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Supplier Code of Conduct

“Operating with Integrity and Transparency” is the cornerstone of our business. We partner with suppliers who embody the same values and are committed to operating lawfully, ethically, transparently, and responsibly. This Supplier Code of Conduct sets out Black Swan’s expectations for our suppliers’ business conduct when working with Black Swan.

This Supplier Code of Conduct applies to the suppliers of Black Swan Data Ltd and its subsidiaries and controlled affiliates (Black Swan or we) located anywhere in the world. A “supplier” (or you) is a third party that provides any kind of goods or services to Black Swan in exchange for value. We expect each supplier to communicate the content of this Supplier Code of Conduct to its employees, agents, subcontractors, and other representatives working with or for Black Swan. Failure to meet the expectations in this Supplier Code of Conduct may adversely impact current and future work with Black Swan.

Operate honestly. Act ethically. Follow the law. Be transparent.

  • Compliance with applicable law

At Black Swan, we respect applicable law, including local laws and regulations that apply to our business. Our suppliers must comply with applicable law and our contractual terms. If adhering to this Supplier Code of Conduct would violate any local law, we expect you to comply with that law.

  • Conflicts of Interest

We all work hard to drive Black Swan’s success. In the interest of transparency, promptly disclose to Black Swan any activity, transaction, or relationship that may create an actual, potential, or perceived conflict of interest with Black Swan. Examples of situations that could present a conflict (even if none exists today) that you should tell Black Swan about include:

    • A member of your staff doing work for Black Swan has a close personal relationship with a Black Swan staff member, and your work with Black Swan involves working with that Black Swan staff member.
    • You are partly owned or controlled by the government.
    • You are a public international organization.
    • You are a political party.
    • A member of your staff doing work for Black Swan is a government official — in other words, your staff member works for or on behalf of any government at any level or for any branch of government.
    • A member of your staff doing work for Black Swan is a political candidate.

Promptly send a disclosure to describing the situation. Black Swan’s Business Conduct team will review your disclosure and let you know whether any action is needed. If you have any questions, please reach out to

  • Antitrust and competition

We support vibrant competition within our own business and within the business of our partners and suppliers. We expect our suppliers to understand and respect antitrust and competition laws. Never make a deal on behalf of Black Swan with a Black Swan competitor on how we will compete, such as by allocating markets, fixing prices, promising not to hire certain candidates, agreeing not to pursue certain advertisers, verticals or audiences, or other concerted action.

  • Preventing bribery and corruption

As a global company, we respect and adhere to anti-corruption laws around the world, including the UK Bribery Act and the US Foreign Corrupt Practices Act. We honor both the letter and spirit of these laws and our suppliers and other agents must do the same. Suppliers must not offer, give, or authorize the payment of anything of value on behalf of Black Swan to secure an improper advantage or otherwise improperly influence the decisions of others. You must not solicit or accept a bribe or kickback in any form. Black Swan also expects its suppliers to maintain accurate and complete books and records, and have in place any necessary policies or procedures to prevent violations of the applicable anti-bribery laws. It’s important that your staff, subcontractors, and agents understand these obligations.

  • Gifts and political participation

To protect the integrity of Black Swan’s business processes, to support our business relationships, to avoid conflicts of interest, and to help us comply with anti-bribery laws, Black Swan has clear procedures for gift giving and receiving. If you want to give a gift to a Black Swan team member, please ask the recipient first to make sure it aligns with our policies. Suppliers may not give a gift or donation on Black Swan’s behalf to any third party without prior written approval from Black Swan Legal.

Black Swan is committed to undertake any lobbying activities in compliance with all applicable laws and to behave ethically in our interactions with governments, agencies, and their representatives. We expect our suppliers to ensure that their own lobbying activities also are performed with the same high ethical standards and in compliance with applicable law. Suppliers may not engage in lobbying or make political contributions on Black Swan’s behalf without advance written authorization from Black Swan Legal to do so.

  • Trade restrictions

Black Swan is committed to complying with applicable international trade restrictions, including any applicable UK, US, and EU sanctions programs. Trade restrictions include economic sanctions, embargoes, export and import controls, and anti-boycott rules. These laws limit our ability to do business with or provide our services, products, and technologies to certain individuals, entities, or governments. Black Swan requires its suppliers to abide by applicable laws and not to cause Black Swan to violate any relevant trade restrictions. A supplier working with Black Swan must follow applicable UK, US, and EU sanctions and trade restrictions in the conduct of its business with Black Swan, even if the supplier is not otherwise subject to those requirements.

Protect the assets of Black Swan and its customers, licensors, and partners

  • Confidentiality

Information is valuable, and we need to be careful with Black Swan’s confidential information, as well as the confidential information of our customers, licensors, and partners, that you may have access to in connection with your work for Black Swan. Confidential information is any information that people outside of Black Swan don’t generally know about or have access to, as well as any information that third parties give to Black Swan in confidence. Our suppliers must abide by the terms of any confidentiality agreement that applies to the confidential information or to you. If you’re not sure whether something is confidential, ask Black Swan Legal for help (

  • Insider trading

Don’t trade stock or other securities of Black Swan or its customers on the basis of material, non-public information, including confidential information, and don’t pass on such information to other people so they can trade. Material, non-public information is any information that has not been disclosed to the public and that a reasonable investor might use to buy, sell or hold stock in a company. All information about Black Swan and its customers, including information about its performance and its business plans and strategies, is potentially material, non-public information.

  • Protecting sensitive data

If you have access to any personal data as part of your work for Black Swan, whether of employees of Black Swan or its customers or otherwise, we expect you and your staff to access and use such data only in connection with a legitimate Black Swan business purpose, in accordance with your contract with Black Swan and applicable law. Further, we expect you to maintain robust security and data privacy practices to ensure they align to industry best practices and applicable legal requirements, and operate in a safe and secure manner.

  • Intellectual property

We expect you to protect intellectual property rights, safeguard trade secrets and inventions, and comply with all of the requirements in your agreements with Black Swan. This includes the intellectual property rights of our customers, licensors, and partners. You may not use our logo or brand name (including on your website or marketing materials) without written authorization from Black Swan Legal.

  • Speaking for Black Swan

Unless specifically authorized in your agreement with Black Swan, you may not speak publicly on Black Swan’s behalf.

  • Workplace safety, security and privacy

Black Swan is committed to providing a clean, safe, and violence-free workplace, and expects its suppliers to do the same. We strive to protect the natural world and expect suppliers to comply with all applicable environmental, health, and safety laws. We don’t tolerate threats, hostility, disrespectful conduct, or aggressive acts in our workplace, and weapons are not permitted on any Black Swan premises. Alert the Black Swan Legal immediately to report any concerns about unsafe conditions.

To protect the company, enforce our policies, or comply with law, Black Swan may view, search, and save relevant information and communications on company-owned devices and personal devices in accordance with our device management policies. Black Swan may also perform physical searches, use video surveillance, and control or restrict access of Black Swan premises as permitted by law. We expect you to adhere to Black Swan’s security requirements, in accordance with applicable law.

Be a good employer

  • Human rights

Black Swan is committed to respecting human rights, including the principles recognized in international human rights standards like the International Bill of Human Rights (consisting of the Universal Declaration of Human Rights, the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights) and the UN Guiding Principles on Business and Human Rights. Our suppliers should share the same goals and must comply with all applicable legal requirements related to human rights. When local laws are in conflict with internationally recognized human rights standards, you should comply with the law while promoting the principles set forth in this Supplier Code of Conduct.

Modern forms of slavery and human trafficking have no place in Black Swan’s supply chains or our business and Black Swan has no tolerance for the use of forced, compulsory, or child labor. Our suppliers must comply with all applicable laws related to human trafficking and the prevention of modern forms of slavery, including the UK Modern Slavery Act 2015, and suppliers must comply with applicable wage and hour labor laws and regulations, and should ensure appropriate work hours, fair wages, and working conditions in line with the standards set out in the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work.

  • Harassment, discrimination, and equal employment opportunity

We want to have the best qualified people working for Black Swan. Black Swan is an equal opportunity employer and makes employment decisions on the basis of merit. In addition, Black Swan is committed to providing a diverse work environment that is free of discrimination, harassment, mistreatment, and retaliation. We prohibit unlawful discrimination, harassment, and retaliation in employment, as set out in our internal policies, and expect our suppliers to maintain equivalent work environment and standards for their own workforces.

  • Diversity and inclusion

Having a diverse and inclusive team is critical to Black Swan’s ability to offer its services. We expect our suppliers to value the individual backgrounds, experiences, differences, and capabilities of its workers. In selecting suppliers, we favor suppliers that embrace inclusive principles and reflect diverse backgrounds. We won’t partner with anyone whose practices or company policies discriminate on the basis of a person’s social background, race, caste, religious creed (or lack thereof), color, national origin, ancestry, physical or mental disability, medical condition, genetic information, marital status, sex, gender, gender identity, gender expression, age, sexual orientation, military or veteran status, or any other category protected by applicable law. Whenever possible we seek out partners who go above and beyond the law in addressing underrepresentation and biases that impact marginalized and underrepresented communities.

  • Reporting

It’s important that any suspected non-compliance with this Supplier Code of Conduct—and any other suspected unethical behavior, violations of company policy, or illegal conduct—be reported to Black Swan. Black Swan takes reports seriously.

Specifically, a supplier must notify us if it or any of its owners, officers, or directors:

    • has been investigated for, convicted of, or has pleaded guilty to an offense involving fraud, corruption, or moral turpitude;
    • has been charged with or convicted of any offence involving export controls, bribery, corruption, or slavery or human trafficking;
    • has been debarred, suspended, proposed for suspension or debarment, or otherwise is ineligible for government procurement programs;
    • has knowledge of any ongoing or impending investigation involving the supplier, or any of its owners, officers, or directors, relating to export control, anti-corruption, anti-bribery, or anti-slavery and human trafficking laws; or
    • acts that could give rise to claims of violation by the supplier, or any of its owners, officers, or directors, of any export control, anti-corruption, anti-bribery, or anti-slavery and human trafficking laws.

We will investigate all credible concerns raised, and expect you and your staff to cooperate with the investigation. We try to keep investigations confidential to the extent possible and in accordance with law. Reports can be made:
To Black Swan Legal at
Snail mail (option to remain anonymous) to
Black Swan Data Ltd
Attn: Legal
15th Floor, WeWork Building, 10 York Rd
London SE1 7ND

Compliance with this Code

Failure to meet the expectations in this Supplier Code of Conduct may adversely impact your current or future business with Black Swan. If this Code conflicts with your written agreement with Black Swan, that agreement controls with respect to the inconsistency.

Black Swan will update this Supplier Code of Conduct from time to time. The current version is available at

Version date: 1st December 2020

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