1

1. Rokt Why, How and What5

1.1. Why, How and What5

1.2. Our Value Proposition

5

1.3. Our Culture & Values

5

1.4. Our Values in Detail6

1.5. Our Commitment to Human Rights

8

1.6. Our Value Proposition to Rokt’stars

8

1.7. Work-Life Balance8

1.8. Better Together

91.9. Information Security, Privacy and Conﬁdentiality

9

1.10. Dress Code10

1.11. Feedback Channels

11

2. Achieving Results - How We Operate

122.1. Objectives and Key Results (OKRs)

12

2.2. Directly Responsible Individual (DRI)

12

2.3. Lightning Rods

12

2.4. Delegation Matrix

12

3. Beneﬁts

14

3.1. Time O Policies

143.2. Paid Time O (PTO)

14

3.3. Unpaid Leave

20

3.4. Work Travel

21

3.5. Working Arrangements & Flexibility

21

3.6. Training and Development (LevelUp! Allowance)

22

3.7. Wellness Allowance

23

3.8. Mental Health Support

23

3.9. Required Technology Allowance (RTA)

24

3.10. Phone Allowance24

4. Compensation and Contracts

25

4.1. Employment Agreements

25

4.2. Salary and Payroll

25

4.3. Short Term Incentive Program (STIP) and Commissions

25

4.4. Retirement, 401K and Pension Programs

25

4.5. Long Term Incentive Program (LTIP): Rokt’star Stock Program

26

4.6. Rokt'star Referral Program26

5. Technology and Communications

27

5.1. Software Systems

27

5.2. Required Technology

27

5.3. Rokt Communications and Meeting Guides

29

5.4. Content Creation Guide

29

6. Travel and International Mobility

30

6.1. Travel Policy30

6.2. Travel Approval and Booking

32

6.3. Relocation Allowances

33

6.4. Travel Insurance

35

6.5. Visa and Permanent Residency

35

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6.6. Global Kick Off (GKO)37

7. Expenses

38

7.1. Expenses Platform

38

7.2. Submission Detail38

7.3. Multiple Party Expenses

38

8. People and Behavior

40

8.1. Personal Details

40

8.2. Professional Development

40

8.3. Internal Mobility at Rokt41

8.4. Organizational Structure Guidelines

43

8.5. Performance Management44

8.6. Performance Review Cycles

44

8.7. Rokt’star Behavior

45

8.8. Serious Misconduct

46

8.9. Communication of Issues

47

8.10. Breaches and Reporting47

8.11. Code of Conduct48

9. Exiting the Company

50

9.1. Principles

50

9.2. Types of Exits

50

9.3. Involuntary With Agreement50

9.4. Involuntary Without Agreement (For Cause)

51

9.5. Voluntary Exit51

9.6. Final Arrangements

51

9.7. Final Payment and Expenses

51

9.8. Rokt’star Stock Program

51

9.9. Contact Information

51

9.10. Technology and Security

51

10. Rokt People Leaders53

10.1. Principles Behind Rokt’s Approach to People Leadership53

10.2. People Processes and Approaches

54

11. Appendix

57

11.1. Appendix 1.1 - Expenses and Allowance Amounts

57

11.2. Appendix 1.2 - Additional Expense Reimbursement Requirements

59

11.3. Appendix 2.1 - Rokt Communication Guide

60

11.4. Appendix 2.2 - Rokt Meeting Guide

64

11.5. Appendix 2.3 - Content Creation Guide

65

11.6. Appendix 3 - Wellness and Safety in the Workplace Policies

67

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Welcome!
Welcome to your Rokt’star Handbook!
In this Handbook, we detail all of our Rokt1 beneﬁts, policies, guidelines, and procedures we use tounlock the potential of each and every Rokt’star around the world. That’s you!
At Rokt we work hard to be generous, transparent and of course to ensure we follow all of thelegislative requirements in the countries where we have Rokt’stars doing their amazing work.
What do we need from you? We ask that you read, understand, and comply with the provisions
within this Handbook while you are working at Rokt. We update our Handbook regularly and thecurrent version will be published on our website so you can easily ﬁnd it anytime.
Our objective is to provide you with a positive and safe work environment so that you can conquer
new frontiers and raise the bar every day! Please let us know if something in this Rokt’star
Handbook doesn't make sense to you, or if you have any ideas of how to help make Rokt a better
place for all. We are always striving to be a force for good company, so that you may also be yourbest self at work.
This is a living and breathing document, and we encourage collaboration and feedback in all that
we do, including our Handbook. If you have feedback, please let your People Leader know orreach out to a member of the People Team. We are always better together!

1“Rokt” refers to the Rokt Group of companies, including the group parent entity in the USA (Rokt US
Corp.) and our operating entities in Singapore (Rokt Pte Ltd), Australia (Rokt Pty Ltd), USA (Rokt US Corp),
Japan (Rokt GK) and the United Kingdom (Rokt (UK) Ltd), along with the O erLogic Inc., Calreply Groupand AfterSell by Rokt entities.

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1. Rokt Why, How and What
1.1. Why, How and What
WHY:

Unlock the Moments that Matter Most

HOW:

Where Relevance Rules

WHAT:

Rokt Ecommerce Trusted Platform and Network

1.2. Our Value Proposition
Platform for Customer Relevance
In today's world, consumers are bombarded with choice and decisions. The challenge with all
this choice is that when consumers feel overwhelmed, they are less likely to act. This is
known as the Paradox of Choice. In ecommerce, this is a tough problem to solve because a
lot of content is ﬁxed, there is a wide and rapidly expanding range of choices across thetransaction moment (e.g. payments) and some components are not native to ecommerce(e.g. shopping reviews and social plugins).
However, there is a big prize to solving this problem. This is the moment that matters most,often generating close to 100% of the proﬁt. Unlocking this potential can put products andservices in the reach of more people. While there is still a long way to go to make this vision a
reality, today Rokt delivers a 25-40% increase to the economics of ecommerce.
Trusted Ecommerce Network
Rokt’s network unlocks access to billions of ecommerce transactions and provides a trusted
environment that ensures control and safety of your most valuable assets (customers anddata) at the moment that matters most, when customers' minds and wallets are open. Roktuses AI and machine learning to present the most relevant products and services to eachcustomer in the ecommerce transaction.
We uniquely enable partners to deliver against their commercial objectives, using technology
to increase engagement, revenue and customer acquisition, by unlocking the value of theirﬁrst-party data. Ecommerce is connected by design - requiring many working together inharmony to be successful. Rokt makes this connected ecosystem smart with relevance at
the center.

1.3. Our Culture & Values
We are a mission-driven, hyper-growth community of curious explorers, intent on unlocking
the full potential in ecommerce and beyond. Our bias for action means we are not afraid toquickly venture into new frontiers, take risks or challenge the status quo; in doing so we either
win or learn. We are better together as one aligned team never letting egos get in the way ofbrilliant ideas. We value diversity, transparency and smart humble people who enjoy building
a disruptive business together. We pride ourselves on being a force for good as we make theworld better.
We're not here to follow the beaten path. We're here to forge new trails. We chase theunknown and the unseen. That’s where greatness resides. Rokt’star’s know it’s more than

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just reaching our goals, it's about surpassing them. We don't wait for the perfect moment, wecreate it. We're not content with the status quo, we challenge it. We don't fear what's ahead,
we unlock it.
To unlock the moments that matter most, we…
● Start with the customer
We work backwards from the customer, where value is created when we unlock
relevance.
● Own the outcome
We are all owners and take accountability for delivering results.
● Bias for action
We are driven by progress, understanding most decisions are reversible & better ways
are found by doing.
This requires every Rokt’star to..
● Conquer new frontiers
We are curious explorers always looking for new and better ways.
● Raise the bar
We look to stretch ourselves and set higher standards.
● Be smart with humility
We empower through transparency, robustly challenge and never let egos get in the way.
With a culture that celebrates being..
● Better together
We love what we do, enjoy the ride and thrive knowing great things come from working
together.
● A force for good
We ﬁght for a fairer world, actively investing in our people, communities and culture to
unlock possibilities.

1.4. Our Values in DetailRokt’stars start with the customer
We work backwards from the customer, where value is created when we unlock
relevance● Rokt'stars always start with the end customer and work backwards. It’s how
we understand our real customer needs, vet our ideas and obsessively
maximize value.
● Rokt'stars are curious explorers, focused on the bigger picture. We areconstantly recalibrating to ensure our teams are aligned and working on thechallenges that will make our vision a reality.
● Descriptors: We are Obsessed, Empathetic, Responsible

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Rokt’stars own the outcomes
We are all owners and take accountability for delivering results● Rokt'stars act as owners of the company, because we are. It's the
responsibility we each carry. We treat the company's money as if it's our own.
We rise to the occasion, good or bad. We never say “that’s not my job,” nor do
we ignore smoke.
● Rokt’stars provide context to empower and encourage ownership. Rokt’stars
have the freedom, autonomy and responsibility to act in the best interests of
Rokt.
● Descriptors: Accountable, Delivery-focused, Detail-oriented
Rokt’stars bring bias for action
We are driven by progress, understanding most decisions are reversible & betterways are found by doing● Rokt'stars know that speed matters in business. We know that the greatest
learning comes from doing.
● Rokt'stars win or learn. Many decisions and actions are reversible and do notneed extensive study. We know that achieving our vision requires us to takerisks and support others to do the same.
● Descriptors: Agile, Fast, Tenacious
Rokt’stars conquer new frontiers
We are curious explorers always looking for new and better ways
● Rokt’stars are mission-led and laser focused on turning our vision into reality.
● Rokt'stars have bold ambitions and move with imagination. We act fearlessly
to explore ideas and paths to get us closer to achieving our vision.
● Descriptors: Courageous, Curious, Ingenious
Rokt’stars raise the bar
We look to stretch ourselves and set higher standards● Rokt’stars are constantly in the pursuit of making us all better. We recognize
exceptional people and develop talent. We support everyone at Roktbecoming their best selves and reaching the next level.
● Rokt'stars continually raise the bar by developing their skills and abilities. We
seek feedback and lean into areas for development. We act quickly on
performance issues and do so in a kind, direct and respectful way. When it
comes to hiring, our bias is to screen out early.
● Descriptors: Challenge, Coach, Growth
Rokt’stars are smart with humility
We empower through transparency, robustly challenge and never let egos get in theway● Rokt'stars constantly seek the truth. We probe with thoughtful questions tochallenge our own beliefs. We use data, knowledge and experience to form
opinions, make decisions and preempt market trends & customer needs. We
have good instincts and commercial acumen.
● Rokt’stars empower through transparency where the best ideas always win an ideas meritocracy. We do not avoid di cult conversations. We
democratize ideas with concise written communication, providing context.
We always acknowledge our mistakes, putting the team ahead of ourselves.
● Descriptors: Humble, Vulnerable, Transparent, Concise

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Rokt’stars are better together
We love what we do, enjoy the ride and thrive knowing great things come fromworking together● Rokt’stars believe that career development, apprenticeship and company
growth accelerates more quickly when we spend time together. We believethat two heads are better than one.
● Rokt'stars are passionate about what we do and the journey we are on
together. We inspire, encourage and enable each other to be at our best. We
bring fun & enjoyment to our everyday work lives & celebrate all of our
successes along the way.
● Descriptors: Supportive, Appreciative, Humorous
Rokt’stars are a force for good
We ﬁght for a fairer world, actively investing in our people, communities & culture to
unlock possibilities● Rokt’stars believe our collective strength comes from diversity – which is why
we strive to make Rokt an inclusive space for everyone.
● Rokt’stars have a genuine concern for each other and the world around us.
We believe our communities get stronger when everyone gets an equal
opportunity to unlock their full potential.
● Descriptors: Caring, Inclusive, Fair

1.5. Our Commitment to Human Rights
We believe that the world is a better place when everyone is able to reach their full potential. As
such we are deeply committed to respecting and promoting human rights as enshrined in the
Universal Declaration of Human Rights. We also acknowledge the traditional owners, indigenous,
and First Peoples of every nation and community in which we operate.

1.6. Our Value Proposition to Rokt’stars
Unlock your inner voice. The one that knows you can do it. The one to listen to more. Unlock thatdesire you’ve always had to achieve something bigger. Take the leap. Be part of a team of diverse
individuals who thrive by conquering new frontiers and working in di erent ways, always better
together. Learn, grow, and then learn some more in a hyper-growth environment. Develop yourvoice, your ideas, your ability to help others. People at Rokt aren't inspired by job titles, they are
inspired by other people. Unleash all the possibilities. At Rokt you’ll unlock your full potential.

1.7. Work-Life Balance
At Rokt, we consider it essential for all of our Rokt’stars to live a healthy life - where work andpersonal life are in balance. To help you achieve this we actively support initiatives like blocking oof personal time and ensuring you can completely switch o from work on weekends and when
taking time o . To support this, we o er a generous PTO program including Bonus PTO (High Five
Days), a Flexible Public Holiday Program as well as the opportunity to take a Sabbatical.
As a global company, meetings with Rokt’stars in other o ces can sometimes require slots of timeoutside of traditional business hours. We appreciate your contribution to these where required,and support you working with your People Leader to manage your time around them. For

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example, we actively encourage you to block out time in your calendar the following morning when
you have been involved in late night calls.
Our People Leaders are encouraged to support you in balancing your schedule.

1.8. Better Together
We believe passionately that we are better together. While we are a globally distributed team of
Rokt’stars, we care a great deal about personal, human connection and we value spending time
together. We are a largely ‘in person' culture because we believe that real innovation anddevelopment through apprenticeship is faster and better when we spend time together.
Rokt invests in bringing all of our Rokt’stars to one location each year for our Global Kick O(GKO), despite being a globally distributed company. To this end, new Rokt’stars are regularly
inducted globally on-site in New York throughout the year. Connections between departments,
even amongst departments located across global locations, create the magic that is Rokt. We
encourage you to always ask your People Leader about travel to another o ce where it will create
positive business outcomes as we strongly believe this is core to our success and is a part of who
we are.
Rokt invests heavily in face-to-face training and spending time coming together at local
celebrations as well as at GKO. In addition, we o er a lot of training and activities focused on
further development. We work to create cohorts of all types of groups, including leaders andinductees, so that you may create connections which unlock personal and professional beneﬁts
during your journey at Rokt. We also warmly support our Rokt-star founded and managed A nity
Groups and the activities/learning experiences they create and organize.

1.9. Information Security, Privacy and Conﬁdentiality
Rokt sits at the intersection of two data rich environments -- ecommerce and marketing; we arehelping to make the relationships between our Rokt Ecommerce clients and their customers amore personal and relevant experience. We also power important advertiser outcomes for our
Rokt Ads clients. We also act as a distribution mechanism for providers using Rokt Distributed
Commerce. As such, Rokt’s continued success relies on ensuring and preserving the ongoingtrust between Rokt and our clients, and their end customers. This trust is in the hands of every
Rokt’star, every day. Our entire team of Rokt’stars will be asked to undertake compulsory annual
training on Information Security, Privacy and Conﬁdentiality as this is fundamental to our success.
1.9.1. Client Conﬁdentiality
Conﬁdentiality means, in practice, being highly discretionary about what information you sharewith others. It means asking ‘does this person actually need to know this information’ for us to get
the job done; if the answer isn’t a clear “yes”, err on the side of conﬁdentiality. It means making
sure you do not inadvertently disclose information, such as by mis-addressing an email, or better
still, deciding that you do not need to include conﬁdential information in an email, at all. Ultimately,
it means exercising good judgment.

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That being said, there are certain mandatory rules regarding Client conﬁdentiality at Rokt which all
Rokt’stars must adhere to:1.

You may not trade the securities of any Rokt Client: As an employee or contractor of
Rokt, you have unique insights into our Clients’ business (including past clients andprospects), much of which is non-public. Using such information to make investment
decisions, or sharing such information with family, friends or acquaintances for their own
use in making investment decisions, may constitute a violation of law in many of themarkets in which we operate. Regardless, it plainly constitutes a violation of our Client’s
trust and is not permitted. Before you trade securities of any company (whether buying or
selling) you must make a request to the Rokt Legal Team, who will review the request
including whether the trade involves a Rokt client or a related party to a client. Note that
this does not preclude investments in mutual funds, ETFs, or similar investment vehicles
where individual stocks are not bought/sold at your instruction.

2.

Do not share conﬁdential information externally: More generally, you may not use a
Client’s commercially sensitive information for any purpose other than for providing that
Client with the best services possible. This means you may not share a Client’scommercially sensitive information with another Client, a potential prospect, or any otherthird party.

1.9.2. Customer Privacy
Concern about data also extends to end-users of the Rokt platform, and any personal information
the Rokt platform processes on behalf of clients. We call this realm ‘privacy’. Adhering to Rokt’s
position on privacy is a core requirement of your role as it’s of paramount importance to all of ourclients and their end customers, this is critical to our role as a trusted intermediary in ecommerce.
Rokt'stars must be committed to ensuring personal information is protected. Your responsibilities
include the appropriate usage of provided tools and systems to query personal information. E.g.,
usage is limited to respond to direct consumer or client queries, but excludes personal queries onfamily, friends, colleagues, etc. Consumer data must never be shared except with the consumer
themselves or with the client as contractually required.
As a result, all Rokt'stars must be familiar with, and abide by, Rokt’s Information Security Policies.
This is why you will be required to undertake annual training on these requirements.
1.9.3. Intellectual Property
Any intellectual property made, developed, or contributed by you in the course of youremployment with Rokt remains the property of Rokt.

1.10. Dress CodeOur goal at Rokt is to maintain a comfortable, respectful and inclusive environment which is also
professional. It is common for us to host clients, candidates and other partners in the o ce and wewant them to always feel comfortable; therefore our o cial dress code is business casual.

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Your choice of clothing reﬂects on your professionalism in your role and your respect for those you
work with. Some points to consider when choosing your work attire:●●If you are in a client-facing role, aim to equal or exceed the dress code of your client.
Always dress to be ready for an unexpected meeting with a client, candidate or senior
representative from a supplier partner.

1.11. Feedback Channels
At Rokt, we believe feedback is important to continually ‘Raise the Bar’ and make Rokt the bestplace to work for all of our Rokt’stars. Rokt’stars can use a variety of channels to share feedback
and suggestions, and we encourage this at all times.
Multiple times per year we survey all Rokt’stars about your opinion on what is working really well at
Rokt and what you think we can improve together, we also enable feedback on your People
Leader. Our Engagement Surveys are anonymous to ensure we capture all of your feedback
securely, but we also encourage you to o er regular feedback in multiple channels directly with thebusiness and your People Leader The Engagement Score results and any key insights from thissurvey are shared with the Rokt team, including with our Board, and help inform our People
strategy and priorities. Our ‘always on’ channels include the `Ask Anything - Ideas, Discussion &Learning` chat room and Rokt comment box (which can be used anonymously).
We also provide opportunities for Rokt’stars to ask questions directly to the CEO and ExCo during
each All Hands meeting, which are held regularly, and during other company events held
throughout the year.

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2. Achieving Results - How We Operate
We hire incredibly talented people (like you!) who care a great deal about delivering extraordinary
results. The following section outlines some of the ways that we help create alignment ro raise thebar, own the outcome and have a bias for action - which ultimately allows teams to operate
independently.

2.1. Objectives and Key Results (OKRs)
OKRs are a collaborative goal-setting tool used by both teams and individuals at Rokt to set
challenging, ambitious goals with measurable results that are aligned to Rokt’s mission, visionand company goals.
●●●

An Objective is the outcome to be achieved and typically set collaboratively by teams.
Key Results (KRs) are measurable milestones that show progress towards achieving an
Objective. E ective KRs are speciﬁc, time-bound, measurable and veriﬁable.
It is common for Objectives to be long-lived while KRs evolve over time as progress ismade towards the Objective.

2.2. Directly Responsible Individual (DRI)DRI is the ultimate owner of an outcome on any given project. The DRI can be a leader orindividual contributor. The selection of a DRI and their speciﬁc role will vary based on their own
skillset and the requirements of the project.
●●

All projects are assigned a DRI who is held accountable for its success (or failure).
The DRI is empowered to get it done or ﬁnd the resources and path to make it
happen.

2.3. Lightning Rods
Concisely written one-page memos are powerful tools to explain and crystalize an idea. They also
help broaden the involvement of others, like team members in other o ces. We use RoktLightning Rods to make proposals and to share, iterate and align on ideas, principles andconcepts. At Rokt, we strive to use clear and simple language which is easy to understand. Where
possible, we try to avoid technical jargon which may be unclear or require further explanation.
Being able to communicate with impact is a key requirement in being successful at Rokt as it
helps create alignment in conquering new frontiers.

2.4. Delegation Matrix
Rokt’s Delegation Matrix describes the extent to which the Board, CEO, key executives and otherRokt’stars can make contractual or ﬁnancial commitments on behalf of the company. The
Delegation Matrix is periodically updated and approved by the Board. Before exercising adelegation, you must receive training from Rokt Legal, which is made available for eligible
Rokt’stars following updates to the Matrix and promotion cycles. Rokt’stars are required to consult
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the company. If you have any questions, please reach out to Rokt Legal. We always encouragethat you check ﬁrst if you are in any way unclear about whether you have authority to makeﬁnancial commitments, of any value, on behalf of Rokt. A link to the Rokt Delegation Matrix is
included in the Rokt Career Ladder.

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3. Beneﬁts
We value all Rokt’stars and o er a variety of awesome beneﬁts. While some beneﬁts are speciﬁc
to particular roles and locations, the following beneﬁts are o ered to all permanent employees of
Rokt:
●
●
●
●
●
●
●
●
●

Rokt'star Stock Program
Wellness allowance
Technology allowance
Rokt facilitated learning and development programs and a 'LevelUp' allowance for external
training, learning and development programs
Rokt'star referral program
Global mobility opportunities
Paid Time O , including Paid Parental Leave
Rokt'star awards programs
Lunches, snacks, co ee, and drinks

Your Employment Agreement or contract with Rokt will include additional details regarding youreligibility for speciﬁc beneﬁts.

3.1. Time O Policies
At Rokt, we believe it is essential for all Rokt'stars to take breaks throughout the year to stayrefreshed. We also understand there are times when leave is required unexpectedly.
Our success as a team depends on ensuring we have e ective coverage for each other when weare away from work - this means clients always get the best experience and teammates areprepared to support each other. To facilitate this, all time o is managed through BambooHR. For
part-time Rokt’stars, your time o entitlements will be on a pro-rata basis.

3.2. Paid Time O (PTO)
Your PTO2 should be covered by the Rokt's policies detailed here, however there can sometimes
be variations due to individual contractual commitments and local legislation.
PTO entitlement accruals reset on February 1st each year (the start of Rokt’s ﬁnancial year). The
carryover of any unused entitlements from the prior year is limited to 8 days unless otherwise
speciﬁed by your region’s applicable legislation.
With the approval of your People Leader, you may be able to go into a small quantity of negative
leave before you are required to take unpaid leave. Your accrued PTO must return to a positive
value before you can take any more leave days.

2

Referred to as “PTO” in some markets and “Annual Leave” in others.

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When leaving Rokt, an eligible Rokt'star will be paid for any accumulated PTO, at their base rate ofpay. Similarly, a negative PTO balance on termination of employment will be adjusted through adebit applied to your ﬁnal termination pay.
3.2.1. Public Holidays
We celebrate having a diverse group of Rokt’stars and believe that you should have theopportunity to observe cultural or religious holidays that are important to you. As such, we areproud to o er a Flexible Public Holiday Program (FPHP). Rokt’stars who opt into the program will
receive 6 ﬁxed holidays[1] within the Rokt Holiday Shutdown and are able to select an additional 6(or 9 if you are based in Japan) days of religious or cultural signiﬁcance to the communities inwhich we live and work[2].
On an annual basis between December 15 and January 15, Rokt’stars will be prompted to selectthe public holidays you wish to observe for the upcoming Rokt ﬁscal year which starts on 1
February. New Starters who join after the enrollment window has closed and Rokt’stars who do
not make an election in the required period will be allocated to the ﬁxed[1] and default FPHP
holidays for your region[3], unless they opt out of the FPHP.
In November each year, ahead of the annual election period, Rokt’stars will be able to nominate
additional days to be included in the FPHP. These days should be days of religious or cultural
signiﬁcance celebrated or observed in the communities in which we live and work. National
holidays from countries where Rokt does not have a presence or professional recognition days
are not eligible for the program.
Rokt’stars who opt out of the FPHP will follow the public holidays calendar for your country[4]. In
this case, all days not listed as public holidays during the Rokt Holiday Shutdown period will be
automatically deducted from annual leave/PTO.
USA

AUS

CAN

JPN

6 Days: December 25 (Christmas), December 26 (Boxing Day),
December 27, December 31 (New Years Eve), January 1 (New Years Day), January 2[1]Fixed Days
(within FPHP)

6 Days# Selectable
Days (FPHP)[2] Selectable
Days of
Religious andCulturalSigniﬁcance(FPHP) in
addition to theany of theregional
holidays listed
in [3]● Ashura● Chanukah● Columbus Day● Coming Out Day● Dia De Los Muertos● Diwali● Eid al-Adha● Eid ul-Fitr● Indigenous Peoples Day● Islamic New Year
● Juneteenth● Kwanzaa● Lailat al Miraj● Laylat al Bara’at● Lunar New Year

[3] Default● MLK Day

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UK● Australia Day

8 Days9 Days● Mawlid● Night of Destiny● Presidents Day● Passover● Purim● Rosh Hashanah● Shavuot● Simchat Torah● Start of Ramadan● Sukkot● Veterans’ Day● Yom Kippur● Good Friday● Good Friday

Rokt’star Handbook, 02.01.24● Coming of Age

15

USA

AUS

Schedule of
Flexible Days
(FPHP; for new
starters or if
you do notselectalternate days)● Memorial Day● IndependenceDay● Labor Day● Thanksgiving● Day afterThanksgiving[4]Public
Holiday
Calendars (Ifopting out of
the FPHP)● New Years Day● MLK Day
● Memorial Day● Juneteenth● IndependenceDay● Labor Day● Thanksgiving
Day● Day afterThanksgiving● Christmas Day

UK

CAN

JPN

● Good Friday● Easter Monday● Easter Monday ● May Bank
● Anzac Day
Holiday● King’s Birthday ● Bank holiday● Labour Day
for thecoronation ofKing Charles III● Spring Bank
Holiday● Summer Bank
Holiday● Easter Monday● Victoria Day● Canada Day● Labor Day● National Day for
Truth andReconciliation● Thanksgiving Day● Remembrance Day● National FoundationDay● Emperor’s Birthday● Vernal Equinox● Constitution MemorialDay● Children's Day● Autumnal Equinox Day● Culture Day● Labour Thanksgiving
Day● New YearsDay● Australia Day● Good Friday● Easter
Monday● Anzac Day● King’s
Birthday● Labour Day● Christmas● Boxing Day

●
●
●
●
●

● New Years Day● Coming of Age● National FoundationDay● Emperor’s Birthday● Vernal Equinox● Showa Day● Constitution Memorial
Day● Greenery Day● Children’s Day● Marine Day● Mountain Day● Autumnal Equinox Day● Respect for Aged Day● Culture Day● Labor Thanksgiving
Day● New YearsDay● Good Friday● Easter
Monday● May Bank
Holiday● Spring Break
Holiday● SummerBank Holiday● Christmas● Boxing Day

●
●
●
●
●
●
●
●
●

New Years Day
Good Friday
Easter Monday
Victoria Day
Saint-Jean-Baptiste
Day
Canada Day
Civic Holiday
Labor Day
National Day for
Truth andReconciliation
Thanksgiving Day
Remembrance Day
Labour Day
Christmas
Boxing Day

3.2.2. Bonus Paid Time O - “Rokt High 5 Days”
We believe it’s important for Rokt’stars to take regular breaks. As such,those Rokt’stars who use
most of their leave in any given year are eligible for ﬁve (5) days of additional paid time o , termedHigh 5 Days. In short, we are rewarding you with more PTO for taking the majority of your PTO in
the prior year.
High 5 Days are credited at the commencement of the Rokt Fiscal Year on February 1st for all
Rokt'stars who were employed before April 1st of the prior year and ﬁnished the prior ﬁscal yearwith a PTO balance of 5 days or less. Rokt’stars are encouraged to take PTO throughout the year
and proactively communicate with their People Leader and team about vacation plans to help
minimize disruptions to the business or instances where multiple people from the same team areout at the same time. If you wait until January to take last minute leave as catch up for High FiveDays, there is a risk your leave may not be approved, particularly where there are already a lot ofother Rokt’stars on leave.
3.2.3. Sick & Carers Leave
There may be times when you, or a family member, aren’t well and you need to take some time o .
Rokt’stars are eligible to take paid Sick Leave when you are unable to work because of a personalillness or injury (including stress and pregnancy related challenges). You may also take paid
caregiver's leave to care for or support a member of their immediate family or household who is

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sick, injured or has an emergency. The allowance varies by region and is set out in the table below.
We always want to ensure that you can focus on what’s most important to you at any given time
and we encourage our People Leaders to be ﬂexible and generous in supporting you through any
personal need that arises.
Please notify your People Leader when you need to take Sick or Carers Leave. Rokt may requestthat you provide a medical certiﬁcate (in accordance with relevant labor laws).
Sick/Carers Leave Allowance
US, JP, UK, CA

80 hours (10 days) per year, not carried forward

AU

In accordance with Fair Work AU

3.2.4. Community Service Paid Time O
Aligned to Rokt’s ‘Force for Good’ value, we support Rokt’stars who volunteer with community or
not-for-proﬁt organizations. Rokt will credit 50% of the time you take to volunteer using your PTO(up to 3 days per year).
Please submit (via email) a summary of the selected volunteer activity for approval from yourPeople Leader. Upon approval, please submit a request in BambooHR and the People Team will
adjust your PTO balance accordingly.
3.2.5. Compassionate and Bereavement Leave
To o er proper space and time for Rokt'stars to deal with the loss of a family member, Roktprovides the following bereavement leave:●●

5 days for immediate family members that you live with or have responsibility to care for1 day for other family members or close friend

If you have su ered a bereavement, please reach out to your People Leader or a member of thePeople team who can provide appropriate support and ensure this leave is captured in
BambooHR. We always want to ensure that you can focus on what’s most important to you at any
given time and we encourage our People Leaders to be ﬂexible and generous in supporting you
through any personal need that arises.
3.2.6. Pregnancy & Parental Leave
Rokt’stars are eligible for parental leave if you or your partner are due to give birth or adopt a childafter 8 months of employment. Eligibility for parental leave is as follows:●●Pregnancy Leave: Birth parents are o ered 10 calendar weeks paid Pregnancy Leave (tobe taken as a single block) to be used between 4 weeks prior to birth date and to becompleted no later than 12 months after the birth date of the child.
Parental Leave: All parents, including birth parents (additional leave), non-birth parents
and adoptive parents, are o ered 6 calendar weeks paid Parental Leave (to be taken as asingle block) to be used between 4 weeks prior to birth date or adoption and to becompleted no later than 12 months after the birth date or adoption of the child.

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Birth parents are entitled to access both Pregnancy Leave and Parental Leave. For part-time
Rokt’stars, your Pregnancy and Parental Leave entitlements will be pro-rata based on the average
percentage of FTE worked in the 12 months prior to commencing leave.
Pregnancy and Parental Leave, as applicable, will run concurrently with any government paid
parental leave programs. This means if you live in a country where a statutory parental leave
beneﬁt is available, you will be required to claim statutory parental leave pay (if eligible), and Roktwill supplement any gaps.
In addition to the above, Rokt’stars are eligible to take unpaid parental leave up to 12 months
following the birth or adoption (or 24 months if you are located in Australia). To the extent thatgovernment paid parental leave extends beyond the period of Rokt’s Pregnancy and/or Parental
Leave, you may continue to receive government paid parental leave during periods of unpaid
leave from Rokt.
The following table summarizes the treatment of various entitlements during Pregnancy, Parental
and unpaid parental leave:

Pregnancy Leave

Parental Leave

Unpaid Parental
Leave

PTO and otherstatutory leave
entitlements

Continue to accrue

Continue to accrue

Do not accrue

Vesting of employee
equity awards

Uninterrupted

Paused for periods ofParental Leave

Paused for periods of
unpaid parental leave

Paid based on theprior two quarters of
performance with a
cap at 100%Pro-rata adjustment
based on the durationof the leave

Pro-rata adjustment
based on the durationof the leave

Continue per theoriginal schedule

PausedPausedPausedPausedPausedAble to be utilized

Able to be utilized

Not able to be utilized

Able to be utilized
subject to People
Leader approval

Able to be utilized
subject to People
Leader approval

Able to be utilized
subject to People
Leader approval

STIP or commission
payments(if applicable)

Sign-on bonus
payments (ifapplicable)
Travel allowances (ifapplicable)
Telephone andWellness allowance
RTA and Level-Up
Allowance

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We understand that complications during pregnancy, birth and/or adoption can occur and that
Rokt’stars may have many di erent caregiving situations (e.g. shared caregiver arrangements).
We endeavor to support Rokt’stars in these situations and encourage you to discuss your speciﬁc
circumstances with your People Leader, 2-Up People Leader or someone in the People Team
including the Chief People O cer. We want you to have access to someone you feel comfortable
talking to about any family health or caregiver challenge that arises. Rokt’s parental leave policy
extends to parents who su er a stillbirth or death of their baby.
Please reach out to a member of the People Team to conﬁrm your Parental Leave arrangements,and ensure it is accurately recorded in BambooHR, ideally at least 4 weeks prior to the start ofleave.
We are committed to supporting the well-being of our Rokt’stars, including new mothers who arebreastfeeding. As part of this commitment, we provide reasonable accommodations for
employees to express breast milk. For New York based Rokt’starts, the notice from the
Department of Labor can be found here.
3.2.7. Rokt’star Sabbatical
To celebrate our longer tenured Rokt’stars we launched Rokt’star Sabbatical so that you can takepaid extended leave to go and do what is important to you. More time with family? A travel
adventure? Whatever appeals most to you - we’d love to see some photos while you’re away
enjoying your well earned break! That is why we o er a paid Rokt’star Sabbatical Leave for all
eligible Rokt'stars. The payments and time available will depend on the Rokt'stars tenure with
Rokt and are detailed in the table below.
Tenure Required

Calendar Weeks
Available (to be taken as asingle block)

Payment (% of Fixed
Annual Remuneration“FAR”)

5 years

4 weeks

100%

6 years

6 weeks

100%

7 years

7 weeks

100%

8 years

8 weeks

100%

9 years

9 weeks

100%

10 years

12 weeks

100%

Sabbatical leave needs to be requested and approved by your People Leader and your 2-Up
People Leader, with at least 3 month’s notice so the business can prepare for the time you’re away.
Rokt’stars must be in good standing in order to take Sabbatical leave. Sabbatical leave must be
taken at one time (i.e. as a single block) and can be combined with other types of leave.
During Sabbatical leave:

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●
●
●
●
●

PTO and other statutory leave entitlements will continue to accrue;
Rokt’stars may utilize their Wellness Allowance;
People Leader approval is required to utilize Required Technology Allowance (RTA), or
Level-Up Allowance;
Vesting in relation to employee equity awards will be paused for all periods of sabbaticalleave; andSTIP, sign-on payments and/or commission payments will be adjusted based on the
duration of the leave.

For the purposes of assessing eligibility for Sabbatical leave, tenure is adjusted for part-timearrangements and/or periods of unpaid leave. Tenure calculations will reset to zero once a
Rokt’star utilizes Sabbatical Leave, and in the case of Rokt’stars who leave and rejoin thecompany.
The Rokt’star Sabbatical leave operates as an extension of long service leave entitlements inrelevant geographies. Where regulated beneﬁts are more generous or regulation restricts
enhancing a long-service leave entitlement, then the regulated program will replace the Rokt’star
Sabbatical leave program.
3.2.8. Jury Duty
If you are called to attend a court for jury duty, please record the leave as ‘Jury Duty’ in
BambooHR. Rokt will cover up to a maximum of 5 days or the minimum legal requirement in eachjurisdiction as paid leave. Please present your People Leader with the court summons to record
this leave. You are not expected to work whilst you are attending court.
3.2.9. Rokt Holiday Shutdown
All Rokt o ces close for a period in late December / early January each year so the Rokt team cancollectively enjoy a period of time o where all Rokt’stars are able to unplug, shut down theirdevices, and recharge. Please refer to Public Holidays for information on how this period interacts
with PTO and public holidays.
In 2024/2025, the Rokt Holiday Shutdown will run from December 21st, 2024 through to January
5th, 2025. Where business requirements necessitate, certain teams or Rokt’stars may agree toalternate arrangements during and around the Rokt Holiday Shutdown. The People team and therelevant ExCo member need to be consulted in all cases where alternative arrangements areagreed.

3.3. Unpaid Leave
Periods of unpaid leave may be approved for many reasons, for example, to have the trip of alifetime, build your dream house, pursue further education, care for a loved one, or support a
spousal initiative.
Unpaid leave needs to be approved by your People Leader and your 2-Up People Leader.
During Unpaid leave:

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●

Rokt’stars who receive health beneﬁts will continue to receive these beneﬁts during theirleave but will not be able to utilize Wellness, Required Technology (RTA), or Level-Up
Allowances while on unpaid leave;●●●

Leave accruals will be paused;vesting in relation to employee equity awards will be paused; andSTIP, sign-on payments and/or commission payments will be adjusted based on the
duration of the leave.

3.4. Work Travel
Prior to booking work-related travel, you must get approval from your People Leader, and if
required, your 2-Up People Leader as detailed in Rokt’s travel policy. Please familiarize yourself
with Rokt’s travel and expense policies prior to booking or commencing any work travel.
Once your trip is approved, record your travel dates in BambooHR via the ‘Work travel’ category in
the Time O section. This information is integrated with Rokt’s company calendar and enables us
to better respond and support Rokt’stars in cases of emergency.

3.5. Working Arrangements & Flexibility
At Rokt, we believe in Better Together which is one of our company values - spending meaningfultime together in person improves our ability to solve problems collaboratively, to move quickly, andto support one another. This results in a stronger culture & business and has been a key part of
Rokt's success to date.
All Rokt’stars are expected to work in person, in the o ce, at least four days per week. We support
this by investing in great workspaces and by providing lunches and an array of snacks andrefreshments in the o ce. For locations where we are building a presence and we do not haveenough people to generate the beneﬁts associated with Better Together (apprenticeship andcollaborative innovation) we will have a transition plan that encourages these people to spend
time in other Rokt locations - this applies to locations with less than 10 Rokt’stars. We target
having Rokt workspaces wherever we have more than 5 people in a location. Once a location
grows beyond 10 people we will create a transition plan that will involve more ﬂexibility throughperiods of rapid growth aligned to establishing appropriate great workspaces.
Recognising the diverse and global nature of our team and business, Rokt’stars are eligible to
Work from Anywhere (WFA) for 1 week each quarter, to be taken in blocks of 1 week. To utilize thisbeneﬁt, please submit a leave request in BambooHR using the ‘Work from Anywhere’ category,
which will be approved by your People Leader.
We understand the circumstances of each Rokt’star are unique and for many having some
ﬂexibility in work arrangements (whether occasional, temporary or more permanent) is valuable.
We trust you to be professional, use good judgment (taking into account the needs of your team
as well as your own needs), and clearly communicate regarding where and when you will beworking.
Rokt supports ﬂexible working arrangements, and we will aim to accommodate all requests where
possible. If you have speciﬁc ﬂexibility requirements, please discuss them with your People

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Leader or a member of the People team. While each arrangement must receive speciﬁc approvalby the 2-Up People Leader (such that it works for the Rokt’star, their team and the business),below are some examples of the types of arrangements we have supported in the in the past:
●
●
●

●

Working from a di erent Rokt o ce on a temporary or permanent basis (driven byprofessional or personal reasons).
Working part-time. We have supported this at all levels of the business.
Time in lieu as recognition for a period of intense or out of hours work, or where a Rokt’star
has simply gone above and beyond. This is commonly used when someone wants or needs
to work above and beyond to get a project ﬁnished (e.g. the support team during GKO andthe ﬁnance team during audit/year-end).
Flexible working hours to meet personal or professional needs. This is sometimes related toa role requirement (e.g. to support another time-zone) but also may be due to personalneeds. We try to structure these arrangements such that they still provide for signiﬁcant
overlap in the o ce with your team.

When working outside the o ce, including when WFA, please ensure your team knows how tocontact you and that you are available for important meetings as you would be if you were in theo ce during normal working hours. Please also ensure you have access to excellent WIFI when
you are working from outside the o ce.

3.6. Training and Development (LevelUp! Allowance)Your professional development is important to us. At Rokt we believe the only way we will unlock
the potential of our business is by unlocking the potential of every Rokt'star. It's for that reason we
strive to create industry leading Learning & Development opportunities for every employee. This
ranges from regular leadership training, All Hands sessions, team performance journeys,
executive coaching, renowned guest speakers, an annual company-wide conference (GKO) and aconstantly updated library of onboarding and functional training solutions, and LevelUp!.
The purpose of the Rokt LevelUp! program is to enable Rokt’stars to Raise the Bar in their current
role or in support of a career development ambition. Speciﬁcally, LevelUp! provides Rokt'stars anallowance to engage in external training and development programs of your choice, within certain
parameters, with the approval of your People Leader. How to spend your LevelUp! allowanceshould be determined through thoughtful conversation with your People Leader.
With the approval of your People Leader, each Rokt'star can spend up to the amount speciﬁed inAppendix 1.1 each year on external training or development programs. For one-time programs
that exceed this amount, or for incremental spend above the annual allowance, the approval ofyour 2-Up People Leader is required. Teams may also decide to use their LevelUp! allowancescollectively for speciﬁc team based training.
The Learning & Development team can provide assistance in ﬁnding suitable ways to leverage theLevelUp! Program. The following are eligible expenses under the program: any in person or online
training, books, audiobooks, learning subscriptions, executive or skills coaching, and conferences
related to career development.
Please use your RTA for the purchase of any work tools, such as phones, tablets, e-readers,e-notebooks, productivity software and computers as these are not eligible for reimbursement

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under the LevelUp! program. Similarly, any health & wellness expenses falling under the wellness
allowance guidelines or mental health support should be categorized as such.
Rokt’stars do not need to take PTO while undertaking ‘LevelUp’ training but please ensure you get
approval from your People Leader if you will be unavailable during normal working hours.
Reimbursements for LevelUp expenses should be made in Expensify. Please include a copy of
the approval from your People Leader with your Expensify report. Reasonable travel expenses
related to LevelUp are reimbursable, yet please be mindful and adhere to the general Rokt T&E
policy. If you choose to use your LevelUp budget on a training or resource taking place in thefollowing ﬁscal year, the expense will be deducted from the year that the purchase is made andexpensed.

3.7. Wellness Allowance
To support Rokt’stars remaining happy and healthy, Rokt o ers a monthly allowance (seeAppendix 1.1) that can be used for health and wellness related activities. Common uses of theWellness Allowance include:
●
●
●
●
●
●

Joining a social club with 4 or more other Rokt’stars in your o ce (2 or more Rokt’stars insmall o ces)
Gym membership or group ﬁtness classes
Bicycle sharing schemes such as ‘CitiBike’
Online health classes (Peloton, Yogaworks etc.)
Mental health programs including counseling services (or co-pays), subscriptions such as
Headspace, Down Dog or Simple Habit, or meditation classes
Home exercise equipment and hardware

If you are unsure whether something would be eligible for the Wellness Allowance, please checkwith your People Leader.
Unused Wellness Allowance does not carry over from month to month and reimbursement claims(with supporting receipts) are required to be submitted in Expensify at least quarterly.

3.8. Mental Health Support
Rokt'stars have free access to the Modern Health wellness platform, which o ers extensive
resources to support wellbeing and mental health. This platform is completely conﬁdential.
Rokt sponsors the following for each Rokt'star:●●●●

6 x 1:1 sessions with certiﬁed mental health, professional, or ﬁnancial well-being coaches;
6 x 1:1 sessions with licensed clinical therapists;
Unlimited group support sessions called Circles;
Guided meditations & self-paced digital courses

To access the Modern Health wellness platform:●●

Download the Modern Health app on your mobile device or go to my.modernhealth.com
Sign up with your work email and Rokt as your company name.

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●

Answer a few questions about your well-being, needs, and preferences.

3.9. Required Technology Allowance (RTA)
At Rokt, you have the option to purchase your own work devices, including laptops. The Rokt
Required Technology Allowance (RTA) is provided to assist with the cost of such purchases.
You have the option of whether you decide to take this allowance up or not. In the case where a
Rokt’star decides not to take up this option, then there will be no allowance, and a desktop will be
provided by Rokt.
For countries (UK and Canada) where the personal income tax code requires Rokt to maintainownership in order for the RTA to be non taxable when you are reimbursed - Rokt will maintainownership. All other aspects of the RTA policy still apply. For Rokt’stars in these countries, when
you upgrade your device or leave Rokt you have the option of returning the old device or keeping
it. If you keep the device, Rokt is required to include the market value of the device (at the point intime you decide to keep it) on your tax withholding statements - i.e. this will be reported as income.
Please see the section in Technology and Communications for further details.

3.10. Phone Allowance
Every Rokt'star is expected to have a mobile phone.
Rokt’stars have the option to utilize corporate phone plans in most markets, and can becoordinated by your local O ce Champion. The corporate plan will o er you free roaming,
international calls (in your home country) and all calls during all travel but may require you tochange your current mobile phone provider.
If you have a pre-existing plan, you are not obliged to join the corporate plan, but you are required
to be accessible when traveling. Rokt provides a phone allowance while traveling but you will be
responsible for all charges in excess of this amount. Rokt does not pay break fees for existing
contracts. However, the purchase of a new or buy-out of an existing handset can be claimed
against your RTA allowance.
If you choose not to join the corporate plan, Rokt reimburses the cost of the monthly usage up to
the amounts found in Appendix 1.1. Phone expenses for plan coverage and phone purchase costs
that are billed monthly as part of your plan are covered by this policy.

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4. Compensation and Contracts
4.1. Employment Agreements
All permanent Rokt'stars have an Employment Agreement that details the speciﬁc terms andconditions of your employment. Any changes to your employment arrangements will be
documented by the People Team and communicated to you. Your Employment Agreement and allother relevant documents will be stored in BambooHR.

4.2. Salary and Payroll
All information about your compensation, including pay schedule can be found in the ‘Job’ tab in
BambooHR. You will be given access to the relevant payroll system by the Finance Team where
you can view your payslips.
Rokt strives to pay all Rokt’stars accurately and on time. We also have an obligation to withholdcertain amounts from your paycheck as dictated by applicable state/federal legislation orotherwise required by law. If you have questions about your wages, including any concern that
improper deductions have been made, please reach out to the People Team or Payroll Team.

4.3. Short Term Incentive Program (STIP) and Commissions
Rotkstars may be eligible to participate in a Short Term Incentive Program (STIP) based on theirrole and level as detailed in the Career Ladder. Rokt’s Short Term Incentives including
commissions are separate incentive programs that are detailed in the Career Ladder but arecollectively referred to as STIP.
If you are eligible to participate in a STIP, the speciﬁc details will be set out in your Employment
Agreement (or other document) or Career Ladder and it will be reﬂected in your BambooHR
records. All STIP awards are at the complete discretion of Rokt and are subject to change at any
time. You must be a current Rokt'star to be eligible to receive STIP payments.
In most cases, STIP payments are determined at the end of each ﬁscal quarter and paid on thelast day of the month following the end of quarter (i.e. May 31st for Q1).

4.4. Retirement, 401K and Pension Programs
Rokt o ers pension beneﬁts that vary based on place of employment. These beneﬁts aredesigned to meet or exceed local legal requirements.
●●●

Australia - Super guarantee percentage of monthly salary and STIP contributed to yourdesignated fund for Superannuation, subject to contribution caps.
Canada - Canada Pension Program (CPP) contributions made monthly.
United States - Rokt o ers a 100% match of 401k salary contributions, up to 4% of aRokt’star’s 401k eligible income and subject to government caps. At the end of each year,
Rokt conducts a true-up to ensure each participant has received an aggregate match of the

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minimum of 1) 4% of eligible income and 2) their total employee contribution. Rokt’stars are
required to continue to be employed at the time of the true-up in order to be eligible for it.
United Kingdom - Rokt'stars and Rokt each contribute 4% of the Rokt'star's monthly salaryto their pension scheme with Scottish Widows, subject to caps. Rokt'stars can only opt outof the scheme after joining and are eligible for a full refund of contributions if you opt out
within 30 days of joining.

●

4.5. Long Term Incentive Program (LTIP): Rokt’star Stock Program
We believe ownership is important and so we strive to provide an opportunity for all Rokt’stars to
become owners of Rokt. This is a value we take seriously, and so more than 20% of Rokt fully
diluted stock is held by current and former Rokt’stars (this is over and above shares held byfounders).
The Rokt’star Stock Program, known as the ‘Long Term Incentive Program’ (LTIP) is designed toprovide an opportunity for all Rokt’stars to share in the value created at Rokt. New Rokt’stars will
receive an invitation to participate in the LTIP typically within the ﬁrst 3 months of starting at Rokt.
After 12 months of tenure, Rokt’stars are assessed for annual refresh grants in December eachyear. The issuance of stock invitations and the vesting and other conditions are at the discretion of
the Rokt Board of Directors and the terms and conditions are set out in the Rokt’star Stock
Program Rules.

4.6. Rokt'star Referral Program
We value it when existing Rokt’stars recommend candidates for open roles. Rokt o ers a referralbonus for successfully hired Rokt'stars who you refer. All referral bonuses are paid at the end of
the month following the new Rokt’star’s start date.
Referral bonus payments are only made to Rokt’stars employed at the time of payment insituations where there are no other fees (e.g. recruiter fees) associated with the hire. The following
Rokt’stars are not eligible to participate in the Referral Program:●●●

Level 6+ Rokt’stars;
Members of the recruiting team;
People Leaders for roles that have either a direct or indirect report line to the People
Leader.

Referral bonus amounts are in Appendix 1.1.
To submit a candidate, please use Workable to search for open job postings and submit referrals
directly. You can also track the status of your referrals through the same system. Once a referredcandidate is successfully hired, referrals will be approved and recorded in BambooHR by the
People team. Any referrals recorded in BambooHR will be tracked and paid out as per the above
timeline. If you do not see a referred candidate on your proﬁle in BambooHR, please ask yourPeople Leader or People team to submit a request via BambooHR.

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5. Technology and Communications
5.1. Software Systems
Rokt uses a number of systems that vary by department. We use Google Workspace as our coreproductivity suite, Workday as our ﬁnancial information system and BambooHR as our people
information systems.

5.2. Required Technology
Protecting customer and client information is critical to Rokt’s ongoing success. Therefore a key
requirement when you join Rokt will be complying and agreeing to Rokt’s information security
policies. Below are current minimum requirements for Rokt Required Technology.
Minimum Device Speciﬁcations
Laptops
Department

Engineering, Design, Business
Analytics

All other departments

ModelApple MacBook Pro

Apple MacBook Air

CPUApple Silicon3 required, Apple M2 or above preferred

RAM

24GB RAM

16GB RAM

Storage

512GB SSD storage

256GB SSD storage

Operating System

macOS version equal or newer than two generations back4
Mobile Phones/Tablets●●

Allowed are any Apple iOS and Android devices with operating support provided by the
manufacturer (e.g., availability of regular updates and security patches). A strong
preference is for Apple iOS devices.
Devices must not be rooted or jailbroken and apps must only be downloaded throughthe o cial Stores (e.g., Apple App Store and Google Play Store5). Mobile phones must
be capable of running Rokt apps or mobile-site functionality.

3

The term ‘Apple Silicon’ refers to the ARM-based CPU technology introduced by Apple in November 2020.
Compatible devices are marketed as Apple M1, M1 Pro, M1 Max, M2 Pro, and M2 Max chips. Older Macs
come with an Intel x86 CPU architecture (e.g., Intel Core i5 or i7).
4

Find out which macOS your Mac is using

5

Engineers are allowed to install and test work-related apps outside of these official sources (e.g., Mobile
SDK team).

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5.2.1. Allowance and Reimbursement (RTA)
Eligible Rokt’stars will be given an initial Required Technology Allowance (RTA) on their start date,
and an annual RTA ‘top-up’ will be added to the account to help fund the ongoing costs ofmaintaining and upgrading your required technology at the start of each Rokt Fiscal Year.
Allowances are cumulative, without expiry, and roll over year on year.
For new employees, your ﬁrst annual RTA top up will generally be a pro-rata amount based onwhen you joined Rokt and received your initial RTA allowance (e.g., if you start on August 1st, youwill get the initial allowance at that time; your account then will be topped up with 6 month’s worth(50%) of the annual allowance at the start of the Rokt Fiscal Year on February 1st).
Once you have been employed for more than 12 months, any unused allowance at the time of
employment termination will be paid as a taxable bonus to the individual in their ﬁnal salary
payment. For Rokt'stars who terminate (voluntarily or involuntarily) within 12 months of
employment, any unused allowance at the time of employment termination will not be paid out.
The allowance is also not accessible to Rokt’stars upon the announcement of their termination.
Rokt will reimburse claimable RTA expenses via the monthly expense reimbursement process.
Reimbursements will only be allowed for expenses incurred in the current ﬁnancial year, e.g. you
will not be reimbursed after February 2024 (Rokt Fiscal Year commences on February 1st) for an
expense that was incurred in 2023. Reimbursements will not be paid out until your work devices
are compliant with the requirements in this policy.
Refer to Appendix 1.1 for allowance amounts.
5.2.2. Responsibilities
For Rokt’stars participating in RTA, you will own your equipment and can, for instance, sell it ortake it with you when you leave Rokt. However, this also means you are responsible for the
maintenance and operational ability of the equipment.
Where Rokt provides equipment to you (such as a laptop, keyboard, monitor, printer, etc) that was
not paid for by your RTA allowance (if any), that equipment belongs to Rokt both during and after
your employment. When you leave the organization, all such equipment must be returned to Rokt.
If you do not return such equipment, Rokt will deduct the replacement cost of the device from any
ﬁnal payments (your ﬁnal paycheck, for example) to you or otherwise seek repayment. Thisapplies to equipment provided to both Rokt’stars and Externals.
5.2.3. Fixed Equipment
Any ﬁxed equipment and accessories for use in the o ce (i.e. monitors, cables, keyboards, mice)that may be provided by Rokt must not be removed from o ces. Please contact your local O ce
Champion to inquire about which items your o ce has available. Other accessories should bepurchased using your allowance or out of your own pocket.
5.2.4. Rokt Provided Hardware
While Rokt rarely issued devices, devices provided by Rokt will be replaced approximately every
three years. Please note that Rokt-provided devices are for business use only, and no personal

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data should be stored on them. While devices are insured by Rokt, if a second device needs to be
replaced within a 12-month period, the Rokt’star will be responsible for 50% of the replacementcost.

5.3. Rokt Communications and Meeting Guides
The Rokt ‘Communication’ and ‘Meeting’ guides have been developed to improve how wemanage communications and meetings at Rokt. They include best practices and well-researchedrecommendations for how best to interact across teams, divisions, departments at Rokt, including
when working with geographically diverse teams and/or navigating challenging time zones. We
encourage you to build them into how you work and hope you ﬁnd these useful.
The Rokt Communication Guide can be found in Appendix 2.1,
The Rokt Meeting Guide can be found in Appendix 2.2.

5.4. Content Creation Guide
The Rokt Content Creation Guide summarizes the best practices and recommended structure ofcontent creation at Rokt, and can be found in Appendix 2.3. This ensures consistency acrossteams, departments and geographies, and makes it easier to discover and access content acrossthe organization.

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6. Travel and International Mobility
We ﬁrmly believe that we are better together and that in-person interaction boosts innovation,
creates meaningful relationships, and provides opportunity for apprenticeship. With o ces,
Rokt’stars and partners located around the world, most Rokt’stars will have requirements to travel
for work during their tenure. To avoid risk for the business, Senior Leaders members’ ﬂights are
staggered in a way such that more than 20% of senior leaders are not on the same ﬂight.
We expect Rokt’stars to exercise good judgment (particularly as our policies will never cover all
scenarios) and act as if you are spending your own money. If you need guidance, please discusswith your People Leader before incurring an expense.
The Rokt Travel Policy provides guidance for standard business travel expenses. In addition,certain employees may have Travel and/or Relocation Allowances. If you are eligible for one ofthese allowances, it will be speciﬁed in your Employment Agreement.

6.1. Travel Policy
6.1.1. Flight Costs
When you need to ﬂy, Rokt'stars are expected to use ﬂights that will result in the lowest overall
cost incurred by the business.
Rokt’stars in levels 6 through 8 are eligible to ﬂy Premium Economy, while Rokt’stars in levels 1
through 5 should reference the ﬂight allowances listed in Appendix 1.1. Note that the allowances
reﬂect the roundtrip cost inclusive of taxes, and are dependent on the one-way scheduled ﬂight
time.
United Airlines is Rokt’s preferred airline partner and we have access to promotional rates. Roktalso gets additional value as an incentive from United Airlines as part of this relationship. You may
choose to ﬂy a di erent airline if there is a cheaper and better travel option for your requirements.
To be considered a cheaper option, the alternative ﬂights need to be 25% cheaper than the lowest
United Airlines fare using a Google Flight search.
For travel on United Airlines, your ﬂights will be booked centrally by our internal travel team after
you have received travel approval in BambooHR. For travel on other airlines you should bookdirectly once you have received travel approval and seek reimbursement via Expensify. You must
attach a snapshot of the approval in BambooHR (if applicable) along with receipts as support in
the Expensify report.
If it is not possible to ﬁnd ﬂights within the stated benchmark limits (as set out in Appendix 1.1),
and the travel is not time sensitive, consider traveling at a time when costs are more a ordable.
6.1.2. Accommodation Costs
For group travel, including Induction, GKO and event travel, accommodation will be booked by
Rokt and you do not need to book separate accommodation.

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For other types of travel, you should book your accommodation directly after you have received
travel approval. If you choose to stay with friends or family for multiple nights, you may take yourhosts out for a meal and expense the reasonable costs of this meal. We expect Rokt’stars to
exercise good judgment in these circumstances.
The accommodation allowances are listed in Appendix 1.1. Please note that these allowances areinclusive of tax. If it is not possible to ﬁnd accommodation within the stated limits (as set out inAppendix 1.1), and the travel is not time sensitive, consider traveling at a time when costs are
more reasonable. Particularly for New York City, hotel rates can vary widely from week to week. If
you elect to use your travel allowance or personal funds to upgrade your room or hotel, please
only claim up to the allowances in Appendix 1.1.
Rokt’stars who are attending a conference or event are permitted to stay at the hotel where theconference or event is being held where there are no suitable alternative hotel options, even if theaccommodation costs exceed those listed in Appendix 1.1. In these situations, please exercise
good judgment depending on the rates of the conference hotel and the availability of convenient
alternative accommodation options. If you are in doubt, please check with your People Leader
before booking. Please note you are attending a conference in your Expensify report.
6.1.3. Meals
While traveling for work purposes, Rokt'stars are entitled to claim reimbursement for your meals.
Allowable claims are capped at the daily rate listed in Appendix 1.1 and include taxes and tips.
Please ensure you capture tips, which can be handwritten on an itemized receipt.
Note: Client and Team Entertainment expenses are covered under a separate policy.
6.1.4. Ground Transport
When traveling, Rokt'stars are entitled to claim reimbursement for ground transport incurred forbusiness purposes. Rokt’stars are expected to use any reasonable mode of transportation thatwill result in the lowest overall cost incurred by the business, and where possible, public
transportation is greatly encouraged.
For travel to and from the airport, taxis or ride share services may be utilized where public
transportation is not convenient or practical. Where you are traveling with other Rokt’stars,
including to client meetings, we encourage you to ride together where possible.
When visiting another Rokt o ce, we ask that you travel by public transportation to commute
between the o ce and their hotel, unless it is not practical (please discuss with your People
Leader and request approval in advance where this is the case).
6.1.5. Phone Expenses - International Travel
You are entitled to claim the amount listed in Appendix 1.1 when you are traveling to anothercountry.

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If you are US based and travel overseas often, we recommend that you consider joining Rokt’s
corporate T-Mobile plan (see ‘Phone Allowance’ section). This provides you with unlimited
international calling, data roaming and telephone calls when you are in another country.
6.1.6. Incidental Travel Expenses
Other incidental costs incurred when traveling for work purposes are required to be approved byyour People Leader prior to submission for reimbursement via your expense claim for the month.
6.1.7. Expenses Due to Trip Extensions
If you are required to stay in the city of travel over a weekend and into the next week for businesspurposes, Rokt will reimburse your accommodation costs over the weekend. However, if you
choose to stay additional days in the city of travel for personal reasons, then your accommodation
costs will be at your own expense. Should the associated ﬂight cost for your return at the end of
the extension fall outside the allowed policy, you will be responsible for the di erence.
6.1.8. Non-Expensable Examples
As stated above, we expect Rokt’stars to exercise good judgment and act as if you are spending
your own money. The following are examples of expenses which are non-reimbursable:
●
●
●
●
●
●
●
●

Membership fees to airline frequent ﬂier groups
Fines for tra c violations while on Rokt business
Damages to a Rokt'star’s vehicle while on Rokt business
Loss of, or damage to, any personal property while on Rokt business, including phones,
headphones and laptops (unless covered by Rokt’s Travel Insurance policy)
Purchase of any form of insurance during travel (Rokt has a corporate Travel Insurance
policy as above that includes rental car coverage)
Purchases of clothing and other personal items such as haircuts, toiletries, newspapers,
magazines, tobacco, alcohol etc.
Purchase of in-room movies and entertainment
Medical expenses (unless covered by Rokt’s Travel Insurance policy)

6.2. Travel Approval and Booking
As a general rule we ask that you use common sense and act in the best interests of the business
when booking travel. If your travel dates are ﬂexible, please consider planning your travel when it
is most cost e ective. We also expect Rokt’stars will exercise good judgment and factor in yourtime and productivity when selecting ﬂights and hotels.
We use United Airlines to be our preferred travel partner.
6.2.1. Approval
Where approval is required, travel must be approved before any commitment or booking ismade. The approvals required are based on the total estimated cost of the trip including
ﬂights, hotels, ground transportation, meals and taxes. We ask that all Rokt’stars act as
business owners and make choices about travel expenditure as if you are spending your own
money. No approval is required for day trips.

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Travel approval requests should be made via the appropriate travel approval form which canbe accessed from your proﬁle in BambooHR.
To make the approval process e cient for all, we ask that you include an estimate of the total
trip cost, attach a link to a Google Flights search (excluding any ﬁlters) for estimated ﬂight
costs and note whether hotels or ﬂights exceed benchmark rates. If either ﬂights or
accommodation exceed benchmark rates, consider adjusting travel dates if possible or seekother alternatives.
Total EstimatedTravel Cost (USD)*

ActionBamboo HR
Request FormApprovals Needed

Day trips

Book trip

Travel Day Trip (forbooking United
Flights)

None<=$5,000

Request approval tobook

Travel Standard

People Leader>$5,000

Request approval tobook

Travel High Cost

People Leader &2-Up People
Leader*Includes estimated costs for ﬂights, accommodation, ground transportation, meals andtaxes
Please note for group events where a speciﬁc travel budget is set (e.g. GKO), expenditure above
the budget will not be reimbursable.
6.2.2. Booking Via Rokt’s Internal Travel Team - United Flights
For travel on United Flights, Rokt’s internal travel team will receive a notiﬁcation once your travel
has been approved and will proceed to book your ﬂights directly in order to access discounted
rates, utilize centrally managed payment methods and access incentives from our partners.
6.2.3. Booking Your Own Travel - Accommodation & Non-United Flights
Travel booked directly is subject to the same approvals and requirements. Rokt’stars are required
to use the regular expense reimbursement process via Expensify. If applicable, you must attach asnapshot of the approval in BambooHR along with receipts as support in the Expensify report.

6.3. Relocation Allowances
As a result of our global presence, Rokt may o er opportunities for you to transfer to another Rokto ce, permanently or temporarily. When the relocation is at Rokt's request, temporary andpermanent relocation support is o ered. Both new and current Rokt’stars that request to relocate
voluntarily are typically not eligible for relocation support. Refer to the Rokt Career Ladder for
potential Relocation Allowance amounts.

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When you relocate between Rokt entities, for the purposes of existing allowances and PTO
accruals, you will be treated as if you were terminated in the old Rokt entity and re-hired in the new
Rokt entity. This means that all relevant allowances and balances will be settled in the old entity as
if you were departing Rokt, and you will receive all relevant allowances in the new entity as if you
were a new starter. Your tenure will continue to reﬂect your original hire date so that LTIP vestingand eligibility for the Sabbatical program remain una ected.
6.3.1. Voluntary Relocation Requests
Rokt’stars are welcome to express a desire to relocate to an alternative Rokt o ce. When such
requests are made, we will consider a variety of factors including the business merits, immigration
requirements, level and tenure and performance. Where Rokt is able to support a voluntary
relocation request, the terms and conditions for your transfer will be agreed between yourself, yourfuture People Leader and 2-up People Leader. Voluntary relocation requests are subject toapproval from the relevant ExCo Leader. Rokt’stars are responsible for their own relocation costs
when voluntarily relocating and no allowances are provided, although we will assist with visa
support.
If Rokt agrees to a relocation, the terms of your relocation and new employment details (including
compensation and beneﬁts) will be set out in a new employment agreement. In most instances,
your employment will be subject to the governing laws, entitlements, and beneﬁts of the new Roktlocation.
6.3.2. Rokt Requested Relocation Allowances
Where the relocation is at Rokt’s request, we will provide a Relocation Allowance to be used for
expenses incurred in the relocation. The nature of the relocation will inform the size and form of
the Relocation Allowance, if any.
Employees who are relocating for a period less than 6 months are not entitled to a Relocation
Allowance and the Travel Policy will apply. Relocations for periods between 6 months and two
years, are considered ‘Temporary Relocations’ and Rokt’stars will be entitled to a monthly
Relocation Allowance as detailed in the Career Ladder.
In both of the above scenarios, there is an expectation the Rokt’star will return to their prior role (orequivalent) at their original location at the end of the assignment.
Relocations for periods exceeding two years are considered ‘Permanent Relocations’ andRokt’stars will be entitled to one-time Relocation Allowance as detailed in the Career Ladder. In
these scenarios, there is no expectation the Rokt’star will return to their prior role (or equivalent) attheir original location.
If a Temporary Relocation is extended and becomes Permanent, you may be eligible for an
additional one-time relocation allowance with the approval of your 2-Up People Leader.
In addition to the Relocation Allowance, visa support and one-way ﬂights for you and yourimmediate family to your new location are provided. You are responsible for all other costs relating
to the relocation (e.g. managing your personal tax).

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Permanent Relocation Allowances will be paid as taxable income in a lump sum payment within
the ﬁrst month following the relocation. Temporary Relocation allowances will be paid as taxable
income in normal payroll cycles for the duration of the temporary relocation.
If Rokt agrees to a relocation, the terms of your relocation and new employment details (including
compensation and beneﬁts) will be set out in a new employment agreement. In most instances,
your employment will be subjected to the governing laws, entitlements, and beneﬁts of the new
Rokt location.
6.3.3. Clawback
All relocation allowances, visa related costs and expenses, bonuses, and Rokt borne expenses
will be subject to clawback (as legally permitted) as follows:●●

100% clawback if employment ends within 0 - 6 months of relocation/visa renewal/startdate.
50% clawback if employment ends within 6 - 12 months of relocation/visa renewal/startdate.

6.4. Travel Insurance
Rokt has a group travel insurance policy through Chubb Insurance. This insurance covers the
movements of all Rokt'stars when traveling for business. Speciﬁcally, it covers travel involving adestination ﬁfty kilometers or more from the Rokt’stars normal place of business or residence.
Cover commences from the time you leave and continues on a full-time twenty-four (24) hourbasis until you returnOur insurance covers among other things medical expenses, personal liability, emergency
evacuation, and accidents. If you have speciﬁc coverage questions, please reach out to the RoktLegal Team.
●●

Claim Form
24/7 Emergency Contact number ○ Australia: +61 2 8907 5995
○ Canada: 800-532-4822○ Japan: 0120-320-322○ United Kingdom: +44 203 538 7228
○ United States: 1-800-682-4822

6.5. Visa and Permanent Residency
While Rokt provides support for visa and permanent residency applications, it is yourresponsibility to ensure you have a valid visa and/or right to work at all times.
6.5.1. Visa or Permanent Residency Applications
If eligible, Rokt will nominate you for/apply for a visa required for you to gain or renew employment
authorization. This includes renewal of work authorizations for DACA recipients. Should aRokt’star incur costs related to obtaining the employment pass or visa, you will be entitled toreimbursement.

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Rokt will cover the following costs for you and your immediate family members:
●
●
●
●
●

Visa issuance fees
Visa interview fees
Employment pass application
Employment pass cards
Medical testing related speciﬁcally to the approval of employment passes or visas.

If you want to change your status to permanent residency and subject to the approval of your 2-Up
People Leader, Rokt will cover additional immigration (visa/lawyers/applications) costs up to anallowance maximum (refer to Appendix 1.1). To be eligible for this beneﬁt, you must have beenworking for Rokt for 2 years in the relevant country, be in good performance standing and be
eligible for the visa you wish to apply for.
Costs relating to visa or permanent residency applications may be subject to clawback if you
leave Rokt within 12 months of obtaining the Visa or Permanent Residency and will be detailed ina letter provided by the People team.
6.5.2. Travel related to Visa or Permanent Residency Applications
Unless otherwise agreed, Rokt does not cover travel costs relating to visa renewals or permanent
residency applications unless the Rokt’star is required to travel internationally for work purposes
within six months of visa expiry. In these cases, the Rokt’star should seek to renew their visa
during a work trip when possible (e.g. if the Rokt'star is going to a GKO event within six months ofvisa expiry, then renewal should be done at that point in time).
If you are not required to travel internationally for work purposes within 6 months of your visa
expiry, then you should plan to obtain a new visa stamp during your next personal international trip
and you will be responsible for covering the costs of your visa related travel. Rokt provides
support for visa renewals and PR applications which you can utilize if you have questions aboutvisa related travel.
Rokt’stars are responsible for making their own consulate appointments to renew visas.
Rokt’stars should check wait times for visa renewal appointments and should plan ahead where
possible. To the extent you have any concerns about obtaining a visa renewal, please discuss witha member of the People team.
All visa related travel where you will be working remotely or expensing any travel related costs are
subject to 2-Up People Leader approval and approval by the Chief People O cer. Any costs
incurred by Rokt relating to the renewal of your visa will be subject to clawback per 6.4.3
Clawback. .
Where visa renewal travel is approved, you are expected to work remotely during this time in thetimezone of the o ce they are employed through (and should be recorded in BambooHR as Out
of O ce) or alternatively, the Rokt'star should submit a leave request.

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6.6. Global Kick O (GKO)
Global Kick O is an annual company-wide event where the Rokt team comes together at one
location to bond, learn, and prepare as a team for the upcoming ﬁscal year. The cost of attendanceis covered by Rokt. Further details and requirements surrounding GKO will be provided to you in
writing by the Rokt People Team. Attendance at GKO is mandatory, unless a dispensation isprovided to you in writing by the Chief People O cer and your People Leader, in which case you
may be asked to utilize your PTO/Annual leave for the duration of GKO.

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7. Expenses
7.1. Expenses Platform
Rokt uses Expensify as our expense reimbursement tool.
Expensify allows Rokt'stars to capture expense details as and when they occur. Expensify is set
up so that your expense claims go immediately to your People Leader for approval. Onceapproved, the claim will automatically be sent to the Finance team for review and processing. It is
the responsibility of both the Rokt’star and their People Leader to ensure that expense claims arecomplete and adhere to our policy.
Your submission must include fully detailed receipts and pre-approvals (if applicable). We ask
both Roktstars and People Leaders who approve expense claims, to ensure all expenses haveappropriate supporting documentation and are coded to the proper categories. Expenses should
be submitted within 30 days of the incurrence of the expense. Expenses submitted over 60 days
after the incurrence of the expense may be rejected to comply with local regulations.
Once reviewed by the Finance team for policy adherence, claims will be included in payroll for the
relevant month. Employees are reimbursed monthly and complete and approved expense claims
should be submitted prior to the 10th of each month.

7.2. Submission Detail
While the procedure for the submission and payment of expense claims within Rokt varies region
to region, in general, all expense claims must contain the following details:
●
●
●
●
●

Pre-approvals attached for Travel or out-of-policy items from someone with a ﬁnancialdelegation
Date of expense
Total in original currency, including prevailing local taxes, tips etc.
Name of vendor
Category of expense (i.e.: travel, entertainment, phone etc.)

Certain additional requirements for Australia and APAC regions are required for tax purposes as
outlined in Appendix 1.2.
Only one expense report should be submitted per month.

7.3. Multiple Party Expenses
7.3.1. Client Meals, Entertainment. and Gifts
When meeting with clients, Rokt'stars can claim entertainment costs incurred for both themselves
and their clients within the Rokt approved thresholds listed in Appendix 1.1. These spending limits
include meals and beverages, prevailing taxes and tips. In most instances, Rokt’stars should not

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outnumber clients. Only one team member should submit the claim on behalf of the entire teamand in all cases this should be the senior-most team member present.
Client Meals and Entertainment require the following additional information for expense
reimbursement:●●●●

Tag (i.e.: your team)Business purpose
Name of client (where applicable)
Number of meeting attendees, both client and Rokt'stars (where applicable)

Client gifts are managed centrally by Rokt’s Marketing team. If you wish to arrange gifts for aclient, please submit a ticket to the Marketing Service Desk. Client gifts purchased individually are
not eligible for reimbursement.
7.3.2. Team Building
We believe it's important to facilitate opportunities for teams at Rokt to get together to celebratesigniﬁcant milestones, including when a team member joins or departs, when teammates are
visiting from other o ces, and/or when the team has completed a signiﬁcant project. People
Leaders have access to team building budgets for these occasions which are subject to thethresholds listed in Appendix 1.1. Only one team member should submit the claim on behalf of theentire team and in all cases this should be the senior-most team member present.
7.3.3. Employee Gifts
Rokt provides onboarding, birthday, anniversary and newborn gifts to make our Rokt'stars feelvalued and appreciated, enhance their experience and reinforce our commitment to Enjoying the
Ride! These gifts are managed centrally by the Employee Experience team.
People Leaders should consult a member of the Employee Experience team in your local o ce toarrange a condolence gift if a member of your team, or a member of their immediate family, hassu ered a signiﬁcant injury, illness or loss.
Rokt’stars, at their discretion, may wish to use personal funds to organize a gift or celebration toacknowledge an important milestone for a colleague (e.g. graduations, engagements, weddings,
baby showers, etc.). Rokt’stars are not eligible to expense these gifts for their team members orcolleagues.

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8. People and Behavior
8.1. Personal Details
Rokt’stars are responsible for keeping their personal details and contact information in the‘Personal’ section in BambooHR up to date, including your emergency contact information.

8.2. Professional Development
Your continuing professional development is extremely important to us. We want to provide youwith opportunities to develop broadly, including in areas that may not be a strength for you, as well
as recognize the things you already excel at.
While Rokt has a variety of structures, programs and processes to support the ongoingprofessional development of every Rokt’star, we encourage you to take an active role in managing
your growth and development. In addition to formal performance evaluations and discussions,
you are encouraged to have an ongoing dialogue/discussion with your People Leader, and othersenior leaders in the business, about your development aspirations, needs and achievements,
and pathway for growth. Ultimately, you are the master of your destiny - and we are here to support
it as much as we can, within the parameters of the Rokt business, present and future.
8.2.1. Formal Development and Training
Each Rokt'star is strongly encouraged to meet with their respective People Leader to discuss theirperformance on a quarterly basis at a minimum. The emphasis will be on fostering discussion
between Rokt'star and People Leader and setting key focus areas and goals for the coming 3
months.
These conversations are great opportunities to discuss how you may leverage LevelUp! Programfor external training that supports your development goals.
8.2.2. Informal Development and Training
Rokt has a strong culture of continuous on-the-job learning. As pioneers in our ﬁeld, tacklingoutsized goals in tight timeframes, you may sometimes ﬁnd there is no manual or instruction
book! But ﬁguring things out is often part of the fun! (And maybe you are just the person to write
the instruction guide for the next person coming along.)
The senior leadership team, and your fellow Rokt’stars alike, have a truly diverse and deep rangeof proﬁles, backgrounds, qualiﬁcations, and experiences. We encourage you to get to know otherRokt’stars and their stories - these can provide unique opportunities for personal growth foreveryone.

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8.2.3. Professional Membership Fees
In the case where a Rokt’star incurs professional membership fees relevant to a qualiﬁcation
required to meet their job description, you will be entitled to reimbursement for said fees.
Rokt'stars must obtain their ExCo member’s approval for these fees prior to ﬁrst claiming them.

8.3. Internal Mobility at Rokt
8.3.1. Purpose & Scope
Rokt believes that internal mobility is essential for the growth and development of its employees
and is committed to providing a supportive and inclusive environment for all employees to explore
and pursue new opportunities within the organization.
The purpose of this internal mobility policy is to provide transparency for Rokt’stars and People
Leaders about internal mobility within Rokt. This policy serves to ensure that internal transitions
are managed e ectively, aligning with Rokt’s Career Ladder key principles while supporting
employee aspirations.
This policy applies to all Rokt’stars and outlines: where to ﬁnd internal job postings, eligibility
criteria, application process, selection process, and position transfer procedure. Policy exceptions
require 2-up People Leader and your ExCo representatives approval. This process applies to anyrole change outside the standard performance and promotion cycles.
8.3.2. General Guidelines
All openings can be found on our careers page at https://rokt.workable.com/. All roles that areopen for application (internal or external) will be published here. Rokt’stars are encouraged to
explore internal career opportunities by directly engaging with hiring managers across di erent
teams, without the obligation to inform their current People Leader and disclosure of interest ininternal mobility will not adversely impact your current position.
If you wish to apply for a role internally, it is assumed that you have discussed your intended
application with your People Leader and your People Partner before submitting yourapplication.All applicants (including internal) will be required to complete an interview process.
If you are selected for the position, you will transition into the new role on a date agreed to by yourcurrent and new People Leader coordinated by your People Partner. Most internal transfers will
require a transition period (which will vary based on the role). Transitioning to a new position may
impact your leveling and compensation. Discuss with your People Partner how any potential
transition may impact you.
8.3.3. Eligibility Criteria●

Performance in role: Rokt’stars must be considered in good standing and have received
a minimum of meets expectations rating (or 100+) in their most recent performance cycle.
Employees who are currently completing a performance plan are not eligible to apply forinternal positions until the performance plan is completed successfully.

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If Rokt’star is not meeting expectations, and not on a performance improvement plan(either because one has not yet started or because they have graduated from the planprior to the next performance cycle), they may only be eligible for internal mobility withmutual Exco approval from both the team the individual would be leaving, and the team theindividual would be transferring into.
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Relevant experience: It is highly recommended you meet many of the qualiﬁcations andrequirements of the desired position.

8.3.4. Application & Interview Process
How to apply: After speaking with your People Leader and your People Partner, the process will
be as follows:●●●

Submit an application in Workable: All openings can be found on our careers page athttps://rokt.workable.com/. Please click the ‘apply’ button and follow the prompts.
Connect with a recruiter: A member of the recruiting team will reach out to you regarding
the steps in your recruiting process. They will manage your application in Workable andwill keep you apprised of the process as you progress. If you have any questions in theinterim, you can always reach out to Recruiting@rokt.com or ﬁnd any member of thePeople team to help you identify the responsible recruiter for any open position in advanceof applying.
Update your resume: Please provide an updated resume alongside your application in
Workable. It’s likely you’ve developed skills in your time at Rokt that are not reﬂected inyour original Rokt application!

Interviewing: Internal interview processes may vary from standard external candidate interview
processes. While we strongly prefer to hire from within our company to foster growth, you will beassessed against the requirements for the role. You can therefore expect:●●

Technical or Practical Assessment: these are role dependent and can vary from awriting sample to a presentation to a coding or design assignment.
○ For engineering roles involving coding and system design, internal candidates are
required to undergo interviews with trained assessors. These interviews will utilize
assessments distinct from our standard external assessments to ensure a fair andspecialized evaluation process.
2Up or senior leadership meeting: as all hires require 2Up approval you will meet withboth the hiring manager and the 2Up People Leader as part of your process.

Note: you will not be required to retake the CCAT or complete the Bar Raiser.
Interview Feedback●

Feedback: All feedback will be managed directly by the recruiting team and shared withcandidates at the completion of the interview process.

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Evaluation: All candidates are evaluated on their skills, qualiﬁcations, and overall ﬁt forthe job position. Note: time and performance in your current role may be considerations forsuitability.

If you are successful●●

Job o er: A formal job o er will be presented to you, including all relevant details about
the position, responsibilities, and changes to your current terms of employment.
Transition Plan: Once the job o er has been o cially accepted in writing, you are
expected to work with your current department and People Leader to create a smoothtransition plan. You are expected to communicate the transition to relevant teams andensure a seamless handover of your responsibilities.

8.4. Organizational Structure Guidelines
Rokt aims to keep its organization ﬂat to allow for faster communication and decision making. As
such, we apply the following organizational structure guidelines wherever possible:
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●

●

Teams (People Leader and direct reports) of less than 5 people are actively avoided.
We aim for People Leaders to have between 6 and 10 direct reports.
People Leaders own the day-to-day people issues of hiring, performance management,
onboarding and o boarding (leveraging the support of the 2-Up People Leader, where
relevant).
There can be a functional directly responsible individual (DRI) that provides the day to day
direction to coordinate a set of activities (e.g. a big client, project, skill specialty - legal ordesign) that sits outside the people management structure.
Generally, we avoid dual and dotted reporting lines as they slow down decision making
and create a need for a lot more coordination.

We prioritize having local People Leaders which sometimes means these organizationalguidelines can not be met.
8.4.1. Rokt Career Ladder
Rokt has a transparent and ﬁxed Career Ladder. This means that any Rokt’star can see thecompensation and career expectations for every role in the company and can feel conﬁdent they
are remunerated fairly. We decided to do this because we believe that being transparent serves
two purposes for us:
1. It makes outcomes fairer. Two individuals doing the same role in the same location receive
the same remuneration. When we adjust remuneration, both existing and new Rokt’stars
doing the same role will get the same adjustment.
2. We avoid the noise, distraction and negotiation that commonly occurs whencompensation is a ‘secret’ or obscure. We hope the Career Ladder gives each Rokt’star
clarity in what you need to do to advance in their careers and it focuses e orts on personal
development.
Rokt is a company that prides itself with looking from within ﬁrst as it looks to ﬁll new
requirements. Our Career Ladder, which includes remuneration and requirements for all standard

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roles, is open for all Rokt’stars to view and visualize their next career step, remuneration and thesteps required to achieve it.
The Career Ladder is usually updated quarterly and available on the shared Google Drive‘Published Policies’.

8.5. Performance Management
Performance management is a continuous process of improving performance by setting clear
performance expectations (that are aligned to the goals and strategic plan of the organization),
reviewing and assessing progress, and developing Rokt’stars to deliver against these
performance expectations.
When you are not performing at your best, it can impact your job satisfaction, Rokt, your morale,
and the morale of others. Rokt recognizes that for any number of reasons there may be times
when your performance or conduct may fall below our expectations. We are committed to the
support and development of our Rokt'stars and as such, all issues surrounding performance,
conduct or capacity that require improvement will be proactively addressed. Performance
management is one of the more formal feedback mechanisms we use to ensure you know how
you are performing to assist you to reach your potential.
For the purposes of this policy, performance management focuses on managing sub-par
performance relating to work, acceptable and unacceptable behaviors, and misconduct.
This policy applies to all Rokt'stars and outlines the steps that we will take in the case where yourperformance or conduct does not meet Rokt’s expectations.

8.6. Performance Review Cycles
The purpose of the Performance Review cycle is to ensure that the objectives, contributions, anddevelopment of our Rokt’stars are aligned with organizational goals and the overall performanceof Rokt. It is also a great time to have a focussed conversation with your People Leader about yourpersonal development and career goals (although we encourage these to always be ongoing as
per Professional Development section).
At Rokt, performance is assessed two times per year - at the end of our ﬁrst and third quarters (i.e.
April, and October). Rokt’stars and their People Leader each reﬂect on the previous 6 months andinput those reﬂections into the Culture Amp Performance Management Platform. People Leaders
also record their team member’s performance in Culture Amp. Rokt holds People Leader
Calibration sessions twice per year to ensure performance is being assessed consistently andfairly across the whole company. For any promotion recommendations, we require People
Leaders to collate feedback from other Rokt’stars who work closely with the individual as part ofthe submission.
Outside of these cycles, Rokt'stars can initiate documented feedback requests through Culture
Amp at any time. The feedback can be kept private for each Rokt'star to review, or you can choose
to share this feedback with their People Leader.

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8.7. Rokt’star Behavior
At Rokt we enjoy coming together to connect and do business. In addition to day to day workplaceinteractions and meetings or calls, we host regular All Hands Meetings, end of week celebrations(including Duck Friday in Sydney) and TGIF (Thank Goodness it is Friday) in New York), end ofquarter events and an annual, whole team Global Kick O event.
Rokt expects that all Rokt’stars will conduct themselves in a professional and respectful mannerat all times when interacting with others (internally and externally) and when managing
colleagues. All Rokt’stars should consider their own behavior and the impact that this can have onothers. Rokt has a framework of 8 company values (Start with the customer; Own the outcome;
Bias for action; Conquer new frontiers; Raise the bar; Be smart with humility; Better together; andForce for good) and associated behaviors we expect to be displayed and adhered to in our
workplace community. Details can also be found in the Career Ladder document distributed to all
Rokt’stars internally and updated each quarter.
8.7.1. Romantic Relationships at Work
It is extremely important that all Rokt'stars feel safe and comfortable at Rokt. We do not prohibit
romantic relationships. We understand the workplace can be a common place for friendships andrelationships to arise, and there are Rokt’stars who are in appropriate consensual relationships.
If you are in, or enter into, a consensual relationship with a colleague, you are required to notify the
People Team, who will keep it conﬁdential and only share with others as necessary. We need to beaware so we can handle any potential conﬂicts of interest.
People Leaders are not permitted to initiate romantic relationships with a direct or indirect report.
Pre-existing relationships that are disclosed are allowed. If you are unsure about how to navigate asituation, talk to the People Team.
We expect our Rokt'stars to treat each other with respect. If you want to express your interest in acolleague, it is important to ensure you do not do so in a manner that would embarrass or pressure
them or invade their privacy. It is also essential that you respect their choice if they decline youroverture or otherwise suggest, directly or indirectly, your interest is not reciprocated. At Rokt, you
may express your romantic interest to a colleague only once and if they do not responda rmatively, you may not ask again.
If a colleague is persistent about initiating a romantic relationship with you, you should feel free tomake it clear to them that you are not interested and inform your People Leader and/or PeopleTeam. If you feel in any way uncomfortable about the unwanted approaches, please reach out tothe People Team and/or your People Leader for support.
You should immediately alert the People Team and/or your People Leader if anyone at Rokt or aperson in the workplace makes unwanted sexual advances to you or a colleague. Sexual
harassment is prohibited and is subject to disciplinary action. For more details on what constitutes
sexual harassment and how to report it, please refer to our Bullying and Harassment policy.

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8.7.2. Unacceptable Behaviors
Rokt does not tolerate unacceptable behavior (including bullying, harassment, and retaliation) in
any form. Unacceptable behavior may involve actions, words or physical gestures that could
reasonably be perceived to be the cause of another person’s distress or discomfort. Bullying or
harassment may be by an individual against an individual or involve groups of people. Roktdeﬁnes behavior as being unacceptable if:●●●

It is unwanted by the recipient,
It has the purpose - or e ect - of violating the recipient’s dignity and/or creating an
intimidating, hostile, degrading, humiliating or o ensive environment; andConsidering the totality of the circumstances, including the recipient’s perception, it was
reasonable to expect the behavior to have that e ect.

Unacceptable behavior is not limited to face-to-face interactions. It may take many forms, such as
written, telephone or e-mail communications, the sharing of images, communication during video
calls, text/chat messages or through social media (including communications with third-parties).
Any external party (i.e. someone who is not an employee of Rokt, e.g., a customer, a supplier or avisitor) who behaves in an unacceptable manner should be reported to your People Leader and amember of ExCo immediately. They will determine an appropriate course of action to deal with theissue alongside the People Team.
Some examples of unacceptable behavior include but are not limited to:
●
●
●
●
●
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●
●
●
●
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Aggressive or abusive behavior, such as shouting or personal insults
Spreading malicious rumors or gossip, or insulting someone
Discrimination or harassment when related to a protected characteristic
Unwanted physical contact
Stalking
O ensive comments/jokes or body language
Publishing, circulating, or displaying pornographic, racist, sexually suggestive, orotherwise o ensive material or pictures
Isolation, deliberate exclusion, and/or non-cooperation at work
Persistent and unreasonable criticism
Unreasonable demands and impossible targets
Coercion, such as pressure to subscribe to a political or religious belief

8.8. Serious Misconduct
Rokt may decide to immediately terminate your employment without performance management
should you participate in an activity classed as serious misconduct. Termination of employment
for serious misconduct will result in the discontinuation of your participation in the Rokt’star Stock
Program (in accordance with the Plan Rules), among other things. ‘Serious Misconduct’ isregarded as misconduct that involves one or more of the following:●●

Willful or deliberate behavior that is inconsistent with the continuation of the contract of
employment,
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●Conduct that causes a threat to the reputation, viability or proﬁtability of our company.

The following actions may, given the speciﬁc circumstances, constitute serious misconduct (thelist is not exhaustive):
●
●

●
●
●
●
●
●
●
●
●
●
●
●
●
●
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Failure to utilize 2-factor authentication on work email systems,
Breach of conﬁdentiality or data security, including the unauthorized disclosure of Company
business to the media or any other party (this rule does not apply to making, in good faith, aprotected disclosure (whistleblowing),
Unauthorized access to or use of computer data or computer hardware,
Unlawful discrimination, harassment or bullying (refer to the Bullying and Harassment
Policy),Theft, dishonesty and/or fraud,Fighting, assault, act of violence or aggression,
Unacceptable use of obscene or abusive language (including language of a discriminatory
nature),Gambling, bribery or corruption (refer to the Anti-bribery and Anti-corruption Policy),
Consumption of illicit drugs (other than medically prescribed drugs) or being intoxicated(with either illicit or legal substances) during working hours,
Willful damage to Rokt's property or the property of its Rokt'stars or clients, suppliers orbusiness partners,
Falsiﬁcation of records or other Company documents, including those relating to obtaining
employment,
Serious insubordination,
Refusing to commit to a lawful and reasonable instruction that is consistent with yourcontract of employment,
Serious breach of Rokt's policies or procedures,
Bringing Rokt into disrepute,
Serious negligence which causes or might cause unacceptable loss, damage or injury; orConviction of a criminal o ense (except for minor road tra c o enses) that impacts on yoursuitability to do your job or your relationship with Rokt, your work colleagues or Rokt's
clients, suppliers or business partners.

8.9. Communication of Issues
If you are having problems at home or work which are a ecting your ability to perform, we
encourage you to talk to us about it.
Similarly, if you are unclear about our expectations and standards, please speak to your People
Leader or People Team partner. We would prefer that you come to us so we can do what we can tohelp you to understand our business expectations.

8.10. Breaches and Reporting
Everyone has a responsibility as part of their employment to adhere to our policies. If you areconcerned that a policy has been breached, you should report your concerns to your People
Leader or People Team partner.

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Please refer to the Grievance Policy for the process and procedures that may be followed to
manage breaches of this policy.

8.11. Code of Conduct
Rokt aspires to conduct its business in accordance with uncompromising ethical standards
and in full compliance with all laws and regulations. Accordingly, we expect all Rokt’stars to
act responsibly and with integrity. This includes an expectation that all Rokt’stars are familiarand comply with the Rokt Code of Conduct set out below.
8.11.1. Drug and Alcohol Use
We want to promote a safe and productive working environment for all Rokt’stars. This policy
outlines our expectations for behavior at the workplace, during onsite and o site events and while
traveling for work, and clearly deﬁnes our expectations for Rokt’stars related to alcohol, smoking
and drug consumption. Rokt’stars who are found to have violated any of these policies are subject
to discipline up to and including termination.
Whenever Rokt’stars are working on Rokt premises or are conducting company-related worko site, you are prohibited from:●●

Using, possessing, buying, selling, manufacturing or dispensing an illegal drug.
Being intoxicated, whether from alcohol, cannabis or other recreational drugs or any illegal
drug.

Any illegal drugs or drug paraphernalia found in or on any Rokt property or leased event space will
be turned over to an appropriate law enforcement agency and may result in criminal prosecution.
At Rokt sponsored events, everyone has a responsibility to promote a safe and productive work
environment. Where alcohol is served, Rokt’stars are expected to exercise good judgment andconsume alcohol responsibly. Rokt does not tolerate conduct that is inappropriate, endangers thesafety of others, or violates internal Rokt policies or the local laws. Excessive consumption of
alcohol, as well as underage consumption, is not permitted when you are attending a Rokt-related
event, whether onsite or o site.
People Leaders are responsible for ensuring that company-sponsored events, whether onsite oro site, are safe. People Leaders are expected to ensure teams are aware that excessive drinking
is not permitted and to discourage overconsumption, as well as to address inappropriate conductthat violates our policies. The People Team also has a responsibility to respond if they are awareof excessive drinking or other behavior that is a violation of policy.
Smoking (including cannabis) is prohibited in any part of the o ce (including outdoor rooftops or
terraces) at all times. This includes the use of devices that resemble and operate like an actual
cigarette, including but not limited to cigarettes, cigars, e-cigarettes or other vapor smoke devices.
Rokt’stars who violate the code of conduct may be subject to discipline up to and including
termination and, in certain situations, may be subject to civil or criminal penalties. Rokt’stars must
notify the Chief People O cer of any violation occurring in the workplace. Upon conﬁrming a

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violation took place, Rokt may discipline the o ending Rokt’star and/or require the Rokt’star toparticipate in a rehabilitation program.
8.11.1.1. Potential Actions
Each Rokt’star is expected to play a role in creating a safe workplace culture. If you see orexperience something that doesn’t feel right, please speak to either a member of the People
Team, ExCo, or your People Leader.
Additionally, if we have reasonable suspicion that a Rockstar is under the inﬂuence of drugs
and/or alcohol and such inﬂuence could adversely a ect the Rokt’star’s job performance oranyone’s safety, we may be entitled to request an alcohol and/or drug screening for the Rokt’star
as allowed under local law.
8.11.1.2. Resources Available to Rokt’stars
We recognize that drug, alcohol or substance addiction can be an illness. Rokt has resources tohelp, including referrals to drug counseling services, rehabilitation programs and other employee
assistance programs. If you are in need of any of these services, please connect with the PeopleTeam.
8.11.2. Other Policies
In addition, all Rokt’stars are subject to the following policies:
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Anti-discrimination and Equal Employment Opportunity Policy
Bullying and Harassment Policy
Grievance Policy
Workplace Safety Policy
Anti-bribery and Anti-corruption Policy
Anti-slavery and Human Tra cking Policy
Compliance with Laws
Conﬂict of Interest

In any instance when a Rokt’star displays unacceptable behavior, please report the matter to yourPeople Leader or a member of ExCo so that an appropriate course of action can be taken. (SeeSerious Misconduct above).

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9. Exiting the Company
Rokt is growing fast and sets a high bar on performance and behavior. Our core ‘why’ is to unleash
potential - so we work hard to ensure every Rokt’star is set up for success. For most, this will mean
a lot of growth and success at Rokt - however for some there will be better paths elsewhere andthis is OK. When this happens, we do our best to set up the departing Rokt’star for success inwhatever they do next.

9.1. Principles
We apply the following principles when a Rokt’star departs the business:
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No surprises: Exits should not come as a surprise to the individual. All Rokt’stars should
understand how they are performing and what is expected of them. Rokt will actively
explore other options when Rokt’stars are struggling to meet the requirements of theircurrent role. People Leaders should not avoid di cult conversations.
Lead with Empathy: Compassion and respect are important as they enable departing
Rokt’stars to move on with dignity. Be clear and transparent on the reasons for termination.
Respect their privacy when they depart.
Fair: Fairness and consistency is important to ensure that we treat people in the sameway.
Communicate with your team: Ensure you communicate the departure to the respective
teams that the Rokt’star worked with. Be straightforward while also respecting thedeparting individual’s privacy.
Partner with your People partner: Enlist your People partner to help you manage theprocess and answer questions as they arise. Your People partner should always be in theroom when you are terminating someone - this helps both the departing Rokt’star and theirPeople Leader.

9.2. Types of Exits●●●

Involuntary With Agreement: A Rokt initiated termination or redundancy where we enter
into a separation agreement.
Involuntary Without Agreement (For Cause): Rokt initiated termination for cause and/or
where we cannot agree to separation conditions.
Voluntary: Rokt’star initiated resignation

9.3. Involuntary With Agreement
Rokt aims to create a fair and respectful experience for Rokt’stars at all times, including when they
are leaving Rokt. We understand that some decisions to leave are initiated by Rokt, and in thosesituations we are going to try and help create a bridge for the departing employee to ﬁnd their next
opportunity. In this process, we also want to ensure we create the least amount of disruption to therest of Rokt.

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9.4. Involuntary Without Agreement (For Cause)
Our objective is to avoid these types of exits. However, in rare cases we have situations where weneed to terminate for cause and/or we can not reach an agreement on terms of separation.
Employees should review the rules of the Rokt’star Stock Program to understand the implicationsof a for cause termination on any equity grant a departing employee may have received.

9.5. Voluntary Exit
Should you make the decision to resign from your role at Rokt, please provide a letter ofresignation to your People Leader and the People Team within the timeframes in youremployment agreement.

9.6. Final Arrangements
On or prior to your ﬁnal day, the People Team will conduct an exit interview, and we will ask you tocomplete a brief survey. The in-person conversation will help us learn about your experience atRokt, as well as help you manage beneﬁts transition and any of the requirements to ensure asmooth transition for all parties.

9.7. Final Payment and Expenses
The payment of ﬁnal wages, expenses and any other adjustments will be completed via standard
payroll, on the last working day of the month, unless the local labor laws of your country or state of
employment require a di erent arrangement.
If you have incurred any expenses during your ﬁnal month of employment that are claimable under
Rokt’s Expense Policies laid out in the Technology or Travel sections, you must submit your claim
report via Expensify to obtain your People Leader’s approval prior to your last working day.

9.8. Rokt’star Stock Program
If you have any vested equity you are considering exercising, and are still eligible to so according
to program policies, please contact your Finance and People Team representatives for next steps.

9.9. Contact Information
Please ensure your personal contact information (email, phone and mailing address) is updated in
BambooHR and Carta before you depart so you can access payslips, year-end tax statements(where applicable) and details of any vested equity (where applicable). This will also ensure Roktcan communicate with you in the future regarding any potential transactions or events impacting
your vested equity.

9.10. Technology and Security
If you have any existing software subscriptions under Rokt’s name, you must ensure the license
keys are removed from your computer and phone before you leave. Any Rokt phone plans must

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be canceled, and access passes to Rokt buildings must be handed to the O ce Champion or
People Leader before you leave.

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10. Rokt People Leaders
We take leadership really seriously at Rokt. When you take on People Leadership responsibility,
your impact signiﬁcantly increases. As such, we want to ensure our People Leaders are set up for
success. We have created this guide to ensure that we treat all our Rokt’stars in a consistent andfair way, while empowering our People Leaders to independently act when managing people. If
you are unsure of any aspect of your managerial role or need to seek clariﬁcation, you should
contact a member of the People Team.

10.1. Principles Behind Rokt’s Approach to People Leadership
Understanding some of the key principles often provides more guidance - than policies - when
dealing with People Leaders' discretion and how to deal with unique situations that leading people
inevitably leads to.
10.1.1. People First
People Leaders should always put people ﬁrst when thinking about the right way to handle asituation. At Rokt, this means treating people in the same way that you would want to be treated with respect, directness, fairness, honesty, and transparency. This does not mean compromising
Rokt’s mission or drive to achieve results.
New people leaders may confuse this with guidance to always deliver good news when providing
feedback. However, this approach is misguided because it can deny Rokt’stars actionable anduseful feedback which will help them become the best version of themself - and ultimately this is
not people ﬁrst.
10.1.2. We Thrive Together
As a global organization, one of the toughest things to manage is bridging the tyranny of distancethat exists between our various teams and o ces. We have an ambitious vision and, to make it areality, we need to solve a lot of complex problems. This is a problem for any global organization
but for one moving as fast as Rokt it can be an outsized challenge.
Bringing people together as much as we can ensures people have the opportunity to learn, build
relationships and develop empathy for others. It also strengthens our culture and performance asa business. This is why we invest heavily in opportunities for Rokt’stars to come together as often
as possible and why we do not support full-time work from home.
This principle also ensures we operate in a way that is fair and equitable across teams andregions. We realize when teams operate to di erent standards it creates tension and means
people are less likely to go the extra mile for each other.
10.1.3. Show, Don’t Tell
One of the most important aspects of leadership is the example you set. Telling people to dosomething (e.g. follow these policies) but not demonstrating the same behavior yourself is a

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recipe for a cynical, disengaged and poorly performing team. Your team will learn what ‘great’
looks like by watching you - so every word you say and action you take matters.
10.1.4. Relentlessly Evaluate Leadership
Building teams and developing people is a continuous process that happens at both the macroand micro levels of Rokt, day in and day out. It also takes courage and focus to give honest
feedback about where Rokt’stars are succeeding, and where they may need to improve. It’s
important to have the courage to act if such improvement is not forthcoming. Rarely does a teamor a people problem ﬁx itself and we expect our People Leaders to be courageous and decisive.
People Leaders should be self aware about their own strengths and areas for improvement when it
comes to leading teams and people. It takes a willingness to acknowledge that if the team is not
functioning as well as it might, the problem may lie not with the team, but with your ability tomotivate and direct the team as e ectively as possible.

10.2. People Processes and Approaches
At Rokt, we have two tiers of people that can access our core systems:
1. Rokt’stars: Rokt’stars are internal team members. Rokt’stars are treated the sameirrespective of employment instrument - full-time Rokt’stars, part-time or contractors.
2. Externals with Limited Access (Embedded Externals). Embedded Externals require
access to our o ce and/or systems as part of the services they provide to Rokt (e.g. IT
support, recruiters, etc.). Embedded Externals are a valuable part of the broader Roktbusiness but do not participate in a lot of the Rokt training events (e.g. GKO andinduction), do not need Sensitive System Access and will not be People Leaders.
Sensitive System Access is deﬁned as admin access to any system, access to client data,or access to developing environments for our core systems. Anyone who requires
sensitive system access should go through the full Rokt’star process.
We have people processes that span from hire to exit and are relevant for every Rokt’star at somepoint during their time at Rokt. For Rokt’stars, our approach is agnostic to the employment
instrument, structure, or location of the role. We believe this is critical to preserve and build theculture we all love at Rokt.
There are two broad concepts we use for the approvals in our people processes to ensure we can
execute quickly but also maintain and build our capability:●

2-Up: All people management decisions must involve a discussion with, and approval from,the 2-Up People Leader. A 2-Up process essentially means that if you are the direct People
Leader for a Rokt’star, when making signiﬁcant people decisions (including hiring,
performance management, terminations, etc.) you must discuss and get approval from yourimmediate People Leader. We do this so that our People Leaders get the opportunity toreceive advice from more senior people leaders, and so develop into better People Leaders
themselves with practice and mentorship through real situations. This also ensures thatsigniﬁcant people management decisions always involve more than one person.

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●

Bar raiser: Bar raisers are senior managers across the business who have been trained toensure that every person we bring into Rokt increases the capability of the team, and thatrole levels are being applied uniformly across Rokt. We do a bar raiser interview for every
new hire into Rokt. The bar raiser interview is conducted by someone outside of thedepartment of the role the candidate is applying for.

For those in the External Embedded category, an ExCo interview is done to check for alignment tovalues instead of a bar raiser interview. Other recruiting and onboarding processes are the same including background checks.
In addition to External Embedded, Rokt engages other External Service Providers to provide usservices who typically do not require access to our o ces or core systems to perform these
services. In general, these External Service Providers are engaged through an entity (vs. as anindividual contractor) and have a tightly deﬁned scope of work and delivery timeframe (e.g.
penetration testers, auditors, brokers, travel agents, etc.). Rokt undertakes a diligence process
before engaging any External Service Provider and Legal reviews and signs o on the contractual
terms of these engagements. Unless an individual employed by one of Rokt’s External Service
Providers requires access to our core services, and therefore is classiﬁed as an External
Embedded, background checks and values interviews are typically not required.
10.2.1. Rhythm and Frequency of People Processes
Generally speaking, People Leaders should think about people management as a daily task - notsomething that you do twice a year before formal performance evaluations - but rather the
fulﬁllment of a mutual contract with our Rokt’stars. This mutual contract is one where our
Rokt’stars commit to building Rokt’s success and where we (as People Leaders) commit to
helping them grow and support their development
In addition, People Leaders are encouraged to discuss and review individual development plansand objectives (e.g. detailing growth and performance objectives using SMART Goals) with teammembers as often as makes sense for the individual.
We also encourage our Rokt’stars to be the CEOs of their own career, seek out development
conversation time with your People Leader and request whatever feedback and resources youneed to be successful in your role, to meet your ambition for growth.
More detail on the frequency and cadence of formal People Processes can be found in the‘Performance Review Cycles’ section.
10.2.2. Setting SMART Goals
All performance expectations should be set using the OKR framework to deﬁne what ‘success’
looks like for the individual team member. Once determined, all objectives should be written as
SMART objectives:●●●

Speciﬁc: we need to reference a speciﬁc result we are trying to achieve,
Measurable: the outcome needs to measurable in an objective way,
Agreed: agreed with the People Leader and 2-up People Leader.

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●
●

Realistic: not easy, should include stretch but they need to consider resourcing and otherrequirements and objectives; andTime bound: these need to be delivered by a speciﬁc date and the measurement period
should also be speciﬁed (by default we use the end of quarter as the delivery date and thelast month as the measurement period).

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11. Appendix
11.1. Appendix 1.1 - Expenses and Allowance Amounts
We expect Rokt’stars to exercise good judgment (particularly as the policy will never cover all
scenarios) and act as if you are spending your own money. All amounts are inclusive of tax unlessotherwise stated. Refer to the relevant sections for more details.
US
(USD)

AU
(AUD)

NZ
(NZD)

CA
(CAD)

UK
(GBP)

JP
(JPY)

$3,000$3,000$3,000$3,000£2,000¥300,000$5,000$5,000$5,000$5,000£3,500¥500,000- In the US we have a corporate plan that you
can access

$50

$50

$89

$50

£35

¥5,500Social/wellness allowance per month

$75

$75

$75

$75

£58

¥7,895

Allowance
Referral bonus- Rokt’stars L1 to L5C are eligible for Referralbonuses. Referral bonuses are based on thehome o ce of the referring Rokt’star.
- People Leaders are not eligible for referralbonuses for direct and indirect reports

LevelUp! per annum
Mobile phone allowance per month

T&E policy (Budgets based on the destination of your travel)
Accommodation per night- Inc tax. Note that some locations andwebsites initially quote the rate excluding tax

Mileage reimbursement- When using own car, per km

Travel meals per day- Including tax and tips

$400

$350

$350

$350

£300

¥40,000

IRS

ATO

IRD

Canada.caGOV.uk

¥60

$100

$100

$100

$100

£70

¥10,000

$5

$5

$5

$5

£4

¥600

$120

$100

$100

$100

£80

¥10,000

$80

$80

$80

$80

£60

¥8,000International phone allowance per day- Note for US we have a company plan and canprovide a SIM if you are regularly traveling to
the US

Client meals and entertainment perperson- There should be more clients than Rokt’stars

Team building per person per quarter

Return Flight Benchmark and 'in policy' amounts (ﬂight duration as scheduled each way)
Levels 2-5 (economy seats)< 7 hours

US$1,000 return / US$500 one way

7 - 12 hours

US$2,000 return / US$1,000 one way>12 hours

US$3,000 return / US$2,000 one way

Levels 6+ (premium economy seats where available)*

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Allowance

US
(USD)

AU
(AUD)

NZ
(NZD)

CA
(CAD)

UK
(GBP)

< 7 hours

US$1,500 return / US$750 one way

7 - 12 hours

US$3,000 return / US$1,500 one way>12 hours

US$5,000 return / US$2,500 one way

JP
(JPY)

Required Technology Allowances (RTA) by Function
Engineering, Design, Analytics, and/or Level 6 and above
RTA Initial Allowance$2,700$3,600$3,900$3,600£2,300¥340,000

RTA Top-up Allowance$1,350$1,800$1,950$1,800£1,150¥170,000

RTA Initial Allowance$1,550$2,200$2,500$2,200£1,450¥200,000

RTA Top-up Allowance$775$1,100$1,250$1,100£725¥100,000$10,000$10,000$10,000$10,000£7,000¥1,000,000

All other departments

Permanent Residency Costs
Allowance*Use economy benchmark rates if premium economy seats not available

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11.2. Appendix 1.2 - Additional Expense Reimbursement Requirements
11.2.1. Additional Requirements - Australia
Receipts for expenses >$75AUD (pre-GST) must be ‘tax invoices’ which meets the below
characteristics in order to be reimbursable:
●
●
●
●
●
●

Words identifying that this is indeed a tax invoice (usually just these 2 words),
The seller’s identity,
The seller’s Australian business number (‘ABN’),The date the invoice was issued,
A brief description of the items sold, including the quantity and the price; andThe GST amount (if any) payable (can be shown separately, or if the GST amount is exactly
1/11th of the total price, as a statement such as ‘Total price includes GST’

For Fringe Beneﬁt Tax (FBT), you must include details of meeting attendees and receipt split
between clients and Rokt’stars in the detail section of Expensify, for all client and Roktstar’s
entertainment costs incurred. For example:●●

You should put the following in the detailed description of the cost: ‘Meeting with David
Jones, 2 x Rokt attendees + 2 x DJs attendees’
You should ensure you split the categories of this cost in Expensify between ‘Client
Entertainment’ and ‘Employee Entertainment’.

11.2.2. Additional Requirements - APAC
APAC Rokt’stars (Australia and Japan) will need to include the following information in the tax
ﬁelds when preparing expense reports.
●●

For expenses incurred in foreign currency, select "GST free expenses / No tax".
For expenses incurred in local currency,○ if GST was charged, select "GST on expenses / Tax on purchases"

If GST was not charged , select "GST free expenses/ No tax".

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11.3. Appendix 2.1 - Rokt Communication Guide
Using the right channel for communication helps everyone be more e ective and e cient. As a
globally distributed business, we rely heavily on digital communication methods. That said, where
it is an option, we encourage people to communicate in person or via video call as we are all Better
Together.
11.3.1. When to use Email vs Chat vs Direct Message
Email is a more formal communication channel where it is expected that people read messages
thoroughly and action requests. It is most e ective when you are clear about the timeframe inwhich you need a response. Emails should be used for important announcements, requests,
approvals, and items that require action.
Group Chat Spaces (Chat) are more informal and are best used for collaboration, social, andin-the-moment communication between colleagues. Chat is especially useful if you are looking to
get feedback or to spark discussion around a topic for those who may be interested, or theaudience of your message is less deﬁned. Additionally, chat may be an appropriate venue where
you want to make broader announcements to people outside of your team, but where the formalityof email is not needed or desired.
Di erent people consume chat content di erently, and this should factor into your choice of whichchannel to use. For some, chat is an always-on and immediate communication tool that they are
regularly interacting with, while chat is consumed at a less frequent pace for others. This meansthat a message sent via chat might be read now, later, or not at all. If you need a higher degree of
conﬁdence that the message will be received and read in a timely manner, email may be a better
choice.
Direct Message (DM) is used where you need an immediate response and may refer to either a
1:1 message on Google Chat or text message. This should be used sparingly, primarily when an
immediate response is required or you need to make someone aware of something. For example,
when a critical service has failed, a guest is waiting, there is an urgent, time-sensitive matter todiscuss, or you want to prompt someone before you escalate.
Keep in mind that when you interrupt someone it typically takes the other person some time torefocus on what they were doing (see here and here for more information).
11.3.2. Email Best Practices●●●

Be concise and speciﬁc when drafting emails. Show that you value the other person's timeby making the message quick and easy to read and action.
Be clear about what you want the recipient to do early in the email. For example, “Elizabeth, I
need a response on the two points below”, or “Stuart, this is FYI”. It is also best if you include“Action required” or “Input needed” in the subject line to make it easier to triage the email
without opening it.
Avoid using group distribution lists that include members outside of your team. For example,
if you look after the travel pod then you would send it to the travel pod but not to the wholeorganization or customer team.

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●

●
●
●
●

Avoid copying (CC’ing) in people that are tangentially related to the request in the hope ofgetting a quicker response or copying in other people to apply pressure to get someone todo something.
Think carefully before copying someone into an email and remove people from the copy list
if they are not relevant to the ongoing conversation (and use bcc to announce the change).
Bcc should only be used to remove people from the message. e.g. "Thanks for the
introduction John (moved to bcc), Hi Tim, ...."Take a moment to send a "Got it", "Leave it with me" or "I will get back to you in a week" reply
to acknowledge a message and set an expectation around the response or action.
Never send anything via email that you would not be comfortable showing up on the front
page of the paper. Do not yell, be abusive or get emotional. Try to consider in advance how
the recipient will receive the message and remember that there is a person, not a machine,on the receiving end of the message.

11.3.3. Chat Best Practices
Threads are used in rooms to organize discussions around a topic. Comments are added by
replying to an existing thread to continue the conversation, or by starting a new topic in the room
using the ‘Add New Thread’ button. If you accidentally step on an existing conversation by
replying instead of starting a new topic, you can delete the message and post it again as a new
thread.
When you want certain people to have a higher likelihood of seeing a comment in a thread, you
can tag them using the @ symbol. Note that tagging someone is not the same as sending them anemail or DM. If you need to ensure the message is read, then sending a DM or email may be more
appropriate. Please be mindful to limit your use of @all in chat rooms (aim to use it only inabsolutely necessary circumstances) rather, be speciﬁc about who needs to see the message bytagging them (and email if it’s important they see it soon).
Collaboration with external clients and partners can be done on Google Chat. Please follow Rokt’s
security protocol when collaborating with others through Google Chat (e.g. No transferring of PII
data in whatever form).
Use the room that is most relevant for the content you want to post. Rooms are organized into
categories based on the label at the start of the room name. If you need to create a new room thencreate it using the naming convention below, and if you want the room to be accessible toeveryone at Rokt, add Rokt Team to the room:
●
●
●
●
●
●
●

Client (e.g. Client - Ticketmaster): for internal discussions about that client.
Product (e.g. Product - Rokt Upsells): for discussions about that product.
Department (e.g. Marketing - Product Marketing): for discussion about and within thatdepartment.
Procedure (e.g. Procedure - Campaign Policies and Placement Rules): for discussing
approaches, policies, and procedures for certain aspects of Rokt.
Group (e.g. Group - New York O ce): for discussing things with a certain group of people
Rokt (e.g. Rokt - Ticketmaster - EXTERNAL): for external collaboration with a client
Temp (e.g. Temp - GKO 2023 Organizing): for more ad-hoc topics or issues with a shorter
timespan

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11.3.3.1. Recommended Chat Spaces
In addition, there are a number of special chat spaces that all Rokt’stars should join:
Google Chat Space

Description

Group - Everyone - General Chat

For communicating to everyone at RoktGroup - Everyone - Company Announcements

Company Announcements: for Rokt-wide
company announcements.

Ask Anything - Ideas, Discussion & Learning

Ideas, Discussion & Learning”: for questions,answers, and comments from/with Senior LeadersThank YouFor recognition of Rokt’stars

Rokt’star Team Changes

For announce new Rokt’stars, departing Rokt’stars
and promotions/role changes

11.3.3.2. Community Channel Communication Guidelines
A “Community Channel” is any Google Chat Space or internal email group that a Rokt’star is
automatically enrolled in as part of their role. Some examples are Group - New York O ce,
Group - Everyone - General Chat, and BD Team (Global).
Rokt’stars abide by the following Standards when posting in Community Channels.
1. Stick to Professional Topics: Community Channels should focus on work-related
topics and initiatives. Rokt’stars should keep discussions relevant to their roles and thecompany's objectives.
2. Use Respectful and Inclusive Language: Respectful and inclusive language isimportant in Community Channels. O ensive, discriminatory, or harassing posts andcomments should not be tolerated. If you feel speciﬁc language in a post violates thisstandard, please contact the poster directly.
3. Avoid Political, or Controversial Discussions: Discussions that are not directly
related to Rokt’s business which are also relevant to all members of the Community
Channel should be avoided. These conversations should only occur in personal chats,or chats Rokt’stars opt-into (i.e., Rainbow Rokts, Run Club, etc.). Communication inthese channels should be approached with an eye toward inclusivity.
4. Be Mindful of Tone: Written messages can be misinterpreted, so be mindful of tone!
Use emojis or other cues to convey emotions when necessary, keeping in mind thatthese can also express political or controversial opinions (which should be avoided).
5. No Spam or Self-Promotion: Community Channels should not post spam,solicitations, advertisements, or self-promotional content. These messages should
only be sent in personal chats, or chats Rokt’stars opt-into (i.e., Pets of Rokt, Music
Club, etc.).
6. Respect Privacy and Conﬁdentiality: Rokt’star privacy and conﬁdentiality ofcompany information is important. Rokt’stars should not share sensitive or private
information in public chat rooms.

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11.3.3.3. Rokt What's On Calendar
You may want to subscribe to the ‘Rokt What’s On’ calendar to keep on top of what is happening at
Rokt.
11.3.4. Escalating Unresponded Messages
A lack of a timely response can be frustrating and result in missed opportunities. If you are notgetting the response you require:●●●

Give the person a prompt if you do not get a reply in 24 hours; either by talking to them if you
are in the same o ce or via direct message if you are not.
Escalate to the person’s People Leader or another senior manager if you still do not get a
reply in another 24 hours: Title the start of the subject line of the email “Escalating for
Action”, or make it clear in the DM that you are escalating an issue for action.
Escalate again to the 2-up People Leader if you still do not get a response and continue toescalate accordingly on a 24-hour cadence.

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11.4. Appendix 2.2 - Rokt Meeting Guide
This guide is largely focused on internal meetings. Generally external meetings, particularly with
Clients, are almost always a good thing. For external meetings we should aim to maintain abalance between the number of Rokt’stars and external guests attending.
11.4.1. Agenda and Attendees
The larger the meeting, the less productive they tend to become. Larger meetings (more than 7people) also have a negative impact on Rokt'star engagement as larger meetings make it harderfor everyone to contribute. While these large meetings are sometimes necessary for alignment
and information sharing, they should be kept short and to the point to reduce time used. As aguide, research suggests that 4 attendees are the optimum number to decide or solve a problem.
All meetings should include an agenda and desired outcomes in the invite, with any
background/pre-read material distributed a minimum of 1-2 days prior. It is recommended thatteam meetings should rotate the meeting lead who will create, drive and own the agenda. This not
only shares the workload, but also allows di erent voices and styles to be surfaced.
Attendees are encouraged to challenge the need for the meeting if the purpose and agenda is notclear, or to say "No" to some meeting invites if you feel you are not going to add any value or you
could get an update afterwards. You should discuss with your People Leader and/or the organizer
whether a meeting is mandatory for you and/or your team, preferably before declining themeeting. Research says that two-thirds of meetings are not productive.
11.4.2. Volume of Meetings
Where possible, individual contributors should not be in internal meetings for more than 2 hours a
day on average. The role of a People Leader inherently involves more meetings, but it is still
important for them to try and maintain time each day outside of meetings. To aid this, it isrecommended you block time in your diary for completing tasks that require focus and attention tocomplete.
There are only a few mandatory meetings at Rokt; a one-o induction, GKO, sometimes teammeetings, 1:1s and All Hands.
Recurring group meetings are often the largest contributor to time lost in unproductive meetings.
Recurring meetings should not be booked more than a month ahead to force a review of themeeting before it is set up again, and feedback should be sought to evaluate the e ectiveness andnecessity of the meeting. Note that it is normal to have recurring one-on-one meetings but theyoften do not need to be done on a weekly cadence.
In addition, instead of using the calendar defaults of 30 or 60 minutes, try a 10-minute stand-up
meeting. Stand-up meetings where people do not sit down are a great way to keep meetings on
point and productive. You can always arrange a follow up if you need more time. It is good practice
to set your default meeting times to leave a 5- or 10-minute bu er to meeting lengths. In yourcalendar settings, you can enable “Speedy Meetings” to automatically set a bu er at the end of
meetings.

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11.5. Appendix 2.3 - Content Creation Guide
Content creation is used by many teams for many purposes at Rokt, but there are common
themes - communication, alignment, collaboration, and education. As content proliferates,
discovery, fragmentation, conﬂict, and access issues are common challenges we face.
To help solve some of these challenges and make it easier to share content, we have developed arecommended process for producing content, including the tools used for each step:
11.5.1. Content Creation and Review
We have found content creation tends to be a focused and collaborative process amongst a small
group of Rokt’stars. Similarly, it is important to keep the group of tools small for consistency,
productivity, and ease. When you use tools other people are comfortable with, you makecollaboration and communication a lot easier.
Under the G Suite, we use Google Docs, Sheets and Slides for content creation, which all
integrate natively with Google Drive. You can use other tools individually, but when collaborating,you should use tools within G Suite.
Ownership of documents is another important step in keeping track of content, which often has tolive for extended periods of time. This owner is responsible for resolving comments and adding
updates where appropriate. You can identify the owner of a document from the initials at the end of
the document name (see Document Naming Convention).
When the document owner is comfortable and the content is ready for broader review, they should
post the content to appropriate Chat Space for discussion and input or email it if it requires
approval. Generally, the document owner is looking for this to be accepted and merged into thebroader knowledge base and existing processes.
11.5.2. Publishing and Repurposing
When a document is ‘published,’ it signals to everyone that the content is ready for adoption,broader use and can be referenced for building out other content. To signal this, the documentname should be adjusted from ‘DRAFT’ to ‘FINAL’, and a version number added in the document.
General share access should also be changed to view or comment only to prevent further editing.
In addition, the document should be moved (if not already) to an appropriate shared drive on
Google Drive.
For internal content that is accessed by more than one function (e.g. policies like this handbook)the application that is used across the company is Google Docs.
Sometimes, another team may want to repurpose content for other purposes. For example,
marketing produces short videos for clients, and the People Team wants to utilize them withininternal training courses. In this case, it is important that only published ‘FINAL’ content is used.

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11.5.3. Retirement
When appropriate, the functional owner should retire content that is no longer relevant. The
content should be deleted or archived and renamed ‘ARCHIVED’ for Google Docs, and removed
for publishing tools.
11.5.4. Document Naming Conventions
Please use the following naming convention when creating documents to be shared withcolleagues or saved on Google Drive:[YYYYMMDD]-[DOCUMENT TILE]-[YOUR INITIALS]-[DRAFT/FINAL/ARCHIVED]This makes it easier to ﬁnd ﬁles, identify recent vs older versions of documents, as well as
document ownership. Make sure to always save documents into an appropriate folder on a Rokt
Shared Drive and not your personal Drive.
11.5.5. Document Sharing with Clients
If you need to share static documents with clients (e.g., presentations, reports, etc.) use HubSpot
Documents in PDF form where possible.
If you need to collaborate with a client on a document or you have more dynamic content (e.g., aspreadsheet with campaign performance) you can share individual ﬁles within the “RoktBusiness” team drive externally.

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11.6. Appendix 3 - Wellness and Safety in the Workplace Policies
11.6.1. Anti-discrimination and Equal Employment Opportunity Policy
Rokt wants to ensure we create an environment in which everyone is provided the best
opportunity to succeed, and as such, we make employment decisions based on merit and support
a discrimination-free workplace. It is important to us that Rokt'stars, clients and any other people
who you may know as part of your employment with Rokt feel welcome, supported, and notdiscriminated against.
At Rokt, we believe that we get the best results when everyone - regardless of who
you are - has the same chance to shine. Diversity also helps us approach problems
with di erent perspectives and ultimately come up with better solutions. Rokt is atruly diverse global organization employing people of myriad nationalities frommultiple cultures, across the globe.
In support of this belief, Rokt makes employment decisions based on merit to support a
discrimination-free workplace, and enforces non-discrimination in any work-related context
including conferences, work functions, o ce parties and business trips. We also adhere to allanti-discrimination legislation in each market in which we operate. In an e ort to support you in
understanding this policy and our commitment to it, we host training annually on behaviors ofinclusion and unconscious bias and on preventing discrimination and harassment in theworkplace.
This policy applies to any form of discrimination that occurs not only between each other but also
between clients or any other people who you may get to know as part of your employment withRokt.
We take a ﬁrm stance on discrimination and breach of this policy is considered to be serious andmay result in legal and disciplinary action, including termination, against the o ending individual.
This policy applies to all team members, contractors, volunteers, and any other persons you may
come into contact with during your employment with Rokt.
11.6.1.1. What is Discrimination?
Discrimination occurs when a person or group of people are treated less favorably due to their:
●
●
●
●
●
●
●
●
●
●
●
●

race, including color, descent, ethnicity, or national origin,gender,age,
religious belief or activity,
disability, including physical, mental, or intellectual,
medical condition,
sexual orientation,
gender identity,
relationship status,
political belief or activity,
industry or trade union membership or non-membership,
criminal record,

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●
●

service in the Armed Forces, or
caregiver’s and/or family responsibilities including pregnancy.

It is unlawful to discriminate against a person or group of people based on any of the above traits
or attributes or any other characteristic protected by applicable law.
11.6.1.2. Equal Opportunity Employer
Being an equal employment opportunity employer means endeavoring to ensure that everyone
has equal access to available employment activities (such as recruitment, promotions, training
and development), free from discrimination and harassment and providing programs to assist
people to overcome disadvantage, if required.
11.6.1.3. Retaliation or Victimization
Retaliation is when a person is retaliated against or subjected to discrimination because they havelodged, intend to lodge, or are otherwise involved in a discrimination complaint. You must notparticipate in retaliation against a person who raises a complaint or subject them to any physicalor psychological harm.
People Leaders have additional responsibilities and obligations imposed on them to take
immediate action if and when violations are reported to them. Please refer to the Grievance Policy
for more detail on the requirements and process to follow if a violation is reported or observed.
11.6.1.4. Breaches and Reporting
At Rokt, everyone has a responsibility as part of their employment to adhere to this policy. If you
feel you are (or observe someone else) being discriminated against, we strongly recommend thatyou should immediately report your concern to your People Leader or People Team partner.
Please refer to the Grievance Policy for further information on how a claim of discrimination will behandled at Rokt.
11.6.2. Harassment
Everyone has a right to feel safe and supported, and that you have avenues to raise concerns if
you feel you are being harassed. This policy deﬁnes the behaviors that are considered
unacceptable when it comes to workplace harassment - including sexual harassment - and what
to do if you have any concerns.
At Rokt, we believe that we get the best out of our people and teams when they can work in anenvironment that is free from harassment. As such, Rokt team members are expected to be
inclusive, collaborative, and supportive. It is important that you consider the implications of yourbehaviors and support your colleagues to speak up and raise concerns.
Bullying and harassment of all types are unlawful under discrimination and work health and safety
legislation in any work-related context including conferences, work functions, o ce parties andbusiness trips.
This policy applies to any form of bullying and harassment, including sexual harassment that
occurs not only between Rokt'stars but also between any other people that you may come into

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contact with as part of your employment with Rokt. Sexual harassment as well as harassment due
to a person’s race, age, national origin, religion, disability, sexual orientation, or any otherprotected characteristic under the law or Rokt’s equal employment opportunity policy is strictly
prohibited.
We take a ﬁrm stance on bullying and all forms of harassment and breach of this policy is
considered to be serious and may result in disciplinary and/or legal action against the o ending
person. This policy applies to all Rokt'stars, workers and contractors.
11.6.2.1. Sexual Harassment
Sexual harassment is any unwelcomed sexual advance or other conduct of a sexual nature whichmakes a person feel o ended, humiliated, or intimidated where a reasonable person would
anticipate that reaction in the circumstances. Examples of sexual harassment may include, but
are not limited to:●●●●

Unwelcome physical contact such as pinching, touching, grabbing, kissing, or hugging,
Sexual jokes or comments, sexually explicit emails, texts and/or conversations,Intrusive questions or insinuations about a person’s private life; orRequests for sexual favors.

Even if you did not intend to o end, humiliate, or intimidate the other person, certain conduct canamount to sexual harassment. Sexual harassment is not interaction, ﬂirtation or friendships,
which are mutual or consensual.
11.6.2.2. Bullying
Bullying is repeated, unreasonable behavior directed towards a worker or group of workers thatcreates a risk to health and safety. Bullying does not have to be directed at a particular individual to
be unlawful. Behavior which creates a hostile working environment can also be unlawful.
Examples of bullying include, but are not limited to:●●●

Physical or verbal abuse,
Yelling, screaming, o ensive behavior or language; and/or
Intimidation.

Legitimate and reasonable management actions - such as actions taken to transfer, demote,discipline, retrench or dismiss an individual - are not considered to be bullying, providing theseactions are conducted in a reasonable way. Further, it is not bullying for your People Leader tocounsel you regarding your performance or conduct in a reasonable way as this may benecessary to ensure you are meeting our expectations.
11.6.2.3. Retaliation and Victimization
Retaliation is where a person is retaliated against or subjected to bullying because they havelodged a complaint or intend to lodge a complaint alleging, among other things, harassment,
bullying, discrimination, or other unlawful activities or are involved in investigating a complaint or aproceeding of such activities (e.g. appearing as a witness). You must not retaliate against aperson who raises a complaint of bullying or harassment or subject them to any physical or

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psychological harm. We aim to support you and encourage you to display this same behavior by
ensuring that any person who is involved in a grievance or complaint is treated with respect andconﬁdentiality.
11.6.2.4. Breaches and Reporting
At Rokt, everyone has a responsibility as part of their employment to adhere to this policy. If you
feel you are (or observe someone else) being bullied, harassed, sexually harassed or retaliatedagainst in violation of this policy, you should immediately report your concern to your People
Leader or People Team Partner.
Please refer to the Grievance Policy for further information on how a claim of bullying and/or
sexual harassment will be handled at Rokt.
11.6.3. Grievance Policy
At Rokt our aim is to create a work environment where you feel safe, happy, and supported to doyour best work. Occasionally there may be times when there are disputes in the workplace andsupport may be required to resolve some of these situations.
This policy outlines the process that Rokt will follow in the event of a grievance and as such,applies to all Rokt'stars, volunteers and contractors.
11.6.3.1. What Is a Grievance?
A grievance is any type of problem, concern, or complaint you may have about work or the work
environment. A grievance can relate to almost any aspect of employment and can be about any
act, behavior, omission, situation or decision impacting on you, that you think is unfair, unjustiﬁed
or in violation of any Rokt policy, such as the Anti-discrimination and EEO Policy or the Bullying
and Harassment Policy.
11.6.3.2. Grievance Process
Please note, this Grievance Policy can be amended by Rokt as it sees ﬁt and does not vest
enforceable rights in Rokt'stars, contractors or workers.
Option 1: Attempt to resolve the grievance yourself
If you feel comfortable in doing so, attempt to address the issue directly with the person involved.
It is important that you address concerns in a professional and non-confrontational manner andclearly explain what the behavior of concern is and how it is a ecting you and/or your work.
Always ensure you remove any emotion from the discussion and simply focus on the facts that
require addressing. Be aware that the person you are having an issue with may have no priorknowledge of your concerns or how their behavior is being perceived.
Option 2: Report the grievance to your People Leader or Rokt’s Whistleblower Service
If you do not feel comfortable talking to the person(s) involved, or have tried and the issue was not
resolved, you should report the matter to your People Leader, 2-Up People Leader, ExCo member
or People Team partner.

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If you do not feel comfortable reporting the matter directly or you wish to remain anonymous, you
may report the matter to Rokt’s externally managed Whistleblower service, EthicsPoint.
Rokt’stars can report matters to EthicsPoint via a website, mobile site or telephone service.
Contact details for EthicsPoint can be found in Guru under the “EthicsPoint Whistleblower Service
Details” card.
Submissions to Ethics Point will be routed to the General Counsel, Chief People O cer and Chief
Operating O cer. If a submission explains that any of those three individuals are involved in thecomplaint, the third-party provider will not notify them of the case. If each of these individuals is
involved, the matter will be raised directly with Rokt's Audit Committee Chairperson.
After reporting a grievance, your People Leader, Chief People O cer, Chief Operating O cer,
General Counsel or a representative from EthicsPoint (as appropriate) may use reasonableendeavors to conduct an initial meeting, or engage,with you to:●●●

Obtain information about your grievance and what you believe will resolve it,
Explain how the grievance procedure works, including protection from retaliation; andDecide if they are the appropriate person to handle the grievance. If your People Leader
decides they are not the appropriate person to manage the complaint they will refer thecomplaint to the People Team.

If you elect to report a matter via EthicsPoint, it is possible for you to communicate and provide
additional information in an anonymous manner.
To resolve the grievance, there could be three separate steps undertaken in the process: theinformal, formal and appeal processes.
Informal Process
Many grievances can be resolved through our informal process. Usually the People Leader will
facilitate a discussion between those involved in the grievance. In circumstances where thePeople Leader considers this process to be inappropriate or where it is not achieving the desired
outcome, the grievance may be escalated to the formal process.
Formal Process
The formal process involves an investigation of the grievance and a decision about appropriate
actions and outcomes. Depending on the circumstances and the nature in which the complaint
was raised, the formal process may be conducted internally by Rokt or by an external party
including EthicsPoint or a law ﬁrm. A record of all conversations, interviews and supporting
documentation collected throughout the grievance process will be kept on ﬁle.
This process may include some or all the following steps depending on the type and severity of
the complaint:
1. A formal written complaint is submitted to the People Leader. The complaint should
include dates, the people involved, the facts of the event, how it has been dealt with to date
and the desired outcome for it to be resolved e ectively.

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2. The relevant person on the People Team will review the complaint and decide if aninvestigation needs to take place prior to a formal meeting.
3. An investigation will be conducted in circumstances where more information is required,
where there are conﬂicting accounts of events or to establish if the complaint has merit.
The investigation may include individual interviews with those involved and/or thecollection of supporting documentation or evidence. E orts will be taken to carry out theinvestigation in a conﬁdential manner.
4. Once an investigation has been conducted, a formal meeting will be held to allow theperson(s) whom the complaint is about to o er their response on the concerns raised
throughout the investigation or complaint documentation.
5. Following the investigation, a resulting course of action may be provided for those involved
based on all the information collected. Potential actions may include, but are not limited toperformance management, a formal warning, training or mentoring; and/or termination of
employment.
Once a course of action has been put in place, Rokt will follow up with those involved to ensure thegrievance has been e ectively resolved. Please note that should an investigation into a complaint
show that the complaint was knowingly false, this will be followed up with the complaint and dealt
with under the Performance Management policy, and there may be resulting disciplinary actions
taken that could include termination of employment.
Appeal Process
If you are dissatisﬁed with the outcome of the formal investigation, you may appeal the decision to
the CEO or their delegate. The decision of the party conducting this appeal will be ﬁnal with nofurther internal steps available.
During the Process
During all stages of the grievance process, everyone involved will be treated fairly. We will ensurethat all individuals are:
●
●
●
●
●

Informed of any allegations against them,
Given an opportunity to respond,
Allowed a support person,
Treated in a professional and non-judgmental way; andGiven adequate notice of meetings.

11.6.3.3. Vexatious or False Claims
Should an investigation into a complaint show that the complaint was knowingly false or broughtfor the purpose of harassing another employee, it will be followed up with the complainant anddealt with under the Performance Management policy and there may be resulting disciplinary
actions taken.
11.6.3.4. Documentation
Where considered appropriate, agreed resolutions of grievances arising from the informal
procedure may be recorded and signed by all parties. Generally, it will not be necessary to put
records of a grievance in a Rokt'star’s ﬁle, unless there is some disciplinary action taken as a

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result of the grievance. A record of any disciplinary action that is taken arising from a formal
investigation will be placed on an employee’s ﬁle.
11.6.3.5. Professional Conduct
Work will continue as normal while a grievance is being dealt with unless the situation is deemed
serious enough for this to be inadvisable. In these situations, work modiﬁcations may be
implemented during the course of the investigation to ensure those involved are able to work in anenvironment that they feel safe and comfortable in. Anyone a ected by the grievance is expected
to cooperate with us to ensure an e cient and fair resolution.
During a grievance process, we expect all Rokt'stars to be honest, professional, respectful, and tokeep the grievance-related details conﬁdential. Disciplinary action, including possible termination,
may be taken against any person who breaches conﬁdentiality, fails to cooperate, or victimizes the
person who lodged the grievance.
11.6.3.6. At-will Employment
If the nature of your employment contract with Rokt is at-will and is explicitly stated so in youremployment contract, nothing in this policy alters the policy of employment at-will. Therefore, if
your individual written contract of employment details at-will employment, the employment
relationship remains terminable at-will by either Rokt or the Rokt'star, with or without cause orprior notice.
11.6.3.7. Access to Support and Representation
If you are involved in a grievance in any capacity, you can seek advice from another representativeat any stage during the grievance process. You are entitled to bring a support person to any formal
meeting if you wish and Rokt will provide you with a reasonable amount of time for you to arrange
for this person to attend. This support person, however, is not entitled to speak on your behalf
during the meeting and it is requested that you provide 24 hours’ notice of your intent to bring a
support person to the meeting, as well as their name.
11.6.3.8. Breaches and Reporting
At Rokt, everyone has a responsibility as part of their employment to adhere to this policy. If you
feel the policy has been breached, you should immediately report your concern to your People
Leader or People Team partner.
Please refer to the Performance Management policy for further information on how a breach ofthis policy will be handled at Rokt.
11.6.4. Workplace Safety Policy
At Rokt we take workplace health and safety seriously and endeavor to provide a safe working
environment. While it is normal to want to have some fun at work, we take a ﬁrm stance on
workplace health and safety.
This policy outlines the responsibilities of all Rokt'stars in creating and maintaining a safe working
environment. Breach of this policy is considered to be serious and may result in legal and/or
disciplinary action.

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11.6.4.1. Hazards and Risks
A hazard is anything in the workplace that has the potential to harm someone. Some examples
may include poorly placed cords and wires, incorrect manual handling procedures, slippery ﬂoors,cleaning products, unsafe workplace behaviors and fatigue.
A risk is when it is possible that a hazard will cause harm. The level of risk will depend on factors
such as how often the job is done, the number of people involved and how serious any injuries that
result could be.
11.6.4.2. Identifying Hazards and Risks
Rokt maintains its commitment to a safe working environment by:●●●

Routinely conducting assessments of the workplace to detect, assess and respond to
identiﬁed hazards or risks,
Prioritizing the removal of any hazards or risks to prevent injury, illness, or incidents fromoccurring; andReducing the likelihood of the risk or hazard occurring and its severity, where we are unable
to eliminate the risk entirely.

11.6.4.3. Workplace Health and Safety Responsibilities
You play a key role in creating and maintaining a safe working environment. As such, you have an
obligation and a responsibility to:
●
●
●
●
●
●
●
●

Conduct yourself in a manner that is appropriate, always exhibiting safe and healthy work
practices,
Be responsible for your own health and safety, ensuring you do not conduct yourself in amanner that might compromise the health and safety of others,
Disclose to the People Team if you su er from a medical condition that may impact yourability to perform in your role with or without reasonable accommodation,
Undertake ﬁtness for work assessments if inherent requirements of the job are unable to be
performed,
Follow all safe work method statements, safe travel practices, procedures, instructions, andrules,
Comply with legislation and laws relating to workplace health and safety and follow all safe
work practices, procedures, instructions, and rules,
Encourage others to work in a safe and healthy manner; andUphold and familiarize yourself with the duties that apply to you.

If you are a People Leader, you have additional responsibilities to ensure a safe working
environment:●●

Treating all breaches of workplace health and safety standards seriously and taking
appropriate action; andProviding adequate information, instruction, training, and supervision to enable yourRokt'stars to perform their roles e ectively and safely.

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11.6.4.4. Workplace injury and Compensation
All Rokt'stars are covered by workers’ compensation insurance, which compensates a Rokt'star
for lost time, medical expenses and loss of life or dismemberment from an injury arising out of or in
the course of work. Rokt'stars must immediately report any accident or injury to their People
Leader and the Rokt People Team so that the necessary paperwork may be completed.
All claims for compensation in respect of injury, disease or death sustained whilst at work or whilst
traveling to or from work shall be dealt with in accordance with the Workers’ Compensation
legislation in force at the relevant time.
Rokt'stars who return to work after a medical-related absence may be required to submit aphysician's statement detailing their ﬁtness for their return to work. Rokt reserves the right to have
Rokt'stars submit to a medical examination by a physician designated by Rokt at no expense to
the Rokt'star.
11.6.4.5. Breaches and Reporting
At Rokt, everyone has a responsibility as part of their employment to adhere to this policy. If you
observe a hazard or a risk in the workplace or are involved in a safety incident, you should reportyour concerns to your People Leader or the People Team partner.
Please refer to the Performance Management policy for further information on how a breach ofthis policy will be handled at Rokt.
11.6.5. Anti-bribery and Anti-corruption Policy
At Rokt, we are committed to conducting business in compliance with the law including allanti-bribery and anti-corruption laws.
Rokt expects every Rokt'star to adhere to high ethical standards, promote ethical behavior and behonest and forthright in dealings with one another as well as with clients, business partners andthe public. Rokt'stars must not engage in conduct or activity that may raise questions as to the
Rokt’s honesty, impartiality, or reputation. Every action should be judged by considering whether it
is legal, fair to all concerned, in the best interests of our stakeholders, Rokt'stars and clients andable to withstand public scrutiny.
Rokt is committed to conduct business in compliance with the law, including all applicableanti-bribery and anti-corruption laws in all countries in which we operate. Acting outside of the law
places the long-term success of the business in jeopardy and exposes both Rokt and its
Rokt'stars to ﬁnes and other penalties including imprisonment. As part of their own supply chain
assurance, our Partners and Advertisers also demand that we abide by the law, and not undertake
bribery or engage in corruption. Thus, Rokt’stars are required to comply with all Anti-Corruption
Legislation.
This Policy does not prohibit interactions with Government O cials, but it does it forbid corrupt
interactions with such individuals.
Bribery and the related improper conduct addressed by this Policy are serious o enses. If Rokt or
one of its subsidiaries is found to have taken part in bribery, or any other related improper conduct

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addressed by this Policy, it could face a ﬁne and su er reputational harm. An individual may besubject to penalties or lengthy terms of imprisonment. Breach of this Policy by Rokt'stars will be
regarded as serious misconduct, leading to disciplinary action, which may include termination of
employment.
11.6.5.1. Deﬁnitions
In this policy, the following words or phrases mean the following:
Anti-Corruption Legislation means the Singapore Prevention of Corruption Act 1993, UnitedStates Foreign Corrupt Practices Act (the “FCPA”), the Criminal Code Act 1995, (Commonwealthof Australia) and the Bribery Act 2010, (United Kingdom).
Bribery means the o ering or providing (or authorizing the o er or provision) of any loan, gift,lavish trip or entertainment, donation, payment, or any other thing of value directly or indirectly, incash or in kind, to or for the beneﬁt of any O cial or Third Party to obtain or retain business or tosecure any improper advantage for Rokt.
Business Associates means third party companies and individuals (such as joint venture
partners, consultants, and agents) acting on Rokt's behalf, whether directly or indirectly, byrepresenting Rokt’s interests to foreign governments in relation to international businessdevelopment or retention of business opportunities.
Facilitation Payment means payments of nominal amounts to persons to ensure or speed up the
performance of a Government O cial’s routine governmental duties or actions.
Government O cial means anyone regardless of rank or title who is:
●
●
●
●
●
●

engaged in public duty in a government agency whether elected or appointed, and at any
level of government including national, state, or local government entities,
a member of any legislative, administrative, or judicial body,a Rokt'star of a government agency, regardless of rank including an administrative and/oro ce worker,
an o cer or Rokt'star of a government‐owned or government‐controlled entity, including
state‐owned entities that operate in the commercial sector,
an o cer or Rokt'star of a public international organization (such as the United Nations, theWorld Bank, or the International Monetary Fund); or
acting in an o cial capacity for a government, government agency, or state‐owned
enterprise.

Item of Value or anything of value includes cash, travel, meals, gifts, and other tangible orintangible beneﬁts.
O cial means a Government O cial, political party, o cial or o cer of a political party or
candidate for political o ce.
Rokt'star means all persons acting on behalf of Rokt at all levels, including o cers, directors,
employees of Rokt.
Secure an improper advantage includes obtaining any commercial or ﬁnancial beneﬁt.

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Third Party means any individual or organization other than O cials, with whom Rokt Rokt'stars
come into contact during the course of their employment or business relationships associatedwith Rokt.
11.6.5.2. Prohibition against Bribery and Corruption
Rokt strictly prohibits Rokt'stars engaging in or tolerating Bribery or any other form of corruption.
Rokt’s corporate values require that in all aspects of business all Rokt'stars act honestly, adhere to
the highest ethical standards, and act in compliance with all relevant legal requirements. In thisrespect Rokt'stars must not engage in Bribery, or any other form of Corruption.
The prohibition of Bribery under this Policy includes the provision or conveying of anything ofvalue to any Third Party, O cial or family members of O cials, whether directly or indirectly, tosecure any improper advantage or to obtain or retain business. This means that Rokt'stars must
not:
●

●

●

●
●
●
●

O er, promise or give an Item of Value with the intention of inﬂuencing an O cial or Third
Party who is otherwise expected to act in good faith or in an impartial manner, to do or omit
to do anything in the performance of their role or function, To provide Rokt with business oran improper advantage; orAuthorize the payment or provision of Items of Value to any other person, if it is known, or
reasonably should have been known, that any portion of that payment or Item of Value will
be passed onto an O cial or Third Party to secure an improper advantage or obtain or retain
business; orEngage, or procure, a third party to make a payment or provide an Item of Value to an O cialor Third Party, (or to procure another person to make such payment or provision), To secure
an improper advantage or obtain or retain business.
The prohibition of Bribery under this Policy also includes the request or acceptance of (orthe agreement to accept) anything of value from an O cial or Third Party either:intending that, in consequence, a function or activity should be performed improperly(whether by the requestor/acceptor or another person); or
where the request, agreement, or acceptance itself constitutes the recipient's improper
performance of a function or activity; or
as a reward for the improper performance of a function or activity (whether by the recipient or
another person).

All interactions with O cials and Third Parties must comply with this Policy, and Rokt andRokt'stars must not take any actions, whether direct or indirect, which create the appearance ofimpropriety, regardless of whether there is any improper intent behind their actions.
Rokt will separately provide Rokt'stars with detailed guidelines on gifts and entertainment.
If you are in any doubt as to the appropriateness of any gift or entertainment, you should consult
the General Counsel before it is given or accepted or otherwise as soon as possible.
The prohibitions under this Policy include a prohibition on Rokt'stars using personal funds toundertake any interaction or transaction that is prohibited under this Policy

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11.6.5.3. Policy Compliance, Training and Review
Rokt’s General Counseland is responsible for the overall administration of this Policy. Rokt’s
General Counsel will monitor the implementation of this Policy and will review on an ongoing basis
the Policy's suitability and e ectiveness. Internal control systems and procedures will be audited
regularly to ensure that we are e ective in minimizing the risk of non-compliance with this Policy.
All Rokt'stars are required to understand and comply with this Policy and to follow the reporting
requirements set out in this Policy. To this end, regular and appropriate training on how to comply
with this Policy will be provided to all senior managers and other relevant Rokt'stars by theGeneral Counsel for each business.
The prevention, detection and reporting of bribery and other improper conduct addressed by thisPolicy are the responsibility of all those working for or engaged by Rokt. All Rokt'stars should be
vigilant and immediately report any breaches or suspicious activity to the o cer responsible forcompliance.
11.6.5.4. Documentation and Record Keeping
As part of Rokt’s commitment to open and honest business practice, Rokt requires all its
businesses to maintain accurate books of accounts and records.
All Rokt subsidiaries must keep accurate and complete records of all business transactions:●●●in accordance with generally accepted accounting principles and practices,in accordance with Rokt’s accounting and ﬁnance policies, andin a manner that reasonably reﬂects the underlying transactions and events.

It is the responsibility of all Rokt'stars to ensure that all business transactions are recorded
honestly and accurately and that any errors or falsiﬁcation of documents are promptly reported tothe appropriate member of the senior management team of the relevant subsidiary, and corrected.
11.6.5.5. Types of Payments, Contributions and Donations
Prohibition of Facilitation Payments
Rokt does not condone the making of Facilitation Payments and the making of these by Rokt'stars
are prohibited.
Political Contributions
Rokt prohibits Rokt'stars from making political contributions to candidates for any foreign politicalo ce on behalf of Rokt. This Policy does not allow Rokt to curtail an individual's freedom to makepolitical contributions in their personal capacity.
The context of any other political contributions is key in determining their appropriateness. For
instance, it is permissible for Rokt to make a payment to attend a political function incircumstances where such payment could not be construed as an attempt to inﬂuence thepolitical party.

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If you are in any doubt as to the appropriateness of any political contribution, you should consult
Rokt’s General Counsel before it is given or accepted or otherwise as soon as possible.
Charitable Donations
Rokt is committed to the communities in which it does business. To this end, Rokt supports
selected charitable organizations as determined by the local business. To ensure that donations
made by Rokt are for proper charitable purposes, Rokt'stars must only make donations on behalfof Rokt to charitable organizations previously approved by Rokt.
11.6.5.6. Compliance with Local Laws Required
If local laws, codes of conduct, or other regulations in a particular country or region are more
restrictive than this Policy, then any Rokt'star, including any Business Associates operating in thatcountry or region must fully comply with the more restrictive requirements.
To the extent that laws and regulations in any country are more rigorous or restrictive than thisPolicy, those laws and regulations should be followed by any subsidiary operating in that country.
Rokt may, from time to time, provide country‐speciﬁc directions for particular markets.
11.6.5.7. Reporting Violations and Suspected Misconduct
Any Rokt'star or stakeholder who believes that a violation of this Policy or any laws has beencommitted, is being committed, or is being planned, should report the matter immediately to theChief People O cer.
If anyone is unsure whether a particular act constitutes bribery, or a facilitation payment, or has
any other queries, you should ask the Chief People O cer.
11.6.5.8. Protection for Whistleblowing
Whistleblowers are those who sound the alert on danger, malpractice, bribery, or corruption orother illegal conduct. Rokt prohibits retaliation against anyone reporting such suspicions will
support the rights of Rokt'stars who:●●

Report in good faith any perceived wrongdoing, impropriety, serious unethical behavior, legal
or regulatory non-compliance or questionable accounting or audit matter; orExpect and receive protection from any reprisal or detrimental action resulting from suchdisclosure.

11.6.5.9. Reporting
Rokt'stars and stakeholders are encouraged to disclose to their People Leader or People Team
partner, preferably in person (but alternatively by telephone or email) any behavior, practice, or
activity that they reasonably believe or perceive to:
●
●
●
●
●

Be unethical or improper,
Constitute ﬁnancial malpractice, impropriety, corruption, bribery or fraud,
Be potentially damaging to Rokt, a Rokt'star and/or Rokt’s reputation,
Be in breach or potentially in breach of any law or regulation,
Amount to an abuse of authority,

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●
●
●

Amount to non-disclosure or manipulation of the internal or external audit process,Be a breach of the Rokt’s policies; orInvolve harassment, discrimination, victimization, or bullying.

All disclosures made under this Policy will be documented and investigated promptly, initially byan internal investigator.
In making a disclosure under this Policy, Rokt'stars and stakeholders must act in good faith on a
genuine belief that there has been wrongdoing, and not for any malicious purpose. Where it isdetermined that a disclosure is made by a Rokt'star falsely or for a malicious purpose, the Roktreserves the right to take disciplinary action against the disclosing Rokt'star.
11.6.5.10. Protection for Good Faith Disclosures
Rokt'stars who wish to raise a concern or report another's wrongdoing, or who have refusedpressure to either accept or o er a bribe, should not be worried about the possible repercussions.
Rokt encourages openness and will support anyone who raises genuine concerns in good faithunder this Policy.
Rokt will not tolerate any reprisals against Rokt'stars or stakeholders who have made a disclosureof any matter under this Policy where the disclosure has acted in good faith and on a genuine
belief or perception of wrongdoing, and on reasonable grounds. Rokt will act in the best interestsof a disclosure to protect them from any victimization, adverse reaction, or intimidation, andcommits to ensure conﬁdentiality (to the extent permitted by law) and fairness in all matters raised
under this Policy.
11.6.6. Anti-slavery and Human Tra cking Policy
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms,
such as slavery, servitude, forced and compulsory labor and human tra cking, all of which have incommon the deprivation of a person’s liberty by another to exploit them for personal orcommercial gain. Rokt is committed to acting ethically and with integrity in all our businessdealings and relationships and to implementing and enforcing e ective systems and controls toensure modern slavery is not taking place anywhere in our own business or in any of our supply
chains.
11.6.7. Compliance with Laws
Rokt and its Rokt'stars must obey all applicable laws and regulations that a ect Rokt’s business.
Although Rokt does not expect its Rokt'stars to be experts in legal matters, we hold each Rokt'star
responsible for being familiar with the laws governing your areas of responsibility. If you have aquestion concerning the application of any law or regulation to a contemplated action, it is yourresponsibility to seek guidance.
11.6.8. Conﬂict of Interest
Each Rokt'star has a duty to carry out his or her responsibilities with the utmost good faith andloyalty to Rokt. A “personal conﬂict of interest” occurs when your own interests (for example,
personal relationship, ﬁnancial gain, career development, or reputation advantage), or those of

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your immediate family, interfere in any way or even appear to interfere with Rokt’s legitimate
business interests or your ability to make objective and fair decisions when performing your job.
You must endeavor to avoid situations in which your personal interests could conﬂict, or may beperceived to conﬂict, with those of Rokt. If you are in doubt whether a situation or certain activity
constitutes a conﬂict of interest, it is your responsibility to seek guidance.
If you have or think you may have a personal, business or ﬁnancial relationship that conﬂicts, or
may conﬂict, with the interests of the business, you must immediately report it to the Chief People
O cer.
The Chief People O cer will notify relevant ExCo members as applicable in the event there is apotential conﬂict of interest. From there, decisions will be made on restricting/limiting systems anddata access and changes to reporting lines. Any changes that are the result of conﬂicts of interest
will be disclosed to the individual as they are made.
11.6.9. Code of Conduct and Business Ethics
Rokt aspires to conduct its business in accordance with uncompromising ethical standards and infull compliance with all laws and regulations. In the course of conducting Rokt business andundertaking duties of your role, integrity must underlie all Rokt relationships.

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