Legal

Supplier Code of Conduct: April 2023

28 February 20265 pages2,221 words

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.

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