Glovo Standards of Ethics & Business Conduct for Third Parties

Glovo is committed to upholding the highest ethical and professional standards consistent with our core values. Glovo impacts millions of people who have great experiences with us every day. These positive interactions help to define who we are. The Global Code of Ethics and Business Conduct was developed in compliance with our core values and the principles of the United Nations Global Compact. The relationship between Glovo and its customers, suppliers, couriers, partners and/or any other parties who have a direct and/or indirect relationship with Glovo (hereinafter, “stakeholders”) is subject to this Guidelines and is an important component in the achievement of high performance in Glovo’s business.

Our Glovo Standards of Ethics & Business Conduct for Third Parties (“Guidelines”) are in harmony with the Glovo Code of Ethics & Business Conducts and its related policies and procedures, which are set forth in the standard practices that the Third Parties connected to Glovo’s businesses are required to comply with.

Glovo is committed to helping its Third Parties comply with these standards. In turn, Glovo expects its suppliers to apply these standards to their suppliers and/or others connected with their business.

Glovo has a channel (compliance@glovoapp.com) available for the purpose of contacting any stakeholders regarding compliance matters and/or regulatory issues, and it has published the Glovo Standards of Conduct to Third Parties on its website for this purpose.

These guidelines are fundamentally built on the framework of Glovo’s core values: Gas, Good Vibes, Stay Humble, Care and Glownership. Our core values shape the culture and define the character of our company. They guide how we behave and make decisions as well as how we conduct our business with ethics and integrity. Each core value is supported by specific behaviours that we expect Glovo’s stakeholders to also promote in their own businesses.

1.Environment

Glovo’s stakeholders are conscious of their impact on the environment and strive to minimise the negative impacts of their actions to preserve our natural resources for future generations. At a minimum, Glovo’s stakeholders comply with all applicable environmental laws and regulations, such as waste management and recycling.

• Complying with all applicable environmental laws

  Glovo’s stakeholders shall comply with all applicable environmental laws, regulations and standards.

• Reducing their negative environmental impact

  Glovo’s stakeholders are committed to reducing their negative environmental impact and to giving visibility to their progress towards this commitment. They encourage the development and use of environmentally friendly technologies and practices and the reduction of negative environmental impacts throughout their supply chain.

2.Stakeholders’ Interactions with Other Parties

Glovo’s stakeholders mobilise the power of teaming across organisational and geographical boundaries to deliver consistently exceptional products and services. They understand and comply with the laws and regulations that apply to their business.

• Complying with applicable competition laws

  Glovo’s stakeholders comply with competition law wherever they do business. In particular, Glovo’s stakeholders understand and comply with all applicable competition laws, including those related to teaming and information-sharing with competitors (whether through joint ventures, partnerships or other collaborations). All of Glovo’s stakeholders shall conduct their business in line with fair competition and in accordance with all applicable competition laws.

• Complying with all applicable international trade controls

  Glovo’s stakeholders who serve Glovo across national and/or international borders understand and comply with all applicable international trade controls (i.e. export controls, economic sanctions and anti-boycott laws).

• Complying with all applicable Anti-money Laundering and Combating the Financing of Terrorism laws

  Glovo’s stakeholders comply with anti-money laundering and combating the financing of terrorism laws wherever they do business and they do not engage in, or assist any third parties with, such crimes.

• Protecting the privacy of personal information

  Glovo’s stakeholders protect personal privacy and comply with all applicable privacy and data protection laws. They secure Glovo data, in accordance with Glovo’s own standards, against unauthorised access and use, and they do not reuse Glovo personal data for their own business purposes without prior permission. Glovo’s stakeholders recognise that any use, sharing or retention of personal data must be supported by, or based on, consent or a legitimate, compelling business purpose, and strictly in accordance with the contractual terms and conditions agreed with Glovo.

• Prohibition of corruption and bribery

  Any form of corruption, bribery, extortion or embezzlement is prohibited and not to be practised or tolerated by Glovo and its suppliers. No conducts aimed at unlawfully influencing others in business dealings by giving or accepting unfair advantages (e.g. unfair gifts or invitations) are permitted either domestically or abroad.

3.Respect for Individuals

Glovo’s stakeholders value diversity, ensure an inclusive environment and treat people with respect and dignity.

• Treating people with dignity and respect

  Glovo’s stakeholders support and respect internationally recognised human rights as expressed in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labor Organization’s Declaration on Fundamental Principles and Rights at Work. Accordingly, Glovo’s stakeholders treat people with dignity and respect, and maintain a respectful and safe workplace. They do not tolerate physical violence, threats, corporal punishment, mental coercion, verbal abuse, disrespectful behaviour, bullying or harassment of any kind (whether or not such harassment is legally prohibited on the basis of protected characteristics).

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• Allowing freedom of association and collective bargaining for employees

  Glovo’s stakeholders, when applicable, recognise and respect the right of their people to freely join or refrain from joining any worker organisations of their choosing and entering into collective bargaining processes as permitted by law.

• Not using, encouraging or engaging in human trafficking, slavery, servitude, forced or compulsory labour, or child labour

  Glovo’s stakeholders do not use, encourage or engage in human trafficking, slavery, servitude, forced, bonded, compulsory, indentured or involuntary labour. Employees of Glovo’s stakeholders voluntarily agree to the terms and conditions of their employment without coercion; and they can freely terminate their employment either: (i) immediately without notice; or (ii) by giving reasonable notice (required notice periods are always set out in employment contracts and vary based on the seniority of the employee and the requirements of local laws).
  In addition, where permitted by the applicable local employment laws, Glovo’s stakeholders may recover from an employee who terminates their employment within a defined period: (i) training expenses; (ii) payments made for retention purposes; and (iii) hiring bonuses or other variable compensation. Notwithstanding this, Glovo’s stakeholders’ suppliers do not require employees to work a longer period than their contractual notice period in order for Glovo’s stakeholders to recover such expenses, payments or bonuses. Glovo’s stakeholders do not use, encourage or engage in human trafficking. They do not, among other things: destroy, conceal, confiscate or otherwise deny employees’ access to identity or immigration documents; charge workers recruiting fees; employ recruiters that violate labour laws; provide housing that fails to meet safety or housing laws; use fraudulent or misleading recruitment practices; fail to provide written work documents, where required; or provide documents in a language that their workers do not understand.
  Glovo’s stakeholders do not use, encourage or engage child labour. Child labour means labour that deprives children of their childhood, their potential and their dignity, and that is harmful to their physical or mental development. Many countries have a minimum age for employment or work, and Glovo’s stakeholders understand and respect those requirements and do not employ people under the compulsory education age. Glovo’s stakeholders’ suppliers may operate workplace apprenticeship, work experience or internship programmes that comply with applicable laws.

• Complying with all applicable laws relating to employment

  Glovo stakeholders comply with all applicable employment laws and regulations, including those relating to working time, overtime and minimum wage requirements. In addition, Glovo’s stakeholders strongly encourage all its suppliers whose people provide services directly to Glovo’s stakeholders and/or clients to commit to paying all such people a living wage, which shall be higher than the legal minimum wage and shall take into account relevant actual living costs.

• Providing a safe and healthy work environment

  Glovo’s stakeholders are committed to the health and safety of their people and of visitors to their work locations. Glovo’s stakeholders’ suppliers comply with all applicable health and safety laws, provide a safe, healthy working environment and take the necessary precautions to protect everyone from workplace injuries and occupational disease.

• Not engaging in inappropriate use of social media

  Glovo’s stakeholders do not tolerate disrespectful or unprofessional usage of social media (whether or not such usage relates to Glovo’s stakeholders or to its business, clients, employees or business partners), such as posting content that is abusive, malicious, obscene, threatening or intimidating or that contains ethnic, religious, gender-related or other derogatory statements in any message or post.

4.Integrity

Glovo’s stakeholders understand and comply with all applicable laws. Glovo’s stakeholders inspire trust by taking responsibility, acting ethically and encouraging honest and open debate.

• Not offering inappropriate gifts or entertainment to Glovo’s stakeholders or third parties

  Stakeholders do not make bribes or any other improper payments directly or through a stakeholder’s third party in the form of gifts or entertainment to stakeholders’ employees, public officials, commercial clients, business partners or other third parties; and employees of Glovo’s stakeholders do not accept gifts or entertainment from third parties that are, or could be perceived as, bribes.

• Road safety, food handling, restaurant operating license and regulatory laws

  Every stakeholder is responsible for knowing and obeying all applicable laws regarding the terms applicable to them for the use of Glovo, including road safety rules such as speed and traffic laws, food and food handling, transport of sensitive products, and any other rules and regulations, at all times when using Glovo. For example, Customers should not ask a courier to speed or to make illegal stops, drop-offs or manoeuvres, and Couriers should similarly not stop on bicycle lanes or blocking accessibility ramps in breach of the law.
  All relevant licences and accreditation requirements must be kept up to date, and the stakeholder is fully responsible for promoting qualified services and complying with the law.

• Complying with all anti-corruption laws

  Complying with all anti-corruption laws including, but not limited to, the US Foreign Corrupt Practices Act and the UK Bribery Act 2010 and/or any other local legislation. Glovo is committed to conducting its business in an honest and ethical manner and has zero tolerance for corruption or any other activity that violates anti-corruption laws in any place where we conduct business. Glovo’s stakeholders comply with all applicable anti-corruption laws and regulations, including the US Foreign Corrupt Practices Act, the UK Bribery Act 2010 and/or any other local legislation. In connection with doing business with or on behalf of Glovo, Glovo’s stakeholders do not offer, promise, authorise, give, demand or accept any gifts, loans, fees, rewards or any other advantages to or from any persons as an inducement: to do something that is dishonest, illegal or a breach of trust; to obtain, retain or direct business; or to secure any other improper advantage. Under these standards, improper payments include offers, promises, authorisations or payments of anything of value to expedite routine government actions. Glovo’s stakeholders shall implement procedures to ensure their employees and suppliers are fully in compliance with the applicable anti-corruption laws and these standards.

• Glovo will not tolerate any kind of fraud, theft and/or misconduct that could conflict with the rights of Glovo and/or any other Party

  Stakeholders must not falsify information or assume someone else’s identity, for example when signing in or undergoing a security check, as this is against the law and is not allowed. It is important to provide accurate information when reporting incidents, disputing charges or fees, and requesting credits. Stakeholders are only allowed to request fees or refunds that they are entitled to, and to use offers and promotions only as intended.
  Fraudulent activity may also include, but is not limited to: deliberately increasing the time or distance of a delivery for fraudulent purposes or otherwise; accepting order or delivery requests without the intention to complete them, including causing couriers or Glovo customers to cancel for fraudulent purposes; creating dummy accounts for fraudulent purposes; claiming fraudulent fees or charges, such as false cleaning fees; intentionally requesting, accepting or completing fraudulent or false deliveries; claiming to have completed a delivery without ever picking up the delivery item; picking up a delivery item but retaining all or a portion of the item and not delivering the entire order; actions intended to disrupt or manipulate the normal functioning of Glovo, including manipulating the settings on a phone to prevent the proper functioning of the app and the GPS system; abusing promotions and/or using them otherwise than for their intended purpose; disputing charges for fraudulent or illegitimate reasons; creating improper duplicate accounts; or falsifying documents, records or other data for fraudulent purposes. Couriers and Partners should never tamper with an order or take or eat any part of an order – this is considered theft and may result in loss of access to the Glovo account as well as in any other consequences under the local law.

Glovo’s due diligence rights in relation to these Guidelines

Glovo’s stakeholders understand and comply with all applicable laws. Glovo’s stakeholders inspire trust by taking responsibility, acting ethically and encouraging honest and open debate.

Glovo may conduct due diligence procedures to ascertain stakeholders’ adherence to these Guidelines in relation to the locations where, or from which, goods or services are provided to Glovo. Such audits may be conducted on an annual basis during normal business hours, and Glovo shall provide at least 60 days’ prior written notice of its intention to conduct such an audit. Glovo shall conduct such audits in a manner that results in minimal disruption to the business and operations of Glovo’s stakeholders.

Glovo’s employees or independent representatives (who must not be competitors of Glovo’s stakeholders) shall sign appropriate confidentiality agreements prior to such an audit.

For the purposes of the said audit, Glovo’s stakeholders shall provide Glovo’s employees, and/or independent representatives if applicable, with reasonable access to relevant information about Glovo’s stakeholders’ policies and procedures. The reasonable costs and expenses incurred by Glovo’s stakeholders may be charged to Glovo if more than 2 man-days of Glovo’s stakeholders are required in relation to the relevant audit. Unless otherwise agreed in writing, Glovo will not be entitled to audit any other of its stakeholders’ confidential information, including: (a) information about other clients or business partners of Glovo’s stakeholders; (b) cost or pricing information; (c) internal employee surveys or survey results; (d) employee demographic information; (e) information about grievances or legal claims; (f) legally privileged advice; or (g) non-public personal data relating to employees (including individual training records).

Glovo will not be entitled to interview randomly selected employees of Glovo’s stakeholders.

Glovo shall notify the relevant stakeholder if any matters of concern are identified by its audit, and the parties may agree to meet in order to discuss such concerns.

5.Enforcement of Guidelines

Glovo may from time to time request valid documentation from stakeholders to promote proper due diligence on their accounts and/or the services provided to Glovo. Stakeholders must maintain documentation that demonstrates compliance with these Guidelines and the applicable laws and regulations.

Failure to comply with these Guidelines or the applicable laws will entitle Glovo to immediately terminate the relationship with the Party and/or to disclose the matter to the appropriate authorities, regulators and/or law enforcement bodies. If permitted by the applicable law, Glovo shall inform the stakeholder of the matter and give the said party a reasonable opportunity to respond before informing the relevant authority, regulator or law enforcement body.

Where applicable, for example in relation to suppliers, companies and/or business partners, stakeholders shall continuously improve their internal control environment by establishing objectives, implementing plans and taking appropriate corrective action in connection with any deficiencies identified by internal or external assessments, inspections or management reviews.

Glovo encourages a culture of transparency among stakeholders and expects them to implement such culture in their organisation and supply chain, as well as have in place a confidential channel for their employees to report any legal or ethical concerns, including through line management channels and/or formal reporting channels. All stakeholders must report suspected violations of these standards by the stakeholders themselves (or by their own employees, contractors, sub-contractors or suppliers). Stakeholders must also report any specific issues of which they become aware regarding Glovo’s financial affairs, accounting practices, auditing matters, corruption or fraud, or any behaviour by Glovo employees, that are inconsistent with the standards set out in this Guidelines.

Glovo’s stakeholders must prohibit any retaliation against any of its employees who: (1) come forward to raise, in good faith, a concern about a violation of any law and/or any violation of these Guidelines; or (2) assist Glovo, or a law enforcement authority, by providing information to address a concern. In these Guidelines, “retaliation” means unfair treatment of any kind resulting from the raising of a concern in good faith (or any threat of such unfair treatment).

6.Contact

Such reports must be made through the Glovo Compliance channel (compliance@glovoapp.com), where you may report your concern in good faith by email.

Glovo treats all allegations seriously and in strict confidence. Depending on the nature and circumstances of the allegation, Glovo may seek to work – where appropriate – together with its stakeholders and other affected Parties in order to reach a proper and timely resolution.