Looker Data Sciences, Inc. including its subsidiaries (“Looker”) believes that the success of our business
and the strength of our relationships are directly related to our actions. That’s why we’ve established
high ethical standards and guiding principles for how we operate, and we expect each of our Suppliers to
do the same. This Supplier Code of Conduct (the “Supplier Code”) describes the standards by which our
Suppliers must operate and will be held accountable.
This Supplier Code applies to all Looker suppliers of products or services, including consulting firms,
independent contractors, staffing agencies, agency temps, licensees, regardless of their title or the
product or services they provide (“Suppliers”). Suppliers also includes partners, meaning any company
or individual who has agreed to the Looker Partner Program Agreement. Suppliers should also
encourage third parties they work with to comply with the standards described here. In your capacity as
a Supplier, we expect you to know and follow all federal, state, provincial, and international laws and
regulations that apply to your work where you do business.
This Supplier Code reflects Looker’s ethics and values, who we are and how we behave:
- We are honest, ethical and maintain the highest level of professional standards;
- We avoid actual or apparent conflicts of interest;
- We follow the letter and spirit of the law;
- We protect our assets and confidential information;
- We ensure financial integrity and responsibility; and
- We are good global citizens.
While this Supplier Code may serve as a guide, it is not intended to cover every applicable scenario or
address every situation that may arise. You are expected to use good judgement in line with the high
standards of ethics and integrity to which Looker has committed. You are expected to raise
questions/concerns or seek additional guidance on appropriate conduct when a particular situation
arises that may not be addressed in this Supplier Code. Yous should also encourage third parties they
work with to comply with our standards.
I. SUPPLIERS ARE HONEST, ETHICAL AND MAINTAIN THE HIGHEST LEVEL OF PROFESSIONAL STANDARDS
Suppliers must strive to be honest, ethical and professional in all dealings with each other and with third
parties. You are committed to being truthful, compete fairly, and respect and treat others with dignity.
Open and Honest Communication
Suppliers help create a culture of open and honest communication where everyone is encouraged to ask
questions and share their concerns. From the top down, you have the responsibility of creating an
environment that is supportive and responsive, and you raise concerns when you observe or hear about
questionable behavior. Questions and concerns are investigated by the appropriate members of
management and the appropriate remediation efforts are taken. Where improper behavior is found to
have occurred, you will take appropriate action and will not tolerate retaliation against individuals who
have identified or reported such behavior.
You are honest and truthful with all of Looker’s customers, vendors, business partners and government
or other public officials. Looker strives to outperform our competition through superior performance of
our products and services, not through unethical or illegal business practices. This means you deal fairly
with whomever you have contact in the course of performing your jobs. You do not engage in deceptive,
unfair or unethical practices.
II. SUPPLIERS AVOID ACTUAL OR APPARENT CONFLICTS OF INTEREST
Suppliers must make business decisions based on the best interests of Looker or Looker’s Supplier and
not based on personal relationships or benefits, either for yourselves or for others. You do not use or
attempt to use your position to obtain improper personal benefits.
A conflict of interest may exist where the interests or benefits of one person or entity conflict or appear
to conflict with the interests or benefits of Looker or Looker’s Supplier. A conflict of interest may also
arise whenever an action you have taken prevents you from objectively and honestly performing your
duties and responsibilities to Looker. Common examples of situations that may create conflicts of
- Offering, exchanging or accepting anything more than a nominal gift from a prospect, customer,
partner, vendor or even a colleague - any of this could be viewed as a bribe, favoritism, an
attempt to exert inappropriate influence, etc.
- Loans or favors that the Supplier, a worker, or a family member receives through your
relationship with Looker.
- Improper advantages gained by acting on information
learned through your relationship with Looker.
- Business opportunities that belong to Looker.
- Suppliers that employ or are controlled by Looker employees or their family members.
If you become aware of a possible conflict of interest, or if you have questions about whether a conflict
of interest exists, consult your internal resources or your Looker business
Gifts and Entertainment
We never want an exchange of gifts to be perceived as a bribe or an attempt to gain improper
advantage with partners, customers or government and other public officials. Gifts can be anything of
value, including meals, entertainment or physical objects. The exchange of nominal gifts such as t-shirts,
swag or meals in conjunction with business discussions may be acceptable, provided the item or meal is
not extravagant, is reasonable and appropriate for the circumstance, is given openly and directly
without expectation of anything in return, and the gift or meal is not offered, provided or accepted to
further a business interest. Gifts should not be: (i) made or received on a regular or frequent basis, (ii)
made in cash, or gift or money cards, (iii) susceptible of being construed as a bribe or kickback, or (iv) be
given or received in violation of any laws. In some parts of the world gift giving is common practice and
not accepting a gift could reflect badly on Looker or Looker’s Supplier. Even in those instances,
however, you should avoid giving a gift that exceeds a nominal value.
Gifts and entertainment involving government officials are expressly prohibited. A government official
can be a national or local government employee, a political candidate, a party official, a member of a
royal family, or an employee of a government-controlled entity.
Supplier employees who make, facilitate, and/or approve expenditures for meals, refreshments, or
entertainment must use discretion and care to ensure that such expenditures are in the ordinary and
proper course of business, conducted in appropriate locations, and could not be misconstrued.
If any uncertainty exists with respect to the appropriateness of any entertainment or gifts, consult your
internal resources or your Looker business contact.
III. SUPPLIERS FOLLOW THE LETTER AND SPIRIT OF THE LAW
You strive to comply with the laws of the jurisdictions and countries where you do business. You are
responsible for knowing and following the laws, rules and regulations applicable to Looker and Supplier.
Where this Supplier Code or Looker guidelines differ from local laws or regulations, you always follow
the higher standard. Violations of laws and regulations have serious consequences and may adversely
affect the reputation and the trust we have built with our communities.
Disregard of laws, rules or regulations are not tolerated, and you understand that violation of domestic
or foreign laws, rules and regulations may subject an individual, Suppliers, as well as Looker, to civil
and/or criminal penalties, fines or restrictions.
As a Supplier, you may have access to material, non-public information about Looker or other
companies. The United States and many other countries have insider trading laws that restrict trading
common stock or other securities and other activities by anyone who is aware of material, nonpublic
information. Information is material if a reasonable investor would consider it important in deciding
whether to buy, hold, or sell a company’s securities. Information that is not available to the public is
called “inside” information.
To use material inside information in connection with buying or selling securities, including “tipping”
others who might make an investment decision on the basis of this information, is unethical, a violation
of this policy, and illegal, irrespective of whether the information is about Looker or another company.
If you become aware of material, nonpublic information, you do not:
- Trade in or execute transactions regarding that company’s stock or other securities, or
- Disclose that information to others who may buy or sell securities because of the information, or
otherwise use the information for personal advantage or the personal advantage of others.
Anti-Corruption, Bribery, and Kickbacks
Bribery is illegal in every jurisdiction where Looker does business, and the consequences are severe. You
strictly prohibit the offer or acceptance of any bribes or kickbacks and participation in or facilitation of
corrupt activity of any kind.
- Bribery is offering or giving something of value in order to improperly influence the recipient’s
- A “facilitation” payment is a tip, small payment or anything of value made to influence someone
in their official or professional capacity, such as a government or public official in order to
expedite a routine government action, such as issuing a permit or providing utility service. Many
countries’ laws define facilitation payments made to government officials as bribes.
- A “kickback” is the return of a sum paid or to be paid as a reward for fostering a business
arrangement. Accepting or offering a kickback violates this Supplier Code.
It is a violation of the U.S. Foreign Corrupt Practices Act of 1977 (“FCPA”), the U.K. Bribery Act of 2010
and other similar international anti-corruption laws to engage in any form of bribery. Penalties for
violating anti-corruption laws are severe and can include large fines and prison time.
This policy against offering, promising or paying bribes also applies to third parties who provide services
or act on Looker’s behalf. You must never engage a third party whom you believe may attempt to offer a
bribe in connection with Looker business. These laws apply to all Supplier employees, officers and
directors and also to Supplier’s agents, consultants, distributors, independent contractors or anyone
working on our behalf.
When doing business with government or public officials or others who may be connected to a
government agency, please be aware of any special rules or laws that apply.
You do not use Looker or Supplier funds or resources to support political activity or lobbying.
You are committed to participating in international efforts to combat money laundering and to prevent
the funding of terrorist and criminal activities.
If you believe corrupt practices are occurring within Looker’s supply chain, report your concerns to your
internal resources or your Looker business contact immediately.
Suppliers must comply with antitrust laws that are designed to protect the competitive process. This
means you are generally prohibited from entering into the following agreements or arrangements:
- agreements, formal or informal, with competitors that harm competition or customers,
including price fixing and allocations of customers, territories or contracts;
- agreements, formal or informal, that establish or fix the price at which a customer may resell a
- the acquisition or maintenance of a monopoly or attempted monopoly through anti-competitive
You do not exchange certain kinds of information, such as pricing, production and inventory, with
competitors, regardless of how innocent or casual the exchange may be.
Antitrust laws impose severe penalties for certain types of violations, including criminal penalties and
potential fines and damages of millions of dollars, which may be tripled under certain circumstances.
Understanding the requirements of antitrust and unfair competition laws of the various jurisdictions
where we do business can be difficult, and you are urged to seek assistance from your internal resources
for guidance about such laws.
Import and Export Compliance
Suppliers must comply with U.S. Export Control Laws that govern all exports of commodities and
technical data from the U.S., including electronic or physical distribution of software and source code
and written, electronic, or oral disclosure of technical data to a foreign visitor or H1B Visa worker.
Individuals involved in international transactions need to know what is expected of Looker and Looker’s
Suppliers, including any requirements related to taxes, verification, licensing, and permits. You are
responsible for knowing and following the appropriate rules and procedures for imports and exports.
Compliance with export control laws is essential to do business in the international marketplace. United
States and foreign governments maintain strict rules regarding the methodology for goods exchanged
across their borders. When working with international customers, there may be additional steps
required before delivering products or services internationally.
In many cases, the law requires an export license or other appropriate government approvals before an
item may be shipped or transferred. As Looker and Looker’s Suppliers comply with these laws and
regulations, you do not:
- Proceed with a transaction if you know that a violation has occurred or is about to occur;
- Transfer controlled software and technology unless appropriate authorizations are obtained; or
- Apply an inappropriate monetary value to goods and services.
Failure to comply with U.S. export control laws could result in significant fines and penalties, denial of
export licenses and/or the loss or restriction of our export privileges. Violation of these laws and
regulations, even inadvertent ones, may also result in fines and imprisonment for individual employees
and their management chain.
No Unsanctioned Boycotts
You do not participate in, cooperate with, or otherwise comply with laws, regulations or requirements
associated with, unsanctioned foreign boycotts, including the Arab boycott of Israel. Questions or
concerns about unsanctioned boycotts should be addressed to the your internal resources or your
Looker business contact.
IV. SUPPLIERS PROTECT OUR ASSETS AND CONFIDENTIAL INFORMATION
You are committed to being an ethical steward of the data and personal information of its users,
customers, prospects and employees and other individuals with whom Looker and its Suppliers interact.
This helps create an environment of trust and integrity with Looker’s customers and the business
community, and drives how Looker complies with applicable global data protection and privacy laws.
Supplier’s policies and standards are consistent with applicable laws.
All non-public information about Looker, Supplier or a company with which we do business is considered
confidential information. You protect assets and maintain the confidentiality of confidential information
entrusted to Looker by Looker’s employees, job applicants, independent contractors or and other
companies, including our customers.
You responsibly collect, use and protect the data and personal information that customers give or that
are obtained through business partnerships. This includes the data and personal information that
Looker’s customers give about their own customers or employees. Personal information includes names,
email and street addresses, telephone numbers and login identification, financial account or personal
health information, benefits information, Social Security, national identification, passport and driver’s
Personal information is not disclosed except when that disclosure is authorized by the responsible entity
or individual, or mandated by applicable law, regulation, legal process, or lawful government request,
including in connection with national security or law enforcement requirements.
You follow all Looker security policies, privacy policies and supporting standards and procedures when
engaging in any business process, delivering and supporting the Looker product and platform, or when
using applications or systems that involve the use, storage or transmission of data and personal
Protection and Proper Use of Corporate Assets
Looker trusts our Suppliers with a wide range of technology and other tools that make it possible to do
your job effectively. You are required to use these tools wisely and ensure their efficient use, as
carelessness, waste and theft have a direct impact on profitability. Assets are only used for legitimate
business purposes and not for any personal benefit or the personal benefit of others. Looker’s name,
brand name or any trademark owned or associated with Looker are not to be used for any personal
The following activities are strictly prohibited while acting on behalf of Looker or while using Looker
computing or communications equipment or facilities:
- accessing the internal computer system (also known as “hacking”) or other resource of another
entity without express written authorization from the entity responsible for operating that
- committing any unlawful or illegal act, including harassment, libel, fraud, sending of unsolicited
bulk email (also known as “spam”) or material of objectionable content in violation of applicable
law, trafficking in contraband of any kind or espionage of any kind.
If authorization to access another entity’s internal computer system or other resource is received, a
permanent record of that authorization must be made so that it may be retrieved for future reference,
and access may not exceed the scope of that authorization.
Any misuse or suspected misuse of Looker assets must be immediately reported to your Looker business
Looker protects our Suppliers’ confidential information. In return, Suppliers must protect Looker’s
confidential information. You should never disclose such information to anyone without our express
Confidential information includes non-public information that might be of use to competitors or harmful
to Looker or Looker’s customers if disclosed, such as business, marketing and service plans; financial
information; product ideas and roadmaps; computer code (both source and object code); engineering
ideas, designs and techniques; databases; customer and supplier lists; pricing strategies; inventions;
mask works; and personnel data, personally identifiable information pertaining to Looker’s employees,
customers or other individuals; and similar types of information to any of the above, as provided to
Looker by our customers and partners. This information may be protected by patent, trademark,
copyright and trade secret laws.
In addition, you protect the sensitive and confidential Information of third parties, including Looker’s
customers, partners and vendors, through formal agreements, such as Non Disclosure Agreements
(NDAs), Data Protection Agreements (DPAs) and confidentiality clauses in the Looker Master Services
Agreement (MSA) and the Partner Program Agreement. When you interact with other companies and
organizations, there may be times when you learn confidential information about them before that
information has been made available to the public. You treat this information in the same manner as
you treat Looker’s sensitive, confidential and proprietary information.
You are expected to keep sensitive, confidential and proprietary information confidential unless and
until that information is released to the public through approved channels. Unauthorized use or
distribution of confidential information may be illegal and could result in civil liability and/or criminal
You also take care not to inadvertently disclose sensitive and confidential information. Materials that
contain confidential information, such as memos, notebooks, computer disks, mobile devices, memory
sticks and laptop computers, are stored securely. You are fair and truthful in your public statements, and
abide by the applicable Looker media policy and social media guidelines. Unauthorized posting or
discussion of any information concerning Looker’s business, information or prospects on the Internet is
prohibited. You are mindful of conversations regarding Looker in public spaces. All emails, chats and
IMs, voicemails and other communications pertaining to Looker business are held as confidential
information and are not to be forwarded or disseminated except for Looker business purposes.
Questions, issues or concerns regarding Looker assets or the protection of confidential information can
be raised to your internal resources or your Looker business
V. SUPPLIERS ENSURE FINANCIAL INTEGRITY AND RESPONSIBILITY
Looker relies on our books and records to report our financial results, make required legal filings, and
make business decisions. As a Supplier, you must keep accurate books and records of all your business
dealings with Looker. These records must be in accordance with applicable standard accounting
practices. You strive to promote financial integrity throughout your business and in your financial
reporting. You are responsible and fully comply with any requirements to file timely reports with
government agencies and make disclosures that are accurate, balanced, complete and understandable.
If you know of any actual or potential financial, accounting, or books and records issue related to Looker,
speak to your Looker business contact.
VI. SUPPLIERS ARE GOOD GLOBAL CITIZENS.
You make concerted efforts to promote the protection of individuals and conduct business activities and
operations in a manner that minimizes your impact on the environment. You comply with all applicable
laws and regulations regarding the safety and health of our personnel. Your products do not contain
conflict minerals such as tantalum, tin, tungsten and gold that finance or benefit armed groups
perpetrating serious human rights abuses in the Democratic Republic of the Congo or an adjoining
Respect for the Individual
You are an equal opportunity employer that is committed to hiring individuals based on necessary
qualifications, merit and credentials required for the role. You prohibit discrimination based on gender
identity, gender expression, family medical history or genetic information, race, age, sexual orientation,
ethnicity or national origin, disability, pregnancy, religion, political affiliation, veteran status or any other
characteristic protected by law. You are also committed to a workplace that is free of harassment and
bullying and where everyone is treated with dignity and respect.
In addition, compensation paid to workers complies with all applicable wage and labor laws, including
those relating to minimum wages, overtime hours and legally mandated benefits. Working hours do not
exceed the maximum hours set by local law and you do not employ child labor.
You do not tolerate any violence or threat of violence, as well as any behavior that impedes on the
mental and emotional safety in the workplace, including offsite business or social events. You are
committed to a violence-free environment that includes appropriate controls and safety procedures and
compliance with relevant local and national laws, codes and regulations.
If you see something, say something. Discovery of potential threats to the security or privacy of Looker’s
customer or employee information, should be reported immediately.
You actively aim to minimize your environmental footprint by taking steps across your offices to
conserve energy, recycle and minimize waste. You comply with all local and environmental regulations
and laws and strive to conduct our operations in a way that conserves natural resources.
This Supplier Code is a statement of certain fundamental principles, policies and procedures that govern
Looker’s Suppliers in the conduct of your business. Reported violations of this Supplier Code will be
investigated and appropriate action taken.
Looker is committed to continuously reviewing and updating our policies, and Looker’s management will
review this Supplier Code on a regular basis. Looker therefore may amend this Supplier Code at any time
and for any reason.