Supplier code of conduct

1. Protecting our planet’s environment

We’re committed to:

• sourcing products and services that minimize environmental harm, and

• working with suppliers on ways to understand the environmental impact of our products, and

• encouraging the continual evaluation of environmental best practices.

2. Conduct business lawfully and with integrity

We expect our suppliers to adhere to local laws and international standards regarding human rights, workplace safety, workers compensation and treatment.

3. Treat employees with dignity and respect

We believe employee equality is a fundamental human right. We expect all suppliers to establish a safe, respectful, and inclusive workplace for their employees.

4. A safe and healthy workplace for everyone

We expect our suppliers to conduct their activities in a manner that respects human rights as set out by international frameworks, including the United Nations Guiding Principles on Business and Human Rights.

5. Respect and support local communities

We believe every company has a responsibility to the local communities on which they have an impact and from which they profit. We are committed to working with suppliers who understand the issues facing the communities in which they operate, and to endeavour to conduct business in a way that builds social capital and achieves a positive impact.

As a minimum, suppliers must comply with all applicable environmental regulatory requirements and employ reasonable measures to mitigate any adverse impacts its products and services may have on the environment.

Where we classify a supplier as having either a high or medium environmental impact, they should have policies and procedures in place to manage these risks.

Suppliers recognise the importance of addressing environmental sustainability in their business and continuously work to minimise the environmental impact of their operations, as much as possible.

We seek to ensure that best practice in environmental principles, statements and metrics are incorporated in our business policies. We pay particular attention to ethical and sustainable sourcing, environmental performance and our relationships with our suppliers and customers.

Suppliers must comply with all applicable laws, regulations, and standards within the countries in which they operate and in which they carry out activities for us. Suppliers will conduct business in an honest and ethical manner.

We have  zero-tolerance for any form of bribery, corruption, extortion, fraud, theft, or embezzlement. All of our Suppliers must comply with all applicable anti-bribery laws and maintain accurate records that correctly reflect their transactions and contain no false or misleading information.

We expect our suppliers to disclose any and all conflicts of interest in any business dealings. Suppliers must avoid all conflicts of interest that may adversely influence business relationships.

Any ownership or beneficial interest in a Supplier’s (including a Supplier’s subcontractors or agents), business by a government official, representative of a political party, or any of our employees must be declared to us prior to entering into any business relationship with us.

We expect our Suppliers to obtain and use all market intelligence legitimately and in compliance with all applicable laws and regulations.

We strongly discourage gift giving, however, we appreciate that in limited instances, gift-giving (of nominal value) may be customary in some countries and cultures to maintain business relations. Gift-giving should occur sparingly and always be legitimate and aligned with our Code of Conduct.

In no instances shall Suppliers accept from or offer to our employees any cash or cash equivalent gifts. Any gifts, entertainment, or hospitality must always be of nominal value and, regardless of amount, never received or offered during contract negotiation, bidding, tender, or award. All employees are provided with training on gifts and hospitality and all employees and Board members must disclose all gifts on our Gift Register.

Suppliers must comply with applicable embargoes and trade sanctions, including the restrictions maintained by the EU, UN, US, and the UK (or all other applicable laws). These laws prohibit dealings with restricted countries, governments, businesses, and individuals.

All business and commercial dealings are transparently performed and must be accurately recorded in the Supplier’s records. Suppliers will not falsify records or misrepresent conditions or practices. There must be no actual or attempted participation in financial crime, tax evasion, facilitation of tax evasion, and money laundering and Suppliers will take steps to prevent financial transactions from being used by others to launder money or evade or facilitate the evasion of taxes.

No confidential information in the Supplier’s possession regarding us or our affiliates is used to either engage in or support insider trading.

We have a zero-tolerance policy towards tax evasion or facilitation of tax evasion. We are fully committed to complying with all legislation, regulation, and applicable guidelines designed to prevent tax evasion and the facilitation of tax evasion wherever we, our clients, our Suppliers, and our business partners operate. At all times, business is to be conducted in a manner such that the opportunity for, and incidence of, tax evasion is prevented.

Our confidential information, know-how, and intellectual property must be respected and safeguarded. Any and all personal information about individuals, such as our consumers or employees, must be handled with full respect for the protection of their privacy and for all relevant privacy laws and regulations. All information provided by us that is not in the public domain is deemed confidential and it is only used for its intended and designated purpose.

We expect Suppliers not to misuse or misappropriate any of our physical assets and proprietary information. All such information and data must be kept confidential and protected from any unauthorized access, destruction, use, modification, and disclosure, through appropriate organizational and technical controls. Suppliers must respect the intellectual property rights of all third parties.

All employees (whether directly employed or not) are provided with means by which to raise their concerns about any of these requirements.

We expect suppliers to establish a safe, respectful, and inclusive workplace for their employees. All employees are treated with respect and dignity. No employee is subject to any threats, bullying, or unlawful harassment of any type, including emotional, physical, or sexual harassment. We expect Suppliers not to discriminate against any person or group of people in its hiring and employment practices, codes of conduct, programs, services, compensation, advancement, discipline, termination, or retirement or in any other aspect of its operations or activities on the basis of that person or group of people's personal characteristics or attributes.

Any form of disrespect and abuse towards any of our employees is not tolerated.

We expect Suppliers to create a work environment where all individuals have equal opportunities and are treated with dignity and respect. We encourage Suppliers to seek to create an equally diverse and global workforce, and to expect their employees to embrace norms that support an inclusive culture, workplace, and community. 

Under no circumstances should a Supplier use forced labor, whether in the form of compulsory or trafficked labor, bonded labor, indentured labor, or other forms. Mental and physical coercion, slavery, and human trafficking are prohibited. 

All employees are paid fair wages which meet or exceed the legal minimum standards or appropriate prevailing industry standards, whichever is higher. Other than legally mandated deductions, all other deductions from wages must be made only with the express and written consent of the employees concerned and in compliance with applicable laws and international human rights standards.

Working hours for all employees are reasonable, and employees are not required to work more than the regular and overtime hours allowed by the law of the country where the employees are employed. All overtime work by employees is on a voluntary basis and compensated in line with relevant regulations.

We expect all suppliers to provide their employees with a healthy and safe workplace, as per local health and safety laws and regulations, to prevent accidents and injury arising out of, linked with, or occurring in the course of work or as a result of the supplier/employer’s operations.

All employees - whether permanent, fixed term, or casual - are provided with employment documents that are freely agreed to and respect employees’ legal and contractual rights.

All employees are of an appropriate age

Under no circumstances should a supplier employ individuals under the local legal minimum age for work or mandatory schooling. When young employees are employed, they must not do work that is mentally, physically, socially, or morally dangerous or harmful or interferes with their schooling by depriving them of the opportunity to attend school.

The rights of employees to freedom of association and collective bargaining are recognized and respected. Employees are not intimidated or harassed in the exercise of their right to join or refrain from joining any organization.

We encourage Suppliers to bolster the well-being of the local community through their business. Suppliers must operate with respect for local communities and indigenous people and their rights and title to property and land.

We encourage Suppliers to understand and observe the cultural and economic context in which they are working, to operate safely and responsibly, to be mindful of the wellbeing of communities and to foster positive social and economic relationships with local communities.

We recognize the mutual influence between supply chains and communities and encourage our Supplier to take opportunities to integrate sustainability initiatives into their supply chain - through creating value for communities and providing a more integrated and holistic consideration of supply chain-community interactions.