Important laws and policies

Equal Employment Opportunity (EEO)

Gorilla 76 is committed to equal employment opportunities for all. We hire, compensate, promote and manage employees based on qualifications and performance without regard to race, color, religion, sex, age, national origin, disability, genetic information, sexual orientation, gender identity, citizenship status, marital status or any other legally protected characteristic.

This policy applies to all aspects of employment, including including hiring, compensation, benefits, promotions and terminations. Violations will result in disciplinary action. Jon and Joe oversee this policy, and employees should reach out to them with any concerns. Inclusivity is one of our core values, and we take it seriously.

Non-discrimination and anti-harassment policy

Illegal harassment is prohibited, and Gorilla 76 will not tolerate it in the workplace. This policy applies to all employees and includes harassment based on age, disability, national origin, sex, race, pregnancy, marital status, military status, sexual orientation and other protected characteristics. Gorilla 76  considers illegal harassment based on protected characteristics to be a major offense and appropriate action will be taken with regard to persons found to have engaged in such conduct including, but not limited to, suspension, demotion, pay decrease and termination.

Gorilla 76 is committed to a work environment in which all individuals are treated with respect and dignity. We believe in fostering a respectful and inclusive workplace. Discriminatory practices and harassment are strictly prohibited. Be kind and treat others as you’d want to be treated. It’s really pretty simple.

Sexual harassment is illegal and includes:

• Unwelcome sexual advances or requests for favors as a condition of employment
• Employment decisions based on submission to or rejection of such conduct
• Behavior that creates an intimidating, hostile or offensive work environment

Per the Equal Employment Opportunity Commission’s (EEOC) definition of sexual harassment, it’s important to note that sexual harassment does not have to involve conduct of a sexual nature in order to constitute unlawful behavior. For example, abusive, offensive or demeaning behavior that is directed to members of one gender only may be deemed a form of sexual harassment, even though the conduct was not motivated by sexual desire or gratification. In addition, harassment of a male by another male or of a female by another female also constitutes an unlawful form of sex discrimination.

Additionally, illegal harassment based on protected characteristics — whether verbal, physical or visual — based on a legally protected characteristic is strictly forbidden. This includes, but is not limited to:

• Inappropriate jokes, slurs or offensive remarks
• Unwanted advances, gestures or suggestive communications
• Favorable or non-favorable treatment
• Retaliation

If you experience or witness harassment:

1. If comfortable, ask the offending party to stop
2. Report the issue to Jon, Joe, Jen Dhar or Stephanie Hall (“Authorized Representatives”) immediately — whether or not you confronted the offender; this includes not only supervisor/subordinate actions but also actions between co-workers, vendors, customers or other non-employees

Managers aware of possible harassment must report it promptly. The identity of the complaining employee, witnesses and alleged harasser will be protected from disclosure as much as is possible under the circumstances of each situation to protect employee privacy and minimize the damage to career and reputation in the event the claim is without merit. Confidentiality cannot be guaranteed. Any employee found to have retaliated against another employee for reporting illegal harassment or participating in a harassment investigation will be subject to disciplinary action up to and including termination of employment. Employees who make complaints in bad faith, may be subject to disciplinary action up to and including discharge.  All employees must cooperate with the investigation.

Disabilities, pregnancy and reasonable accommodation under state and federal law (Americans with Disabilities Act (ADA))

Gorilla 76 is committed to complying with all the relevant and applicable provisions of the Americans with Disabilities Act (“ADA”) and the Pregnancy Workers Fairness Act (“PWFA”), as well as applicable state and local laws. Gorilla 76 will not discriminate against any Qualified individual with a disability (whether employee or job applicant) with respect to any terms, privileges or conditions of employment because of a person’s physical or mental disability. Gorilla 76 will make Reasonable Accommodations for employees or applicants with disabilities, provided that the individual is otherwise qualified to safely perform the Essential Job Functions, with or without Reasonable Accommodation, and provided that the Reasonable Accommodation does not impose an Undue Hardship on the Company or pose a direct threat to safety. Employees who believe Reasonable Accommodation is necessary for them to be able to perform the Essential Functions of their job should notify an Authorized Representative. The Company will collaborate and establish an interactive dialogue with any individual requesting Reasonable Accommodations on a case-by-case basis, to determine if and how Reasonable Accommodation(s) may be provided. Essential Functions are those activities of a job that are necessary to perform the job and cannot be modified

We do not discriminate against any employee due to pregnancy, childbirth, or pregnancy-related conditions. We are committed to providing Reasonable Accommodations to applicants and employees who need such accommodations for any medical, mental or common conditions related to pregnancy and/or childbirth. Such accommodations will be evaluated on a case-by-case basis and may include, if/as appropriate, more frequent, or longer breaks, modifications to job schedules and/or reasonable time off work as may be required by the pregnancy, childbirth or related conditions. Employees covered under the PWFA can be qualified even if they do not perform essential functions of the job so long as the inability is temporary, employee can perform duties in near future and the inability can be reasonable accommodated.

If you need an accommodation, let us know. We encourage open conversations – it’s our hope that you’d never feel this is something you’d need to hide. Jon, for example, has been vocal about his journey with multiple sclerosis, reinforcing our commitment to inclusivity.

Work Authorization

Gorilla 76 is legally bound to hire and keep in employment only United States citizens or aliens lawfully authorized to work in the United States. All employees must produce documentation, upon hire by exhibiting identity and work authorization and complete and sign a verification form (Immigration and Naturalization Service Form I-9) certifying that they are eligible to work in the United States. Before starting work, newly rehired employees must also complete the I-9 form if their previous I-9 is more than three years old or if their previous I-9 is no longer valid.

Victims Economic Safety and Security Act (VESSA)

Gorilla 76 is committed to providing a safe and supportive workplace for all employees. VESSA aims to support employees who may be experiencing domestic violence, sexual assault or stalking by outlining the rights, resources and support available to them. Gorilla 76 prohibits discrimination or retaliation against employees who are victims of domestic violence, sexual assault or stalking.

Employees experiencing these situations are encouraged to notify an Authorized Representative for assistance and support. All information shared will be treated confidentially to the extent possible, respecting the employee’s privacy and safety.

Gorilla 76 will make reasonable accommodations to ensure the safety and well-being of employees affected by domestic violence, sexual assault or stalking. This includes, but is not limited to, adjusting work schedules, providing security measures or granting up to two weeks of unpaid leave as appropriate under applicable leave policies if they need time to address these situations.

Diversity, Equity, Inclusion and Belonging (DEIB)

Gorilla 76 has created, and will maintain, a workplace where everyone feels welcome. We don’t just invite different perspectives to the table, we ask them to be a part of the conversation as well.

We honor this in the following ways:

• Hiring based on skills, not requiring a college degree
• Operating as a remote workforce to increase accessibility
• Accommodating religious needs (see “Time off” section of this handbook)
• Partnering with City Academy to educate youth about careers in marketing
• Regularly reviewing DEIB insights through Workleap Officevibe in leadership meetings.
• Being a veteran-friendly employer — thank you to those who wear, and who have worn, the uniform

Code of conduct

Our success is built upon fair dealing and ethical conduct. Maintaining our reputation for integrity requires strict adherence to all applicable laws and the highest standards of personal and professional behavior. We even have our own code of ethics.

Our clients trust us, and we’re committed to preserving that trust. Employees have a duty to act in a way that upholds the confidence of our clients, colleagues and the public. We comply with all laws and expect employees to do the same, refraining from any illegal, dishonest or unethical conduct.

Conflicts of interest — real or perceived — are unacceptable. Employees must avoid situations where personal interests could conflict with the company’s interests. When in doubt, consult with Jon or Joe.

Every employee is responsible for upholding this Code of Conduct. Violations may result in disciplinary action, up to and including termination.

AI-forward work

1. You’re proficient enough with AI to do quality work faster and more thoroughly than you could do by hand
2. You keep asking what new AI capabilities make possible for our clients

1. Use any Gorilla-provided skills, assets and systems that apply to your work
2. Solve problems; when you notice a gap, whether it’s an issue with a skill or system or a new way to deliver value for clients, build a v1 of the solution to start the conversation
3. Managers examine how work gets done in their departments and propose systems that create capacity or more value for clients

Personal operating systems policy

We’ve built systems that help us use AI to produce quality work (not slop). One is a personal operating system we call a “Second Brain.” It gathers the context of your role (email, meetings, the project management system) into one place AI tools can search. It’s the best way we’ve found to give AI the context it needs to be useful.

Having a Second Brain is optional. People who have one find it helps them organize priorities and do work that reflects the full context of their role. If you choose to leave Gorilla, you may delete anything personal from it and export what the team needs: skills and automations, client context and process documents for your role. We won’t save your Second Brain in a shared Dropbox folder or hand it to anyone on the team. No one will open it unless the handoff of context and skills didn’t happen. Once necessary shared context has been exported, your second brain will be deleted. It’s important to remember that any work done on a company computer reflects on the company and on you, individually, and is property of the company. And there may be situations where we are required to preserve files from your computer.

Shared knowledge systems policy

Our shared knowledge system holds all client context: customer research, positioning, consulting calls, workshops, subject-matter expert interviews and more. Everyone is responsible for “promoting” client calls, and anything else that would help a teammate on that account, into the system. Account managers keep their clients current there.

AI notetakers and transcriptions

We use AI notetakers as a key context source on work decisions, client information and commitments. When this context is available, it enables a number of down-stream benefits:

• Recording client meetings allows us to populate a shared knowledge base that any team member can pull from as they complete work (content, consulting, quarterly planning, workshop prep) for that client; it also allows us to draw on the collective “knowledge” across all our client work for Gorilla marketing (case studies, blog posts, podcast planning, original research and more)
• Recording internal meetings can help you remember priorities and tasks, and allows for seamless briefing with all of the context and various viewpoints (anonymized) if an issue needs to be communicated to another department or person; it also allows for greater visibility to the manager on the overall issues their department is facing, to enable better long-term planning on how to improve things for their department
• Collectively, notes about all of the conversations you’re having at work allow you to more effectively remember one-off commitments you made in meetings, themes about issues your team is experiencing to spot opportunities for us to improve our operations — and the bank of subject-matter expert interviews, customer research and client calls allow us to more effectively and efficiently complete client work

AI enables us to gather more context about our work than every before — for any number of downstream benefits. Every Gorilla will be given an AI notetaker they can bring to meetings.

A few notes on AI notetaker expectations:

• Always (always, always) let someone know you’re recording by clearly calling it out in the calendar invite as well as by enabling proactive notifying people (through watermarking your video, messages sent in Zoom or verbally announcing it
• Always record client meetings; you can turn it off if a client asks you to
• Record department meetings by default, though you can turn it off when needed
• Record other internal meetings (one-off 1:1s, working sessions) when you’ll want to reference the discussion later
• In internal meetings, anyone can ask you to stop recording; stop when asked
• Rule of thumb: Will this be useful to my work later? Do I have consent to record?

You don’t need to record everything. Skip personal catch-ups, and feel free to turn it off if having the recorder is preventing you from feeling comfortable finding the words to describe an issue accurately.

Recorded or not, any conversation on a company device or on the company’s behalf reflects on Gorilla and on you. We expect every Gorilla to act in line with our core values and the policies in this handbook.

AI policy for content

Clients who provide confidential information throughout the course of a normal business relationship hold the reasonable expectation that their information will not be shared with third parties – and we’re bound to that expectation when that information is explicitly protected by an NDA. However, clients should also understand that their information is shared within our company and the third-party contractors with which we engage, including Dropbox, Rev, Loom, Zoom and ChatGPT, among others. We already follow strict confidentiality practices to protect all sensitive information in these platforms. This policy reinforces existing protocols and applies to all employees of Gorilla 76 and to all work that its employees perform.

Given the novel application of traditional guidelines covering data privacy and protection with generative AI, our approach must be cautious and conservative. The force of this caution depends on the platform’s security. The following advisories address paid and free generative AI use separately.

All tools will be documented in our internal employee software tracking sheet.

Paid generative AI

Unless you have received explicit permission for an alternative LLM (large language model), Gorilla 76 employees are to use paid versions of Google Gemini, OpenAI’s ChatGPT and Claude by Anthropic. Per the controlling companies’ own policies, these secure conversations are not used to train the LLMs. Since the platforms’ security measures are engineered to safeguard sensitive data, Gorilla 76’s exposure to liability is significantly reduced. However, we must still exercise due diligence in managing and controlling access to sensitive data in order to ensure compliance with legal standards.

Each department director’s approval grants limited use of generative AI chatbots. Company email addresses, credentials or phone numbers can be used to create accounts with these platforms.

Employees wishing to use a new-to-Gorilla generative AI must inform their director. Directors must approve or deny requests within ten (10) days. Directors will seek approval from co-founders when necessary. All AI-generated content must be reviewed for accuracy before relying on it for work purposes. If factual information cannot be verified by a reliable source, that information cannot be used.

Acceptable uses include but are not limited to:

• Brainstorming
• Building outlines or summaries
• General knowledge building to enhance your grasp of complex topics
• Rephrase headlines, metadata, sentences or content personalization
• Clarifying highly technical, rambling exchanges in SME (subject matter expert) interviews
• Thematic analysis for product market canvas and positioning preparation
• Creating formulas for Excel spreadsheets or similar programs
• Foreign language translations
• Spreadsheet calculations
• Coding development or debugging

Unacceptable uses include but are not limited to:

• Using direct, AI-generated content without intervening to verify that it meets ethical and operational standards
• Inputting client information explicitly shielded by “off the record” requests

If you don’t know whether an application is acceptable or not, contact your director.

Unpaid generative AI

Feeding data into free versions of generative AI may release it into an LLM knowledge pool with uncertain permanence. Employees must avoid inputting “unanonymized” data that could be sensitive or proprietary. Due to its extensive learning capabilities, future renditions of AI could de-anonymize data.

The department director’s approval grants limited use of generative AI chatbots. Company email addresses, credentials or phone numbers can be used to create accounts with these platforms. Personal or sensitive company data of any kind must not be submitted to these platforms.

Employees wishing to use generative AI chatbots must inform their director how the chatbot will be used. Directors must approve or deny requests within ten (10) days. Directors will seek approval from co-founders when necessary.

Acceptable uses include:

• Brainstorming
• Building outlines or summaries
• General knowledge queries to enhance your grasp of complex topics
• Prompting to rephrase anonymized headlines, metadata, sentences or content personalization
• Foreign language translations
• Spreadsheet calculations
• Coding development or debugging

Unacceptable uses include:

• Using direct, AI-generated content without intervening to verify that it meets ethical and operational standards
• Using AI-created text without a thorough review of factual verification
• Inputting client information, even in an anonymized form, that is vulnerable to de-anonymization
• Names, phone numbers, email addresses, proprietary engineering information (as vague as verbal descriptions to CAD models and everything in between) or anything explicitly protected by an NDA or “off the record” request

If you do not know whether an application is acceptable or not, contact your director.

Training

All managers will be trained on the nuances of data privacy and protection in the context of generative AI to reinforce a comprehensive understanding of the risks involved.

Ethical use

Whether free or paid, employees must use generative AI while respecting the confidentiality and privacy of client information, in accordance with our understanding of data protection laws and expectations. Employees must also use generative AI in accordance with all of Gorilla 76’s conduct and anti-discrimination policies. These technologies cannot be used to create content that is inappropriate, discriminatory or otherwise harmful.

Employees agree to abide by all company policies regarding generative AI and the like.

Confidential nature of work

Our customers trust us with very confidential information. All Gorilla 76 records and information relating to Gorilla 76 or its customers are confidential and employees must treat all matters accordingly. This includes customer lists and information, company financial information, marketing strategies, sales materials and any other material labeled as confidential. That’s why we ask you to sign a Confidentiality Agreement.

Employees who are unsure about the confidential nature of specific information should ask their manager for clarification. Employees who improperly use or disclose trade secrets or confidential business information will be subject to disciplinary action, up to and including termination of employment and legal action, even if they do not actually benefit from the disclosed information.

Health and safety

The well-being of our employees is a priority.

As a remote company, we minimize in-person interactions. However, meetings and events still occur. If you’re feeling unwell, please refrain from attending any Gorilla-related gatherings. When visiting client offices or worksites, employees must comply with all health and safety policies in place at those locations.

This guidance applies to all employees of Gorilla 76.

People policy

This is our commitment to our people during this time of change, as AI is transforming marketing faster than most agency models can adapt. And while we believe our industry will exist in five years, we also believe it will look quite a bit different.

Roles will evolve and deliverables will change, making smart and versatile marketers more valuable than ever. The agencies that grow complacent will become irrelevant, as will the individuals.

We won’t let that happen at Gorilla. We’ll remain people-first and AI-forward.

This creates an opportunity to build marketers who are ready for the future, provide stability for our team and their families, and strengthen a culture where people feel valued and take pride in their work.

As a company, we commit to…

• Reinvesting in our people through up-skilling and personal development
• Evolving our product offerings, redeploying affected Gorillas per their strengths
• Piloting new ways of using AI in our work
• Designing tests that minimize client risk, and sharing what we learn — good and bad
• Staying true to our Core Values, because acting ethically matters more than ever

The Gorilla in our name comes from a nod to guerilla marketing. When we hung our shingle in 2006, we succeeded by working in unconventional ways and adapting constantly. Evolution is in our DNA. Please choose to be curious — we’ll be our strongest when we all take up-skilling seriously.

Our people are what make us special. Our goal is to equip every Gorilla — and our agency — for the future of our industry. We have the right people to build what’s next. Answer the call, work as a team and develop the skills we’ll all need to thrive in an AI-native world.