Building Trust with Our Customers

We win business on the strength of our solutions and by building relationships based on integrity and trust. We never resort to bribery or other corrupt practices in pursuit of business.

We conduct our business ethically and free of bribery and corruption. Bribery undermines fairness, transparency, and trust in both the public and private sectors. It is illegal in every jurisdiction in which Salesforce does business, and its consequences are severe, potentially including fines and jail sentences.

We live our values by following all applicable laws and refuse to engage in corrupt activities, even if it carries a cost or we lose a business opportunity. No amount of profit is worth the sacrifice of our values, and pursuing success is never at the expense of our integrity.

We prevent bribery and corruption by:

• Never offering, promising, authorizing, giving, providing, soliciting, accepting, or receiving a bribe, kickback, or anything of value — directly or indirectly — to or from Government Personnel or others, to gain an improper business advantage
• Never engaging in facilitation payments, even where it may be legally acceptable
• Keeping accurate and complete records that truthfully represent all financial transactions
• Only doing business with third parties who share our commitment to integrity and ethical business practices
• Never using an agent, consultant, reseller, supplier, nonprofit organization, or any other third party to make any improper payments on our behalf — remember that anything we can’t do directly, we also can’t do indirectly (through a third party)
• Avoiding undisclosed arrangements with any stakeholders, needlessly complicated transactions, or hidden terms and conditions
• Contacting the Global Ethics & Integrity team when we need guidance

Below are some important definitions to help you understand bribery and corruption.

Bribery is the act of offering, promising, authorizing, giving, providing, soliciting, accepting, or receiving anything of value, directly or indirectly, to or from an individual or entity, in order to improperly induce, influence, or reward the actions 
or decisions of someone, to gain an improper business advantage, or to improperly obtain or retain business.

Anything of value is anything that has a value to the recipient (including their family members), or that would represent an advantage or could be exchanged 
for an advantage, financial or otherwise, directly or indirectly, to the recipient or 
their family members. Examples include:

• Cash
• Cash equivalents (money orders, gift cards, vouchers and certificates, securities, etc.)
• Gifts, entertainment, or meals
• Travel, transportation, or lodging
• Charitable contributions
• Political contributions
• In-kind services
• Offers of employment or internship
• A chance to win anything of value

A kickback is giving back some amount of money paid (or due to be paid) as a reward for a business arrangement. Accepting, soliciting, offering, promising, authorizing, or giving a kickback is a violation of our Code.  Government Personnel includes employees at any level of government (e.g., national, regional, or local), political appointees, elected officials, candidates for political office, members of a royal family, and employees of a Government Entity (including public international organizations like the International Monetary Fund, United Nations, or World Bank) or a Government-owned Entity. A facilitation payment is a tip or small payment to Government Personnel to expedite or secure a routine, non-discretionary government action, to which the payer would be entitled ordinarily. Such actions typically include issuing a permit or providing utility service. This is illegal in most countries and is always prohibited at Salesforce, per our Global Anti-Corruption Policy.

Giving or receiving appropriate business gifts and entertainment can help us build and strengthen business relationships with our stakeholders. However, gifts and entertainment must be undertaken with care. Improper gifts and entertainment present a serious risk to the company and to those with whom we do business. We never offer or accept anything to obtain any improper advantage, nor can we offer or accept anything that could improperly influence or reward an action or a business decision.

We sometimes offer or accept gifts and entertainment to or from our stakeholders as a token of esteem and appreciation. However, giving or receiving these gifts can present ethical and legal concerns to all parties involved. To protect our reputation and our stakeholders’ trust, it is important that we never offer, promise, authorize, give, provide, solicit, accept, or receive anything that could create real or perceived biases or conflicts of interest, improperly influence or reward actions or business decisions, or constitute a bribe.

We handle gifts and entertainment responsibly by:

• Ensuring that gifts and entertainment are infrequent, reasonable in amount, transparent in nature, in line with Salesforce values, and will not embarrass Salesforce if publicly disclosed
• Being mindful of what is legal and appropriate in the different locations and cultures where we do business
• Considering key factors related to gifts and entertainment, including permitted gift types, allowed monetary thresholds, and approval procedures, as established by the Global Gifts and Entertainment Policy
• Never soliciting gifts or entertainment for personal benefit
• Never soliciting or accepting gifts or entertainment from third parties in return for directing business to a particular organization
• Never using personal funds to provide gifts or entertainment on behalf of the company
• Taking special care if solicited for gifts or entertainment, which can result in actual or perceived bias, impropriety, or illegality
• Never using a consultant, reseller, supplier, nonprofit organization, or any other third party to offer gifts or entertainment that would not be appropriate for us to offer directly
• Understanding the restrictions that may apply and always complying with Salesforce policy with respect to gifts and entertainment involving Public Sector Customers, as they are often subject to specific and strict requirements related to gifts and entertainment
• Obtaining pre-approval from the Global Ethics & Integrity team, through the GEM app, before offering, promising, authorizing, giving, or providing any gifts or entertainment to Government Personnel, regardless of value or type, except otherwise noted in the Global Gifts and Entertainment Policy
• Never offering, promising, authorizing, giving, or providing any gifts or entertainment to someone with the intention to benefit Government Personnel, or to evade the pre-approval requirements established by the Global Gifts and Entertainment Policy
• Consulting your manager or the Global Ethics & Integrity team if you are not sure what is appropriate or allowed

Gifts and entertainment, as noted in this Code, is a nomenclature that refers collectively to gifts, entertainment, meals, travel and transportation, lodging and hospitality, or more broadly to anything of value. They can be an appropriate way to build and strengthen business relationships, as a token of esteem and appreciation. Gifts and entertainment should only be used for a legitimate business purpose, creating an environment for discussing business, with the promotion, demonstration, or explanation of Salesforce products and services.

Gifts and entertainment should not be (or appear to be) excessive, extravagant, or lavish. They should not create an appearance of impropriety or a sense of obligation or expectation.

We are privileged to have relationships with Public Sector Customers and public policy partners around the world. Strict laws and regulations govern our interactions with these customers and individuals. We embrace the special responsibilities of these relationships.

Public Sector Customers spend public funds when they enter into contracts. This means that both they and the companies they do business with are subject to heightened legal and ethical requirements. We earn trust by showing that we understand and respect these requirements. Not following these requirements could lead to contract termination, criminal and civil penalties, and suspension or debarment from government contracting.

We work ethically with the Public Sector by:

• Taking special care when doing business with Public Sector Customers and public policy partners, as these interactions are often subject to specific and strict requirements
• Understanding and complying with the governmental restrictions that may apply
• Always complying with Salesforce policy and applicable laws related to interacting with Public Sector Customers and public policy partners
• Obtaining pre-approval from the Global Ethics & Integrity team, through the GEM app, before offering, promising, authorizing, giving, or providing any gifts or entertainment to Government Personnel, regardless of value or type, except otherwise noted in the Global Gifts and Entertainment Policy
• Never offering, promising, authorizing, giving, or providing any gifts or entertainment to someone with the intention to benefit Government Personnel, or to evade the 
pre-approval requirements established by the Global Gifts and Entertainment Policy
• Being mindful that Public Sector Customers may have maximum thresholds applicable for receiving gifts and entertainment, and may need to disclose and record such instances in their entity's records
• Following all government procurement and lobbying disclosure requirements
• Making sure all our communications with and submissions to Public Sector Customers and public policy partners are transparent and accurate

Public Sector Customers include Government Entities, Government-owned Entities, and Government Personnel, defined below. Public Sector Customers include not only our customers, but also prospective customers and business partners. For the latest version of these definitions, please consult the Global Public Sector Addendum to the Code of Conduct.

• Government Entity means any national, state, provincial, municipal, local, First Nations, or Native American governmental organization, including any department, agency, ministry, instrumentality, or branch of such organizations, as well as public international organizations like the International Monetary Fund, the United Nations, and the World Bank.
• Government Personnel includes employees at any level of government (e.g., national, regional, or local), political appointees, elected officials, candidates for political office, members of a royal family, and employees of a Government Entity.
• Government-owned Entity means organizations owned or controlled by a Government Entity. Examples include:
  • Companies that are owned (30% ownership or more), controlled, or funded by a Government Entity
  • Companies that perform government functions on behalf of government (also known as “State-Owned Enterprises” or “SOEs”), such as a public school or university, public hospital, state-owned oil company, bank, airline, energy, water and other utility, customs agency, or sovereign wealth fund
  • Companies owned or controlled by a royal family or, if outside of the U.S., a political party

Communications with some Government Personnel that attempt to influence their decision-making may trigger lobbying compliance requirements for Salesforce and individual employees such as registration and disclosure filings.

Our relationships with business partners such as agents, consultants, suppliers, resellers, and distributors help us serve customers around the world. Their actions reflect on us and have impact on the world. As a result, we only work with business partners who will uphold our values.

Our relationships with business partners are important to our work. We must be able to trust that these partners are committed to doing business our way — fairly and with integrity. We can be held liable for the misconduct of our business partners and suppliers, even if we aren’t aware of the misconduct.

We ensure our business partners share our values by:

• Only working with those who have passed a risk-based due diligence process (including risk-based legal due diligence for resellers, consulting partners, and strategic partners), and who meet our engagement requirements
• Only doing business with business partners who share our commitment to integrity and ethical business practices
• Never using a business partner to do anything that our policies or the law does not allow us to do directly
• Avoiding even the appearance of conflicts of interest in our business partnerships
• Never soliciting or accepting anything of value from a business partner in return for retaining business or directing business to a particular organization
• Choosing and evaluating all business partners based on clear and objective measures such as quality, service, price, and availability
• Reporting to EthicsPoint any good-faith concerns of third-party misconduct

We compete for and win business through ethical and honest practices in the marketplace. We collect information about our competitors through legitimate sources and never try to restrain free and fair trade.

Competition laws (also known as antitrust laws in the U.S.) help ensure a level playing field for all businesses. These laws prohibit agreements that would lessen competition or restrain trade. By complying with competition laws, we do our part to support fair competition. Failure to comply with applicable competition laws is a violation of Salesforce’s Global Antitrust Policy and can also have serious legal consequences.

We compete fairly by:

• Never discussing or reaching agreements with competitors on pricing, bidding, or allocation of customers or markets
• Never exchanging competitively sensitive information with our competitors
• Never reaching improper agreements or understandings with other companies to refrain from hiring or recruiting each other's employees (sometimes referred to as “no-poach” agreements)
• Never dictating the prices at which Salesforce business partners must sell to end customers
• Never agreeing to any suggestions by competitors to enter into agreements or arrangements that may restrain competition and promptly reporting such incidents to the Salesforce Antitrust Legal team
• Never gathering information about our competitors, directly or indirectly, through manipulative or deceptive means

In addition, it’s important that we communicate with care, both internally and externally, so as not to create the misimpression that Salesforce engages in any kind of anticompetitive or abusive behavior, acts dishonestly or in bad faith, or dominates any potential market. All such practices create potential legal concerns for Salesforce.

Examples of activities that could violate competition laws include:

• Dividing or allocating markets, where competitors agree to limit their sales activities related to particular territories or customers in a way that allocates customers or markets between them
• Price fixing, where competitors agree to charge particular prices for certain products or services
• Agreements among companies not to hire or recruit their respective employees
• Boycotting, where competitors agree to avoid dealing with a particular customer or supplier
• Bid rigging, where competitors agree among themselves to bid in a way that allows a certain bidder to win

Keep in mind that “agreements” do not have to be signed contracts or otherwise memorialized in writing to be problematic. An informal written or oral understanding with a competitor, or even a conversation that implies an understanding, can be a problem. If any of these topics come up while you are talking with a competitor, stop the conversation immediately and report it to the Salesforce Antitrust Legal team. Important note: A Salesforce partner, such as a reseller or a system integrator, can also be a competitor to Salesforce in certain situations. In these situations, it is important for the Salesforce team competing against the partner to treat the partner

We do business with the utmost integrity and communicate honestly with our stakeholders.

Being clear and candid about the genuine value of our products and services builds trust with our stakeholders and keeps our reputation strong.

We do business honestly by:

• Describing and representing our products and services and the capabilities of our channel network honestly and not making commitments we know we cannot meet
• Understanding the needs of our customers and offering solutions and information aligned with those needs
• Complying with applicable legal requirements when interacting with procurement officials and participating in public tenders, not drafting technical specifications so as to improperly favor Salesforce in a public tender, and never submitting false information in response to an opportunity or tender
• Never doing anything illegal, dishonest, or lacking integrity to win or keep business
• Maintaining accurate sales and other business records, including, but not limited to, accurate records of all negotiations and agreements

Salesforce is committed to following all international trade laws that govern our business worldwide. These include export control, economic sanctions, anti-boycott, and customs laws and regulations.

International trade laws affect how we sell and export our products and services around the world. As a U.S.-headquartered company, Salesforce and all its employees must comply with U.S. sanctions, export control laws, and regulations in our operations around the world, including at each of our global subsidiaries. Other countries’ laws and regulations may apply to our regional or global operations as well. These laws are complex and vary across jurisdictions. Violations can mean large penalties for Salesforce. Understanding and following these laws helps protect our reputation and the future of our global business.

We conduct global trade with integrity by:

• Knowing and following the export control rules, classification procedures, and reporting requirements that apply to selling our software and services around the world
• Screening customers and business partners to identify sanctioned or restricted parties
• Implementing controls to prevent access from embargoed territories
• Reviewing red flags that may indicate a prohibited transaction
• Implementing controls on international shipments
• Alerting the Global Trade team about any possible trade compliance concerns, including any concern that a transaction may involve a prohibited party, end-use, or territory, and any request to participate in an international boycott

When we use powerful new tools such as Artificial Intelligence (AI) and other emerging technologies, we do so carefully and with integrity. We also work to identify risks and help our customers and business partners use our products ethically.

We know how quickly technology evolves. Technologies such as AI can help make us more productive and creative, but their use can also raise ethical concerns. We are committed to the responsible use of AI and technology in general, and we hold our customers and business partners to the same standards in their use of our products.

We use technology wisely and ethically by:

• Only using AI for internal tasks and projects if we have explicit approval to do so, as outlined 
in the policies and other documents governing the use of AI at Salesforce
• Complying with our internal policies when using third-party AI, or Salesforce products or functionalities with AI
• Protecting data privacy and intellectual property when using technology, including AI tools
• Carefully reviewing AI-generated content for accuracy and appropriateness before using it

Risk identification is a crucial part of ensuring that our products are not used in prohibited ways. Risks posed by customer or partner activity require subject matter expert evaluation and may lead to account suspension, service limitations, or onboarding denial for prospective customers.

Promptly report any concerns regarding the potential improper use of our products, including disallowed AI product usage, by existing or prospective customers or partners (including resellers, AppExchange (ISV) partners, and consulting partners) to the AUP Compliance team.

For issues related to the potential improper use of our products by employees, including but not limited to AI products, please report concerns to EthicsPoint .

We treat all Customer Confidential Information with the utmost integrity and handle it in compliance with our contractual commitments and data protection laws.

Protecting the security and privacy of Customer Confidential Information strengthens customer trust in Salesforce. We comply with the many laws and regulations that apply to the collection, storage, use, transfer, and disposal of Customer Data and always respect the confidential information of our customers.

We protect Customer Confidential Information by:

• Respecting customer instructions regarding the processing, security, and confidentiality of Customer Confidential Information
• Never disclosing Customer Confidential Information to anyone outside of Salesforce without the approval of the Salesforce Legal team
• Using Customer Confidential Information only as needed to provide services to our customers and sharing it only with those who have permission to view it
• Understanding and following all the data protection and privacy laws that apply to our work in different countries
• Reporting any suspected or confirmed security incidents to the Information Security team

Customer Confidential Information includes all information disclosed by a customer to Salesforce, whether orally or in writing, that is designated as confidential or that reasonably should be understood to be confidential given the nature of the information and the circumstances of disclosure. Customer Confidential Information includes Customer Data.

Customer Data includes all information and data that customers and their users submit to Salesforce or that are submitted on behalf of customers through Salesforce services or applications, such as contacts, account information, marketing data, health data, and any other information that a customer processes or stores on Salesforce services.