Supplier Code of Conduct for Individual Talent and Creative Service Suppliers

Take-Two Interactive establishes a mandatory framework for individual talent and creative service suppliers to ensure all external partners operate with integrity, transparency, and legal compliance. Effective as of May 2026, this policy mandates that all third-party creative contributors adhere to ethical standards that mirror the company’s internal code of conduct. The primary objective is to mitigate corporate risk by requiring suppliers to maintain professional environments, protect intellectual property, and strictly follow international trade and anti-corruption regulations.

The policy explicitly prohibits discrimination and harassment, defining these terms to include any conduct that creates a hostile or offensive work environment based on protected characteristics. Furthermore, suppliers are required to safeguard company assets and confidential information, ensuring that non-public data is never utilized for personal gain or insider trading. The guidelines also emphasize strict adherence to global anti-bribery laws, specifically restricting the exchange of value with public officials without prior written authorization.

Operational compliance is a condition of the business relationship. Suppliers must maintain accurate financial records and are obligated to report any legal investigations, criminal actions, or regulatory sanctions related to their work for the company immediately. Failure to comply with these standards or to provide timely notification of legal issues grants the company the right to terminate the contract. Additionally, the policy restricts suppliers from speaking on behalf of the organization to the media or government agencies and mandates strict compliance with international trade sanctions and export control laws, particularly regarding restricted regions and designated individuals.