Living the Twilio Magic
Twilio Code of Conduct

A message
from our CEO

Twilions,
We are a company with a unique spirit that manifests in who
we are and how we work together. We go out of our way tohelp each other, we invest in each other’s success, we believein the power of human potential, and we do the right thing.
What we do at Twilio matters, and how we do it matters evenmore.
This Code of Conduct provides us with the resources andinformation we need to operate with high ethical standards
and live the Twilio Magic. Making the right decisions in ourwork protects our reputation and builds trust with ourcustomers, partners, and one another. Use the Code as a

The Code contains practical guidance for handling situations
where doing the right thing may not be immediately clear. If
you’re ever unsure, there are plenty of resources available tohelp you. Reach out to your manager, the Ethics & Complianceteam, Employee Relations, your HR Business Partner, anETeam member or the Ethics Helpline.
Building an impactful, high-growth company while operatingin line with our core values is critical to our success. By living
the Twilio Magic, we embrace the role that each of us plays indeveloping an open and inclusive culture. Our future successdepends on all of us following these principles and taking
them seriously.

guide in making decisions that will protect our company andThank you for following our Code and living the Twilio Magic infurther enhance our reputation.

all that you do.
Onward!
jeffiel2Living the Twilio Magic

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We communicate appropriately			

We take ethical conduct seriously		5

Who does the Code apply to?			

5

18

We maintain accurate
business records						19How we use the Code					6Making good decisions					6Owning our responsibilities				6Reporting concerns						7Investigations							8Our Reputation
We build partnerships based on merit

21

We compete fairly and honestly			22

We do not tolerate bribery				23

We act responsibly with gifts
and entertainment						25Our Team
We embrace diversity, inclusion andequal opportunity						10We support and respect each other		

11

We avoid conflicts of interest			27

We do not trade on inside information30

We comply with international
trade laws								31We keep our workplaces, safe, secure,and healthy								12Our Stakeholders
Our Responsibilities
We protect confidential information		

14

We contribute to our communities		

33

We uphold human rights				34

We protect Company assets & use
them appropriately						16We safeguard data privacy				Resources

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Living the Twilio
Magic
We take ethical conduct seriously
Who does the Code apply to?
How we use the Code
Making good decisions
Owning our responsibilities
Reporting concerns
Investigations

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We take ethical conduct seriously

Twilio is a remote first company, and remote workers

We reflect Twilio’s unique spirit in who we are and how weare responsible for following the Code and all relevant

work together. Achieving our mission starts by applying our

employment, corporate and other applicable policies whilevalues to what we do every day. The purpose of Twilio’s Codeworking remotely, regardless of their work location.

of Conduct is to guide our decision-making in a thoughtful,
legal and ethical way. The success of our business relies

If any part of the Code conflicts with local laws or regulations,on the trust and confidence we build with our employees,

only the sections of this Code permitted by applicable laws

customers and business partners. We establish and maintainand regulations will apply. To the extent that they conflict withcredibility when we behave ethically.

this Code, any policies that are specifically applicable to yourWho does the Code apply to?
We expect all employees and Board members to read,understand, and comply with the Code and associatedpolicies. Failure to do so can result in disciplinary action, up
to and including termination of employment. Although theCode is written for our employees and board members, italso applies to our contingent workforce (including vendor
workers, consultants, and contractors) and suppliers inconnection with the services they provide for us. Failure of amember of our contingent workforce or other covered service

jurisdiction will take precedence.

Only Twilio’s Chief Legal Officer may grant a waiver under
this Code for Twilio employees other than executive officers
or senior financial officers. Any waiver or modification of thisCode for a member of the Board of Directors, executive officer,
or senior financial officer must be approved by the Board of
Directors and promptly disclosed, in each case as may berequired by applicable law or the rules of the stock exchange
on which Twilio’s common stock is listed for trading.

provider to follow the Code can result in termination of theirrelationship with Twilio.

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Making good decisions

Consider these key questions to help identify
situations that may be unethical, inappropriate, or
illegal. Ask yourself:
Click to reveal

Is it legal, honest, and ethical?

Our Responsibilities

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How we use the Codeuncertain about the right course of action. If you observe any

The Code contains our standards for ethical conduct at Twilio.

behavior that you believe violates our Code or any other Twilio

By embracing the Code, you commit to upholding the Twilio

policy, it’s your job to report it using one of our Company

Magic and operating in an ethical manner.

Resources. In the event of a suspected violation of law,

Acting in accordance with the Code, acting lawfully, honestly,and ethically, and completing required training are essential
for all Twilions. You are also expected to act responsibly andexercise common sense, regardless of whether a policy is inplace to prohibit specific behaviors.
To support Twilions in understanding the Code, we arededicated to providing ongoing training and education on its
key principles and guidelines. In situations where the rightcourse of action is not clear, our Company Resources areavailable to provide guidance and support whenever needed.

you have the option of raising the issue through the Ethics
Helpline or with a government agency. Through these actions,
we each do our part to embody the spirit of the Twilio Magic
and uphold our culture.

Managers have a special responsibility to uphold our values
and maintain our culture of integrity. They lead by example
by discussing the Code and ethical conduct with their teams,
emphasizing business integrity in all work and interactions.
As leaders, they listen with an open mind, treat all employees
fairly, and prevent retaliation against anyone who raises
a concern in good faith. Finally, they promptly report any

Owning our responsibilities

unresolved ethics or compliance concerns to the Ethics &What does it mean to meet the high standards we’ve set forCompliance team. Together, we foster a culture built on trust

ourselves? It starts with upholding our values, embracing theand ethical behavior.

Code, and complying with Company policies and applicablelaws and regulations. It also involves speaking up if weknow of or suspect a violation. Each of us is responsible forexercising sound judgment and asking for help when we are6Living the Twilio Magic

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Reporting concerns
As Twilions, we should feel comfortable speaking up, especially if wehave ethics-related concerns. By asking questions and raising concerns if

Q: If I make a report to the Ethics Helpline, is it confidential and kept anonymous?

something doesn’t seem right, we can actively contribute to preventing and

A: The Ethics Helpline is hosted and maintained by a third-party company All reports

detecting wrongdoing. It’s important for you to feel safe when speaking

will be handled promptly and discreetly. If you choose to remain anonymous, weup, and we strictly prohibit any form of retaliation against those who raise

will not make any effort to identify you. If you provide your name, confidentiality andquestions or concerns in good faith.

anonymity will be maintained to the greatest extent possible, consistent with and inaccordance with applicable law.

You can report concerns using any of our Company Resources, including the
Ethics Helpline at +1-844-637-6752 or www.twilio.ethicspoint.com. Details on
ethics reporting and our investigations process are contained in our Global
Speak-Up Policy.

Q: What if I make a report about a suspected violation and it turns out to be wrong?
A: If you suspect something, say something. Reporting in good faith means you’rebeing honest with information that you believe is true and accurate, even if it turns
out that you were mistaken. It’s better to report a potential problem than to wait. By
reporting an integrity concern, you can be confident that you’re doing the right thing
and that your concern will be handled appropriately.

Q: I’m concerned about retaliation. Am I safe making a report?
A: Yes, you can feel safe speaking up at Twilio. It takes courage to speak up when
you suspect that something is not right. Be assured that we do not tolerate retaliation
against anyone who raises a concern in good faith about potential misconduct, orfor cooperating in an internal investigation. If you believe you have experienced
retaliation, contact the Ethics & Compliance team or the Ethics Helpline.

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Investigations
When we become aware of a potential violation of the law, the Code, or
any other Twilio policies, Twilio will take action. When Twilio conducts aninvestigation, we do so fairly, objectively, and thoroughly, and we takeappropriate disciplinary action if we determine that a policy violation
occurred. Through the investigation process, we make every effort tomaintain confidentiality to the greatest extent possible and in compliance withapplicable laws.

All Twilions are expected to cooperate with company investigations, and it’s
important to feel safe doing so. We do not tolerate retaliation against anyone
who participated in an investigation of a possible violation of the Code, ourpolicies, or the law.

Learn more
• Ethics Helpline at +1-844-637-6752 or www.twilio.ethicspoint.com• The Ethics Hub• Twilio Magic

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Our Team
We embrace diversity, inclusion, and equal opportunity
We support and respect each otherWe keep our workplaces safe, secure and healthy

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We embrace diversity, inclusion, andequal opportunity
What we believe

How we achieve it									At Twilio, we believe our existence should strengthen ourEqual employment opportunity

communities and society overall. We look to identify andTwilio is committed to equal employment opportunities

appropriately build new pathways for all communities tobased on merit, qualifications, and skills. We strictly

succeed at Twilio, but also to create systemic solutions forprohibit unlawful discrimination or harassment on theto create a diverse and inclusive

lasting change in the workplace. We work closely with ourbasis of race, color, ethnic or national origin, religion or

workplace where everyone has theemployee resource group communities to foster an inclusive

religious creed, protected military or veteran status,

culture with community advocacy. We work to eliminate bias

ancestry, pregnancy status, sex, gender identity or

anywhere it may exist in the workplace.

expression, age, parental status, marital status, mental or

Our values are best measuredin actions, not words. We strive

opportunity to thrive. By valuing andrespecting one another for who
we are and what we offer, we will

We do that by:•Hiring, growing, developing, and retaining people with

continue to build great things

various experiences from within and outside ourtogether.

industry to build a more equitable tech industry•

Identifying and eliminating bias•

Creating an inclusive culture and eliminating barriers toinclusion so that every Twilion feels welcome•

physical disability, medical condition, sexual orientation,or any other characteristics protected by law. We also
make all reasonable accommodations to meet our
obligations under laws protecting the rights of thedisabled. This applies to all aspects of employment,
including recruiting, hiring, job assignment, promotion,compensation, training, and benefits.

Intentionally prioritizing equity at all levels of
the Company•

Making reasonable accommodations under applicablelaw for those who experience disabilities and forreligious beliefs and practices

Learn more
• Twilio 2022 Impact and DEI Report10Living the Twilio Magic

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We support and respect each other
How we achieve it									Harassment, discrimination, retaliation

Twilions are expected to do everything they can to create

and bullying

a culture that is free from harassment, intimidation, bias,

As discussed more fully in our local employee

unlawful discrimination, retaliation and bullying. We expect

handbooks, policies, and internal work rules, we prohibit

Twilions to be upstanders when they feel safe to do so. That

harassment, discrimination, retaliation, and bullying inmeans evaluating the situation, speaking up in the moment inany form - verbal, physical, or visual. We do not toleratea safe and respectful way, and then reporting it.

mistreatment of anyone at Twilio, including employees,

In doing so, we create an environment in which we are eachaccountable for:•

Treating others with respect, fairness, kindness
and dignity•

Promoting a supportive and open community•

Prohibiting bullying, incivility, workplace violence,harassment, discrimination or retaliation

What we believe
We are committed to a supportive,
respectful, and collaborative work•

Resolving problems appropriately – never resorting tocontractors, consultants, service providers, vendors,
guests, clients, or agency partners. This applies atwork or in any work-related situation. The premise issimple: everyone has the right to be treated with dignity
and fairness. This means Twilio prohibits all forms ofharassment and discrimination, including subtler forms
such as stereotyping and repeated microaggressions, inaccordance with applicable law.

threats or violence•

Being allies and speaking up if we see offensive
behavior or other misconduct

environment where all Twilions can reach
their full potential.
Learn more
• Local employee handbook or relevant local policy• Global Community Engagement Guidelines11Living the Twilio Magic

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We keep our workplace safe, secure and healthy
How we achieve it									We foster a culture of health and safety where we prioritize

What we believe
We make health and safety a daily
priority not only because it’s the rightthing to do, but because it promotes
a caring and supportive work
environment where Twilions can thrive.

looking out for one another. Performing at our best every
day means we carry out our work free from any substancethat could hinder our ability to perform our jobs safely andeffectively. In addition, acts of violence or intimidation have noplace within our company and must be reported immediately.
Together, we create a supportive environment where
everyone can thrive.

sponsored events. If a manager has reasonable suspicion
that an employee’s use of drugs or alcohol may be negatively
impacting their job performance or the safety of themselves
or others at work, they may request an alcohol and/or drug
screening. Such suspicions should be based on objective
symptoms, such as changes in appearance, behavior
or speech.

Safe workplace
We strive to maintain a violence-free workplace. This means

Drugs and alcoholthat any form of violence or threat of violence is strictly

We believe that substance abuse is incompatible with theprohibited, whether it occurs in company offices, remotehealth and safety of Twilions, and we don’t permit it. While

workplaces, Twilio-sponsored events, or any activity where

we do not prohibit the consumption of alcohol at work

you represent Twilio. You are not allowed to bring any items

or Twilio-sponsored events, you must always use goodthat could be considered weapons to any Twilio-related

judgment. You should never consume alcohol in a manner

location or event, regardless of the circumstances. If youthat leads to impaired performance, inappropriate behavior,

become aware of a potential violation of this policy, reportjeopardizes the safety of others, or violates the law. You

it immediately to your HR Business Partner. In the event

must also be of legal age to do so. The use of illegal drugs,of a situation that could be perceived as violent or has thecontrolled substances, or any other substance that could

potential to escalate to violence, contact Twilio Security

compromise the safety of yourself or others or performance

immediately at nest@twilio.com.

is strictly prohibited in any workplace setting, whether it’sin company offices, remote workplaces, or during Twilio-

Learn more
• Local employee handbook or relevant local policy

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Our Responsibilities
We protect confidential information
We protect Company assets & use them appropriately
We safeguard data privacy
We communicate appropriately
We maintain accurate business records

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We protect confidential information
What we believe
We respect the value of nonpublic information, regardless ofwhether it pertains to Twilio or
another company. Each of us carries

How we achieve it									been entrusted to us.

Requiring third parties accessing confidential

Twilio’s confidential information is a valuable asset that gives

information owned or managed by Twilio to sign

us a competitive advantage.

appropriate non-disclosure agreements or data

We ensure the protection of confidential information by:•

Restricting access to only those individuals whose job
responsibilities require it•

the responsibility to safeguard
confidential information that has•

Securing documents, data, and devices in accordancewith the Twilio Information Security Policy•

protection addendums•

Limiting the sharing of confidential information to only
what is essential and required•

Immediately reporting any breaches or vulnerabilities
to the Information Security and Legal teams

Prioritizing privacy and confidentiality of information on
Twilio systems•

Avoiding working in public places or non-private
areas where there is a risk of it being viewed or heard
by others•

Requiring appropriate confidentiality agreements forboth employees and nonemployees•

Upholding confidentiality obligations even after
leaving Twilio•

Treating confidential information of third parties (i.e.,
suppliers, carriers, vendors, customers and business
partners) as carefully as you would Twilio’s or your own

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Examples of confidential information•

Trade secrets•

Research and development ideas•

Proprietary source code•

Contracts, sales, pricing and invoice data•

Existing or potential client lists•

Nonpublic financial data or projections•

Employee lists and salary data•

Potential acquisitions or investments•

New product or marketing plans

Learn more
• Twilio Information Security Policy
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We protect Company assets and use them appropriately
How we achieve it
Our assets encompass everything that Twilio owns and uses tocarry out business operations. This can include both tangible
and intangible assets, including trademarks, logos, copyrights,
patents, business plans, ideas, and other trade secrets. It canalso extend to the various electronic resources and equipment
provided for work, such as computer equipment, supplies, networking and communications platforms, and corporate credit
cards. Intellectual property, confidential information, and otherintangible Twilio resources represent substantial investments
and hard work, differentiating us from other companies.

•

employees, customers and business partners incompliance with applicable laws and Twilio policies•

Following Twilio’s established security controls, including
how and where we access Twilio data or resources•

Only using Twilio systems, internet, and third-

information on unauthorized online platforms), which
could result in unauthorized access to our businessdata and compromise the security of our customer andstakeholder information••

and utilizing non-disclosure and licensing agreements•

Never sharing passwords•

Securing laptops, important equipment andpersonal belongings•

Never using Twilio equipment to access, download ortransmit materials that violate our harassment policies•– including pornography or anything that could beperceived as contributing to a hostile workplace•

Understanding that all activity on Twilio equipment,
networks, systems or communications platforms –including things we write, store, send, or download –may be monitored as part of Twilio’s legitimate interestin protecting our assets

Protecting our intellectual property, logos andconfidential information by working with the Legal teamparty technology for lawful, ethical and businessappropriate activities

Never misusing messaging apps for work (i.e.,
capturing and sharing screenshots of Twilio confidential

We protect our competitive advantage by:•

Ensuring that we access data regarding Twilio

Always wearing our Twilio badge when in the office, andWhat we believe
Being an owner requires us to use Twilio’s

never giving that badge to anyone else

physical, electronic and information assets

Never bringing guests on site without going through the

responsibly and appropriately at all times.

visitor approval process•

Spending Twilio’s money as we would our own –responsibly and in support of Twilio objectives

By following these guidelines and practices, we uphold ourcommitment to protecting our company assets and maintaining a secure and ethical work environment.

Learn more
• Twilio Information Security Policy• Twilio Global Acceptable Use Policy• Local employee handbook or relevant local policy

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We safeguard data privacy
What we believe
We are entrusted with data from ouremployees, customers, customers’ users,
and business partners, including personal
data and communications data. We arecommitted to treating such data with care.

How we achieve it									

•purposes and on a limited “need-to-know” basis

Being an owner requires each of us to handle all dataappropriately. We are committed to protecting the privacy
and security of data, and we have implemented policies
and procedures that facilitate the necessary extra level ofprotection. Ensuring the proper protection and handlingof personal data and private communications is crucial tomaintaining trust in our relationships.

Examples of personal data and private communications
data include:•

Q: I accidentally sent a report that includes certain
customer personal data to the wrong customer.
What should I do?

A: Contact the Security Incident Response Team
immediately at securitysirt@twilio.com. They will
be able to coordinate with an appropriate crossfunctional team, including members of the Privacy
team, to provide guidance on the necessary steps
based on the specific circumstances of how andwith whom the data was inadvertently shared.

Developing secure products and services that protect
customer, employee and business partner data•

Being transparent about how and why wecollect, use, and otherwise process personal andcommunications data•

Abiding by all applicable privacy and data protection
laws and regulations•

Following Twilio’s privacy principles in our Binding

Individually identifying health orhealth-related information•

Names of family members•

Employee identification numbers and government
identification numbers (passport, drivers license andWe build trust by:•

Using and processing data for legitimate businessnational identification)•

Contact information, including email addresses andtelephone numbers•

Credit card or personal financial account information•

IP address/device identification numbers•

Customer message detail records•

Customer email communications•

Call or video recordings or transcriptions

Corporate Rules as well as accompanying privacy
policies and standards•

Honoring our customers’ privacy choices

Learn more•

Limiting the use and transfer of personal data

• Twilio Privacy Noticeor communications data to the minimum
amount necessary• Twilio Global Employee Privacy Notice• Twilio’s Binding Corporate Rules – Controller andProcessor Policies

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We communicate appropriately
How we achieve it									

•customers, clients, suppliers, vendors, carriers, partners

We speak with one voice when communicating about
our business.

What we believe

We exercise utmost caution to ensure that we are:•

We believe that as owners, it is essential
for our communications to be honest,
recognizing the significance of our

Could the post be perceived as disrespectful to ouror competitors?
•

Is it clear that I’m writing on my own behalf?

•

If I’m discussing Twilio or our competitors, am I

Not speaking on behalf of the Company unlessbeing honest and transparent about my role as aauthorized to do so

Twilio employee?

•

Not disclosing confidential information or relationships•

Not disparaging our customers

Responding to the media or government inquiries•

Not posting anything on social media that might be

If you receive any media inquiries or requests for comments,

seen as threatening, harassing, or bullying

you must immediately forward them to press@twilio.

Using social media wisely, making clear that any

com. We want to make sure our responses come from thepersonal postings are our own individual views, and areappropriate channels, so we leave discussions with industry

not being shared on behalf of Twilio

professionals, analysts and the press to the experts. When

Using internal tools like Megaphone to find approved

it comes to government inquiries or requests, it’s essential

content that is appropriate to share with our networks

to provide truthful and accurate responses. But before

words and their impact.
••

you do, engage the Legal team for guidance. And if you’re
If you’re still unsure about whether to post something on

ever considering meeting with a government agency orsocial media, ask yourself:

official on behalf of Twilio, contact the Legal team first.

•

Could the post possibly contain confidential trade or

They will make sure everything is in order and provide any

business secrets?

necessary approvals.
Learn more
• Corporate Communications Policies and Procedures
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We maintain accurate business records
How we achieve it											We keep complete and accurate records because it’s good business practice

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Red flags

Stop and seek help if you hear statements like these:
Click icons to reveal

and helps us meet applicable legal requirements. Financial accuracy also
reflects on our reputation and credibility, and allows us to make businessdecisions based on sound data. We maintain Twilio’s accounts, financial
statements and records accurately, with reasonable detail and in conformity
with applicable law and internal controls.
We manage our records properly by:•

Following policies relating to maintenance and disposal, including
preserving and protecting documents on a legal hold•

Providing full and accurate information to government andregulatory agencies•

Ensuring that financial statements, accounts, time reports, expense
reports and other records are accessible, accurate, complete and secure•

Properly classifying transactions in the appropriate accounting period,
account and department•

Insisting on transparency in all transactions – never allowing hidden
terms or side deals•

What we believe
We are honest and complete in what we report because

Verifying that only individuals with appropriate signatory authority

keeping accurate records is a critical factor in meeting

approve expenditures and enter agreements that bind the Company

our regulatory obligations and earning the trust of ourLearn morecustomers and investors.

• Signature Authority Matrix• Global Procurement Policy

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Our Reputation
We build partnerships based on merit
We compete fairly and honestly
We do not tolerate bribery
We act responsibly with gifts and entertainment
We avoid conflicts of interest
We do not trade on inside information
We comply with international trade laws

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We build partnerships based on merit
How we achieve it

What we believe
We work with others who commit toour high ethical standards. We view
our customers, suppliers, carriers

We are committed to dealing fairly with our customers,
suppliers, carriers and vendors, knowing that even one
dishonest act can seriously damage these relationships. We

behavior in all our interactions.

same thing as a third-party relationship?

know that our partners’ actions can impact our reputation,and enter these partnerships based on a commitment toethics and mutual trust.

and vendors as true partners. We
require transparency and honest

Q: What is a Partnership? Is that theWe build partnerships of merit by:•

Making decisions based on quality, price and service•

Choosing business partners that are committed toour ethical standards and agree to comply with our

A: We consider partners the same as
third parties. We may enter into purchasecommitments or agreements with these
entities to assist in performing operations.
These partnerships could include suppliers,
carriers, vendors, distributors, agents,
contractors, consultants, and even customers.

Supplier Code of Conduct•

Treating our partners fairly•

Avoiding and actions that could create even theappearance of a conflict of interest

Learn more
• Supplier Code of Conduct

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We compete fairly and honestly
How we achieve it									We compete fairly by delivering a high-quality product, andnever by entering into any agreements that interfere with fair•unlawfully prevent competition•

permission, and immediately contacting the Legal team

By putting our customers first, we build brand loyalty andWe compete honestly and within legal boundaries by:•Gathering competitive intelligence through appropriate

Never using confidential or proprietary informationof a competitor or another third party without theirtrade or that may otherwise violate local legal requirements.

market share.

Never using our market strength to unfairly harm or

if we come into contact with such information•

Prohibiting employees from inappropriately using
any third party’s confidential information, including
information belonging to prior employers

public sources – never misrepresenting who we are•

Avoiding any agreement with competitors that limits
competition by setting prices, dividing territories,
markets or customers•

Refusing to participate in any form of bid rigging witha competitor

What we believe•

boycott another company or prevent another company

We believe in being bold, but our desire tobuild a meaningful and impactful company
can only be achieved when we compete
fairly and honestly.

Never entering into an agreement with a competitor to

Q: While attending a trade association meeting, I had aconversation with a representative from a Twilio competitor
about an upcoming government bid. The representative asked
me what Twilio’s current pricing was, and if we could both agree
not to go below a certain amount in our bids. Was this okay?

from entering the market•

Being mindful of information shared at conferences

A: No. You should never discuss these topics with aand trade shows and avoiding discussions ofcompetitor. You must report the conversation immediately
to the Legal team. Any violation of competition laws could
result in damage to Twilio’s reputation, prison sentences,significant fines, debarment or other sanctions.

competitively sensitive subjects, such as non-public
prices or costs

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We do not tolerate bribery
How we achieve it											Our success is based on the quality of services we provide to our customers –Our Reputation

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Red flags

Stop and seek help if you hear statements like these:
Click icons to reveal

never on unethical behavior. If you’re ever in a situation where you believe thatpayment of a bribe is necessary, walk away from the situation and refuse toengage. Business obtained in this manner is not the business we want – and it
exposes Twilio to significant legal, financial, and reputational risk.
We avoid corruption by:•

Never offering, paying, seeking or accepting bribes or kickbacks•

Avoiding hidden terms in deals or side deals•

Insisting on transparency in all transactions•

Never making payments known as “expediting,” “facilitating,” or “grease”
payments, to speed permits, approvals, or government processes•

Making hiring and promotion decisions based exclusively on merit, andnever at the request of a customer or government official•

Using reputable agents and intermediaries•

Ensuring that any charitable donations are made in support oflegitimate causes, and never given at the request of a customer orgovernment official•

Keeping accurate and detailed books and records

What we believe
We win business on the strength of our products, people andservices. Corruption is illegal, unethical, and has no place atTwilio. As Twilions, we build our business with transparency,
trust and a commitment to doing the right thing.
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Never offer or accept anything of value from any third party, whether it is anexisting or prospective customer, vendor, or supplier, if it could be considereda kickback. For instance, employees involved in HIPAA-eligible products mustensure that any offering to healthcare customers is of nominal value and isconsistent with common and appropriate business practices.
Click to reveal

What is a bribe?

Q: A vendor offers you a cash incentive to prioritize their products. How should you
respond?

A: Decline the vendor’s offer and immediately report the incident to the Ethics &What is a kickback?

Compliance team.

Q: I was asked to secure an internship at Twilio for a relative of a government official who
is currently reviewing some of Twilio’s business activities in the region. Is this okay?

A: No. You can only provide information that would allow the relative to apply for aninternship, just like any other candidate. Doing any special favors at the request of agovernment official could be viewed as a bribe.
Learn more
• Anti-Bribery and Anti-Corruption Policy• Global Travel and Expense Policy• Supplier Code of Conduct

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We act responsibly with gifts and entertainment
How we achieve it									What we believe
We are careful in giving and receiving
gifts and entertainment so we can makedecisions that support the Company’scommitment to business integrity. We’re
all responsible for building our businesswith honest and transparent businesspractices. This means we don’t give or
receive excessive or inappropriate gifts
or entertainment, and we keep accurate
records relating to the associated costs

Any gifts or entertainment given or received must reflect ourcommitment to operating with integrity. Where there is nointent to improperly influence others, it can be appropriate

Q: A vendor has offered me tickets tounder certain circumstances to exchange modest gifts or

the Super Bowl. Can I accept them?

host entertainment for third parties. A lot depends on who isreceiving the gift. The general limit for gifts and entertainment
given or received is $100 USD or local equivalent.
Gifts and entertainment given or received must not:•Appear to be an attempt to influence decision-making•

Create a sense of obligation for the recipient to return

A: No. The value of this gift exceeds theallowable limit. And even if you think the gift
won’t affect your ability to be fair in futurebusiness decisions, others may not see itthat way.

the favor•

Violate any law, regulation, Twilio policy, or
partner policy•

Be lavish or excessive•

Appear to be a quid pro quo, or given in exchange for an

and people involved.

improper or personal benefit•

Be cash or cash equivalents•

Be frequent or repetitive•

Be undocumented in Twilio records•

Be inconsistent with local business practices•

Be in poor taste or inappropriate for the occasion
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Government Officials and Public Entity Customers
Special rules apply to the giving of courtesies to government employees
and officials. Many countries in which we do business prohibit the giving
and receiving of gifts, travel, lodging, meals or entertainment to government
officials. We are responsible for understanding and complying with theselaws and regulations. Even the appearance of impropriety in connection
with gifts and entertainment creates risk for Twilio - both for our brand andwith regulators.

It’s never appropriate to give gifts to thank government officials for doing theirjobs. What may be appropriate for a commercial business partner could posea serious problem for a government official, and for Twilio.

You must never promise, offer or give gifts, entertainment, gratuities, meals,
lodging, travel, or anything of value to a government official or public entity
customer unless you have received prior written approval from the Ethics &Compliance team.

Learn more
• Anti-Bribery and Anti-Corruption Policy• Global Travel & Entertainment Policy
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Living the Twilio Magic

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We avoid conflicts of interest
How we achieve it
We act in Twilio’s best interests when we avoid situations in which ourloyalties are divided or we are personally benefiting at Twilio’s expense. Even
the appearance of a conflict can be as damaging as an actual conflict. It’s
simple: we must always act in the best interest of our Company.

We put Twilio’s best interests before our own by:•

Disclosing outside business activities and any potential conflictsof interest•

Not accepting any gifts, entertainment or other business courtesies that
could influence our decision-making•

Remaining alert for situations where personal activities or relationships
could affect our objectivity•

Removing ourselves from resolving conflicts of interest where we are a
related party•

Only benefiting from our employment with Twilio through our normalcompensation program

What we believe•

Obtaining pre-approval for board seats, consulting or otheroutside employment

We put the Company’s goals and our customers’ interests before
personal gain. This commitment to ethical behavior helps us
make unbiased, smart decisions that benefit our business.
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While potential conflicts of interest can arise in many different scenarios, below are some common examples.

Financial interests

Business opportunities

We avoid making personal investments in Twilio businessBusiness opportunities found through your work at Twilio

partners or businesses that are competitive with Twilio.

belong to Twilio first. If you’re interested in pursuing a

Such investments could harm Twilio and cause a perception

business opportunity that arose through your work at Twilio,that your loyalties are divided. Before making a personal

you must first obtain approval from your manager and yourinvestment, consider the conflict of interest risk and disclose

HR Business Partner.

any potential conflicts to the Ethics & Compliance team. Any
passive investment of not more than two percent (2%) of

Use of Twilio products

the total outstanding shares of a publicly-traded company

You must not use Twilio products, services, internal tools, oris permitted, as long as the investment is not so large

information in a way that improperly benefits you or someone

financially (either in absolute dollars or percentage of your

you know, or creates the appearance that you have an unfair

total investment portfolio) that it creates the appearance of aadvantage over users outside Twilio.

conflict of interest.

Inventions
Outside employment

Developing or helping to develop outside inventions may

Outside employment, consulting engagements, advisory roles,

create conflicts of interest if they relate to your positionboard seats, and new business start-ups require caution. We

at Twilio or to Twilio’s existing or reasonably anticipatedavoid conflicts by obtaining approval through the Outside

products and services, or if they are developed using Twilio

Activities Disclosure process prior to beginning any suchcorporate resources. Such inventions may also be subject toposition outside Twilio. Activity that actually or potentiallythe provisions of your Proprietary Information and Inventioncompetes with Twilio will not be approved.

Assignment Agreement, or other employment agreements.
Contact the Legal team if you have any questions about
potential conflicts or intellectual property ownership involving
an outside invention.

Learn more
• Outside Activities Disclosure form

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Friends, relatives, and co-worker relationships
It’s a conflict of interest for a Twilion to participate in management or decisionmaking of potential or existing Twilio business relationships that involve
relatives, spouses or significant others, or close friends. We avoid conflicts byrecusing ourselves from:•The hiring process for any position in which a conflicted person (family
member, spouse, significant other or close friend) is being considered•

Decision-making concerning a conflicted person’s performance review,compensation, promotion, discipline, or termination•

Managing accounts for any company that is associated with aconflicted person

Personal Relationships
A personal or romantic relationship between co-workers can create an actual
or apparent conflict of interest for the individuals involved, depending on theirwork roles and positions. Twilions must not be directly or indirectly involvedin the management of any individual with whom they have a personal
relationship. In addition, they must not have the ability to review or influencesuch an individual’s employment status, job evaluation, pay, benefits, or any
other work condition. You are required to report any romantic relationshipthat could create a conflict of interest to your HR Business Partner.
Romantic relationships that create a conflict may require changes to work
arrangements, or even termination of employment.

Q: My sister owns a company that provides the service we have been looking for. I can get
Twilio a good deal on the services due to the family connection. Can I engage her company
as a service provider?

A: No. It’s a conflict of interest for you to make a business decision that will benefit a
relative. You must remove yourself from the situation and let your manager know you
cannot be involved. Your manager may decide to pursue the opportunity, or assign it toanother decision maker outside of the reporting chain. The selection of this vendor must
follow the appropriate procurement process.

29Living the Twilio Magic

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We do not trade on inside information
How we achieve it

What we believe
It’s imperative that we follow thelaw when it comes to buying or

We are sometimes exposed to information about Twilio, or
other companies we conduct business with, that requires
us to act with caution. This knowledge makes us “insiders.”
Trading on inside information, or tipping someone off, is a

Q: I heard we were going to buy oneof our competitors. This information
isn’t public yet. I’d like to help a friend by
telling her what I know. Is this okay since
I would not be profiting personally?

crime, violates trust with Twilio’s investors, and is unfair toselling shares of Twilio, or any other

other investors. We never give or receive “tips” of material

A: No. It does not matter whether you

company’s stock. We do not engage

non-public information about Twilio or any company.

in insider trading because it’s illegal

Examples of material, nonpublic information can include:

would be personally profiting from sharing
this information. The law prohibits you fromtipping someone off to inside information.
Remember, inside information is any
material, non-public information about
Twilio or any other company. Information isconsidered material if a reasonable investor
would rely on it in deciding whether tobuy or sell the company’s stock. If you’re
unsure whether information is material
or non-public, ask the Legal team.

and would harm our reputation.

•

New products in development•

Significant litigation or a pending regulatory action•

An acquisition or merger•

Positive or negative quarterly earnings•

New or lost customers

We only trade shares of Twilio when the trading window is
open, and we do not have non-public material information.
Consult the Insider Trading Policy for further guidance or
updated communications for specific circumstances.
Learn more
• Insider Trading Policy

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We comply with international
trade laws
How we achieve it
We comply with the letter and spirit of applicable international trade laws. By
respecting the laws where we do business, we contribute to a fair society andhelp strengthen those communities.

We uphold business integrity by:•

Doing business only with countries and third parties that are free fromtrade embargo and economic sanctions concerns•

Avoiding marketing or distributing any product across international
borders without first consulting the Legal team•

Alerting the Legal team if we are asked to participate in a boycott of acompany or country•

Being honest with government representatives and officials•

Ensuring that our partners are not “Restricted Persons” from asanctions perspective

What we believe
Our work at Twilio takes us around the world. To operate on a global
scale, we are committed to conducting business ethically and in strict
compliance with all applicable laws and regulations, including laws that

Learn moregovern international trade.

• U.S. Export Controls & Economic Sanctions
Compliance Program31

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Our Stakeholders
We contribute to our communities
We uphold human rights

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We contribute to our communities
How we achieve it
We are committed to serving the broader communities in which we live
and work. Our commitment is reflected in our social impact arm at Twilio.
Our mission at Twilio.org is to fuel communications that give hope, power,
and freedom. Through Twilio.org we connect social impact organizations,passionate software developers, and the full power of the Twilio platform toignite positive change from a local to global scale.
Our goal at Twilio is to limit our impact on climate change and to carry out ourbusiness activities in a sustainable manner. As a business that is conductedlargely online, our carbon footprint may be smaller than manufacturing orother businesses, but we still strive to limit our impact on climate change. In
addition, we strive to develop environmentally and socially sustainable chainsof responsibility with our suppliers, carriers, vendors and other third parties.
More details on Twilio’s commitment to environmental sustainability arecontained in the Twilio Impact and DEI Report.

What we believe
We believe the tools we build can improve lives
everywhere. Twilio commits our technology, funding, andtime to help organizations change lives in times of crisis,

Learn more

and to prevent crises from happening.

• Twilio Impact and DEI Report• www.twilio.org

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We uphold human rights
How we achieve it											We condemn all forms of human trafficking and sexual exploitation. We will
not employ underage children or utilize forced labor. At Twilio, we upholdhuman rights in all aspects of our work. Our commitment to doing businessonly with those who uphold the same standards helps us demonstrate ourrespect for human dignity.
At Twilio, we identify and mitigate risks to human rights that could impact ouremployees and our customers. These areas include protecting our customer
and employee information and focusing on ethical labor practices, diversity,and anti-discrimination. We take these issues seriously, and commit toensuring that our impact is positive. Through focused policy implementation,
decision-making and investments in non-profit organizations, we are actively
engaged in effecting positive change in the global community.

What we believe
We believe every human being has the right to be safe
Learn more
• Statement on Human Rights• Supplier Code of Conduct

and secure, and we conduct our business in a mannerthat protects human rights.
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Resources

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Living the Twilio Magic

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At Twilio, we are Living the Twilio Magic when we follow the letter and spiritof the guidance and policies outlined in this Code. The Code is not intended
to be exhaustive, but is instead a guide for helping you operate with integrity
and transparency. If you face a problem and aren’t sure of the best course ofaction, or if you know or suspect that a legal or policy violation has occurred,
contact one of our Company resources.
•

Your manager•

Your HR Business Partner•

Employee Relations•

The Legal team•

The Ethics & Compliance team•

The Ethics Helpline: +1-844-637-6752 or www.twilio.ethicspoint.com

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Today’s leading companies trust Twilio’s Customer Engagement Platform (CEP) to build direct, personalized relationships with
their customers everywhere in the world. Twilio enables companies to use their communications and data to add intelligence andsecurity to every step of the customer journey, from sales to marketing to growth, customer service and many more engagement
use cases in a flexible, programmatic way. Across 180 countries, millions of developers and hundreds of thousands of businesses
use Twilio to create magical experiences for their customers.
For more information about Twilio (NYSE: TWLO), visit: www.twilio.com.
All rights reserved. Copyright @ 2023 Twilio Inc.