Ethics and compliance.

Hinlab conducts business ethically, honestly, and in full compliance with applicable laws and regulations. This applies to every business decision in every area of the company worldwide.

The following principles guide Hinlab’s business practices:

- Honesty — Demonstrate honesty and high ethical standards in all business dealings.
- Respect — Treat customers, partners, suppliers, employees, and others with respect and courtesy.
- Confidentiality — Protect Hinlab’s confidential information and the information of our customers,
partners, suppliers, and employees.
- Compliance — Ensure that business decisions comply with applicable laws and regulations.

Hinlab expects its suppliers, contractors, consultants, and other business partners to follow these
principles when providing goods and services to Hinlab or acting on our behalf.

The Business Conduct Policy applies to all full and part-time employees of Hinlab, and provides a
standard guide for what is required of everyone at Hinlab. Relevant sections also apply to members of
Hinlab’s Board of Directors.

All employees are required to complete annual Business Conduct training, and review and certify theirunderstanding of the Business Conduct Policy.

Focused live training is also arranged periodically on Business Conduct and other relevant topics.

Your Responsibilities and Obligation to Take Action

Everything we do is a reflection of Hinlab. We expect you to:

- Follow the Policy. Comply with the letter and spirit of Hinlab’s Business Conduct Policy and all
applicable legal requirements.
- Speak up. If you see or hear of any violation of Hinlab’s Business Conduct Policy, other Hinlab
policies, or legal or regulatory requirements, you must notify either your manager or the CEO of
- Use good judgment and ask questions. Apply Hinlab’s principles of business conduct, and review our
policies and legal requirements. When in doubt about how to proceed, discuss it with your manager. Any
failure to comply with Hinlab’s Business Conduct Policy—or failure to report a violation—may result in
disciplinary action, up to and including termination of employment.
You are also required to fully cooperate in any Hinlab investigation, and keep any information shared with you
confidential to safeguard the integrity of the investigation.

Reporting a Concern

To report a concern or ask a question about Hinlab’s Business Conduct Policy contact your manager or the CEO of Hinlab. 

Your information will be shared only with those who have a need to know to help answer your questions or investigate concerns, ensure the prompt enforcement of this Policy, and, if appropriate, determine disciplinary action. If your information involves accounting, finance, or auditing, the law may require that necessary information be shared with the Board of Directors. Hinlab’s Business Conduct Policy is administered by the COO

No Retaliation

Hinlab will not retaliate—and will not tolerate retaliation—against any individual for reporting a good-faith concern or complaint to a manager or for participating in the investigation of a concern or complaint. We do not tolerate knowingly false reporting.

Your Rights as an Employee

While we expect employees to follow the Business Conduct Policy, nothing in this Policy should be interpreted as being restrictive of your right to speak freely about your wages, hours, or working conditions.

Human Rights

Hinlab is committed to respecting internationally recognized human rights. Hinlab’s approach to respecting human rights is based on the United Nations Guiding Principles on Business and Human Rights, the global standard on business and human rights.

Workspaces Behaviors

Drugs and Alcohol

 Hinlab cares about the health and safety of our employees. You are expected to comply with Hinlab’s guidelines regarding alcohol, drugs, and smoking, whether it is in the workplace, at Hinlab-sponsored events, or while conducting Hinlab business. You are not permitted to be under the influence of any legal or illegal drug that impairs your ability to perform your job, and employees are prohibited from manufacturing, soliciting, distributing, possessing, or using any illegal drugs or substances in the workplace, or while working. Use good judgment and keep in mind that you are expected to perform to your full ability at work. For more information, see the Alcohol, Drugs and Smoke-Free Environment Policy. 

Environment, Health, and Safety (EH&S) 

Hinlab is committed to protecting the environment, health, and safety of our employees, customers, and the global communities where we operate. 

Use good judgment and always put the environment, health, and safety first. Work proactively to anticipate and manage EH&S risks in a timely manner. 

Harassment and Discrimination 

Hinlab is committed to providing a workplace free of harassment (including sexual harassment) or discrimination based on a personal trait. Personal traits include race, color, ancestry, national origin, religion, creed, age, mental and physical disability, sex, gender, sexual orientation, gender identity or expression, medical condition, genetic information, marital status, military or protected veteran status, or any other characteristic protected by law. 

We are dedicated to maintaining a creative, culturally diverse, and supportive work environment, and do not tolerate discrimination or harassment of employees or non-employees with whom we have a business, service, or professional relationship. This applies to all interactions where you represent Hinlab, including interactions with employees, customers, suppliers, and applicants for employment. 

If you have been harassed or discriminated against, or have witnessed such behavior, report the incident to a supervisor or manager at any level. 

Protecting Hinlab

Protecting Hinlab’s Assets and Information 

You play a key role in helping us protect Hinlab. Assets include Hinlab’s proprietary information (such as intellectual property, confidential business plans, unannounced product plans, sales and marketing strategies, and other trade secrets), as well as physical assets such as cash, equipment, supplies and product inventory. 

• Watch what you say. Being aware of where you are, who is around you, and what they might see or overhear is an important way we all protect Hinlab’s secrets. 

• Protect our assets. Keep track of the assets and information Hinlab has entrusted to you, and prevent loss, misuse, waste, or theft. 

• Set an example. Model behavior that protects our assets and information at all times. 

Hinlab Confidential Information 

One of our greatest assets is information about our products and services, including future product offerings. Never disclose confidential, operational, financial, trade secret, or other business information without verifying with your manager whether such disclosure is appropriate. We are very selective when disclosing this type of information to vendors, suppliers, or other third parties, and only do so once a non-disclosure agreement is in place. Even within Hinlab, confidential information should only be shared on a need-to-know basis. The Intellectual Property Agreement that you signed when you joined Hinlab outlines your duty to protect our information. 

Non-Disclosure/Confidentiality Agreements 

Never share confidential information about Hinlab’s products or services without your manager’s approval. When there is a business need to share confidential information with a supplier, vendor, or another third party, never volunteer more than what is necessary to address the business at hand. Any confidential information shared outside Hinlab should be covered by a non-disclosure/confidentiality agreement (NDA). Contact Legal in your region to obtain an NDA. 

Customer and Third-Party Information 

Customers, partners, suppliers, and other third parties may disclose confidential information to Hinlab during the course of business. We are all responsible for protecting and maintaining the confidentiality of any information entrusted to us by our partners. Compromising that trust may damage relations with our partners and can also result in legal liability. 

Accuracy of Records and Reports 

Accurate and honest records are critical to meeting our legal, financial, and management obligations. You should ensure that all records and reports, including customer information, technical and product information, correspondence, and public communications are comprehensive, fair, accurate, timely, and understandable. 

Do not misstate facts, omit critical information, or modify records or reports in any way to mislead others, and never assist others in doing so. Intentional manipulation of Hinlab records is a form of fraud. 

Accuracy of Business Expenses 

You are responsible for observing all policies and procedures regarding business expenses, including meal and travel expenses, and for submitting accurate expense reimbursement reports. Guidelines on daily meal expenses vary worldwide. For more information, see the Travel and Expense Policy. 

Records and Information Management 

Hinlab owns all records and information in any form, such as electronic or paper, that is created or received in the course of doing Hinlab’s business. Records are a type of information that must be kept because the information meets certain criteria. Examples include corporate tax documents, financial statements, design documents, and personnel records. 

Employees are responsible for managing and protecting information and records. Privacy laws may dictate how long these records can be retained. At times, Hinlab will need to retain records and information beyond the normal retention period for legal reasons or audits. If you have records and information that are categorized as under a “legal hold” you should not alter, destroy, or delete them in any way. Legal will notify you of any legal holds you may be subjected to and what is required. 

Side Deals or Side Letters 

Hinlab formally documents all terms and conditions of the agreements into which it enters. Contractual terms and conditions define Hinlab’s rights, obligations, liabilities, and accounting treatments. We do not accept business commitments outside of the formal contracting process managed by Legal. Side deals, side letters, or other informal documentation created by employees without Legal oversight are impermissible. You should not make any oral or written commitments that create a new agreement or modify an existing agreement without securing approval through the formal contracting process. 

The Hinlab Identity and Trademarks 

The Hinlab name, names of products, names of services, taglines, and logos collectively create the Hinlab identity. Before publicly using any of these assets check with your manager. Also check with your manager before using the product names, service names, taglines, or logos of any third parties. 

Third-Party Intellectual Property 

Hinlab respects third-party intellectual property. Never use the intellectual property of any third party without permission or legal right. If you are told or suspect that Hinlab may be infringing on third-party intellectual property, including patents, copyrights, trademarks, or trade secrets, contact your manager or the CEO. 

Copyright-Protected Content 

Never use or copy software, music, videos, publications, or other copyright-protected content at work or for business purposes unless you or Hinlab are legally permitted to use or make copies of the protected content. You should never use Hinlab facilities or equipment to make or store unauthorized copies. 

Hinlab Inventions, Patents and Copyrights 

Hinlab has a robust patent program that protects innovations related to our current or future products and services. You should submit your invention disclosure to your manager. It’s best to submit your invention disclosure well before you share an invention outside of Hinlab, even if under an NDA, because doing so may compromise Hinlab’s patent rights. 

You may pursue, for your own personal ownership, inventions within the legal framework defined in your work contract. 

Be alert to possible infringement of Hinlab’s patents and notify Legal of any possible infringements. If you create original material for Hinlab that requires copyright protection, such as software, place Hinlab’s copyright notice on the work and submit a copyright disclosure form to Legal. For more information, see the Copyright Policy. 

Activities Related to Open Source Software 

Open source software is usually collectively developed software with its source code made available under an open source license. Before using, modifying, or distributing any open source software for Hinlab infrastructure, or as part of an Hinlab product or service development effort, you must receive management approval. 

Publishing Articles 

If you want to contribute an article or other type of submission to a publication or blog on a topic that relates to
Hinlab’s business or products or could be seen as a conflict of interest, you must first request approval from your manager. 


You should never endorse a product or service of another business or individual in your role as Hinlab employee, unless the endorsement has been approved by your manager. This does not apply to statements made in the normal course of business about third-party products sold by Hinlab.

Publishing Articles 

If you want to contribute an article or other type of submission to a publication or blog on a topic that relates to
Hinlab’s business or products or could be seen as a conflict of interest, you must first request approval from your manager. 


You should never endorse a product or service of another business or individual in your role as Hinlab employee, unless the endorsement has been approved by your manager. This does not apply to statements made in the normal course of business about third-party products sold by Hinlab. 

Individual Accountability 

Avoiding Conflicts of Interest 

A conflict of interest is any activity that may damage Hinlab’s reputation or financial interests, or gives the appearance of impropriety or divided loyalty. Avoid any situation that creates a real or perceived conflict of interest. If you are unsure about a potential conflict, talk to your manager. 

The following are common situations employees may encounter that could present a conflict of interest. 

Significant Personal Relationships 

Personal relationships in the workplace can present a real or perceived conflict of interest when one individual in the relationship makes or influences employment decisions regarding the other, including performance or compensation. 

Significant personal relationships include, but are not limited to, spouses, domestic partners, family members, dating or physical relationships, close friends, and business relationships outside of Hinlab. Hinlab business relationships include, but are not limited to, vendors, customers, suppliers, contractors, temporary agency workers, or similar relationships. 

Do not conduct Hinlab business with family members or others with whom you have a significant personal relationship. Do not use your position at Hinlab to obtain favored treatment for yourself, family members, or others with whom you have a personal relationship. This applies to product purchases or sales, investment opportunities, hiring, promoting, selecting contractors or suppliers, and any other business matter. 

If you believe that you have a potential conflict involving a family member or other individual, disclose it to your manager and your People Business Partner to review and work through any potential conflicts. 

You should not allow any relationship to disrupt the workplace or interfere with your work or judgment. 

In rare cases where exceptions may be appropriate, written approval from the CEO is required. 

Conflicts of Interest and Outside Activities 

You may participate in outside activities, including secondary employment, businesses, inventions, and serving on boards, only if they do not present a conflict of interest and you adhere to the rules set out below. 

Hinlab generally considers an outside activity to be a conflict of interest if it: 

  • Is for a company or organization that makes or sells competing products or services to Hinlab, or that Hinlab is reasonably anticipated to create. 
  • Generates or exposes you to intellectual property that competes with or relates to Hinlab’s present or reasonably anticipated business, products, or services. 
  • Would require you to disclose or use confidential Hinlab information. 
  • Is the same work you do for Hinlab. 
  • Arises from your role in Hinlab’s business relationship with the organization. 

Work with your manager to evaluate a potential conflict of interest. If an outside activity presents a conflict of interest, you must obtain written approval from your manager. 

Any employee, full or part-time, who is participating in an outside activity, must comply with the following rules. 

Do not: 

  • Use any time at work or any Hinlab assets for your outside activity. This includes Hinlab’s workspace, phones, computers, Internet access, photocopiers, and any other Hinlab assets or services. 
  • Use your position at Hinlab to solicit resources or any other benefit for your outside activity, obtain favored treatment, or pressure others to assist you. 
  • Participate in an activity that could have an adverse effect on your ability to perform your duties at Hinlab. 
  • Use confidential Hinlab information. 

Outside Employment and Inventions 

Before participating in creating inventions or businesses that are in the same area as your work for Hinlab, or that compete with or relate to Hinlab’s present or reasonably anticipated business, products or services, you must have written permission from your manager. Before taking any paid employment outside of Hinlab, you should notify your manager. 

Personal Investments 

You should avoid investing in companies that are Hinlab competitors or business partners when the investment presents a conflict of interest. When determining whether a personal investment creates a conflict of interest, consider if you are in a position to influence transactions between Hinlab and a business in which you have invested. If a real or apparent conflict arises, disclose the conflict to your manager. Your manager will help determine whether a conflict exists and, if appropriate, the best approach to eliminate the conflict. If you still need help, contact Business Conduct. 

Personal Political Activities 

You are free to personally participate in political activities, including running for and serving in public positions, and supporting candidates and causes, as long as you comply with the points below: 

  • Do not represent or give the impression that you are representing Hinlab during any political activities or in campaign materials. 
  • Do not make public comments that could be misconstrued as being made on behalf of Hinlab, or give the impression that Hinlab is endorsing any particular legislation, position, or issue. 
  • Do not use Hinlab work time, equipment, or resources for political or campaign activities. 
  • If holding a public office, you may need to recuse yourself from any matters involving Hinlab. 


Giving or accepting business gifts can create a real or perceived conflict of interest and can lead to a perception of favoritism and an expectation of reciprocity that could compromise an employee’s objectivity, even inadvertently. Hinlab employees are under a $150 gift rule. Employees under the $150 gift rule may only give or accept gifts if the value is under $150, unless one of the key exceptions below applies. Gifts must not reflect poorly on Hinlab if publicly disclosed, and must be legal in the location and under the circumstances where given. Gifts given with the purpose of influencing a decision are always prohibited. 

A gift is considered anything of value, including a meal, travel, entertainment (including tickets), Hinlab logo items, equipment or loans, and employee discounts. Gifts that are cash or cash equivalents, such as gift cards, are never allowed. In addition, paying for a gift without getting reimbursement from Hinlab does not remove the requirement to comply with the gift policy. Gifts between employees are not considered business gifts. 

Key Exceptions 

Gifts that fall under one of the following exceptions are permissible for most employees, regardless of gift rule (additional approval requirements may be noted): 

  • Business meals.  Employees may provide and accept reasonable and appropriate business-related meals, provided they are limited in frequency and expense. Any meals paid for by Hinlab must comply with Hinlab’s Travel and Expense Reimbursement Finance Policy. 
  • Commemorative items. Employees may accept commemorative items of nominal value, such as inexpensive and infrequent vendor promotional items like pens, calendars, and t-shirts. 
  • Business-related event attendance. Free tickets for sporting events and other forms of entertainment where participation is directly related to an employee’s job function and part of legitimate Hinlab business are not considered a gift under Hinlab’s policy. If you are unsure if attendance at an event is directly related to your role, check with your manager. For high-value or high-profile events, you should review your attendance with your manager. Employees should never use relationships built through Hinlab business for their personal advantage, such as obtaining tickets that are difficult to access, since that is preferential treatment and could be considered a conflict of interest. 
  • Conferences. Free tickets to conferences that are offered by a vendor, supplier or other third party are permissible if the tickets are free to all attendees, offered as part of a contract with Hinlab, or offered to all customers of a particular vendor. Tickets outside of those parameters do not fall under an exception, and require approval if the value is over your gift limit. Conference tickets purchased by Hinlab are not a gift. 
  • Vendor-supplied local ground transportation. Operations employees may accept reasonable local ground transportation provided by vendors to and from work locations. 

Any other exceptions must be approved by your manager. 

Refusing and Returning Gifts 

Gifts outside the limits of your gift rule should be declined or returned whenever possible. If it is impossible or inappropriate to refuse or return a gift, you should notify your manager immediately after accepting the gift. Perishable, non-alcohol gifts may be placed in a common area for employees to share. 


Current and potential vendors and suppliers may provide product samples to Hinlab for business evaluation purposes. These samples are not gifts and may not be used for personal purposes. Receipt of samples should be documented according to any internal policies, and where appropriate, returned to the vendor and supplier when the evaluation is complete. 

Gifts to Public Officials 

Hinlab permits providing gifts to public officials only when permissible under applicable laws and policies. A public official is any person who is paid with government funds or performs a public function. This includes individuals who are elected or appointed to public office, as well as individuals who work for local, state/provincial or national government, public international organizations, public (government-owned or operated) schools, and state-owned or state-run enterprises. Employees at such organizations are considered public officials regardless of title or position. 

U.S. Public Officials 

For U.S. public officials, anything other than refreshments of nominal value ($10 or less) must be pre-approved by your manager or comply with internal guidelines if available, including disclosure requirements 

Non-U.S. Public Officials 

In many countries, it is considered customary to provide token ceremonial gifts to government officials on certain occasions. All gifts exceeding USD $10 in value require pre-approval from your manager. Meals that comply with posted guidance for a country are permissible and do not need pre-approval. Meals that are frequent and/or lavish could appear to influence a business decision and are inappropriate. 

Business Integrity 

Governments as Customers 

Governments are unique customers for Hinlab. They often have unique bidding, pricing, disclosure, and certification requirements. When dealing with government customers, make sure to partner with Legal when bidding for business.

Hiring Government Employees 

Laws often limit the duties and types of services that former government, military, or other public sector employees
may perform as employees or consultants of Hinlab, especially in regard to matters they were involved in while with the government. Employment negotiations with government employees may be subject to legal restrictions and disclosure requirements, particularly if the government employee is involved in a matter involving Hinlab’s interests. Contact your manager before entering such negations. You may never hire any individual in exchange for securing or retaining business or securing an improper advantage. We also prohibit hiring preference being given to anyone in return for special treatment of any kind. For more information, see the Anti-Corruption Recruiting Policy. 

Bribery and Corruption 

At Hinlab, we do not tolerate corruption in connection with any of our business dealings. Corruption can take many forms, but most often it occurs through bribery. A bribe is offering or giving anything of value, including cash, cash equivalents such as gift cards, gifts, meals, travel and entertainment, to any person for the purpose of obtaining or retaining business or securing an improper advantage. You cannot offer or receive bribes from any individual, regardless of whether that individual is a public official or a private party. Kickbacks are a type of bribery, and occur when a person is offered money or something of value in exchange for providing something, such as information, a discount or a favor, to a third party. Kickbacks are not permissible and are strictly prohibited by Hinlab. 

Facilitating payments are a type of bribe generally used to facilitate or expedite the performance of routine, non-discretionary government action. These payments are not permissible and are strictly prohibited by Hinlab. Exceptions may be made in circumstances that involve an imminent threat to health or safety, and such situations must be immediately reported to your manager. 

Hinlab can be found responsible for bribes, kickbacks, and/or facilitating payments made by third parties in connection with Hinlab’s business. Before engaging a third party that will be interacting with the government or public officials on Hinlab’s behalf, contact Business Conduct to evaluate whether we need to conduct additional due diligence. 

Money Laundering 

Money laundering occurs when individuals or organizations try to conceal illicit funds or make those funds look legitimate. Money laundering is illegal and strictly prohibited by Hinlab. In certain countries, we are required to report suspicious activity. If you deal directly with customers or vendors, the following examples may signal potential money laundering: 

• Attempts to make large payments in cash
• Payments by someone who is not a party to the contract
• Requests to pay more than provided for in the contract
• Payments made in currencies other than those specified in the contract
• Payments from an unusual, nonbusiness account
• Transactions forming an unusual pattern such as bulk purchases of products or gift cards or repetitive cash payments 

Competition and Trade Practices 

Competition and innovation are at the core of Hinlab’s DNA. We vigorously compete to develop and create the very best products for our customers. Hinlab will never seek to eliminate or reduce competition through illegal agreements with competitors. Agreements with competitors are subject to rigorous scrutiny in all countries. Agreements with our resellers, distributors, and suppliers can also give rise to scrutiny, particularly if Hinlab has a leading position in the market. 

You should never: 

  • Agree with or exchange information with competitors regarding price, policies, contract terms, costs, inventories, marketing plans, capacity plans, or other competitively significant data. 
  • Agree with competitors to divide or assign sales territories, products, or dedicate customers. 
  • Agree with resellers on the resale pricing of Hinlab products without legal approval. Resellers are free to determine their own resale pricing. 
  • Violate fair bidding practices, including bidding quiet periods, or provide information to benefit one vendor over other vendors. 

Obtaining and Using Business Intelligence 

Gathering information about customers, competitors, and markets in which we operate is a common business practice, but you must always do so with integrity. You may generally obtain information from public sources, surveys, and competitive research. Personal information shall not be obtained from third parties without confirming with Privacy. We do not seek business intelligence by illegal or unethical means. It is never appropriate to engage in theft, espionage, or breach of a non-disclosure agreement. If you obtain confidential nonpublic information, accidentally or provided by unknown sources, that relates to a competitor, it may be unethical to use the information. If this happens to you, immediately contact your manager. 

Trade Restrictions and Import/Export Controls 

Many countries periodically impose restrictions on imports, exports, and other dealings with certain countries, persons, or groups. These can include the trading of commodities or technologies, travel to or from a sanctioned country, and investments. Certain laws also prohibit support of boycott activities. 

Private Employee Information 

You should never share a coworker or prospective employee’s personal information. This includes information regarding their employment history, personal contact information, compensation, health information, or performance and disciplinary matters. Any Legal or business need-to-know exceptions should be approved by your manager and Legal. 

As an Hinlab employee, you should understand that subject to local laws and regulations and in accordance with Hinlab’s review process, we may do one of the following when you access Hinlab’s network or systems, or use any device, regardless of ownership, to conduct Hinlab business: 

  • Access, search, monitor, and archive all data and messages sent, accessed, viewed, or stored (including those from iCloud, Messages, or other personal accounts). 
  • Conduct physical, video, or electronic surveillance, search your workspace (e.g. file cabinets, desk drawers, and offices, even if locked), review phone records, or search any non-Hinlab property (e.g. backpacks, handbags) while on company premises. 
  • Disclose to law enforcement, without prior notice, any information discovered during a search that may indicate unlawful behavior 

While limited personal use of Hinlab equipment and systems is allowed, Hinlab may monitor equipment and systems. You should not have any expectation about the privacy of content or personal information on Hinlab systems or networks, including VPN. 

Human Trafficking 

Hinlab is committed to treating everyone in our business and supply chain with dignity and respect, to upholding human rights across our global network of suppliers, and to protecting the planet we all share. Human trafficking and the use of involuntary labor are strictly prohibited in Hinlab’s supply chain and our own business operations. If you become aware of human trafficking or behavior supporting human trafficking, you must report this activity to your manager as soon as possible. Some Hinlab employees who interact with the U.S. government must abide by additional requirements set for government contractors. 

At Hinlab we don’t think that reinventing what already exists is good business. So, for our Ethics and Compliance policy above we went right to the best: Apple, and adopted their policy with small adjustments. A big thank you to Apple for leading the way.