ETHICS
To meet social responsibilities and to achieve success in the marketplace, Supplier will uphold the highest standards of ethics including:
Business Integrity; No Improper Advantage
Supplier will uphold the highest standards of integrity in all business interactions. Supplier will have a zero tolerance policy for offering and accepting any and all forms of bribery, corruption, extortion and embezzlement (covering promising, offering, giving or accepting any bribes). Supplier will perform all business dealings transparently and these dealings will be accurately reflected on Supplier’s business books and records. Supplier will not make illegal payments themselves or through a third party (or agent). Supplier will implement monitoring and enforcement procedures to ensure compliance with anti-corruption laws.
Disclosure of Information
Supplier will disclose information regarding business activities, structure, financial situation and performance in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the Supply Chain is unacceptable and not permitted.
Intellectual Property
Supplier will respect intellectual property rights and will conduct the transfer of technology and know-how in a manner that protects intellectual property rights.
Fair Business, Advertising and Competition
Supplier will comply with all applicable fair business, advertising and competition laws, including fair trading and antitrust laws.
Responsible Sourcing of Minerals
Google expects full compliance with the Dodd-Frank Wall Street Reform and Consumer Protection Act’s provision and corresponding enabling regulations regarding conflict minerals, including regulations passed by the Securities and Exchange Commission and other applicable laws (the “Act”). Supplier will exercise due diligence to comply, and demonstrate compliance, with the Act, regarding the source and chain of custody of these materials. Supplier will make its due diligence measures available to Google upon Google’s request and will respond to Google’s request for compliance information in a timely manner. Supplier will have a policy to ensure compliance with this section.
International Trade
Supplier will comply with all applicable laws and regulations concerning importing and exporting products and services. This includes complying with regulations preventing U.S. companies from supporting or cooperating with an unsanctioned boycott of another country, or from doing business with certain persons or entities.
Privacy
Supplier will commit to protecting the reasonable privacy expectations of personal information of everyone they do business with, including suppliers, customers, consumers and employees. Supplier will comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted and shared.
Non-Retaliation
Supplier will have a communicated process for their personnel to be able to raise any concerns without fear of retaliation. Supplier will also maintain programs that ensure the confidentiality and protection of supplier and employee whistleblowers. A whistleblower is any person who makes a disclosure about improper conduct by an employee or officer of a company, or by a public official or official body.
MANAGEMENT SYSTEM
Supplier will adopt or establish a management system whose scope is related to the content of this Supplier Code. The management system will be designed to ensure: (a) compliance with applicable laws, regulations and customer requirements related to the Supplier’s operations and products; (b) conformance with this Supplier Code; and (c) identification and mitigation of operational risks related to this Supplier Code. It should also facilitate continual improvement.
The management system should contain the following elements:
Company Commitment
A corporate social and environmental responsibility policy affirming Supplier’s commitment to compliance and continual improvement, endorsed by executive management.
Management Accountability and Responsibility
Clear identification by the Supplier of company representatives responsible for ensuring implementation of the management systems and associated programs. Senior management will review the status of the management system on a regular basis.
Legal and Customer Requirements
A process to identify, monitor and understand applicable laws, regulations and customer requirements, including the requirements of this Supplier Code.
Risk Assessment and Risk Management
A process to identify the environmental, health and safety and labor practice and ethics risks associated with Supplier’s operations. Determination of the relative significance for each risk and implementation of appropriate procedural and physical controls to control the identified risks and ensure regulatory compliance.
Improvement Objectives
Written performance objectives, targets and implementation plans to improve the Supplier’s social and environmental performance, including a periodic assessment of Supplier’s performance in achieving those objectives.
Training
Programs for training managers and workers to implement Supplier’s policies, procedures and improvement objectives and to meet applicable legal and regulatory requirements.
Communication
A process for communicating clear and accurate information about Supplier’s policies, practices, expectations and performance to workers, suppliers and customers.
Worker Feedback and Participation
Ongoing processes to assess employees’ understanding of and obtain feedback on practices and conditions covered by this Supplier Code and to foster continuous improvement.
Audits and Assessments
Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the Supplier Code and customer contractual requirements related to social and environmental responsibility.
Corrective Action Process
A process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews.
Documentation and Records
Creation and maintenance of documents and records to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy.
Supplier Responsibility
A process to communicate Supplier Code requirements to the Supply Chain and to monitor Supply Chain compliance to the Supplier Code.
ONGOING ASSESSMENTS, MONITORING AND CONTINUED IMPROVEMENT
If requested by Google, Supplier will provide additional information to ensure adherence to this Supplier Code. Requests may include, among other things, information on social and environmental practices, social and environmental self-assessments, product content details, environmental metrics (e.g., greenhouse gas emissions, water use, water quality data), social metrics (e.g., working hour data, wage information, injury rates), management systems certifications, etc. Monitoring and ongoing resolution of findings are critical for advancing social and environmental responsibility, so Supplier will cooperate with announced or unannounced formal assessments and audits by Google and its agents (who have agreed to obligations of confidentiality similar to those agreed between Supplier and Google).