Last Updated: August 20, 2021
Snowflake Inc. and its subsidiaries (together, “Snowflake” or “our”) are committed to maintaining a work environment that is free from human trafficking and slavery, which, for purposes of this policy, include forced labor and unlawful child labor. We do not tolerate or condone human trafficking or slavery in any part of our global organization. This policy is consistent with our Global Code of Conduct and Ethics and expresses our firm commitment to protect and advance human dignity and human rights in our global business practices.
This policy applies to all of our employees, agents, Board members, and contractors, each of whom are responsible for understanding and complying with this policy. Managers are responsible for ensuring that workers who report to them comply with this policy and complete any certification or training required of them. If you have any questions or concerns, please contact the Legal team at [email protected]. We also require our business partners, including subcontractors, vendors, resellers, partners, and any other entities that work with or supply goods and services to Snowflake to avoid being complicit in any human trafficking or slavery.
Policy Statement
Snowflake complies with all applicable human trafficking and slavery laws, including global human rights laws prohibiting human trafficking and slavery, and we require our business partners to do the same.
The following activities are prohibited:
• Engaging in any form of trafficking of persons, including sex trafficking or severe forms of trafficking in persons;
• Using force, fraud, or coercion for the purpose of subjecting a person to involuntary servitude, peonage, debt bondage, or slavery;
• Procuring commercial sex acts;
• Using forced labor in the performance of any work;
• Destroying, concealing, confiscating, or otherwise denying access by an employee to the employee’s identity or immigration documents, such as passports or drivers’ licenses, regardless of issuing authority;
• Using misleading or fraudulent practices during the recruitment of employees or offering of employment, such as failing to disclose, in a format and language accessible to the worker, basic information or making material misrepresentations during the recruitment of employees regarding the key terms and conditions of employment, including wages and fringe benefits, the location of work, the living conditions, housing and associated costs (if employer or agent provided or arranged), any significant cost to be charged to the employee, and, if applicable, the hazardous nature of the work;
• Using recruiters that do not comply with local labor laws of the country in which the recruiting takes place;
• Charging applicants recruitment fees;
• If required by law or contract, failing to provide return transportation or paying for the cost of return transportation upon the end of employment;
• If required by law or contract, failing to provide or arrange housing that meets the host country housing and safety standards;
• If required by law or contract, failing to provide an employment contract, recruitment agreement, or other required work document in writing;
• Engaging in child labor, forced, bonded, or indentured labor, involuntary prison labor, slavery, trafficking of persons, physical punishment, or inhumane work conditions; or
• Failing to pay minimum wages.
Terms used in the list above have the meanings given to them under the Federal Acquisition Regulation (FAR) clause 52.222-50 (Combating Trafficking in Persons).
Procedures
Snowflake is committed to maintaining processes and procedures designed to avoid human trafficking and slavery.
Vendors. Snowflake has adopted Business Partner Standards of Conduct that prohibit the use of human trafficking or slavery. The Business Partner Standards of Conduct apply to all Snowflake business partners, including our distributors, resellers, solution and consulting partners, alliances partners, vendors, and service providers.
Training. Snowflake provides anti-human trafficking and slavery training to employees that directly engage in government contracting.
Accountability. Snowflake will promptly investigate any suspected breach of this policy or applicable law. Snowflake representatives found to violate the law or this policy, or who fail to cooperate with an investigation, will be subject to discipline up to and including termination. In addition, any noncompliance by our business partners may result in termination of our business relationship, in addition to the exercise of any other rights available to us.
Raising Issues and Concerns
If you have questions about your legal obligations or this policy, please contact the Legal team at [email protected]. You must report any suspected violation of laws, rules, regulations, or this policy to Human Resources or Legal immediately.
Snowflake does not tolerate retaliation. Snowflake will not retaliate, and will not tolerate retaliation, against anyone who, in good faith, reports violations or suspected violations or assists in an investigation of a reported violation. Immediately report to Human Resources or Legal any acts that appear to be retaliation.
If you prefer to remain anonymous, you can also report your concerns through the Snowflake Whistleblower Hotline in one of two ways:
• Phone: 1-844-476-9147
• Website Intake URL: snowflake.ethicspoint.com
The Whistleblower Hotline allows you to report anonymously. If you report anonymously, Snowflake will protect your anonymity to the extent possible, but cannot guarantee it. If you make an anonymous report, we encourage you to provide as much detail as possible about the complaint or concern because our ability to investigate depends on the quality and specificity of the information. All properly reported potential violations of this Code will be promptly investigated. Please see Snowflake’s Global Code of Conduct and Ethics and Whistleblower Policy for more information.
Concerns may also be reported to the National Human Trafficking Hotline:
• Phone: 1-888-373-7888
• Website Intake URL: [email protected]
Snowflake will comply with its reporting obligations under the Federal Acquisition Regulation (FAR) clause 52.222-50 (Combating Trafficking in Persons).