3.1 Fair treatment of partners
Ubisoft is committed to dealing fairly with partners through every point of our professional relationships. This means all team members must make sure they follow a certain number of rules.
This begins with engaging in open and competitive bidding, where personal contacts do not bypass formal procurement processes. It continues with contacting the relevant internal experts to prepare for any negotiation, and never disclosing information during a bidding process which might give one supplier an unfair advantage over another.
The company also expects teams to honor the written agreements and never asking suppliers to work for free or without a contract.
As part of the above process, Ubisoft expects team members dealing directly with partners to ensure all procurement and legal processes are strictly applied, to make sure that partners respect human rights and fundamental freedoms, as well as the health and safety of their teams and environmental responsibilities. Likewise, team members must follow the social responsibility and corruption risk-analysis as part of their selection and routinely re-assess existing partners. By following the proper process, you help Ubisoft deliver on these commitments.
Team members should report to a manager, the purchasing team or the whistleblowing line any actions made by, or towards, our partners which conflict with this Code of Conduct.
For more information on our relationship with partners, you can contact the Procurement Team. If you have a specific question about a contract with one of our partners, you can contact the Legal Team.
For more information on the conflicts of interest, see our Code of Conduct’s section 3.6.
3.2 Trade restrictions and export controls
As a company operating globally, Ubisoft complies with regulations concerning export controls, financial sanctions and trade restrictions.
Economics and trade sanctions include controls which restrict dealings with certain countries or individuals. For some countries, these sanctions amount to complete export and import embargoes meaning that any kind of trade or other commercial activity with that country is prohibited.
“Export controls” regulate the movement of certain goods considered sensitive, such as valuable information or technology, for example by requiring government licenses to move them across borders.
Ubisoft expects team members:
In our sourcing activities, not to contract with partners based in territories/countries subject to comprehensive sanctions/embargoes or with partners subject to individual sanctions.
In our distribution activities, not to offer our products or services in those territories/countries (directly or through distributors).
Failure to comply with these rules may result in severe penalties, fines and damage to our reputation.
3.3 Fighting corruption and influence peddling
Ubisoft is committed to conducting its business with integrity, transparently and in compliance with applicable laws. We have therefore adopted a zero-tolerance policy on corruption and influence peddling in all their forms and under all circumstances.
Ubisoft expects every team member to respect this zero-tolerance approach to corruption and influence peddling, and to participate in the associated training sessions.
This means never:
Soliciting, promising, authorizing, offering or accepting anything of value or any other benefit in exchange for undue advantage or to influence a business decision.
Paying or providing anything of value to a public official in order to induce them to perform their ordinary duties or perform them more quickly (facilitation payments).
Participating in any decision-making (e.g. partner selections) in which we could be influenced by a conflict of interest.
Using an intermediary as a way to make improper payments or bribes.
Failure to comply with these principles may result in disciplinary measures and exposure to civil and criminal sanctions for both the team member and the company.
Countering corruption and influence peddling is everybody’s responsibility.
Ubisoft expects every team member to be vigilant and to report any instance of corruption, influence peddling or related situations via the Whispli speak-up system.
For example, in the context of Ubisoft’s activities, acts of corruption or influence peddling could be motivated (either by a team member or a partner):
To obtain or renew a contract to work with us, to favor the renewal or signing of a contract, to obtain favorable decisions (being awarded a tender, gaining advantageous contractual clauses…).
To pursue a commercial relationship.
To obtain a retro-commission or obtain a personal service.
To obtain an undue advantage in exchange for donations to associations.
To obtain confidential and strategic information from Ubisoft in exchange of money, gifts or invitations.
To favor a recruitment of a relative.
For more information on the conflicts of interest, see our Code of Conduct’s section 3.6. Regarding gifts and invitations, see section section 3.4. About community involvement, see section 5.1.
3.4 Gifts and invitations
Gifts and invitations are an ordinary part of business life when they are a mark of courtesy to maintain quality business relationships.
However, in certain circumstances, gifts and invitations can be, or be perceived as, an act of bribery or corruption intended to influence a decision in favor of Ubisoft, a third party or an individual.
Ubisoft is committed to avoiding any exchange of gifts or invitations that could be perceived as bribery or dishonest activity.
Ubisoft therefore expects all team members to ensure under all circumstances that gifts and invitations, whether given or received, are:
Not exchanged at inappropriate times such as during partner assessments or selections, negotiations, signing or renewal of contracts or advantageous contractual clauses, etc.
Not made with the expectation of any obligation, influence or undue advantage in return.
Reasonable: by respecting the annual financial thresholds for each country as defined in Ubisoft’s Gifts and Invitations Policy.
Occasional i.e., not regular, frequent or systematic.
Transparent i.e., exchanged openly and without any concealment.
Compliant with all applicable local procedures and laws.
Failure to comply with these principles, our ‘Gifts and Invitations Policy’ or related laws, may result in disciplinary measures and exposure to civil or criminal sanctions, for the company as well as team members.
The company expects team members to follow the Gifts and Invitations Policy, which also addresses the case of business-related meals and the coverage of business travel & hospitality expenses for event invitations.
For more information on fighting corruption and influence peddling, see our Code of Conduct’s section 3.3.
3.5 Responsible lobbying
Ubisoft strives to act in a spirit of cooperation, transparency and mutual benefit with public institutions such as government bodies and local authorities. However only authorized team members may represent Ubisoft in discussions with public bodies.
Ubisoft is committed to ensuring that all of its lobbying-related activities are conducted legally and ethically, and we expect partners to adopt this same approach and principles.
Team members approved to engage in lobbying-related activities are registered and these activities are formally declared where the law requires it.
If Ubisoft employs an individual or organization to assist with lobbying-related activities, they must be open about the fact they are working for Ubisoft and follow Ubisoft’s rules on gifts, invitations and bribery.
As a team member, you cannot solicit directly or indirectly an elected official, a cabinet official, a ministry representative or a government-related agency on any Ubisoft-related matter. If you require government intervention on any matter, please refer to Corporate Affairs. If you are solicited directly or indirectly by an elected official, a cabinet official, a ministry representative or a government-related agency, on any Ubisoft-related matter, you must also refer such solicitation to Corporate Affairs.
Also, if you are invited to sit on the board of an organization in connection with government institutions, NGOs or advocacy bodies, or to participate in a specific mission initiated by such an organization, you might be perceived as representing Ubisoft.
In such a case, you must make sure you make it clear that you are acting in your own personal capacity. If you have a doubt about an invitation you have just received and wonder if you were invited in your personal or professional capacity, ask yourself the following questions:
How did the invitation arrive: were you reached through a corporate email address?
Are the membership fees of the organization paid by Ubisoft? Is Ubisoft a sponsor of the organization?
How is your affiliation with Ubisoft perceived by those who invited you: were you invited because you work for Ubisoft?
If the answer to one of those questions is ‘yes’, you should get in touch with the Corporate Affairs Department.
At any rates, if you are representing Ubisoft in any capacity, it is essential to note the following points:
You must make sure Corporate Affairs is informed of your participation on the Board of an organization in connection with a government / institutions / NGO / advocacy bodies, or a specific mission initiated by such an organization.
You must be trained to recognize and avoid conflicts of interest and you must know what Ubisoft’s positions are on the subjects of the day. You must not misrepresent Ubisoft’s positioning or present your own ideas as the company’s.
After any such external meeting/event or when you are participating actively in the management of an institution/association on a longer-term basis, you must make sure that Corporate Affairs department knows what has been discussed and provide feedback to Ubisoft so that we can develop our positioning on the issues at hand.
If you are in doubt or have concerns about activities that might conflict with our commitments on lobbying, you can speak to the Corporate Affairs Department.
3.6 Conflicts of interest
Ubisoft is dedicated to creating a work environment in which decisions are made fairly and in the best interests of the company as a whole.
However, any team member may find themselves confronted with situations of conflict of interest, in which their personal interest, or that of individuals or entities to which they are linked may come into conflict with the interest of Ubisoft.
It doesn’t matter if the intentions are good, even a perceived conflict of interest can have negative impact and legal implications for Ubisoft and the teams involved.
Conflicts of interest can also sometimes reveal situations of corruption, influence peddling or favoritism.
Ubisoft expects team members to always act with integrity, impartiality, fairness and in compliance with the law. When they are or believe to be confronted with a risk of conflict of interest, team members must immediately inform their direct manager before taking any further action.
Team members who have been witness to a conflict of interest are expected to report it immediately, using the Whispli speak-up system.
A few examples of conflicts of interest:
a team member’s relative owns a company that wants to work with Ubisoft. If team members can decide whether to award their family’s company a contract, that is a conflict of interest, as there is a risk of unfair preferential treatment.
a team member intervenes in order to favor the recruitment of a relative at Ubisoft.
a team member participates in a project that would be in competition with the activities of an organization in which the person concerned exercises functions.
For more information on the personal relationships at work, see our Code of Conduct’s section 1.7.
3.7 Respect for open and fair competition
Ubisoft commits to being fair in its dealings with competitors, consumers and partners.
In practice, this commitment means we never engage in any discussions with our competitors about pricing, market segmentation, or any other behavior that might reduce competition in the industry and increase prices.
Ubisoft also chooses its partners objectively and never selects any suppliers, distributors or other business partners based on any form of agreement with competitors.
Ubisoft expects all team members to know and understand these principles, especially if they interact with our competitors directly or indirectly as part of their role.
3.8 Prevention of money laundering
Money laundering is a process that turns illegally earned money into seemingly legitimate funds. Companies are sometimes targeted by criminals who see an opportunity to engage in money laundering through the company’s assets.
Ubisoft is committed to preventing money laundering in all its forms.
Money laundering can take many forms. It is important for us to be vigilant to these risks, in order to preserve the company’s reputation, maintain the trust of our shareholders, business partners and players, and avoid severe criminal sanctions or fines.
Ubisoft expects all team members to remain alert to the potential warning signs of money laundering, especially if they are working with external partners. Warning signs include:
Payments that look unusual such as being unexpectedly large, in the wrong currency or from unknown accounts or partners.
Situations in which partners insist on cash payment.
Payments where the paperwork does not match the activity taking place.
Transactions in which the requested payment method is not transparent, accurate or properly recorded.
To mitigate the risks, team members must abide by contractual terms and processes, ensure our transactions are maintained in a transparent, accurate and complete manner, declare conflicts of interest, avoid payments in cash, and be thoughtful when designing our in-game monetization systems.