AMERICAN EXPRESS SUPPLIER CODE OF CONDUCT

American Express is a global company that is committed to working with all suppliers that
adhere to the same standard of ethics, legality, and integrity as American Express does. We
value responsible business practices and a commitment to following these practices.
We seek to provide the world’s best customer experience, which at times includes relying on
services provided by thousands of suppliers worldwide. The American Express Supplier Code
of Conduct outlines the expectations that American Express has for its suppliers and will
apply to any employee, agent, contractor, or other representative of any supplier that
provides goods or services to American Express. To ensure the awareness of the Supplier
Code of Conduct, suppliers are responsible for reviewing, communicating, and sharing these
expectations and principles, with all associations to the supplier.
Scope
A supplier is any third party that furnishes goods and/or services to American Express,
including those that perform functions on our behalf or that provides benefits and services to
our prospects and/or customers. The following persons, entities, and organizations
(collectively referred to as Suppliers) are covered by the Supplier Code of Conduct and are
thereby subject to its provisions:
• Suppliers, vendors, providers, consultants, agents, contractors, temporary workers;
and
• The owners, officers, directors, employees, consultants, affiliates, contractors and
sub-contractors of these organizations and entities.

American Express is committed to working with suppliers that share our values regarding
environmental sustainability, diversity, ethical sourcing, responsible operations, human rights,
and gender equality. In this document, we will outline some of our key behavioral expectations
for suppliers.
American Express’s Supplier Code of Conduct consists of the following areas of focus:
1. Compliance with Supplier Code of Conduct
2. Business Practices & Ethics
3. Environmental Sustainability
4. Social
5. Amex Ethics Hotline

1. Compliance with Supplier Code of Conduct

Suppliers and their sub-contractors must follow the Supplier Code of Conduct when
conducting business with American Express or on behalf of American Express to
maintain the highest standards of integrity. Any violation of this Supplier Code of
Conduct may require corrective action plans, or may result in disciplinary action up to
termination of contract. Suppliers must be forthcoming and transparent about any
Oct 21, 2024
 situation that may arise that could jeopardize or violate the Supplier Code of Conduct
set below through the appropriate channels or the supplier’s designated point of
contact at American Express. The Company prohibits retaliation against anyone who
makes a good faith report of a suspected violation of the Supplier Code of Conduct.
2. Business Practices & Ethics
American Express respects and promotes human rights and is committed to responsible
workplace practices across our company and in all aspects of our business. We strive to
conduct our business in an approach consistent with the United Nations Guiding Principles on
Business and Human Rights as shown in our Code of Conduct. Our Supplier Code of Conduct
aims to embody the same level of values from our suppliers, with a commitment to fair and
equal treatment of all persons and to conducting business in an ethical manner.
2.1 Conflicts of Interest
American Express expects our suppliers to disclose any actual, potential, or perceived
conflicts of interest before starting their relationship with us or as soon as they become aware
of a conflict(s) after beginning the relationship. Suppliers, their employees, and family
members cannot receive improper benefits through their relationship with American Express
or allow other activities to conflict with acting in the best interests of American Express.
2.2 Anti-Trust
American Express supports vigorous yet fair competition. Organizations must all abide by
competition laws (also referred to as “antitrust,” “monopoly” or “cartel” laws), which are
designed to preserve free and open competition. American Express expects suppliers to
conduct business in full compliance with fair competition laws that are applicable to the
jurisdiction in which they operate and conduct business. These laws vary, but their common
goal is to promote a competitive marketplace that provides consumers with high-quality
goods and services at competitive prices. Antitrust and fair competition laws prohibit us from
sharing pricing and other competitive information with competitors and other third parties,
and therefore, we expect our suppliers to comply as well.
2.3 Anti-Corruption
American Express has adopted a zero-tolerance policy prohibiting bribery, regardless of
location. Suppliers may not give or receive anything of value – meals, gifts, entertainment,
travel, job opportunities, contracts, incentives, or other benefits or favors – with the intent to
improperly obtain or retain business, secure services, influence any decision or obtain an
improper business advantage for American Express. We expect our suppliers to comply with
all applicable laws, regulations, and government-issued rules and guidance.
2.4 Customer Facing Interactions
All Customer Facing Interactions, such as sales, marketing, advertising, servicing, and
collections activities must be always conducted with honesty and integrity. This applies to all
interactions with customers including current and prospective clients and merchants.
Suppliers and their subcontractors must meet the appropriate legal and regulatory
expectations applicable to the service they are providing, including sales, referral,
compensation, incentive guidelines, and relevant procedures.

Oct 21, 2024

2.5 Meals, Gifts, Entertainment and Other Benefits
When doing business on behalf of American Express, the supplier must be cautious when
offering, giving or accepting meals, gifts, entertainment, contracts, incentives, or other
benefits to or from anyone who does or seeks to do business with your Company. Doing so
may influence, or appear to influence, the ability to make objective business decisions. In
addition, you may not solicit any meals, gifts, entertainment, or other benefits from current or
potential customers or other business partners.
The supplier may never accept or offer gifts that are: Cash or monetary equivalents, such as
gift cards or vouchers, objects that have significant value, or may appear significant to others,
indicative of preferential treatment. In addition, we may never accept or offer entertainment
that is excessive in value, not business-related, and in an inappropriate setting.
2.6 Political Activities and Lobbying
Supplier must never use its position of authority to make another colleague feel compelled or
pressured to participate in any way in any political event or cause, or for any political purpose.
The U.S. Federal Government, each state, and certain localities, have laws requiring
registration and reporting by lobbyists and, in some cases, by the lobbyists' employers.
Lobbying activity generally includes attempts to influence the passage or defeat of legislation.
The U.S. Government and many states and localities, however, have extended the definition of
lobbying activity to cover efforts to influence formal rulemaking by executive branch agencies
or other official actions of agencies, including the decision to enter into a contract or other
financial arrangement. Moreover, "grassroots" activity is in many cases also considered
lobbying activity.
Governments in certain other jurisdictions may have similar laws, with which Suppliers must
comply.
To ensure that American Express and its Suppliers are in compliance with these laws,
Suppliers may not engage in any of the lobbying activities, as described above, or retain any
other person or entity to do so, on behalf of American Express without prior approval of the
appropriate contact, and must be in full compliance with applicable international, federal,
state, and local laws.
Attempts to obtain business or contracts from a governmental entity should be done in
consultation with the appropriate contact. Any corporate donations to government entities,
which may be viewed as lobbying require prior approval of the relevant contact details.
2.7 Intellectual Property
American Express values its intellectual property and recognizes it as an important asset to
our business. Suppliers are expected to protect all American Express intellectual property
with the same care and protection in which the supplier would safeguard their own
information. We expect all suppliers to comply with all applicable rights and laws with regards
to intellectual property and the use of the information provided from American Express.

Oct 21, 2024

2.8 Privacy, Data Protection & Management
Suppliers of American Express must handle all data, sensitive information, confidential
information, personal information, and business records with care and in accordance with
data privacy laws and regulations.
Written and electronic records should be properly identified, retained, and disposed of
according to legal, regulatory, and contractual expectations. All records that relate to any
imminent or ongoing investigation, lawsuit, audit, or examination involving American Express-
related business should not be destroyed, concealed, or altered to impede the proceedings.
All applicable litigation hold instructions should be applied immediately and consistently.
2.9 Labor and Human Rights
American Express is committed to upholding and protecting human rights around the world.
American Express expects its Suppliers to take necessary steps to prevent acts of forced
labor and human trafficking from occurring both within our business and our supply chain by
ensuring we only work with Suppliers of the highest standard.
Suppliers should sustain a workplace environment where business standards are clearly
understood and provide clear channels for individuals to communicate and make good faith
report of suspected violations without threat of retaliation. Our company strives to provide a
safe, diverse, and equal opportunity workplace, and inhumane practices of forced labor within
both American Express and within our Suppliers, will not be tolerated.
Our Human Rights Statement, Code of Conduct and Australian Modern Slavery Statement
also express our commitment to fair and equal treatment of all people.
3. Environmental Sustainability

3.1 Greenhouse Gas Emissions

American Express is focused on efforts to minimize our carbon footprint. This will also be
encouraged for our suppliers and the impact they have on the emissions of our value chain.
We will work with our suppliers to reduce their impact on our value chain by inviting them to
track, reduce, and eventually neutralize their own operational greenhouse gas emissions.
American Express supports and encourages them to set science-based emissions reduction
targets.
Suppliers should work towards calculating their scope 1, 2 and 3 emissions on a yearly basis.
Suppliers should aim to provide accurate emissions data to American Express upon request
through preferred methods and channels (e.g CDP (Carbon Disclosure Project)). American
Express’s suppliers are encouraged to commit to setting net-zero targets in alignment with
the Science Based Targets initiative and share those targets and boundaries with American
Express, when they are publicly announced.

Oct 21, 2024

3.2 Paper Statement
American Express continues to source its direct marketing, customer communications, and
office paper from certified responsibly managed forests, including by the Forest Stewardship
Council, Sustainable Forestry Initiative, and Programme for the Endorsement of Forest
Certification. We expect our suppliers to source paper from certified responsibly managed
forests where applicable.
3.3 Waste/Water
We encourage all suppliers, where applicable, to reduce their waste and water consumption
and to track and manage this to the best of their ability.
4. Social

4.1 Anti-Discrimination
American Express aims to create a workplace where colleagues do not feel harassed or
discriminated against based on any protected characteristic, including, but not limited to, age,
race, national origin, immigration or citizenship status, color, disability, gender, gender
identity, marital status and partnership status, pregnancy and lactation accommodations,
caregiver status, sexual and reproductive health decisions, religion/creed, uniformed service,
and sexual orientation. We aim for our suppliers to follow this code, and not to engage in
unlawful discrimination in the workplace.
4.2 Supplier Diversity
American Express is committed to partnering with diverse and inclusive suppliers to deliver
products, services, solutions, and innovation. It’s important to us to forge meaningful
partnerships by promoting economic opportunities across our broad customer base and
business partners. American Express seeks to provide opportunities for procurement to
Minority Business Enterprises, Women’s Business Enterprises, LGBT Business Enterprises,
Veteran’s Business Enterprises, Service-Disabled Veteran’s Business Enterprises, Disability-
Owned Business Enterprises, and Small Business Enterprises.
We encourage suppliers of American Express to have a similar outlook or strategy to ensure
diversity within their supply chain.
4.3 Tier 2 Supplier Diversity Reporting
American Express reports on Tier 2 Supplier Diversity spend from suppliers to allow American
Express the opportunity to understand our supplier’s inclusion and diversity practices in their
supply chains, as well as seek to scale the impact of our Supplier Diversity program. This
information is reported within the annual ESG Report and is requested on a quarterly basis
from select suppliers. Please note: This is only applicable to Suppliers providing services in
the United States.
4.4 Economic Impact Reporting
American Express participates in Economic Impact Reporting to expand our measurement
impact beyond how much we directly spend with diverse suppliers to include impact within
the communities we serve through jobs created, wages earned, taxes generated, and more.

Oct 21, 2024

This information is reported within the annual ESG Report and does not require any additional
input from our Suppliers. Please note: This is only applicable to Suppliers providing services in
the United States.
4.5 Disability Statement
American Express encourages its suppliers to share and uphold its commitment to disability
inclusion. When providing goods and services, American Express encourages suppliers to do
the following:
1. Provide products and services that are accessible and usable to people with disabilities
and long-term medical conditions.
2. Promote their own disability commitment internally and externally.
3. Remove barriers, foster environments and provide reasonable accommodations as
appropriate for employees with disabilities and long-term medical conditions.

5. Reporting Concerns
American Express expects suppliers to maintain reporting and grievance mechanisms for
their employees to report concerns relating to the topics discussed in this Supplier Code of
Conduct.

In addition, if a supplier or supplier employee believes that an American Express employee or

another supplier or supplier employee providing services to American Express has engaged in
conduct in violation of this Supplier Code of Conduct or our American Express Code of
Conduct, they are expected to promptly report those concerns by telephone or through our
web portal to the Amex Ethics Hotline, anonymously if preferred. American Express strictly
prohibits retaliation for reporting concerns in good faith.

Oct 21, 2024