Conflict of Interest

We all must avoid conflicts of interest. A conflict of interest exists when a personal interest or activity interferes or appears to interfere with the duties that you perform at, or owe to, Starbucks. A conflict of interest may unconsciously influence even the most ethical person and the mere appearance of a conflict may cause a partner’s acts or integrity to be questioned.

In addition to annual disclosure, potential conflicts of interest must be disclosed to the partner’s manager or the vice president in charge of the partner’s department or business unit, who will contact the chief ethics and compliance officer (CECO). If preferred, disclosure can be made directly to the CECO via Ethics & Compliance. Members of the Board of Directors should disclose actual, potential or apparent conflicts of interest to the Chair of the Audit & Compliance Committee.

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Some examples of situations in which conflicts of interest may arise:
  • Being employed by or operating a firm, including consulting, that does or desires to do business with Starbucks or that competes with Starbucks (for example, working in a competitor’s coffee shop)
  • Making a substantial direct investment in such a firm (by you or a member of your immediate family)
  • Acting on behalf of anyone besides Starbucks in any transaction with Starbucks (for example, helping someone sell products and/or services to Starbucks)
  • Engaging personally in transactions in which Starbucks has an interest

Starbucks Conflicts of Interest Standard

Gifts & Entertainment

A gift or favor should not be accepted or given if it might create a sense of obligation, compromise your professional judgment or create the appearance of doing so. In deciding whether a gift is appropriate, you should consider its value and whether public disclosure of the gift would embarrass you or Starbucks.

Giving or accepting valuable gifts or entertainment might be construed as an improper attempt to influence the relationship.

Trading items of value with other businesses, including shops and restaurants, is strictly prohibited. Starbucks prohibits offering, giving, soliciting or receiving any form of bribe or inducement. There are serious penalties for engaging in this conduct. 

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A gift of money should never be given or accepted. (Some retail partners, however, may accept customary tips for service well done.) A gift of nominal value may be given or accepted if it is a common business courtesy, such as coffee samples, a coffee cup, or a similar token.

During traditional gift-giving seasons in areas where it is customary to exchange gifts of money, partners should not solicit but may exchange cash with nongovernmental business associates in nominal amounts. Please consult local procedures for additional information.

Starbucks Gifts & Entertainment Standard

LEARN MORE ABOUT ENTERTAINMENT

Partners may offer or accept meals and entertainment if they are reasonable and customary, appropriate, occur infrequently and are not expensive. Please consult the travel and/or expense guidelines for your business unit or department for additional guidance.

You may not encourage or solicit meals or entertainment from anyone with whom Starbucks does business or from anyone who desires to do business with Starbucks. Giving or accepting valuable gifts or entertainment might be construed as an improper attempt to influence the relationship.

International Business

Partners must comply with all local and foreign laws regarding customs and trade. Starbucks will be accurate and truthful in representing business transactions to government agencies. All information that a partner furnishes to any customs official or to any agent hired by Starbucks to facilitate imports and exports must be accurate and truthful.

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If you conduct business internationally on behalf of Starbucks, please make sure you have a thorough understanding of these laws and know enough about any third parties doing business in Starbucks name to ensure they are making appropriate decisions on our behalf.

Starbucks partners at no time are permitted to influence the outcome of any business decision by exchanging bribes or kickbacks of any kind.

Interaction with the Government


Starbucks policy is to deal honestly and fairly with government authorities and to comply with valid governmental requests and processes. Payments made to any foreign agent or government official must be lawful under the laws of the United States and the foreign country. Payments by or on behalf of Starbucks to foreign agents or government officials should always be strictly for services rendered and should be reasonable in amount given the nature of those services. 

We must be truthful and straightforward in our dealings with the government.
It is against Starbucks policy (and may be a breach of law) to offer or make a payment or gift of any kind in order to facilitate a local process or to influence a local government official. Under no circumstances may a partner make payments in violation of the law or to induce a government official to do business with Starbucks. If you are contacted by a government or regulatory representative and asked to provide information or submit to an inspection, you should inform your manager immediately. Your manager will take appropriate actions or contact the appropriate department for guidance.

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We must be truthful and straightforward in our dealings with the government and may not direct or encourage another partner or anyone else to provide false or misleading information to any government official or representative. Partners must not direct or encourage anyone to destroy records relevant to an investigation.

Certain partners will be notified and trained on a regular basis for the purposes of compliance with relevant federal laws, including those regarding lobbying disclosure, anti-bribery and anti-corruption.

Sales Practices and Advertising

Starbucks competes on the merits of our products and services in all sales and advertising. Our communications with our customers or potential customers must be truthful and accurate. When we say something about our products and services, we must be able to substantiate it.

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We sell the quality of what we do; we do not disparage our competitors.

Fair Competition

Fair competition laws are intended to promote vigorous competition in a free market. It is in Starbucks best interest to promote free and open competition. Starbucks must make its own business decisions, free from understandings or agreements with competitors or suppliers that restrict competition. We consider compliance with these laws of vital importance.

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When conducting Starbucks business, all partners must:

  • Not discuss pricing, production or markets with competitors
  • Not set resale prices with customers or suppliers
  • Always present Starbucks services and products in a manner consistent with our core values
  • Not induce a third party to breach an existing agreement
  • Never act in a manner that could be seen as an attempt to exclude present or potential competitors or to control market prices