Supplier Code of Conduct

Last Updated: September 14, 2020

INTRODUCTION

At Twilio, we are guided by Twilio Magic, the principles we use to build an impactful, high-growth business while staying true to ourselves. We are committed to conducting business ethically and legally across all our global operations, and we expect our business partners to share in this commitment. Our Supplier Code of Conduct (the “Supplier Code”) sets out expectations for our business partners in the areas of business integrity, labor practices, anti-corruption, health and safety, environmental impact, diversity and inclusion. Twilio is committed to protecting human rights and strives to develop environmentally and socially sustainable chains of responsibility within our sphere of influence.

Twilio expects the business partners that we work with, including all vendors, consulting firms, staffing agencies, agency temps, partners and licensees (“Suppliers”), to adhere to the high standards set forth in this Supplier Code as a condition of doing business with Twilio. If you suspect illegal or unethical practices, it is your responsibility to report it to Twilio and local authorities.

Compliance with the Supplier Code

Twilio requires Suppliers and any subcontractors, providers, or agents that they use to abide by all applicable laws, regulations and other legal requirements in jurisdictions in which they operate, and the Supplier Code.

Reporting Misconduct

Twilio is honest and transparent about our supply chain, incorporating our ten core values in how we conduct business with everyone. We expect Suppliers to strive to act honestly, directly and transparently in all aspects of business as well. In order to promote a high standard of ethical and professional conduct, we have an ethics reporting hotline, where, as permitted by law, employees, customers and Suppliers can address any issues on a confidential and anonymous basis. Suppliers should report any known or suspected violations of the Supplier Code, laws, or regulations to Twilio’s ethics and whistleblower hotline +1-844-637-6752 or website www.twilio.ethicspoint.com. Any questions regarding the scope or compliance with the Supplier Code may be directed to legalnotices@twilio.com.

EMPOWER OTHERS

We believe that unleashing human potential — both inside and outside our company — is the key to our success. Invest in each other.

General Rights of Workers

Twilio acknowledges and respects basic and fundamental human rights. Suppliers shall treat workers with dignity and respect as understood and defined by applicable law. Suppliers shall make all relevant information about their employee’s rights easily accessible to the employees.

Humane Treatment

Twilio requires its Suppliers to ensure there is no inhumane treatment or threat to workers, including any sexual harassment, sexual abuse, harassment, corporal punishment, or mental or physical coercion of workers. Suppliers must treat all workers with dignity and respect.

Health and Safety

We expect Suppliers to provide all employees with safe and healthy working conditions that comply with local laws. Safe and healthy working conditions include offering emergency training and resources, practicing industrial hygiene, and enacting equipment safety initiatives, as appropriate. Suppliers should take proactive measures to prevent workplace hazards.

Labor Practices

Twilio recognizes that our business decisions have a direct impact on people and communities. We are committed to enacting fair labor practices and expect Suppliers to share that commitment.

Fair Compensation

Twilio requires Suppliers to comply with the local minimum wage laws and benefits requirements. Additionally, Suppliers should not unlawfully use deductions from wages as a disciplinary measure.

Working Hours, Rest Days, and Compensation

Twilio expects its Suppliers to ensure their workers have reasonable work schedules that comply with local laws. While it is understood that overtime may be required, Twilio expects Suppliers to carry out their services in a way that promotes humane and productive working conditions. Suppliers shall comply with local laws regarding payment and working hours, including overtime, rest days and public holidays. Compensation paid to employees shall comply with all applicable local wage laws, including those relating to minimum wages, overtime hours, and legally mandated benefits.

Freedom of Association

Open communication and direct engagement between workers and management are effective ways to resolve workplace and compensation issues. We seek Suppliers who respect employees’ right to freedom of association and collective bargaining in accordance with local laws. Suppliers will not unlawfully discriminate in employment decisions against or engage in threatening or harassing behavior towards workers because of their affiliation with worker groups.

Child Labor

We do not tolerate the use of underage labor and will not work with suppliers that utilize underage workers. Suppliers shall adhere to minimum age provisions set forth in local laws and regulations and should not use workers that are under the legal age for employment. Suppliers may employ workers that are younger than 18 years of age, if they are legally employed in accordance with the law of the country in which they are working. Suppliers must monitor any and all employees under the age of 18 to ensure they are performing age-appropriate tasks, in age appropriate working conditions, and are protected from any type of labor likely to jeopardize their health or safety.

No Forced Labor or Human Trafficking

Twilio condemns human trafficking and forced labor and will not work with Suppliers who engage in these practices. Suppliers must ensure that they do not use involuntary prison labor, or forced, bonded, or indentured labor, and do not employ anyone against their will. We expect Suppliers to adhere to all applicable anti-modern slavery and human trafficking laws, including the UK Modern Slavery Act 2015. Workers shall not be required to relinquish control of identity or immigration papers (including but not limited to passports, drivers’ licenses, or work permits). Additionally, Suppliers must ensure that all work is voluntary and that their employees are free to resign their employment in accordance with applicable law.

Grievance Procedures

We require Suppliers to offer reasonable procedures so that their employees can bring workplace concerns to management.

BE AN OWNER

We believe in thinking long term and recognize that environmental sustainability is critical to succeed as a business and a community. Twilio expects Suppliers to share in this commitment by responding to challenges posed by climate change and working toward protecting the environment.

Environmental Protection

Our Suppliers should conduct their operations in ways that are environmentally responsible and in compliance with all environmental laws, regulations, and standards. Whenever possible, Suppliers are encouraged to develop and maintain business practices to promote energy efficiency, reduce pollution (including greenhouse gas emissions), and conserve resources. This includes managing, reducing and properly disposing or recycling all hazardous and non-hazardous waste, such as e-waste and wastewater.

Community Impact

Twilio strives to promote the well-being of the communities in which Twilio does business. Social responsibility is as critical to our success as a company as any other initiative. Through Twilio.org, our social impact arm, we fuel communication that gives hope, power, and freedom. Suppliers are encouraged to actively engage the communities in which they do business to promote sustainable social and economic practices and development. Suppliers should assess the potential impact of their activities on the local community and take steps to mitigate and avoid any negative impacts on the environment and community.

BE INCLUSIVE

Twilio is intentional about prioritizing equality of opportunity.

At Twilio, we believe our existence should strengthen our communities and society overall. In becoming an anti-racist company, we commit to acknowledging and addressing systemic racism in society through our work with the community and our customers. Using our products, our people, and our resources, we will create systemic change in the world around us through election participation, advocacy, and legislation.

As such, we encourage Suppliers to:

Demonstrate a commitment to identify, measure, and improve a culture of diversity and inclusion through all aspects of workplace management.
Include small and socioeconomically diverse suppliers in subcontracting activities where possible.
Share in Twilio’s commitment in eliminating systemic bias from people processes.
Proactively engage with their local communities to positively contribute to economic growth and opportunities for social change.

Twilio respects individual and cultural differences and will not tolerate discrimination. Twilio is committed to equal opportunity and we expect that Suppliers share that commitment and have appropriate policies in place.

Respect, Dignity, and Non-Discrimination

Suppliers will not discriminate in screening, hiring, or employment practices based on race, color, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, ethnicity, national origin, caste, disability, genetic information, medical condition, pregnancy, religion, political affiliation, union membership, covered veteran status, or body art. Suppliers will not permit harassment, sexual harassment, corporal punishment, inhumane treatment, bullying, and threats of physical violence. Suppliers shall provide a working environment that is free of abusive, violent, threatening, disruptive, demeaning, and other improper behavior.

Suppliers will not inquire about potential workers’ criminal histories on employment applications or before initial interviews, or, if no interview is conducted, before making conditional offers of employment. Twilio also expects Suppliers to refrain from disrespectful, unprofessional, harassing, defamatory actions and any activities that are prohibited by law or the terms of use on social media platforms.

NO SHENANIGANS

We strive to always act in an honest, direct, and transparent way. Twilio is committed to conducting our business in compliance with all applicable laws, and we expect our Suppliers and business partners to do the same.

Business Practices and Ethics

Suppliers must not engage in any unlawful activity in conducting business for or on behalf of Twilio, nor should Suppliers instruct others to do so.

Ethical Conduct

Suppliers must adhere to the highest standard of ethical conduct, respect all local laws, and not engage in any form of illegal or improper business practices such as extortion, fraud or any other act which could enable corruption in any manner. Suppliers shall comply with all legal requirements regarding accurate marketing and sales, and shall act with integrity when handling competitive or proprietary information. Suppliers should not engage in false or misleading accounting practices and should not use fictitious, inaccurate or misleading documents to support transactions related to business with Twilio.

Fair Dealing

We expect Suppliers to comply with all applicable laws and regulations regarding fair competition and antitrust.

Anti-Corruption

Twilio is committed to conducting its business in compliance with all laws prohibiting bribery and other corrupt practices. Suppliers must comply with the U.S. Foreign Corrupt Practices Act, the UK Bribery Act, equivalent laws of Supplier’s jurisdiction, and all applicable anti-corruption regulations and international anti-corruption conventions.

Conflicts of Interest

A “conflict of interest” occurs when personal or professional interests or activities interfere with, or appear to interfere with, the best interests of Twilio or Supplier.

We trust that Suppliers will:

Avoid conflicts of interests and situations that may have the appearance of a conflict of interest.
Disclose to Twilio any material transaction or relationship that reasonably could be expected to give rise to an apparent or actual conflict of interest regarding its relationship with Twilio.

International Trade and Export Controls

Twilio expects Suppliers to comply with all applicable import, export, customs, sanctions, embargoes, boycott and other trade compliance laws and regulations.

Data Information and Privacy

Twilio is committed to protecting the privacy and security of data in our developer ecosystem, and of our customers and users. We expect Suppliers to comply with all applicable data privacy laws and regulations when processing the personal or identifying information of Twilio and Twilio’s employees, customers and end users, workers, and suppliers.

Intellectual Property and Confidential Information

Suppliers may not share, disclose or use Twilio’s intellectual property, confidential information, or any other proprietary or non-public information that the Supplier acquires through its engagement with Twilio except as provided for in the applicable contract with Twilio or as provided by express written consent by Twilio.

WRITE IT DOWN

At Twilio, we understand that our business is complex, so we take the time to express ourselves in prose — for our sakes and for the folks with whom we’re collaborating.

Monitoring and Auditing

We expect that every Supplier will:

Monitor its own operations through appropriate due diligence, audits or other activities.
Maintain honest and accurate accounting and business records that comply with all relevant legal and regulatory requirements.
Comply with its agreement with Twilio including any permissions to review records or facilities.