Legal · February 28, 2026

Supplier Code of Conduct: April 2023

Summary

The Supplier Code of Conduct for Take-Two Interactive Software, Inc., updated in April 2023, establishes the ethical, legal, and professional standards required of all third-party partners. The primary thesis is that all suppliers, consultants, and vendors must mirror the company’s internal commitment to honesty, integrity, and human rights. This mandate extends globally to any entity providing goods or services, including distribution, marketing, and manufacturing, and requires these partners to ensure compliance among their own subcontractors and employees. The document outlines specific legal requirements across several critical domains. Suppliers must strictly adhere to competition and antitrust laws, anti-bribery and corruption statutes such as the US Foreign Corrupt Practices Act and the UK Bribery Act, and anti-money laundering regulations. Furthermore, the scope includes strict compliance with trade sanctions and export controls, specifically highlighting high-risk regions such as Iran, Cuba, Syria, North Korea, and certain areas of Ukraine. Partners are also prohibited from engaging in insider trading based on non-public information gained through their relationship with the company. Beyond legal compliance, the standards emphasize social responsibility and operational integrity. Key provisions include the prohibition of child or prison labor, the protection of fundamental human rights, and the maintenance of a work environment free from discrimination and harassment. Suppliers are required to maintain accurate financial records, protect intellectual property, and avoid conflicts of interest. To ensure adherence, the company reserves the right to conduct periodic audits and requires immediate notification of any legal investigations or violations. A global reporting infrastructure is provided, featuring a 24-hour ethics hotline available across more than twenty countries, supported by a non-retaliation policy for those reporting grievances in good faith.

From the report

PAGE 1 / 5 SUPPLIER CODE OF CONDUCT APRIL 2023 SUPPLIER CODE OF CONDUCT 1. Introduction 1.1 Take-Two Interactive Software, Inc (together with its subsidiaries and afﬁliated companies, “Take-Two”) is committed to conducting business fairly and ethically, complying with domestic and international laws, and promoting a work environment that values honesty, openness, integrity, and respect for fundamental human rights, wherever in the world we operate. Our Global Code of Business Conduct and Ethics reﬂects this commitment. 1.2 We expect and require all of our suppliers, vendors, consultants, and other third parties we engage (“Supplier” or “Suppliers”) to be committed to these same values. Our Suppliers include not only traditional suppliers of goods, software and services to Take-Two, but also businesses providing services on our behalf such as distribution, marketing, shipping, lobbying, manufacturing, consulting, travel and entertainment. 1.3 To this end, we undertake due diligence to conﬁrm Suppliers do business in a manner that is fair, ethical, and respectful of human rights. We also require our Suppliers to adhere to the letter and the spirit of this Supplier Code of Conduct in all business dealings with or on behalf of Take-Two. Its provisions echo those in our Global Code of Business Conduct and Ethics.

, and respectful of human rights. We also require our Suppliers to adhere to the letter and the spirit of this Supplier Code of Conduct in all business dealings with or on behalf of Take-Two. Its provisions echo those in our Global Code of Business Conduct and Ethics. 1.4 Suppliers should likewise ensure that all their employees, agents and subcontractors are fully compliant with all applicable laws and this Supplier Code, including through implementing adequate compliance procedures, training, and monitoring. 1.5 Suppliers must promptly notify Take-Two if, in the course of their work for Take-Two, they become aware that any applicable laws and/or this Supplier Code have been violated. Take-Two must be notiﬁed immediately of any criminal or civil legal actions, investigations, ﬁnes or other sanctions against the Supplier. 1.6 If Supplier fails to comply with applicable law or this Code, Take-Two reserves the right to require the Supplier to take steps to bring itself into compliance or, ultimately, to terminate the business relationship. 1.7 Take-Two reserves the right to require Supplier’s periodic certiﬁcation of compliance with this Supplier Code, and to audit Suppliers on a periodic basis to ensure their compliance. 2. Key Applicable Laws and Requirements Under This Supplier Code 2.1 Competition/Antitrust Laws

7 Take-Two reserves the right to require Supplier’s periodic certiﬁcation of compliance with this Supplier Code, and to audit Suppliers on a periodic basis to ensure their compliance. 2. Key Applicable Laws and Requirements Under This Supplier Code 2.1 Competition/Antitrust Laws In most countries, there are laws that govern the ways in which entities may compete. Generally these laws prohibit agreements and practices that reduce competition. Take-Two expects Suppliers to understand and ensure their full compliance with these laws. Examples of problematic conduct can include:

PAGE 2 / 5 SUPPLIER CODE OF CONDUCT APRIL 2023 (a) agreements to ﬁx prices, co-ordinate or rig bidding activities, allocate markets or customers, or limit product or sales of products; (b) exchanging competitively sensitive information with competitors; or (c) placing certain restrictions on to whom, where and at what price products are re-sold. 2.2 Anti-Bribery and Corruption Laws Take-Two expects full compliance with anti-bribery and anti-corruption laws, including the US Foreign Corrupt Practices Act and the UK Bribery Act. It is illegal and unacceptable for Suppliers to be in any way involved in the payment or receipt of bribes, or with corrupt practices. In particular: (a) Suppliers must not give, offer, receive, or request anything of value (e.g., cash, gifts, business opportunities, charitable donations, favors, etc.) if such is intended to secure an improper beneﬁt. Suppliers must also not pay or receive bribes through third parties, agents, consultants and other intermediaries. Particular care should be taken when Suppliers deal, directly or indirectly, with public ofﬁcials. In particular, Suppliers may not on behalf of Take-Two, or in relation to any activity of the Supplier that may beneﬁt Take-Two, give anything of value to a public ofﬁcial without written approval in advance from Take-Two’s Chief Legal Ofﬁcer or his designee within the legal department.

als. In particular, Suppliers may not on behalf of Take-Two, or in relation to any activity of the Supplier that may beneﬁt Take-Two, give anything of value to a public ofﬁcial without written approval in advance from Take-Two’s Chief Legal Ofﬁcer or his designee within the legal department. (b) Suppliers must be vigilant in monitoring and ensuring the compliance of agents, consultants and anyone performing services on their behalf. Conducting appropriate due diligence and implementing effective compliance procedures relating to third parties is central to mitigating the risk of bribery and corruption. 2.3 Anti-Money Laundering and Tax Compliance Laws Anti-money laundering laws exist in many countries, imposing signiﬁcant penalties for possessing or dealing with the proceeds of crime, as well as concealing the identity of illegally obtained money. Suppliers must understand and ensure full compliance with anti-money laundering laws. Suppliers must also comply with all tax laws and regulations (including sales, income, and other taxes, customs duties and fees, and other types of direct and indirect taxes) that relate to their work for Take-Two. In particular, Suppliers must be vigilant in monitoring for “red ﬂags” in transactions that may indicate non-compliance with these laws, such as requests by third parties to submit or receive payment through unrelated entities or countries; large cash sums or anonymous payment forms (e.g. prepaid cards); or any other oddly structured transactions. 2.4 Trade Sanctions and Export Control Laws

dicate non-compliance with these laws, such as requests by third parties to submit or receive payment through unrelated entities or countries; large cash sums or anonymous payment forms (e.g. prepaid cards); or any other oddly structured transactions. 2.4 Trade Sanctions and Export Control Laws Suppliers must act in accordance with all applicable laws, rules and regulations relating to trade sanctions, export controls, and anti-boycott or blocking activity. Particular care is required at present for any transactions related directly or indirectly to Iran, Cuba, Syria, North Korea or certain areas of Ukraine (Crimean Peninsula, Luhansk and Donetsk) and for any transactions which may involve a party designated under sanctions laws. Suppliers must understand and ensure full compliance with these laws.

Pages: 5
Words: 2,221
Format: PDF
Type: Legal

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