Matterport Global Code of Conduct and Ethics

Opening Statement

Matterport, Inc is the global leader and innovator of spatial 3D modeling and is the category creator of digital twin technology. With offices across the globe and a rapidly growing workforce, we strive to foster relationships with our suppliers and customers so we may build a more diverse, dynamic and better working world together.

We believe this can only be achieved by getting one percent better every day. To accomplish this, we are setting high standards and holding ourselves and those we work with accountable to these standards. We want to encourage our suppliers and customers to continually improve on their own processes and the way in which they manage the important issues we all face in the world today.

This document sets out the expectations and minimum level of standards we, with our suppliers and customers, are aiming for. They are a result of not only the changing global regulatory environment, but also the increasing expectations of our wider community and the people we do business with.

1. About This Code of Conduct & Ethics

The purpose of this Global Code of Conduct and Ethics (“Code”) is to:

  • Explain Matterport’s values and how they relate both to our day-to-day work and the key ethical issues Matterport faces.

  • Provide information and guidance in relation to:

    • how we should conduct ourselves when carrying out Matterport's business;

    • how Matterport shall deal with ethical issues;

    • set out expectations in relation to how we expect our customers and suppliers to handle ethical dilemmas.

  • Ensure that all of our customers and suppliers are aware, support and follow this Code, and share the same principles as Matterport.

This Code has been implemented following consultation with the Matterport Board.

2. Whom This Code Applies To and Compliance with the Code

This Code applies to all persons working for us, our suppliers and our customers, including all employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns and individual temporary or fixed-term contractors, wherever located.

This Code does not form part of any contract of employment or contract to provide services and we may amend it at any time. However, we require our customers and suppliers to explicitly acknowledge and follow the principles embodied in the Code and to ensure that their own customers and suppliers will also follow these principles.

We hope and expect that our customers and suppliers will support the Code as outlined and will integrate and apply the Code in a manner consistent with their own supplier programs.

3. Responsibility for the Code

The Chief Compliance Officer of Matterport has overall responsibility for ensuring the Code complies with our legal and ethical obligations, and that all those under our control comply with it.

The Chief Compliance Officer has primary and day-to-day responsibility for implementing this Code, monitoring its use and effectiveness, dealing with any queries about it and auditing internal control systems and procedures to ensure they are effective in managing ethics and conduct on behalf of Matterport.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this Code and are given adequate and regular training on it and the issues covered by it.

4. Workplace Environment

4.1 Diversity, Equity, and Inclusion

To ensure that, at all times, there is a culture of diversity, equity, inclusion and respect for all employees. This should include (but not be limited to) taking these positive steps: promoting equal opportunities and fair treatment of all employees, irrespective of race, religion, age, skin color, nationality, ethnicity, social background, disabilities (whether visible or not), gender, gender identify, sexual orientation, marital status, religious beliefs or expression, or political affiliation or trade union membership.

4.2 Discrimination, Harassment, and Bullying

To ensure that, at all times, there is a culture that does not discriminate and respects all employees. This should include (but not be limited to) the refusing to tolerate any treatment of individuals which is unacceptable, unprofessional, threatening or disrespectful such as any form of sexual harassment, discrimination including gestures, language and physical contact, that is sexual, coercive, threatening, abusive or exploitative and or any form of mental cruelty.

4.3 Health and Safety

To ensure that we are always acting in accordance with all applicable laws and regulations regarding occupational health and safety and provide safe working conditions to all. Furthermore we shall ensure that adequate, free and professional training is provided to all employees to educate them in all relevant health and safety requirements and issues.

A health and safety management system should be deployed and monitored at all locations.

4.4 Working Hours, Wages and Benefits for Employees

To ensure that, at all times, we adhere to all applicable working-hours regulations globally. We shall allow workforce flexibility in locations to carrying out our duties if the role allows and not to pressure any home based employee into an office environment.

To pay fair wages for labor and adhere to all applicable wage and compensation laws globally.

To adhere to all applicable legal requirements, including, without limitation, complying with minimum wages requirements, in the event any personnel is asked to work overseas then Matterport, its customers and suppliers

4.5 Workplace Violence

To refuse, under any circumstances to tolerate actual or threatened violence in the workplace or at a work-related event. Any incident will be dealt with by HR and may lead to dismissal.

4.6 Drugs and Alcohol

To comply at all times with the Matterport Drugs and Alcohol at Work Policy available upon request.

5. Business Practices

5.1 Conflicts of interest

Customers and Suppliers shall disclose to Matterport any actual or potential conflicts of interest that arise. It is a requirement for the Customer and or Supplier to notify Matterport where any of their employees or contractors have any personal, business or any other relations with Matterport that may pose a potential conflict of interest. The standard test is that the existence of such potential conflict may affect the principle of integrity and fair and proper decision-making.

5.2 Competition

All activities must be carried out in full compliance with all relevant competition and or antitrust laws where Matterport, its suppliers and or customers are conducting their business or providing services. Matterport will not and its customers and suppliers shall never agree, discuss or share non-public information regarding pricing, costs, customers, marketing or any other commercially sensitive information with competitors. Customers and suppliers are expected to refrain from engaging in any form of unfair trade practices in violation of applicable competition and or antitrust laws.

5.3 Bribery and Corruption

Matterport operates a zero-tolerance policy in relation to all matters of bribery and corruption and is committed to preventing bribery, fraud and all other corrupt business practices. All customers and suppliers are expected to have the same level of concert and practice the policy so that they comply with all anti-bribery and anti-corruption laws and regulations.

Suppliers shall not offer or pay any bribes (including any offer to provide improper gifts or entertainment or facilitation payments) to secure or retain a business advantage (for the benefit of Suppliers or for the benefit of Company). Suppliers further agree that it shall not offer or pay any bribe to any person (including to any government official or any employee of Company or relative of the Company officials) in connection with any aspect of the performance of services or supply of goods to the Company.

5.4 Gifts and Hospitality

Comply at all times with the Matterport Gifts and Hospitality Policy available upon request.

5.5 Anti-money Laundering

Matterport will not and expects its customers and suppliers shall not to directly or indirectly engage in money laundering, terrorist financing activities, tax evasion or fraud, or conduct that violates anti-money laundering laws by accepting, transferring, converting or concealing money obtained from criminal activities or related to terrorist financing.

5.6 Trade Sanctions and Import/Export Controls

Export controls, sanctions, trade embargos, or other trade restrictions are political instruments, used by the US, the UK, United Nations and the EU with the aim of bettering the behavior of the targeted country’s regimes, individuals or groups in a direction which will improve the situation in that country.

Matterport will and expects that all of its Customers and Suppliers shall conduct their business in compliance with all lawful international sanctions regimes. As such, we and they must fully comply with all applicable laws, regulations and rules relating to trade rules, export controls, restrictions, sanctions, import and export embargos including illegal boycotts. They must also implement effective internal controls to minimize the risk of any non-compliance with relevant sanction regimes, including training and support for their employees and contract workers.

5.7 Slavery, Human Trafficking and Child Labor

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labor, bonded and child labor and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights. Matterport takes compliance with all human rights seriously and expects the same from its business partners and suppliers. In particular:

Workers shall not be subject to forced, prison, bonded, indentured, slave, trafficked or compulsory labor in any form, including forced overtime. All work must be carried out voluntarily.

Workers shall not be coerced to provide their labor and shall not have their identity or travel permits, passports, or other official documents or any other valuables withheld as a condition of employment and the withholding of property shall not be used to restrict workers' freedoms or to create workplace slavery.

Workers shall not be required to make payments which have the intent or effect of creating workplace slavery, including security payments, or be required to repay debt through work.

There shall be no use of child labor. Nobody shall be employed under the minimum age.

Workers and their families or carers shall not be subject to harsh or inhumane treatment, including but not limited to harassment or intimidation, punishment of any kind, physical, psychological or sexual violence or coercion or abuse of any sort.

Workers shall be free to move without unreasonable restrictions and shall not be physically confined to the place of work or other employer-controlled locations (for example accommodation homes). There shall be no requirement placed on workers that they take accommodation in employer controlled premises except where this is necessary due to the location or nature of the work being performed.

Where it is necessary to recruit workers who are engaged via a third party, such as an employment agency, then only reputable employment agencies shall be engaged. Where workers are sourced to be employed directly, only reputable recruitment agencies shall be engaged. All such agencies must have the necessary licences and registrations under local laws; agree to adhere to this Code of Conduct; and agree to be audited to ensure their compliance with this Code.

5.8 Environmental Operational Compliance

We’re a technology-based company that uses natural resources to run our business. We are acutely aware of how our actions impact the climate. Our strategy is to build resilience and do more each year with fewer natural resources. We require our customers and suppliers to consider their impact on the environment. We encourage all our customers and suppliers to provide positive solutions to reduce the effects their consumption, products, services and logistics have on the environment

As a minimum, customers and suppliers must comply with all applicable environmental laws and regulations and minimize harm to the environment, establish operational practices which minimize the impact on the environment and deploy measures to prevent and reduce harm to the environment

Furthermore, we expect customers and suppliers to have commitments to identify, measure and reduce significant environmental impacts, identify business risks associated with climate change and align with Matterport’s environmental policies.

5.9 Sustainability

We are committed to building a better world and we want our customers and suppliers to do the same. Sustainability is an integral part of who we all are and what we all do every day. We understand progress involves us balancing the many elements of business such as human, manufacturing, financial and social relationships. This includes environmental controls and goals, social responsibility and economic growth. We (and expect our customers and suppliers to also) provide an environment and solutions that make productive and efficient use of resources.

6. Company Assets and Information

6.1 Intellectual Property

Matterport is the category creator of digital twin technology and constantly delivers innovations that improves customers experiences and innovates change and enhancements in 3D modelling and by working with suppliers that can best meet our business demands and requirements in terms of cost, innovation, integrity, quality, suitability, credibility and sustainability and working with customers to whom we add value to their own businesses. Matterport, therefore, requests that all customers and suppliers respect all of Matterport’s intellectual property rights and protect our trade secrets, know-how and confidential information, and safeguard customer information.

We expect and ask that all customers and suppliers protect intellectual property rights by using technology and processes and know-how.

6.2 Data Protection

Matterport believes that the right to privacy is a fundamental right of an individual and Matterport respects the privacy of individuals and is committed to complying with the applicable data privacy laws and legislations including but not limited to the European General Data Protection Regulation, the California Consumer Privacy Act, the Data Protection Act 2018 in the UK and other applicable privacy laws to the extent that they apply to Matterport’s processing of personal data.

Matterport, therefore, expects its customers and suppliers to comply with all applicable laws relating to the protection of data when any personal information is collected, stored, processed, transmitted, and shared and to take appropriate measures to keep the data confidential and protected from any unauthorized use or access, modification, destruction, and disclosure, by means of adequate organizational and technical measures.

Matterport further requests that its customers and suppliers comply at all times with the Matterport Privacy Policy available here

7. Information Community Involvement and Social Responsibility

7.1 Human Rights

Matterport is fully committed to supporting and respecting human rights. We support the United Nations Guiding Principles on Business and Human Rights (UNGPs) otherwise known as the Ruggie Framework. As a result, we require our suppliers and customers to commit to the same level of respect for human rights.

7.2 Conflict Zones

Matterport believes that everyone has the right to be safe and feel safe wherever they live or reside and that without expressing any political positions, will not tolerate supporting aggressors or invaders and expects the same from its customers and suppliers.

7.3 Environmental Action

Matterport does and therefore expects its customers and suppliers to comply with all applicable environmental regulations. This includes having systems in place to ensure the safe handling, movement, storage, and recycling or waste and emissions. It also holds all required environmental permits, licenses, information registrations and restrictions and expects that its customers and suppliers shall obtain what they require to conduct business

In addition to the waste and emission requirements above, customers and suppliers shall have documented policies on the management of waste, air emissions and wastewater discharges. Customers and suppliers shall have systems in place to prevent and mitigate accidental spills and releases to the environment.

8. Your Responsibilities

You as an employee, customer or supplier must ensure that you read, understand and comply with this Code. You must also notify your manager or the compliance manager or any confidential helpline (if available) as soon as possible if you believe or suspect that a breach has occurred, or may occur in the future.

9. Consequences of Failure to Comply

Internally Matterport personnel, disciplinary action, up to and including termination and/or legal proceedings, may result from any failure to comply with:

  • The Code.

  • Applicable laws, rules or regulations.

  • Any other Matterport policy or the staff handbook.

For our customers and suppliers, our commitment to integrity and professionalism is set forth in this Code, which provides a clear set of standards for all of our business conduct. Our Code is on our website at and will be updated from time to time. We believe that deviations from, or violations of the Code are not acceptable and that our personnel, suppliers and customers should feel able to raise issues without any fear of retaliation or discrimination. We, therefore, have a confidential email or [email protected] for anyone to report any issues covered by this Code.

10. Process for Review

This Code will be reviewed annually or as required following any legislative changes or changes to industry guidance that might impact it; if there are any changes to other associated internal policies, processes or procedures or if there is any breach or other incident relating to the issues addressed in this Code.

11. Acknowledgement