Supplier Code of Conduct


Flywire Corporation and its subsidiaries (“Flywire,” “we” or “our”) are dedicated to making a positive contribution to society through, among many areas of focus, our people (“FlyMates”), responsible and ethical business practices, sensitivity to environmental impact and community investment. This focus is a direct reflection of Flywire’s core values of Global Collaboration, Authenticity, Fulfillment, Execution, Ambitious Innovation and Evolved Learning. These values enhance our ability to provide superior service to our clients and users, FlyMates, and our communities. We expect our service providers, vendors, and suppliers (“Suppliers”) to adhere to these key values and apply them to how they do business with Flywire and in general.

Flywire expects its Suppliers to comply with all applicable laws and adopt practices in accordance with the principles set forth in this Supplier Code of Conduct (“Supplier Code of Conduct”). These requirements are in addition to any requirements imposed by contract or law. Any Supplier may be asked to demonstrate compliance with this Supplier Code of Conduct on request. Flywire will assess conformance with these requirements and will consider a Supplier’s compliance in making sourcing and procurement decisions.

Flywire appreciates our Suppliers’ ongoing willingness to follow these standards. We hope that our Supplier Code of Conduct makes our dedication to our values clear.


Human Rights

Flywire is committed to supporting the protection and advancement of human rights in our business and throughout our supply chain. We strive to conduct our business operations in ways that seek to respect, protect and promote the full range of human rights, such as those described in the United Nations’ Universal Declaration of Human Rights.

Suppliers must comply with all applicable legal requirements related to human rights. When local laws conflict with international human rights standards, Suppliers should comply with the law while seeking to advance the underlying principles of this Supplier Code of Conduct.

No Forced Labor

Suppliers will not use forced, bonded (including debt bondage), indentured, or involuntary prison labor, and will not engage in slavery or trafficking of any person. Suppliers will ensure that workers will have access to their personal identification documents (e.g., government-issued identification, passports, or work permits). Flywire has specifically adopted a Modern Slavery and Human Trafficking Statement.

No Child Labor

Suppliers will not use child labor. We consider child labor to be anyone under 15 unless local law sets a higher threshold. Suppliers are required to comply with applicable child labor laws and employ only workers who meet the applicable minimum legal age requirement in their countries of operation.

Labor and Employment Laws

We expect all Suppliers to provide a safe, secure, and healthy work environment for their staff. Suppliers will comply with all applicable labor, employment, and occupational health and safety laws and regulations, including those related to employment practices, performance management and worker discipline, wages, and worker classification. Suppliers will also comply with all applicable wages and benefits laws, including but not limited to those relating to minimum wages, overtime hours, and legally mandated benefits.

Equity, Inclusion & Diversity

Flywire values equity, inclusion and diversity as a high priority for its workforce. These principles are representative of Flywire’s customer base and users and the many different communities in which Flywire operates. As such, Flywire expects Suppliers to engage a team that reflects these principles and is inclusive of diverse groups.

Anti-Discrimination & Harassment

Unlawful discrimination or harassment in the workplace cannot be tolerated. Discrimination, retaliation, or attempted retaliation on the basis of sex, gender, gender identity, religion, ethnicity, race, color, national origin, age, citizenship, familial status, marital status, veteran status, alienage, sexual orientation or disability or any other status protected under any applicable law is prohibited. Suppliers are required to comply with all applicable laws concerning discrimination in hiring and employment practices.

No Abuse

Suppliers will comply with all applicable laws on abuse of employees. Suppliers will not engage in any harsh or inhumane treatment, including but not limited to sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, or verbal abuse.

Freedom of Association

Suppliers should respect the rights of their employees to form, join, or not join a labor union. Where such rights are prohibited or restricted by law, Suppliers should nonetheless be committed to an open and constructive dialogue with their employees and, if applicable, their representatives.


Flywire recognizes the critical importance of a healthy environment to our global society, our economy, our business and our people. Suppliers are required to comply with all laws, regulations, ordinances, rules, permits, licenses and approvals regarding the environment in their countries of operation. In addition, beyond this, Suppliers should commit to operating in an environmentally responsible and efficient manner, including measuring, reducing, and reporting on their environmental impact. This may include conserving natural resources and minimizing their own supply chain’s impact on the environment.


Fraud, dishonesty, unethical or criminal conduct on the part of any Supplier will not be tolerated. Suppliers are required to conduct their business in a responsible and ethical manner. Suppliers must carry out their business honestly and ethically, and operate in full compliance with all applicable laws, rules and regulations. Flywire has specifically adopted a Code of Conduct that applies to its directors, officers and employees.

Bribery and Anti-Corruption

Corruption, extortion, embezzlement, bribery and kickbacks in any form are strictly prohibited. Suppliers must comply with all applicable anti-corruption laws and regulations.

Conflicts of Interest

Flywire manages, mitigates and prohibits, as appropriate, business conduct and practices that may pose a conflict among the interests of Flywire, its employees and its clients and users (See, e.g., the Code of Conduct). Suppliers will report to Flywire any conduct or relationship that could present an actual or perceived conflict with Flywire.


Suppliers shall protect all personal information received during the course of its business operations. When personal information is stored, collected, processed, transmitted, or shared, Supplier will comply with all reasonable customer requirements and applicable privacy, data protection, or information security regulations.

Insider Trading

Material Non-Public Information (“MNPI”) is a form of confidential information and includes all non-public information that may have a significant impact on the price of a security or other financial instrument, or that a reasonable investor would likely consider important in making an investment decision. Buying or selling securities while in possession of MNPI that is acquired by virtue of the Supplier’s relationship with Flywire is strictly prohibited, as is the communication of such information to others. Suppliers must comply with all insider trading laws, and Flywire expects its Suppliers to have reasonable controls in place to prevent its workers from transacting in Flywire securities based on Flywire MNPI.