Code of Ethics

1. Introduction

Our culture is built around eight Core Values:

- A culture of purpose and inspiration

- A workplace where people look forward to Monday

- A culture where autonomy, ideas, curiosity and creativity are nurtured and encouraged

- Our status-quo is to disrupt the status-quo

- Innovation is the theme of the day, every day

- A culture of radical candor

- A team guided by empathy

- Heck-yah!

It clarifies the expectations around all behavior, and reinforces our shared responsibility for this incredible Pathfinder community. The Code of Ethics applies to all employees, officers and directors of Pathfinder365 Adventure Agency Inc. and its subsidiaries, as well as all of our Businesses and Travellers.

2. Belonging is Everyone’s Responsibility

2.1 Pathfinder Responsibilities

Pathfinder will consistently strive to provide a platform that meets the needs of its Businesses and Travellers, so that they can effectively engage with one another, and exchange value. Pathfinder will seek to regularly add features, tools and functionality, and ensure Pathfinder’s continued relevancy with regards to Business and Traveller needs. Pathfinder will resolve Business and Traveller questions, concerns and reports with sensitivity, and respect for confidentiality to the greatest extent possible.

2.2 Pathfinder Employee Responsibilities

Every Pathfinder employee is expected to understand the requirements described in the Code of Ethics. Before you make a work-related decision or take action, think about the Core Values and the Code of Ethics. Ask yourself the following questions, and if the answer to any of the questions is “No” or “I don’t know,” your decision or action is probably inappropriate:

- Is this action legal and ethical?

- Is this action aligned with both the spirit and the letter of the Code of Ethics?

- Is this action aligned with Pathfinder Core Values?

- In significant decisions, have I considered the impact of this action on our stakeholders?

- Will this action seem appropriate to others?

- Would your coworkers be embarrassed or compromised if this action were to become known within Pathfinder or publicly?

The best way to safeguard our reputation and preserve our culture is to hold ourselves accountable. No one at Pathfinder has the right to discourage anyone else from reporting a Code of Ethics issue or to retaliate against anyone who reports a concern. See “We Prohibit Retaliation” below.

2.3 Business Responsibilities

Business owners occupy positions of authority within their respective businesses, and therefore it’s important that they each act as ethical role models in the tourism community. Businesses communicate their commitment to the Code of Ethics by (1) recognizing and striving to incorporate Pathfinder’s Core Values into their own business; (2) consistently upholding high standards throughout their business operations, and avoiding even the appearance of unethical behavior; (3) holding themselves and others accountable for their decisions and behaviors and (4) being alert to and taking steps to address situations that could violate the Code of Ethics or damage theirs, and Pathfinder’s, reputations.

2.4 Traveller Responsibilities

Travellers are the architects of all transactions and interactions through the Pathfinder platform. They are pivotal in engineering the direction of this marketplace, and are essential and beneficial community members. Travellers play a highly influential role in curating and guiding Pathfinder’s positive network effect, and therefore it’s their duty and responsibility as Pathfinder community members to dedicate themselves to a progressive code of conduct, and position themselves as empathetic community leaders. Travellers will interact with one another, with Businesses, and with Pathfinder, in a manner that’s professional, respectful, kind, ethical, responsible and reasonable.

2.5 Everyone’s Responsibilities

We must all play by the rules. Pathfinder complies with national, provincial and local laws and regulations that apply to our business. As a member of our community, you have a responsibility to be aware of and comply with the laws and regulations that apply to your area of responsibility. If you don’t understand a particular law or regulation, or if you are not sure it applies to you, be sure to consult with your legal advisor.

It’s everyone’s responsibility to interact in a manner that’s professional, respectful, kind, ethical, responsible and reasonable. Consequences of violating the Code of Ethics, or another Pathfinder policy, will depend on the gravity of the violation, and can result in discipline up to and including removal from the Pathfinder platform.

2.6 Reporting and Responses to Concerns

Should any challenges, concerns or discrepancies arise during an exchange of products or services, they should be brought to the attention of the applicable Business or Traveller immediately. All resolutions should be addressed and resolved in a professional, respectful, kind, ethical, responsible and reasonable manner, between the Business and the Traveller. Retribution or negative public declarations regarding disputes will not be tolerated, and could result in the removal from the Pathfinder platform.

Pathfinder will act as a moderating agency only as a last resort, and if both parties agree to such. We will thoroughly, promptly and impartially examine and address disputes, and take appropriate steps to maintain confidentiality, though we cannot guarantee absolute confidentiality or anonymity. Businesses and Travellers are required to cooperate with investigations conducted by Pathfinder by providing truthful and complete responses to investigators.

When claims are substantiated in whole or in part, we will take appropriate action, from recommendations and coaching, to warnings, or to termination of the applicable relationship.

2.7 We Prohibit Retaliation

As mentioned previously, it is a violation of this Code of Ethics to retaliate against anyone because they reported a concern, they helped someone report a concern, they participated in an investigation, they exercised a legal right, or they acted according to a company policy. If you suspect retaliation or have any questions about retaliation, please let us know.

3. Respectful Relationships

Belonging is a concept that defines the Pathfinder community, and every member should confidently experience and express it. Because all levels of belonging begin with respect, these policies outline the minimum expectations for respectful interactions at work.

3.1 We Promote Diversity, Inclusion & Equal Employment Opportunity

We believe in equal employment opportunity, which means we respect and embrace each other’s differences. We give every applicant and employee equal opportunities without regard to characteristics and statuses protected by country, regional or local laws. Protected characteristics and statuses around the world include such things as: race, religion, national origin, social condition, criminal record, citizenship, culture, color, gender, gender identity, gender expression, genetic characteristics, age, disability, medical condition, pregnancy, marital status, military status, civil status, HIV status and sexual orientation.

We practice and promote equal opportunity in every employment-related activity. We make employment-related decisions only on the basis of individual ability, performance, experience, and business requirements. Our employees should be free from discrimination in all aspects of the employment relationship — from recruitment and hiring, compensation, performance evaluations, project assignments, training opportunities, promotions, to the end of employment.

3.2 We Do Not Tolerate Harassment or Bullying

We’re all professionals at Pathfinder. We’re open-minded, respectful and hospitable. We’re committed to and look out for each other. Harassment, discrimination and bullying are incompatible with our values and are not tolerated. We ensure that our place of work is free of all forms of harassment, discrimination, bullying and retaliation.

3.3 What We Expect

We expect all internal leaders, as well as Business allies, to maintain healthy, inclusive work environments — where bullying, discrimination and harassment are never tolerated.

However, a culture of belonging is everyone’s responsibility, and requires each person to act appropriately with one another, whether it’s colleagues, contractors or vendors, and to take action when necessary, to ensure our work environment is free from bullying, discrimination and harassment.

3.4 We are Exemplary Businesses and Travellers

We are proud to have so many Businesses and Travellers who are champions of Pathfinder’s mission. As a Pathfinder member, we are each a representative of the other in our community; with our professionalism, our ethics, and our values. This is a significant responsibility. And whether you’re a Pathfinder employee, a Business or a Traveller, we expect everyone to be an exemplary member of the Pathfinder community.

Remember, exemplary communication is the foundation of an exemplary experience.

4. Final Note

It’s everyone’s responsibility to be aware of and understand this Code of Ethics, and to keep it relevant and effective. Together, if we insist on respectful relationships, safe and secure workplaces, and kind and reasonable interactions driven by empathy, we will ensure that Pathfinder remains a healthy and sustainable community for decades to come.

As Pathfinder grows, we will continue to add aspects to this document.

This Code is not intended to and does not create any rights in any employee, customer, client, visitor, supplier, competitor, shareholder or any other person or entity.