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The Google Code of Conduct is one of the ways we put Google’s values into practice. It’s built around the recognition that everything we do in connection with our work at Google will be, and should be, measured against the highest possible standards of ethical business conduct. We set the bar that high for practical as well as aspirational reasons: Our commitment to the highest standards helps us hire great people, build great products, and attract loyal users. Respect for our users, for the opportunity, and for each other are foundational to our success, and are something we need to support every day. So please do read the Code and Google’s values, and follow both in spirit and letter, always bearing in mind that each of us has a personal responsibility to incorporate, and to encourage other Googlers to incorporate, the principles of the Code and values into our work. And if you have a question or ever think that one of your fellow Googlers or the company as a whole may be falling short of our commitment, don’t be silent. We want – and need – to hear from you. Who Must Follow Our Code?We expect all of our employees and Board members to know and follow the Code. Failure to do so can result in disciplinary action, including termination of employment. Moreover, while the Code is specifically written for Google employees and Board members, we expect members of our extended workforce (temps, vendors, and independent contractors) and others who may be temporarily assigned to perform work or services for Google to follow the Code in connection with their work for us. Failure of a member of our extended workforce or other covered service provider to follow the Code can result in termination of their relationship with Google. What If I Have a Code-Related Question or Concern?If you have a question or concern, don’t just sit there. You can contact your manager, your Human Resources representative or Ethics & Business Integrity. You can also submit a question or raise a concern of a suspected violation of our Code or any other Google policy through the Alphabet Helpline. If you believe a violation of law has occurred, you can always raise that through the Alphabet Helpline or with a government agency. If you have a misconduct concern about the CEO, a direct report to the CEO, or a Senior Vice President, you may also notify the Audit Committee of Alphabet’s Board of Directors. To notify the Audit Committee, please mail your concern to: Alphabet Inc. Attn: Workplace Concern 1600 Amphitheatre Parkway Mountain View, CA 94043 You may report your concerns to the Audit Committee anonymously. However, the Audit Committee encourages you to provide your name and contact information so that we may contact you directly if necessary. No RetaliationGoogle prohibits retaliation against any worker here at Google who reports or participates in an investigation of a possible violation of our Code, policies, or the law. If you believe you are being retaliated against, please contact to Ethics & Business Integrity. I. Serve Our UsersOur users value Google not only because we deliver great products and services, but because we hold ourselves to a higher standard in how we treat users and operate more generally. Keeping the following principles in mind will help us to maintain that high standard:
II. Support and Respect Each Other
III. Avoid Conflicts of InterestWhen you are in a situation in which competing loyalties could cause you to pursue a personal benefit for you, your friends, or your family at the expense of Google or our users, you may be faced with a conflict of interest. All of us should avoid conflicts of interest and circumstances that reasonably present the appearance of a conflict. When considering a course of action, ask yourself whether the action you’re considering could create an incentive for you, or appear to others to create an incentive for you, to benefit yourself, your friends or family, or an associated business at the expense of Google.If the answer is “yes,” the action you’re considering is likely to create a conflict of interest situation, and you should avoid it. Below, we provide guidance in seven areas where conflicts of interest often arise:
In each of these situations, the rule is the same – if you are considering entering into a business situation that creates a conflict of interest, don’t. If you are in a business situation that may create a conflict of interest, or the appearance of a conflict of interest, review the situation with your manager and Ethics & Business Integrity. Finally, it’s important to understand that as circumstances change, a situation that previously didn’t present a conflict of interest may present one. Personal InvestmentsAvoid making personal investments in companies that are Google competitors or business partners when the investment might cause, or appear to cause, you to act in a way that could harm Google. When determining whether a personal investment creates a conflict of interest, consider the relationship between the business of the outside company, Google’s business, and what you do at Google, including whether the company has a business relationship with Google that you can influence, and the extent to which the company competes with Google. You should also consider 1) any overlap between your specific role at Google and the company’s business, 2) the significance of the investment, including the size of the investment in relation to your net worth, 3) whether the investment is in a public or private company, 4) your ownership percentage of the company, and 5) the extent to which the investment gives you the ability to manage and control the company. Investments in venture capital or other similar funds that invest in a broad cross-section of companies that may include Google competitors or business partners generally do not create conflicts of interest. However, a conflict of interest may exist if you control the fund’s investment activity. Outside Employment, Advisory Roles, Board Seats, and Starting Your Own BusinessAvoid accepting employment, advisory positions, or board seats with Google competitors or business partners when your judgment could be, or could appear to be, influenced in a way that could harm Google. Additionally, because board seats come with fiduciary obligations that can make them particularly tricky from a conflict of interest perspective, you should notify your manager before accepting a board seat with any outside company. Google board members and employees who are VP and above should also notify Ethics & Business Integrity. Finally, do not start your own business if it will compete with Google. Business Opportunities Found Through WorkBusiness opportunities discovered through your work here belong first to Google, except as otherwise agreed to by Google. InventionsDeveloping or helping to develop outside inventions that a) relate to Google’s existing or reasonably anticipated products and services, b) relate to your position at Google, or c) are developed using Google corporate resources may create conflicts of interest and be subject to the provisions of Google’s Confidential Information and Invention Assignment Agreement and other employment agreements. If you have any questions about potential conflicts or intellectual property ownership involving an outside invention or other intellectual property, consult Ethics & Business Integrity or Legal. Personal Relationships at WorkCertain relationships within Google may compromise or be seen to compromise your ability to perform your job responsibilities, may create uncomfortable or conflicted positions, and may raise issues of fairness, favoritism, or harassment. Therefore, be mindful of how your relationships within Google could impact or be perceived by others. Romantic, physical or familial relationships are not permitted between a Googler and another Googler or member of the extended workforce where one individual is in a position to exercise authority or supervision over the other. This prohibition includes any situation where one person is in the reporting line of the other, or, for example, a situation where one person is a project or a technical lead on a project on which the other person is working. For more information, see the Policy on Personal Relationships at Work. Accepting Gifts, Entertainment, and Other Business CourtesiesAccepting gifts, entertainment, and other business courtesies from a Google competitor or business partner can easily create the appearance of a conflict of interest, especially if the value of the item is significant. Google’s Non-Government Related Gifts & Client Entertainment Policy provides specific guidance on when it is appropriate for Googlers to accept gifts, entertainment, or any other business courtesy (including discounts or benefits that are not made available to all Googlers) from any of our competitors or business partners. Generally, acceptance of inexpensive “token” non-cash gifts is permissible. In addition, infrequent and moderate business meals and entertainment with clients and infrequent invitations to attend local sporting events and celebratory meals with clients can be appropriate aspects of many Google business relationships, provided that they aren’t excessive and don’t create the appearance of impropriety. Before accepting any gift or courtesy, consult the Non-Government Related Gifts & Client Entertainment Policy, and be aware that you may need to obtain manager approval. Contact Ethics & Business Integrity if you have any questions. See the discussion of Anti-Bribery Laws in Section VII(d) for guidance on when it is appropriate to give gifts and business courtesies in the course of doing Google business. Use of Google Products and ServicesAvoiding potential conflicts of interest also means that you should not use Google products, services, internal tools, or information in a way that improperly benefits you or someone you know or creates the appearance that you have an unfair advantage over users outside of Google. For example, you should never approve Google accounts, services, or credits for yourself, your friends, or family members. Similarly, you should not use the tools, information, or access that you have as a Googler to participate in or to generate a financial benefit for yourself or others from invalid ad traffic (IVT) on Google products, such as generating IVT, purchasing or selling IVT (except for the purposes of company sanctioned research), or linking to (or appearing to link to) business partners that may be engaging in IVT. If you find yourself subject to a conflict of interest regarding the use of Google’s products, services, tools, or information, discuss the situation with your manager, Legal, or Ethics & Business Integrity. ReportingEthics & Business Integrity will periodically report to the Google Compliance Steering Committee all matters involving Google officers – VPs and above – approved under this section of the Code, and will periodically report to the Google Nominating and Corporate Governance Committee all matters involving Google executive officers and Board members approved under this section. IV. Preserve ConfidentialityWe get a lot of press attention around our innovations and our culture, and that’s usually fine. However, certain kinds of company information, if leaked prematurely into the press or to competitors, can hurt our product launches, eliminate our competitive advantage and prove costly in other ways. Our responsibilities extend beyond not revealing Confidential Google material – we must also:
V. Protect Google’s AssetsGoogle has a well-earned reputation for generosity with our employee benefits and openness with confidential information shared within the company. Our ability to continue these practices depends on how well we conserve company resources and protect company assets and information.
VI. Ensure Financial Integrity and ResponsibilityFinancial integrity and fiscal responsibility are core aspects of corporate professionalism. This is more than accurate reporting of our financials, though that’s certainly important. The money we spend on behalf of Google is not ours; it’s the company’s and, ultimately, our shareholders’. Each person at Google – not just those in Finance – has a role in making sure that money is appropriately spent, our financial records are complete and accurate, and internal controls are honored. This matters every time we hire a new vendor, expense something to Google, sign a new business contract, or enter into any deals on Google’s behalf. To make sure that we get this right, Google maintains a system of internal controls to reinforce our compliance with legal, accounting, tax, and other regulatory requirements in every location in which we operate. Stay in full compliance with our system of internal controls, and don’t hesitate to contact Ethics & Business Integrity or Finance if you have any questions. What follows are some core concepts that lie at the foundation of financial integrity and fiscal responsibility here at Google.
VII. Obey the LawGoogle takes its responsibilities to comply with laws and regulations very seriously and each of us is expected to comply with applicable legal requirements and prohibitions. While it’s impossible for anyone to know all aspects of every applicable law, you should understand the major laws and regulations that apply to your work. Take advantage of Legal and Ethics & Business Integrity to assist you here. A few specific laws are easy to violate unintentionally and so are worth pointing out here:
VIII. ConclusionGoogle aspires to be a different kind of company. It’s impossible to spell out every possible ethical scenario we might face. Instead, we rely on one another’s good judgment to uphold a high standard of integrity for ourselves and our company. We expect all Googlers to be guided by both the letter and the spirit of this Code. Sometimes, identifying the right thing to do isn’t an easy call. If you aren’t sure, don’t be afraid to ask questions of your manager, Legal or Ethics & Business Integrity. And remember... don’t be evil, and if you see something that you think isn’t right – speak up! Last updated January 24, 2022 Back to top |