NerdWallet, Inc. and its affiliates and subsidiaries (collectively, “NerdWallet”) expects the vendors, suppliers, contractors, and other business partners with which we do business (collectively, “Suppliers”) to conduct themselves ethically, with transparency and integrity in their business dealings. To that end, this Supplier Code of Conduct (“Code”) sets forth our minimum requirements for Suppliers, and it is intended to complement each Supplier’s own policies, applicable legal requirements, and the terms of any agreements with NerdWallet.
COMPLIANCE WITH LAWS
We expect Suppliers to comply with the laws and regulations governing their activities in each jurisdiction in which they operate.
HUMAN RIGHTS AND LABOR
We expect our Suppliers to share NerdWallet’s commitment to human rights and equal opportunity in the workplace. Suppliers should have policies and procedures to meet their responsibility to protect and respect human rights that apply to all workers, vendors, and their supply chains. For instance, Suppliers should:
Freely Chosen Employment and Combating Modern Slavery. Not use or permit any form of forced, bonded, or indentured labor, and comply with laws and regulations prohibiting compulsory labor and human trafficking.
Working Hours, Wages and Benefits. Compensate workers with wages, work hours, and benefits as established by applicable law.
Humane Treatment and Non-Discrimination. Establish and conduct activities in a workplace free of harassment and unlawful discrimination.
Health and Safety. Comply with applicable health and safety laws, regulations, and practices.
ETHICS AND COMPLIANCE
We expect our Suppliers to uphold high standards of ethics to promote honesty and integrity in business operations, including:
Business Integrity. Never engage in corruption, extortion, embezzlement, or bribery to obtain an unfair or improper advantage, such as making facilitation payments. Suppliers will abide by all applicable anti-money laundering and anti-corruption laws and regulations of the jurisdictions in which they operate, including, but not limited to, the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and applicable international anti-corruption conventions.
Intellectual Property. Suppliers must comply with the intellectual property ownership rights of NerdWallet and others, including copyrights, patents, trademarks and trade secrets. Suppliers may not use the NerdWallet brand or trademarks without express written permission.
Privacy and Information Security. Suppliers must comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.
Accurate Books and Records. All business dealings should be transparently performed and accurately reflected in your company’s books and records.
Gifts and Entertainment. Gifts and entertainment may create an inappropriate obligation or expectation on the part of the recipient or provider. We expect Suppliers to refrain from providing personal gifts, fees, other compensation, including entertainment activities, which are intended to influence, or might reasonably appear to influence, a business decision. This includes gifts extended to NerdWallet employees if they do not comply with NerdWallet’s Code of Business Conduct requirements to which all NerdWallet employees are subject.
Personal Relationships. Suppliers will disclose all known family or close personal relationships with NerdWallet employees or directors who are involved in the Supplier’s engagement with NerdWallet.
We recognize the importance of working with Suppliers to promote environmental sustainability. We expect Suppliers to review the impact of their operations, adhere to applicable environmental laws and regulations, and operate in a manner protective of the environment and human health and safety.
We expect Suppliers to safeguard and protect NerdWallet’s confidential information. Confidential information should be interpreted broadly to include all nonpublic information relating to NerdWallet and which might be of use to competitors or harmful to NerdWallet or its customers, if disclosed. Suppliers may not disclose or distribute NerdWallet’s confidential information, except when disclosure is authorized by NerdWallet or required by applicable law, rule, or regulation, or pursuant to an applicable legal proceeding. Suppliers shall use confidential information solely for legitimate company purposes. Additional restrictions on the use and handling of confidential information may be included in an agreement you enter with NerdWallet.
If you have questions or concerns about this Code or your business relationship with NerdWallet, please raise them with your NerdWallet business contact or the NerdWallet procurement team ([email protected]).
If you want to report anonymously or report ethical or compliance violations (such as accounting matters or controls, corruption or bribery), these issues may be reported through our online reporting tool nerdwallet.allvoices.co.
We maintain the right to review compliance with this Code and suspend or, under the appropriate circumstances, terminate relationships with a supplier found to be in breach. We may review and update this Code at our sole discretion.