GoPro Supplier Code of Conduct

GoPro makes the world’s most versatile cameras, and we strive to do it responsibly. We are committed to achieving universal ethical trading standards throughout all parts of our supply chain. This includes a commitment to ensuring that workers are treated with respect and dignity, and that business operations and manufacturing processes are environmentally responsible and conducted ethically.

Accordingly, we require all suppliers to comply with our GoPro Supplier Code of Conduct (the “Code”). The Code seeks to promote safe and fair working conditions and urges our suppliers to go beyond legal compliance to advance social responsibility. Our Code draws upon principles articulated in the Responsible Business Alliance Code of Conduct, the Universal Declaration of Human Rights, and standards issued by organizations such as the International Labour Organization, Social Accountability International, and the Ethical Trading Initiative. Among other things, our Code prohibits the use of underage labor, prohibits forced or prison labor, and mandates workplaces free of harassment or discrimination. Our suppliers are further required to comply with applicable laws and regulations in the rights of workers to form and join labor unions or workers organizations of their own choice.

GoPro employees undergo training on the Code, including ways to mitigate the risk of suppliers violating workplace laws. As part of our verification process, we, or a designated third party, may conduct onsite visits, and our suppliers are otherwise contractually obligated to certify and warrant compliance with all laws, rules, and regulations of the countries in which they operate, which may include applicable laws on workplace conditions, slavery, and human trafficking. It is intended that this statement extends to the obligations set forth in section 54(12), UK Modern Slavery Act 2015 and GoPro shall, upon request, provide a statement of such steps it has taken, together with such other information a requestor may reasonably require to enable it to prepare a slavery and human trafficking statement in accordance with section 54, UK Modern Slavery Act 2015.

Once engaged to work with us, suppliers must actively monitor their own practices to ensure continuous compliance with our Code. GoPro, or a designated third party, may also conduct announced audits of suppliers to further ensure compliance. As part of our auditing process, we provide our suppliers with reports and if necessary, require corrective action to cure any compliance issues. Among other things, suppliers who do not resolve the issues to our satisfaction are subject to termination as a GoPro supplier and appropriate legal action. GoPro may also utilize third parties to assist with ensuring GoPro complies with certain laws, rules, and regulations, such as but not limited to, Prop 65, REACH, RoHS and TSCA compliance. All GoPro suppliers are required to comply and cooperate with GoPro designated third parties during audits and the compliance activities stated herein.

As part of our commitment to fair working conditions, GoPro may update our Code or other procedures as needed to ensure that our suppliers conduct business ethically and responsibly.

Labor & Human Rights

Child Labor. GoPro will not tolerate the use of child labor. Our suppliers must engage workers whose age is the greater of: (i) 15, (ii) the age of completion of compulsory education, or (iii) the minimum age to work in the country where work is performed. Furthermore, workers under the age of 18 must not perform hazardous work. Suppliers shall implement an appropriate mechanism to verify the age of workers. GoPro supports the development of legitimate workplace apprenticeship and workplace learning programs that comply with applicable laws and this Code. Suppliers 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 laws and regulations. Suppliers shall provide appropriate support and training to all student workers. In the absence of 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.

Involuntary Labor, Human Trafficking, and Slavery. Workers must not be forced to work against their will. Our suppliers must not use forced labor - slave, prison, indentured, bonded, or otherwise. Our suppliers must not traffic workers or in any other way exploit workers by means of threat, force, coercion, abduction, or fraud. Working must be voluntary, and workers must be free to leave work and terminate their employment or other work status with reasonable notice. Where workers are required to pay a fee in connection with obtaining employment, suppliers shall be responsible for payment of all fees and expenses more than the amount of one month of the worker’s anticipated net wages. Such fees and expenses include, but are not limited to, expenses associated with recruitment, processing, or placement of both direct and contract workers. Our suppliers must not require workers to surrender government issued identification, passports, or work permits as a condition of working, and our suppliers may only temporarily hold onto such documents to the extent reasonably necessary to complete legitimate administrative and immigration processing. Workers must be given clear, understandable contracts regarding the terms and conditions of their engagement in a language understood by the worker. Suppliers must ensure that each of its staffing or recruiting agencies comply with this Code and with the more stringent of the applicable laws of the country where work is performed and the worker’s home country.

Wages and Benefits. Our suppliers must pay their workers in a timely manner and provide compensation (including overtime pay and benefits) that, at a minimum, satisfy applicable laws. Suppliers must provide to their workers the basis on which workers are being paid in a timely manner via pay stub or similar documentation. Deductions from wages as a disciplinary measure are not permitted. Suppliers shall offer vacation time, leave periods, and holidays consistent with applicable laws and regulations. All use of temporary, dispatch and outsourced labor will be within the limits of the local law.

Working Hours. Except in unusual or emergency situations, (i) suppliers must not require a worker to work more than 60 hours per week, including overtime, and (ii) each worker must be entitled to at least one day off for every seven-day work period. In all circumstances, working hours must not exceed the maximum amount permitted by law.

Anti-Discrimination. Suppliers must commit to a workplace free of unlawful discrimination. Conditions of working must be based on an individual’s ability to do the job, not on personal characteristics or beliefs. Our suppliers must not discriminate on the basis of race, color, national origin, gender, sexual orientation, religion, disability, age, political opinion, pregnancy, marital or family status, or similar factors in hiring and working practices such as job applications, promotions, job assignments, training, wages, benefits, and termination. Suppliers must not subject workers or applicants to medical tests (i.e. pregnancy test) that could be used in a discriminatory manner. Workers shall be provided with reasonable accommodation for religious practices.

Humane Treatment and Non-Harassment. Suppliers shall not tolerate or permit harsh or inhumane treatment including violence, gender-based violence, sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, bullying, public shaming, or verbal abuse of workers; nor is there to be the threat of any such treatment. Suppliers shall commit to a workplace free of harassment. All workers must be treated with respect and dignity. Workers must be free to voice their concerns to GoPro or its auditors, and allowed to participate in the GoPro audit process, without fear of retaliation by supplier management. Disciplinary policies and procedures in support of these requirements shall be clearly defined and communicated to workers.

Immigration Compliance. Our suppliers may only engage workers who have a legal right to work. If suppliers engage foreign or migrant workers, such workers must be engaged in full compliance with the immigration and labor laws of the host country.

Freedom of Association. Open communication and direct engagement between workers and management are the most effective ways to resolve workplace and compensation issues. Our suppliers must respect the rights of workers to establish and join a legal organization of their own selection. Workers must not be penalized or subjected to harassment or intimidation for the non-violent exercise of their right to join or refrain from joining such legal organizations.

Safety and Health

Our suppliers must provide workers with a safe and healthy work environment, and suppliers must, at a minimum, comply with applicable laws regarding working conditions and with the standards below. GoPro recognizes that in addition to minimizing the incidence of work-related injury, illness, and hazards; a safe and healthy work environment enhances the quality of products and services, consistency of production and worker retention and morale.

Recognized management systems such as ISO 45001 and ILO Guidelines on Occupational Safety and Health were used as references in preparing the Code and may be useful sources of additional information.

Suppliers shall commit to creating safe working conditions and a healthy work environment for all their workers in all aspects of its workplaces.

Occupational Safety & Injury. Suppliers must educate workers on safety procedures and control worker exposure to potential physical safety hazards by implementing physical guards, barriers, and/or engineering and administrative controls. Workers must be informed and receive appropriate education in advance if they will be working with (or otherwise exposed to) hazardous or dangerous conditions or materials. In addition, workers must be given appropriate personal protective equipment and educated and trained on the proper use of such equipment. Suppliers must manage, track, and report occupational injuries and illnesses. Suppliers shall not discipline workers for raising safety concerns and workers shall have the right to refuse unsafe working conditions without fear of reprisal until management adequately addresses their concerns. Suppliers shall establish procedures and systems to prevent, manage, track, and report occupational injury and illness. Such procedures and systems shall encourage worker reporting, classify, and record injury and illness cases, provide necessary medical treatment, investigate cases, and implement corrective actions to eliminate their root causes, and facilitate the workers’ return to work.

Industrial Hygiene. Worker exposure to chemical, biological, and physical agents is to be identified, evaluated, and controlled according to the Hierarchy of Controls. If any potential hazards were identified, Suppliers shall look for opportunities to eliminate and/or reduce the potential hazards. If elimination or reduction of the hazards is not feasible, potential hazards are to be controlled through proper design, engineering, and administrative controls. When hazards cannot be adequately controlled by such means, workers are to be provided with and use appropriate, well-maintained, personal protective equipment free of charge. Protective programs shall be ongoing and include educational materials about the risks associated with these hazards.

Physically Demanding Work. Suppliers must continually identify, evaluate, and control physically demanding tasks to ensure that worker health and safety is not jeopardized.

Emergency Preparedness and Response. Suppliers must identify and plan for emergency situations and implement and train their workers on response systems, including emergency reporting, alarm systems, worker notification and evacuation procedures, worker training and drills, first-aid supplies, fire detection and suppression equipment, and unblocked exit facilities. Suppliers must maintain all facilities in good fire safety conditions with appropriate fire detection and suppression equipment, adequate exit facilities in accordance with the applicable laws and regulations or industry benchmark standards or relevant international standard. Suppliers shall incorporate C-TPAT security criteria into their business processes as described in the U.S. Customs website, www.cbp.gov.

Machine Safeguarding. Suppliers must implement a regular machinery maintenance program. Production and other machinery must be routinely evaluated for safety hazards.

Sanitation, Dining, and Housing. Workers must be provided with reasonable access to clean toilet facilities and potable drinking water. If suppliers provide a canteen or other food accommodations, they must include sanitary food preparation, storage, and eating accommodations. If suppliers provide residential facilities for their workers, they must provide clean and safe accommodations. In such residential facilities, workers must be provided with emergency egresses, reasonable and secure personal space, entry and exit privileges, reasonable access to hot water for bathing, adequate heat and ventilation, and reasonable transportation to and from work facilities (if not reasonably accessible by walking).

Ergonomics. Suppliers shall identify, evaluate, and control worker exposure to physically demanding tasks, including manual material handling, heavy or repetitive lifting, prolonged standing, and highly repetitive or forceful assembly tasks.

Health and Safety Communication. Suppliers shall provide workers with appropriate workplace health and safety information and training in the language of the worker or in a language the worker can understand for all identified workplace hazards that workers are exposed to, including but not limited to mechanical, electrical, chemical, fire, and physical hazards. Health and safety related information shall be clearly posted in the facility or placed in a location identifiable and accessible by workers. Training is provided to all workers prior to the beginning of work and regularly thereafter. Workers shall be encouraged to raise any health and safety concerns without retaliation.

Business Ethics

Suppliers must be committed to the highest standards of ethical conduct when dealing with workers, suppliers, and customers to meet social responsibilities and to achieve success in the marketplace.

No Bribery. Our suppliers must not offer nor accept bribes or other means of obtaining undue or improper advantages to anyone for any reason, whether in dealings with governments or the private sector. Our suppliers must not induce GoPro employees to violate our Business Code of Conduct.

Anti-Corruption. Suppliers must comply with applicable anti-corruption laws, including the United States Foreign Corrupt Practices Act and the United Kingdom Bribery Act, and not offer anything of value, either directly or indirectly, to government officials to obtain or retain business. Suppliers must not make illegal payments to government officials themselves or through a third party. Suppliers must have a zero-tolerance policy to prohibit all forms of bribery, corruption, extortion, and embezzlement (covering promising, offering, giving, or accepting any bribes) or other means to obtain an undue or improper advantage. Suppliers must uphold fair business standards in advertising, sales, and competition. All business dealings should be transparently performed, and accurate procedures shall be implemented to ensure compliance with anti-corruption applicable laws.

Whistleblower Protections. Suppliers must protect worker whistleblower confidentiality and prohibit retaliation against workers who report workplace grievances. Suppliers must create a mechanism for workers to submit their grievances anonymously.

Disclosure of Information. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable. Suppliers must transparently perform, accurately record, and disclose information regarding their business activities, structure, financial situation, and performance in accordance with applicable laws and regulations and prevailing industry practices.

Intellectual Property. Supplier must commit to respect intellectual property rights, and transfer of technology and know-how is to be done in a manner that protects intellectual property rights.

Protection of Identity and Privacy. Suppliers must maintain programs that ensure the confidentiality and protection of supplier and employee whistleblowers, and prohibit retaliation against workers who participate in such programs in good faith or refuse an order. Suppliers shall provide an anonymous complaint mechanism for workers to report workplace grievances in accordance with local laws and regulations. Suppliers must protect the reasonable privacy expectations of personal information of everyone they do business with, including suppliers, customers, consumers, and employees. Suppliers are to comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.

Community Engagement. Suppliers are encouraged to engage the community to help foster social and economic development and to contribute to the sustainability of the communities in which they operate.

Environmental

Our suppliers must comply with applicable environmental laws. GoPro encourages our suppliers to implement systems that are designed to minimize the impact on the environment by the supply chain system, the production process, and the products themselves.

Environmental Permits and Recordkeeping. Suppliers must obtain and keep current all required environmental permits, approvals, and registrations and follow applicable operational and reporting requirements.

Pollution Prevention and Resource Reduction. Emissions and discharges of pollutants and generation of waste are to be minimized or eliminated at the source or by practices such as adding pollution control equipment; modifying production, maintenance, and facility processes; or by other means. The use of natural resources, including water, fossil fuels, minerals, and virgin forest products, is to be conserved by practices such as modifying production, maintenance and facility processes, materials substitution, re-use, conservation, recycling, or other means.

Effective Management and Disposal of Hazardous Substances. Suppliers must effectively identify and manage the safe handling, movement, storage, and disposal of chemicals and other substances that pose a threat to the environment, including providing workers with appropriate training on the safe-handling and disposal of hazardous substances. Suppliers must also monitor and control wastewater or solid waste generated from operations before disposing in accordance with applicable laws. In addition, suppliers must characterize, monitor, control, and treat regulated air emissions before discharging in accordance with applicable laws.

Continuous Improvement. GoPro encourages our suppliers to continuously improve and reduce waste. GoPro welcomes suggestions and feedback from its suppliers to improve GoPro's own operations and processes.

Air Emissions. Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting substances, and combustion byproducts generated from operations are to be characterized, routinely monitored, controlled, and treated as required prior to discharge. Ozone-depleting substances are to be effectively managed in accordance with the Montreal Protocol and applicable regulations. Suppliers shall conduct routine monitoring of the performance of its air emission control systems.

Material Substance Restrictions and Regulations. Supplier must identify the chemicals and other materials posing a hazard if released to the environment and manage to ensure their safe handling, movement, storage, use, recycling or reuse and disposal. Suppliers shall comply with the most up-to-date version of GoPro Environmental Requirements (970-01019-000) and with any applicable laws and regulations prohibiting or restricting the use or handling of specific hazardous substances. Suppliers shall comply with applicable laws and regulations regarding prohibition or restriction of specific substances and hazardous substances including labeling for recycling and disposal.

Water Management. Suppliers shall implement a water management program that documents, characterizes, and monitors water sources, use and discharge; seeks opportunities to conserve water; and controls channels of contamination. All wastewater is to be characterized, monitored, controlled, and treated as required prior to discharge or disposal. Suppliers shall conduct routine monitoring of the performance of its wastewater treatment and containment systems to ensure optimal performance and regulatory compliance.

Energy Consumption and Greenhouse Gas Emissions. Suppliers are to establish a corporate-wide greenhouse gas reduction goal. Energy consumption and all relevant Scopes 1 and 2 greenhouse gas emissions are to be tracked, documented, and publicly reported against the greenhouse gas reduction goal. Suppliers are to look for methods to improve energy efficiency and to minimize their energy consumption and greenhouse gas emissions.

Air Management. Supplier shall characterize, manage, monitor, control and treat air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals, and combustion by-products generated from operations, as required by applicable laws and regulations prior to discharge.

Management Systems

Suppliers must adopt a management system to ensure compliance with applicable laws and this Code and to facilitate continual improvement.

Management Accountability and Responsibility. Suppliers must have designated representatives responsible for implementing management systems and programs that oversee compliance with applicable laws as well as this Code. Senior management must routinely review and assess the quality and efficiency of the management systems and programs. GoPro also expects our suppliers to hold their suppliers and subcontractors to the standards and practices covered by this Code.

Risk Management. Suppliers must establish a process to identify the environmental, health, safety, and ethical risks associated with their operational and labor practices. In addition, management must develop appropriate processes to control identified risks and ensure regulatory compliance.

Training. Management must maintain appropriate training programs for managers and workers to implement the standards in this Code and to comply with applicable legal requirements.

Communication and Worker Feedback. Suppliers must clearly and accurately communicate and educate workers about GoPro policies, practices, and expectations. GoPro may require suppliers to post this Code in a location accessible to their workers (translated into the appropriate local language(s)). In addition, GoPro encourages suppliers to partner with us to implement a process to assess workers' understanding of the standards and practices covered by this Code.

Documentation and Records. Suppliers must create, retain, and dispose of business records in full compliance with applicable legal requirements along with appropriate confidentiality to protect privacy.

Audits and Assessments. Suppliers shall conduct periodic self-evaluations to ensure compliance with this Code and with applicable laws and regulations. Suppliers shall conduct periodic evaluations to ensure that its subcontractors and its next-tier suppliers are complying with this Code and with applicable laws and regulations.

GoPro Conflict Minerals Policy and Supplier Requirements

GoPro is committed to sourcing components and materials from companies that share our values around human rights, ethics, and environmental responsibility. We expect all our suppliers to abide by the requirements of our Supplier Code of Conduct, which prohibits human rights abuses and unethical practices. We also require all suppliers to comply with applicable legal standards and requirements. On August 22, 2012, the U.S. Securities and Exchange Commission issued the final conflict minerals rule under Section 1502 of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Rule”). The Rule requires publicly traded companies to investigate and report annually on the presence of Conflict Minerals in their products. The term “Conflict Minerals” refers to tin, tantalum, tungsten, and gold. Congress enacted the Rule because of concerns that the exploitation and trade of these minerals by armed groups is helping to finance conflict in the Democratic Republic of the Congo (“DRC”) or adjoining countries Angola, Burundi, Central African Republic, the Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia (collectively with DRC, the “Covered Countries”), contributing to an emergency humanitarian crisis.

GoPro supports the goal of ending violence, human rights violations, and environmental devastation in the Covered Countries. We are committed to complying with any requirements applicable to our Company under the Rule and expect our suppliers to provide materials to GoPro that are conflict-free. We strive to work cooperatively with our supply chain partners in implementing Conflict Minerals compliance programs. GoPro requires all our suppliers to engage in the due diligence described in this policy and to provide completed Conflict Minerals declarations using the Conflict Free Sourcing Initiative’s (“CFSI”) Conflict Minerals Reporting Template. We may reconsider our willingness to partner with suppliers that fail to provide full and timely disclosures in accordance with this policy. GoPro expects suppliers to steer their supply chain towards using only conflict-free smelters. A list of smelters that have been audited for compliance with the CFSI conflict-free smelter program is available on the CFSI website, which is continuously updated as more smelters are audited. We request all suppliers using smelters that are not yet verified as conflict-free to address these smelters with a request to participate in the CFSI conflict-free smelter program or otherwise switch to an already audited smelter.

Suppliers / Partners are required to implement processes to undertake:
(1) a reasonable inquiry into the country of origin of Conflict Minerals incorporated by the supplier or by any of its manufacturers or suppliers into any materials provided to GoPro, to determine if there is reason to believe that Conflict Minerals may have originated in a Covered Country;
(2) if such inquiry determines there is reason to believe that Conflict Minerals from the Covered Countries are present in any materials provided to GoPro, due diligence to determine the source and chain of custody of the Conflict Minerals in the supplier’s supply chain, including the facilities in which they were processed as necessary, to determine if any of these minerals directly or indirectly financed or benefited armed conflict in the Covered Countries;
(3) appropriate risk assessment and mitigation actions in connection with its country-of-origin inquiry and due diligence process, consistent with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

If the supplier does not know the original source of the minerals, the supplier agrees to cooperate with GoPro, including disclosing from whom the supplier purchased the minerals and urging others to disclose such information, so that the original source of minerals can be accurately determined and reported. The supplier shall comply with all laws regarding the sourcing of minerals, including, without limitation, the Rule and other laws prohibiting the sourcing of minerals from mines controlled by combatants. Without any further consideration, Supplier shall provide such further cooperation as GoPro may reasonably require to meet any obligations it may have under conflict minerals laws, including, without limitation, under the Rule. Interested parties can report improper activities in violation of the Conflict Minerals Policy at conflictminerals@gopro.com.

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Code of Conduct Last Updated: October 20, 2021.

GoPro employees who manage our manufacturing supply chain receive training on our Code. GoPro also requests that our Suppliers acknowledge the Code. GoPro or independent third-party auditors may periodically conduct both unannounced and announced on-site audits of our manufacturers. GoPro aspires to audit our Suppliers before GoPro begins ordering products, and we require that all our Suppliers meet the standards in our Code as a condition of doing business with GoPro. GoPro's agreements require our suppliers to comply with supply chain standards, which, among other things, include laws regarding slavery and human trafficking.

Supplier Registration

Suppliers interested in doing business with GoPro are invited to register their information and capabilities in our Supplier registration database. If our procurement team decides that our contracting needs align to the products or services your business offers, we will contact you regarding next steps.