Code of Conduct

Invest Europe Code of Conduct

Curiosity adheres to the key principles of the Invest Europe Code of Conduct:

Act with Integrity

Integrity is the fundamental building block of trust in business relationships. Trust is built upon repeated interactions between individuals that involve clarity, reliability, honesty and a high standard of both personal and professional behaviour. Integrity implies that competitive advantage and commercial success are derived through the application of individual and collective skill and not through the use of inappropriate pressure, or manipulative, coercive or deceptive devices or practices.In the same way that the LP will act with integrity towards the GP, the GP will act with integrity towards its LPs, portfolio companies and other stakeholders and will seek to ensure that the portfolio company conducts its business with integrity. In order to maintain these high standards of behaviour firms are expected to implement and maintain processes and controls to both detect and address conduct that is either unethical or breaks the law. The GP expects the same from its LPs in all areas where they interact. Acting with integrity implies not seeking to evade or avoid the consequences of error.

Keep your promises

Ethical business behaviour implies keeping promises regardless of whether or not there is a legal obligation to do so.Promises are made in the light of circumstances which are known at the time that the promise is made. Within the industry, commitments are often made subject to conditions such as the provision of further information, carrying out due diligence, the results of uncertain external events and other matters. This means that clarity about what is actually committed to and what is still subject to further investigation is very important. The ethical individual or business only makes promises which they reasonably believe are capable of being fulfilled. Promises are of equal importance regardless of to whom they are made.

Disclose conflicts of interest

Conflicts of interest can occur when a person who has a duty to another also has a personal or professional interest that might interfere with the exercise of independent judgement. They inevitably arise within business. In our industry, conflicts can arise between the GP and the fund and its LPs; between different funds; between different LPs in the fund; between LPs of different funds managed by the GP; and between the fund and other investors in the respective portfolio companies. Procedures to ensure the management and disclosure of conflicts should be in place at all firms, and conflicts of interest should be diligently identified and disclosed to all parties concerned.A GP should seek to manage conflicts of interest fairly. Where these conflicts of interest affect LPs, the GP may consult with the LP Advisory Board as part of this process. To facilitate the management of conflicts, LPs should ensure they declare their own conflicts of interest in any situation.

Act in Fairness

Fairness means “playing by the rules,” whether legislative or not, based on facts and circumstances. Fairness must also take account of the impact of decisions and actions on others, both as individuals and groups, and how these actions would be perceived.Rules for conducting business may vary between countries, regions, societies, legal systems and transactions. The “fairness” of actions will often be judged by the rules, formal or informal, that apply to a particular jurisdiction, business or situation. “Fairness” can have a regulatory, legal and reputational as well as a commercial dimension when considered in the context of relationships with investors.Whilst management of the fund by the GP must be in accordance with the fund’s strategy and objectives as agreed in the documentation, there are other occasions when a GP should consider the treatment of investors on an individual basis to be satisfied that it is treating them fairly. In particular, a GP should consider carefully whether any particular investor is being given preferential treatment and if so whether this has been disclosed to the other investors. Fairness may not always mean treating everyone the same way, but transparency in this context is a key element of “fairness”. Legal and regulatory requirements may also make specific provisions relating to disclosures. Consultation with the LPAC or all LPs, where relevant, helps to ensure fair treatment and an awareness of the issues of concern to these groups. LPs should engage with the GP and other LPs in a timely manner when situations arise which require consideration, particularly when they might lead to an LP vote under the fund documents. Ensuring adequate information is available ensures actions are judged objectively for their fairness.

Maintain confidentiality

In the ordinary course of business, individuals and firms will obtain a range of financial and non-financial information from other market participants and through their role in the managing of investments. Some of this information will be publicly available; however, some will be commercially sensitive and the dissemination of which could cause damage or a financial loss to the information’s owner. The GP will treat portfolio company or LP information as confidential in so much as they are made aware that, or should expect that, it is confidential or commercially sensitive.Any usage of such information should be restricted to what has been agreed with the owner of such information or may be mandated by law or regulation. LPs should also comply with the contractual and regulatory requirements to maintain confidentiality; for example, on receiving confidential information when carrying out due diligence on a fund (to which it may or may not decide to commit), or when receiving information that would be considered confidential as an LP in the fund.In an effort to safeguard the commercial interests of disclosing parties, reasonable steps should be taken to protect information from inappropriate disclosure and due care should be taken to follow any agreed procedures.

Do not harm the industry

Success in commercial enterprise requires the pursuit of competitive advantage. The pursuit of competitive advantage is not in itself harmful to the industry.Industry members should, however, conduct their business in a responsible manner and not engage in practices that are foreseeably damaging to the public image and general interests of the industry and its stakeholders.All participants in the industry should promote best practices and a high standard of both personal and professional behaviour to support the wider benefits of long-term, sustainable investment, economic growth and value creation. Private equity plays an important part in today’s economy. As such Invest Europe expects its members and the funds and portfolio companies they manage to comply with the applicable laws and regulations in the jurisdictions in which they operate. Private equity aims at creating lasting value in the companies they own. Therefore, causing reputational damage to the industry through the violation of applicable laws and regulation for gain or gratification is considered harmful to the industry as a whole. The industry’s wider engagement with regulatory bodies, other stakeholders and society at large, requires as much trust, evidence- and data-based exchanges of knowledge and positions as do interactions between contractual partners. Invest Europe members should therefore assist the association in the collection of data pertaining to their businesses and portfolio companies, when relevant for the industry.

Diversity and Inclusion Policy

At Curiosity, we believe not only that great companies can come from anywhere, but that great people do too. As an early-stage fund, we can shape a more diverse and inclusive future through the way we invest and build our own firm. Building a diverse team, and a team that values the importance of diversity makes us a better investor, employer, and partner for our entrepreneurs. These values are fundamental to everything we do, including but not limited to our experts and advisors selection, recruitment and retention, investment strategy, and our involvement in the wider community.

We seek to identify and select a diverse set of people affiliated to our fund and provide a fair and inclusive working environment with equal opportunities for all people we work with. We encourage respectful communication, cooperation, teamwork, and participation with representation across all groups. We treat employees, experts and advisors, investors, entrepreneurs, and people we interact with fairly and ethically, regardless of age, gender, ability, ethnicity, religion, culture, or sexual orientation. We believe this is key and fundamental to the principles of ethical business. Therefore we expect the same from others, including, but not limited to, our investors, other investment firms, and of course, the entrepreneurs and businesses we invest in. Curiosity will not tolerate any form of discrimination, harassment, or victimisation.

We provide hands-on support and mentorship to help our portfolio companies develop their own diversity policies and initiatives, as we do with any other area involved in scaling a business where our expertise allows for it. With the introduction of this policy, we will be requiring any portfolio company, where we are the lead investor, to have their own official diversity policy in place within six months of our investment or before their next round of financing. We are committed to providing whatever support is necessary to ensure this happens.

As a firm at the beginning of its journey, we draw inspiration from other institutions we hold in high esteem. This D&I policy is inspired by Atomico's policy and their work on diversity. Click here for their report and method of integrating a workable D&I framework with an organisation. Furthermore, Curiosity is a member of Diversity VC (formerly #Fundright, supported by to drive more equity towards female and mixed-gender founding teams.

Anti-Discrimination and Harassment Policy

Purpose and scope

At Curiosity we believe in treating people the way we want to be treated ourselves, which means we treat people with respect and equality. We are committed to providing a healthy work environment and culture and extend those commitments to our dealings with all external parties.

Whether you work in Curiosity or are interacting with us, you should at all times feel welcomed, respected and included. 

The perceived power relationship between investors and founders should be recognised by all investors and they should be mindful never to abuse this position when interacting on potential investments or post investment.

We expect everyone associated with Curiosity to abide by this code of conduct, that includes but is not limited to; employees, contractors, founders, funders, investors, mentors, partners, advisors and attendees of our events. The code of conduct also applies in any setting associated with Curiosity, such as offices, work events, social outings, conferences, homes, lodgings, phone calls, video conferences, emails, chat, social media, blogs, or other online communications.

Unacceptable behaviours

Discrimination and harassment

Discrimination is unfairly treating a person or group of people differently from other people. Harassment is unwanted and unwelcome words, deeds, actions, gestures, or behaviours that make someone feel uncomfortable. Discrimination on the basis of age, disability, gender reassignment, marriage and civil partnership pregnancy and maternity, race, religion or belief, sex (gender) and sexual orientation is not only illegal it is wrong and unacceptable. Types of discrimination include direct discrimination (directly treating someone less favourably), indirect discrimination (discriminating a group who share a certain protected characteristic to put them at a disadvantage against those without the characteristic), harassment (unwanted conduct towards an individual) and victimisation (disadvantage to an employee who for example made an allegation of discrimination). This includes but is not limited to:

  • Negative comments or discrimination based on age or family role
  • Asking a job applicant about their health, absences from work or disability before offering them employment
  • Deliberate mis gendering (e.g., using different pronouns than requested)
  • Ignoring an employee for promotion because they are in a civil partnership
  • Discriminating against pregnant people or mothers
  • Racial or ethnic slurs
  • Discriminatory comments against members of marginalised religions as a group
  • Misogynist comments
  • Homophobic or transphobic comments or slurs

Sexual Harassment

Sexual harassment means any unwanted, unwelcome or uninvited behaviour of a sexual nature which a reasonable person in the circumstances would find humiliating, intimidating or offensive. Sexual harassment doesn’t have to be repeated or ongoing.

Sexual harassment takes many forms, from sexual comments to actual physical violence. Curiosity has a zero-tolerance to any form of sexual harassment. Some examples of sexual harassment include:

  • Verbal harassment: Sexual or sexually suggestive comments, jokes, insults, metaphors, pranks or gestures
  • Propositions: invitations or advances including repeated requests for dates, drinks or personal contact, including condescending remarks or inappropriate sexually-themed communication in person or online
  • Sexual assault or coercion, including sexual activity under pressure or threat, for a reward, or in a context where it is difficult for the recipient to say no. This may include requesting sexual activity in exchange for reward including funding, referrals, future employment, promotion, or invitation to exclusive events
  • Non-verbal assault can take the form of touching, leering, brushing against the body or displaying sexually suggestive objects, pictures, posters or cartoons 

Other Types of Harassment
  • Advocating for or supporting any unacceptable behaviour
  • Deliberately and repeatedly acting in a manner, either directly or indirectly, which is contrary to the terms (or the spirit) of this code of conduct
  • Threatening, rewarding, or otherwise coercing someone to not report or lie about a violation of the code of conduct
  • Physical conduct such as assault

Reporting and investigating

Any individual either external or internal to Curiosity Venture Capital that believes an incident or incidents of harassment or discrimination has taken place, should report this in the knowledge that it will be investigated swiftly and without prejudice.

All complaints can be emailed to Lisa Brouwer at Alternatively, please report it to anyone within Curiosity whom you feel comfortable discussing the matter with and they should then escalate the complaint.

Reports will be acknowledged within three business days and actioned within 10 business days. Depending on the degree of violation, actions may include:

  • Nothing - if no violation has occurred
  • Verbal warning
  • Written warning
  • Temporary or permanent ban from events/spaces/boards
  • Suspension
  • Removal of responsibilities
  • Termination of employment
  • Reporting to the authorities

© 2022 Curiosity Venture Capital B.V.