Preface

The term “employee/employees” mentioned throughout this Code of Conduct applies to all Calico employees, temps, vendors, visiting scholars, and contractors.

Calico’s Code of Conduct sets forth the standards by which we conduct our operations. It covers a range of subjects, from the use of Calico funds to conflicts of interest and protection of Calico information.  How we conduct our business and how we treat others — our colleagues, suppliers, and business partners — will continue to influence how we feel about Calico and how the world views Calico. We expect all employees to represent Calico in a manner that is consistent with our values.

Employees of Calico should do the right thing — a commitment to integrity, treating each other with respect, acting honestly and ethically, and complying with the letter and intent of the law are critical to our continued success.

We expect all of our employees to know and follow this Code of Conduct. Calico managers are responsible for ensuring that all employees reporting to them receive the help and advice they need to comply with the Calico Code of Conduct.

Any employee who raises a compliance concern in good faith acts in the interest of Calico and deserves support. Calico will not tolerate any retaliation against an employee who raises a compliance concern in good faith.

I. Avoid Conflicts of Interest

A conflict of interest may arise any time competing loyalties could cause an employee to pursue a personal benefit for themselves, their friends, or their family at the expense of Calico. Employees need to avoid conflicts of interest and circumstances that reasonably appear to be a conflict. Sometimes a situation that previously didn’t present a conflict of interest may develop into one.

II. Gifts and Entertainment

To avoid both the reality and perception of improper relations with existing or potential business partners, Calico employees adhere to internally established parameters for giving and receiving gifts and entertainment.

III. Confidential Information

Calico employees have access to confidential information related to our business. Employees need to only share confidential information with a person who needs to know said information for essential business reasons and who is entitled to get this information. If we share confidential information with a third party, any exchange of such information is subject to the signing of a confidentiality agreement.

It is imperative that a Calico employee never imparts information to others at Calico that is confidential (e.g. information from previous employers).

As a member of the Alphabet family, Calico employees may become knowledgeable of sensitive or confidential information related to Alphabet including financial, partner, business, technical and intellectual property information, and must ensure that such information remains confidential.

IV. Obey the Law

Calico employees comply with all applicable legal requirements and understand the major laws and regulations that apply to their work. A few specific areas of the law that are easy to violate unintentionally and are worth pointing out here:

• Trade Controls
• Competition Laws
• Copyright Laws
• Anti-Bribery Laws, including dealing with government officials

Nothing in this policy or any other policy, limits employees’ rights to (1) talk about pay, hours, or other terms of employment or working conditions, or (2) communicate with a government agency or official regarding those topics or any violation of the law.

V. Good Operating Practices

Calico adheres to sound quality practices in our operations. This means that we comply with all applicable laws dealing with Good Laboratory Practices and Good Clinical Practices (collectively included under GxP). All employees who are engaged in related activities are expected to know their relevant GxP responsibilities.

VI. Financial Integrity and Responsibility

It is important we ensure that money is appropriately spent, our financial records are complete and accurate, and our internal controls are honored.

If an employee’s job involves the financial recording of our transactions, they need to make sure that they are familiar with all relevant policies.

Never interfere with the auditing of financial records. Similarly, never falsify any company record or account.

VII. Scientific Integrity

Calico is committed to the highest standards of professional conduct and integrity in research.

• We properly collect, record and maintain research data.
• We take responsibility for all publications and presentations of which we are author or co-author.
• We appropriately acknowledge, in publications and presentations, those who have contributed to our research.
• We do not tolerate plagiarism, falsification, fabrication of research data or other scientific misconduct.

Falsifying records and accounts or misrepresenting facts may constitute fraud. In addition to Calico’s liability as a company, employees who engage in such illegal behavior may be subject to severe penalties.

VIII. Data Privacy

We respect the privacy of our employees and safeguard the confidentiality of personal records. Calico collects and retains personal information needed to support functions such as benefits, compensation and payroll. We will protect private employee personal information and use it only for legitimate business purposes, in accordance with all relevant laws.

We’re required to protect the privacy and security of any personal data we collect or handle. Security procedures strictly limit access to and use of personal information, and require that each of us take measures to protect data from unauthorized access.

IX. Data Security

We protect the confidentiality, integrity and availability of critical information, regardless of its form and location.

We must take reasonable steps to protect private information from loss, misuse, unauthorized access, disclosure or alteration

X. Discrimination or Harassment

It is Calico’s policy to comply with all applicable national, state and local laws pertaining to nondiscrimination and equal opportunity.

XI. Public Communications and Media Inquiries

All communications with the news media are potentially important and reflect upon Calico’s image and business. Communications from Calico need to be consistent, and all regulatory and legal obligations need to be fulfilled. Calico employees need to ensure that they have the appropriate approval prior to engaging in communications with the news media.

XII. Conclusion

We rely on one another’s good judgment to uphold a high standard of integrity for ourselves and our company. We expect all employees to be guided by both the letter and the spirit of this Code of Conduct.