupervised capacity for any Viamo project.

The Safeguarding Policy on expected behavior is not limited to what occurs within a Viamo workspace or during working hours. Inappropriate behavior will not be tolerated at work, or anywhere else.

Principles

Viamo employs a holistic approach to preventing abuse and ensuring safeguarding. The approach comprises of:

1. Commitment to prevention through training and awareness
2. Strong, clear policy, including definitions, commitments, team member Code of Conduct
3. Leadership support and commitment
4. Company culture
5. Clear, confidential complaints, reporting and response process.

Privacy and confidentiality

All parties to a safeguarding complaint are expected to respect the privacy and confidentiality of all other parties involved and to limit the discussion of the complaint to those that need to know.

Viamo and all individuals involved in the complaint process, will comply with privacy legislation to protect personal information.

Definitions

Abuse – Offending or humiliating someone physically or verbally; threatening or intimidating someone; making unwelcome jokes or comments about someone’s race, national or ethnic origin, colour, religion, age, sex, sexual orientation, marital status, family status, disability or pardoned conviction.

Sexual abuse – is the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. This means that the use of actual force is not necessary to constitute sexual abuse. Sexual abuse can also occur in situations of inequality or under coercive conditions.

Sexual exploitation – is any actual or attempted abuse of a person, or of a position of vulnerability, differential power, or trust, for sexual purposes, including, but not limited to profiting monetarily, socially or politically from the sexual exploitation of another. This means that any individual acting as an intermediary in the organization of abuse is equally guilty of exploitation.

Zero-tolerance – zero tolerance requires that every staff member, volunteer/intern, consultant and representative, and partner of Viamo at all levels of the organization take on the responsibility to act on rumors of and possible incidents of sexual harassment, sexual exploitation, and other forms of abuse, such as bullying. It requires that the organization respond to all verified incidents with disciplinary action, including dismissal, when appropriate.

Child – Any person below 18 years of age

Vulnerable adult – A person aged over 18 years may be vulnerable (temporarily or permanently) if they:

• have a learning or physical disability
• have a physical or mental illness, chronic or otherwise, including an addiction to alcohol or drugs
• have a reduction in physical or mental capacity
• are receiving any form of healthcare
• are detained in custody
• are receiving community or aid services because of age, health or disability
• are living in a shelter, refugee camp or residential care home
• are unable, for any other reason, to protect themselves against significant harm or exploitation.

Viamo team member – broadly includes all team members of Viamo, board members, volunteers, interns, international and local consultants.

Understanding Abuse

Abuse and exploitation can happen once or many times and may include physical, verbal or non-verbal actions. Individuals exposed to this kind of treatment may feel offended, humiliated or violated.

Definitions are provided within this policy for abuse. However, there are instances of abuse and exploitation which may be subjective and circumstantial. Key here is to consider Viamo’s Team Member Code of Conduct as a minimum and strive to maintain an even higher standard of professional conduct. An exhaustive list of behaviours cannot be provided, but below are some examples of ones which may constitute abuse:

• Hostile gestures
• Unwelcome teasing
• Pushing, shoving
• Sexual pranks, teasing, jokes
• Verbal comments of a sexual nature
• Physical touching of a sexual nature
• Giving sexually suggestive gifts
• Making sexually suggestive gestures
• Posting sexually suggestive pictures

Abuse and exploitation may take the more direct form of aggressive, unwelcome behavior. However, they may take the form of an exchange or a quid pro quo. An example would be offering some kind of benefit to a colleague, subordinate, partner or beneficiary in exchange for a sexual favour or threatening to withhold benefit if sexual favours are not granted.

Viamo considers all such behavior unacceptable.

Responsibilities and expectations

Viamo’s Board of Directors is ultimately responsible for:

• ensuring a framework is in place to promote the safeguarding of children and vulnerable adults and to prevent the abuse and exploitation of co-workers, beneficiaries and other collaborators in the discharge of the duties of Viamo team members.

Executive Director of Human Resources is responsible for:

• ensuring that this policy is applied in a timely and consistent manner
• ensuring the confidentiality of the case, particularly the complainant
• ensuring the incorporation of job responsibilities (such as staff training, application of complaints and investigation procedure, and incident tracking) in specific job descriptions to ensure effective implementation of organizational strategies to prevent and respond to abuse
• determining whether or not allegations of abuse are substantiated
• determining what corrective action is appropriate where an allegation of abuse has been substantiated
• taking swift and appropriate action against Viamo team members who perpetuate exploitation and abuse. This may include administrative or disciplinary action and/or referral to the relevant authorities for appropriate action, including criminal prosecution, in the abuser’s country of origin as well as the host country
• providing reports on the safeguarding system, including data on complaints, to the Board of Directors, bi-annually or when appropriate
• publishing Viamo’s Safeguarding Policy and making best efforts to ensure that Viamo engages in partnership only with organizations with similar policies in place / committed to align with Viamo’s policy.

Human Resources is responsible for:

• providing regular training on this policy, including during onboarding, to ensure awareness and understanding of definitions and the complaints procedure
• the day-to-day administration of this policy, including receiving complaints
• maintaining appropriate records of every complaint and investigation, keeping these records confidential and ready for a routine audit by the Executive Director of Human Resources or Viamo’s Board of Directors
• in compliance with applicable law and to the best of our ability, prevent perpetrators of exploitation and abuse from being hired/rehired or deployed/redeployed by Viamo. This could include the use of background and criminal reference checks.
• undertaking a review of Viamo’s Safeguarding Policy at least every five years, making necessary adjustments to ensure that this policy meets the needs of the organization.

Managers are responsible for:

• fostering a culture of zero tolerance to abusive behavior
• setting an example about appropriate behavior in the discharge of work
• communicating the complaints and investigations procedure in the case of violation of the Safeguarding Policy
• dealing with safeguarding incidents immediately upon becoming aware of them, whether or not a complaint has been made
• taking appropriate action during an investigation, including separating the parties when appropriate, providing basic emergency assistance (medical, legal) and basic psychosocial support as appropriate and feasible
• ensuring safeguarding incidents are dealt with in a sensitive and confidential manner.

Team members are responsible for:

• treating co-workers, partners and beneficiaries with dignity and respect
• acting in a manner that ensures the safeguarding of children and vulnerable adults in the discharge of their work
• reporting incidents of abuse and/or exploitation perpetuated by Viamo team members that they observe or become aware of
• cooperating fully with a harassment investigation
• respecting confidentiality related to the investigation process.

Team members can expect:

• that reported abuse or exploitation will be dealt with in a timely, confidential and effective manner
• to have their rights to a fair process and to confidentiality respected during an investigation
• to be protected against retaliation for reporting abuse or cooperating with an investigation of abuse or exploitation.

End users, partners and the public can expect:

• that Viamo team members have received training as to what constitutes abuse and exploitation
• to have a clear, accessible confidential process to report incidents of abuse or exploitation involving Viamo team members where they arise.

Complaints and investigation procedure

1. Initial contact

Individuals wanting to make a complaint should do one of the following:

1. Complete this short web form
2. Phone a Viamo Abuse Prevention Hotline (please see annex for dial in details by country)
3. Contact Viamo’s HR team at hr@viamo.io

Viamo’s contact person will:

• acknowledge receipt within two working days
• be available to listen to concerns
• not form a view on the merit of any allegations
• provide information about the complaint procedure
• advise the person that in some situations where serious allegations are raised – for example, allegations that may expose the organization to legal liability – the issue may need to be reported to management and dealt with as a formal complaint
• where appropriate, provide support for a person if he or she wants to try and resolve the issue personally
• explain that the complainant can elect to have a friend, family member, or an impartial third person, accompany them during a formal complaint process for support
• outline other options available to the person, such as lodging a complaint with an external agency or local authorities.

2. Informal resolution

In some situations it may be appropriate to consider informal resolution of an initial complaint without undertaking an assessment of its merit. This approach may be useful where:

• the complainant indicates a desire to sit down and discuss the matter with the respondent informally and this seems appropriate in the circumstances
• the information on hand supports a view that the complaint has arisen from a misunderstanding or miscommunication
• the behavior being complained about is not serious and does not appear to be abuse, as defined by the organization’s policy.

Informal resolution may involve:

• a direct private discussion between the complainant and the respondent
• an impartial third person conveying information between those involved
• an impartial third person helping those involved to talk to each other and find a solution.

In some situations the impartial third person may need to be someone external to the organization, such as a professional mediator.

3. Formal resolution

If a person wants to proceed with a formal complaint, or if this is considered to be the most appropriate course of action, the following steps are recommended.

1. Obtain information from the complainant

The person handling the complaint should:

• provide information about the complaint process, potential outcomes and options for support and protection from victimization
• ensure the complaint is documented in writing
• ask the complainant to provide relevant documents or details of witnesses that may support the allegations
• explain that the process is confidential
• explain what records of the complaint will be kept, and where
• explain the action that may be taken if the complaint is found to be vexatious or malicious.

2. Advise the respondent about the complaint

The person handling the complaint should:

• advise the respondent that a complaint has been made against him/her and provide as much information as possible about the allegations and supporting information
• confirm that the respondent will be given the opportunity to respond to the allegations in writing or through an interview
• provide information about the complaint process, potential outcomes and options for assistance/support
• explain that the process is confidential
• explain what records of the complaints will be kept, and where
• explain that it is unacceptable to victimize someone who has made a complaint.

3. Assess the information

If the respondent confirms that s/he did what is alleged to have occurred, and if this behavior would be considered abuse as defined in the organization’s policy, the next step is to consider an appropriate outcome (see below). It is recommended that the respondent is provided with the opportunity to comment on any proposed decision and outcome before a final decision is made.

If there is disagreement about what happened, the person handling the complaint will consider whether there is other information that will help to determine what happened.

Given the nature of abuse and harassment, there may often be no direct witnesses or documents to support the complainant’s version of events. This does not mean that the allegation is untrue. In these situations, the complainant should be given the opportunity to comment on the information that has been provided by the respondent and to provide any other information to support his or her allegations before a final decision is made. It is generally understood that the person making the decision should be satisfied that it is ‘more probable than not’ that what is alleged to have happened did happen.

In serious cases, external parties may be required in the decision process and criminal charges may follow Viamo’s internal process.

4. Outcomes
5. Where the allegations are admitted or substantiated

Outcomes for the respondent may include:

• an official warning
• a requirement to provide a formal apology to the complainant
• participation in mediation
• disciplinary action e.g. suspension, probation or dismissal.

Outcomes for the complainant may include:

• supportive counseling
• participation in mediation
• a change in the work environment e.g. a change in team or location

It is important that the complainant is provided with general information about the outcome of a complaint, as this may affect their decision to pursue the matter with an external agency. The level of detail provided should be balanced against the need to respect the privacy of the respondent.

1. Where the allegations are not admitted or substantiated

Where allegations have not been admitted or substantiated, it may still be appropriate for the employer to take some action as a result of the complaint. For example, it may be appropriate to:

• re-issue the safeguarding policy to all team members
• provide refresher training for all staff regarding appropriate behavior.

If such action is taken, it is important that it is not done in a way which could be seen as singling out or punishing the respondent, especially where there has been no finding that he or she has breached the organization’s policy or Code of Conduct.

Annex – Viamo Abuse Prevention Hotlines

Viamo Business Code of Conduct

Statement of Purpose

The Viamo Business Code of Conduct is our guidebook for putting our values into practice in the way that we conduct business. It sets out an ethical framework for how we engage with partners and end-users, ensuring that we always make the best choices possible.

Viamo Values

We envision a world where all people have access to the information they need to make decisions for healthy, prosperous lives, and have meaningful relationships with governments, civil society, and businesses.

• We seek to delight our partners and users by exceeding expectations and holding ourselves accountable for achieving results.
• We strive to make things better for our users by creating lasting positive impact at scale.
• We invent solutions as they’re needed, testing, iterating, and trying new things along the way.
• We unleash the best in our diverse and competent global team, trusting our colleagues to rise to the challenge.

Guiding Principles

Viamo’s guiding principles for partnerships are inspired by leading resources from the development and social impact sector. The decision to establish or maintain a relationship with a company or organization for a particular project is guided by both positive and negative criteria which is detailed in our internal partnership assessment tool.

As a rule, Viamo will never engage with any partners that in any way promote arms dealing, pornography, tobacco, alcohol, illegal drugs (production & distribution), gambling, partisan political messages, human trafficking, hate, violence, or predatory lending.

Viamo will proactively engage with projects whose work makes progress towards the Sustainable Development Goals and the Universal Declaration for Human Rights.

Further guiding principles for all our business relationships include:

• Mission Alignment: As a matter of absolute priority, Viamo shall not accept any support from or collaborate with a company, foundation, entity, or organization if it might endanger the capacity for us to carry out our mission or compromise our values outlined above.
• Compliance: Viamo is committed to establishing mutually beneficial relations with our suppliers, partners, and end-users. We expect our partners to adhere to business principles consistent with our own. This means at minimum, compliance with laws/policies in the country of operation, donor regulations where applicable, and a commitment to working towards creating a positive global impact.
• Transparency: Viamo seeks to engage with companies and organizations that clearly publish and adhere to ethics and compliance policies such as fair trade, anti-corruption, anti-discrimination, and fair worker policies. For companies who have publicly acknowledged past wrongdoing, and demonstrated actionable change, Viamo will engage with them as well. Viamo seeks to improve access to information globally and therefore we prioritize projects that promote transparency.
• Environmental Sustainability: Viamo seeks to engage with companies and organizations that promote conservation and actively benefit the environment, or otherwise minimize the climate emergency. Viamo’s end-users are among the poorest people in the world who are most affected by climate change, therefore we prioritize environmental sustainability in all our projects.
• Social Responsibility: As a social enterprise, Viamo has a vested interest in working with partners who share our drive for social impact. Therefore, Viamo always prioritizes engagements with partners who create positive impact in the communities they serve. Viamo rejects companies or organizations whose products or methods to doing business are widely recognized as deleterious to the health, stability, or well-being of our communities or end-users.
• Net Positive Impact: Viamo will assess the overall net positive impact to all people impacted by our products and services, including end-users as well as those who may be affected in any way in both the short and long term. If a Viamo project is deemed to not have a net positive impact for all groups involved, Viamo will not accept the project.

Living our Values

The continued success of our business is dependent on the trust and confidence we earn from our employees, our partners, and our end users. We gain and retain credibility by adhering to our commitments, living our values, acting with integrity, and reaching company goals solely through honorable conduct. We will bring our values and purpose to every partnership and every project, enabling all stakeholders to operate with an ethical and empathetic approach that creates sustainable impact. We know it is easy to say what we must do, but that ultimately, we will be judged on what we do. The following lays out our Code, how we operationalize it, how we continually review and improve our standard of operation, and how we respond to questions of misconduct.

Employees

This Code was developed by employees across all levels of the organization. All Viamo employees should feel comfortable to voice their opinion, particularly with regards to our partnerships and how we do business. Managers have a responsibility to create an open and supportive environment where employees feel comfortable raising ethical concerns about our partnerships should they feel that any project is in conflict with our values.

Partners

Viamo is committed to establishing meaningful relationships with our partners in the public and private sectors. In our business dealings we expect our partners (clients, suppliers and other partners) to adhere to business principles consistent with our own. Viamo has a zero tolerance policy for any act of abuse and will decline to work with organizations or partners who do not share our rigorous standards for safeguarding people and their personal data. This means that all projects using Viamo’s products and services build awareness, create communication linkages and feedback loops, and empower marginalized communities to make decisions and take actions to improve their health and wellbeing.

End-users

Viamo is committed to delivering services that provide relevant, validated, and actionable information for healthy, prosperous lives. We are committed to designing our products and services in collaboration with those we serve and conducting all business in a way that will continually improve their well-being.

Viamo helps our employees live the Code:

1. Ensure all team members have access to information about all clients, suppliers and other partners of Viamo and the results of the Annual Viamo Partner Audit.
2. Equip our sales team with a Business Code of Conduct Development Tool. This tool helps our team members assess and confirm that every partner Viamo works with adheres to the values we embody and the ideals we hope to foster. This includes helping our team operationalize Viamo’s partner exclusion criteria, ensuring our platform, products, and services are in service to companies who share our vision.
3. Conduct an internal Annual Viamo Partner Audit which is an audit of all partnerships done on an annual basis to confirm that we are adhering to the Code, and make recommendations for improvements.

In Summary

Ensuring that all engagements reflect Viamo’s principles and values is the responsibility of every Viamo team member across the organization. Any BD lead (ie Director of Partnerships, Country Manager, Country Director, Regional Director, or Chief Program Officer) is recommended to submit a standard partner assessment tool as part of the due diligence process to evaluate the relationship based on the ethical criteria described in this code.

The team responsible for the Annual Viamo Partner Audit will rotate yearly, with the members recruited during Viamo’s annual global staff meeting (ViaFest), and they will be representative of the diversity of the organization. In any instance where an engagement is questionable, staff members are encouraged to report the concern to the Chief Operating Officer so that an appropriate response can be determined in close collaboration with the Chief Programs Officers and the CEO.

Viamo’s strength lies in the shared values of our team and acting with integrity is part of who we are. We extend our deep gratitude and thanks to our partners for their diligence and for helping create a fairer and more principled world as we work towards delivering our vision of being the global leader in tech for social impact. For more information on Viamo’s commitment to responsible business, please contact info@viamo.io.