Bloomberg LP Sustainable Operating Guidelines
March 2021
Bloomberg LP. Confidential. For internal purposes only.
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the recipient to obtain, retain, or direct business for or to any person or for the purpose of securing any
improper advantage for any person; (ii) authorize the giving of, offer, or give anything of value to any Public
Official or any other person with knowledge, substantial certainty or firm belief that all or a portion of the
thing of value will be offered, given, or promised, directly or indirectly, to such Public Official or other
person, for the purpose of securing any improper advantage for any person; (iii) authorize the receipt of,
request, solicit or receive anything of value from any Public Official or any other person, the purpose of
which is to influence or induce the recipient to obtain, retain, or direct business for or to any person or for
the purpose of securing any improper advantage for any person; (iv) offer, promise or give a bribe, request
a bribe, or seek to extort a bribe either directly or indirectly from Bloomberg or anyone acting on its behalf
(including without limitation, an officer, agent, director, employee, contractor or advisor); and/or (v) offer,
promise or give a gift of any kind, including with respect to hospitality, to Bloomberg or anyone acting on its
behalf that exceeds token value.
Suppliers shall maintain policies and procedures reasonably designed to ensure compliance with all
applicable laws, statutes, and regulations relating to anti-bribery and anti-corruption, including, but not
limited to, the United States Foreign Corrupt Practices Act and the United Kingdom Bribery Act 2010, each
as may be amended from time to time, and shall take reasonable steps to ensure that any person acting on
its behalf complies with such policies and procedures. Suppliers shall implement monitoring and
enforcement procedures to ensure compliance with anti-corruption laws.
Suppliers shall inform Bloomberg if any person acting on its behalf is, or is controlled directly or indirectly
by, a Public Official. Suppliers shall promptly inform Bloomberg of (i) any request or demand for any undue
financial or other advantage of any kind received by Supplier in connection with Supplier’s relationship with
Bloomberg and (ii) any offer, promise or bribe made to Supplier for the purpose of securing any improper
financial or other advantage of any kind in connection with Supplier’s relationship with Bloomberg. Suppliers
shall inform Bloomberg of any alleged or actual violation or failure to comply with any part of this section
“Anti-Bribery and Anti-Corruption”.
2) Excluded Jurisdictions
Suppliers shall not conduct activities in certain jurisdictions. Suppliers shall not provide, receive or use any
services, goods, products, staff or other resources to, from, or that pass through, (i) anyone engaged in
activities relating to nuclear, chemical or biological weapons proliferation, terrorism, corruption, undermining
of democratic rights and government, money laundering, tax evasion or human rights violations, or other
similarly egregious activities; or (ii) Crimea, Syria, Cuba, North Korea, or Iran (each, an “Excluded
Jurisdiction”). Suppliers shall not make payments to, or conduct any activity in connection with, or for the
benefit of, an Excluded Jurisdiction.
3) Sanctions
Suppliers shall not provide, receive or use any services, goods, products, staff or other resources: (i) in, or
for the benefit of any country and/or region with respect to which the United Nations, the United States,
European Union and/or United Kingdom (the “Sanctioning Authorities”) maintains sanctions prohibiting all
or substantially all shipment or provision of services, goods, technology or software (a “Sanctioned
Jurisdiction”); (ii) to, or for benefit of, the government of an Excluded Jurisdiction or a Sanctioned
Jurisdiction or a person located in or normally resident of an Excluded Jurisdiction or a Sanctioned
Jurisdiction; (iii) involving or benefiting a government or person whose assets a Sanctioning Authority has
blocked or to which a Sanctioning Authority restricts the shipment or provision of services, goods,
technology or software (a “Prohibited Party”); or (v) for any purpose that would be prohibited under the
economic sanctions of any Sanctioning Authority.
If a Supplier becomes subject to any action of a Sanctioning Authority that blocks or otherwise prevents
children, parents or siblings) or close associates (e.g., business partners, key business colleagues, personal advisors or controlled
legal entities) of the foregoing.