At HERE we hold ourselves to the highest ethical standards and our customers, employees, and the communities in which we operate expect HERE to be a lawful, reliable, and ethical business.
HERE expects the same from all its Suppliers. HERE Suppliers must abide by this Code of Conduct.
HERE expects all Suppliers to meet or exceed all applicable laws and regulations that are in force in the countries where HERE and the Supplier operate. We encourage Suppliers to go beyond legal compliance by committing to meet relevant international standards and to continuous improvement.
This Supplier Code of Conduct is designed to help you understand HERE’s business values and your responsibilities. You should read it carefully and, in its entirety, share it with all personnel who will be working with or supporting HERE.
The standards set forth in this Supplier Code of Conduct are intended to guide you as you fulfill your role as a HERE Supplier. They are not intended to change or replace any specific contractual or legal requirements placed on the Supplier. Rather, this Supplier Code of Conduct establishes the basic principles for business conduct which HERE expects from Suppliers. If Suppliers are subject to stricter or more detailed requirements than this Supplier Code of Conduct, under contract or applicable law, then we expect Suppliers to meet those more stringent requirements.
This Supplier Code of Conduct has been created based on the principles set forth in internationally recognized standards and applicable laws.
This Supplier Code of Conduct applies to all Suppliers (vendors) of HERE, regardless of the product or service they provide to HERE.
HERE | HERE means HERE International B.V. and all the direct and indirect subsidiaries of HERE International B.V. in which HERE International B.V. owns a majority of the shares or exercises effective control. |
Local Law | Local Law means any applicable local laws, rules, or regulations and/or any applicable collective agreements, works council agreements and agreements related thereto. |
Supplier | Supplier means any third-party that provides services or goods to HERE. |
ESG | Responsible investing is widely understood as the integration of environmental, social and governance (ESG) factors into investment processes and decision-making. |
This Supplier Code of Conduct includes requirements in the following areas:
Ethics
Human rights and working conditions
Health and Safety
Environment
Compliance Management Systems
HERE Suppliers shall conduct their business in accordance with the highest ethical standards and all applicable laws and require the same compliance throughout their entire supply chain.
While conducting business with HERE customers, or otherwise for, on behalf of or in connection with HERE’s business, Suppliers will conduct all activities in accordance with applicable law, with integrity, fairness, respect and in an ethical manner. All business dealings shall be transparently performed and accurately reflected within their records.
HERE expects and requires that Suppliers, in connection with HERE’s business, design, implement and maintain at all times a compliance program, policies, procedures and a system of internal controls, sufficient to ensure compliance with all laws applicable to Suppliers and the standards required by this Supplier Code of Conduct.
All Supplier staff interacting with HERE or undertaking any activity for or on behalf of HERE, must be adequately trained on such compliance program and HERE’s Supplier Code of Conduct. Implementing such formal policies and procedures related to business conduct and compliance helps drive business ethically, honestly, and in full compliance with all laws and regulations.
HERE Suppliers shall not engage in corruption, extortion, embezzlement or money laundering in any form, offer, give, receive, or solicit any bribes or employ other means to obtain any improper benefit or advantage in the conduct of their business. HERE Suppliers shall not allow others to make improper payments for their benefit.
HERE Suppliers must comply with all applicable anti-corruption, anti-bribery and anti-money laundering laws and regulations, including the U.S. Foreign Corrupt Practices Act, the UK Anti-Bribery Act, as well as laws governing lobbying, gifts, donations, hiring, and payments to government officials, political campaign contribution laws, and other related regulations.
All countries in which HERE conducts business prohibit bribery. Typically, these laws prohibit providing, or promising to provide, any money or anything of value to a government official, in order to obtain or retain business, or to secure any improper advantage. In some countries this prohibition extends to the commercial context as well (i.e., bribery of employees of private companies). These prohibitions apply whether such action is taken directly, by HERE’s employees or through third parties, such as agents, consultants and intermediaries. It is also illegal and against HERE policy for Suppliers to solicit or accept any payment or anything else of value in return for improperly performing a function of their employment with a Supplier or a duty to HERE. Violation of these laws is a crime that can result in severe fines and criminal penalties. Accordingly, Suppliers must not offer, give, solicit, or receive any form of bribe or kickback anywhere in the world.
It is a violation of this Supplier Code of Conduct (and may be a breach of law) for Suppliers to offer or make a payment or gift of any kind in order to facilitate a local process or to influence a local government official, however small the payment or routine the government function involved.
Additionally, no Supplier may bribe or provide kickbacks or any other improper payments or improper gifts to any director, employee, representative or agent of HERE, or seek any such bribe or kickback from HERE or any other party.
HERE Suppliers must immediately report to HERE any circumstance where an officer, director, employee, representative or agent of HERE has made any improper request or demand of a Supplier.
HERE Suppliers’ accounting records must (1) be kept and presented according to all applicable laws and regulations, (2) in reasonable detail, accurately and fairly reflect transactions, assets, liabilities, revenues, and expenses, and (3) not contain any false or misleading entries. HERE Suppliers must also have robust processes to prevent and promptly identify fraud.
HERE expects that HERE Suppliers shall disclose information truthfully and as they pertain to their business activities, structure, financial situation, and performance in accordance with applicable laws, regulations, and prevailing industry practices.
HERE Suppliers shall always respect intellectual property rights. Any transfer of technology and know-how shall be carried out in a manner that protects intellectual property rights.
HERE Suppliers shall comply with all applicable laws and regulations relating to intellectual property and will not violate, misappropriate or infringe upon the intellectual property rights of any person or entity, including intellectual property belonging to HERE, its customers or other business partners.
HERE Suppliers will only use information technology and software that has been legitimately acquired and licensed. HERE Suppliers will only use lawful methods of gathering competitive intelligence about products that compete with HERE’s technologies.
Counterfeit parts are items that are not as represented with the intention to deceive its buyers or users. HERE Suppliers should prevent such parts from being used in the supply chain.
To do so, HERE Suppliers should:
Use all appropriate ways to reduce the risk of counterfeit parts being delivered to HERE.
Notify HERE in writing as soon as HERE Suppliers have come to know or been informed that these counterfeit parts had been delivered to HERE.
From time to time, HERE Suppliers may have access to HERE confidential information and/or personal data that belongs to HERE employees, customers, consumers, developers, and others. HERE Suppliers shall recognize that information and take appropriate actions to protect it from misuse and unauthorized disclosure.
HERE Suppliers who obtain material, nonpublic information about public companies, including HERE's customers, as a result of their relationship with HERE, are prohibited by law and HERE policy from buying, selling, or holding stock or any other security based on that information. HERE Suppliers shall not communicate such information to others who might trade based on that information.
HERE Suppliers should report any event of potential unauthorized disclosure promptly to HERE. If you have questions, contact your HERE representative for help.
HERE expects that HERE Suppliers comply with privacy and information security laws and regulatory requirements, where applicable, when processing, collecting, storing, transmitting, or sharing personal data related to customers, suppliers, consumers, and employees. HERE Suppliers shall commit to protecting the reasonable privacy expectations of personal information of everyone you do business with.
HERE Suppliers must understand and comply with all applicable fair business, advertising and competition laws including fair trading and antitrust laws.
HERE's policy is to compete vigorously and ethically while complying with all antitrust and competition laws. Antitrust and competition laws are designed to protect consumers and competitors against unfair business practices and to promote and preserve competition. These laws, among other things, prohibit or restrict activities related to fixing, coordinating, or controlling prices and allocating or dividing customers, territories or markets. As a result, Suppliers should take care in any communications with competitors about any aspect of HERE’s business (e.g., at industry events, trade associations, etc.).
HERE Suppliers must be committed to dealing honestly, ethically, respectfully, and fairly with each other and our competitors, customers, and other Suppliers. HERE expects behavior consistent with this core principle. Suppliers must not make false, misleading, deceptive, or fraudulent statements regarding HERE’s products and services to anyone else. Suppliers must not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation, or any other unfair dealing practice.
HERE Suppliers shall avoid conflicts between them and HERE by ensuring that they disclose any personal or outside business arrangements between their employees and themselves and any HERE employees or their families.
HERE Suppliers must immediately report to HERE in writing any "conflict of interest" they become aware of. A “conflict of interest” is any circumstance, transaction or relationship directly or indirectly involving a Supplier in which the private interest of any director, employee, representative or agent of HERE or the Supplier improperly interferes, or even appears to improperly interfere, with the interests of HERE, or with HERE employees’ or Suppliers' duties owed to HERE.
If HERE Suppliers manufacture components, parts, or products containing tin, tantalum, tungsten, or gold, HERE Suppliers must source those materials from environmentally and socially responsible sources only. Materials, which either directly or indirectly contribute to a conflict, are unacceptable. Suppliers in this category must exercise due diligence regarding the source and chain of custody of these minerals and make any due diligence measures available to HERE upon request.
As a global business powering location-based services for organizations and people around the world, HERE is required to comply with U.S., E.U., Dutch and other countries trade sanctions, and export controls which restrict where and with whom it can do business, including even indirectly through partners. Sometimes these are inconsistent. It is therefore important for HERE to know where and by whom its services and solutions are being provided and accessed and where its raw materials and technology are sourced from.
HERE Suppliers shall comply with all applicable international laws, national laws, regulations, and other controls which govern the transfer, access, export, re-export, and import of products, services, and technology. HERE Suppliers must maintain, where applicable, robust compliance programs and policies to manage technologies, products, and technical data that is controlled or restricted by law.
HERE Suppliers will not provide controlled technologies, products, or technical data to HERE, without providing notice of such controls as necessary for HERE to maintain compliance with applicable laws.
HERE Suppliers should respect the rights to water and sanitation for people who could potentially be affected by their activities, including their employees, contractors and neighboring communities. HERE Suppliers should seek to avoid any impacts to land, forest or water in areas where they operate and, if not feasible, should adopt mitigation measures that remedy the impact. HERE Suppliers should avoid forced evictions or resettlement of any acquired land for their operating activities.
HERE Suppliers should promote animal welfare in case of procurement of animal derived materials and should comply with all applicable legislation (local as well as international).
HERE Suppliers shall comply with all laws and regulations that protect human rights of their workers (whether employees or external workers) and shall ensure that human resources are managed in accordance with internationally recognized principles of corporate responsibility. This will include but is not limited to:
HERE Suppliers must not use forced, bonded, compulsory, or imprisoned labor, or allow such practices in their supply chains. HERE Suppliers shall not force anyone into performing work and shall not be involved in any manner in human trafficking.
A “child” is any person who is younger than (i) 15 years old (or the legal minimum age for employment under applicable Local law); (ii) the minimum age for completing compulsory education in the country of employment; or (iii) the minimum age for employment in that country, whichever is the highest. Additionally, we expect HERE Suppliers to refrain from hiring anyone under the age of 18 to carry out work which is likely to jeopardize their health, safety, or morals.
HERE Suppliers shall ensure that their employees receive at least the minimum compensation, benefits and overtime payments required by law.
HERE Suppliers shall take all appropriate steps to ensure workweeks do not exceed the maximum working hours as defined by Local Laws or applicable collective agreements except in emergency or extraordinary situations with the consent of the employees.
HERE Suppliers shall treat all employees with respect and dignity, and ensure that they are protected from physical, sexual, verbal, or other forms of abuse, coercion, or harassment.
HERE Suppliers shall not discriminate in their employment or hiring practices. This includes discrimination based on race, color, age, gender, gender identity or expression, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership, marital status, or any status or characteristic which does not relate to any individual’s qualifications or the inherent requirements for a position.
HERE Suppliers should acknowledge that women’s rights are human rights. As stated in the United Nations’ 1948 Universal Declaration of Human Rights, all humans are “born free and equal in dignity and rights”. As such, HERE Suppliers should be committed to providing liberty, dignity, and equal rights to all their workers, regardless of gender.
HERE recognizes that certain groups of individuals may be particularly vulnerable to adverse impacts from discrimination, including indigenous people, national or ethnic, religious and linguistic minorities, children, LGBTQ+ people, people with disabilities, and migrant workers and their families. HERE is committed to respecting the rights of these individuals.
When HERE Suppliers work with public and/or private security entities to protect their facilities and their employees, HERE Suppliers will do so in a manner that supports and reinforces respect for human rights.
HERE Suppliers shall recognize their employees’ rights to join or refuse to join labor unions or associations and to bargain collectively as permitted by law.
HERE Suppliers shall provide their employees with a safe and healthy working environment in compliance with all applicable laws and regulations.
We expect HERE Suppliers to have effective safety programs covering such areas as: human safety, emergency preparedness, chemical, physical, and biological agent exposure, ergonomics, which includes incident reporting and investigation.
HERE Suppliers shall define a Health and Safety policy and implement a Health and Safety management system (EHS) with the aim of getting it certified against the appropriate health and safety management system standard such as ISO 45001 by an accredited third-party agency.
HERE Suppliers should minimize the negative impacts their business operations have on the community, environment, and natural resources throughout their supply chain.
HERE Suppliers shall adhere to all applicable laws, regulations and any additional environmental requirements agreed upon with HERE.
HERE Suppliers must obtain, maintain, and keep current all applicable environmental permits, approvals, and registrations. Suppliers shall abide by and follow relevant operational and reporting requirements.
HERE Suppliers shall ensure that they identify and quantify the environmental impact of their operations, products and/or services.
HERE Suppliers should endeavour to reduce their water consumption, as well as identify ways to minimize waste generation and promote reuse and recycling.
GHG (Green House Gas emissions/Decarbonization)
Where possible, HERE Suppliers shall investigate ways to improve energy efficiency including quantifying, disclosing, and reducing greenhouse gas emissions and shall incentivize their own suppliers to do the same.
Renewable energy
HERE Suppliers should endeavour to source energy from renewable sources i.e., energy from non-fossil sources.
Reduce air pollution
HERE Suppliers shall endeavour to minimize air pollution. HERE Suppliers shall characterize, monitor, control and treat as required prior to discharge air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations.
Soil quality
Where and when appropriate, HERE Suppliers shall identify, monitor, and control their impact on soil quality to prevent harmful soil changes.
Noise pollution
Where and when appropriate, HERE Suppliers shall identify, monitor, and control their noise pollution levels to reduce noise pollution as much as possible.
Biodiversity, land use and deforestation
Where and when applicable, HERE Suppliers should endeavour to limit the impact of their operations on biodiversity and ecosystems.
HERE Suppliers shall ensure that chemical and other materials - that pose a hazard if released to the environment - are identified and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.
HERE Suppliers shall treat wastewater and solid waste generated from operations and sanitation facilities according to legal requirements and good environmental practices.
HERE Suppliers shall define an Environmental policy and implement an Environmental management system (EMS) with the aim of getting it certified against the appropriate Environmental management system standard such as ISO 14001 by an accredited third-party agency.
When HERE Suppliers purchase any component or material or avail the services of a third-party, they shall ensure that their suppliers are taking care of social and environmental factors and integrating these factors within their procurement operations.
HERE Suppliers shall have adequate management systems in place, which are designed to ensure compliance with this Supplier Code of Conduct and applicable laws.
We encourage HERE Suppliers to make corporate, social, and environmental responsibility statements, endorsed by executive management. These shall affirm their commitment to the values and topics addressed in this Supplier Code of Conduct and to their continuous improvement.
HERE Suppliers shall identify who in their company is responsible for ensuring implementation of their management systems and associated programs.
HERE Suppliers shall ensure that they have adequate processes in place to identify, monitor and understand applicable laws, regulations, and HERE’s requirements, including the requirements of this Supplier Code of Conduct.
HERE Suppliers shall have adequate processes in place to identify risks (such as the environmental, health and safety, labor and human rights, ethics and legal compliance risks) associated with their operations and have appropriate procedures and controls to manage such risks and ensure regulatory compliance.
HERE Suppliers shall have sufficient processes in place to ensure that clear and accurate information about their policies, expectations, and performance, including the requirements in this Supplier Code of Conduct, is communicated to their employees, suppliers, and customers. In addition, HERE Suppliers shall have sufficient training programs in place to ensure proper implementation.
HERE Suppliers shall create an environment where employees are comfortable raising concerns. HERE Suppliers shall have adequate “whistle-blower” or reporting channels available and feedback processes in place designed to ensure confidentiality and protection for employees and suppliers, without fear of retaliation.
Neither Suppliers nor their employees, contractors, officers or directors shall discharge, demote, suspend, threaten, harass, or engage in any other manner of discrimination against anyone who, in good faith, reports a suspected violation.
HERE Suppliers shall periodically evaluate their conformity to the standards set forth in this Code of Conduct and maintain open discussions with HERE in order to maintain continuous improvement and correct any deficiencies in a timely fashion.
HERE Suppliers shall ensure that they and their suppliers have adequate process for the creation and maintenance of documents and records designed to ensure regulatory compliance and conformity to document along with appropriate confidentiality to protect privacy.
An important part of upholding this Supplier Code of Conduct is ensuring that Suppliers only do business with others that adhere to the same standards of ethics and compliance as HERE expects of its Suppliers.
Each HERE Supplier shall have a program in place to conduct due diligence, monitor and control their own business partners to help ensure that they all meet expectations consistent with those set out in this Supplier Code of Conduct.
HERE Suppliers may not engage in any activity prohibited by this Supplier Code of Conduct by knowingly employing – or failing to impose appropriate corrective action, up to and including termination, upon a subcontractor or supplier who performs the prohibited activity on behalf of such HERE Supplier. HERE Suppliers shall never engage a sub-supplier to undertake any activity that would be prohibited by this Supplier Code of Conduct or applicable law if undertaken by HERE Suppliers or their staff.
All HERE Suppliers shall abide by this Supplier Code of conduct. HERE Suppliers must also maintain all documentation necessary to demonstrate their compliance with this Supplier Code of Conduct and shall provide HERE access to such documentation upon request.
To identify whether a Supplier is in compliance with this Supplier Code of Conduct, HERE reserves the right to require any Supplier to complete self-assessments, disclose relevant policies or procedures, participate in and provide information to any ESG assessment/rating platform engaged by HERE or to be subject to announced and unannounced on-site direct and/or third-party audits or evaluations of the Supplier’s facilities, records and operations.
HERE Suppliers shall make such staff and documentation available to HERE or its representatives as may be requested in connection with such an audit.
Upon request by HERE, HERE Suppliers shall promptly provide to HERE any and all information or material required for HERE or its customers to comply with all applicable laws and regulations.
HERE Suppliers shall cooperate with HERE investigations related to potential violations of law, regulation, policy, contract, or this Supplier Code of Conduct.
Any violation of this Supplier Code of Conduct may result in corrective action. The appropriate action in a particular case depends on the nature and severity of the Code violation and the circumstances surrounding the situation.
Failure to comply with this Code and/or any additional requirements set forth by HERE, or any applicable laws and regulations may result in the termination of any agreement as a HERE Supplier and referral of the matter to local authorities.
If you have any questions regarding the Supplier Code of Conduct, please contact HERE’s Sustainable Sourcing program team via the following email address: sustainable.sourcing@here.com
HERE Suppliers must immediately notify HERE upon learning of any known or suspected (1) improper or illegal behavior by any employees or representatives of HERE, (2) improper or illegal behavior by the Supplier, any sub-supplier, or anyone else providing goods or services to HERE, including but not limited to breaches of this Supplier Code of Conduct.
HERE reserves the right to change, revise, or rescind this Supplier Code of Conduct and similar rules as the need or circumstances may so require without prior notice.
The final decision on any question regarding interpretation of the Supplier Code of Conduct rests with the management of HERE.
