Updated on June 21, 2023
Redis Ltd., including its affiliates and subsidiaries (“Redis”) is committed to the highest standards of legal and ethical business conduct. Redis expects its partners, vendors, suppliers, service providers and subcontractors, and their respective employees, agents, and representatives (collectively, “Suppliers”) to share the same commitment. This Supplier Code of Business Conduct and Ethics (this “Policy“) serves as a source of guiding principles and summarizes the ethical standards of conduct that we require of our Suppliers.
This Policy is not intended to cover every possible situation that may give rise to an ethical or legal concern, but is intended to promote:
Suppliers are expected to review, understand, and comply with this Policy. The Policy should be viewed as the minimum standards that we expect from our Suppliers and is not intended to reduce, replace, or limit any other legal or contractual obligations that you have to Redis or otherwise. Any questions about this Policy or the appropriate course of conduct in a particular situation should be directed to Redis Legal at legal@redis.com.
Suppliers are responsible for the accurate and complete reporting of financial information with respect to the provision of goods or services to Redis. Financial information submitted to Redis, government agencies, or the general public must be full, fair, accurate, timely and understandable. All agreements with Redis should be in writing and executed by a Supplier representative with appropriate authority.
Redis must ensure that all disclosure in reports and documents that Redis files with, or submits to, the Securities and Exchange Commission and in other public communications is full, fair, accurate, timely, and understandable. Supplier should cooperate and take all steps available to assist Redis in these responsibilities to the extent consistent with Supplier’s scope of role to Redis. Supplier should provide prompt, accurate answers to all relevant inquiries in connection with Redis’ preparation of its public reports and disclosures. Supplier may not make public communications on Redis’ behalf without Redis’ prior written consent.
This Policy does not prohibit normal, appropriate, and modest hospitality to or from third parties during the course of a business relationship designed to build goodwill among business partners. However, Suppliers must not give or accept gifts, gratuities, or hospitality where doing so would create a conflict of interest, or violate any U.S. or foreign laws, including, but not limited to, the United States Foreign Corrupt Practices Act, the United Kingdom Bribery Act of 2010, the United States Travel Act, Title 18 of the United States Policy section 201 and all local anti-bribery, anti-corruption or anti-money laundering laws that may be applicable. Suppliers should adopt internal policies and procedures to ensure no payments or gifts are offered, made, requested, or received that are inconsistent with this Policy.
Suppliers may not give or accept gifts with an intention, or a reasonable prospect, of influencing Redis’ customers, prospects, employees, representatives, or other suppliers to obtain or retain an improper business advantage, or to reward the provision or retention of an improper business advantage, or in explicit or implicit exchange for favors or benefits. Supplier must always remain mindful that government or public officials, international organization officials, or employees of state-owned or state-controlled companies are restricted in the benefits they can accept for performing their duties, including both cash and non-cash benefits such as meals, gifts, travel, and entertainment.
The practice of giving business gifts and taking part in corporate hospitality or undertaking speaking engagements varies between countries, regions, and industries. What may be normal and acceptable in one locale may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable (both from the perspective of the provider and recipient) rather than lavish and extraordinary, bearing in mind that what may normally be viewed as small or insignificant in some countries can be of significant value in another. The intention behind the gift should always be considered and nothing must be explicitly or implicitly expected or demanded in return.
Supplier must never directly or indirectly (e.g., via a third party) make or provide a payment (including cash, cash equivalents, or any other items of value such as meals, gifts, travel, entertainment, etc.) to a foreign official or government employee to influence the foreign official or government employee, to obtain or retain business for Redis or to acquire any improper advantage.
Suppliers should endeavor to protect Redis’ assets (including data, systems, and equipment) to which Supplier has access and ensure their intended and authorized use. Any suspected incident of fraud or theft should be reported immediately to Redis Legal at legal@redis.com for investigation.
In doing business with Redis, Suppliers may learn confidential or proprietary information about Redis, its customers, employees or other Suppliers. Confidential or proprietary information of Redis, and of other companies, includes any nonpublic information that would be harmful to the relevant company or useful to competitors if disclosed. Confidential information includes, but is not limited to, Redis’ business and marketing plans, intellectual property, trade secrets, business processes, information relating to Redis’ prospects and customers, and product pricing information.
Supplier must (1) maintain the confidentiality of information about Redis and other companies entrusted to Supplier by Redis; (2) use such information only for authorized business purposes and in accordance with any restrictions imposed by the disclosing party; and (3) limit dissemination of the confidential information to individuals who need to know the information for business purposes. Any such individuals must be bound by similar obligations of confidentiality, unless disclosure is authorized or legally mandated.
Redis has a history of succeeding through honest business competition. Redis does not seek competitive advantages through unlawful or unethical business practices. Supplier should similarly endeavor to deal fairly with its customers, service providers, business partners and competitors. Suppliers should not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation of material facts or any other unfair dealing practice.
Suppliers must avoid situations or relationships that may give rise to an actual, apparent or potential conflict of interest, especially as it relates to Supplier’s activities with or on behalf of Redis. Suppliers must disclose actual, apparent or potential conflicts of interest to Redis Legal at legal@redis.com. Raising an issue right away will allow Redis to assess the situation and address it appropriately.
Redis strives to comply with all laws and governmental regulations that are applicable to its activities, and likewise expects all Suppliers to respect and obey all applicable laws and regulations when doing business with Redis or otherwise carrying out responsibilities on behalf of Redis.
Suppliers have an obligation to be knowledgeable about specific laws, rules, and regulations that apply to Supplier. If a law conflicts with this Policy, Supplier must comply with the law. If a conflict of law arises, Redis requests the Supplier provide written notice of the potential conflict to Redis Legal at legal@redis.com.
The following is a summary of certain topics about which Supplier should be aware:
Redis is dedicated to compliance with laws governing fair competition, including antitrust laws, in all of its activities. Competition laws and regulations throughout the world are designed to foster a competitive marketplace and prohibit anti-competitive conduct or activities that restrain trade. Supplier must not take actions in combination with other companies that restrain competition in violation of applicable laws. Certain antitrust violations involving agreements with other Suppliers or competitors are criminal and can result in large fines and prison terms for the individuals involved. In addition, actions taken by an individual company in market segments in which it has a particularly strong position may violate antitrust laws if the actions have the effect of excluding competition through unfair means.
Redis is firmly committed to providing a healthy and safe work environment in which all individuals are treated with respect and dignity, without regard to race, religion, skin color, sex, pregnancy, national origin, age, physical or mental disability, military or covered-veteran status, marital status, sexual orientation, family medical leave, gender identity or any other classification protected by applicable law. Every individual has the right to work in a professional atmosphere that is free of violence and bullying, that promotes equal employment opportunities and where discriminatory practices, including harassment, are prohibited. Redis requires Suppliers to promote policies and practices that prohibit violence, bullying, discrimination, and harassment consistent with this Policy and applicable local law. Redis also requires Suppliers to ensure that their workers have an effective and accessible system to report grievances, including ones that comply with applicable law. The mechanism should encourage workers to openly bring concerns to management and where appropriate, facilitate open communication between the management team and workers.
Suppliers are required to provide workers with a safe and healthy environment that conforms to all applicable health and safety laws and regulations. Suppliers should implement health and safety measures to minimize potential safety hazards. Workers shall not be disciplined for raising safety concerns. Suppliers will comply with all applicable quality, health, and safety regulations. All required insurance, permits, licenses and registrations must be obtained, maintained, and kept up-to date. Suppliers must comply with all laws that apply to its relationship with its workers, including, but not limited to, laws that govern the terms and condition of respective employment relationships.
The use of child labor shall not be used under any circumstances. No person under the age of 15 (or under 14 according to the applicable local laws) may be employed by Redis or our Suppliers. Procedures and documentation to verify that no workers are younger than the local legal age for completing compulsory education are required. Workers under the age of 18 may not perform work that is likely to jeopardize their health or safety. All parties must comply with applicable labor and employment laws, rules, and regulations.
We have zero tolerance to slavery and human trafficking. We expect all those in our supply chain, our partners, employees and contractors share our values. Suppliers and employees must uphold the human rights of workers, and to treat them with dignity and respect as understood by the local, national, and international principles, including, but not limited to the Tracking Victims Protection Act and the UK Modern Slavery Act of 2015. Redis prohibits engaging in human trafficking, slavery, servitude, forced or compulsory labor, forced child labor and all other trafficking-related activities. Forced, bonded, or indentured labor or involuntary prison labor shall not be used under any circumstances. All workers will be voluntary, and workers should be free to leave upon reasonable notice. Workers must be compensated in a timely manner at pay rates that comply with applicable wage laws, including minimum wages and overtime.
As part of Redis’ commitment to human rights, we look internally as well as externally for ways to address this concern. Internally, we provide annual training to employees on this important topic and have in place systems to encourage the reporting of concerns and the protection of reporters and whistle blowers. Externally, we are building long-standing relationships with suppliers and service providers and make clear our expectations of business behavior in this regard. With regards to national or international supply chain, our point contact is preferably with a local company or branch and we expect these entities to have suitable anti-slavery and human trafficking policies and processes.
Redis is committed to minimizing the impact of its activities on the environment and we ask our Suppliers to do the same. Waste of all types should be eliminated at the source or reduced by practices such as modifying production, maintenance, and facility processes, using materials substitution, conservation, recycling, and re-using materials. All required environmental registrations and permits are to be obtained and maintained. Supplier will manage and dispose of all materials in an environmentally responsible manner that is protective of human health and the environment, in accordance with applicable laws, rules, and regulations.
Supplier may only transact business on behalf of Redis in foreign markets and with foreign government officials in accordance with Redis’ established policies regarding foreign corrupt practices and/or any applicable law, including but not limited to the United States Foreign Corrupt Practices Act (the “FCPA”), the United Kingdom Bribery Act of 2010, the United States Travel Act, Title 18 of the United States Code section 201 and all local anti-bribery, anti-corruption, or anti-money laundering laws that may be applicable. Supplier must never engage in any bribery, kickbacks, or other types of corruption, including, but not limited to, when dealing with customers or other third parties regardless of local laws, practices, or competitive intensity. Specifically, Supplier must never directly or indirectly via a third party make or provide a payment (including cash or any other items of value such as meals, gifts, travel, entertainment, etc.) to a foreign official or government employee to corruptly influence the foreign official or government employee, to obtain or retain business for Redis or to acquire any improper advantage.
If Supplier will be representing or acting on Redis’ behalf, then Supplier also must comply with Redis’ Global Anti-Corruption Policy, a copy of which is available by contacting Redis Legal at legal@redis.com.
Export control laws govern the export of commodities, technical data, and written or oral disclosures of technical data from the United States, as well as trade with and the provision of services to, certain individuals, entities, and nations. Redis requires Suppliers to comply with these laws to the extent applicable.
Under federal and state securities laws, it is illegal to trade in the securities of a company while in possession of material nonpublic information about that company. Because Supplier may come across knowledge of specific confidential information that is not disclosed outside Redis which will constitute material nonpublic information, trading in Redis securities could constitute insider trading and could violate the law, as could giving material nonpublic information to others who trade on that information. It is Supplier’s responsibility to comply with these laws, the Redis Insider Trading Policy, and not to share material nonpublic information or trade in Redis stock if in possession of material nonpublic information.
Suppliers shall audit their compliance with this Policy and customer contractual requirements related to any other responsibility. Redis may also audit its Suppliers for compliance to the Policy or request written certification from Supplier (signed by an officer of the Supplier) of its compliance with this Policy. Suppliers shall cooperate timely and fully with any such reasonable compliance audit or request for certification by Redis. Suppliers shall have a corrective and preventative action process in place to address non-compliances to the Policy. Suppliers shall also create and maintain documents and records to ensure regulatory compliance and conformity to the Policy and any other agreed Redis requirements.
Suppliers are encouraged to seek guidance from Redis when in doubt about whether a particular situation violates this Policy. In most instances, questions regarding this Policy should be brought to the attention of Redis Legal at legal@redis.com.
Suppliers are responsible for preventing and reporting violations of this Policy. If Supplier knows of or suspects a violation of this Policy, or of applicable laws and regulations (including complaints or concerns about accounting, internal accounting controls or auditing matters), Supplier should report it immediately to Redis Legal at legal@redis.com.
Reported violations will be promptly and thoroughly investigated by Redis Legal The person reporting the violation should not conduct an investigation on their own. Supplier is expected to cooperate fully with any appropriately authorized investigation into reported violations, and should not withhold, tamper with, or fail to communicate relevant information in connection with an appropriately authorized investigation.
Violations of this Policy or applicable law may result in termination of Supplier’s relationship and agreement with Redis. Redis may also report violations of law to the appropriate law enforcement authorities.
Nothing contained in this Policy or any other Redis agreement or policy is intended to prohibit or restrict Supplier from disclosing confidential information to any government, regulatory or self-regulatory agency, including under Section 21F of the Securities and Exchange Act of 1934, as amended, and the rules thereunder.
