Code of Conduct

1. Why This Code Exists

Steward Market exists to connect business owners, buyers, and advisors around values-aligned ownership transitions. The conversations that happen here are often early, sensitive, and personal. A founder weighing succession. A buyer thinking hard about what kind of steward they want to be. An advisor stepping into a conversation long before a deal is on the table.

That kind of exchange only works if people trust the space. This Code exists to name the standards that make Steward Market worth participating in—and to make clear what won't be tolerated.

By using the Platform, you agree to follow this Code. It applies to every interaction on Steward Market: your listing, your profile, your messages, your meetings that begin here, and your conduct toward every other member of the community.

2. The Steward Market Standard

Everything in this Code is rooted in what we call the Steward Market Standard—transparency, alignment, and long-term stewardship. The Standard is what we stand for here. It's a signal of intent, not a guarantee.

The Code of Conduct translates the Standard into specific expectations for how members show up on the Platform. When you use Steward Market, you're participating in that Standard. This Code is how we hold it.

3. Who This Applies To

This Code applies to everyone on the Platform:

• Sellers sharing their business, story, and succession plans
• Buyers exploring acquisition opportunities
• Partners offering advisory, brokerage, ESOP, investment, or other professional services
• Steward Market team members who we hold to the same standard

If you are representing an organization on Steward Market, you are responsible for ensuring that anyone acting on your behalf follows this Code.

4. What We Expect

Members of Steward Market are expected to:

Be honest

Represent yourself, your business, your financials, your credentials, and your intentions accurately. If something changes—your timeline, your capital position, your fit for a conversation—update the other person or your listing. Misrepresentation is the single fastest way to lose a place here.

Be respectful

Treat other members as you would a potential long-term partner—because in this context, many of them are. That means respectful disagreement, thoughtful questions, and patience with people at different stages of their process.

Respect confidentiality

Information shared on Steward Market—financials, ownership structures, succession timelines, personal circumstances—is often not public. Treat what you see here as confidential unless you have explicit permission to share it. Do not forward, screenshot, or distribute another member's information without their consent.

Engage in good faith

Show up when you say you will. Respond in reasonable timeframes. If you are no longer actively exploring a conversation, say so. Ghosting, stringing people along, or using the Platform for purposes other than the one you signed up for erodes trust for everyone.

Bring your values to the conversation

Steward Market was built on the premise that ownership transitions are not just financial events. Members are expected to take the values, stewardship intentions, and culture questions seriously—whether they ultimately align with yours or not.

Flag what doesn't belong

Steward Market is largely a self-governing community. We rely on members to surface conduct that falls below the standard. If you see something, flag it (see Section 6). You are not expected to be anyone's moderator—but you are expected to help keep the space healthy.

5. What's Not Okay

The following behaviors violate this Code and may result in content removal, account suspension, or permanent removal from the Platform:

Misrepresentation

• Falsifying your identity, credentials, affiliations, or authority to act on behalf of a business
• Providing false or materially misleading financial, operational, or ownership information
• Misrepresenting your intent—for example, posing as a buyer when you are primarily collecting competitive intelligence
• Inflating or fabricating certifications, track records, or deal history

Breaches of trust

• Sharing another member's confidential information without permission
• Using information learned on the Platform to compete unfairly, solicit the sharing member's employees or customers, or harm the sharing member
• Recording meetings or calls without disclosed consent

Disrespectful or harmful behavior

• Harassment, intimidation, or threats toward any member or the Steward Market team
• Discriminatory conduct based on race, ethnicity, national origin, gender, sexual orientation, religion, age, disability, or similar protected characteristics
• Sexual advances, unwelcome personal contact, or inappropriate content
• Targeted personal attacks, public shaming, or retaliation against members who flag conduct

Platform abuse

• Spam, mass solicitation, or unsolicited marketing outside the purpose of the Platform
• Scraping, crawling, or harvesting data on members, listings, or the Platform itself
• Circumventing Steward Market to avoid fees on introductions facilitated through the Platform
• Creating duplicate, fake, or impersonation accounts
• Using the Platform for purposes unrelated to business ownership transitions, acquisitions, or values-aligned advisory

Unlawful conduct

• Violating securities, anti-money-laundering, sanctions, or other applicable laws
• Offering or soliciting regulated securities in violation of the law
• Infringing intellectual property, privacy, or publicity rights
• Any other conduct that violates our Terms of Service or applicable law

6. How Self-Moderation Works Here

Steward Market is a community of professionals, and we treat it that way. We don't pre-screen every listing, review every message, or sit between every conversation. That approach would be slow, paternalistic, and would signal that we don't trust the people on the Platform—when in fact the quality of the community is what makes it valuable.

Instead:

• You are responsible for your own conduct. The expectations in Section 4 and the prohibitions in Section 5 apply to you without needing a reminder from us.
• You are responsible for your own due diligence. We do not verify the claims other members make. You are expected to assess fit, verify information, and engage your own advisors before making any business decisions.
• The community holds the standard. When something falls below the line, we rely on members to flag it. Self-moderation works when members participate in it.
• We step in when needed. When conduct is flagged, severe, or patterns emerge, Steward Market will investigate and act.

7. How to Report a Violation

If you experience or witness a violation of this Code, please let us know. You can report in any of the following ways:

• Email: support@stewardmarket.com
• Urgent safety concerns: support@stewardmarket.com with “Urgent” in the subject line

When you report, it's helpful (but not required) to include:

• What happened, in your own words
• Who was involved (usernames, listing names, or other identifiers)
• When and where it happened on the Platform
• Screenshots, message excerpts, or other context, if you have them
• Whether the conduct is ongoing

We take every report seriously. We do not require you to confront the other party or resolve the issue yourself. You are not expected to have proof—just your honest account of what happened.

8. Confidentiality and No Retaliation

We treat reports confidentially to the extent we can while still investigating. We will not share the reporter's identity with the person being reported unless it's necessary to investigate, or unless you give us permission.

Retaliation against anyone who reports in good faith—whether through the Platform, by contract, or through other means—is itself a serious violation of this Code and may result in immediate removal from the Platform.

We also recognize that false reports can be used as a weapon. Knowingly submitting a false or bad-faith report is a violation of this Code.

9. How We Respond to Violations

When we receive a report or otherwise become aware of a possible violation, we will:

• Review the report and the available context
• Gather information from the people involved, as needed
• Decide on a response that reflects the severity, pattern, and impact of the conduct
• Follow up with the reporter when we reasonably can, understanding that we can't always share details

Our responses may include:

• A private conversation. Sometimes a direct conversation resolves the issue.
• A warning. Formal notice that conduct must change.
• Content removal. Removing a listing, profile element, or message that violates this Code.
• Feature restriction. Limiting access to messaging, listings, or other Platform features.
• Suspension. Temporary removal from the Platform while we investigate or following a serious violation.
• Permanent removal. Termination of the account, with loss of access to the Platform. Fees paid are non-refundable as set forth in our Terms of Service.
• Legal referral. Referral to law enforcement or appropriate authorities when conduct involves unlawful activity.

We take into account the severity of the conduct, whether it was a pattern or isolated, whether the member has previously violated this Code, and the member's response when notified. Serious violations—fraud, harassment, unlawful activity, significant breaches of confidentiality—may result in immediate removal without prior warning.

Decisions are made by Steward Market in our reasonable discretion. We aim to be fair and consistent. We are not a court, and we do not provide formal adjudication.

10. Relationship to Other Policies

This Code works alongside our Terms of Service, Privacy Policy, and Cookies Policy. Where this Code and the Terms of Service address the same conduct, both apply. This Code does not create additional contractual rights or remedies beyond what is set out in the Terms of Service.

11. Updates to This Code

We may update this Code from time to time as the community grows and as we learn. When we make meaningful changes, we will update the “Last updated” date and, where the changes are material, notify members through the Platform or by email.

12. Contact

Questions about this Code, or want to talk through a situation before deciding whether to flag it? Reach out:

Thank you for helping make Steward Market what it's meant to be.