Vendor Code of Conduct

Coinbase Global, Inc., its subsidiaries, and its affiliates (collectively, “Coinbase”) is founded and operates on the simple but fundamental principle that everyone deserves access to financial services that can help empower them to create a better life for themselves and their families.  As Coinbase continues to build tools to increase economic freedom, we are committed to ensuring each vendor in our global supply chain complies with this Vendor Code of Conduct (the “Code”). Coinbase’s Code is based on the following guiding tenets:

 

              A.          FAIR DEALING & PROTECTING INFORMATION 

              B.          LABOR & NON-DISCRIMINATORY EMPLOYEMENT  

              C.          STEWARDSHIP OF THE ENVIRONMENT  

              D.          VENDOR BELONGING

              E.          COMPLIANCE WITH TRADE LAW  

               

Coinbase requires its vendors to follow these same tenets to protect and guarantee the fundamental rights and dignity of all individuals who provide services for Coinbase. We expect each of our vendors to operate in full compliance with the letter and spirit of the laws, rules, and regulations that apply to it and to Coinbase. In complying with these objectives, we expect all our vendors to strictly adhere to this Code and a business ethical framework that prevents bribery and corruption, trade law violations,  or slavery and human trafficking,  provides protection for worker whistleblower confidentiality, and establishes safeguards against retaliation. Coinbase will not tolerate unlawful tax evasion. Vendors must not directly or indirectly engage in, or facilitate the engagement by others in, the deliberate and fraudulent diversion of funds from a tax authority. Vendors are expected to implement and maintain reasonable processes that prevent such conduct. We also expect all our vendors to report to Coinbase, without undue delay, any actual or reasonably suspected violation of this Code, or any request to undertake any action that, if completed, would reasonably lead to a violation of this Code.  It is the responsibility of the vendor to know the requirements of this Code and to operate in accordance with its principles.

 

For purposes of this Code, vendors include any third party, firm or individual that provides a product or service to Coinbase, including: vendors, suppliers, agents, consultants, temporary workers or other third parties acting on behalf of Coinbase. It also includes the vendor’s employees, directors, officers, owners, consultants, affiliates, contractors, subcontractors and others acting on behalf of the vendor.

 

A.          FAIR DEALING & PROTECTING INFORMATION 

 

We expect all vendors to have and uphold the highest standards of integrity in all business interactions. Vendors must deal honestly, ethically, and fairly with customers, partners, suppliers, competitors, and other third parties.  Vendors shall maintain a zero tolerance policy for, and prohibit any and all forms of, bribery, corruption, extortion, and embezzlement by their employees, directors, suppliers, contractors and others acting on their behalf. To that end, vendors are required to comply fully with the Foreign Corrupt Practices Act, the UK Bribery Act and the other anti-bribery and corruption laws that apply to it and to Coinbase. Vendors shall also adhere to the highest standards of ethical requirements and business integrity when dealing with workers and suppliers. Furthermore, we expect our vendors to have in place, enforce and comply with policies and procedures that, among other things:

 

a.      prohibit authorizing, offering, giving, soliciting, requesting, or accepting anything of value, whether directly or indirectly, to or from anyone, including any representative of a government, labor union, customer, or supplier, in order to improperly influence action or obtain an improper advantage or benefit. Anything of value should be broadly construed and may include, but is not limited to, gifts, business hospitality, entertainment, charitable donations, political donations, sponsorships, honoraria/speaker fees, offers of employment or other work experience, discounts or other perks.

 

b.     prohibit the use of facilitation or grease payments (i.e., providing anything of value to a government official to expedite performance of a routine and non-discretionary duty)

 

c.      ensure that it maintains accurate and complete books, records and accounts

 

d.     protect all proprietary data our customers, partners, or suppliers provide to us as reflected in our agreements with them or as compelled by law

 

e.      prohibit its personnel from taking unfair advantage of its customers, partners, or suppliers, or other third parties, through manipulation, concealment, abuse of privileged information, or any other unfair-dealing

 

f.        Follow the Coinbase Non-Employee Travel & Expense policy if any travel is associated to a particular project or Statement of Work

 

In addition, vendors must ensure that employees, directors, suppliers, contractors and others acting on their behalf are aware of,  receive appropriate training on, and comply with the foregoing policies and procedures.

 

Our vendors are, on occasion, entrusted with Coinbase’s confidential information. This information may include: (1) technical or scientific information about current and future services or research; (2) business or marketing plans or projections; (3) earnings and other internal financial data; (4) personnel information; (5) supply and customer lists; and (6) other non-public information that, if disclosed, might be of use by our competitors, or harmful to the Coinbase's suppliers, customers or other business partners. This information is the property of Coinbase, or the property of Coinbase’s suppliers, customers or business partners, and in many cases was developed at great expense. 

 

Vendor shall maintain a program that ensures the confidentiality, anonymity, and protection of Coinbase’s supplier and employee whistleblowers, unless prohibited by law. Vendor shall create and maintain a formal process by which all of its personnel are able to raise any concerns without fear of retaliation.  All vendors must comply with all applicable privacy and information security laws and regulations when personal information is collected, stored, processed, transmitted, and shared.

 

 

B.          LABOR & NON-DISCRIMINATORY EMPLOYEMENT

 

We expect our vendors to share our commitment to uphold the human rights of all workers and non-discriminatory employment. We have based our Code on the United Nations Guiding Principles on Business and Human Rights, and the Core Conventions of the International Labour Organization (ILO); we also have obligations under the UK Modern Slavery Act 2015 to prevent modern slavery (forced labour, debt bondage, servitude and trafficking for the purposes of labor exploitation) and human trafficking in our business dealings and relationships, and to ensure as far as possible that our supply chains are free from any such activities. We are firmly committed to protecting the fundamental rights of all workers so that workers are not exploited, compensation levels meet applicable laws and wages are paid in a timely manner, and vendors do not use forced labor, and workers are treated fairly without discrimination.

 

We expect our vendors to implement all necessary safeguards and protections to prevent and be accountable for maintaining a safe and healthy work environment. All vendors must comply with all applicable laws and regulations with respect to labor, including working hours, minimum pay, overtime and days of rest. Working hours are not to exceed the maximum set by local law. Overtime hours shall be compensated in accordance with local laws and applicable standards.

 

Coinbase, Inc. is a federal contractor subject to Executive Order 11246, Section 4212 of the Vietnam Era Veterans’ Readjustment Assistance Act of 1974, as amended, and Section 503 of the Rehabilitation Act of 1973, as amended.  As such, it is committed to taking positive steps to implement the employment-related aspects of the company’s equal employment opportunity policy. It is Coinbase’s policy to take affirmative action to employ, advance in employment, and otherwise treat qualified minorities, females, protected veterans, and individuals with disabilities without regard to their race or ethnicity, color, religion, sex, sexual orientation, gender identity, national origin, veteran status, or disability.  Pursuant to 41 CFR §§ 60-300.44(f)(1)(ii) and 741.44(f)(1)(ii), we hereby notify you of our policy related to our affirmative action efforts and request appropriate action on your part.   Vendors shall, to the extent they apply, abide by any obligations prohibiting discrimination against qualified individuals based on their protected status. 

Vendors shall also not discriminate based on the perception that anyone has any of those characteristics or is associated with a person who has or is perceived to have them. The foregoing governs all aspects of employment and vendors shall not engage in nor permit harassment of any kind of its employees. Harassment includes verbal or physical conduct, visual displays, or retaliation for any complaint that creates an intimidating, offensive, or hostile work environment or that interferes with work performance. Vendors shall ensure the confidentiality and protection of employee whistleblowers and shall not engage in any form of retaliation against such whistleblower employees.

 

C.          STEWARDSHIP OF THE ENVIRONMENT 

We are committed to minimizing and reducing the environmental impacts of our business. All vendors are expected to develop, implement, and maintain environmentally responsible business practices, such as seeking ways to conserve natural resources and energy, reduce waste and the use of hazardous substances, and minimize adverse impacts on the environment. Furthermore, vendors must comply with all applicable environmental laws, regulations, including applicable laws regulations that regulate hazardous materials air, water, emissions, and wastes.

 

D.          VENDOR  BELONGING

At Coinbase, we are committed to ensuring fairness and accountability, supporting a diverse workforce, and embedding practices of belonging, inclusion and diversity into our teams including into our vendor partnerships.  We are committed to increasing usage of small and diverse businesses in our mission to build products and technology that create an open financial system. We believe that our commitments  will encourage belonging, inclusion and diversity practices with those we partner with.

As such, we encourage our vendors to:

●        Demonstrate a commitment to improve representation, engagement and a sense of belonging for diverse talent  through aspects of workplace and supplier management.

●        Include small and diverse suppliers in subcontracting activities where possible.

●        Proactively engage with their local communities to positively contribute to economic growth for all.

 

E.          COMPLIANCE WITH TRADE LAWS

As a global company, Coinbase is required to comply with a variety of economic sanctions, embargoes, import/export controls, technology transfer limitations, and other trade restrictions (collectively, “Trade Laws”), such as but not limited to those administered or enforced by the U.N., E.U., U.K., and U.S. (e.g., Office of Foreign Assets Control (“OFAC”) Specially Designated Nationals List (“SDN List”), Export Administration Regulations (“EAR”)).  To help ensure Coinbase’s compliance with Trade Laws, in connection with their performance for Coinbase, we expect that our vendors:

 

  1. Are knowledgeable about Trade Laws applicable to them and their performance, and will obtain and maintain all required certifications, licenses, and/or permits.

  2. Are not providing any product or service to Coinbase with a certificate of origin from, or with a majority of components sourced from, a Prohibited Party or from any country or region that is the target of applicable Trade Laws, or that would otherwise cause Coinbase to violate any Trade Laws applicable to it.

  3. Are not themselves a Prohibited Party; are not owned or controlled by a Prohibited Party; and are not performing directly or indirectly, in whole or in part, on behalf of or to the ultimate benefit of any Prohibited Party. 

 

A “Prohibited Party” is any individual or entity that is the target of applicable Trade Laws and/or located, organized or resident in a country or territory that is, or whose government is, the subject of comprehensive or targeted geographic Trade Laws , and for which no applicable license, exception or exemption exists.  Notwithstanding the foregoing, Coinbase does not mean for anything herein to be intended or interpreted to require a vendor to act in any manner which is inconsistent with, penalized, or prohibited under any laws or regulations applicable to them which relate to Trade Laws.