Supplier Code of Conduct

• COMPLIANCE WITH LAWS AND REGULATIONS
• BUSINESS PRACTICES AND ETHICS
• LABOR PRACTICES
• ENVIRONMENT, SOCIAL AND GOVERNANCE 
• DATA PRIVACY AND PROTECTION, INTELLECTUAL PROPERTY AND ASSETS
• MONITORING AND REPORTING CONCERNS

At Eventbrite (the “Company”, “we”), we are dedicated to fostering an environment that values high ethical standards and integrity in all that we do. Our Code of Conduct - which applies to our Board of Directors and all employees - outlines the standards for conducting business in an ethical, lawful and responsible way. In accordance with these standards, we have established this Supplier Code of Conduct to ensure our suppliers are committed to the same principles.

COMPLIANCE WITH LAWS AND REGULATIONS

Accessibility: Eventbrite is committed to partnering with Suppliers that comply with the Web Content Accessibility Guidelines (“WCAG”) 2.1 Conformance Level AA (“Access Standard”). Suppliers whose services integrate with the Eventbrite platform in a manner that presents the Supplier’s Third-Party content to Eventbrite’s end users agree to ensure that their Third-Party content complies with the Access Standard.

Anti-Bribery, Anti-Corruption, Anti-Money Laundering and Fair Dealing: Eventbrite is committed to dealing fairly and honestly with all our Suppliers, regardless of where they are located or the type of products or services they provide. Suppliers should never propose or enter into any agreement with a competitor to fix margins, prices or contractual terms, or to divide up the market in any way. Suppliers should never give or offer anything of value to gain an improper advantage, whether it be in dealings with government officials or the private sector. Suppliers are required to comply with all applicable laws and regulations, including but not limited to the Foreign Corrupt Practices Act (FCPA) and U.K. Bribery Act.

Suppliers should prevent and monitor for possible money laundering, terrorist financing or activity violating any applicable sanctions or export-based restrictions. Suppliers should ensure they are conducting business only with reputable customers and suppliers, for legitimate business purposes, with funds derived from legitimate sources.

Antitrust: Suppliers shall not participate in any anti-competitive conduct such as discussing or exchanging competitively sensitive information or agreeing to geographic markets, customers or pricing with competitors. Suppliers are required to comply with all applicable antitrust and fair competition laws.

Trade: Suppliers shall comply with applicable import and export laws, act in accordance with trade restrictions of the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) and any other applicable trade restrictions.

BUSINESS PRACTICES AND ETHICS

Conflicts of Interest: Suppliers shall avoid situations that create, or even appear to create, a conflict of interest with Eventbrite. Suppliers must not deal directly with any Eventbrite employee whose spouse, domestic partner or other relative has an interest in the Supplier as an employee, partner, owner, investor, or similar roles, including negotiating the Supplier contract. The Supplier should disclose that relationship to the Eventbrite Legal department.

External Communications: Suppliers shall not speak publicly on Eventbrite’s behalf unless authorized to do so by Eventbrite Legal.

Gifts and Hospitality: Suppliers shall avoid giving gifts or providing lavish hospitality to Eventbrite employees or their immediate family members. If offering a gift or hospitality to an Eventbrite employee or immediate family member, Suppliers should use good judgement and ensure it:

• is reasonable and not extravagant,

• is appropriate under the circumstances and serves a valid business purpose,

• is customary and appropriate under U.S. and local customs,

• is not being offered for any improper purpose and could not be construed as a bribe or payoff, and

• does not violate any U.S., local or international laws or regulations.

Insider Trading: Suppliers should comply with securities laws and may never buy or sell Eventbrite stock when in possession of material non-public information, or pass such information to any others, including friends or family.

Product and Service Quality: Any Supplier who is supplying products and services to Eventbrite shall meet and comply with applicable regulatory quality and safety standards, in addition to Eventbrite’s policies, procedures and contract requirements. Suppliers shall:

• Follow Eventbrite’s procurement rules and procedures, including not beginning any work for Eventbrite without an authorized purchase order and contract

• Conduct appropriate due diligence before engaging third parties, such as employees, agents, consultants, suppliers, resellers, or distributors

• Not subcontract work for Eventbrite unless subcontracting is permitted under the Supplier’s contract with Eventbrite or unless the Supplier obtains prior written consent from Eventbrite

Records Management: Suppliers shall accurately record, maintain and report financial and business information and comply with all applicable laws and regulations regarding such information. 

Risk Management: Suppliers shall implement internal policies, procedures and controls to identify, address and remediate risks addressed in this SCoC as well as applicable legal requirements.

Training and Communication: Suppliers shall communicate this SCoC to all employees or contractors who will be conducting business with Eventbrite and conduct training for such employees and contractors, when necessary.

Use of Artificial Intelligence: Supplier must not share any Eventbrite customer or confidential data with generative artificial intelligence (AI) third-party tools, including but not limited to:

• Personal identifying information (e.g., names, emails, phone numbers, addresses, etc.)

• Financial information (e.g., revenue, forecasts, or other non-public information)

• Source code

• Non-public strategic or product roadmaps

• Usernames and passwords

• API keys or secrets

• Documents or files containing any of the above information

• Material Non-Public Information Supplier has access to (if applicable)

• Trade secrets (e.g., proprietary technology, code base, client list, business strategies, or research plans)

• Information subject to confidentiality obligations 

Suppliers should closely check and verify all output content from AI tools, including testing code and conducting a human review of non-technical output for inaccuracies, biases or references to unsupported authority.

LABOR PRACTICES

Anti-harassment and Unlawful Discrimination: Eventbrite does not tolerate, and Suppliers shall not engage in, any form of discrimination, harassment or demeaning behavior against any individual or group on the basis of race, color, religion, sex, sexual orientation, gender identification, national origin or ancestry, citizenship, age, marital or family status, military or veteran status, physical or mental illness or disability, pregnancy or any other basis prohibited by applicable law.

Compensation: Suppliers shall provide compensation (including overtime and benefits) that at a minimum, complies with local laws. Suppliers must pay their employees in a timely manner and provide documentation detailing the basis of their pay (e.g., paystub).

Parental Leave: Suppliers shall abide by all applicable laws pertaining to parental leave, and offer paid benefits that are gender inclusive when possible. Work Hours and Age Laws: Suppliers shall comply with all applicable laws on work hours and overtime, as well as all applicable laws on wages and benefits. In addition, Suppliers shall observe all applicable legal requirements for work of employees under 18 years of age, particularly those pertaining to hours of work and working conditions.

ENVIRONMENT, SOCIAL AND GOVERNANCE 

Environment & Sustainability: Suppliers shall comply with all applicable laws for hazardous materials, air emissions, waste, and wastewater discharges. Eventbrite encourages Suppliers to conduct business in an environmentally responsible and sustainable manner, including: resource-efficient consumption of energy, water and other natural resources, minimizing waste and diversion from landfills, and reducing harmful chemical use.

Freedom of Association: Suppliers shall abide by all applicable laws pertaining to freedom of association and collective bargaining. Suppliers shall not retaliate against employees who choose to organize.

Health and Safety: Suppliers shall develop and implement health and safety management practices in all aspects of their business, including complying with all applicable occupational health and safety laws and regulations, including but not limited to laws and regulations that address occupational safety, emergency preparedness, occupational injury and illness, industrial hygiene.

Human Rights: We are opposed to all forms of discrimination with respect to employment and occupation, modern slavery, human trafficking, forced or compulsory labor, and child labor. In accordance with the United Nations Declaration on Human Rights and the International Labour Organization Declaration on Fundamental Principles and Rights at Work, we expect our Suppliers to share in our respect for human rights, employee health and safety, and a voluntary labor force.

Pre-Placement Background Screens: Suppliers shall comply with Eventbrite’s background screening processes and perform background checks on all Supplier’s personnel as required by Eventbrite.

Suppliers Diversity & Inclusion: Diversity, equity and inclusion are core to Eventbrite’s mission and we are committed to creating an inclusive culture where all of our employees can do their best work. We strongly encourage our Suppliers to put in place their own diversity and inclusion plans, comply with all applicable local laws and regulations, and ensure that a broad range of perspectives are included. We also encourage our Suppliers to partner with small and socio-economically diverse suppliers in their own procurement and subcontracting activities. Our Diversity, Equity and Inclusion team is happy to meet with any of our Suppliers who are early on their DEI journey and are looking for guidance and support.

Whistleblower Programs and Non-Retaliation: Suppliers shall maintain programs that ensure the confidentiality, anonymity and protection of employee whistleblowers, unless prohibited by law. Suppliers shall implement a communicated process for Suppliers’ employees to be able to raise any concerns without fear of retaliation.

DATA PRIVACY AND PROTECTION, INTELLECTUAL PROPERTY AND ASSETS

Data Protection: Suppliers shall protect confidential and proprietary information of Eventbrite, Eventbrite employees, creators, consumers, and others with whom we do business. Information should not be disclosed without proper authorization and should only be used for a legitimate business purpose. All information uses must comply with all applicable laws, regulations, and governing contracts.

Intellectual Property: Suppliers may only use Eventbrite’s intellectual property to the extent permitted under their contract with Eventbrite and must not infringe or misuse the intellectual property of Eventbrite or others. Eventbrite’s intellectual property (including name, logo, trademarks, etc.) and tangible assets should be used for legitimate business purposes and only when authorized to do so by Eventbrite. Suppliers agree they shall promptly remove any use of Eventbrite’s intellectual property upon Eventbrite’s request.

Privacy: Suppliers shall comply with all applicable data privacy laws including but not limited to the EU’s General Data Protection Regulation (GDPR), the CaliforniaConsumer Privacy Act (CCPA), as modified by the California Privacy Rights Act (CPRA), and the UK Data Protection Act.

MONITORING AND REPORTING CONCERNS

If a Supplier is in violation of this SCoC they are required to notify Eventbrite immediately.

Subcontractor Monitoring: Suppliers shall engage in monitoring and verification of their subcontractors to assess, prevent, remediate and/or report any actual or potential noncompliance associated with all sections of this SCoC.

Whistleblower Hotline: To report concerns about activity related to violations of this SCoC you may do so confidentially, anonymously (if desired), and free of retaliation. You may report violations to your contact at Eventbrite or by any of the following:

• Phone: +1 (800) 916-7037

• Online: https://irdirect.net/evtbrt/whistleblower_iframe 

• By Email: complianceofficer@eventbrite.com

• By Mail: Compliance Officer, 95 Third Street, 2nd Floor, San Francisco, CA 94103