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Snap Inc. general counsel Michael O'Sullivan, only months into his tenure with the tech company, is putting internal leakers on blast.

A Jan. 8 memo from O'Sullivan to Snap's employees, which says the company has a “zero-tolerance policy” for leakers and mentions lawsuits and jail time for violators, was obtained by financial news network Cheddar, which published it Friday.

The reveal of O'Sullivan's memo comes at a challenging time for the Venice, California-based company, which Cheddar reported on Thursday has laid off nearly two dozen people on eight different teams. The memo itself is dated for the day before the Daily Beast reported the company was struggling to monetize its Discovery feature and that Snap used a culture of intense privacy to keep both employees and investors in the dark. The article sited former and current unnamed Snap employees as sources.

Michael O'Sullivan.

In his memo, O'Sullivan wrote that company has “a culture of sharing information across many teams.”

“That includes metrics, financial results, new products and features, potential partnerships, and strategies. We do this to help us do our jobs better, which in turn makes Snap better,” he wrote. “But this information carries a heavy responsibility. Its premature disclosure can significantly harm our business, including our ability to compete.”

O'Sullivan noted that as a publicly traded company, leaked information about Snap could heavily affect stock prices. He informed employees that they were not to speak with any reporters, on or off the record—in fact, they're not allowed to speak about their work with anyone, potentially even co-workers, who isn't explicitly authorized to know that information.

And for employees who don't adhere to Snap's code of silence, O'Sullivan threatens intimidating repercussions.

“If you leak Snap Inc. information, you will lose your job and we will pursue any and all legal remedies against you. And that's just the start,” O'Sullivan wrote. “You can face personal financial liability even if you yourself did not benefit from the leaked information. The government, our investors, and other third parties can also seek their own remedies against you for what you disclosed. The government can even put you in jail.”

O'Sullivan, a former partner at Munger, Tolles & Olson, joined Snap in August 2017, just weeks after his predecessor Chris Handman told employees he'd be leaving for personal reasons.

Snap did not immediately respond to a request for comment on the memo.


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