Vendor Code of Conduct

Getty Images is committed to sustaining our reputation as a company of integrity. To that end, Getty Images has established a set of company standards of business practices and regulatory compliance which are set out in the Code of Business Conduct which applies to all Getty Images employees, contractors, officers and directors. Getty Images expects that its Vendors will also share and embrace the letter and spirit of our commitment to integrity and will adhere to the highest standards of legal, ethical and professional behavior in their business activities and relationships on behalf of the company. Accordingly, Getty Images has established this Vendor Code of Conduct (the “Code”).

Getty Images understands that Vendors are independent entities. However, since the business practices of a vendor may reflect upon Getty Images, we require all Vendors and their representatives, employees, agents and subcontractors (hereinafter referred to collectively as “Vendor”) to adhere to this Code while they are conducting business with or on behalf of Getty Images. All Vendors should ensure that their representatives understand and will comply with this Code. Vendor representatives shall be provided with a copy of this Vendor Code of Conduct upon entering the premises of Getty Images and, if working with Getty Images remotely, shall be deemed to have been provided a copy by Getty Images in advance of any work performed on or on behalf of Getty Images.

While we have outlined several important topics within this Code, not all situations may be addressed in this Code. Therefore, we ask that you consult your contact person at Getty Images or a member of our legal group for clarification if you have any questions about this Code. The terms of a specific contract between you and Getty Images may contain additional provisions addressing some of these same subjects. Nothing in this Code is meant to supersede any more specific provision in a particular contract, and to the extent there is any inconsistency between this Code and any provision of a particular contract, the contract provisions control. This Code is not meant to supersede any law. Vendors shall comply with all applicable laws and regulations in every jurisdiction where they operate.

Business Practices

Theft, carelessness and waste have a direct impact on Getty Images’ profitability. Getty Images’ Vendors shall, in addition to Vendor’s specific obligations of an agreement with Getty Images, conduct their business with integrity and in accordance with their obligations under their agreement(s) with Getty Images. Additionally, Vendor shall comply with the following practices:

Use good judgment when offering gifts or favors to any Getty Images employee. Vendors covered by this policy may not give any gifts or favors to any Getty Images employee (other than a gift of nominal value — less than US$500 in a given year) without the prior consent of the senior vice president to whom that employee receiving the gift reports to. In no event should a Vendor give any gift in any form to include cash, stocks, bonds, options, loans, or guarantees of loans. Gifts or favors may not be given with the purpose, or perceived purpose, of influencing someone in connection with Getty Images’ business or in an effort to gain a business advantage.
Use Getty Images provided information technology and systems (including email) only for authorized business-related purposes. Getty Images strictly prohibits Vendors and their Representatives from using its technology and systems to create, access, store, print, solicit, or send any material that is intimidating, harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate and/or send any false, derogatory, or malicious communications using, through or to Getty Images provided information assets and systems.
Comply with all Getty Images regulations concerning information technology and systems, including Getty Images’ Security Standards. All data stored or transmitted on Getty Images’ owned or leased equipment is to be considered private and/or proprietary and is the property of Getty Images. Getty Images may in its sole discretion monitor all use of its network(s) and all systems (including email) and/or access all data stored or transmitted using its network(s).
Comply with all intellectual property rights of Getty Images, including but not limited to patents, copyrights, trademarks and trade secrets. Vendor shall implement and maintain security safeguards, including administrative, physical and technical safeguards designed to protect its information systems from unauthorized access, and shall promptly inform Getty Images if it believes its systems have been compromised in a manner that could result in harm to Getty Images. Vendors must use Getty Images’ confidential information, data, trade information, copyrights, and trademarks only in a manner that is permitted under their contracts with Getty Images and at a minimum protect such information with a reasonable degree of care. Vendors shall not misappropriate or infringe upon the trade information, trademarks, or copyrighted works of others. Vendors must not misuse trade secrets or proprietary or confidential information of others or disclose such information to unauthorized third parties. Vendors must promptly notify Getty Images of any unauthorized use of Getty Images’ data, trade secrets, trademarks, logos or confidential information by Vendor or a third party.
Publicly represent Getty Images to the press only where expressly authorized to do so in writing by Getty Images.
Avoid the appearance of or actual improprieties and/or conflicts of interest. Any questions regarding the existence of such impropriety and/or conflict of interest shall be directed promptly to Getty Images’ General Counsel at 206-925-5000.

Legal and Regulatory Practices

All Vendors shall comply with all applicable laws and regulations while conducting their business with Getty Images. Specifically, Vendor shall:

Comply with anti-bribery and corruption laws in all countries where they do business, including the United States Foreign Corrupt Practices Act and the UK Bribery Act. Bribes or other means of obtaining undue or improper advantage shall not be promised, offered, authorized, given or accepted. Vendors also shall not promise, offer, authorize, give or accept anything of value in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage. Facilitation payments to speed up the performance of routine governmental function are also prohibited. Vendors shall not engage third parties to do anything that Vendors are prohibited from doing directly as set out herein.
Comply with all applicable antitrust and fair competition laws in countries in which they conduct business.
Comply with all applicable environmental laws and regulations, including permit and reporting requirements. Getty Images is committed to social responsibility and doing its part to protect the environment, and we encourage our Vendors to do the same. Vendors shall look for cost effective methods to improve energy efficiency and to minimize their energy consumption and greenhouse gas emissions. For our manufacturing Vendors, we also require: pollution prevention and resource reduction; safe handling, storage, movement, use and disposal of hazardous substances and chemicals; controlled use and reduction of wastewater; and monitoring and control of air emissions (including volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products).
Comply with all applicable trade control laws as well as all export and import requirements in addition to any destination restrictions issued by U.S. and other governments and the U.S. Export Administration. These include laws on the import and export of goods; transactions with certain sanctioned entities, persons, or countries; and anti-boycott laws: (i) Import/Export Laws: Many countries have laws that restrict the export and import of “dual use” items. These are items (such as goods, software or technology) that can be used for both civilian and military applications (such as night vision equipment or satellite phones); (ii) Sanctions Laws: The U.S., UK, and UN, as well as other countries in which you do business, have imposed trade sanctions that target certain entities, persons, territories or countries on a lists maintained by the U.S. Treasury Department’s Office of Foreign Asset Control (OFAC), and its equivalent in other countries. Affected countries and territories include, but are not limited to, Iran, Iraq, Syria, Cuba, North Korea, Libya, Balkans, Burma, Belarus, DR of Congo, Sudan and Yemen, and are subject to change at any time. You can find out more at www.treasury.gov/resource-center/sanctions.aspx; (iii) Anti-Boycott Laws: Vendors must also comply with U.S. anti-boycott laws. These laws prohibit companies, such as Vendors, from participating in any international boycotts not sanctioned by the U.S. government .
Be forthright, honest and direct in all dealings with regulatory agencies and government officials.
Disclose all information regarding Vendor’s labor, health and safety, environmental practices, business activities, structure, financial situation and performance in accordance with applicable laws and regulations and prevailing industry practices. Vendors shall not misrepresent activities in their disclosures.

Fair Employment Practices

Getty Images expects its Vendors to share its commitment to human rights and equal opportunity in the workplace. Accordingly, all Getty Images Vendors shall:

Practice employment practices that promote consistency and fair treatment based on legitimate job-related criteria.
Provide a work environment free of unlawful discrimination or bias and ensure that all its employees and applicants are treated in a non-discriminatory manner. Comply with all applicable federal, state or local laws prohibiting discrimination based on race, religion, sex, (and gender- related conditions including pregnancy, childbirth and related medical conditions), national origin, age, sexual orientation, disability, veteran’s status or any other basis prohibited by federal, state or local law. Vendors shall treat employees with dignity and respect and provide a work environment that is free from harassment and abuse. Vendors shall not engage in hiring or employment practices that discriminate based on traits unrelated to the performance of an employee’s job. Workers shall be provided with reasonable accommodation for religious practices. In addition, workers or potential workers shall not be subjected to medical tests or physical exams that could be used in a discriminatory way.
Comply with all local, state and/or national labor laws, including local minimum working age laws, overtime laws, and child labor laws. The term “child” refers to any person under the age of 15, or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. Workers under the age of 18 (Young Workers) shall not perform work that is likely to jeopardize their health or safety, including night shifts and overtime. Vendors shall ensure proper management of student workers through proper maintenance of student records, rigorous due diligence of educational partners, and protection of students’ rights in accordance with applicable law and regulations. Vendors shall provide appropriate support and training to all student workers. In the absence of relevant local law, the wage rate for student workers, interns and apprentices shall be at least the same wage rate as other entry-level workers performing equal or similar tasks.
Provide a safe and healthy work environment and comply with all applicable environmental, health and safety laws and regulations including: occupational safety (limiting workers exposure to potential safety hazards); emergency preparedness (implementation of emergency plans and response procedures, including worker training and drills); occupational injury and illness prevention and reporting; industrial hygiene (control and limit exposure to chemical, biological and physical agents); limiting of physically demanding work and safeguarding for heavy or dangerous machinery use; access to a clean and safe work environment (including clean toilet facilities, potable water and sanitary food preparation); and clear communication of health and safety information.
Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. Vendors shall compensate workers for overtime in accordance with local laws. Deductions from wages as a disciplinary measure shall not be permitted. For each pay period, workers shall be provided with a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work performed. All use of temporary, dispatch and outsourced labour shall be in accordance with local law.
Keep employee records in accordance with applicable laws and regulations.
In accordance with local law, Vendors shall respect the right of all workers to form and join trade unions of their own choosing, to bargain collectively and to engage in peaceful assembly, as well as respect the right of workers to refrain from such activities. Workers and/or their representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management practices without fear of discrimination, reprisal, intimidation or harassment.
There shall be no harsh or inhumane treatment including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers; nor is there to be the threat of any such treatment. Disciplinary policies and procedures in support of these requirements shall be clearly defined and communicated to workers.

Fair Dealing

Getty Images is committed to creating business opportunities with integrity. Each Vendor is expected to use fair dealing in its interactions with Getty Images employees, agents, subcontractors and Vendors. You may not take unfair advantage of anyone through manipulation, concealment, abuse of privileged and confidential information, misrepresentation of facts or any other unfair-dealing practice.
The highest standards of integrity are to be upheld in all business interactions. Vendors must respect the customs, rules, practices, and codes of conduct that apply to Getty Images’ industry and practice areas in all countries where Vendor provides services to Getty Images, including those related to Getty Images’ clients, colleagues, and fellow professionals. Vendors shall have a zero-tolerance policy and prohibit any and all forms of bribery, corruption, extortion and embezzlement.
All business dealings shall be transparently performed and accurately reflected in Vendor’s business books and records and Vendor shall comply with all applicable legal and regulatory requirements regarding the creation, retention and disposal of business records. Vendors will not make any false representations or provide false information or data to Getty Images or in connection with any transaction or work involving Getty Images or its clients. This includes making false statements of fact or supplying or using false data. Vendors must only accept work for which they are suitably skilled and experienced. Vendors should stay informed about the practices in the profession to ensure ethical conduct and delivery of quality products and services to Getty Images and its clients. Monitoring and enforcement procedures shall be implemented to ensure Vendor’s business practices comply with these requirements.

Privacy & Data Protection

Vendors shall maintain internal policies and procedures reasonably designed to protect data provided by Getty Images or obtained by the Vendor or any of its subcontractors on behalf of Getty Images or its clients (“Getty Images data”). Vendors shall comply with all applicable laws relating to privacy, and the processing of personal data that may exist in any relevant jurisdiction, including, where applicable, the guidance and codes of practice issued by the supervisory authorities including but not limited to EU-U.S. and Swiss-U.S. Privacy Shield as set forth by the US Department of Commerce, European Directives 95/46/EC and 2002/58/EC (as amended by Directive 2009/136/EC) and any legislation and/or regulation implementing or made pursuant to them, or which amends, replaces, re-enacts or consolidates any of them (including the General Data Protection Regulation (Regulation (EU) 2016/279)) (individually and collectively, “Data Protection Laws”). Vendors shall execute appropriate data transfer agreements with Getty Images in any form that Getty Images or its clients are required by applicable laws to execute with service providers or to flow down to subcontractors. Vendor shall provide a minimum of 30 days’ notice to Getty Images before engaging a new subcontractor to process Getty Images data and shall obtain Getty Images’ consent before allowing any subcontractor to process or otherwise handle Getty Images data.
Vendor shall promptly notify Getty Images if Vendor determines that Vendor can no longer provide this level of protection. In such event, or if Getty Images otherwise believes reasonably that Vendor is not protecting the Personal Data to the standard required under the Data Protection Laws, Getty Images may either: (a) instruct Vendor to take reasonable and appropriate steps to stop and remediate any unauthorized processing, in which event Vendor shall promptly cooperate with Getty Images in good faith to identify, agree and implement such steps; or (b) terminate any master services agreement, memorandum of agreement, purchase orders, releases or other means of ordering goods or services between Vendor and Getty Images (each, an “Agreement”) without penalty by giving notice to Vendor. Vendor acknowledges that Getty Images may disclose this Code and any relevant privacy provisions in the Agreement to the US Department of Commerce, the Federal Trade Commission or data protection authority upon their request and any such disclosure shall not be deemed a breach of confidentiality.
Vendor will implement industry standard physical, administrative and technical security controls and provide appropriate technical and organizational measures to protect personal data against accidental or unlawful destruction or accidental loss, alternation, unauthorized disclosure or access.

Confidentiality

All Vendors are expected to maintain the confidentiality of any confidential information of Getty Images (or that of our customers) that is disclosed to them. Confidential information includes all non-public information that would be of use to competitors, or harmful to the company or its customers, if disclosed. This would include things like marketing plans, budgets, pricing information, customer lists, unpublished financial information, new revenue opportunities and proprietary technology information. All Vendors are required to execute and to hold their Representatives to the terms of the Getty Images’ Non-Disclosure Agreement.

Compliance with the Vendor Code of Conduct

Vendor shall ensure that its representatives understand and comply with the Code and shall inform its Getty Images’ contact (or a Getty Images manager) if it becomes aware of any situation in which it believes that Vendor is operating in violation of the Code. Vendors are expected to self-monitor their compliance with this Vendor Code of Conduct. In addition to any other rights Getty Images may have under its agreement with Vendor, Getty Images may request the immediate removal of any Vendor who behaves in a manner that is against the law or is in violation of this Code or any Getty Images policy.

How to Report any Illegal or Unethical Behavior

Vendors should either (i) maintain a whistleblower hotline or similar process for its employees to report violations of this Code or any related integrity concerns involving work for Getty Images, or (ii) allow its employees to have access to the Getty Images Whistleblower Hotline. Vendors shall maintain programs to ensure the confidentiality, anonymity and protection of Vendor and employee whistleblowers, unless prohibited by law. In either case, Vendors have an affirmative obligation to promptly report to Getty Images any information or allegation it receives related to a violation of this Code of Conduct. A Vendor must also promptly inform Getty Images if it becomes aware that any employee or any third party has raised any claim or complaint against Getty Images. All reports to Getty Images should be made at https://gettyimages.alertline.com/gcs/welcome. If you become aware of any situation you believe constitutes a breach of this Code or any other type of legal or ethical violation, we encourage you to communicate this to your Getty Images contact immediately. However, we recognize that there may be instances in which this is not possible or appropriate. In such instances, please contact Getty Images General Counsel. You may also report concerns regarding accounting, financial, auditing or internal controls by calling 1-800-425-0889.

All violations will be addressed promptly, professionally and with the appropriate level of confidentiality. Getty Images will not retaliate, nor will it tolerate any retaliation, against any individual who in good faith reports a violation or potential violation of the Code, or any other applicable law or regulation.