Global Supplier Code of Conduct

The Global Supplier Code of Conduct establishes the ethical and legal standards required of all third parties engaged by Take-Two Interactive Software, Inc. The primary purpose of this document is to ensure that suppliers, vendors, consultants, and service providers operate with integrity, transparency, and respect for human rights. By mandating adherence to these principles, the company seeks to mitigate operational, legal, and reputational risks across its global supply chain, which encompasses diverse functions such as manufacturing, distribution, marketing, and consulting.

The code outlines specific requirements across several critical domains, including compliance with antitrust, anti-bribery, and anti-money laundering laws. It explicitly prohibits corrupt practices, such as the exchange of bribes or improper gifts, and mandates strict adherence to international trade sanctions and export controls. Furthermore, the document addresses corporate governance by requiring accurate financial record-keeping, the protection of intellectual property and confidential information, and the prevention of conflicts of interest. Suppliers are also expected to uphold rigorous standards regarding labor rights, including the prohibition of child and prison labor, the prevention of harassment and discrimination, and the maintenance of safe working environments.

To ensure compliance, the company reserves the right to conduct periodic audits and require formal certifications from its partners. Suppliers are obligated to monitor their own subcontractors and report any legal violations or investigations immediately. The document also provides a global reporting framework, including a 24/7 ethics hotline and an online portal, to facilitate the disclosure of potential misconduct. Take-Two maintains a policy of non-retaliation for individuals who report concerns in good faith, emphasizing that failure to meet these standards may result in corrective action or the termination of the business relationship.