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Qualtrics Supplier Code of Conduct

Revised October 31, 2022

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INTRODUCTION

Qualtrics’ Global Procurement Organization has a goal of integrating sustainability and integrity into Qualtrics’ core business. Our procurement policy and practices are based on high ethical standards. As we regard our supplier base as a critical and a necessary extension of our operations and success, we are committed to create a positive impact throughout our supply chain. This Supplier Code of Conduct (“Code”) is based on our commitment to the United Nations Global Compact, the Universal Declaration of Human Rights, and the International Labor Organization.

Qualtrics expects its contractors, consultants, suppliers, vendors and all other third-party companies that comprise Qualtrics’ supply chain (“Suppliers”) to follow, and conduct its business in accordance with the guidelines set forth in the framework of acceptable conduct .

All work performed for Qualtrics must be in full compliance with this Supplier Code of Conduct and all applicable laws, rules, regulations, and contracts. For suppliers who have employees contracted to work directly for Qualtrics, these guidelines must be reviewed by all employees and subcontractors working on Qualtrics matters.

We expect our employees and our Suppliers to conduct themselves in a safe and professional manner, to refrain from any action that may be considered a conflict of interest, and to treat others with respect, fairness, and dignity while working on behalf of Qualtrics. We regard our supplier base as a critical and necessary extension of our operations and future success, and we thank you for continuing to make compliance and integrity a top priority as you work with Qualtrics.

Failure to accept the Qualtrics Supplier Code of Conduct and to comply with it during the course of doing business with Qualtrics will lead to your disqualification as an accepted supplier and will eliminate you from consideration for the supply of new business to Qualtrics in the future.

You also commit to the obligation of reporting to Qualtrics any violation of this policy, as you become aware of it, by sending an email to compliance@qualtrics.com or by submitting an anonymous report on Qualtrics’ Ethics Hotline.

We expect our Suppliers to confirm and ensure that all subcontractors are equally compliant with our policies and the Qualtrics Supplier Code of Conduct. Qualtrics has the right to conduct risk-based due diligence on any supplier at any time, which may include requesting information about the supplier, requesting copies of its compliance policies and programs, security procedures, and gathering anti-bribery certifications. In addition, Qualtrics may request a Supplier conduct annual anti-bribery training or make their relevant personnel available for interviews.

Any change in Supplier’s ownership, senior management, corporate structure, business lines or model, key personnel, subcontractors or any other factor that might reasonably affect Qualtrics’ risk evaluation must be communicated promptly to the Qualtrics Procurement team by emailing procurement@qualtrics.com.

COMPLIANCE WITH LAWS, RULES, AND REGULATIONS

As a Supplier, you agree to abide by the terms of this Code and acknowledge that compliance with this Code is required to maintain your status as a Qualtrics Supplier. You agree that all business conducted on behalf of Qualtrics shall be accomplished in full compliance with applicable laws, rules, regulations, and policies. If local laws are less restrictive than the principles set forth in this Code, Suppliers are expected to, at a minimum, comply with the Code. If local laws are more restrictive than this Code, Suppliers are expected to, at a minimum, comply with applicable local laws.

Anti Corruption Laws
Suppliers shall not make, authorize, or offer any bribes, kickbacks, or payments of money or anything of value to anyone, including officials, employees, or representatives of any government, public or international organization, or to any other third party (public or private sector) for the purpose of obtaining or retaining business, or influencing any other favorable business decision, that is related in any way to Qualtrics. This includes giving money or anything of value to anyone when there is reason to believe that it will be passed on to a government official or the decision maker at a customer or potential customer company for this purpose. Suppliers are required to comply with all applicable local anti-bribery laws, including but not limited to the German Criminal Code, the U.S. Foreign Corrupt Practices Act and the UK Bribery Act.

Antitrust and Competition Laws
Antitrust and competition laws are designed to protect consumers and competitors against unfair business practices and promote and protect healthy competition. Qualtrics is committed to observing the applicable antitrust or competition laws of all nations or organizations, and Qualtrics expects its Suppliers to comply with all applicable antitrust or competition laws as well. Antitrust and competition laws vary from country to country, but generally such laws prohibit agreements or actions that unreasonably restrain trade, are deceptive or misleading, or unreasonably reduce competition without providing beneficial effects to consumers. Such agreements or actions are prohibited by this Code.

Securities and Insider Trading Laws
Suppliers are expected to comply with applicable insider-trading and securities laws governing transactions in the securities of Qualtrics. Securities include common stocks, bonds, options, futures, and other financial instruments. Suppliers that possess or have access to material, nonpublic information (“MNPI”) gained through their work with Qualtrics may not use MNPI to trade in Qualtrics securities or the securities of another company to which the information pertains. Suppliers’ employees may not engage in any other action to take advantage of, or pass on to others, MNPI gained through working with Qualtrics until a reasonable time after full public disclosure has occurred. These restrictions also apply to family members, friends, and associates. MNPI includes any information that a reasonable investor would consider important in a decision to buy, hold, or sell securities. Such information may include financial and key business data; merger, acquisition, or divestiture discussions; award or information related to the cancellation of a major contract; changes in key management; forecasts of unanticipated financial results; significant litigation; or gain or loss of a substantial customer or supplier.

Modern Slavery
Suppliers must comply with all applicable employment, labour and related laws (including those aimed at eradicating modern slavery) and to meet in full their obligations under such laws. In addition, at a minimum, Qualtrics expects Suppliers to take all reasonably practicable steps to ensure that participants in their supply chains do not engage in conduct amounting to modern slavery.

Qualtrics takes human rights violations extremely seriously. Any concerns that a violation of this policy or a violation of human rights has occurred may result in an investigation being conducted by Qualtrics, and may lead to the suspension and/or termination of the Supplier’s services to Qualtrics. Qualtrics shall not be liable for any such suspension or termination.

You can report violations of Modern Slavery or human rights to compliance@qualtrics.com or anonymously via Qualtrics Ethics Hotline.

Export Control & Trade Sanctions Compliance
Destination Restrictions:
Suppliers shall not provide Qualtrics with products or services that are manufactured in/provided from:
  • Crimea Region / Sevastopol
  • Cuba
  • Iran
  • North Korea
  • Russia
  • Syria
* Please note, this list is subject to change.

End-User Restrictions:
Supplier shall ensure that the provisioning of products and services to Qualtrics is not supported by entities and individuals with whom transactions are prohibited under applicable export control and sanctions laws, including those listed on any applicable sanctioned party lists (e.g., European Union Consolidated Sanctions List, U.S. Specially Designated National (SDN) lists, U.S. Denied Persons List, BIS Entity List, United Nations Security Council Sanctions).

Covered Telecommunications Equipment or Services
Supplier will not supply Qualtrics with any “covered Telecommunications equipment or services” as more specifically described in the United States Federal Acquisition Regulation clause 52.204-25, “Prohibition on Contracting for Certain Telecommunications and Video Surveillance Services of Equipment”.

Additional Security Protocols and Standards
We are raising the bar at Qualtrics by building security into all of our processes. We expect our suppliers to commit and uphold certain security standards as outlined below.

Qualtrics expects all suppliers to review and follow all Technical and Organizational Measures (TOMs) as outlined on our website. Additionally, Suppliers that play key roles in supporting internal processes, such as the Qualtrics platform, or access customer data, i.e. subprocessors, are required to undergo an independent evaluation by a recognized third-party audit firm, such as ISO 27001 or SOC 2 Type II.

If you have any questions about these requirements, please contact the Procurement team at procurement@qualtrics.com.

EMPLOYMENT/LABOR STANDARDS

Suppliers are committed to uphold the human rights of workers and to treat them with dignity and respect.

Freely Chosen Employment
Forced, bonded, or indentured labor or involuntary prison labor is prohibited. All work will be voluntary and workers should be free to leave upon giving reasonable notice and at their own will. Workers shall not be required to forfeit any documents related to travel or identification, including but not limited to government-issued identification, passports, or work permits, as a condition of employment.

Child Labor Avoidance
Child labor is prohibited in any and all stages of manufacturing or the delivery of goods or services. The term “child” refers to any person employed under the age of 15 (or 14 where the law of the country permits), under the age of completing compulsory education, or under the minimum age for employment in the country – whichever is the greatest. The use of legitimate workplace apprenticeship programs, which comply with all laws and regulations, is supported. Workers under the age of 18 should not perform hazardous work and must be restricted from night shifts, with consideration given to educational needs.

Working Hours
Supplier shall ensure that it complies with local laws relating to working hours and rest periods.

Wages and Benefits
Qualtrics expects its suppliers to adhere to minimum wage laws. All benefits required by local laws need to be provided. Payments need to be made regularly and directly to the workers. Deductions from or withholding of payments need to be in compliance with local laws only, and the workers need to have full understanding of the actions taken. The same goes for advances and loans. Workers must receive information about hours worked, rates of pay, and the calculation of legal deductions. Workers must retain full and complete control over their earnings. Wage deductions to keep workers tied to the employer or to their jobs are not permitted. Holding workers in debt bondage, forcing them to work in order to pay off a debt, and deception in wage commitments, payment, advances, and loans are prohibited.

Humane Treatment
There is to be no harsh or inhumane treatment, including any sexual harrassment, sexual abuse, corporal punishment, mental or physical coercion, or verbal abuse of workers; nor is there to be the threat of any such treatment.

Non-discrimination
Suppliers should be committed to a workforce free of harassment and unlawful discrimination. Companies shall not engage in discrimination based on culture, race, color, age, gender, gender identity or expression, sexual orientation, ethnicity, disability, pregnancy, religion, political affilitation, union membership, or marital status in hiring and employment practices, such as promotions, rewards, and access to training. In addition, workers or potential workers should not be subjected to medical tests that could be used in a discriminatory way.

Freedom of Association
Open communication and direct engagement between workers and management are the most effective ways to resolve workplace and compensation issues. Suppliers are to respect the rights of workers to associate freely, join or not join labor unions, seek representation, or join workers’ councils in accordance with local laws. Workers shall be able to communicate openly with management regarding working without fear of reprisal, intimidation, or harassment.

Contracts of Employment
All employees shall be provided with an employment contract in a language they understand, clearly indicating their rights and responsibilities with regard to wages, working hours, and other working and employment conditions . Any changes of the employment contract and the working conditions agreed upon must be in alignment with local laws.

Workplace Equality
Qualtrics expects that all workers, irrespective of their nationality, sex, gender identity, sexual orientation, age, religious beliefs, disabilities, legal status, or other relevant characteristics, are treated fairly and equally. No employee shall be threatened with denunciation to authorities to coerce them into taking up or or maintaining employment.

HEALTH AND SAFETY

Suppliers recognize that the quality of products and services, consistency of production, and workers’ morale are enhanced by a safe and healthy work environment. Suppliers also recognize that ongoing worker input and education are key to identifying and solving health and safety issues in the workplace.

Suppliers shall prevent worker exposure to potential safety hazards (for example, electrical and other energy sources, fire, vehicle, and fall hazards, and exposure to chemical, biological, and physical agents) and make sure they are controlled through proper design, engineering and administrative controls, preventive maintenance, and safe work procedures (including lockout-tagout). Where hazards cannot be adequately controlled by these means, workers are to be provided with appropriate personal protective equipment.

Workers shall not be disciplined for raising safety concerns. Suppliers identify and assess emergency situations and events, and minimize their impact by implementing emergency plans and response procedures, including emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, adequate exit facilities, and recovery plans.

Procedures and systems are to be in place to manage, track, and report occupational injury and illness, including provisions to encourage worker reporting, classify and record injury and illness cases, provide necessary medical treatment, investigate cases and implement corrective actions to eliminate their causes, and facilitate the return of workers to work.

Suppliers identify, evaluate, and control worker exposure to physically demanding tasks, including manual material handling and heavy lifting, prolonged standing, and highly repetitive or forceful assembly tasks. Physical guards, interlocks, and barriers are to be provided and properly maintained for machinery used by workers.

Suppliers provide workers with clean toilet facilities, access to potable water, and sanitary food preparation and storage facilities. Where provided, worker dormitories provided by the Supplier or a labor agent are to be clean, safe, and provide emergency egress, adequate heat and ventilation, and reasonable personal space.

DIVERSITY, EQUITY AND INCLUSION (DEI)

DEI is a cornerstone of Qualtrics’ company culture. We are taking action to improve DEI through our people, processes, and technology, and we expect the same from our supply chain. Suppliers are encouraged to provide an inclusive, healthy, bias-free work environment to their employees. Suppliers should, if applicable, strive to foster:
  • Gender intelligence by offering equal rights for men and women
  • Have practices and policies that do not condone or tolerate racism
  • Create safe environments that do not discriminate against LGBTQ+ employees
  • Cross-generational intelligence by having people of all ages and at every work and career stage
  • Culture and identity by empowering many voices to help gain strength from people’s differences
  • Opportunities for disabled people by focusing on their unique abilities and providing a work environment that considers the needs and skills of each employee
  • Empower small, diverse businesses and promote sustainability and diversity in supply chains
Accessibility
Suppliers are encouraged to deliver goods and services that are accessible to everyone, including those with disabilities. If accessibility standards – for example, Web Content Accessibility Guidelines (WCAG) 2.0 Level AA, included in US Section 508, and the harmonized EN 301 549 including WCAG 2.1 Level AA , and Germany’s Barrier-Free Information Technology regulation (BITV) – are applicable for the goods or services delivered, suppliers are strongly encouraged to take these standards into consideration and meet them.

PROTECTING THE ENVIRONMENT

Qualtrics is committed to protecting and respecting our environment. At a minimum, we expect our Suppliers to follow all applicable environmental laws, regulations, and standards. This includes requirements for chemical and waste management and disposal, recycling, industrial wastewater treatment and discharge, air emissions controls, environmental permits, certifications and environmental reporting. Suppliers should have their own environmental management system, including goals to reduce environmental impact, measures and controls (including audits), reporting, and training. Suppliers must comply with all requirements regarding conflict minerals, exercise proper due diligence, and provide evidence that they are in compliance.

MANAGEMENT SYSTEM

Suppliers shall adopt or establish a management system whose scope is related to the content of this Code. The management system shall be designed to ensure compliance with applicable laws, regulations, and customer requirements related to Supplier operations and products; conformance with this Code; and identification and mitigation of operational risks related to this Code. It should also facilitate continual improvement.

Suppliers commit to the statements on corporate social and environmental responsibility, affirming compliance and continual improvement. Suppliers hold clearly identified company representatives responsible for ensuring implementation and periodic review of the status of the management systems. Suppliers identify, monitor, and understand applicable laws, regulations, and customer requirements. Suppliers establish a process to identify the environmental, export control and trade sanctions, health, and safety and labor practice risks associated with Supplier operations.

Suppliers determine the relative significance for each risk and implementation of appropriate procedural and physical controls to ensure regulatory compliance to control the identified risks. Suppliers create and maintain written standards, performance objectives, targets, and implementation plans including a periodic assessment of Supplier performance against those objectives. Suppliers establish programs for training managers and workers to implement Supplier policies and procedures.

Suppliers establish and monitor ongoing processes to assess employees’ understanding of and obtain feedback on practices and conditions covered by this Code. Periodic self-evaluations shall be conducted by Suppliers to ensure conformity to legal and regulatory requirements, the content of the Code, and requirements related to social and environmental responsibility.

Suppliers establish a process for timely correction of deficiencies and creation of documents and records to ensure compliance and conformity, along with appropriate confidentiality to protect privacy.

RESPONSIBILITY FOR COMPANY RESOURCES

Suppliers are expected to safeguard Qualtrics resources, which include property, assets, intellectual property, company technology assets (network, phone, Internet, software applications, and e-mail systems), trade secrets, and other confidential, proprietary, or sensitive information while performing work for Qualtrics. Use of Qualtrics resources without proper approvals, or for anything other than to perform Qualtrics work activities, is strictly prohibited. Intellectual property rights of Qualtrics must be protected. Qualtrics confidential or sensitive information must be protected.

Suppliers may only possess such information if they need to do so to perform work activities. Suppliers should not use this information for gain or advantage and should never share this information without appropriate Qualtrics approval. All confidential or sensitive information obtained by a supplier must have documented authorization in place. Inappropriate use of Qualtrics Internet, e-mail, and facilities is strictly prohibited.

Suppliers are expected to safeguard confidential information by not reproducing copyrighted software, documentation, or other materials without permission and by not transferring, publishing, using, or disclosing it other than as necessary in the ordinary course of business or as directed or authorized. Suppliers should observe applicable data privacy standards.

Materials that contain confidential information or that are protected by privacy standards should be stored securely and should be shared only internally with those employees with a “need to know.” For example, Qualtrics confidential information may include, but is not limited to, software and other inventions or developments (regardless of the stage of development) developed or licensed by or for Qualtrics, marketing and sales plans, competitive analyses, product development plans, pricing, potential contracts or acquisitions, business and financial plans or forecasts, and prospect, customer, and employee information. However, the terms of any confidentiality provision in the agreement between the Supplier and Qualtrics will govern confidentiality terms between the parties.

Qualtrics retains the right to monitor its assets and work environments in compliance with applicable federal, state, and local law. We monitor to promote safety, prevent criminal activity, investigate alleged misconduct and security violations, manage information systems, and for other business reasons.

Additionally, if Suppliers, or any of their resources supporting Qualtrics, have been assigned Qualtrics-owned assets, such as laptops or monitors, it is required that all assets be returned within the designated time frame specified by Qualtrics. If there are any questions about the IT return process, please reach out to procurement.

BUSINESS CONDUCT

Qualtrics expects suppliers to compete fairly and ethically for all business opportunities. Suppliers’ employees involved in the sale or licensing of products and services and the negotiation of agreements and contracts to Qualtrics must ensure that all statements, communications, and representations to Qualtrics are accurate and truthful.

Financial Integrity
Accurate and reliable financial and business records are of critical importance in meeting Qualtrics financial, legal, and business obligations. Suppliers should not have any false or inaccurate entries in the accounting books or records related to Qualtrics for any reason. Suppliers’ business records must be retained in accordance with record retention policies and all applicable laws and regulations. Suppliers should not knowingly shift an expense to a different accounting period.

Conflicts of Interest
The term “conflict of interest” describes any circumstance that affects or appears to affect a Suppliers’ ability to act with total objectivity with regard to the supply of products and services to Qualtrics and other customers, and/or when there is a choice between acting in a personal interest (financial or otherwise) or in the interest of Qualtrics. Qualtrics wants its Suppliers’ services to be free from any conflicting interests.

While engaged in Qualtrics-related work, Supplier must exercise reasonable care and diligence to avoid any actions or situations that could result in a conflict of interest or the appearance thereof. This includes not accepting other outside activity that creates a conflict of interest with Qualtrics or in any way compromises the work Supplier is to perform for Qualtrics.

Suppliers shall not encourage or influence current or former Qualtrics employees in any manner which would cause them to disclose or provide any confidential, proprietary, or other restricted information obtained while employed or engaged by Qualtrics so as to influence Qualtrics existing or proposed commercial transactions for the purpose of gaining a commercial advantage.

In order to avoid any conflict of interest or appearance thereof, if a Qualtrics employee leaves Qualtrics and thereafter is engaged by a Supplier, Qualtrics may in its’ sole discretion decide whether current or former Qualtrics employees who are engaged by a Supplier, may (i) act on behalf of the Supplier in discussions or negotiations with Qualtrics, or (ii) be part of the service delivered by the Supplier to Qualtrics. Suppliers are expected to cooperate with Qualtrics investigations and to provide reasonable assistance as requested.

Qualtrics expects suppliers to prevent or immediately disclose in writing a conflict of interest or the appearance of a conflict of interest as soon as possible to the Qualtrics Compliance team (compliance@qualtrics.com). Qualtrics may require, and Supplier shall comply, with any instruction to the supplier to correct any actual or perceived conflict of interest at any time during the agreement.

Offering and Accepting Business Courtesies
Suppliers should use discretion and care to ensure that any expenditure offered to or received by any Qualtrics employee is in the ordinary and proper course of business could not reasonably be construed as a bribe or improper inducement. Business courtesies cannot be designed or appear to be designed to influence the recipient and secure unfair preferential treatment.

A general guideline for evaluating whether a business courtesy is appropriate is whether public disclosure would be embarrassing to the Supplier or Qualtrics. Employees of the Supplier are permitted to offer and accept meals and other business entertainment from third parties in connection with Qualtrics business only when accepting such business courtesy:
  • Serves a bona fide business purpose
  • Does not inappropriately influence, or appear to influence, any business decision
  • Is not offered during any pending bidding or negotiation process
  • Is given openly and transparently
  • Is not unlawful or contrary to ethical business principles, local business customs, or the customer, vendor, competitor, or partner’s company policy
Generally, meals or business entertainment should not exceed $150 USD (or equivalent in local currency) per person.

Gifts in kind, payment, loan, vacation, or other privilege (collectively, a “Gift”) from current or prospective customers, vendors, competitors, or partners to Qualtrics employees and their relations, life companions, and other people with whom they have a close personal connection should not be given where:
  • The Gift is worth more than the financial threshold described in Qualtrics’ Code of Ethics and Business Conduct. This amount is currently $100 USD per person (or equivalent in local currency) , but is subject to change.;
  • Accepting the Gift would prejudice Qualtrics’ business interests; or
  • Accepting the Gift would create a payback obligation, or
  • The Gift is given during negotiation or bidding, directly or indirectly by a party to that negotiation or bidding, or
  • Accepting the Gift would allow an impression of unjust advantage to arise, or
  • The Gift is unlawful or contrary to ethical principles, or
  • The Gift is associated with earlier gifts.
This rule does not apply to promotional gifts of low value of a customary kind, such as branded ink pens, mugs or other small tokens.

Discounts and other privileges offered to an employee of Qualtrics as part of private transactions with customers, vendors, competitors, and partners of Qualtrics may only be accepted if these are granted to all Qualtrics employees in that region.

REPORTING CONCERNS

The standards of conduct described in these guidelines are critical to the ongoing success of Qualtrics’ relationship with its Suppliers. If you have questions or concerns about compliance or ethics issues while working for Qualtrics or want to report illegal or unethical activities:
  • Leave a message on the Ethics HelpLine at (800) 461-9330 . (Additional international numbers can be located on the Ethics HelpLine webpage at ethics.qualtrics.com).
  • Report an incident or concerns on our Ethics HelpLine webpage at ethics.qualtrics.com. These reports can be fully anonymous if you chose so.
  • Send an email to compliance@qualtrics.com Your message will be routed to the appropriate team member for assistance or guidance as necessary.
All matters raised in good faith through these reporting lines will be handled on a confidential non-retaliatory basis. All information will be maintained as confidentially as practical, taking into account the need for Qualtrics to conduct an investigation and implement remedial measures. Anonymity will be granted upon request by the reporting person.