Blackhawk Network, Inc. Supplier Code of Conduct
At Blackhawk Network, we are committed to doing business responsibly, ethically, and honestly. We expect our suppliers, vendors, and partners (collectively referred to as “Suppliers”) to share the same principles. To provide guidance, we have developed this Supplier Code of Conduct, which sets out our expectations for anyone who does business with Blackhawk Network Holdings, Inc., or any of its subsidiaries around the globe (“Blackhawk Network”). We encourage our Suppliers to require their subcontractors to acknowledge and implement equivalent standards of conduct.
Business Practices and Ethics
- Prohibit Bribery and Corruption. Our Suppliers must not directly or indirectly offer or accept bribes—or anything else of value—to obtain an improper advantage in business dealings. This applies to dealings both with private, commercial entities, as well as public entities that are related to or controlled by the government. Suppliers must comply with all applicable anti-corruption laws, including, without limitation, the U.S. Foreign Corrupt Practices Act and the United Kingdom Bribery Act. Facilitating payments (also known as “grease payments”) are small payments made to lower-level government or private sector employees to secure or speed up performance of routine actions, such as processing government papers, issuing licenses or permits, or clearing goods through customs. Blackhawk Network prohibits facilitating payments, and Suppliers must not make any such payments on our behalf.
- Limit Gifts, Meals, and Entertainment. Suppliers must avoid giving gifts or hospitality that may influence, or appear to influence, the independent judgment of Blackhawk Network employees, or any other individuals with whom Suppliers deal with on our behalf. We understand that gifts, meals, and entertainment are a form of courtesy in many countries, and we allow items of reasonable value that are appropriate to the circumstances and would not be understood by the recipient or others as a bribe. Gifts and hospitality should be infrequent in occurrence, should never be in the form of cash or cash equivalents, and must be permitted by all applicable laws. Promotional gift cards of nominal value that are given infrequently and used to demonstrate our products and services are acceptable.
- Avoid Conflicts of Interest. Suppliers must disclose any potential conflicts of interest that influence—or appear to influence—one’s ability to act in Blackhawk Network’s best interests. Suppliers must inform us if any Blackhawk Network employee, or an employee’s family member, holds a significant financial interest in the supplier’s business. A “significant financial interest” means (i) ownership of greater than 1% of the supplier’s equity or (ii) an investment in the supplier that represents more than 5% of the total assets of the employee, or the employee’s family member.
- Protect Intellectual Property and Confidentiality. Suppliers must respect and protect Blackhawk Network’s intellectual property rights and maintain the confidentiality of our trade secrets and other Blackhawk Network confidential information. This includes any information that is non-public or not easily obtained by others. Suppliers may not use Blackhawk Network’s name or trademarks in any advertising or marketing materials without prior written authorization from Blackhawk Network.
- Comply with Insider Trading Laws. Suppliers that have material non-public information relating to Blackhawk Network may not use or share that information to trade in our stock or the stock of any company to which that information relates.
- Prohibit Retaliation. Suppliers must prohibit retaliation against workers who report misconduct or any other workplace complaints. Suppliers must protect the confidentiality of workers who make reports, to the extent possible, and support a process for anonymous reporting.
Labor Practices and Human Rights
We expect our Suppliers to operate in accordance with all applicable modern slavery laws including those prohibiting human slavery and slavery like practices, human trafficking and child labor.
- Use Only Voluntary Labor. Suppliers must not use forced labor-slave, prison, indentured, bonded, or otherwise. Our Suppliers must not traffic workers or exploit workers using threats, force, abduction, or fraud.
- Prohibit Child Labor. Suppliers must only employ individuals whose age is the greater of: (i) 15 years, (ii) the age of completion of compulsory education, or (iii) the minimum age to work in the country where work is performed. Individuals under the age of 18 must not perform hazardous work.
- Provide Safe Working Conditions. Suppliers will provide a safe and healthy work environment to prevent accidents or injury arising from, or linked with performing work or as a result of operating employer facilities.
- Prevent Harassment or Discrimination. Suppliers must provide a workplace free from harassment, threats of violence, corporal punishment, coercion, sexual abuse, and verbal or psychological harassment or abuse. All workers should be treated with dignity and respect. Suppliers must not discriminate against individuals because of race, color, religion, ancestry, national origin, gender, marital status, sex (including pregnancy), sexual orientation, age, physical or mental disability or mental condition, veteran status or other characteristic protected by law.
- Comply with Wage and Benefit Laws. Suppliers must comply with all applicable wage, hour, and benefit laws, including laws governing minimum wages, maximum hours, days of service, rest periods, leaves, and overtime pay and restrictions. Suppliers must pay their workers in a timely manner and convey the basis on which workers are being paid.
- Comply with Work Authorization Laws. Suppliers may only engage workers who have a legal right to work. Any foreign or migrant workers must be engaged in full compliance with immigration and labor laws of the host country.
Environmental Protection
- Comply with Environmental Laws. Suppliers must comply with all applicable environmental laws and regulations regarding hazardous materials, air emissions, waste, and wastewater discharges. This includes the manufacture, transport, storage, disposal, and release of such materials to the environment.
- Reduce waste. Suppliers should reduce or eliminate waste by implementing appropriate conservation measures in their facilities. This includes proper maintenance and production processes, recycling, and re-use.
- Manage Environmental Permits and Records. Suppliers must obtain, maintain, and keep current all required environmental permits and registrations and follow all required operational and reporting requirements.
Compliance and Reporting
- Establish Management Oversight. Suppliers must ensure one or more of its management staff is responsible for assessing and monitoring its compliance with this Supplier Code of Conduct and all applicable legal requirements. If Blackhawk Network or a regulatory agency identifies areas of non-compliance, Suppliers are expected to develop, document, and implement plans to remediate these issues in a timely manner. We may pursue legal or other sanctions against any Suppliers who violate this Code of Conduct or applicable laws when conducting Blackhawk Network business. We may also terminate the relationship, and any related contracts, to the extent permitted by applicable laws.
- Implement Training. Suppliers must develop and maintain internal training and policies to ensure that any workers supporting Blackhawk Network understand the requirements of this Supplier Code of Conduct, or the supplier’s own substantially similar policies.
- Report Ethics Issues or Concerns. If a supplier becomes aware of any violations or breaches of this Code of Conduct irrespective of whether those breaches are directly related to them or they reside in their supply chains -or if it suspects that a Blackhawk Network employee has acted improperly or unethically—the supplier must immediately report such issues to our Compliance and Ethics department by emailing bhn.compliance@bhnetwork.com. Suppliers can also make anonymous reports by using our third-party Ethics and Compliance Helpline below.