Supplier Code of Conduct
This Supplier Code of Conduct applies to Snap Inc. suppliers and their subsidiaries, affiliates, and subcontractors (each a “Supplier”) providing goods or services to Snap Inc. or for use in or with Snap Inc. or other Snap Inc. products. It sets out legal and social responsibility requirements for our Suppliers. These requirements are in addition to any requirements imposed by contract. References to Snap Inc. in this Code also include Snap Inc. subsidiaries and affiliates, to the extent a Supplier does business with them.
1. GENERAL RULES
Supplier will fully conform with the laws, rules, and regulations (collectively, “laws”) of the countries where it operates, will conform to the requirements of this Supplier Code of Conduct, and will communicate these requirements in writing to its own suppliers and subcontractors. Supplier must be able to demonstrate compliance with the Supplier Code of Conduct on request. Snap Inc. will assess conformance to these requirements and will consider a Supplier’s conformance in making sourcing and procurement decisions.
3. ETHICS REQUIREMENTS
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.
Conflicts of Interest
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.
Intellectual Property & Confidential Information
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.
Disclosure of Information
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.
Fair Business, Advertising & Competition
Supplier will obey applicable laws and uphold industry and regulatory standards of fair business, advertising, and competition.
Training and Communication
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.
Reporting Questionable Conduct
Supplier and its employees should report possible violations of the Supplier Code of Conduct or other questionable behavior. Report by email at email@example.com or access our compliance portal at snap.speakuptrust.com.
4. RESPONSIBLE SOURCING OF MINERALS
Snap Inc. complies with the provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) and corresponding enabling regulations regarding conflict minerals, including regulations promulgated by the Securities and Exchange Commission.
Supplier must exercise all due diligence required by Dodd-Frank to enable accurate reporting to Snap . Supplier must adhere to the OECD Due Diligence Guidance, must exercise diligence on the source and chain of custody of minerals used in their products, and must provide details of their diligence measures on request.
If Supplier produces goods containing tantalum, tin, tungsten, or gold, Supplier must adopt a conflict-minerals policy that is consistent with this Supplier Code of Conduct and the OECD Guidance. Supplier must distribute its conflict-minerals policy to all of its subcontractors and suppliers that provide materials for the manufacture of goods and must obtain agreements from those subcontractors and suppliers that they will also comply with the policy. Supplier may only use tantalum, tin, tungsten, or gold in goods if Supplier can reasonably demonstrate that it has exercised due diligence in accordance with the OECD Guidance regarding the source and chain of custody of such metals, and satisfied the reporting and sourcing requirements of this policy. If Supplier cannot reasonably demonstrate such compliance, then Supplier must not use tantalum, tin, tungsten, or gold in any goods sold to Snap Inc. Supplier must maintain reasonable documentary evidence of Supplier’s reporting, sourcing, and due-diligence activities, and must make such records available to Snap Inc. on request.
5. SUPPLIER QUALITY
Snap Inc. requires that its suppliers provide quality components. We believe quality is best optimized by ensuring that Suppliers have appropriate quality assurance processes and controls.
Supplier must therefore comply with industry standards for manufacturing goods and providing of services to Snap Inc., including a commitment to the philosophy of continuous quality improvement. Supplier will collaborate with Snap Inc. to identify quality issues, risks, and costs, and develop plans for improvement where warranted. Supplier will timely resolve any deficiencies.
Supplier’s commitment to continuous quality improvement will necessarily involve changes to manage cost, quality, delivery, and technology. However, implementation of unapproved changes can have unintended effects on our products. Supplier accordingly will notify Snap Inc. of changes made to materials, products, or processes.
Supplier will make supplier management a part of its quality system. Supplier will actively manage its suppliers, alert Snap Inc. if it becomes aware of any quality (or other) risks posed by a particular supplier, and collaborate with Snap Inc. to agree on how to mitigate and manage any such issues.
Supplier will periodically evaluate its operations and those of its subsidiaries, affiliates, and subcontractors to ensure compliance with this Code. Supplier will allow Snap Inc. or a Snap Inc. agent to conduct an onsite assessment of any operations that are providing goods or services for Snap Inc. or for Snap Inc.’s benefit. Supplier will commit to timely correct any deficiencies identified by an assessment, inspection, or other review.