Axon’s mission is to enhance public safety through our advanced suite of smart weapons, cameras and software. We take this responsibility very seriously and hold ourselves and the suppliers we work with to the highest standards of quality and reliability. Simply put - our products cannot fail.
This Axon Supplier Code of Conduct outlines the expectations we have for our suppliers (and our supplier’s sub-tier suppliers) and contractors (and our contractor’s subcontractors) worldwide. It serves as a guiding framework to ensure that all partners adhere to ethical business practices, comply with applicable laws and regulations, and foster respect for human rights, environmental stewardship, and workplace safety.
Axon’s Supplier Code of Conduct applies to all suppliers in Axon’s supply chain, regardless of location. By working with Axon, you agree to operate in full alignment with these principles and to cascade similar expectations to your own supply chain. Together, we can create a positive impact that goes beyond business, supporting communities and the environment in meaningful and lasting ways.
Underlying these standards are fundamental values to which we hold ourselves accountable:
Human Rights
Health and Safety
Environment
Sustainability
Supplier Diversity
Subcontractors; Sub-tier Suppliers
Ethics/Anti-Corruption
Supplier Quality
Conflict Minerals; Supply Chain Responsibility
· Counterfeit Parts
Business Continuity
Compliance with Laws and Regulations
Labor and human Rights Practices
Combatting Modern Slavery and Human Trafficking
Whistleblower Protection
Conflict of Interest
Cybersecurity/Data Privacy
Artificial Intelligence (“AI”)
Ownership and Bailment
Audit and Enforcement; Noncompliance
We encourage and candidly expect our supplier partners and their extended supply chains to embrace and actively support these values as their own and provide transparency with respect to both current and future operations as it relates to these initiatives.
Axon’s suppliers are required to act in accordance with all applicable international, federal, state, and local laws and regulations. In the event of a conflict between this Code of Conduct and any applicable law or regulation, Suppliers must adhere to the applicable law and regulation.
In the event Axon becomes aware that a supplier has violated this Supplier Code of Conduct and/or any applicable law or regulation, Axon reserves the right pursue any appropriate corrective action (including, without limitation, termination of the respective supplier relationship).
Axon values respect for human life both as part of our mission and our core values.
At Axon, we are committed to conducting business in compliance with applicable laws and the international standards articulated in the United Nations Universal Declaration of Human Rights and the United Nations Guiding Principles on Business, and Human Rights, among others. Additional information can be found in Axon’s Human Rights Policy.
Axon consistently communicates these values to all individuals within our operation (including sub-tier suppliers), as well as to our suppliers, and actively seeks opportunities to build awareness and educate our employees.
All Axon suppliers (and sub-tier suppliers) are expected to comply with Axon’s Human Rights Policy, this Code of Conduct, and all applicable laws and regulations. Axon further expects its suppliers to have in place policies and procedures relating to human rights, and to perform due diligence measures to prevent risks of adverse impacts in their operations and supply chains.
Axon places high priority on protecting the health and safety of all employees and people who enter our global facilities. It is Axon’s expectation that our suppliers embrace the same spirit to ensure the following:
A safe and respectful work environment for all employees and visitors
Employees and visitors are provided appropriate personal protective equipment (PPE)
Health and safety programs are in place to ensure employees and visitors are protected from work place hazards
An appropriate preventative maintenance program is in place to ensure proper operation of equipment and employee protection
Employees are provided the highest level of training to perform their jobs successfully and safely.
Systems are in place to continually improve health and safety performance, decreasing the risk of injury and illness
Axon believes preservation of the environment is the responsibility of all Axon employees and those conducting any activities on behalf of Axon, as reflected in our Environmental Policy, our implementation of an environmental management system and achievement of ISO-14001 certification. In addition to ensuring compliance with applicable regulations, we also recognize the importance of proactively addressing potential environmental risks to prevent harm by managing energy consumption, reducing greenhouse gas emissions, minimizing waste generation, conserving water resources and promoting the responsible use of natural resources.
Axon encourages all of its suppliers, vendors, and any third party conducting any activities on behalf of Axon, to join our efforts and prioritize their own initiatives to promote greater environmental responsibility, and mitigate environmental impact as it relates to their own unique industry and supplied products and services.
Axon believes in a sustainable future, enabling our business to reduce cost and our impact to the environment. We are proud of our steady improvements in this area, which include management of materials throughout the product lifecycle, increasing adoption of sustainable packaging materials, implementing product recycling programs, and environmentally responsible disposal of electronic and electrical waste. We also encourage our supply partners to manage manufacturing consumables, which reduces Axon’s on-hand inventory and the amount of expired product to be disposed. Our sustainability initiatives extend to the way we manage our facilities, including retrofitting Axon facilities with LED lighting where possible, and to our approach to employee commuting and travel, with a view to progressively minimizing our environmental impact over time.
Axon encourages its suppliers, vendors, and any third party conducting any activities on behalf of Axon, to focus on sustainability in their operations and provide us with ideas on how we can continue to most optimally manage this within our own operations relating to their supplied products and services.
Axon’s Supply Chain is committed to finding and working with the best supply partners with regards to quality, cost, and availability. This includes tracking our current supply base and actively seeking and recruiting partners through traditionally disadvantaged channels and using scorecards that give credit for expanding our supplier diversity. Axon works to award opportunities to small, regional, subcontractors on bids for business. Axon recognizes that traditional ways of doing business have historically led to leaving some companies out and actively seeks to change our ways of working to be fair in both the present and future.
We believe a focus on supplier diversity is important at Axon to promote growth and success within underrepresented or disadvantaged business communities. In an effort to continually improve our supplier diversity program, we track key metrics and data, to identify areas of improvement and ensure our goals and objectives are met.
Suppliers must ensure that their own suppliers and subcontractors comply with this Supplier Code of Conduct and all outlined Axon standards. Suppliers must ensure that their supply chains are transparent and comply with Axon’s ethical and legal standards, as well as all applicable laws and regulations.
At Axon, we are firmly committed to upholding integrity by working against corruption in all its forms, including, without limitation, extortion and bribery. This includes a strict prohibition against bribery, corruption, and any form of unethical conduct. Suppliers must comply with anti-corruption laws such as the U.S. Foreign Corrupt Practices Act (FCPA) and the UK Bribery Act, and avoid any improper payments or gifts intended to influence business decisions.
Participation in any bribery or corruption is wholly unacceptable. If a supplier or sub-tier supplier is found to have participated, or, if Axon has reasonable belief that Supplier has participated in any bribery or corruption, Axon reserves the right to immediately terminate any agreement(s) and professional relationship(s) without further notice to that supplier.
Suppliers are expected to deliver top-quality raw materials on 100% of the products it supplies to Axon.
Suppliers are expected to provide prompt and effective support for raw material quality related issues to keep our production up and going and guarantee top quality raw materials to get into manufacturing lines.
Additional information about Axon’s quality management and quality standards for our Suppliers can be found here.
Suppliers must ensure that their own suppliers and subcontractors comply with this Code’s standards. Suppliers must ensure that their supply chains are transparent and comply with Axon’s ethical and legal standards. This includes taking proactive steps to verify that all materials used in products are sourced responsibly and in accordance with applicable laws, such as the Dodd-Frank Act’s provisions regarding conflict minerals.
All suppliers are expected to comply with regulations relating to Conflict Minerals (including, without limitation, as defined in Section 1502(e)(4) of the Dodd-Frank Act), REACH, RoHS, CalProp 65 and others, as applicable.
Further, Suppliers are required to trace and disclose the origin of tin, tungsten, tantalum, and gold (the “3TGs”) to ensure that these minerals are not sourced from regions where mining operations fund armed conflict or violate human rights. Suppliers must take steps to avoid the use of conflict minerals and ensure that they are sourcing materials from responsible suppliers that comply with international standards for conflict-free sourcing. Axon expects full cooperation with any efforts to trace, audit, and report the use of conflict minerals in the supply chain, including providing necessary documentation to verify compliance.
At Axon, we expect our suppliers to ensure that their goods meet Axon’s quality standards. To meet Axon’s quality standards, Axon expects that our suppliers will have in place policies and procedures that ensure that the supplier’s supply chain is secure from tampered or counterfeit parts, and that the quality of all goods provided to Axon adhere to all contractual requirements and industry standards.
Suppliers are expected to have effective processes in place to detect and mitigate counterfeit parts and materials, provide Axon with notice in the event that these processes fail, and further ensure that no counterfeit parts and materials are delivered to Axon.
Axon is a mission driven organization with a critical mission to protect lives. Our supplier’s ability to supply critical goods and services is central to Axon accomplishing that mission.
Therefore, Axon’s suppliers are encouraged to develop and maintain plans for continuity or redundancy in its operations including safety stocks. This activity should be designed to ensure Axon’s ability to maintain continuity of supply in the event of an interruption in any or all of supplier’s operations.
Axon expects its suppliers to comply with all applicable local, national, and international laws, regulations, and industry standards in every region where they operate. This includes, but is not limited to the laws, regulations and standards outlined in this Supplier Code of Conduct.
Axon also requires suppliers to stay informed about legal and regulatory changes that may impact their business operations and take proactive steps to ensure compliance. Any failure to comply with these requirements may result in the termination of the business relationship.
Axon is committed to upholding the highest standards of labor and human rights across our global supply chain. Suppliers must comply with all applicable labor laws and respect the rights of their workers. This includes ensuring that no form of forced labor or human trafficking is used in any aspect of their operations. Suppliers must also adhere to international standards regarding child labor, ensuring that no one under the legal working age is employed in their facilities, and that work conditions for minors comply with the laws in their respective regions.
Suppliers are expected to provide a workplace free from discrimination, harassment, and unfair treatment, offering equal opportunity regardless of race, gender, religion, or other protected characteristics. Wages and benefits must comply with local laws, including minimum wage and overtime regulations.
Suppliers must respect employees' rights to join or refrain from joining unions and engage in collective bargaining without fear of retaliation. By adhering to these standards, suppliers help ensure the well-being and dignity of workers throughout Axon’s global supply chain. Additional information can be found in Axon’s Human Rights Policy.
Axon actively partners with reputable experts and adopts proven methods to help discover and eradicate forced labor from our supply chain. If forced labor indicators are found in a supplier’s production facility, Axon will work quickly to assess the situation and evaluate a variety of factors including the supplier’s and facility’s ability to remediate, the feasibility of providing meaningful remedy to impacted workers and the likelihood of sustained improvement.
Axon complies with the UK Modern Slavery Act 2015, the California Transparency in Supply Chains Act, Part 2 of the Canadian Fighting Against Forced Labour and Child Labour in Supply Chains Act, and U.S. federal contracting rules, maintaining a zero-tolerance policy against human trafficking, forced labor and child labor. We conduct regular risk assessments to identify, assess and mitigate modern slavery risks, which build on our risk-based due diligence approach, including due diligence measures to trace the origins of materials used in our products and scrutinize labor practices within our supply chain. We communicate clear expectations regarding modern slavery compliance to our suppliers and business partners, requiring robust contractual commitments (including audit rights), certification of adherence to this Supplier Code of Conduct.
We are committed to continuous improvement, by regularly reviewing and evolving our operations to align with evolving legal standards and best practices, demonstrating our unwavering dedication to eradicating modern slavery in all its forms. Our efforts in this area are described in our annual Modern Slavery and Human Trafficking Statement.
Axon is committed to protecting the rights of employees and ensures that any individual who, in good faith, reports misconduct will not face any retaliation, harassment, or adverse employment consequences.
Suppliers and their employees are encouraged to report any concerns or violations confidentially and without fear of retaliation. Reports can be submitted securely through Axon’s third-party ethics hotline provider, EthicsPoint, either online or by phone. The contact numbers may vary depending on the country of origin, and specific phone numbers for each location can be accessed on the EthicsPoint website.
Axon expects its suppliers and sub-tier suppliers to conduct its business in a honest, truthful, and direct manner. Suppliers are expected to maintain high ethical standards in all interactions and transactions, and prioritize transparency and trustworthiness.
Suppliers should not have any relationship (financial or otherwise) with any Axon employee that might create a conflict of interest, or even the appearance of a conflict of interest. Axon’s suppliers are further expected to avoid all conflicts of interest or situations giving the appearance of a potential conflict of interest in their dealings with Axon.
In the event that a conflict, or potential conflict arises, Axon expects its suppliers to notify Axon immediately. Any potential conflict must be disclosed to Axon and evaluated by Axon in advance of Supplier performing any work for Axon or supplying any goods.
Axon expects its suppliers to maintain a robust data privacy compliance program that adheres to applicable law. Suppliers must maintain a data privacy and cybersecurity program, including regular training to ensure its personnel are equipped to handle personal data appropriately. Additionally, suppliers are required to implement appropriate technical and organizational measures to safeguard personal data against unauthorized access, disclosure, alteration, and destruction, maintaining the highest standards of data integrity and security.
Axon recognizes the transformative potential and numerous benefits of utilizing artificial intelligence (“AI”) in various aspects of its operations and supply chain. Axon supports and encourages the responsible integration of AI to enhance efficiency, innovation, and competitiveness.
Axon expects its suppliers to comply with all applicable laws and regulations concerning the development, deployment, and use of AI (including, without limitation, data privacy, security, ethical standards, and transparency requirements).
Suppliers must ensure that their AI systems and practices adhere to international, national, and local laws and regulations, as well as industry standards, governing the ethical use of AI technologies.
Axon expects its suppliers will take proactive steps to stay informed about emerging laws, regulations, and best practices related to AI and are expected to continually educate themselves and their employees on the evolving legal and regulatory landscape governing AI. To facilitate this, suppliers should implement training programs and participate in relevant industry forums and workshops to remain current with advancements and changes in AI regulations and ethical guidelines.
All specifications, drawings, schematics, technical information, data, tools, and all other materials that are either: (a) furnished to supplier by Axon; or (b) paid for by Axon will: (i) remain or become Axon’s sole property; (ii) be used by Supplier exclusively for Axon’s benefit; (iii) be clearly marked as Axon’s property; (iv) be segregated from property belonging to others; (v) be kept in good working condition, at Supplier’s sole expense, and (vi) be shipped to Axon at the termination or expiration of any contractual relationship between Axon and supplier, or, upon written request by Axon to supplier (whichever shall occur first).
Except for ordinary wear and tear, Axon’s expectations are that its suppliers will be liable for any loss or damage to Axon’s property, while supplier is in possession or control of Axon’s property.
Axon reserves the right to conduct monitoring and audits of its suppliers to ensure compliance with this Supplier Code of Conduct. These audits may be unannounced and will be performed to identify potential compliance concerns, assess adherence to labor, environmental, and ethical standards, and ensure the accuracy of reported data. Audits may be carried out by Axon’s internal team or by one of Axon’s trusted third-party investigators, who are experienced in conducting thorough, impartial assessments. Suppliers are expected to fully cooperate with these audits and provide access to necessary records, facilities, and personnel. Any findings of non-compliance may require corrective actions, including changes to practices or processes, and may result in further review of the business relationship.
Any non-compliance with Axon’s Supplier Code of Conduct is a serious matter and failure to meet the required ethical, legal, and operational standards outlined in the Code, including areas such as labor practices, environmental responsibility, and anti-corruption, may result in corrective action, up to and including termination of the Supplier agreement. Axon is committed to maintaining partnerships that reflect our values and expect our Suppliers to demonstrate the same commitment.