The trust our clients and partners place in us to handle sensitive commercial data responsibly, to represent our products and capabilities honestly, and to compete and collaborate with integrity is the foundation of everything we build. This Code of Conduct establishes the standards we hold ourselves to, as individuals and as an organization.
Published: April 2026
A note from our CEO, Jay Margolis
At SPINS, we believe our greatest strength is how we show up — for each other, for our partners, and for the communities we serve. Our Code of Conduct is one way we put our values into action. It reflects the high standards we set for ourselves and the responsibility we carry as stewards of data and insights in the consumer products industry.
As we continue to grow and evolve, one thing remains constant: the “how” matters just as much as the “what.” That means we hold ourselves to a standard of integrity, respect, and transparency in every interaction, whether we’re advising a brand, analyzing a dataset, collaborating with teammates, or making decisions behind the scenes.
This Code isn’t just a set of policies; it’s a reflection of our shared commitment to doing the right thing, even when it’s not easy. It’s a reminder that every one of us contributes to the culture we’re building and the trust we earn.
I encourage you to read, understand, and refer to our Code of Conduct. While this Code may not apply to every possible situation you may face, it can help you make informed decisions and provide guidance on when and how to seek advice.
Our mission is ambitious, and we can’t accomplish it alone. Thank you for living our values (being Direct, Determined, Passionate, and Collaborative) and for helping make SPINS a company our partners are proud to work with and where all of us are proud to work.
With appreciation,
Jay Margolis
Chief Executive Officer
SPINS LLC
This SPINS Code of Conduct (“Code“) can’t cover every situation you may face, and it’s not meant to. But it should serve as a helpful guide for navigating challenges, asking the right questions, and knowing when to seek support. Use your judgment, lean on our shared values, and speak up when something doesn’t feel right.
The Code applies to all of us, regardless of title, team, or tenure. That includes:
Everyone has a role to play in upholding our standards. If you represent SPINS, we expect you to know and follow the spirit and the letter of this Code.
The Code is a living document. It reflects SPINS’ values, business practices, and the expectations we hold ourselves to. As our company evolves, and as laws, technologies, and industry standards change, this Code will be reviewed and updated accordingly.
We will periodically review this Code to ensure it remains aligned with our culture and regulatory responsibilities. SPINS may revise the Code at any time, and team members are expected to stay current with updates. You may be asked to complete training or formally acknowledge your understanding. The Legal team is responsible for maintaining the Code and answering any questions about how it applies.
The most current version of this Code is always available on SPINS’ website. SPINS team members will also receive a copy during onboarding, and we’ll continue to highlight key topics through training and team discussions.
As we noted before, team members are expected to speak up when something doesn’t seem right. But at SPINS, ethical behavior goes beyond reporting misconduct. It means building a culture where questions are welcomed, accountability is modeled, and responsibility is shared.
You are expected to promptly report any suspected or actual violation of law or SPINS policy, whether it’s accidental or intentional, and no matter who is involved. That includes conduct by any SPINS team member, officer, executive, or third party acting on our behalf. Timely disclosure allows us to take action and uphold our standards. Failing to report a known or suspected violation is, in itself, a violation of this Code.
We take all reports seriously and investigate them appropriately. You will not face discipline or retaliation for reporting in good faith. We will endeavor to investigate these reports fairly and with discretion. To the extent practical or possible by law, we will protect the identity of the individual making a report.
In addition to SPINS’ anti-retaliation commitment, you may be protected under federal or state whistleblower laws. These laws may provide additional safeguards for reporting certain violations, such as securities fraud or workplace safety concerns.
SPINS will fully comply with all applicable laws and cooperate with any government investigations related to potential unlawful conduct. Nothing in this Code is intended to require any action that would violate applicable law.
Ethical questions aren’t always black and white. If you’re unsure how to handle a situation or if something doesn’t feel quite right, reach out.
Start with your team leader as your primary point of contact. You may also engage the Legal team directly for questions, guidance, or to report concerns. Contact any Legal team member individually or email [email protected]. To report anonymously, call 888-511-2598 or submit a report at www.spins.com/reporting.
We take your concerns seriously and are committed to creating a culture where people feel safe speaking up.
Integrity is about more than just following the rules. It’s about earning trust through our actions, owning our impact, and showing up with clarity and care.
It is your responsibility to:
If you are a team leader, you have additional responsibilities. You are expected to:
Mistakes happen. What matters is how we respond. Taking responsibility for a misstep, a miscommunication, or a missed opportunity is a sign of strength, not weakness. Blame doesn’t move us forward. Accountability does.
SPINS is committed to operating ethically and in accordance with the laws that apply to our business. Compliance is not just a legal obligation; it’s part of how we earn trust and maintain the integrity of our work across the consumer products ecosystem.
We expect every team member, contractor, and partner acting on SPINS’ behalf to understand and follow applicable laws, regulations, and internal policies.
SPINS complies with laws relevant to our operations, products, services, and workforce. Depending on your role and responsibilities, this may include:
We don’t expect every team member to be a legal expert, but we do expect you to ask for guidance if you’re unsure. Legal and compliance risks can arise quickly and unexpectedly, especially as we expand our reach and product offerings.
A happens when our personal interests (or those of someone we have a close personal relationship with) could interfere with what’s best for SPINS. A conflict of interest can include the appearance of, or actual instances of, impropriety. Conflicts of interest can arise when a person engages in activities or holds interests that could affect their ability to perform their duties objectively and effectively.
Some examples of a conflict of interest include, but are not limited to:
If you think there might be a conflict, or even just the appearance of one, disclose it right away.
SPINS strictly prohibits offering, giving, or accepting bribes1, kickbacks2, or anything of value to gain an unfair advantage or to improperly influence a business decision. This includes interactions with public officials, clients, or any other individuals with whom we work.
Giving or receiving gifts, entertainment, or hospitality is not appropriate if it creates an obligation on the part of the team member or recipient, puts the giver or the recipient in a situation where either party appears biased, or is intended by either party to influence an action or business decision. In general, SPINS team members may offer gifts to prospects and customers if the gifts are:
If you’re not sure whether a gift, meal, or business courtesy is appropriate, pause and ask:
If the answer is “yes” or “maybe,” check with Legal before moving forward.
SPINS is committed to competing vigorously, ethically, and in full compliance with antitrust and competition laws. Antitrust and competition laws exist to protect free and fair markets. We follow these laws not only because it’s required, but because we believe in innovation, transparency, and creating a level playing field for our clients and partners.
We never engage in conduct that could unlawfully restrict competition. This means:
Violations of antitrust laws can result in serious civil and criminal penalties, not just for SPINS, but for the individuals involved. Even well-intentioned actions can trigger investigations, lawsuits, and reputational harm.
1 A bribe is anything of value offered, promised, given, or received to improperly influence a decision, secure an unfair advantage, or encourage someone to act contrary to their duties or responsibilities. Bribes can take many forms: cash, gifts, travel, entertainment, services, favors, charitable donations, job offers, etc.
2 A kickback is a type of bribe given to someone as a reward for facilitating a transaction, awarding business, or making a favorable decision.
SPINS strictly prohibits insider trading or “tipping.” You may not use, share, or act on any material nonpublic information, including SPINS data, for personal gain or to benefit others. This includes information about our clients, vendors, or any other companies we work with.
Material nonpublic information is information that a reasonable investor would consider important when making a decision to buy or sell securities and that is not publicly available. This may include sales performance data, merger or acquisition plans, unannounced partnerships, or financial results.
Violations of insider trading laws can result in serious consequences for both SPINS and the individuals involved, including criminal prosecution. If you’re ever unsure whether certain information is appropriate to use or share, consult the Legal team before taking any action.
For more information, refer to the full SPINS Insider Trading Policy available on the People Ops SharePoint.
In addition to legal compliance, SPINS often adopts standards and practices that go beyond the baseline, including voluntary frameworks, client-specific requirements, and industry best practices. These may include:
We take these commitments seriously. If you’re working on a project involving such standards, make sure you understand the requirements, and if you’re not sure, get clarity before proceeding.
SPINS’ work increasingly crosses geographic boundaries, and legal obligations can vary by country, state, or even city. We comply with the laws that apply to us in the jurisdictions where we operate or have legal exposure, but not all global laws apply universally.
If you’re working with cross-border data, international clients, or external partners with operations outside the U.S., check in with Legal to confirm any additional obligations.
Accurate, timely, and complete records are non-negotiable. This includes financial reports, expense submissions, timekeeping, project documentation, internal reports, emails or communications documenting approvals or business decisions, and any other aspect that reflects how we operate or how we utilize company resources.
SPINS team members are expected to maintain complete, accurate, and timely records in all of our books and records. You are expected to follow all internal controls and accounting policies, as well as any applicable legal or regulatory requirements. Records must be stored securely and managed in accordance with SPINS’ Records Retention Policy, which outlines how to properly retain and dispose of company information. We also expect full cooperation with internal and external auditors, investigators, and regulators.
This includes strict compliance with SPINS’ Travel and Expense Reimbursement Policy available on the People Ops SharePoint. All expense reports must be truthful, submitted promptly, and supported by proper documentation. Submitting false or inflated expenses, misclassifying personal purchases as business-related, or failing to follow approval workflows violates this Code. Expenses must be reasonable, appropriate to the business purpose, and aligned with our expectations of professional conduct.
If you become aware of any errors, irregularities, or violations of internal controls, it’s your responsibility to report them promptly. Falsifying records, omitting information, or signing something you know to be incorrect constitutes a serious violation of this Code and may result in legal or disciplinary action.
Violations of this Code or SPINS policies are taken seriously and may result, at SPINS’ full discretion, in disciplinary action, up to and including termination of employment. In some cases, violations may also break the law and carry serious legal consequences, both for SPINS and for the individuals involved.
SPINS is trusted with some of the most valuable information in the consumer products industry, and we don’t take that responsibility lightly. Data is at the heart of what we do, and protecting it is part of everyone’s job.
Whether you work directly with our data, internal systems, confidential, proprietary business information, or intellectual property (“IP“), you’re expected to handle data with care, act with integrity, and always follow SPINS policies.
When we talk about confidential or proprietary information at SPINS, we’re referring to any nonpublic information that, if disclosed without authorization, could harm SPINS, our partners, or individuals. This includes, but isn’t limited to:
This list isn’t exhaustive. When in doubt, assume information is confidential and check with the Legal team before sharing, whether internally or externally.
In addition to our own data, we often work with proprietary information provided by clients, vendors, and other third parties. We treat this information with the same level of care and respect as our own.
You should never use, copy, or share someone else’s confidential information unless you’ve been authorized to do so. And if you ever receive information you believe may have been shared in error, don’t use it and report it immediately.
We all have a duty to protect this information. That means:
Your obligation to protect confidential and proprietary information continues throughout your employment and after you leave SPINS.
We also have an obligation to protect the privacy of individuals whose personal information is entrusted to us. SPINS complies with all applicable privacy laws in the jurisdictions where we operate. To better understand how we protect personal data, you can review the SPINS Privacy Policy at https://www.spins.com/privacy/.
If you suspect that personal data has been misused, mishandled, or shared improperly, even accidentally, notify the Legal team right away. Early reporting helps prevent further risk and allows us to respond appropriately.
We’re committed to using data thoughtfully, transparently, and in line with our contractual and legal obligations. Data should only be accessed, used, and shared in ways that align with our values, client agreements, and intended purposes.
Our analytics have influence. A single data point from SPINS can inform retail decisions, investor behavior, product development, and competitive strategy. That’s why our insights must be presented accurately and without distortion.
You should never:
Trust is reinforced by how we communicate. Be clear about what SPINS data can and can’t do, and don’t overpromise. If we can’t support a particular insight, say so. If a product is in beta, disclose that. If we’ve made a mistake, own it and fix it.
Transparency builds credibility. Obscuring limitations or overhyping results undermines our value and our reputation.
SPINS data is governed by strict usage rights. Every dataset and deliverable has boundaries around where and how it can be used. Misusing, misrepresenting, or re-sharing SPINS data, even unintentionally, can damage relationships, violate contracts, or create legal risk.
You should never:
If you’re unsure whether a specific use is permitted, stop and confirm with your team leader or the Legal team.
Data security is a shared responsibility. You’re expected to follow SPINS’ security policies and best practices, which may include:
A single mistake can lead to serious consequences, not just for SPINS but for our partners and clients.
Work you create or contribute to while employed or while you work with SPINS, including inventions, code, designs, documentation, reports, presentations, and other deliverables, may be considered SPINS IP. Unless otherwise agreed in writing, SPINS owns all rights, title, and interest in work product developed during your employment that relates to our business or is created using company time, equipment, or information.
This includes:
Respecting IP also means not using or bringing in others’ proprietary content without proper authorization. If you have questions about ownership or are developing tools, content, or inventions in your role, reach out to Legal for clarification.
Only authorized team members may speak on behalf of SPINS to the media, analysts, or external audiences. This includes social media, press inquiries, blogs, or public forums. If you’re contacted by a reporter, analyst, or third party about company matters, refer them to the External Communications and Media team.
Team members must also avoid disclosing confidential or proprietary information in any external communication, including online posts or personal social media accounts. Even well-intentioned comments can create reputational or legal risk. If you choose to identify yourself as a SPINS team member online, be clear that your views are your own.
At SPINS, innovation is in our DNA, but so is responsibility. We push boundaries, explore new ideas, and evolve our products and services to meet the changing needs of our ecosystem. But we do so with a clear understanding: just because we can doesn’t always mean we should.
We’re committed to driving progress while protecting the trust our clients, consumers, and team members place in us.
We encourage every team member to ask questions, test ideas, and pursue bold solutions. Innovation doesn’t just happen on product or engineering teams; it happens across the business, wherever someone challenges the status quo or proposes a better way.
This means:
At SPINS, we grow by learning, and we learn by experimenting thoughtfully.
We embrace new tools, including artificial intelligence (“AI“), machine learning, and automation, but we use them deliberately and ethically.
That includes:
All emerging technologies must align with SPINS’ AI Acceptable Use Policy, Privacy Policy, data use standards, and values. If you’re working with a new tool or model, check the SPINS’ AI Acceptable Use Policy for a list of approved AI tools. If you are still unsure whether your use of the AI tool crosses a line, check with the Legal or Product leadership teams before moving forward.
At SPINS, we believe people do their best work when they feel respected, valued, and supported. That’s why we’re committed to fostering an environment where everyone can thrive. When we treat each other with dignity and act with empathy, we create space for new ideas, stronger collaboration, and shared success. Together, we’re building a workplace where integrity isn’t just expected, it’s modeled.
We’re proud of our diverse, creative, and passionate team. We know that different perspectives, experiences, and identities make our work and our culture better. That’s why we actively foster inclusion, belonging, and equity.
SPINS strictly prohibits discrimination or harassment of any kind based on race, ethnicity, gender identity, sexual orientation, religion, national origin, age, disability, or any other characteristic protected by law. We are committed to providing equal employment opportunities, making space for everyone to be their authentic selves, and including team members irrespective of background, experience, or perspective.
Inclusion at SPINS means:
Everyone deserves to work in an environment that’s free from hostility, intimidation, or harm. SPINS has a zero-tolerance policy for harassment, including sexual harassment, whether it happens in person, online, or through any other channel. This can include:
At SPINS, we treat each other with respect and do not tolerate harassment or discrimination, whether against a team member, client, vendor, affiliated agent, or other third party. If you experience or witness any of this behavior, whether in person, online, in meetings, or in messages, report it. You can speak to your team leader, People Ops, or Legal. We’ll handle it with care and urgency.
Respecting the workplace also means taking care of our shared environment, whether at the SPINS Campus or working remotely. That includes:
We also recognize the importance of work-life balance. We encourage you to set boundaries, take time to recharge, and use your time off. A healthy team is a strong team.
SPINS provides access to systems, equipment, and tools to help you do your best work. These resources are intended for business use and must be used responsibly. You should not use company systems, tools, or time for personal benefit, non-SPINS business activity, or any illegal or inappropriate purposes.
This includes:
Working under the influence of substances such as alcohol, cannabis, illegal drugs, or misused prescription drugs can impair your judgment and endanger the safety of others. To protect our team and maintain a productive environment, SPINS prohibits the use, possession, distribution, or sale of illegal drugs or the misuse of controlled substances while working, whether on-site, remote, or at a company-sponsored function.
There may be occasions, such as at SPINS-related events or while entertaining clients, when responsible alcohol consumption is permitted. In these situations, you are expected to maintain good judgment, act in moderation, and uphold SPINS’ standard of professionalism at all times.
We prohibit all forms of modern slavery, including forced labor, child labor, bonded or indentured labor, excessive labor practices, and human trafficking. We comply with all applicable wage and hour laws, health and safety standards, and employment-related laws in every jurisdiction where we operate. We respect the right of team members to join, form, or not to join a labor union or other lawful organization of their own choosing, without fear of reprisal, intimidation, or harassment. Where we can, we transparently report on our practices to promote accountability and progress.
At SPINS, our commitment to bettering the world doesn’t stop at data; it extends to how we operate, whom we partner with, and the long-term impact we aim to make in the consumer products industry.
We believe our business success should go hand-in-hand with environmental stewardship, social impact, and community engagement. Being resourceful means we understand the impact our business has on the environment and work together to mitigate risks and operate sustainably. We promote awareness of environmental responsibility and aim to lead by example in our industry.
We strive to make business decisions that support a healthier planet. That includes:
We know sustainability is a journey, and we’re committed to continuous improvement.
We’re proud to support the people and companies reshaping the consumer products landscape for the better. Whether through our data, partnerships, or community programs, we aim to uplift:
When we succeed, we want others to succeed with us. As a company, we strive to make things better in our communities through charitable contributions, partnerships with nonprofits, and team member volunteering.
SPINS aims to purposefully and authentically support organizations that share and extend our commitment to creating healthier communities and a stronger, more sustainable food system. Each year, SPINS selects up to 3 partners to prioritize corporate giving programs, comprised of time, money, and/or content. For more information about this program, reach out to the People Ops team.
We choose to collaborate with companies that reflect our commitment to ethics, sustainability, and social responsibility. This doesn’t mean every partner needs to be perfect, but we do expect alignment in values, transparency in practices, and mutual respect in all engagements. If you’re involved in selecting, negotiating with, or managing external partners, consider their environmental and social track record alongside financial or operational metrics.
We may also engage with government officials, industry associations, and experts on public policy issues important to our business and to our clients.
Outside of SPINS-sponsored activities, team members are encouraged to engage in charitable or civic efforts in ways that are personally meaningful. If you choose to participate in charitable or political activities, you must do so on your own time, with your own funds, and clearly as an individual, not as a representative of SPINS. SPINS resources (including funds, time, equipment, or personnel) must not be used for personal initiatives, and no one should be pressured or influenced to support any particular cause, candidate, or campaign.