Doing Business the Right Way, Every Day
Progress requires integrity. We set a global ethical standard for our business and community to build trust and ensure respect, inclusivity, and accountability.
Sandisk’s Global Code of Conduct (GCOC) informs our employees of their legal and ethical obligations to the Company and to its employees, customers, competitors, and suppliers. Sandisk embraces diversity in setting one global set of expectations for its workforce worldwide through our Global Code of Conduct. The standards set forth in the GCOC are supported by detailed Company policies and procedures, which supplement or implement those standards. These policies and procedures provide clear, specific guidance concerning important business practices and expectations.
We also inform employees that they are expected to comply with the GCOC and that failure to do so can result in discipline.
Each year, we conduct mandatory training on the GCOC in English or translated into local languages. The training includes a certification to verify that each employee has read and agrees to comply with the GCOC. In addition, the Company conducts an annual disclosure certification on GCOC topics for senior members of management and other key designated employees with special responsibilities. The results of the training and certification are reported to the Audit Committee by the Chief Compliance Officer.
To provide feedback, contact us at compliance@sandisk.com.
The Helpline is managed by Navex Global, a leading provider of customized helpline services, and is staffed 24 hours a day, 365 days a year. While primarily intended for current Sandisk employees, the helpline may be used by other interested parties, including vendors, customers, and former employees.
To make a report via telephone, please use the following telephone numbers by country.
- China: 4001200350
- India: 0124-512-0059
- Israel: 1-809-322-266
- Japan: 0800-300-9360
- Malaysia: 1800-81-0949
- United States: 1-844-787-0288
For additional country telephone numbers or to make a report via the web, access the web-based Ethics Helpline reporting system at www.SandiskEthicsHelpline.com.
We encourage employees to report suspected instances of ethical misconduct within Sandisk, including:
- Trading on inside information or providing illegal tips
- Workplace harassment or discrimination
- Illegal gifts or bribes to or from government officials, vendors, or customers
- Fraud, embezzlement, or theft
- Questionable accounting or auditing matters
- Conflict mineral sourcing
The Ethics Helpline is one avenue for reporting suspected misconduct. Employees may also address problems through their supervisors or our human resources staff. Employees can remain anonymous when they communicate with the Helpline’s operators. And Sandisk will not allow any retaliation against an employee who contacts the Helpline and reports suspected misconduct in good faith.
Sandisk’s Global Code of Conduct describes the standards of integrity that Sandisk expects all of its employees worldwide to follow. The standards set forth in the Global Code of Conduct are supported by more detailed Company policies and procedures, which supplement or implement those standards. These policies and procedures provide clear, specific directions concerning important business practices and expectations.
A copy of the Global Code of Conduct is available to all Sandisk employees. We inform our employees that we expect them to comply with the provisions of the Code of Conduct and that failure to do so is misconduct that can result in disciplinary action.
Each year, senior members of management and key designated employees with special responsibilities complete an online disclosure certification confirming that they have complied with provisions of the Global Code of Conduct.
Sandisk’s Ethics & Compliance team conducts regular risk assessments, including enterprise-wide risk assessments and subject-specific risk assessments in areas such as anti-corruption and privacy. Privacy risk assessments consider, among other things, Sandisk’s use of technology and its practices around user, partner, and employee data.
Sandisk believes its employees and business partners must comply with global anti-corruption laws, including the U.S. Foreign Corrupt Practices Act (FCPA), the UK Bribery Act, and the anti-bribery laws of the countries in which the Company operates.
Sandisk prohibits its, and its subsidiaries’, employees, consultants, agents, and representatives from corruptly seeking to obtain or retain business by offering, paying, or offering to pay money or provide other things of value to foreign or commercial officials for the purposes of:
- Influencing any act or decision of such official in their official capacity, or
- Inducing such official to do or omit to do any act in violation of their official duty, or
- Inducing such official to use their influence with a foreign government or instrumentality thereof to affect or influence a governmental act or decision, or
- Securing an improper advantage
Sandisk’s Global Code of Conduct discusses compliance with global anti-corruption laws. The Company also has a comprehensive anti-corruption policy, which is available internally.
Sandisk participates in legislative, regulatory, and public policy affairs as deemed by management and the Board of Directors to be in the best interests of the Company, without regard for the private political preferences of executives. The Board of Directors’ Governance Committee, which consists solely of independent directors, reviews and approves on at least an annual basis the Company’s political and lobbying strategy, activities and expenditures, including payments to trade associations, and the policies and procedures regarding the foregoing. The Company’s Government Affairs function directs all political activity on the federal, state, and local level, in compliance with the Sandisk U.S. Political Activities Policy, where applicable.
The Company does not have or support a political action committee. The Company also does not make independent political expenditures using corporate funds or resources, nor do we make payments to trade and other industry associations to be used specifically for political purposes. Prior approval by the Governance Committee is required to use corporate funds or resources for donations to local, state, or national elections, whether to candidates, political parties, non-candidate organizations, Section 501(c)(4) organizations, Section 527 organizations, or local or state ballot measures. The Governance Committee has approved the use of corporate funds or resources for donations to local, state, or national elections for the following: None, as of February 21, 2025. This information will be updated if/when any such spending occurs. Should such spending be approved and incurred, this website will be updated accordingly with specific policy positions that form the basis of the spending.