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DeepL Code of Conduct For Suppliers

DeepL is dedicated to upholding the highest standards of ethics and responsible business throughout our global operations and supply chains. We therefore require all of our suppliers, together with their subcontractors (where applicable), to adhere to this Supplier Code of Conduct. By acting as our supplier, you agree to do so.

This Code of Conduct sets out the minimum standards that we require from you as a DeepL supplier. It’s based on core, internationally recognised values such as those set out in the Universal Declaration of Human Rights, ILO conventions, and the UN Global Compact.

In the event of a conflict, please prioritise compliance with applicable law, followed by the terms of your contract with DeepL, and then refer to this Supplier Code of Conduct.

1. Lawful Conduct

You must comply with all national and international laws and regulations applicable to your business.

2. Anti-Corruption

You must conduct your business with integrity and prevent any form of corruption. This includes compliance with all relevant anti-corruption laws, such as StGB §299 (German Criminal Code), the Foreign Corrupt Practices Act (FCPA), and the UK Bribery Act

In particular, this means you must not offer or provide any form of bribe or improper payment to government officials, political parties, private individuals, or other persons to gain an unfair business advantage. Accordingly, the exchange of gifts, meals, or entertainment must be conducted responsibly and transparently, complying with the recipient’s organisational policies.

3. Anti-Money Laundering

You must comply with laws and regulations aimed at preventing and detecting money laundering, terrorist financing, and other illegal financial activities.

4. Fair Competition

You must compete fairly and in compliance with antitrust and competition laws. Prohibited actions include agreements with competitors to fix prices or allocate territories, and exchanging competitively sensitive information.

5. Accurate Record-Keeping

You must maintain accurate and transparent financial and business records in accordance with applicable accounting standards and legal requirements.

6. Conflicts of Interest:

You must avoid situations in which the personal interests of your employees may influence, or appear to influence, business decisions involving DeepL. This includes them having financial interests in our competitors or close relationships with any of our employees involved in procurement. You should promptly disclose any potential or actual conflict to DeepL.

7. Trade Compliance & Export Controls:

We expect you to comply with all applicable export control regulations, trade sanctions, and other international trade laws.

8. Data Privacy 

When processing any personal data on DeepL's behalf or as received from DeepL, you must:

  • comply with all applicable data protection laws and requirements; and
  • have in place measures to ensure an appropriate level of security to prevent accidental or unlawful destruction, loss, alteration, disclosure, or access.

9. Confidentiality & Proprietary Information

It's essential that you maintain the highest levels of confidentiality and protect all proprietary information, in accordance with the terms of your contract with DeepL. You may only use our logo, tradename or trademarks with our written consent. 

10. Human Rights, Ethical Sourcing & Labour Practices:

We expect you to promote ethical practices within your operations and supply chains, specifically:

  • You should take all reasonable steps to ensure that your global business and supply chains are free from child labour, forced labour, slavery, and human trafficking.
  • You should ensure your employees can enjoy a workplace free from discrimination or harassment, with equal opportunities for all.
  • You should have appropriate processes in place to prevent sexual harassment, ensuring prompt investigation and resolution of complaints, and holding violators accountable. If you become aware of any complaints of sexual harassment linked to DeepL, you should promptly let us know (where appropriate).
  • You should comply with relevant regulations governing minimum wages, benefits, holidays, breaks, and working hours.
  • You should ensure your employees enjoy freedom of association and collective bargaining, in accordance with applicable laws.
  • You should ensure a safe and healthy work environment, taking reasonable steps to prevent accidents or injuries.
  • You should ensure that your employees are able to raise genuine ethical or legal concerns without risk of retaliation. 

11. Environmental Responsibility:

You must comply with all applicable environmental regulations and are encouraged to adopt sustainable business practices, such as waste reduction, energy efficiency, and responsible resource usage. DeepL supports continuous improvement in environmental performance and encourages Suppliers to set and pursue sustainability targets.

12. Compliance & Reporting: 

To give effect to this Supplier Code of Conduct, we expect you to:

  • take reasonable steps to ensure relevant employees, agents, and subcontractors are aware of and comply with it,
  • cooperate fully and promptly with us regarding any reasonable compliance request we make, and
  • report to us any suspected breach, or any other unethical or unlawful behaviour involving DeepL-related business.