Vendor Code of Conduct

Updated and effective
as of November 6, 2014

Activision Blizzard, Inc. and its subsidiaries, including Activision Publishing, Inc. and Blizzard Entertainment, Inc. (collectively, “Activision Blizzard”), are committed to maintaining the highest level of integrity and honesty throughout all aspects of its business.  Activision Blizzard believes that it is the responsibility of its business associates, including its vendors and suppliers and their respective sub-contractors and suppliers, to treat others with honesty and respect and to otherwise act in accordance with the highest ethical standards.  As such, Activision Blizzard intends to transact business only with persons that operate in compliance with the requirements described in this Vendor Code of Conduct (“our Vendor Code of Conduct”).

Every business associate must comply with all laws and regulations applicable to its business and Activision Blizzard’s business.  Each business associate must also ensure all of its sub-contractors and suppliers comply with the standards in our Vendor Code of Conduct with respect to work performed for the ultimate benefit of Activision Blizzard.  In addition, each business associate is responsible for ensuring that its employees are aware of the laws and regulations related to their job activities so that they can perform their work in accordance with the letter and spirit of the law. 


The standard of ethical conduct to which business associates must adhere, however, goes beyond mere compliance with legal requirements and also includes those standards of behavior to which people with a strong commitment to social responsibility adhere.

No one under the local legal age limit or the age of 15, whichever is greater, may be allowed to work in a facility that produces merchandise or performs any service for Activision Blizzard.  Activision Blizzard encourages the creation of apprenticeship programs tied to formal education for young people as long as students will in no way be exploited or placed in situations that endanger their health or safety. 

Under no circumstances may business associates use forced or prison labor of any kind.  Further, under no circumstances may business associates work with any person that uses forced or prison labor.

Business associates will not use corporal punishment or any form of physical or mental coercion.  Business associates will not permit sexual harassment by, or of, their employees. 

Business associates must recognize the right of employees to choose (or to choose not) to affiliate with legally sanctioned organizations or associations without unlawful interference.  Business associates must not discriminate on the basis of gender, race, color, national origin, ancestry, religion, creed, physical or mental disability, pregnancy, sexual orientation, gender identity, gender expression, marital status, medical condition, military or veteran status, age or any other basis protected by federal, state, or local law.  

Business associates must provide a safe and healthy working environment for their employees.  Furthermore, if housing is provided to their employees, such housing must be clean and safe. 

All business associates must set working hours, wages and overtime pay that are in compliance with all applicable laws.  Workers must be paid at least the minimum legal wage applicable in their respective countries.  While overtime is often necessary in consumer product production, business associates must operate in a manner that limits overtime to a level that ensures humane, safe and productive working conditions.  Overtime, if necessary, must be paid in accordance with local laws. 

Business associates must comply with all applicable laws and regulations relating to the environment and share Activision Blizzard’s commitment to the environment. 

Business associates that supply Activision Blizzard with physical products are expected to take steps to determine whether the supplied products contain any conflict minerals (i.e., columbite-tantalite (coltan), cassiterite, gold or wolframite, or their derivatives tantalum, tin and tungsten).  If so, Activision Blizzard expects business associates to implement supply chain due diligence processes to identify the sources of these conflict minerals and to support efforts to eradicate the use of conflict minerals that directly or indirectly finance or benefit armed groups in the Democratic Republic of the Congo or any adjoining country.

Business associates must adhere to all United States and foreign customs laws, including all import and export regulations.  Business associates are prohibited from participating, in any manner, in the ‘trans-shipment’ of merchandise from one country to another country in order to illegally evade a country’s customs laws. 

Business associates may not engage in corrupt practices of any kind, including private or public bribery or kickbacks.  Business associates will maintain integrity, transparency and accuracy in corporate record keeping.

Business associates will act lawfully and with integrity in the proper handling and protection of competitive data, proprietary information and other intellectual property (including but not limited to trade secrets, patents, trademarks, and copyrighted works) and comply with applicable legal requirements regarding fair competition, antitrust, and accurate and truthful marketing.  Business associates shall safeguard and make only proper use of confidential information to ensure that Activision Blizzard, worker and customer privacy are protected.

In the event that a business associate becomes aware of any actual or potential violation of any provision in our Vendor Code of Conduct, including any unlawful or unethical situation, that business associate is expected to promptly report its concerns to Activision Blizzard at vendorcompliance@activisionblizzard.com. Every business associate is expected to provide reasonable assistance to any investigation by Activision Blizzard under our Vendor Code of Conduct, and must protect its employees and contractors from any form of retaliation for reporting an actual or potential violation or for assisting in an investigation or proceeding regarding a suspected violation.

The failure of a business associate to comply with one or more of the foregoing guidelines shall give Activision Blizzard the right to immediately terminate any and all agreements with the business associate and its affiliated companies.  Additionally, such compliance failure may result in the business associate’s civil liability and criminal prosecution under the law of the appropriate jurisdiction.  

I have read and understand the Activision Blizzard Vendor Code of Conduct. I acknowledge and agree to adhere to its guidelines. I further understand that any failure to comply with one or more of the guidelines contained in the Vendor Code of Conduct may result in the immediate termination of my business relationship with Activision Blizzard and my civil liability and criminal prosecution under the laws of the appropriate jurisdiction.


ACKNOWLEDGED AND AGREED:

 

 

Date:   ___________      _________________________________

(Name of Entity)

 

By:  ______________________________

 

 

_________________________________

(Print Name)

 

Title: ______________________________


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