MongoDB, Inc. (“MongoDB”), including any entity, affiliate or subsidiary owned or controlled by MongoDB, is committed to maintaining the highest standards of business practices, ethical conduct, social responsibility and environmental sustainability. We expect our vendors, consultants, contractors (including subcontractors) and other providers (together, “Suppliers”) to aspire to these same standards in their business operations.

This Supplier Code of Conduct (this “Code”) reflects the minimum standard for working with MongoDB and operates in addition to a Supplier's existing legal and contractual obligations to MongoDB. Suppliers are expected to understand and comply with the legal and regulatory requirements applicable to their business operations. Where a standard for conduct addressed by this Code is also governed by existing law, Suppliers should follow the strictest applicable standard. If any requirements in this Code may cause a violation of a law applicable to a Supplier in any jurisdiction, the applicable law should take priority.

A violation of this Code will be considered a material breach of any contractual relationship that MongoDB has or will have with Supplier.

Compliance with Law

• Anti-bribery and anti-corruption: MongoDB is committed to conducting its business free from extortion, bribery and all unlawful, unethical, or fraudulent activity. Suppliers shall comply with all applicable laws and regulations, including those with extra-jurisdictional application such as the U.S. Foreign Corrupt Practices Act and UK Bribery Act of 2010. Suppliers will not engage in any form of corruption, including extortion, bribes, kickbacks, inappropriate gifts or hospitality, or providing any other thing of value to a government official or other person for the purpose of influencing any act or purchasing decision.
• Antitrust and Fair Competition: MongoDB’s policy is to compete vigorously and ethically while complying with all antitrust and competition laws. As a result, Suppliers are expected to take care in any communications with competitors about any aspect of MongoDB’s business (e.g., at industry events and trade associations). Further, Suppliers must avoid any actions that violate, or even create an appearance of violating, antitrust laws. Suppliers must not take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation, or any other unfair-dealing practice.
• Privacy and Security: Suppliers must follow all applicable privacy and data protection laws. As the collection, use, storage, and international transfer of personally identifiable information about individuals is increasingly subject to regulation, Suppliers should carefully protect all personal information they acquire or have access to by virtue of their work with MongoDB in a manner that complies with applicable laws and regulations.
• Export Control: MongoDB complies with all international trade laws and regulations, including U.S. trade sanctions, and we expect suppliers to comply with all trade and export control laws that apply to their work with MongoDB.

Ethics and Business Integrity

• Conflicts of Interest: Suppliers must refrain from any transaction or relationship that creates or appears to create actual or potential conflicts of interest between their own interests and the interests of MongoDB. Suppliers must also disclose any transaction or relationship that reasonably could be expected to give rise to a conflict of interest, or the appearance of a conflict of interest, to the Supplier’s primary MongoDB contact.
• Insider Trading: Insider trading is prohibited. As MongoDB is a public company in the United States, Suppliers must ensure that their own officers, employees, and other representatives (i) comply with insider trading laws and regulations and their own internal policies governing trading of publicly traded securities, and (ii) refrain from trading securities of MongoDB or any other issuer based on material non-public information regarding MongoDB, and from providing such information to others.
• Intellectual Property and Confidentiality: Suppliers must respect and protect the intellectual property rights of MongoDB, its customers, and others (including, without limitation, patent, trademark, copyright, and trade secret rights) and use those rights only in accordance with valid licenses, terms of use, or other relevant contractual provisions. Suppliers must notify MongoDB of any unauthorized use of MongoDB’s technologies, products, copyrights, trademarks, trade secrets, proprietary, or confidential information by a third party. Suppliers shall respect intellectual property rights and safeguard customer information. Suppliers shall manage technology and know-how in a manner that protects intellectual property rights and use reasonable efforts to safeguard MongoDB’s confidential information against improper use or disclosure. Suppliers shall comply with all MongoDB requirements and procedures for maintaining passwords, confidentiality, security, and privacy as a condition of providing MongoDB with goods or services or receiving access to the MongoDB internal corporate network, systems, and buildings. If Suppliers learn of a data security breach involving information belonging to MongoDB, its employees, or MongoDB’s customers, Suppliers must notify MongoDB promptly by emailing the MongoDB security team at security@mongodb.com.
• Accuracy of Books and Records and Public Reports: Suppliers’ books, records, and other public reports must be full, fair, accurate, and timely. Suppliers must honestly report all business transactions and maintain accurate records in compliance with applicable legal, accounting, and regulatory requirements. In connection with MongoDB’s business, there cannot be any unrecorded funds, assets, or any other type of “off the books” accounts, no matter what the reason for such accounts (this prohibition includes, but is not limited to, the use of inflated discounts to create additional margins/funds for off-book use). Suppliers must never misrepresent pricing information, or the justification for any margin or discounting requests to MongoDB.

Environmental Responsibility

Suppliers must comply with applicable environmental laws and provide appropriate accountability and transparency when conducting business that may have adverse effects on the environment. Compliance with environmental laws includes but is not limited to obtaining and maintaining environmental permits and approvals for the conduct of regulated activities; managing and properly disposing of hazardous materials; monitoring, managing, and disclosing environmental emissions and contaminants; and ensuring accuracy of environmental claims. Additionally, suppliers shall make a concerted effort to identify, monitor, report, and reduce their carbon emissions. We look to partner with Suppliers that are conserving natural resources, reducing greenhouse gas emissions, minimizing waste, promoting recycling and reuse, and avoiding the use of toxic and hazardous materials.

Discrimination and Harassment

Suppliers must promote equal opportunities and treatment of all employees and a workplace environment that is free from discrimination, exploitation, harassment, or other unacceptable treatment of individuals. MongoDB does not tolerate discrimination and will not conduct business with any company that does not demonstrate the same value of acceptance and inclusion for all. MongoDB does not tolerate harassment and may, in its sole and absolute discretion, remove from the premises any Supplier who engages in offending conduct such as sexual harassment. Similarly, Supplier must promptly report to any member of MongoDB management any offending behavior by MongoDB employees directed toward Supplier or its employees, or by Supplier’s employees directed toward MongoDB or its employees.

Human Rights and Labor Laws

Suppliers must comply with all applicable modern slavery laws and regulations which apply to their business and in any part of their supply chain (including but not limited to the UK Modern Slavery Act 2015).

Suppliers must provide their employees a safe and ethical workplace. MongoDB requires Suppliers to:

• Treat employees with respect and dignity and observe rights to freedom of association and collective bargaining in accordance with applicable laws and regulations.
• Prohibit the use of forced or involuntary labor – including prison, indentured, bonded, or slave labor – and any engagement in human trafficking.
• Prohibit the use of child labor and only employ individuals who meet applicable legal age requirements in the Supplier’s countries of operation.
• Comply with all applicable wage and hour – including overtime – labor laws in the Supplier’s countries of operation.
• Maintain a working environment that is safe and fully compliant with applicable occupational health and safety laws.

Monitoring and Application

MongoDB expects all Suppliers to adhere to, and maintain a record of compliance of, this Code. MongoDB reserves the right to request documentation of compliance with this Code. MongoDB also expects all Suppliers to provide reasonable assistance to any investigation by MongoDB of a violation of this Code.

Certain violations of this Code may require MongoDB to refer the matter to law enforcement authorities for investigation or prosecution.

Miscellaneous

This Code does not confer any rights to any third parties. In addition, no employees of any Supplier will have any rights against MongoDB by virtue of this Code, nor will such employees have any rights to cause MongoDB to enforce any provisions of this Code.

Questions and Reporting

MongoDB encourages open discussion. If you have questions or concerns about this Code or your business relationship with us, please raise them with your primary MongoDB contact. If you believe that a MongoDB employee or anyone on behalf of MongoDB has engaged in illegal or unethical behavior, you should report your concerns by emailing the MongoDB legal team at [legalnotices@mongodb.com]. Any issues regarding payment, billing, etc. should be resolved by contacting your MongoDB contact directly. MongoDB will not tolerate retaliation taken against any individual who has in good faith raised questions, sought advice or reported misconduct, questionable behavior, or a possible violation of law or policy.