SUPPLIER

CODE OFCONDUCTNEXTIMPORTANT NOTE TO THE READER: This Code of Conduct is an internal BCG document
designed for the sole use of BCG and its Suppliers. If you are not such an individual, it may
be shared with you as a third party on the express understanding that it is not intended tocreate legally binding undertakings, representations, or obligations in favor or towards youor your organization. Further, you may not—and it is unreasonable for any third party
to—rely on these materials for any purpose whatsoever. To the fullest extent permitted bylaw (and except to the extent otherwise agreed to in writing in a document signed by BCG),
BCG shall have no liability whatsoever to any third party, and any third party hereby waives
any rights and claims it may have at any time against BCG with regard to the distribution
or content of this document. Receipt and review of this document shall be deemed
agreement with and consideration for the foregoing.
Copyright © 2019 by Boston Consulting Group. All rights reserved

Table ofContents
SUPPLIER

5Introduction to the Supplier Code of Conduct

7Compliance with the Supplier Code of Conduct

9Business Practices and Ethics

11Labor Practices and Human Rights

13

Environmental Regulations and Protection

14

Protection of Assets, Intellectual Property, and Data

15

Reporting Questionable Behavior, Illegal or Unethical Behavior, or
Violations of the Supplier Code of Conduct

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56Introduction
to the Supplier
Code ofConduct

As we continually strive to deliver high performancefor our clients, Boston Consulting Group (BCG) is
committed to upholding the highest ethical andprofessional standards consistent with our corevalues and our Code of Conduct.
The BCG Supplier Code of Conduct aligns with ourcore values and applies to all Suppliers that produce
goods for or provide services to BCG or any of its
subsidiaries, divisions, aﬃliates, or agents. While
BCG recognizes that there are diﬀerent legal andcultural environments in which Suppliers operate
throughout the world, this Supplier Code of Conduct
sets forth the minimum requirements that Suppliersmust meet to do business with BCG.

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7Compliancewith the Supplier
Code of Conduct

BCG Suppliers and their employees, agents, andsubcontractors (collectively referred to as “Suppliers”)
must adhere to this Supplier Code of Conduct while
conducting business with or on behalf of BCG. Suppliers
are expected to self-monitor and demonstrate theircompliance with the BCG Supplier Code of Conduct andmust promptly inform BCG of any circumstances or
event that causes the Supplier to violate this Supplier
Code of Conduct. Notice required under this section shallbe provided to the BCG Speak Up Line or as speciﬁed
within Supplier’s contract with BCG.
BCG may require the immediate removal of any Supplier,its employees, agents, or subcontractors who behave in amanner that is unlawful or inconsistent with this Supplier
Code of Conduct and whose conduct is conﬁrmed to be
unlawful or inconsistent with this Supplier Code of8Conduct or any applicable BCG policies. In addition,
Suppliers are expected to adhere to applicable laws andregulatory requirements relating to relevant
environmental, social, and corporate governancestandards. Supplier shall also take steps to ensure thatthe principles of this Supplier Code of Conduct arecommunicated to and adopted by their own supply chainto the extent relevant. Compliance with this Supplier
Code of Conduct is required in addition to any otherobligations in agreements between Supplier and BCG.
BCG reserves the right to review Supplier compliancewith the Supplier Code of Conduct through periodic
assessments including assessment questionnaires andaudit requests. Suppliers are expected to fully respond tosuch assessments promptly.

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9Business Practicesand Ethics
All Suppliers shall conduct their businessactivities and operations with integrity andin full compliance with the applicable laws
and regulations while conducting businesswith and/or on behalf of BCG:

of business records in full compliance with allapplicable legal and regulatory requirements,and shall be honest, direct, and truthful in
discussions with regulatory agency
representatives and government oﬃcials.
Antibribery and Corruption

Employee Training
Suppliers shall ensure that employees areaware of and adhere to the obligations of thisSupplier Code of Conduct and take
BCG-provided training, when required, toenable compliance with this Supplier Code ofConduct (for example, when they interactwith BCG clients or have access to data or
facilities managed by BCG or BCG clients).
Goodwill
Supplier shall not at any time speak or act inany manner that is intended to, or does infact, damage BCG’s goodwill or business, orthe business or personal reputations of anyof its partners, oﬃcers, agents, employees,clients, or Suppliers. Supplier further agrees
that it shall not engage in any otherdeprecating conduct or communications withrespect to BCG, including making statementsor posts on social media.
Business Information
Suppliers shall honestly and accurately
record and report all business informationand comply with the applicable laws
regarding their completion and accuracy.
Suppliers shall create, retain, and dispose

BCG is committed to conducting its
business free from extortion, bribery and all
unlawful, unethical, or fraudulent activity.
Suppliers shall comply with all applicablelaws and regulations, including those withextrajurisdictional application such as the US
Foreign Corrupt Practices Act and UK Bribery
Act of 2010.
In connection with doing business with BCG,
Suppliers shall not oﬀer, promise, authorize,
give, demand or accept any loan, fee, reward
or other advantage to or receive suchadvantage from any person as aninducement; to do something which isdishonest, illegal, or a breach of trust; toobtain, retain, or direct business; or to secure
any other improper advantage.
Suppliers shall implement an antibribery andcorruption policy with measures to ensurethat their employees, agents, andsubcontractors comply with applicableanticorruption laws and/or standards.
No Publicity
Supplier shall not make public that BCG is
Supplier's client without ﬁrst obtaining BCG'swritten approval.

Insider Trading
Suppliers shall comply with all applicableinsider trading laws which prohibit the buying
or selling of securities while in possession ofmaterial, nonpublic information gained
through Supplier’s relationship with BCG orotherwise. Supplier shall not misuse orcommunicate to others any such material,
nonpublic information in connection with any
securities transactions or otherwise. BCG
considers information material if there is a
substantial likelihood that a reasonable
person would consider the information
important in deciding to buy or sell acompany’s securities. BCG considers
information nonpublic if it has not been
disseminated in a manner making it
generally available to investors or the public.
Gifts and Hospitality
Even a well-intentioned gift might constitutea bribe under certain circumstances or create
conﬂicts of interest.
• Suppliers shall not oﬀer anything of value
to obtain or retain a beneﬁt or advantage
for the giver and shall not oﬀer anythingthat might appear to inﬂuence, compromise
judgment, or obligate the BCG employee.
If oﬀering a gift, meal, or entertainment toBCG’s employees, Suppliers must always
use good judgment, discretion, andmoderation.
• Any gift from a Supplier must bepermissible under the policy of theBCG employee’s business unit andcountry, as individual BCG businessand regional policies may prohibit gifts
entirely or set maximum gift value limits
at varying amounts. Any gifts, meals,
or entertainment must comply withapplicable law, and be consistent withlocal custom and practice.
• Suppliers must comply with all federal,country, state, provincial, and municipal
laws including all antitrust and fair-trade
policies.
Conﬂicts of Interest
Suppliers must avoid engaging in any activity
that would create an actual or potential
conﬂict of interest regarding their provisionof products or services to BCG. A conﬂict ofinterest occurs under this code when theinterest of a Supplier—or the interest of a
Supplier’s employees or suppliers with whomthey work in providing goods and services toBCG—interferes or appears to interfere withthe ability to objectively deliver or perform
services to or for BCG. If an actual or
potential conﬂict of interest arises inconnection with BCG, Suppliers must
promptly report it to BCG.

10antiboycott laws in all jurisdictions inwhich BCG operates. Suppliers must nottransact with individuals or entities if theyknow, should have known, or suspect thatsuch transactions violate applicable
import/customs laws, sanctions or export
controls. Supplier must immediately notify
BCG, in writing, if Supplier becomes awarethat Supplier or any of its owners, oﬃcers oroﬃcials, managers, employees, consultants,
or other representatives are subject tosanctions, export controls, or other tradecontrol laws.
In addition to not transacting with sanctioned
persons or entities, no supplier may deal,
directly or indirectly, with a territory subject
to comprehensive sanctions in connection
with the Supplier’s business with BCG. It is
the Supplier’s obligation to know which
territories are subject to comprehensive
sanctions imposed by the US or any otherjurisdiction. BCG believes that as of March
2024, territories subject to comprehensive
sanctions by the US government are theRussian-occupied areas of Ukraine (Donetsk
People’s Republic, Crimea, Luhansk People’sRepublic), Cuba, Iran, North Korea, and Syria(subject to change). While BCG cannot
provide you with legal advice, if you havequestions or are uncertain about whether
a particular individual, entity, territory ortransaction could be subject to trade control
regulations or sanctions, please contact BCG
on the BCG Speak Up Line.

Trade Compliance
Suppliers shall comply with applicableinternational trade control laws andregulations, including import/customs
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11Labor Practices
and Human Rights
As a participant in the United Nations
Global Compact, BCG supports the Ten
Principles on human rights, labor,environment, and anticorruption, andrespects the UN Guiding Principles on
Business and Human Rights. BCG expects
its Suppliers to share its commitment tohuman rights and equal opportunity in theworkplace. Suppliers shall conduct theiremployment practices in full compliancewith all applicable laws and regulations:

Safe Working Environment
Suppliers are expected to integrate sound healthand safety management practices into all aspectsof their business.
Suppliers shall provide a safe and healthy work
environment and fully comply with all safety andhealth laws, regulations, and practices, including
those applicable to the areas of occupationalsafety, emergency preparedness, occupational
injury and illness, industrial hygiene, physicallydemanding work, machine safeguarding,sanitation, food, water, and housing. Suppliers
shall take adequate steps to minimize the causesof hazards inherent in the working environment.

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Voluntary Labor

Wages, Beneﬁts, and Working Hours

Suppliers shall comply with all applicable laws andregulations, including but not limited to the UK
Modern Slavery Act of 2015 and the AustralianModern Slavery Act 2018. Additionally, Suppliers
are prohibited from using forced labor whether inthe form of indentured labor, bonded labor, or
prison labor. Also prohibited is support of any formof human traﬃcking of involuntary labor throughthreat, force, fraudulent claims, or other coercion.
Supplier employees must be free to terminate
their employment with reasonable notice.

Suppliers shall comply with all applicable wage, beneﬁt,and hour laws and regulations and shall not require
employees or contractors to work more than themaximum work week hours established by local law,including overtime, except in extraordinary businesscircumstances and with the consent of the individual.
Suppliers shall pay employees at least the minimum
wage required by applicable laws and regulations andprovided the required beneﬁts. Suppliers shallcompensate employees for overtime hours at the raterequired by applicable laws and regulations.

Non-discrimination

Freedom of Association and Collective Bargaining

It is BCG’s commitment that diverse businessenterprises shall have equal opportunity to provide
all goods and services and to become preferred
Suppliers for the organization. BCG is committed
to the development and growth of diverse businessenterprises in order to build a better working world
and to expand networks to build trusted andenriched relationships.

Suppliers shall respect employees’ rights with respect
to freedom of association and collective bargaining,
including the right to form or join labor or trade unions
or to join workers’ councils in accordance with local
laws. Employees must be free to engage in these
activities without retaliation, harassment, orintimidation.

BCG expects Suppliers to have equivalent policies
to promote diversity in their supply chain, topurchase from diverse businesses, and to make areasonable eﬀort to utilize diverse suppliers.
Suppliers shall cooperate with BCG’s commitment
to a workforce and workplace free of harassment
and unlawful discrimination. Suppliers must notengage in discrimination in hiring, compensation,access to training, promotion, termination, and/orretirement based on race, color, sex, nationalorigin, religion, age, disability, gender identity orexpression, marital status, pregnancy, sexual
orientation, political aﬃliation, union membership,veteran status or any other characteristic
protected under applicable law.

Harassment
Suppliers shall not condone any form of harassment.
This behavior can take many forms including verbal
remarks, physical advances, bullying, and visual displays.
Although the legal deﬁnition of harassment may varydepending on location and cultural norms, Suppliers
shall follow BCG’s standards that are applied globally.
Minimum Working Age and Child Labor
Suppliers shall comply with all local and national
minimum working age laws and regulations and notuse child labor.

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1314

Protect and responsibly use BCG’s physical andintellectual assets, including intellectual property,
tangible property, supplies, and equipment withconﬁdentiality, and integrity, when authorized by
BCG to use such assets.

Comply with BCG requirements for safeguarding
data as outlined in the contractual agreement with
BCG as a condition of providing BCG with goods orservices or receiving access to the BCG’s internal
corporate network, systems, and buildings.

EnvironmentalRegulations
and Protection
BCG believes environmental stewardship is essential tothe sustainability of our business and to the health of thecommunities where we live and work. Hence, BCG expects
that its Suppliers shall comply with all applicable
environmental laws, regulations, and standards. Suppliers
shall address their material environmental impacts, risks,and opportunities—including, without limitation, measuring,managing, and addressing energy usage, greenhouse gas
emissions, and climate-related risk. Where applicable,
Suppliers shall measure, manage, and reduce pollution,
waste, and the use of water or other natural resources intheir operations. In addition, Suppliers and their supply
chains shall comply with applicable laws and international
conventions with respect to the use, handling, and disposalof hazardous waste, persistent organic pollutants, mercury,and similar substances.

Comply with the intellectual property ownershiprights of BCG and others including but not limited
to copyrights, patents, trademarks, and trade
secrets, and manage the transfer of technology
and know-how in a manner that protects
intellectual property rights.

Protection ofAssets, Intellectual
Property, and Data
Protection of intellectual property rights
is vital for any company. BCG depends on
intellectual property such as information,processes, and technology. Hence, allSuppliers shall:

Ensure compliance with applicable legal
requirements providing for the protection, transfer,access, and storage of personal information. This
includes General Data Protection Regulation(GDPR) (Regulation (EU) 2016/679).

Secure BCG data against unauthorized accessand use, and not reuse BCG personal data for
their own business purposes without priorpermission. Recognize that any use, sharing, orretention of personal data must be supported by,or based on, consent or a legitimate, compellingbusiness purpose.

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15If Suppliers wish to report questionable behavior, illegal
or unethical behavior, or a possible violation of thisSupplier Code of Conduct, BCG requests that theycontact the BCG Speak Up Line.
BCG will maintain conﬁdentiality to the extent possible
and will not tolerate any retribution or retaliation taken
against any individual who has, in good faith, sought out
advice or reported illegal or unethical behavior or apossible violation of this Supplier Code of Conduct.

In the event of any conﬂict or ambiguitybetween any provision of this Supplier
Code of Conduct and the provisions of
any relevant contract with the Supplier,the provisions of the contract will apply.

Failure to comply with these standards or withapplicable laws and regulations, if conﬁrmed, may
result in termination as a BCG Supplier and referralof the matter to local authorities.

Reporting Questionable
Behavior, Illegal or
Unethical Behavior, or
Violations of the Supplier
Code of Conduct
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