HERE Suppliers shall conduct their business in accordance with the highest ethical standards and all applicable laws and require the same compliance throughout their entire supply chain.
While conducting business with HERE customers, or otherwise for, on behalf of or in connection with HERE’s business, Suppliers will conduct all activities in accordance with applicable law, with integrity, fairness, respect and in an ethical manner. All business dealings shall be transparently performed and accurately reflected within their records.
HERE expects and requires that Suppliers, in connection with HERE’s business, design, implement and maintain at all times a compliance program, policies, procedures and a system of internal controls, sufficient to ensure compliance with all laws applicable to Suppliers and the standards required by this Supplier Code of Conduct.
All Supplier staff interacting with HERE or undertaking any activity for or on behalf of HERE, must be adequately trained on such compliance program and HERE’s Supplier Code of Conduct. Implementing such formal policies and procedures related to business conduct and compliance helps drive business ethically, honestly, and in full compliance with all laws and regulations.
Do not give or receive bribes
HERE Suppliers shall not engage in corruption, extortion, embezzlement or money laundering in any form, offer, give, receive, or solicit any bribes or employ other means to obtain any improper benefit or advantage in the conduct of their business. HERE Suppliers shall not allow others to make improper payments for their benefit.
HERE Suppliers must comply with all applicable anti-corruption, anti-bribery and anti-money laundering laws and regulations, including the U.S. Foreign Corrupt Practices Act, the UK Anti-Bribery Act, as well as laws governing lobbying, gifts, donations, hiring, and payments to government officials, political campaign contribution laws, and other related regulations.
All countries in which HERE conducts business prohibit bribery. Typically, these laws prohibit providing, or promising to provide, any money or anything of value to a government official, in order to obtain or retain business, or to secure any improper advantage. In some countries this prohibition extends to the commercial context as well (i.e., bribery of employees of private companies). These prohibitions apply whether such action is taken directly, by HERE’s employees or through third parties, such as agents, consultants and intermediaries. It is also illegal and against HERE policy for Suppliers to solicit or accept any payment or anything else of value in return for improperly performing a function of their employment with a Supplier or a duty to HERE. Violation of these laws is a crime that can result in severe fines and criminal penalties. Accordingly, Suppliers must not offer, give, solicit, or receive any form of bribe or kickback anywhere in the world.
It is a violation of this Supplier Code of Conduct (and may be a breach of law) for Suppliers to offer or make a payment or gift of any kind in order to facilitate a local process or to influence a local government official, however small the payment or routine the government function involved.
Additionally, no Supplier may bribe or provide kickbacks or any other improper payments or improper gifts to any director, employee, representative or agent of HERE, or seek any such bribe or kickback from HERE or any other party.
HERE Suppliers must immediately report to HERE any circumstance where an officer, director, employee, representative or agent of HERE has made any improper request or demand of a Supplier.
Maintain accurate accounting records
HERE Suppliers’ accounting records must (1) be kept and presented according to all applicable laws and regulations, (2) in reasonable detail, accurately and fairly reflect transactions, assets, liabilities, revenues, and expenses, and (3) not contain any false or misleading entries. HERE Suppliers must also have robust processes to prevent and promptly identify fraud.
Disclose information truthfully
HERE expects that HERE Suppliers shall disclose information truthfully and as they pertain to their business activities, structure, financial situation, and performance in accordance with applicable laws, regulations, and prevailing industry practices.
Respect Intellectual Property Rights
HERE Suppliers shall always respect intellectual property rights. Any transfer of technology and know-how shall be carried out in a manner that protects intellectual property rights.
HERE Suppliers shall comply with all applicable laws and regulations relating to intellectual property and will not violate, misappropriate or infringe upon the intellectual property rights of any person or entity, including intellectual property belonging to HERE, its customers or other business partners.
HERE Suppliers will only use information technology and software that has been legitimately acquired and licensed. HERE Suppliers will only use lawful methods of gathering competitive intelligence about products that compete with HERE’s technologies.
Do not use counterfeit parts
Counterfeit parts are items that are not as represented with the intention to deceive its buyers or users. HERE Suppliers should prevent such parts from being used in the supply chain.
To do so, HERE Suppliers should:
- Use all appropriate ways to reduce the risk of counterfeit parts being delivered to HERE.
- Notify HERE in writing as soon as HERE Suppliers have come to know or been informed that these counterfeit parts had been delivered to HERE.
Recognize and protect HERE and others' confidential information
From time to time, HERE Suppliers may have access to HERE confidential information and/or personal data that belongs to HERE employees, customers, consumers, developers, and others. HERE Suppliers shall recognize that information and take appropriate actions to protect it from misuse and unauthorized disclosure.
HERE Suppliers who obtain material, nonpublic information about public companies, including HERE's customers, as a result of their relationship with HERE, are prohibited by law and HERE policy from buying, selling, or holding stock or any other security based on that information. HERE Suppliers shall not communicate such information to others who might trade based on that information.
HERE Suppliers should report any event of potential unauthorized disclosure promptly to HERE. If you have questions, contact your HERE representative for help.
HERE expects that HERE Suppliers comply with privacy and information security laws and regulatory requirements, where applicable, when processing, collecting, storing, transmitting, or sharing personal data related to customers, suppliers, consumers, and employees. HERE Suppliers shall commit to protecting the reasonable privacy expectations of personal information of everyone you do business with.
Comply with fair business, advertising and competition laws
HERE Suppliers must understand and comply with all applicable fair business, advertising and competition laws including fair trading and antitrust laws.
HERE's policy is to compete vigorously and ethically while complying with all antitrust and competition laws. Antitrust and competition laws are designed to protect consumers and competitors against unfair business practices and to promote and preserve competition. These laws, among other things, prohibit or restrict activities related to fixing, coordinating, or controlling prices and allocating or dividing customers, territories or markets. As a result, Suppliers should take care in any communications with competitors about any aspect of HERE’s business (e.g., at industry events, trade associations, etc.).
HERE Suppliers must be committed to dealing honestly, ethically, respectfully, and fairly with each other and our competitors, customers, and other Suppliers. HERE expects behavior consistent with this core principle. Suppliers must not make false, misleading, deceptive, or fraudulent statements regarding HERE’s products and services to anyone else. Suppliers must not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation, or any other unfair dealing practice.
Avoid conflicts of interest
HERE Suppliers shall avoid conflicts between them and HERE by ensuring that they disclose any personal or outside business arrangements between their employees and themselves and any HERE employees or their families.
HERE Suppliers must immediately report to HERE in writing any "conflict of interest" they become aware of. A “conflict of interest” is any circumstance, transaction or relationship directly or indirectly involving a Supplier in which the private interest of any director, employee, representative or agent of HERE or the Supplier improperly interferes, or even appears to improperly interfere, with the interests of HERE, or with HERE employees’ or Suppliers' duties owed to HERE.
Source your materials responsibly
If HERE Suppliers manufacture components, parts, or products containing tin, tantalum, tungsten, or gold, HERE Suppliers must source those materials from environmentally and socially responsible sources only. Materials, which either directly or indirectly contribute to a conflict, are unacceptable. Suppliers in this category must exercise due diligence regarding the source and chain of custody of these minerals and make any due diligence measures available to HERE upon request.
Respect international trade restrictions
As a global business powering location-based services for organizations and people around the world, HERE is required to comply with U.S., E.U., Dutch and other countries trade sanctions, and export controls which restrict where and with whom it can do business, including even indirectly through partners. Sometimes these are inconsistent. It is therefore important for HERE to know where and by whom its services and solutions are being provided and accessed and where its raw materials and technology are sourced from.
HERE Suppliers shall comply with all applicable international laws, national laws, regulations, and other controls which govern the transfer, access, export, re-export, and import of products, services, and technology. HERE Suppliers must maintain, where applicable, robust compliance programs and policies to manage technologies, products, and technical data that is controlled or restricted by law.
HERE Suppliers will not provide controlled technologies, products, or technical data to HERE, without providing notice of such controls as necessary for HERE to maintain compliance with applicable laws.
Land, forest, water rights and forced eviction
HERE Suppliers should respect the rights to water and sanitation for people who could potentially be affected by their activities, including their employees, contractors and neighboring communities. HERE Suppliers should seek to avoid any impacts to land, forest or water in areas where they operate and, if not feasible, should adopt mitigation measures that remedy the impact. HERE Suppliers should avoid forced evictions or resettlement of any acquired land for their operating activities.
HERE Suppliers should promote animal welfare in case of procurement of animal derived materials and should comply with all applicable legislation (local as well as international).