Yahoo Partner & Supplier Code of Conduct

Introduction

Yahoo is committed to conducting business with integrity, respect, and in compliance with applicable laws and regulations. We expect our partners and suppliers (“you”) to uphold these principles by complying with the Yahoo Partner & Supplier Code of Conduct (“Code”). If this Code sets higher standards than what the law requires, Yahoo expects you to adhere to our standards. This Code supplements, but does not supersede, the contract terms between you and Yahoo.

As used in this Code, “Partner” refers to any entity, including but not limited to their employees and agents, that has a business relationship with Yahoo. “Supplier” refers to any vendor, firm or individual, who provides products, staffing, or services to Yahoo. You are also responsible for implementing policies and procedures to ensure compliance with this Code and for taking prompt action to address any non-compliance or issues affecting your ability to comply. Any conduct that is inconsistent with or violates this Code or associated Yahoo policies may be grounds for terminating your business relationship with Yahoo.

This Code also applies to affiliates, intermediaries, and any other parties who act on your behalf.  You are responsible for ensuring that any affiliates, intermediaries or other parties acting on your behalf or in connection with your relationship with Yahoo, are aware of and in compliance with this Code.

Integrity

Yahoo values conducting and winning business fairly. Yahoo expects its Partners and Suppliers not to engage in any forms of illegal or inappropriate activity, including corruption, extortion, embezzlement or bribery, regardless of the country where services or performance under an agreement with Yahoo occur.

Anti-Corruption - Yahoo does not tolerate corruption or bribery in any form and expects the same of its Partners and Suppliers. You must comply with all applicable anti-corruption laws, including but not limited to the U.S. Foreign Corrupt Practices Act & UK Bribery Act. You must not, directly or indirectly, pay, give, offer, permit, authorize, or accept bribes, kickbacks, facilitation payments, or things of value to obtain or retain business or favored treatment, to influence actions, or to obtain an improper advantage for Yahoo, you, or any third party.

This prohibition extends to public officials, candidates for office, personnel of state-owned or operated institutions (e.g. travel boards, banks, airlines), and private parties.

No gifts, entertainment, or things of value can be provided to government officials in connection with Yahoo matters without the express written authorization of Yahoo. “Things of value” include, but are not limited to, cash, cash equivalents, meals, entertainment, gifts, charitable donations, travel, and other benefits.

You must keep accurate, truthful, and complete business records in regard to transactions, expenditures, and/or services performed in the conduct of business with Yahoo.

Privacy & Data Security

Yahoo expects you to protect and make proper use of information or assets that we share with you. Ensure that only authorized personnel are allowed access to Yahoo information. Unauthorized use or disclosure of confidential information may have personal, legal, reputational, and financial consequences, You must comply with all applicable privacy, data protection, information security laws and regulations, as well as Yahoo privacy and data security policies and procedures.

Intellectual Property

If we share or grant you access to our intellectual property, you are responsible for protecting it from unauthorized access, theft, waste, cyber-related attack, misuse, unauthorized distribution, or other type of loss.  Our customer relationship information, technology assets, communication tools, and information systems are Yahoo property and are to be used for Yahoo-related business purposes only.

Implement and maintain appropriate physical, technical, and organizational measures to ensure that the security, confidentiality, and integrity of your systems, processes, and services securely maintain the data that you receive from Yahoo. Promptly inform us if you are aware of any violations of these conditions.

Conflicts of Interest

Avoid any situation that may involve a conflict of interest. Do not use Yahoo’s information for a personal benefit or to promote a competing business or activity.  Disclose to Yahoo any actual, potential, or perceived conflicts of interest with the work you do for Yahoo that result from personal or business relationships with Yahoo, our employees, customers, Suppliers, Partners, or our competitors.

Advertising, Marketing, and Sales

Yahoo expects you to uphold fair, truthful, accurate, and honest business standards in all Yahoo-related activities, including advertising, sales, and competition. Yahoo’s written approval is required before making any reference to Yahoo’s name, logos, products, services, employees, and affiliates in advertising, marketing, sales, or promotional activities.  

Respect

Yahoo is firmly committed to treating people with dignity and fairness in accordance with applicable laws and regulations regarding labor and employment.

Diversity and Inclusion

Yahoo is committed to celebrating diversity. We encourage our Partners and Suppliers to share in our commitment through their operations and supply chain.  We expect our Partners and Suppliers to provide a range of enterprises that are diverse in ownership (e.g. locally owned, women owned) and scale (e.g. small and medium businesses) with the opportunity to compete for business on a fair and equal footing.

Labor and Human Rights

Yahoo recognizes its responsibility to respect human rights. Our approach is reflected in our company's Business and Human Rights Program and our actions in the countries where we do business. We expect our Partners and Suppliers to have similar policies and practices that apply to all workers, suppliers, and their supply chains.

• Slavery, Forced Labor, and Human Trafficking - Yahoo does not tolerate slavery, forced labor, or human trafficking in any form.  We expect our Partners and Suppliers to fully comply with all applicable slavery, forced labor, and human trafficking laws, including without limitation the UK Modern Slavery Act. Do not engage in or support involuntary labor of any kind. Ensure that no abusive, exploitative, or illegal conditions exist in your hiring, recruiting, and other human resources practices.
• Child Labor - Partners and Suppliers must not employ child labor and will take the necessary preventative measures to ensure that it does not employ anyone under the applicable legal minimum age of employment. 
• Wage and Benefits - We expect Partners and Suppliers to timely pay their employees at least the minimum wage required by applicable laws and regulations and to provide all legally mandated benefits.

No Discrimination or Harrassment

Yahoo expects its Partners and Suppliers to maintain a workplace that is free of discrimination, harrassment, victimization, and any other form of inappropriate behavior or abuse on any grounds, including but not limited to age, disability, ethnic or social origin, gender, gender identity, nationality, race, sexual orientation, marital status, parental status, political party, religion, or other status or trait protected by law. You are expected to maintain an environment free of harassment, violence, and abuse at all times.

Safe and Healthy Work Environment

Partners and Suppliers must provide its personnel with a work environment that safeguards against health and safety risks, accidents, injury, and other hazards. Conflict should be resolved in a respectful and productive manner without threats, bullying, violence, or hostility. Yahoo is a drug-free workplace, and does not permit illegal drugs or controlled substances in our workplace, even where local law permits. Do not abuse alcohol or prescription drugs while working or attending business functions on Yahoo’s behalf.

Respect for the Environment

We expect our Partners and Suppliers to operate in an environmentally responsible and efficient manner in compliance with applicable environmental laws and regulations. You may be asked to provide information to show your compliance efforts.

Compliance

Yahoo expects that you will conduct business in full compliance with applicable laws and regulations in the countries and jurisdictions where you operate.

Fair Competition and Antitrust Laws

Yahoo is committed to complying with applicable competition and antitrust laws. As a Yahoo Partner or Supplier, you will conduct their business in full compliance with all applicable fair competition and antitrust laws. Unfair competition and deceptive practices involving Yahoo products is prohibited. You must not conspire with other parties to engage in bid rigging, price fixing, or other forms of collusion.

Export, Import, and Sanctions Laws

All transactions must comply with United States export controls, customs laws, and sanctions programs.  Customs laws and import restrictions in the countries where you conduct business with Yahoo may also apply. If you are engaged in the shipment of items, the transfer of software or technology, or the rendering of services in your business activities with or for Yahoo, you are required to comply with all applicable export and import laws and regulations, which may include licenses, registrations, permits, reporting obligations, and other government authorizations, some of which may be required prior to export and/or import. Participation in international boycotts that are not upheld by the United States Government is prohibited. You must also be responsible for complying with applicable embargoes, sanctions, and other government directives and ensuring that you have the staffing, resources, and tools needed to achieve such compliance.

Anti-Money Laundering Laws

Yahoo requires its Partners and Suppliers to adhere to all applicable anti-money laundering laws and regulations. You must comply with “know your customer” requirements and be alert to unusual or suspicious activity that could involve money laundering, terrorist financing, or other activities involved in concealing and/or facilitating the flow of criminally derived funds. If you become aware of such activities, contact Yahoo via the information provided below.

Reporting Concerns & Engagement With Yahoo

You must promptly report concerns and potential or actual violations of this Code. Contact Yahoo’s Ethics & Compliance Office at 844.943.4554 or eco@yahooinc.com.

Last updated: September 1, 2021