Supplier Code of Conduct
Suppliers will uphold the highest standards of ethics in their operations, including:
Supplier will uphold the highest standards of integrity in business interactions. All dealings will be transparently performed and accurately reflected on Supplier’s books and records. Supplier will have a zero-tolerance policy that prohibits all forms of bribery (covering promising, offering, giving, or accepting any bribes), corruption, extortion, fraud, and embezzlement, and will implement monitoring and enforcement procedures to ensure conformance with anti-corruption laws. When conducting business on behalf of Snap or with Snap employees, supplier will maintain proper business etiquette and will not engage in any of the behaviors described under “No Abuse” and “No Discrimination” in section 2 of this code.
Snap Inc. forbids both actual and apparent conflicts of interest. Supplier must not directly engage with any Snap Inc. employee whose spouse, domestic partner, relative or other family member is employed by or holds a significant financial interest in the Supplier.
Supplier will not give gifts, regardless of value, to any Snap Inc. employee working in procurement or supply chain management. Moreover, supplier will avoid gifts to any Snap Inc. employee when the circumstances create or appear to create a conflict of interest. For example, supplier shall not offer anything of value during a bid process or contract negotiation. Gifts offered or given at such times may appear as attempts to improperly influence Snap Inc. employees. Any gifts, meals, or entertainment must comply with applicable laws, must not exceed $100 in value and must be consistent with local custom and practice. Cash and cash equivalents, such as gift cards, are never acceptable.
Supplier will respect intellectual-property rights. Supplier will transfer technology and know-how in a manner that protects intellectual property rights and conforms to the most stringent information protection requirements under the applicable agreements between Snap Inc. and Supplier. Supplier will use appropriate means to safeguard customer information, in accordance with the most stringent information-protection requirements under the applicable agreements between Snap Inc. and Supplier.
Supplier will disclose information regarding business activities and structure, financial situation, and performance in accordance with applicable law and prevailing industry practices. Falsifying records and misrepresenting conditions or practices in the supply chain are prohibited.
Supplier will obey applicable laws and uphold industry and regulatory standards of fair business, advertising, and competition.
Supplier must implement training and communication programs to educate its employees regarding the requirements of this Code and Supplier’s own related policies. Supplier must maintain a process for communicating clear and accurate information about its practices, policies, and expectations to its workers, next-tier supplier(s), and customers.
Supplier will provide an anonymous complaint mechanism for its employees to report possible violations of this Code and Supplier’s own Code of Conduct. Supplier will protect whistleblower confidentiality and prohibit retaliation.