A NTI -C ORRUPTION P OLICY
1. I NTRODUCTION
Snowflake Inc. and its worldwide subsidiaries (collectively, ' Snowflake ' or ' we ') are committed to conducting business with honesty, integrity, and accountability. We operate in many countries, and strive to meet the highest standards of ethical conduct in all of them. As part of this mission, we seek to avoid even the appearance of corruption or impropriety.
The purpose of this Anti-Corruption Policy (this ' Policy ') is to reiterate this commitment and establish procedures for complying with all anti-corruption laws and regulations applicable to Snowflake's business, including the U.S. Foreign Corrupt Practices Act of 1977, as amended (the ' FCPA '), the UK Bribery Act 2010 (the ' UK Bribery Act '), and anti-corruption laws and regulations in jurisdictions in which Snowflake engages in business. Snowflake prohibits all forms of corruption and bribery, and is committed to ensuring that corruption and bribery do not occur in its business activities.
This Policy applies to all Snowflake employees, directors, and contractors worldwide, including employees of Snowflake subsidiaries.
Policy Statements
- You are strictly prohibited from promising, offering, providing, authorizing, requesting, or accepting money (such as bribes or kickbacks) or anything else of value (such as a gift, benefit, favor, or advantage) directly or indirectly to or from any person to achieve an improper purpose related to Snowflake's business.
- You must comply with all of Snowflake's internal controls, especially those designed to (i) ensure accurate and complete books and records or (ii) otherwise prevent improper payments, self-dealing, embezzlement, or fraud.
There are no exceptions to this Policy, even if our competitors engage in improper behavior or if corruption is an accepted practice in a country where we operate. You are required to adhere to both the spirit and the letter of this Policy with respect to our business anywhere in the world.
2. A NTI -B RIBERY
2.1 Anti-Bribery Rules and Regulations
The FCPA prohibits you and Snowflake from improperly promising, offering, providing, or authorizing the provision of money or anything of value, directly or indirectly, to any foreign official and certain other persons in order to (i) influence any act or decision of the recipient in his or her official capacity; (ii) induce the recipient to do or omit to do any act in violation of his or her lawful duty; (iii) secure any improper advantage; or (iv) induce the recipient to influence any act or decision of a non-U.S. government or instrumentality, in order to obtain, retain, or direct business.
In addition to the United States, almost all other countries, including Australia, India, the Netherlands, and the United Kingdom, have their own anti-bribery laws. One of the most significant and expansive anti-corruption laws other than the FCPA is the UK Bribery Act. The UK Bribery Act differs from the FCPA in two significant ways. First, the UK Bribery Act covers both foreign and domestic bribery. Second, the UK Bribery Act is not limited to bribery of government officials. It covers corruption in a business-to-business commercial context as well as situations where an employee, official, or agent of a government, state-owned enterprise, quasi-governmental entity, publicly-funded institution, or public international organization (collectively, 'Public Sector Entity') is involved (although U.S. laws other than the FCPA prohibit domestic and commercial bribery as well).