WeWork Global Vendor Code of Conduct

I. Introduction

The WeWork Global Vendor Code of Conduct (the “Vendor Code”) sets forth our standards and guidance for living up to our mission of reinventing the way people work through designed space, flexibility, technology and community.  Our reputation, and the trust that our members and clients place in us, drives the success of our global brand. The Vendor Code sets expectations and shared standards that apply to all Vendors to WeWork, including any company, corporation or individual supplying and/or delivering products, components, materials or services to WeWork (“Vendors”). This extends to workers for vendor companies, including hired workers, on-site temporary workers, piece rate workers, contracted workers, trainees and workers on trial or probation.

Our Vendor Code should always be applied alongside the laws and regulations of the countries in which we operate and other WeWork policies and procedures.  If you think a conflict exists between this document and applicable law, rule, or regulation, follow the applicable law and then reach out to your contact on WeWork’s sourcing and supply chain team. If you are unsure of who to contact, contact our Compliance & Ethics team at compliance@wework.com, or reach out using our Helpline.

All products and services provided to WeWork should meet regulatory quality and safety standards set by the relevant standards body, as well as meeting WeWork policies, specifications, and standards.

II. Reporting & Compliance

Reporting Incidents & Violations
Vendors shall report any incident, behavior or other circumstances that are or may be regarded as or potentially resulting in non-compliance with the principles and expectations specified in the Vendor Code to their WeWork Sourcing & Supply Chain contact.

WeWork will never retaliate or permit retaliation against anyone who makes a good faith report about possible misconduct or legal violations to us or a government authority, or assists in an investigation of misconduct or legal violation. The Helpline (helpline.wework.com) can be used to report confidentially if you believe a violation has occurred.

Monitoring and Auditing
Vendors shall maintain sufficient records and documentation to demonstrate compliance with all requirements in this Code.

Monitoring, due diligence, audits, and similar activities as needed to ensure compliance are the responsibility of the Vendor. WeWork reserves the right to audit or inspect Vendors’ records and facilities, as applicable and permitted by law, to confirm compliance.

WeWork reserves the right to assess supplier sustainability and responsible procurement performance through EcoVadis. The frequency of the EcoVadis assessment will be determined by the supplier’s score and will be communicated to the supplier ahead of time. Suppliers who are asked to join EcoVadis will be expected to complete the assessment within 60 days.  The EcoVadis assessment covers criteria from the following categories: environment, labor and human rights, ethics and sustainable procurement. These categories align with WeWork’s sustainability, sourcing and procurement goals outlined in this document. Suppliers may be asked to provide further information or evidence to support claims and compliance with the practices and policies outlined in this document.

Training and Communication
Vendors are expected to establish policies,  procedures, and training as needed to ensure compliance with the policies in this Vendor Code and applicable laws and regulations.  Violations and concerns should be reported promptly to the appropriate authority, maintaining confidentiality to the extent permitted by law.

Consequences for Noncompliance
In addition to its rights and remedies under any applicable contracts and laws, WeWork may refuse to do business with any Vendor that does not comply with this Vendor Code, in WeWork’s sole discretion.  WeWork will determine the appropriate remedial action under the law, applicable contracts, and this Vendor Code prior to continuing a business relationship with any Vendor that it deems to be noncompliant.

Ask For Help
Have a question or concern?  Reach out to your WeWork Sourcing & Supply Chain contact or WeWork’s Global Supply Chain Sustainability team at sustainability@wework.com.

III. Ethics

WeWork is committed to operating and competing on the merits of our work, products, and services.  Vendors are expected to respect and adhere to the applicable laws, rules, and regulations of the countries in which they do business and take appropriate care when engaging others to work on our behalf.

Anti-Corruption
Vendors shall comply with applicable local laws at all times, including anti-corruption laws. WeWork Global Anti-Corruption Policy applies to all officers, directors, and employees of WeWork, but also WeWorks’s agents, vendors, and suppliers and their subsidiaries/other controlled business entities worldwide. 

Vendors shall not directly or indirectly authorize, offer, promise, or give anything of value to a government official or commercial party with the intent to obtain or retain business or any other improper business advantage or as an inducement to do something that is dishonest, illegal, or a breach of duty or trust in the conduct of business. This prohibition covers facilitation or “grease” payments, which are small payments made to government officials to expedite performance of a routine, non-discretionary governmental action, such as obtaining utility services or expediting customs clearance.

This prohibition should be interpreted broadly. A thing of value can include anything of tangible or intangible value, such as cash and cash equivalents, gifts, travel, entertainment, charitable contributions, offers of employment, unpaid internships, and preferred opportunities for select members. A government official can include officers and employees of local governments, national governments, government-owned or -controlled companies, political parties, candidates for office, or international organizations. While family members of government officials are not themselves deemed government officials, caution should be paid when interacting with family members of officials. A business advantage includes obtaining or retaining business or gaining any other advantage, such as reduction in taxes, tolerance of non-compliance with applicable rules, securing zoning or construction permits, inducing a private sector person to do anything unethical, dishonest, illegal, or otherwise in breach of his or her duties, or obtaining other favors or preferential treatment.

Antitrust and Competition Laws
WeWork believes in fair and ethical competition. Vendors must not violate antitrust and competition laws, including laws addressing price discrimination, price fixing, restraint of trade, and monopolies.

Vendors must act confidentially and lawfully when handling competitive and proprietary information and not create an unfair advantage through manipulation, concealment, inappropriate use or misuse of confidential information, misrepresentation of material facts, or any other unfair dealing practices.

Conflicts of Interest
Vendors shall avoid conflicts of interest in accordance with the WeWork Conflicts of Interest Policy. Conflicts include, but are not limited to, advantages, business opportunities, and loans or favors that the Vendor or someone with a personal relationship to the Vendor may receive through your relationship with WeWork.

Vendors must always disclose potential or actual conflicts of interest to WeWork’s Compliance & Ethics team  at compliance@wework.com, or the Helpline. Vendors will never be penalized for reporting a possible ethics concern in good faith.

Anti-Money Laundering Laws
Vendors shall not knowingly participate or facilitate a scheme to launder money, under-report the size of cash transactions, wrongfully avoid tax liability, or other violations of applicable anti-money laundering laws in accordance with the WeWork Anti-Money Laundering Policy.

Independent Auditors
Vendors shall cooperate with independent auditors. Vendors shall not omit material facts or make false or misleading statements in connection with any audit, review, or examination of practices and financial statements as applicable. Attempts to coerce, manipulate, mislead, or fraudulently influence any auditor conducting a review are a violation of the Vendor Code.

Protecting Confidential Information & Company Assets
Vendors must protect the WeWork’s confidential and proprietary information, including non-public information entrusted to us by employees, members, clients, students, or other business partners. This includes disclosing confidential and non-public information without a valid business purpose and prior authorization, including to people within WeWork who have no need to know such information to perform their responsibilities.  Disclosure is acceptable when legally permitted or required.

Any unauthorized use or distribution of WeWork assets by a Vendor is a violation of the Vendor Code. This includes our intellectual property; strategic, operational, business, and marketing plans; engineering ideas; designs; salary and other compensation information; employee and member identification and personal data; credit card data; and all other unpublished financial data.

Don’t Speak on Behalf of WeWork 
Vendors shall never speak on WeWork’s behalf or with the press about WeWork or its operations without permission from our internal Communications team. All media inquiries regarding WeWork and its operations must be referred to press@wework.com

IV. Providing a Safe and Respectful Working Environment

Anti-Discrimination 
WeWork seeks to work with Vendors committed to creating respectful working environments free of discrimination. Vendors shall not discriminate or deny equal opportunity to applicants or employees, including temporary employees and their employees, on any grounds or characteristic protected by applicable local law.  This includes (but is not limited to) gender, sexual orientation, marital/civil status, pregnancy (including childbirth, lactation, or related medical conditions), gender identity, gender expression, transgender status of gender reassignment, race, color, ethnicity, national origin or ancestry, religion or belief, age, disability, genetic information (including testing and characteristics), veteran status, or uniformed service member status, including all other protected characteristic provided by local, state, and federal law.

Anti-Harassment 
Vendors shall establish policies and procedures to prevent harassment in the workplace,  including gestures, language, physical contact, or other actions meant to demean, humiliate, embarrass, or intimidate, sexual or otherwise. Vendors shall establish procedures to ensure a prompt and thorough investigation of reported claims of harassment.

Health and Safety
Vendors shall provide workers with a safe and healthy workplace that complies with all applicable health and safety laws, regulations, and requirements and take proactive measures to prevent their workers from exposure to workplace hazards.  Relevant health and safety policies include, but are not limited to, fire protection, fumes, air ventilation and filtration, temperature, noise, light, and other internal environmental quality issues.

If food is provided by Vendors for their workers, they shall comply with all applicable laws, rules and regulations for food health and safety.

If housing facilities are provided by Vendors for their workers, they shall comply with all applicable laws, rules and regulations for housing in the relevant jurisdiction and ensure quality of life for residents. The infrastructure of the buildings shall ensure the personal safety of the residents, including but not limited to, safe drinking water, safe sanitation facilities, and separation from buildings containing hazardous or flammable materials and processes.

Chemical Management and Disposal
Vendors shall comply with all applicable laws and classification regulations relating to the purchasing, storage, handling, use and transportation of chemicals and maintain valid permits for any chemicals that are legally restricted or controlled.

To ensure safe handling and storage of chemicals, Vendors should provide training to all workers, maintain an updated list of chemicals and material safety data sheets (MSDS) from chemical suppliers, and ensure safe storage and transport of chemicals in a way that prevents emissions to air, ground and water. 

Vendors should create policies and processes as needed to ensure safe environments and products.  Suggested measures include the use of supplier chemical and toxicity management platforms for maintaining accurate chemical inventories; maintenance of bill of materials for each product with all ingredients identified by name and Chemical Abstract Service Registration Number (CASRN) and/or European Community Number (EC Number); regular product emissions testing; and creation of a chemical ingredient disclosure for final products, such as Health Product Declarations (HPD), the Globally Harmonized System of Classification and Labeling of Chemicals rev.6 (2015) (GHS), or similar.

V. Protecting Our Global Community: Labor & Human Rights

WeWork is committed to acting with integrity in our business dealings and in our supply chains. We aim to implement and enforce effective systems and controls that promote workplaces free from child labor, forced labor, and human trafficking, while also supporting fair wages and safe and humane working conditions. We expect the same high standards from all of our contractors, Vendors, and other business partners. 

No Child Labor
WeWork does not tolerate child labor. Vendors shall comply with all applicable laws and regulations in their country of production or operations regarding age appropriate work.  

Vendors should take appropriate measures to ensure that no workers under the legal age for employment are used at their own place of production or operations or at their subcontractors’ place(s) of production or operations.  Vendors should protect young workers of legal working age from any type of employment or work likely to jeopardise their health, safety or morals.  According to law, this includes preventing young workers from performing hazardous jobs and avoiding night shifts, and ensuring minimum wages.

Child labor is defined as work performed by children, which interferes with a child’s right to healthy growth and development and denies him or her the right to quality education.  Additional information on the term ‘child labor’ and relevant internaional standards can be found from the International Labor Organization (ILO) and Principle Five of the UN Global Compact.

No Forced Labor
WeWork has a zero-tolerance approach to modern slavery. Forced or bonded labor must never be used in the production or services supplied to WeWork. For more information regarding our Modern Slavery statement, please see www.wework.com/legal/uk-modern-slavery-statement

Vendors shall comply with relevant national and international laws and regulations and provisions applicable in their country of production or operations.  Vendors should take appropriate measures to ensure that no forced labor occurs at their own place of production or operations or at their subcontractors’ place(s) of production or operations.

Forced labor includes any work or service that a person has not offered themselves voluntarily or have been compelled to carry out under threat of punishment or confiscation of any personal belongings, such as ID card, passport etc. This also includes involuntary prison laborers or military personnel employed as part of their active service. 

Vendors should allow all employees to leave their employment freely upon reasonable notice and refrain from withholding wages, I.D. cards, passports, travel documents, bank payment cards, or other personal belongings, or delaying payments of workers’ salary more than one month more than once every six months.

Social Dialogue
Vendors must respect the right of all workers to freely associate and bargain collectively in accordance with all applicable laws and regulations.

Working Hours
Vendors should ensure that working hours and overtime do not exceed applicable legal limits for their workers.  This includes appropriate time off for meals and breaks and time off/leave from their job according to applicable legislation, local traditions and standards, including. sick/medical leave, annual/earned leave, maternity leave, national holidays, etc. Vendors should maintain a transparent, reliable system for recording working hours and wages of all workers.

Living Wages
Vendors should compensate employees fairly and follow local wage regulations or collective agreements regarding minimum wage, including compensation for overtime.  Wages should be paid at regular intervals and on time with respect to work performed, according to local legislation. The International Labor Organization (ILO) recommends that wages are paid monthly, at a minimum.

Vendors should provide written information, prior to employment, to the worker regarding wages and terms of employment to document the Vendor’s accordance with applicable laws and regulations.

Vendor Diversity
Vendors are encouraged to use diverse businesses. Examples of diverse Vendors include: minorities, women, individuals with disabilities, veterans, lesbian, gay, and bi-sexual or transgender. 

Supporting Our Global Community
WeWork seeks to work with companies who share our vision of elevating the world’s consciousness.  We encourage our Vendors to also engage with the communities where they work and operate to support the social and economic development and the sustainability of our global community.

VI. Protecting Our Global Resources: Environment & Sustainable Procurement

WeWork has a fundamental mission to build and support healthier communities. That means being a model citizen of the global community. We are committed to providing spaces that help people, cities, and the planet thrive.  We seek to address the environmental and health impacts associated with the energy, materials and products that we use, in an effort to leave the world a healthier and more sustainable place, and we seek to work with Vendors who share our values and mission.

Environmental Laws and Regulations 
Vendors must comply with all applicable laws and regulations relating to environmental protection, including necessary permits and test reports if required. These regulations include (but are not limited to): 

  • Environmental classification, reporting, and inspections by authorities.
  • Emissions to the air
  • Emissions to the ground and water
  • Hazardous & Non-Hazardous Waste Management (see additional requirements below)
  • Noise pollution
  • Ground (Site) contamination, including investigation and assessment of possible risks due to previous or ongoing activities on site.

Energy and Carbon Reductions
WeWork is committed to reducing our energy use and becoming operationally carbon neutral by 2023. We seek to work with Vendors who share our vision of the future and are committed to reducing their contribution to climate change. 

Vendors are expected to measure and record energy consumption for all facilities and processes and account for energy use intensity on a per unit or per area basis (such as kWh/sf of product) to demonstrate reductions over time in a consistent manner.  Renewable energy use should be tracked separately to document the percentage of energy use provided by renewable energy. WeWork recommends setting annual energy reduction targets in the form of an energy reduction plan available in writing, with measurable goals and time frames.

Vendors should consider the creation of an ISO 14044 compliant life cycle assessment or third party verified Environmental Product Declaration (EPD) to document the product life cycle impact and global warming potential. EPDs should be compliant with ISO 14025 and EN 15804 or ISO 21930.

Water Use Reductions
Vendors are expected to measure and record water consumption for all facilities and processes and  account for water use intensity on a per unit or per area basis (such as gallons/sf of product) to demonstrate reductions over time in a consistent manner.

WeWork recommends the creation of a water reduction plan with measurable goals and time frames, including measures such as efficient water fixtures and collection of water for reuse on site.

Waste Management and Reductions
Vendors should measure and record their use of raw materials and waste generation for all facilities and processes and investigate opportunities for reducing raw material extraction and waste management.

Recommended measures include:

  • Efficient production strategies to reduce material waste
  • Efficient packaging practices and use of plastic alternatives, including fiber
  • Waste audits on an annual or semi-annual basis
  • Designing for efficient material use and use of byproducts and recycled ingredients to reduce non-virgin material extraction, including 
  • Recycling or composting of waste with available recycling and compost streams, and replacement of non-recyclable waste streams from the product supply chain
  • Creation of extended producer responsibility programs, including ‘take-back’ or rental programs

Vendors must ensure compliance with applicable laws & regulations relating to handling, storage, transportation, recycling and disposing of hazardous and non-hazardous waste, and obtain the necessary permits when required.  

Vendors should ensure safe handling and storage of waste:

  • Establish and maintain a list of hazardous and non-hazardous waste to monitor the type and quantity that is generated that clearly identifies which waste streams are hazardous.
  • Establish a procedure for the handling, storing, transportation and disposal of hazardous & non-hazardous waste that prevents harmful emissions to air, ground and water, prevent risks of ignition/explosion, and ensures worker health and safety.
  • Facilitate recycling whenever possible (non-hazardous waste only)
  • Ensure that workers handling hazardous waste are adequately trained and all waste contractors are licensed according to applicable legislation.

Vendors must not land-fill or incinerate hazardous waste on-site. If non-hazardous waste is landfilled or incinerated on-site, all relevant legal requirements must be followed and documented for review.

Sustainable Procurement Policies
Vendors should exercise proper due diligence and comply with all applicable laws and regulations regarding the ingredients or components sourced for their products.

WeWork is committed to reducing its environmental impact through its procurement policies, and we encourage our Vendors to adopt similar internal policies. 

VII. Amendment and Waiver

WeWork reserves the right to amend, alter, or terminate this Vendor Code at any time for any reason.