Guide to

Kind Business
Snap’s Global Code of Conduct
Guide to
Kind Business A Letter from Evan
People don’t usually think about kindness as a part of business strategy. For
Snap, it’s central to how we grow our business and work as a team to serve our
community and partners.

At Snap, being kind is one of our core values. We don’t disrupt things first and fix
them later; we bring care and long-term thinking into how we solve problems from
the start. That’s why we designed our technology around humans, trying to give
our online community a way to express their full experience with friends and foster
real connection. We bring the same empathy and insight to our other business
stakeholders: our team, our partners, our investors, and the broader world.

When our stakeholders thrive, so do we. That’s why this Code of Conduct is
built around that core value. Our standard for good business conduct is not just
following the law; it’s also treating our stakeholders the right way. Kindness is not
a constraint on our growth; it’s a driver.

To run a kind business, we need to start with ourselves. That’s why we invest
heavily in building diverse and inclusive teams and supporting mental health.
When we respect and value everyone’s humanity, we can work more effectively,
innovate faster, and make better decisions together. I hope that this Code helps
our team members and other stakeholders understand how empathy informs
every aspect of our business and inspires them to lead from their heart.

Evan Spiegel,
CEO, Snap Inc.

2
Guide to
Kind Business Table of Contents
About The Code 4 The Code In Action 12

On Being Kind 6 Be Kind to Each Other 14 Be Kind to Our Investors 26

How to Use This Code 7 Create a Safe and Healthy Workplace 15 Keep Accurate Records and Contracts 27
to Make Kind Decisions
Foster an Inclusive Culture 16 Make Truthful and Accurate 28
Public Statements
Being Kind Is a Shared Responsibility 8 Avoid Conflicts of Interest 17
Don't Trade on Inside Information 29
The Role of Our Leaders 8
Compete Fairly 29
How to Raise a Concern 10 Be Kind to Our Community 18
Respect Snap’s Property 30
Protect Our Community’s Privacy 19
What Happens When 11
Keep Confidential 31
You Raise a Concern Protect Our Community’s Well-Being 20 Information Confidential

Be Kind to Our Partners 21 Be Kind to Our World 32

Don’t Bribe 22
Respect Laws 33
Be Responsible with Gifts, Meals, 23
Entertainment, & Third-Party Travel Protect the Environment 33
Here at Snap, we contribute Choose Trustworthy Third-Parties 24 Respect and Promote Human Rights 34

to human progress by empowering Comply with Sanctions and Trade Laws 25 Give Back 35

people to express themselves,

live in the moment, learn about
the world, and have fun together. This Code also includes Related Policies relevant to each section. Such policies are not hereby incorporated by reference into this Code.

3
Guide to
Kind Business

About
The Code
On Being Make Kind Shared The Role of How to Raise When You Raise
Kind pg. 6 Decisions pg. 7 Responsibility pg. 8 Our Leaders pg. 8 a Concern p. 10 a Concern p. 11 4
Guide to
Kind Business

About The Code

On Being Kind

Make Kind Decisions

Shared Responsibility

The Role of Our Leaders

How to Raise a Concern

Living the Code means acting with courage

When You Raise a Concern

The Code In Action

and empathy, and in a way that instills trust,

Be Kind to Each Other

Be Kind to Our Community

Be Kind to Our Partners

even when the rules aren’t clear.

Be Kind to Our Investors

Be Kind to Our World

5
Guide to
Kind Business On Being Kind
About The Code Being kind is one of Snap’s core values and our
On Being Kind business superpower. By being kind, we don’t just
Make Kind Decisions mean being nice. We mean acting with courage,
To be kind, we must comply
Shared Responsibility using empathy, and instilling trust with our stakeholders.
The Role of Our Leaders
with the law and our policies
— and we must go beyond
How to Raise a Concern Why is kindness a superpower? Because success
mere compliance and invest in
When You Raise a Concern that comes at the expense of others is short-lived.
the health of our stakeholders.
Lasting growth comes from building enduring
It’s not enough to avoid
relationships with our five stakeholders: our team
misconduct; we must act
The Code In Action
members, the community that uses our products,
as a responsible corporate
Be Kind to Each Other
our partners, our investors, and society at large.
citizen in all we do.
Be Kind to Our Community
When we take care of our stakeholders, they help
us succeed.
Be Kind to Our Partners
This Code helps
Be Kind to Our Investors
Being kind also helps us remember that business
Be Kind to Our World show us how.
is not just a means to an end. When we conduct
business with kindness, we bring our humanity to
work and make decisions from both heart and head.

6
Guide to
Kind Business How to Use this Courage It’s not always easy to speak up and share the
truth. But we need to trust our gut, ask the tough

Code to Make
questions, and listen without defensiveness.
Have the courage to
About The Code These courageous conversations are how we work
speak and hear the truth.

Kind Decisions
On Being Kind together to protect Snap and our stakeholders.
Make Kind Decisions

Shared Responsibility

The Role of Our Leaders

How to Raise a Concern

Empathy
This Code provides clear guidelines, and you should
When You Raise a Concern
read and follow them. But making kind decisions is not Empathy is the heart and soul of being kind.
just about knowing all the rules. You will inevitably When we can see the world from others’ points
face situations where the way forward is unclear. Understand the impact of view, we are better able to eliminate bias,
The Code In Action In those situations, the three behaviors from the of your decisions on understand the consequences of our actions,
Be Kind to Each Other kind pillar of Snap’s Values in Action can guide you. our stakeholders. and avoid decisions based on narrow self-interest.
Be Kind to Our Community

Be Kind to Our Partners

Be Kind to Our Investors

Be Kind to Our World

Trust Trust holds our business together. That’s why

we measure our success by the strength of our
relationships. We strengthen those relationships
Choose the path that instills
by acting with honesty, integrity, and transparency.
trust with our stakeholders.
By contrast, we weaken those relationships when
we do things that appear improper, even if they’re
not. How can you tell if your actions appear
improper and weaken trust? Ask yourself if you
would want them reported on the front page of
a newspaper. If the answer is no, they likely don’t
meet the standards of this Code.

7
Guide to
Kind Business Being Kind The Role Being kind

Is a Shared of Our
begins with you.
About The Code

Responsibility Leaders
On Being Kind

Make Kind Decisions

How to Be a Kind Leader:

Shared Responsibility

The Role of Our Leaders

How to Raise a Concern

So who has the responsibility to be kind? If you’re a manager or leader, • Discuss the Code with your team and emphasize the
When You Raise a Concern
Everyone who works for Snap, from team you play a key role in upholding importance of doing business in a way that earns the
members to interns to officers and directors. this Code. That role doesn’t begin trust of our stakeholders.
This Code may also apply to individuals and when a problem arises. Rather,
• Model kind decision-making by using courage,
The Code In Action entities working on our behalf, like suppliers, it starts each day with small actions
empathy, and trust to assess whether a decision
Be Kind to Each Other contractors, consultants, agents, and other that establish safety, empathy,
is a good one.
Be Kind to Our Community partners. It’s part of our jobs to know how to and trust. It’s about talking about
Be Kind to Our Partners make good decisions that reflect courage, ethics and the importance of how • Create an environment of psychological safety
Be Kind to Our Investors empathy, and trust, and follow the principles we do things. It’s about holding by encouraging team members to voice concerns
Be Kind to Our World in this Code. third-parties your team works and opinions, even if they’re different than yours.
with accountable to Snap’s Code. • Practice receiving feedback with an open mind.
It’s about how you make tough
• Ensure everyone has an opportunity to participate
decisions or respond to bad news.
and be heard.
It’s about celebrating how someone
does a job, not just the end result. • Practice being vulnerable and self-aware by sharing
It’s about making sure everyone’s your own mistakes and learnings with your team.
voice is heard. These small daily acts
• Foster a culture of inclusion by demonstrating that you
create space for your team to feel
welcome and value different perspectives and styles,
safe raising concerns about more
especially those that are different from your own.
serious issues.

8
Guide to
Kind Business
What to Do When Someone
Raises a Concern:
About The Code

On Being Kind
• Let the team member know that you are paying
Make Kind Decisions
attention and that you want to hear what they have
Shared Responsibility
to say. Remove distractions.
The Role of Our Leaders
• Remember that the team member might feel nervous.
How to Raise a Concern

When You Raise a Concern • Listen without trying to decide if the team member is right.
Instead, focus on trying to understand their point of view.
• Make sure that the team member feels you received the
The Code In Action message. It helps to repeat back what you heard.
Be Kind to Each Other
• Thank the team member for raising the issue.
Be Kind to Our Community

Be Kind to Our Partners • If the team member approached you in private, respect
Be Kind to Our Investors their confidentiality to the extent possible and only share
Be Kind to Our World the conversation with others as necessary.
Directors, officers, and Integrity
• Decide whether this is an issue you can handle on & Compliance executives bear
your own or whether you should loop in your manager, special responsibility for following
Integrity & Compliance, or your HR Business Partner. this Code. In the event of an
The Raising a Concern Snappy page and Team Handbook alleged violation by any of those
provide guidance, but a good rule of thumb is to get help individuals, the General Counsel
for anything beyond an interpersonal dispute. (or the CEO, if the General Counsel
is implicated) will be informed
• Follow up with the team member with information
and will ensure an appropriate
about the steps you will take and set expectations
investigation and appropriate
as to what will happen next.
discipline for any violation.

9
Guide to
Kind Business How to Raise a Concern
About The Code

On Being Kind So what if you’re the person who spots

Make Kind Decisions something that seems off?
Shared Responsibility

The Role of Our Leaders

What’s the best way to share your concern?
How to Raise a Concern

When You Raise a Concern

Together we can The Helpline
Hopefully, your team leader has done a great job of making
you feel safe raising concerns openly and honestly with make Snap a kinder In situations where you prefer to place
them. There are also plenty of other options, such as your an anonymous report, you can use
The Code In Action
HR Business Partner or Generalist, Employee Relations, Integrity place and a stronger Snap’s helpline, hosted by a third-
Be Kind to Each Other

Be Kind to Our Community

& Compliance, Global Security or Snap’s anonymous helpline community. party provider and available 24/7.
Be Kind to Our Partners
(See sidebar for more details). Whichever path you choose, We welcome reports from internal or
Be Kind to Our Investors
we have your trust top of mind. We maintain confidentiality to external stakeholders regarding any
Be Kind to Our World
the extent possible and limit sharing any information and our issues relating to Snap’s business.
findings to those with a business need to know. You can file your report online or by
phone. Please note that Snapchat user
When you speak up, the company has your back. Snap’s or account reports should be directed
Whistleblower Policy makes it clear that we don’t tolerate to Snapchat Support and will not be
retaliation of any kind for concerns raised in good faith. addressed through the helpline.
Related Policies
We also don’t tolerate retaliation for refusing to do
Whistleblower Policy
something that violates this Code, the law, or Snap’s
policies, or for cooperating with an investigation. Anyone
Related Policies are not who violates Snap’s Whistleblower Policy and does retaliate
hereby incorporated by
reference into this Code.
against a team member on those grounds faces disciplinary
action, up to and including termination.

10
Guide to
Kind Business What Happens When
About The Code

On Being Kind
You Raise a Concern
Make Kind Decisions

Shared Responsibility When you raise a concern, we make sure to Once an investigation is complete, the team
The Role of Our Leaders address it. What that will look like depends in charge determines whether it is likely that
How to Raise a Concern on the specific issue at hand. But we always the alleged conduct occurred and whether it
When You Raise a Concern seek fair outcomes that respect the dignity violated this Code or any of our other policies.
of all involved while also demonstrating
our strong commitment to the values and What happens next depends on the nature
The Code In Action
principles in this Code. of the conduct. Sometimes the best, fairest
Be Kind to Each Other
outcome may be providing some coaching
Be Kind to Our Community
When appropriate, relevant in-house teams and a listening ear. Other times it will mean
Be Kind to Our Partners
will dig deeper and gather more facts to disciplining those who have violated Snap’s
Be Kind to Our Investors
evaluate the concern. These teams are policies. That discipline can range from written
Be Kind to Our World
trained to gather facts in a fair and impartial warnings to separation from the company. For more
way, without making any assumptions. In We also may recommend other appropriate
some cases, the company’s Audit Committee corrective action, such as revisiting or
information, go to the
of the Board of Directors may conduct an enhancing Snap’s policies to prevent the Raise a Concern page
independent investigation. We all have problem from recurring. If we learn a business
a responsibility to fully cooperate with counterparty violated the law or any Snap rules on Snappy!
these teams and Committees with honesty that they agreed to follow, we may end our
and integrity, and without withholding or contract with that counterparty.
mischaracterizing information.

11
Guide to
Kind Business

The Code
in Action
Be Kind to Be Kind to Our Be Kind to Be Kind to Be Kind
Each Other pg. 14 Community pg. 18 Our Partners pg. 21 Our Investors pg. 26 to Our World pg. 32 12
Guide to
Kind Business

About The Code

On Being Kind

Make Kind Decisions

Shared Responsibility

The Role of Our Leaders

How to Raise a Concern So what does being kind look like in action?
When You Raise a Concern

The Code In Action

Be Kind to Each Other

It comes alive through our
five stakeholder relationships.
Be Kind to Our Community

Be Kind to Our Partners

Be Kind to Our Investors

Be Kind to Our World

13
Guide to
Be Kind to

Each Other
Kind Business

About The Code

On Being Kind

Make Kind Decisions

Shared Responsibility

The Role of Our Leaders

How to Raise a Concern

When You Raise a Concern

If we want to practice kindness in TOPICS COVERED:

the world, we need to practice it

Create a Safe and Healthy Workplace
The Code In Action
at Snap. As team members, we are
Be Kind to Each Other

Be Kind to Our Community one of Snap’s most vital resources, Foster an Inclusive Culture
Be Kind to Our Partners and we should treat one another
Be Kind to Our Investors
Avoid Conflicts of Interest
Be Kind to Our World
that way. When we feel safe,
healthy, and respected, we can
make good decisions together
for Snap and our stakeholders.

14
Guide to
Kind Business

About The Code

On Being Kind How We Are Kind

Make Kind Decisions

Shared Responsibility
• We strive to create a workplace that actively
The Role of Our Leaders
promotes mental, physical, and emotional wellbeing.
How to Raise a Concern

When You Raise a Concern

• We comply with workplace health and safety laws.
• We have zero tolerance for discrimination,
harassment, or retaliation.
The Code In Action • We do not tolerate workplace violence in any form,
Be Kind to Each Other including violent acts, threats of violence, or verbal
Be Kind to Our Community or emotional abuse.
Be Kind to Our Partners
• We protect team members’ personal and

Create a Safe and

Be Kind to Our Investors

Be Kind to Our World

confidential information.
• We don’t work under the influence of illicit

Healthy Workplace
drugs or alcohol.
• We follow the company’s security guidelines
(relating to visitors and badges, for example)
to keep Snap safe.
Related Policies We are committed to creating a workplace where we all feel
Global Team Privacy Notice emotionally, physically, and mentally safe and healthy. Without that • We speak and listen from the heart. We consider
Team Member Handbook foundation, it is very difficult to be kind. When we do have a safe how our words will land for the person/group
Workplace Violence and healthy workplace, we are more likely to be empathetic and we are speaking to, and we listen deeply and
Prevention Policy without judgment.
caring towards others.

15
Guide to
Kind Business Foster an How We Are Kind

About The Code

On Being Kind
Inclusive Culture • We invest in Employee Resource Groups (ERGs) across
the world to build a shared sense of belonging within
and across our diverse communities.
Make Kind Decisions
We need everyone’s voice to be heard and valued
Shared Responsibility
• We invite our team members to share stories in our
if we’re going to make the best decisions together.
listening practice, Council to foster empathy and
The Role of Our Leaders For more information on Snap’s equity and inclusion
build allyship.
How to Raise a Concern efforts, check out diversity.snap.com.
When You Raise a Concern • We provide market leading benefits to support a variety
of lifestyles and life events, including therapy sessions,
financial planning and caregiver support.
The Code In Action • We work hard to create a safe and inclusive workplace free
Be Kind to Each Other from discrimination and harassment on the basis of race,
Be Kind to Our Community ethnicity, color, national origin, ancestry, creed, religion
Be Kind to Our Partners or religious creed, sex, gender, sexual orientation, gender
Be Kind to Our Investors expression, marital status or civil partnership/union status,
Be Kind to Our World age, military or veteran status, physical or mental disability,
genetic information, protected medical leaves, or any
other basis protected by applicable laws. And we are
committed to finding fair solutions for team members who
need reasonable workplace accommodations for medical,
lactation, or religious reasons.
Related Policies

Team Member Handbook

16
Guide to
Kind Business Avoid Conflicts of Interest
About The Code We are a community of kind, smart,
On Being Kind and creative people with a wide range
Make Kind Decisions of outside interests. It’s our job to manage
Shared Responsibility those outside interests responsibly and How We Are Kind
The Role of Our Leaders with respect for our commitment to the
How to Raise a Concern company. That means we avoid situations • We put Snap’s interests first. • We disclose any outside employment
When You Raise a Concern where what’s best for us personally conflicts and qualifying projects, relationships,
• We avoid situations where our outside
with what’s best for Snap. When we all put investments, and potential Snap corporate
interests, relationships, or activities
Snap first, we build trust and honor the work or business opportunities through Snap’s
prevent us from making good decisions
The Code In Action
and efforts of our colleagues. By contrast, Conflicts of Interest disclosure tool,
for Snap, or give the appearance that
Be Kind to Each Other
when we introduce conflicts of interest, making sure to also inform our manager.
we are unable to carry out our jobs
Be Kind to Our Community
we undermine trust and we put each other
effectively. We never take Snap’s business • We avoid accepting any gifts or
Be Kind to Our Partners
in uncomfortable positions.
opportunities for our own personal gain. courtesies — whether from third parties
Be Kind to Our Investors or Snap team members — that prevent
Be Kind to Our World
• We avoid situations where our outside
us from making neutral decisions in Snap’s
interests put pressure on our colleagues
best interests, and we follow Snap’s
to make decisions that aren’t in Snap’s
Gifts, Meals, Entertainment, & Third Party
best interests.
Travel Policy.
• We respect and follow Snap’s policies
Related Policies
regarding our outside activities and the
Conflict of Interest Policy responses the company provides when
Gifts, Meals, Entertainment, we disclose them. We recognize that in
& Third Party Travel Policy some cases that may mean stopping those
activities altogether if we wish to stay
employed at Snap.

17
Guide to
Be Kind to

Our Community
Kind Business

About The Code

On Being Kind

Make Kind Decisions

Shared Responsibility

The Role of Our Leaders

How to Raise a Concern

When You Raise a Concern

Since the beginning, Snap has With this privilege comes major
The Code In Action
been about empowering people responsibilities. Each one of us
Be Kind to Each Other to express themselves, live in the is responsible for treating our
Be Kind to Our Community
moment, learn about the world, community with empathy and respect,
Be Kind to Our Partners

Be Kind to Our Investors and have fun together. making decisions that increase that
Be Kind to Our World community’s trust and well-being.
Hundreds of millions of people have
chosen Snapchat as their home to
share moments with their friends, TOPICS COVERED:

family, and in some cases, the world,

Protect Our Community’s Privacy
or use other Snap products like
Spectacles to express themselves. Protect Our Community’s Well-Being

18
Guide to
Kind Business Protect Our
About The Code

On Being Kind
Community’s Privacy
Make Kind Decisions

Shared Responsibility
One of the key ways we respect our community
The Role of Our Leaders
is by protecting their privacy. Their data —
the information they share with each other
How to Raise a Concern
and with us — includes some of the most
When You Raise a Concern
important information about their lives.
Always, always hold that trust in high regard.

The Code In Action

Be Kind to Each Other

Be Kind to Our Community

Be Kind to Our Partners

Be Kind to Our Investors

Be Kind to Our World How We Are Kind

• We follow privacy and data protection laws. we have been explicitly granted access rights as part
We pay careful attention to the company’s of our job and only if we need to do so to perform
required privacy trainings, and complete our job function, and we always respect those users
them in a timely manner. privacy and product settings. Violations of this
Related Policies
rule will be taken extremely seriously and will carry
Snap Access to Personal • We implement privacy-by-design product
Data Policy consequences up to and including termination.
development processes, which requires privacy
Snap Privacy Center reviews before launching a relevant feature. • When we are unsure about the rules to follow or
principles to strive for, we contact the Privacy Legal
• We ensure open and honest communication
team, and when we see or suspect potential data
about how we handle user data.
privacy incidents, we report them promptly.
• We are meticulous in handling user data while
doing our jobs. We access user data only if
19
Guide to
Kind Business Protect Our
About The Code Community’s
Well-Being
On Being Kind

Make Kind Decisions

Shared Responsibility

The Role of Our Leaders

How to Raise a Concern Just as our success depends on the physical

When You Raise a Concern and mental health of our team members,
it also depends on the safety and health of
our online community. We are committed
How We Are Kind
The Code In Action
to safeguarding that well-being through our
• We are a design-led company, dedicated to • We commit to platform integrity, including
Be Kind to Each Other
products and services. For more information,
creating products that align with our mission removing content that violates our
Be Kind to Our Community
check out the Snap Safety Center.
and values. policies, such as drug activity and child
Be Kind to Our Partners sexual exploitation.
Be Kind to Our Investors
• We practice responsible growth by measuring
Be Kind to Our World
our products’ success by the value delivered • We seek to communicate our policies clearly
to the user, rather than just seeking to and enforce them consistently.
grow engagement.
• We seek to eliminate bias in our products.
• We prioritize the online health and wellbeing
• We share our concerns if we think a product
of our users by implementing safety-by-
or feature isn’t serving our users well or
design principles. We take into account the
meeting their needs. Our ability to keep
Related Policies unique sensitivities of minors while designing
making amazing products with integrity relies
Community Guidelines our products and we provide our community
on our team’s creativity and vigilance.
with easy-to-access wellness resources.

20
Guide to
Be Kind to

Our Partners
Kind Business

About The Code

On Being Kind

Make Kind Decisions

Shared Responsibility

The Role of Our Leaders

How to Raise a Concern

When You Raise a Concern

TOPICS COVERED:
Snap doesn’t do it alone. Our
business depends on various Don’t Bribe
The Code In Action

Be Kind to Each Other partners — such as advertisers,

Be Responsible with Business
Be Kind to Our Community developers, suppliers, partners,
Be Kind to Our Partners Entertainment, Gifts, & Travel
Be Kind to Our Investors
and creators — all of whom trust
Be Kind to Our World us to operate a reputable business Choose Trustworthy Third-Parties
and take their interests into account
Comply with Sanctions
when making decisions. and Trade Laws

21
Guide to
Kind Business

How We Are Kind

About The Code

On Being Kind

Make Kind Decisions

• We don’t pay or accept bribes or any • We only offer and accept reasonable
Shared Responsibility
other improper payments or improper and appropriate gifts, meals,
The Role of Our Leaders
consideration of any kind. entertainment, and third-party
travel to counterparties and get
How to Raise a Concern • We understand that bribes can come in
pre-approval when necessary —
When You Raise a Concern many shapes and sizes — not just cash,
see the next section for more info.
but gifts, favors, jobs, and more — and
we steer clear of them in all their forms. • We hire candidates based on their
merits, choose suppliers that
The Code In Action • We understand that bribery laws are
provide fair value to Snap, and
Be Kind to Each Other particularly strict when it comes to
make charitable donations only to
Be Kind to Our Community government officials. We learn the
legitimate charitable causes. We do
Be Kind to Our Partners special rules around dealing with

Don’t Bribe
not engage in any of these activities
Be Kind to Our Investors government officials and are careful
to improperly benefit a customer
Be Kind to Our World to follow them.
or official.

We seek to earn our customers’ partnership with

smart and creative solutions and products. We don’t
try to win their business through bribes, nor do we
Related Policies accept bribes from any of our partners. We never try
Gifts, Meals, Entertainment, to gain a business advantage by making improper
& Third Party Travel Policy
payments to government officials. We put our energy
Policy Prohibiting
Bribery and Corruption and resources into improving our product and winning
Political Contributions and business fairly, not into illegal or unethical payments.
Charitable Donations Policy
Sales Code of Conduct

22
Guide to
Kind Business Be Responsible with Gifts, Meals, How We Are Kind

About The Code

On Being Kind
Entertainment, & Third-Party Travel • We make sure that all gifts, meals,
entertainment, and third-party
travel are reasonable in value, have
Make Kind Decisions
a business purpose, and follow our
Shared Responsibility
It’s a common business practice to build Related Policies, disclosing them
The Role of Our Leaders partner relationships through gifts, meals, when required.
How to Raise a Concern entertainment, and third-party travel. These
• We never make third parties feel like
When You Raise a Concern practices are fine — so long as we follow Snap’s
they need to wine and dine us, or
rules and engage in them responsibly. We never
provide us any personal benefit to
give or receive them if there is a promise — or
win Snap’s business.
The Code In Action even a suggestion of a promise — of favoritism
Be Kind to Each Other or action in return. • We learn and understand the special
Be Kind to Our Community rules that apply to government
Be Kind to Our Partners officials. We recognize that in many
Be Kind to Our Investors countries, “government officials”
Be Kind to Our World includes employees of state-owned
businesses like telcos and universities.
We are careful to follow the applicable
rules for government officials when we
interact with them.
• We accurately record gifts, meals,
Related Policies
entertainment, and travel expenses
Gifts, Meals, Entertainment,
& Third Party Travel Policy in our expense reports.
Sales Code of Conduct • We definitely do not accept or give
Travel & Expense Policy
cash or cash equivalents, such as
pre-paid debit cards.

23
Guide to
Kind Business Choose Trustworthy
About The Code

On Being Kind
Third-Parties
Make Kind Decisions
Snap uses third-parties as agents, partners, and suppliers. All of these third parties must reflect Snap’s values and commitment
Shared Responsibility
to following applicable laws.
The Role of Our Leaders

How to Raise a Concern

When You Raise a Concern

How We Are Kind

The Code In Action • We vet all third parties to ensure that they are reputable and can uphold our high standards.
Be Kind to Each Other
• We ask our key suppliers to abide by Snap’s Supplier Code of Conduct, which codifies our expectations
Be Kind to Our Community
for suppliers to ensure safe working conditions, treat workers fairly, employ responsible environmental
Be Kind to Our Partners
practices, and meet high standards of ethics. We are members of the Responsible Business Alliance (RBA)
Be Kind to Our Investors
and the Responsible Minerals Initiative (RMI), and monitor adherence to this Code through RBA’s onsite
Be Kind to Our World
audits and have programs in place to evaluate and address risks related to slavery, forced labor, and Getting a new
human trafficking. representative or
• We choose suppliers of contingent workers who commit to following all relevant employment laws. supplier approved
• We never ask or suggest that our third parties do anything unethical on our behalf. We work with our sales Snap follows an
agents to ensure that they understand our commitment to anti-bribery. onboarding process for
Related Policies
vetting all new suppliers
Policy Prohibiting • We comply with anti-tax evasion laws, which prohibit the evasion of taxes and related crimes. We look out
Bribery and Corruption before they begin work.
for requests from partners to structure transactions in a manner that appears to facilitate tax evasion, such
Purchasing and To begin the process,
Contracting Policy
as invoicing using an incorrect address, and we report such requests to Integrity & Compliance.
visit the Legal Request
Supplier Code of Conduct • We comply with anti-money laundering laws, which prohibit concealing illegally or dishonestly obtained page on Snappy.
money by hiding it within legitimate economic activities.
• We promptly report any conduct that calls into question a third party’s integrity. (See How to Raise
a Concern, above, for links to report to our helpline or the Integrity & Compliance team.)
24
Guide to
Kind Business Comply with Sanctions
About The Code

On Being Kind
and Trade Laws
Make Kind Decisions

Shared Responsibility
We comply with all relevant trade and sanctions laws
The Role of Our Leaders
not only by following the law ourselves, but by choosing
partners in compliance with those laws.
How to Raise a Concern

How We Are Kind

When You Raise a Concern

• We read and abide by Snap’s International Trade

The Code In Action
Law Policy.
Be Kind to Each Other

Be Kind to Our Community • We vet third parties against sanctions and restricted
Be Kind to Our Partners entity lists as part of our onboarding process.
Be Kind to Our Investors • We respect guidance from Integrity & Compliance
Be Kind to Our World regarding compliance with sanctions or trade laws.
• We seek guidance from Integrity & Compliance before
sharing software source code outside the United States
or exporting any equipment or hardware.
• We stay vigilant for any illegal boycott requests —
Related Policies requests from partners to confirm we aren’t doing
International Trade Law Policy business with certain countries — and we immediately
report such requests to Integrity & Compliance.
• We use the Snappy Shipping Page if we are going
to ship any goods across international borders.

25
Guide to
Be Kind to

Our Investors
Kind Business

About The Code

On Being Kind

Make Kind Decisions

Shared Responsibility

The Role of Our Leaders

How to Raise a Concern

When You Raise a Concern

TOPICS COVERED:
Our investors trust us by using
their resources to back our Keep Accurate Records and Contracts
The Code In Action
company. We honor that trust
Be Kind to Each Other
Make Truthful and Accurate Public Statements
Be Kind to Our Community by safeguarding our corporate
Be Kind to Our Partners resources and always Don’t Trade on Inside Information
Be Kind to Our Investors

Be Kind to Our World

operating honestly and fairly.
Compete Fairly

Respect Snap’s Property

Keep Confidential Information Confidential

26
Guide to
Kind Business

About The Code

On Being Kind

Make Kind Decisions

Shared Responsibility

The Role of Our Leaders

How to Raise a Concern

When You Raise a Concern

How We Are Kind

Keep Accurate
• We record all business activities accurately and honestly.
The Code In Action We do not engage in any activities that would cause those
Be Kind to Each Other records to be misleading.

Records and
Be Kind to Our Community • We respect and follow Snap’s contracting process. We
Be Kind to Our Partners make sure our contracts accurately portray the agreement
Be Kind to Our Investors

Contracts
and capture all terms of the deal. We don’t enter into
Be Kind to Our World “side agreements.”
• We respect Snap’s procurement process and make sure we
have the necessary authorization before entering into any
Related Policies
Document Retention and Our commitment to honesty is reflected in how we agreements or agreeing to any terms on Snap’s behalf.
Acceptable Communication
Tools Policy
keep business records. Those records come in all • We always record user engagement metrics, partner metrics,
Non-Financial Reporting Policy shapes and sizes, from receipts to contracts to our and financial data accurately. We never knowingly falsify,
Policy on Snap Data user engagement metrics and published financials. misstate, mischaracterize, or otherwise inaccurately represent
Purchasing and Whatever the type of record, we apply the same those metrics or financials.
Contracting Policy
approach: we are truthful, transparent, and accurate
Revenue Contract Policy • We immediately notify Risk Advisory Partners (RAP) or
in our documentation. That’s the kind of company that
Sales Code of Conduct Integrity & Compliance if we learn of anything that might
Snap Access to
investors and the public can trust.
Personal Data Policy
cause inaccuracies in our public filings or statements.
Snap Data Deletion
and Retention Policy

27
Guide to
Kind Business Make Truthful and Accurate
About The Code

On Being Kind
Public Statements
Make Kind Decisions
Investors, Customers, and Partners need
Shared Responsibility
to trust what we say because they make
The Role of Our Leaders
financial and business decisions based
How to Raise a Concern
on our disclosures. We take that trust How We Are Kind
When You Raise a Concern
seriously and avoid making misleading
public statements, particularly those related • We prepare complete, timely, and accurate financial reports.
to our finances, user engagement metrics,
• We understand that only designated spokespeople are
The Code In Action and any other data about the company.
authorized to make public statements on Snap’s behalf.
Be Kind to Each Other Likewise, we are truthful and honest when
We direct any press or other public inquiries to our
Be Kind to Our Community communicating with third parties about
Communications team. Snap team members follow
Be Kind to Our Partners our business.
public speaking guidelines and seek approval for
Be Kind to Our Investors
appropriate opportunities.
Be Kind to Our World
• When we communicate with third parties, we always give honest
and accurate information about our business. Our designated
spokespeople follow our corporate disclosure rules.
• We do not misstate, mischaracterize, or otherwise inaccurately
represent Snap data. We follow the company’s data review
Related Policies
and approval processes before releasing any data externally.
Corporate Disclosure Policy
(See Related Policies sidebar links.)
Employee
Communications Guide
• We ensure any research we publish is truthful and accurate,
Intra-Quarter Public
Statements Policy and does not disclose confidential information.
Policy on Snap Data
• We disclose a wider range of issues related to our social
impact through our yearly CitizenSnap Report and our
Diversity Annual Report.

28
Guide to
Kind Business Don’t Trade on Compete
About The Code

On Being Kind
Inside Information Fairly
Make Kind Decisions
We respect our outside investors and want them Everyone benefits when there is a
Shared Responsibility
to feel confident investing in our business. That’s competitive marketplace. We protect
The Role of Our Leaders why we educate our team members to never put that interest by competing according
How to Raise a Concern investors at a disadvantage by unfairly trading on to the rules. We get ahead by being kind,
When You Raise a Concern our inside knowledge of Snap. Insider trading is smart, and creative, not by engaging in
not only illegal, but also it violates the trust of our unfair or unethical business practices.
investors and the public.
The Code In Action

Be Kind to Each Other

Be Kind to Our Community

Be Kind to Our Partners How We Are Kind How We Are Kind

Be Kind to Our Investors

Be Kind to Our World

• We respect all laws banning insider trading. • We don’t engage in collusion with our • We never take advantage of anyone through
Under those laws, we instruct our team competitors. For example, we don’t manipulation, concealment, abuse of
members not to trade based on “material enter into unlawful agreements to do confidential information, misrepresentation
non-public information” (i.e., information any of the following: set pricing, allocate of material facts, or any other unfair practice.
that a reasonable investor doesn’t have, customers or markets between us and
• We do market research through appropriate
but would find important). competitors, rigging bids against each
Related Policies and lawful means that are never misleading,
Insider Trading Policy other, or exclude industry participants.
• We instruct our team members not to and we never rely on confidential
Sales Code of Conduct
trade during the closed trading windows • We ensure that any public statements information from our competitors.
before our quarterly earnings releases. we make about our competitors or the
• We make decisions on hiring and recruiting
industry are true and not misleading,
• We instruct our team members not to give unilaterally and do not come to agreements
deceptive, or fraudulent.
anyone “tips” about material non-public with competitors on who we will recruit.
information or suggest that they make
trades based on our inside knowledge.
29
Guide to
Kind Business Respect Snap’s
About The Code

On Being Kind
Property
Make Kind Decisions

Shared Responsibility
We also demonstrate our integrity by respecting
How We Are Kind
Snap’s property. That property is meant to
The Role of Our Leaders
benefit our investors and other stakeholders, • We never take Snap’s property for our personal benefit.
How to Raise a Concern
not us personally. We are responsible and
When You Raise a Concern • We spend Snap’s money wisely and use its resources carefully.
honest when handling and protecting
For example, we make sure that any expenses are reasonable,
Snap’s property, including money, corporate
tied to a business purpose, and compliant with Snap’s policies.
information, physical property and goods,
The Code In Action intellectual property, and other belongings. • We understand that business communications and data belong
Be Kind to Each Other to Snap and should only be accessed and reviewed according
Be Kind to Our Community We also respect the property of individuals, to our internal policies.
Be Kind to Our Partners such as team members and suppliers,
• We respect the intellectual property of our partners and other
Be Kind to Our Investors consistent with our shared commitment
third parties. For example, we never copy protected materials
Be Kind to Our World to being kind.
or otherwise take or use third-party intellectual property —
such as code, images, text, or other creative works — without
authorization or legal justification.
• We report questions or concerns regarding the protection of
Snap’s property and/or personal property to Global Security or
Related Policies Integrity & Compliance.
Security & Privacy Policies,
and Email Security Policy
Travel and Expense Policy

30
Guide to
Kind Business Keep
About The Code Confidential
Information
On Being Kind

Make Kind Decisions

Shared Responsibility

Confidential
The Role of Our Leaders

How to Raise a Concern

When You Raise a Concern

How We Are Kind
Snap’s continuing product leadership
The Code In Action relies on our ability to out-innovate our • We treat all of Snap’s non-public information as restaurants — this is one of the reasons why
Be Kind to Each Other competitors and surprise our community confidential and we don’t disclose it to anyone our Food team provides in-office meals. And
Be Kind to Our Community with terrific experiences. That means outside the company without the appropriate even inside the office, we only disclose and
Be Kind to Our Partners confidentiality — about our projects, authorization. As part of this commitment, discuss confidential information on a need-
Be Kind to Our Investors our products, non-public financial we never take Snap’s non-public information to-know basis.
metrics, and any other private outside of Snap’s IT environment without a valid
Be Kind to Our World • We respect the confidentiality of our
information — is critical. We treat business reason. We also never expose Snap’s
partners and other third parties, and we
the confidential information of third non-public information to any AI tool that is
never disclose their confidential information
parties with the same respect. not otherwise approved under Snap’s Policy
without authorization.
on Generative AI Use. We understand that non-
public information includes a wide variety of • We do not use confidential information of
information, such as marketing plans, customer Snap or our partners or other third parties
Related Policies
Personnel Cybersecurity Policy information, financial information, metrics, and for personal gain.
Policy on Snap Data internal reports and emails. • We report questions or concerns regarding
Snap Policy on Generative the protection of confidential information to
AI Use • We never hold confidential conversations within
earshot of the public or in public places like Global Security or Integrity & Compliance.

31
Guide to
Be Kind to

Our World
Kind Business

About The Code

On Being Kind

Make Kind Decisions

Shared Responsibility

The Role of Our Leaders

How to Raise a Concern

When You Raise a Concern

TOPICS COVERED:
Snap is only as healthy as the
The Code In Action communities, countries, and Respect Laws
Be Kind to Each Other
planet of which it is a part.
Be Kind to Our Community
Protect the Environment
Be Kind to Our Partners To make sure that those systems
Be Kind to Our Investors stay healthy, we must respect Respect and Promote
Be Kind to Our World
local laws and universal rights, Human Rights
and take responsibility for
Give Back
creating positive social impact.

32
Guide to
Kind Business Respect Laws Protect the Environment
About The Code Our global corporate citizenship begins by respecting the laws We are a citizen not only of the countries where we operate, but
On Being Kind of the places where we operate. also the planet on which we all live. It is part of our responsibility to
Make Kind Decisions
operate our business in a way that respects the environment.
Shared Responsibility

The Role of Our Leaders

How to Raise a Concern

When You Raise a Concern

How We Are Kind How We Are Kind
• We follow all applicable governmental laws, • We take action to reduce the carbon
The Code In Action rules, and regulations. emissions of our products and operations.
Be Kind to Each Other

Be Kind to Our Community

• We pay appropriate tax to the countries and • We educate ourselves about sustainability
Be Kind to Our Partners
localities where we operate. We view tax and environmental impact so that we can
Be Kind to Our Investors
not just as a legal obligation but as a way to make informed choices, such as minimizing
Be Kind to Our World
support those communities. Ensuring that waste and recycling.
we pay the right amount of tax, at the right
• We incorporate sustainability into the design,
time, and in the right place is a critical part
construction, and ongoing occupancy of
of our approach.
our spaces and kitchens.
• If we are ever confused about what the law
• We provide food that is healthy and
requires, or think something we or someone
produced using practices that respect
Related Policies else is doing may be violating the law, we reach
CitizenSnap Report
farmers, workers, animals, and the land.
out to Integrity & Compliance for guidance.
Global Tax Strategy
Political Ad Sales Policy • We have a zero tolerance approach to the
facilitation of tax evasion by Snap, our team
members, or anyone acting on our behalf.
Any concerns regarding potential tax evasion
should be reported immediately.

33
Guide to
Kind Business

About The Code

On Being Kind

Make Kind Decisions

Shared Responsibility

The Role of Our Leaders

How to Raise a Concern

When You Raise a Concern

How We Are Kind
• We
​​ seek to operate according to the expectations
The Code In Action set out in the United Nations’ Guiding Principles on
Be Kind to Each Other Business and Human Rights and are members of
Be Kind to Our Community the Responsible Business Alliance (RBA). We address
Be Kind to Our Partners any adverse human rights impacts with which we
are involved.

Respect and Promote

Be Kind to Our Investors

Be Kind to Our World • We empower people to express themselves through

our products and in our workforce.

Human Rights
• We pay a living wage.
• We protect user privacy.
• We ensure an ethical supply chain.
Related Policies
Snap believes that all companies should respect people’s core
Supplier Code of Conduct • We strive to give all team members the opportunity
human rights, such as the inherent rights to privacy, fair labor,
Team Member Handbook to succeed at Snap regardless of their identity.
and an adequate standard of living. This is something that we ask
of our suppliers; we must make sure that our own products and
operations also reflect this fundamental commitment.

34
 Give Back
Guide to
Kind Business

About The Code

At the end of the day, being kind is about
On Being Kind
recognizing the positive difference we can
Make Kind Decisions
make in people’s lives when we approach
Shared Responsibility
each other with empathy. By leveraging both
The Role of Our Leaders Snap’s resources and our team members’
How to Raise a Concern time and talents, we are able to maximize
When You Raise a Concern our capacity to make a meaningful impact.

The Code In Action

Be Kind to Each Other

Be Kind to Our Community

Be Kind to Our Partners How We Are Kind

Be Kind to Our Investors

Be Kind to Our World

• We promote the well-being of the neighborhoods where we work
through volunteerism.
• We support nonprofits that align with our philanthropic priorities
and mission.
• We get approval from our Philanthropy & Finance teams before
Related Policies
donating any funds or resources on behalf of Snap to charitable
Corporate Giving Policy
causes or tax-exempt organizations related to Snap or our business.
Policy on Political
Contributions and We never present ourselves as Snap’s representative when privately
Charitable Donations
contributing to charitable causes.
Volunteer Time Off Policy
• We make sure to avoid any appearance of impropriety in our
charitable activities and corporate sponsorships.
• We never pressure others, such as co-workers or suppliers, to
contribute to charitable organizations or other community causes.
35
Violations,
Waivers, & Questions or concerns?

Modifications We’re here to help!

You can get in touch with Snap Integrity
& Compliance in a variety of ways:
Violations of this Code may result
in disciplinary action up to and
including termination of employment, MAIL:

at the sole discretion of the Company Snap Integrity & Compliance

or Board. 2772 Donald Douglas Loop North,
Santa Monica, California 90405
The Board of Directors or a delegated
board committee must approve: ANONYMOUS HELPLINE:

• Any substantive modification of Available at www.snaphelpline.com

this Code or by phone at 1-800-461-9330.

• Waivers of any part of this Code International phone numbers available at

for Executive Officers or members www.snaphelpline.com.
of the Board of Directors. All
such waivers must be publicly
EMAIL:
disclosed by publication on
Compliance@snap.com
the Snap website or by filing a
current report on SEC Form 8-K
pursuant to applicable SEC and
stock exchange rules.
Latest version approved by the Board February 2025.