Our expectations
Blackwell Bridge LLC (“Blackwell Bridge,” “BB LLC,” “we,” or “us”) expects suppliers to conduct business lawfully, honestly, and responsibly.
This Supplier Code of Conduct (“Code”) establishes expectations for the organizations and individuals supplying products or services to BB LLC, including hardware vendors, distributors, brokers, cloud and compute providers, integration firms, logistics providers, consultants, and subcontractors.
Our priorities include authentic products, accurate commercial representations, responsible sourcing, protection of confidential information, and reliable delivery.
1. Scope and contractual application
Suppliers should communicate the relevant requirements of this Code to personnel and subcontractors involved in BB LLC engagements and take reasonable steps to promote compliance.
This Code states BB LLC’s supplier expectations. Publication alone does not amend an existing agreement. Contractual obligations arise when this Code is expressly incorporated into an applicable agreement, purchase order, or other accepted terms.
Applicable law must always be followed. If a supplier identifies a conflict between this Code, applicable law, and an agreement, it should promptly notify BB LLC. The agreement’s applicable order-of-precedence provisions govern contractual conflicts.
2. Legal compliance and business integrity
Suppliers must comply with laws and regulations applicable to their operations and the relevant transaction.
Suppliers must not engage in fraud, bribery, corruption, extortion, embezzlement, money laundering, or unlawful anticompetitive conduct.
Suppliers must not offer or accept improper payments, kickbacks, or benefits intended to influence procurement decisions, obtain an unfair advantage, or improperly affect a public official.
Suppliers must accurately represent their legal identity, ownership, commercial authority, licenses, and qualifications. They must not imply vendor authorization, partnership status, certification, or government approval they do not hold.
3. Conflicts of interest and commercial transparency
Suppliers must disclose actual or potential conflicts of interest that could materially affect an engagement with BB LLC.
Referral fees, commissions, rebates, and other compensation arrangements must be lawful and documented where relevant to the transaction. Suppliers must disclose arrangements when required by law or contract, or when necessary to avoid misleading a party about the supplier’s role.
Suppliers must not knowingly misrepresent pricing, inventory, allocation rights, financing terms, delivery commitments, warranty coverage, or support capabilities.
4. Human rights and fair labor
Suppliers must not use forced labor, human trafficking, or unlawful child labor in activities connected with BB LLC engagements.
Employment must be voluntary. Suppliers must not unlawfully retain identity documents, restrict workers’ freedom of movement, or impose coercive recruitment practices.
Suppliers must comply with applicable requirements concerning wages, working hours, benefits, freedom of association, and collective bargaining.
Suppliers must provide a workplace free from unlawful discrimination, harassment, violence, and retaliation.
5. Health and safety
Suppliers must provide safe working conditions appropriate to their activities.
Relevant risks may include electrical work, lifting and handling heavy equipment, battery systems, heat exposure, warehouse operations, transportation, and data-center access.
Suppliers must provide appropriate training, protective equipment, emergency procedures, and incident-response arrangements as required by applicable law and the work being performed.
6. Authentic hardware and responsible sourcing
Suppliers must not knowingly supply counterfeit, stolen, unlawfully diverted, tampered-with, or materially misrepresented products.
Products must be accurately described as new, used, refurbished, remanufactured, repaired, or otherwise conditioned. Material limitations, damage, prior modifications, and known defects must be disclosed before contracting or delivery, as applicable.
Where relevant to a transaction, suppliers must provide reasonable supporting evidence of lawful ownership, source, serial numbers, product condition, authorization status, and warranty eligibility.
Suppliers must not remove or alter identification labels, substitute components, or change the agreed configuration without appropriate disclosure and authorization.
Suppliers must promptly report suspected authenticity, provenance, ownership, or warranty discrepancies affecting a BB LLC engagement.
7. Trade compliance and government-related engagements
Suppliers must comply with applicable export controls, economic sanctions, customs requirements, and import restrictions.
Suppliers must not facilitate unlawful diversion or evade applicable end-user, end-use, destination, licensing, or restricted-party requirements.
Where relevant and reasonably requested, suppliers must provide accurate information concerning product origin, export classification, shipment routing, and supporting trade documentation.
For government-related engagements, suppliers must comply with procurement requirements and contract clauses applicable to their role. They must not misrepresent eligibility, country of origin, security status, certifications, or compliance capabilities.
This Code does not assert that every supplier or product qualifies for government procurement.
8. Accurate compute and performance representations
Cloud, compute, and infrastructure suppliers must accurately describe their offerings, including:
- Accelerator model and configuration.
- Dedicated, shared, reserved, or on-demand capacity.
- Allocation rights and material availability constraints.
- Hosting region and relevant data-location arrangements.
- Pricing, billing units, minimum commitments, and additional charges.
- Service levels and support obligations.
- Software compatibility and material integration limitations.
- Power, cooling, networking, and installation requirements, where relevant.
Performance claims must distinguish measured results from estimates, simulations, projections, and future roadmap capabilities.
Material benchmark assumptions must be disclosed when needed to interpret a claim, including model, precision, workload size, concurrency, latency, throughput, and relevant system configuration.
Suppliers must not represent future capacity or development-stage products as currently available production offerings.
9. Information security, privacy, and responsible AI use
Suppliers must protect confidential information, personal information, credentials, and customer data received or accessed through a BB LLC engagement.
Security measures must be appropriate to the information and services involved and consistent with applicable law and contractual requirements.
Access must be limited to authorized personnel with a legitimate need. Information must be retained, returned, or securely deleted in accordance with applicable agreements and legal requirements.
Suppliers must not use nonpublic BB LLC or customer information to train AI models, upload it to unapproved AI services, or disclose it to third parties without appropriate authorization.
Suppliers must notify the designated BB LLC contact without undue delay after discovering a suspected or confirmed security incident affecting BB LLC or customer information, systems, or services. Contractual and legally required notification timelines remain controlling.
Suppliers must cooperate reasonably with containment, investigation, and remediation.
10. Environmental responsibility and asset disposition
Suppliers must comply with applicable environmental requirements and manage hazardous materials and electronic waste responsibly.
Environmental, energy-efficiency, and sustainability claims must be accurate and supported by appropriate evidence.
Where services involve equipment reuse, refurbishment, recovery, or disposal, suppliers must maintain agreed custody records and disclose material downstream processing arrangements.
Data-bearing assets must be handled and sanitized in accordance with the applicable agreement. Suppliers must not resell or dispose of assets containing customer data without authorized handling and sanitization.
Any certification claimed for recycling, environmental management, or data destruction must be current and applicable to the relevant facility or service.
11. Quality, delivery, and subcontracting
Suppliers must meet agreed specifications and disclose material deviations.
Suppliers must promptly notify BB LLC of issues that could materially affect quality, price, availability, delivery, security, or performance.
Subcontracting must comply with the applicable agreement. Required approvals must be obtained before delegating restricted work.
Suppliers remain responsible for obligations assigned to them under the applicable agreement, including management of their subcontractors where required.
12. Records and reasonable verification
Suppliers must maintain accurate records appropriate to the transaction and applicable legal retention requirements.
BB LLC may request relevant documentation to evaluate supplier representations and compliance.
Audits, site visits, system access, testing, or other intrusive verification activities require an applicable contractual right or separate agreement. Verification must respect confidentiality, privacy, security, and third-party restrictions.
Suppliers must not falsify records or obstruct verification activities they are obligated to support.
13. Reporting concerns and non-retaliation
Suppliers and their personnel should report suspected violations affecting BB LLC engagements through their designated BB LLC contact or the company’s existing contact channel.
Reports should provide enough information to assess the concern without unnecessarily disclosing sensitive personal or third-party information.
BB LLC will seek to handle reports discreetly, subject to investigation needs and legal obligations. Absolute confidentiality or anonymity is not guaranteed.
Suppliers must not retaliate against individuals who raise concerns in good faith or cooperate with an investigation.
14. Corrective action and supplier decisions
BB LLC may request an explanation, supporting information, or a corrective action plan when a potential violation is identified.
Subject to applicable law and contractual rights, BB LLC may decline new business, suspend an engagement, or terminate a relationship for serious or unresolved violations.
Responses may consider the severity of the issue, immediate risk, supplier cooperation, and effectiveness of remediation.
15. Questions, acknowledgment, and updates
Suppliers should raise questions about this Code before accepting terms that incorporate it.
Written acknowledgment may be requested during onboarding or contracting. Website publication alone does not constitute supplier acceptance.
BB LLC may update this Code. Changes to existing contractual obligations must follow the relevant agreement’s amendment and notice provisions.