1.Overview

Violations of the Code

In no circumstance will failure to read the Code or Company policies exempt your obligation to

comply with these requirements. Violations, depending on the nature and severity, may result

in disciplinary action, up to and including, termination of employment or termination of an

engagement service contract, where necessary. Where there is a potential violation of law and/

or policy, the Company will cooperate with the appropriate authorities.

Investigations

For all concerns raised, the Company has the responsibility to take appropriate actions. This

includes conducting a fair, objective, and thorough investigation. Based on the nature of the

violation, the appropriate investigation team will perform an impartial review of all the facts

available, maintain confidentiality to the greatest extent possible, and comply with applicable

laws and regulations. The Company requires employees to cooperate fully with any inquiry or

investigation by providing truthful and complete responses and information to investigators.

The Company will take appropriate action when it determines that a violation has occurred

or someone was untruthful during an investigation. This includes disciplinary action where

appropriate, and corrective actions to improve our policies and internal controls to prevent future

issues.

No Retaliation

The Company strictly prohibits retaliation of any kind against anyone who shares a concern in

good faith or participates in an investigation. An individual would have reported in good faith if

the individual reasonably believes, perceives, or suspects the information reported to be true.

The Company encourages honest reporting, but does not tolerate anyone knowingly submitting

a false report. Making false accusations can lead to disciplinary action as it diverts investigatory

resources away from credible good faith concerns and damages the morale of those impacted. 

As employees, we hold ourselves and each other accountable to high ethical standards, and

help the Company succeed by complying with the Code and the Company’s policies. We

are also proud representatives of the Company, and take pride in preserving the Company’s

image through our actions.

2.1 Confidentiality

The Company attributes its success in part based on innovations, intellectual property

and technology. To ensure the Company’s success, we recognize the importance of our

responsibility to preserve and uphold data confidentiality.

To ensure that we handle confidential information appropriately, each of us needs to

understand the types of confidential information and the ways to protect it. We consider

all non-public information about the Company, its customers and Business Partners as

confidential unless the Company clarifies that the information is public. Non-public information

includes business plans, proprietary data, financial information, internal communications,

organizational structure, operational information, personnel information, and information

related to third parties with which the Company has non-disclosure agreements. We should

not disclose confidential information to third parties, nor should we discuss it in public places.

For confidential information limited to a specific range of people, you should only disclose it

to those who need to use it to perform their duties and are authorized to know.

2.2 User and Business Partner Privacy and Information

Protecting and ensuring the privacy and safety of our users’ and Business Partners’ information

is of the utmost importance. We arrange to take all lawful steps possible to protect user privacy

and Business Partners’ information during the obtaining, processing, and transferring of data.

This includes personal data, customer lists, trade secrets, and patented technologies.

We abide by our policies as well as local laws and regulations regarding personal privacy and

data disclosure for each country in which we do business.

2.3 Proper Use and Protection of Company Assets

The Company provides us with a variety of assets to allow us to complete our work tasks

effectively. These assets include physical (tangible) assets such as IT hardware and equipment,

and non-physical (intangible) assets such as access to internal systems, apps, and emails.

Our policies provide guidelines on proper use of assets including password use, lost/stolen

items, and misuse of company assets (including improper use or over-indulgence). We must:

- use Company assets for legitimate work purposes only;

- ensure the safe and correct operation of Company assets; and

- take appropriate care to protect and secure Company assets, both in the workplace and at

home.

The Company reserves the right to seek remedies should you wilfully damage assets, use

assets for an unlawful purpose, fail to take good care of the assets, or fail to stop losses from

increasing.

2.4 External Communications

With ByteDance being a high-profile global company, the media, organized events,

competitors or interested external parties may contact or ask you to provide commentary.

Such commentary has the potential to cause serious damage, specifically when there is

a perception that the communication is on behalf of the Company, discloses non-public

information, is misinterpreted, or is inaccurate. 

Respect is a fundamental behavior and requirement that we exhibit to promote a positive and

inclusive work culture and environment. We are a company that promotes collaboration, teamwork

and the inclusion of all thoughts and ideas. We act responsibly by demonstrating respect and

kindness to all team members and Business Partners.

3.1 Mutual Respect

We believe in providing every ByteDancer with the opportunity to reach their full potential and

contribute to the Company’s success. We respect and embrace diversity and believe that our

collective differences make us stronger.

We commit to providing a workplace free from discrimination or harassment based on an

individual’s protected status. Protected status refers to an individual’s personal characteristics

including: race, color, age, sex, language, religion, national or ethnic origin, citizenship, marital/

civil status, sexual orientation, gender identity or expression, disability, pregnancy, or any other

characteristics protected by applicable laws.

We oppose any form of discrimination, workplace bullying, harassment or sexual harassment.

This applies to all ByteDancers, and covers actions occurring at the workplace, and any other

settings involving work. To the extent permitted by law, this also applies to dealings with external

parties in the settings involving work.

The Company also provides equal employment opportunities and commits to ensuring that hiring,

continued employment and performance reviews are only evaluated and based on Company

policies, an individual’s work performance, and not influenced by any irrelevant factors.

3.2 Safety and Security

Whether working remotely or in our office we prioritize the safety and security of our colleagues. 

The Company has implemented robust physical security controls including the deployment of

people, technology and procedures, to ensure global workplace security. These controls are

constantly assessed to ensure their continued effectiveness. We have a shared responsibility to

help protect our workplaces by reporting anything that could endanger or detrimentally impact

personnel, property, or the Company’s reputation. In the event of an emergency, please contact

your local emergency authorities.

The Company has also established an Environment, Health and Safety Management System, to

comply with applicable environmental, health and safety laws and regulations in the countries

in which we operate. We take appropriate measures to provide a safe and healthy workplace for

employees, promote employee health management, and protect environmental sustainability.

3.3 Drugs and Alcohol

We take great pride in being able to represent the Company through our work and the products

we deliver. The Company expects us to perform our job duties without being under the influence

of drugs, alcohol, or any substance that could impair job performance. Being under the influence of

such substances can also pose a safety risk to yourself or others.

The Company prohibits substance abuse, including:

- working under the influence of alcohol or drugs while on Company premises or conducting work

for the Company; and

- possessing, selling, distributing, or consuming illegal drugs or controlled substances while on

Company premises, or conducting work for the Company.

There are occasions where the Company permits alcohol consumption (e.g., at approved Company

events). In such case, when consuming alcohol in an approved setting, we should always exercise

sound judgment and ensure our conduct remains professional at all times

4.5 Fair Competition We believe in free, fair and honest competition and should avoid any conduct that unfairly restricts trade. Antitrust or competition laws protect consumers and markets against unfair business practices, and promote and protect healthy competition. We commit to outperforming our competitors legally and ethically, and observing applicable antitrust and competition laws in the countries in which we operate. Additionally, the Company does not seek to obtain confidential information from our competitors, either directly, through third parties, or from current ByteDance employees who may have worked at other companies. 4.6 Financial Integrity and Record Keeping Financial integrity and record keeping are essential to the healthy operations of the Company. We make business decisions based on accurate, clear and complete records. We also maintain compliance with financial reporting regulations to uphold credibility with our customers and stakeholders, and demonstrate success as a company. We strive to: - ensure that our financial statements are always complete and accurate; - follow relevant accounting and reporting standards and policies; and - comply with applicable laws, regulations and policies regarding record keeping and record retention. It is important that we manage and keep records in accordance with applicable record retention policies and legal holds as failures to do so could expose both the Company and you to civil and criminal liability. 4.7 Insider Trading In each of our roles, we may have access to material non-public information about the Company,

as well as our clients or Business Partners. “Insider information” is non-public information that a

reasonable investor would consider important in conducting a trade.

The Company considers transactions of stock in a company while in possession of insider

information about that company obtained in connection with your employment at ByteDance as

insider trading and this is strictly prohibited. Additionally, insider trading includes passing along

insider information to another person who then utilizes that information, and would be strictly

prohibited. Insider trading is not only against policy, but is also illegal and may lead to legal

consequences.

4.8 Corporate Social Responsibility & Sustainability

We understand that as members of a global company we have a positive role to play in the

community, and to consider the social and environmental impact of business decisions. The

Company prohibits child labor, forced or involuntary labor, illegal employment, or trafficking of

persons within our organization or supply chain.

We encourage active participation in public welfare activities, promoting social causes and

becoming part of the solution. We believe that a strong corporate culture is one where we not

only focus on our development needs, but also how we can grow with and help build up our

communities.

We seek to improve the sustainability of our operations and look to find ways to lessen our

carbon footprint and support environmental initiatives. We do this by complying with applicable

environmental laws and recognize our responsibility and commitment to minimize our direct and

indirect impact on natural resources through our business practices. We believe that each of us

has the opportunity and responsibility to address climate change and biodiversity protection.