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.

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, and will communicate these requirements in writing to its own employees, suppliers, and subcontractors. Supplier must ensure that adequate and effective management systems, policies, procedures, and training are in place to ensure ongoing compliance with this Supplier Code and be able to demonstrate compliance on request. Supplier senior executive and company representatives should be responsible for ensuring implementation of related programs and be committed to continuous improvement. Snap will assess conformance to these requirements and will consider a Supplier’s conformance in making sourcing and procurement decisions. Failure to adhere with the requirements of this Supplier Code may result in immediate termination of Supplier’s relationship with Snap.

Overview

Our Social Responsibility Standards are drawn from the Responsible Business Alliance (RBA) and industry codes of conduct, International Labor Organization Conventions, the Universal Declaration of Human Rights, and the UN Guiding Principles on Business and Human Rights. They require all suppliers to ensure that working conditions in their operations and supply chains are safe, that all workers are treated with respect and dignity, and that operations are environmentally responsible and conducted ethically.

Labor & Human Rights

Supplier must uphold the human rights of workers and treat them with dignity and respect. This applies to all workers, including without limitation temporary, migrant, student, juvenile contract, and dispatch workers, as well as direct employees.

No Forced Labor

Supplier will not use forced, bonded (including debt bondage), indentured, or involuntary prison labor, and will not engage in slavery or trafficking of any person. Supplier will ensure that workers have access to their personal documentation (e.g., government-issued identification, passports, or work permits), and will pay any agency recruitment/employment fees and expenses.

No Child Labor

Supplier will not use child labor. We consider child labor to be anyone under 15 years of age unless local law sets a lower age threshold. Supplier agrees that workers under 18 will not perform work that is likely to jeopardize their health or safety, including work overtime or perform night work or physically demanding labor.

Working Hours

Supplier will comply with applicable work hours and overtime laws. Unless local law sets a lower maximum, Supplier will set the maximum at 60 working hours/week, including overtime, except in emergencies, and will guarantee at least one full day off every seven days.  All overtime shall be voluntary, and workers shall be allowed at least one day off every seven days.

Wages & Benefits

Supplier will comply with all applicable wages and benefits laws, including those relating to minimum wages, overtime hours, and legally mandated benefits.

No Discrimination/No Harassment/No Abuse

In its hiring and employment practices, Supplier will not discriminate based on race, color, age, gender, sexual orientation, gender identity or expression, ethnicity or national origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic information or marital status or any other category protected under applicable law. Workers or potential workers should not be subjected to medical tests or physical exams that could be used in a discriminatory way.

Supplier will comply with all applicable laws on abuse of employees. Supplier will not engage in any harsh or inhumane treatment, including but not limited to violence, gender-based violence, sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying, public shaming, or verbal abuse of workers. Disciplinary policies and procedures in support of these requirements shall be clearly defined and communicated to workers. Workers shall be provided with reasonable accommodation for religious practices and disability. 

Freedom of Association

Supplier will comply with all applicable laws on freedom of association and collective bargaining. Workers’ right to associate freely, seek representation, and join worker councils will be respected.

Security

Where applicable, Supplier recognizes they should follow company security guidelines to keep Snap safe and will comply with security policies. 

Health & Safety

Supplier recognizes that a safe and healthy work environment minimizes work-related injury and illness, enhances the quality of products and services, and boosts consistency of production and worker retention and morale. Supplier will comply with all applicable health-and-safety requirements and ensure that the following requirements are met:

Occupational Health and Safety. The exposure of workers to chemical, biological, and physical agents must be identified and evaluated. Supplier will control worker exposure to potential safety hazards according to the hierarchy of controls through proper design, engineering and administrative controls, preventative maintenance and safe work procedures, and ongoing safety training. Workers shall be provided with appropriate, well-maintained, personal protective equipment, training on how and when it needs to be applied and educational materials about risks to them associated with these hazards. Workers shall be provided a low stress working environment, without pressure of productivity at the risk of personal safety. Supplier must also take reasonable steps to remove or reduce any workplace health and safety risks for pregnant women and nursing mothers. 

Emergency Preparedness. Supplier will implement emergency plans and procedures including: emergency reporting, employee notification and evacuation procedures, employee evacuation coordinators, worker training and drills, appropriate fire detection and suppression equipment, adequate means of egress, and recovery plans.

Occupational Injury and Illness. Supplier will implement procedures and systems to prevent, manage, track, and report occupational injury and illness.  Workers have the right to refuse unsafe work and to report any hazardous or unhealthy working conditions, near-misses, or safety observations, without fear of retaliation. Supplier shall allow workers to remove themselves from imminent harm, and not return until the situation is mitigated, without fear of retaliation. 

Industrial Hygiene. Supplier will identify, evaluate, and control worker exposure to chemical, biological, and physical agents. Hazardous chemicals must be properly labeled according to Globally Harmonized System (GHS) regulations, a Safety Data Sheet (SDS) must be provided for all chemicals onsite, and an effective chemical hygiene plan must be implemented if required. Where exposure potential is high, hygiene monitoring should take place to actively reduce harm to human health.

Physically Demanding Work. Supplier will identify, evaluate, and control worker exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing, and highly repetitive or demanding assembly tasks. Office and/or Industrial ergonomics must be addressed, and equipment made available to employees in need.

Machine Safeguards. The machinery must be evaluated for safety hazards. Supplier will provide physical guards, interlocks, light curtains, emergency stops, and/or barriers where machinery presents a hazard, and will ensure these protections are properly maintained in accordance with machinery safety guidelines and regulations for that location. 

Operators of any tool or machine will have been trained on the relevant Standard Operating Procedures or Original Equipment Manufacturer manuals. These materials must highlight safe work and preventative maintenance and be maintained.

Sanitation, Food, and Housing. Supplier will ensure that workers are provided with ready access to clean toilet facilities, potable water, and sanitary food preparation, storage, and eating facilities. Workers must have access to drinking water and cooling structures if working in a warm weather environment, or during an evacuation into warm outdoor weather.

Worker dormitories or other housing provided by Supplier or Supplier’s agent will be well-maintained, clean, and safe. Any such housing will feature appropriate emergency egress and fire protection/suppression, hot water for bathing and showering, adequate heat and ventilation, and reasonable personal space along with reasonable entry and exit privileges.

Health and Safety Communication. Supplier shall provide workplace health and safety information and training for identified workplace hazards that workers are exposed to such as, mechanical, electrical, chemical, fire, and physical hazards. Health and safety related information shall be clearly posted in the facility or placed in a location identifiable and accessible by workers. Supplier shall comply with Snap workplace safety policies and procedures as applicable to their role.

First Aid. Workers must have access to first aid kits, Automated External Defibrillator (AED), fire extinguishers, and eyewash stations/safety showers, if necessary, within 75 feet of normal working locations. 

Environment

Supplier will take steps to eliminate any adverse (and potentially adverse) effects on the community, environment, and natural resources and to safeguard health and safety. Specifically:

Environmental Permits. Supplier will obtain, maintain, and keep current all required environmental permits, approvals, and registrations and will follow their operational and reporting requirements.

Pollution Prevention and Resource Conservation. Supplier will work to reduce or eliminate waste of all types, including water and energy, by practices such as modifying production, maintenance and facility processes, materials substitution, conservation, and recycling and reusing materials.

Hazardous Substances, Dangerous Goods and Waste. Supplier will identify, track, and manage chemicals (and other materials that would pose a hazard if released to the environment including universal waste) to ensure their safe handling, movement, storage, use, recycling and reuse, and disposal. Dangerous goods will only be shipped in accordance with local regulations as set globally within the ADR/IATA framework. All hazardous materials will be supplied to the end user with a safety data sheet. 

Solid Waste. Supplier shall implement a systematic approach to identify, track, manage, reduce, and responsibly dispose of or recycle solid waste (non-hazardous).

Water Management. Supplier shall implement a water management program that documents, characterizes, and monitors water sources, use and discharge; seeks opportunities to conserve water; and controls channels of contamination. All wastewater is to be characterized, monitored, controlled, and treated as required prior to discharge or disposal. Water discharge/runoff will be compliant with any licensing/permitting requirements applicable to that location. 

Air Emissions. Supplier will characterize, monitor, control, and treat air generated by its operations before discharge. Ozone-depleting substances shall be effectively managed in accordance with the Montreal Protocol and applicable regulations.

Materials Restrictions. Supplier will adhere to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances such as Substances of Very High Concern (SVHCs), in products and manufacturing, including labeling for recycling and disposal.

Energy Consumption and Greenhouse Gas Emissions. Where applicable, Supplier is to establish a corporate-wide greenhouse gas reduction goal. Energy consumption on all Scope 1, 2, and significant categories of Scope 3 greenhouse gas emissions shall be tracked. 

Suppliers will uphold the highest standards of ethics in their operations, including:

Business Integrity

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. 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 the “No Abuse” and “No Discrimination” sections of this Supplier Code.

Anti-Bribery and Anti-Corruption

Supplier will have a zero-tolerance policy that prohibits all forms of bribery (defined as promising, offering, giving, or accepting anything of value to improperly influence a decision), corruption, extortion, fraud, tax evasion, and embezzlement, and will implement monitoring and enforcement procedures to ensure conformance with anti-corruption laws. 

Gifts

In all cases, Supplier’s use of gifts and entertainment must have a proper business justification, be legal under local law, and be appropriate under local custom. Cash and cash equivalents, such as gift cards, are never acceptable. Supplier cannot give gifts to third parties on Snap’s behalf, or otherwise related to Snap’s business, without prior written authorization from Snap’s Integrity & Compliance department (compliance@snap.com). 

Supplier gifts and entertainment to or from other Snap team members should never exceed $300 USD and must never 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 employees. 

Conflicts of Interest

Snap forbids both actual and apparent conflicts of interest. Supplier must not directly engage with any Snap employee whose spouse, domestic partner, relative or other family member is employed by or holds a significant financial interest in the Supplier. 

Trade Restrictions and International Sanctions 

Supplier must respect all applicable international trade restrictions and economic and trade sanctions, as well as all applicable laws and regulations concerning export and import controls.  Supplier will not take any actions on Snap’s behalf that causes Snap to violate applicable trade restrictions and sanctions, including but not limited to those promulgated by the United States and the United Kingdom. 

Prevention of Insider Trading

Supplier must refrain from selling or buying shares in Snap based on inside information, either directly or indirectly.

Privacy, Intellectual Property & Confidential Information

Supplier will commit to protecting the reasonable privacy expectations of personal information of everyone they do business with. Supplier is to comply with privacy and information security laws and regulatory requirements for personal information collected, stored, processed, transmitted, and shared.

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 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 and Supplier.

Disclosure of Information

Supplier will disclose information regarding business activities and structure, financial situation, labor, health and safety, environmental practices, and performance in accordance with applicable law and prevailing industry practices. Falsifying records and misrepresenting conditions or practices in the supply chain are unacceptable.

Fair Business, Advertising & Competition

Supplier will uphold standards of fair business, advertising, and competition. Supplier must comply with antitrust and competition regulations, and refuse to participate in any potentially anticompetitive behavior with competitors such as those relating to pricing, bid rigging or allocation agreements.

Training & Communication

Supplier must implement training and communication programs to educate its employees to meet the standards set by this Supplier 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. If Snap deems it necessary to offer additional training of its own choosing directly to Supplier’s employees, Supplier will cooperate with Snap to implement such training and ensure its success. 

Whistleblower Protection

Supplier will provide an anonymous complaint mechanism for its employees to report possible violations of this Supplier 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 this Supplier Code or other questionable behavior. Supplier may report questionable conduct to the Snap employee with whom they have a business relationship, by email at compliance@snap.com, or via Snap’s compliance helpline at https://www.snaphelpline.com. The compliance portal is a confidential and secure way to report concerns which is managed by a third party to help protect the identity of reporters.

Snap 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 Organisation for Economic Co-operation and Development (OECD) Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas or an equivalent and recognized due diligence framework, 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 (3TG), Supplier must adopt a conflict-minerals policy that is consistent with this Supplier Code and the OECD Guidance. Supplier must distribute its conflict-minerals policy to all 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 3TG 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 3TG in any goods sold to Snap. Supplier must maintain reasonable documentary evidence of Supplier’s reporting, sourcing, and due-diligence activities, and must make such records available to Snap on request.

Snap requires that its suppliers provide quality components and components that comply with applicable regulatory requirements. 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 services to Snap, including a commitment to the philosophy of continuous quality improvement. Supplier will collaborate with Snap 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 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 if it becomes aware of any quality (or other) risks posed by a particular supplier and collaborate with Snap to agree on how to mitigate and manage any such issues.

Supplier shall adopt or establish a process to identify, monitor, and understand applicable laws. Supplier shall adopt or establish a process to identify the legal compliance, environmental, health and safety, labor practice and ethics risks, including the risks of severe human rights and environmental impacts, associated with Supplier’s operations. Supplier will periodically evaluate its operations and those of its subsidiaries, affiliates, and subcontractors to ensure compliance with this Supplier Code.

Supplier shall establish written performance objectives, targets and implementation plans to improve their social, environmental, and health and safety performance, including a periodic assessment of their performance in achieving those objectives. Supplier will allow Snap or a Snap agent to conduct an onsite assessment of any operations that are providing goods or services for Snap or for Snap’s benefit. Participants shall determine the relative significance of risks identified during the assessment and implement appropriate procedures and controls to ensure regulatory compliance.

Last Updated March 2024