Supplier Code of Conduct

Last Updated March 2021

Sonder (“Sonder”, “we” or the “Company”) views its responsible business commitments through the framework of: People, our employees and guests, the core of our business. Place, the communities Sonder calls home. And Planet, the environment and minimizing our impact.

The Supplier Code of Conduct (the “Code”) outlines the standards expected of Sonder suppliers. For the purposes of the Code, “Supplier(s)” means any company, individual or entity that sells, or seeks to sell, goods or services to Sonder. The Code holds the Company’s employees and all of those representing Sonder, such as Suppliers, to high ethical standards, particularly during challenging situations.

The Code is based on the standards set out in the Responsible Business Alliance (RBA) Code of Conduct and sets out the social, environmental and ethical standards we expect our suppliers to abide by. The Code draws from the internationally recognised standards and norms standards including the Universal Declaration of Human Rights, ILO International Labor Standards, OECD Guidelines for Multinational Enterprises and ISO and SA standards.

Suppliers should have appropriate management systems in place and take steps to comply with the Code of, including transparency concerning policies and practices and related employee education. Additionally, Suppliers are expected to hold their own suppliers and any sub-suppliers / subcontractors to the standards articulated in the Code or other standards that are at least as strict.

Sonder reserves the right to contractually agree to annual audits and assessments of Supplier facilities to ensure that reasonable efforts are being taken by Suppliers to operate in a manner consistent with the fundamental principles of the Code. Sonder may also hire or work with independent third parties to perform any such assessments, audits and inspections. Violations of the Code will be brought to the attention of the Supplier, and may lead to disciplinary action and escalation, including termination of the supplier relationship or entering into a mutually agreeable remediation plan.

Core Governance Principles

Legal Compliance

Sonder abides by high standards of business ethics everywhere we operate. Our Code is clear – we expect Suppliers to understand and comply with all applicable laws of the countries in which they operate. Our standards may exceed those requirements, but they never fall below them. If Suppliers witness or suspect conduct that is inconsistent with the Code or the law, we want to know about it. Suppliers should raise concerns about business ethics to their Sonder point of contact or [email protected]

Purchasing Practices

We strive to be fair and impartial in our dealings with Suppliers and outside contractors. Purchasing decisions must be based on legitimate, defined criteria, including quality, service levels and price. We honor the terms and conditions of contracts, and protect the confidentiality of the proprietary information of Suppliers and outside contractors. We expect our Suppliers to do the same.

Fair Dealing

All Sonder employees and Suppliers are obligated to deal fairly with fellow employees and with our customers, other suppliers, competitors, and other third parties. This means it is prohibited for Sonder employees or Suppliers to take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation, or any other unfair-dealing practice.

Protecting & Using Information

Sonder and its Suppliers are committed to safeguarding and handling third party information in accordance with applicable laws, our policies, contractual obligations, and in a manner that protects privacy and preserves customer and team member trust. Sonder does not tolerate the inappropriate acquisition, possession or use of proprietary, confidential or trade secret information of Sonder’s competitors or other third parties, such as vendors, suppliers, owners and former employers.

Sonder and its Suppliers are expected to safeguard all customer confidential information and electronic data. Intellectual property rights are to be respected, transfer of technology and know-how is to be done in a manner that protects intellectual property rights, and customer and Supplier information is to be safeguarded.

Bribery & Other Corrupt Practices

Sonder and its Suppliers are committed to conducting their business in compliance with all laws prohibiting bribery and other corrupt practices. As a U.S. based company, Sonder’s business operations around the world must comply not only with local anti-corruption laws, but also with laws that apply to Sonder’s business activities around the world, such as the U.S. Foreign Corrupt Practices Act (the “FCPA”) and the U.K. Bribery Act. The FCPA prohibits Sonder and any of its Suppliers from offering or giving “anything of value” to a government official or their family members to influence that person in their official duties or to encourage improper or unlawful conduct. The U.K. Bribery Act’s prohibitions on bribery also cover bribes offered to private business people.

Our rule is clear: Don't bribe anybody, anytime, for any reason.

This prohibition applies both to activities undertaken by Sonder employees, Suppliers, and by third parties on behalf of Sonder. As noted above, violations of the Code will be brought to the attention of the Supplier, and may lead to disciplinary action, including termination of the supplier relationship.

Anti-Money Laundering

Sonder employees are prohibited from engaging in or facilitating transactions anywhere in the world that involve funds that were derived from illegal activities and expect the same from our Suppliers and their employees. Sonder and its Suppliers must comply with all applicable anti-money laundering laws, rules and regulations of the U.S. and all other countries where we do business. Therefore, all payments and transactions with customers, vendors, Suppliers, agents and affiliates will be scrutinized. We will not accept any funds or make any payments that appear to be derived from illegal activities.

Core Social Principles

Human Rights

Sonder complies with the employment and labor laws in every country and region in which it operates and expects its Suppliers to do the same.

Prohibition of child labor

The employment of children is prohibited. The minimum age of admission to employment may not be lower than the minimum school-leaving age, regardless if conditions are more favorable to young people. Young people admitted to work must have working conditions appropriate to their age and be protected against economic exploitation and any work likely to harm their safety, health or physical, mental, moral or social development or to interfere with their education.

Clear and fair terms of employment

All workers shall be provided with clear, written information about their employment conditions with respect to wages before they enter employment and as needed throughout their term of employment. Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. Sonder requires that all workers are afforded humane working conditions. Working hours must comply with national laws and industry standards. Overtime must be voluntary and in line with local laws.

Employment is freely chosen

Sonder has a zero-tolerance approach to modern slavery, including all forms of human trafficking and forced or bonded labor.

All workers shall be free to leave work at any time or terminate their employment without penalty if reasonable notice is given as per the worker’s contract. Suppliers and their agents and sub-agents may not hold or otherwise destroy, conceal, or confiscate identity or immigration documents, such as government-issued identification, passports, or work permits. Suppliers can only hold documentation of their employees if such holdings are required by law. At no time should workers be denied access to their personal documents. Workers shall not be required to pay Suppliers’ agents’ or sub-agents’ recruitment fees or other related fees for their employment. If any such fees are found to have been paid by workers, such fees shall be repaid to the worker.

Sonder and its Suppliers should pay particular attention to the risks of exploitation that both domestic and foreign migrant workers face.

Freedom of association and right to collectively bargain

Sonder respects, and we expect our Suppliers to respect, the rights of workers to join, form or not to join, an association of their choice without fear of reprisal, interference, intimidation or harassment. Workers should be free to exercise collective bargaining without fear of reprisal, interference, intimidation or harassment. Where the right to freedom of association and collective bargaining is restricted under law, the employer should facilitate, and not hinder, the development of parallel means for independent and free association and bargaining.

Non-Discrimination & Harassment

Sonder and its Suppliers do not tolerate any form of harassment or discrimination based on any characteristic protected by applicable law. Any behavior, communication, or other conduct that creates an intimidating, offensive, abusive or hostile work environment, or that otherwise interferes with any worker’s ability to perform his or her job, is unacceptable. All workers will be treated with respect and dignity and Sonder and its Suppliers will not allow physical or mental punishment or abuse of any team members.

Diversity, Equity, and Inclusion

Sonder seeks to encourage diverse Suppliers who provide quality products and services at competitive pricing to participate in our contracting and subcontracting activities and encourages its suppliers to do the same. Examples of diverse suppliers include those that are owned, managed, and/or operated by: minorities, women, individuals with disabilities, veterans, lesbian, gay, and bi-sexual or transgender.

Safe & Healthy Work Environment

Suppliers are responsible for understanding and complying with all applicable safety and health laws and guidelines. Suppliers are responsible for identifying, assessing and mitigating health and safety hazards and security concerns. Suppliers are responsible for conducting health and safety training and communicating health and safety information in local languages. These trainings should be provided to all workers prior to the beginning of work and regularly thereafter.

Workers should be provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities.


Sonder supports a wide variety of issues and organizations that are important to our business and encourages our team members and Suppliers to volunteer or participate in the economic and social development of their local communities as they deem appropriate.

Core Environmental Principles


Sonder expects 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. At a minimum, Suppliers should comply with all local, state and national environmental legislation. Suppliers should obtain and maintain all required environmental permits, approvals, and registrations and follow all of their relevant operational and reporting requirements.

Sonder encourages Suppliers to proactively minimize their impact on the environment (including with respect to energy and water use, air emissions, greenhouse gas emissions, waste, pollution, hazardous materials, and recycling). In practice, this means:

  • Reducing or eliminating solid waste, wastewater, environmentally damaging chemicals, endangered or non-renewable raw materials, and air emissions as required by applicable laws and regulations, including energy-related indirect air emissions, by (i) implementing appropriate conservation measures and (ii) recycling, reusing, or substituting materials

  • Incorporating the use of recycled materials and reducing the use of single-use plastic where possible, practicable, and feasible

  • Commiting to implement renewable sources of energy where applicable

  • Educating and training employees, agents and contractors on the concept of environmental sustainability and carbon reduction

  • Participating in industry environmental collaboration and partnerships where possible and suitable.

Raw Materials

Sonder is committed to the sustainable use of raw materials, including forestry products. Sonder expects Suppliers to mitigate negative impacts on forestry, such as deforestation.

Animal Welfare

Sonder is committed to the humane treatment of animals. Sonder expects its Suppliers to comply with local standards and surpass national standards where possible.

Other Implementation Principles

Emergency Preparedness and Response

Suppliers should identify and plan for emergency situations, and should implement and provide guidance to workers on emergency response procedures, including emergency reporting, alarm systems, worker notification and evacuation procedures, drills, fire detection and suppression equipment, exit facilities and recovery plans.

Grievance mechanisms

Sonder commits to protect the confidentiality, anonymity, and protection of Supplier and employee whistleblowers, unless prohibited by law. Suppliers should have a communicated process for their personnel to be able to raise any concerns without fear of retaliation.

Amendments to Supplier Code of Conduct

Sonder reserves the right to amend or modify this Supplier Code of Conduct at any time in its sole discretion.

Communicating the Code of Conduct

Sonder expects that its Suppliers clearly and accurately communicate and educate workers about Sonder’s policies, practices, and expectations. Sonder expects Suppliers to maintain appropriate training programs for managers and workers to implement the standards in the Code and to comply with applicable legal requirements.