GOVERNANCE
Strong governance means being clear about our values, transparent about our operations, and accountable to all stakeholders. In 2025, we strengthened our governance infrastructure through how we manage our supply chain, build a culture where compliance is everyone's responsibility, and ensure the accuracy and integrity of the data that informs our business. Across these areas, governance at Snap is grounded in transparency, accountability, and a disciplined approach to oversight and risk management.
Snap's Board of Directors provides oversight and strategic guidance across business, financial, and governance matters, comprising 13 directors — including two Executive Officers and 11 independents — led by an independent, non-executive Chairperson. Three standing committees, each fully independent, support the Board's work across critical areas. Governance guidelines and committee charters are reviewed and updated regularly to reflect best practices, with ESG considerations integrated into both committee and full Board discussions to inform risk oversight, strategy, and decision-making.
At Snap, we take a thoughtful, multi-layered approach to how we govern the data we use internally and share externally. We’re committed to ensuring that all public-facing information — including financials, user metrics, advertising performance, and the data in our Transparency Report and this Citizen Snap Report — is accurate, complete, and responsibly presented. All public data statements follow a rigorous review process with robust checks and controls to uphold the highest standards of integrity.
Snap's approach to integrity and compliance centers on culture, anchored by a living Global Code of Conduct that is reviewed annually and completed by employees worldwide, with training designed around real-world scenarios. We take a zero-tolerance stance on bribery and corruption, backed by updated policies and a new compliance infrastructure that enables continuous, real-time monitoring in place of periodic reporting. Employees have multiple pathways to raise concerns, with strong whistleblower protections in place. Globally, Snap reinforces compliance through regional leadership, localized dashboards, and a Compliance Champions program that extends reach across functions and geographies — ensuring that policies are meaningfully applied wherever Snap operates.
Snap approaches supply chain responsibility through proactive oversight, clear supplier expectations, and continuous program improvement. The Supplier Code of Conduct sets standards across labor, environmental, and ethical practice. In 2025, Snap launched expanded risk assessment surveys covering nine categories across its hardware supplier network, advanced its conflict minerals due diligence (achieving a 99% supplier response rate), and leveraged risk detection tools to identify early warning signals of human rights violations. Snap is also building deeper supply chain visibility beyond Tier 1 suppliers and diversifying its supplier base to address geopolitical risks — all while maintaining a commitment to transparency, accountability, and responsible sourcing.
LOOKING AHEAD
We will continue to reinforce governance infrastructure and expand our commitment to responsible operations. We plan to build upon our risk assessment framework and develop visibility protocols to comply with the Corporate Sustainability Due Diligence Directive (CSDDD) and other evolving regulatory requirements. We will also scale our real-time compliance monitoring capabilities to enable more automated oversight across all compliance domains. We will expand our Compliance Champions program to additional global offices, further embedding our culture of compliance in local contexts. In data governance, we will prepare for the new Digital Services Act Transparency Report requirements from the European Commission, ensuring standardized and timely disclosure.
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