Bigo Business Partner Code of Conduct
This Business Partner Code of Conduct ("Code") establishes the standards and responsibilities that each Business Partner must adhere to. All Business Partners are expected to maintain these standards in their daily operations, comply with all applicable policies and procedures, and ensure that their employees, agents, and downstream suppliers are aware of, understand, and follow these standards. However, this Code is not intended to be exhaustive or to address every possible situation. Additionally, the principles and requirements outlined in this Code are not intended to replace, supersede, modify, or conflict with any applicable legal or regulatory requirements, nor with a Business Partner's contractual obligations with Bigo, its affiliates, and subsidiaries (“Bigo”).
"Business Partners" in this Code refers to all third parties, including but not limited to suppliers, service providers, agents, vendors, resellers, distributors, broadcasters, hosts, broadcaster agents and consultants who provide any kind of products or services or undertake any activity for or on behalf of Bigo ("Business Partners").
Business Partners are responsible for ensuring that all of its employees and any of its service providers and subcontractors performing work for, or related to, Bigo, are informed of, and agree to comply with, the requirements contained in the Code. Bigo will assess a Business Partners’ commitment to compliance with these requirements when entering into a contract or renewing a contract with its Business Partners.
3.1 Compliance with the Code and Laws
Business Partners are obligated to adhere to this Code while conducting business with or on behalf of Bigo. They must also ensure compliance with all applicable laws and regulations in the countries where they operate and provide goods and services. In instances where this Code establishes standards that exceed those required by local laws, the Business Partner is expected to adhere to the standards outlined in this Code.
3.2 Anti-Bribery and Anti-Corruption
Bigo is committed to conducting business with honesty and integrity, maintaining a zero-tolerance policy toward any form of unlawful or unethical behavior. This includes, but is not limited to, corruption, bribery, fraud, extortion, embezzlement, and kickbacks. To foster transparent and trustworthy business relationships, Business Partners are required to uphold these same standards.
Business Partners must comply with all applicable anti-corruption laws and regulations in the countries where they operate, as well as international anti-corruption conventions, the contractual obligations with Bigo, and Bigo’s relevant policies and procedures. Business Partners must not make, authorize, or facilitate any direct or indirect payments—including loans, gratuities, funds, gifts, hospitality, or anything of value—to any government official, employee, political party, or candidate in any country, nor to any private entity or individual, for the purpose of (1) obtaining or retaining business, or (2) directing business to any other person or entity. This prohibition extends to authorizing such payments—whether in cash or otherwise—through a third party, if the Business Partner or supplier knows or has reason to believe that any portion of the payment will be used for these purposes.
3.3 Conflict of Interest
Business Partners are required to avoid any actual or potential conflicts of interest with Bigo. A "Conflict of Interest" refers to any personal interest or activity of a Business Partner or its employees that affects, or appears to affect, their ability to act in Bigo's best interests. For example: in principle, one Business Partner should not hold multiple positions simultaneously. Prior to the commencement of, and throughout the duration of the business relationship, Business Partners must promptly disclose to Bigo any actual or potential conflicts of interest, including those that may arise or are anticipated to arise from relationships between the Business Partner or its employees and Bigo, its employees, former employees, or representatives. Business Partners must cooperate with Bigo to implement effective measures to avoid or mitigate any potential impact of such circumstances on the existing or proposed commercial relationship between the parties.
3.4 Anti-Fraud
Bigo is committed to maintaining the highest standards of integrity and transparency in all business operations. Fraudulent activities, in any form, are strictly prohibited and will not be tolerated under any circumstances.
Fraud includes, but is not limited to, any intentional act or omission designed to deceive others, resulting in financial or personal gain. This may involve (i) illegal consumer frauds, scams, and other deceptive business practices involving Bigo (e.g., frauds carried out through Bigo platforms) that result in financial or other losses to individuals or entities; and (ii) frauds committed directly against Bigo.
Business Partners are responsible for implementing effective internal controls to detect, prevent, and report any suspected fraudulent activity. This includes, but is not limited to: 1) all financial records, invoices, and other documentation must be accurate, complete, and reflect the true nature of transactions; 2) Business Partners must maintain transparency in their dealings with Bigo, ensuring that all information provided is truthful and accurate.
Business Partners are expected to fully cooperate with any investigations conducted by Bigo or relevant authorities into suspected fraudulent activities. This includes providing access to relevant records, employees, and other information as required.
3.5 Fair Competition
Business Partners should comply with all applicable antitrust and competition laws in the regions where they operate and avoid any activities that could be seen as anti-competitive, such as price-fixing, bid-rigging, or coordinating with competitors in a way that harms competition.
Business Partners must not exchange information, engage in discussions, or enter into formal or informal agreements with competitors regarding competitively sensitive matters such as pricing, profits, costs, or other similar terms.
3.6 Trade Compliance
Business Partners will operate its business in compliance with all applicable trade laws and regulations, such as export controls, embargoes, sanctions, and other restrictions imposed by governments or international bodies.
3.7 Anti-Money Laundering
Business Partners are strictly prohibited from engaging in or facilitating money laundering or terrorist financing, which involve the concealment of the origins of funds obtained through criminal activities by making them appear to originate from legitimate sources. Business Partners are required to conduct their operations in full compliance with all applicable anti-money laundering and anti-terrorism financing laws in the jurisdictions where they operate. In order to prevent any violations of such laws, Business Partners must implement and maintain a robust compliance program, including but not limited to conducting appropriate due diligence, maintaining accurate records of transactions and avoiding large cash payments or transactions that could be used to conceal the origins of illicit funds.
3.8 Insider Trading
Business Partners are expected to adhere to the highest ethical standards, including strict compliance with insider trading laws and regulations. Insider trading involves buying, selling, or trading securities based on material non-public information (“MNPI “) that could influence an investor's decision. If, in the course of business relationship, Business Partners come into possession of MNPI related to Bigo or any other entity, they must not engage in any securities transactions or share this information with others until it has been publicly disclosed and is no longer considered non-public.
3.9 Intellectual Property
Business Partners must respect the intellectual property rights of Bigo and any third parties. Unauthorized use, reproduction, distribution, or alteration of Bigo’s IP or that of others, including but not limited to trade secrets, know-hows, patents, copyrights, trademarks, and source codes, is strictly prohibited.
3.10 Information Security and Data Protection
Business Partners must comply with all applicable laws and regulations on cybersecurity, privacy, and data protection in their respective countries of operation and the countries or regions where Bigo operates.
Business Partners shall respect internationally recognized human rights and respect the dignity, personal privacy, and fundamental rights of every individual in accordance with applicable labor and employment laws, regulations, and the standards set forth in this Code.
4.1 Child Labor and Young Workers
Business Partners must comply with all applicable laws and regulations in their country relating to minimum working age, and must not use child labor in any form. Business Partners must implement an appropriate mechanism to verify the age of workers during hiring. Workers under the age of 18 must not perform work that may jeopardize their health or safety.
4.2 Freely Chosen Employment
Business Partners must ensure that all workers are employed on a purely voluntary basis. Business Partners must not employ any form of slave labor (including all forms of modern slavery), forced labor, bonded labor, indentured labor, or prison labor. Business Partners must not restrict workers' freedom of movement, retain workers' identity documents, or engage in any form of human trafficking. This includes transporting, harboring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labor or services.
4.3 Working Hours, Wages, and Benefits
Business Partners must comply with all applicable laws and regulations relating to working hours and breaks. Compensation paid to workers must comply with all applicable wage laws, including those relating to minimum wages, overtime hours, and legally mandated benefits.
All Business Partners are expected to uphold high standards for the health and safety of their employees. Business Partners agree to:
This Code is an integral part of our agreement with Business Partners. Business Partners who engage in unlawful conduct or act in a manner inconsistent with this Code risk the termination of their business relationship with Bigo and may be required to compensate Bigo for any resulting loss or damage.
Business Partners are required to maintain documentation sufficient to demonstrate their compliance with this Code. Bigo reserves the right to audit and verify Business Partners' adherence to this Code, in accordance with applicable laws or as specified in agreements. These audits may be conducted by Bigo directly or through third parties appointed for this purpose. The procedures and arrangements for such audits will be agreed upon in advance with Business Partners.
If a Business Partner becomes aware of or suspects a violation of this Code, it is its responsibility to promptly report the matter to Bigo, which will then investigate the issue. All questions and reports of known or suspected violations will be handled with sensitivity and discretion. Failure to comply with applicable laws or this Code may have serious consequences for both Business Partners and Bigo. Bigo’s policy is that any Business Partner who violates this Code will be subject to appropriate action, including possible termination of engagement, depending on the facts and circumstances of each particular case.
Business Partners are expected to effectively communicate the expectations and requirements outlined in this Code to all employees, board members, officers, managers, agents, subcontractors, or any other third parties acting on their behalf in connection with Bigo's business activities.
Business Partners are required to report to Bigo any conduct by their employees or representatives, as well as any conduct by Bigo’s employees or representatives, that is believed in good faith to constitute an actual, apparent, or potential violation of this Code. Reports should be submitted to [email protected] and will be treated with the utmost confidentiality.