Scope
- This policy is applicable to all employees, agents, representatives, and other associated persons (but not limited to consultants, advisors, and temporary employees).
- It also applies to all suppliers who provide products or services to the company, and includes entities, affiliates, and subcontractors of the supplier.
- The supplier is responsible for ensuring its associated entities, affiliates and subcontractors are advised of and understand the information contained within this policy.
- The company’s procurement teams will build relationships with suppliers, ensuring that they provide the best value with respect to quality, delivery and costs.
- Failure to comply with this policy may lead to a supplier being disqualified from supplying future products and/or services to the company.
Standards / Definitions
The company expects its suppliers to:
1. Human rights - Embrace international standards relating to human rights.
2. Labor rights - Respect the labor rights of their employees in the workplace and monitor adherence to human rights within their own supply chains.
Comply with local employment standards (including terms of hours of work, wages, holidays, and overtime) and maintain a workplace that is free from unlawful discrimination, bullying or harassment.
Pay workers a wage that enables them to live with dignity and participate as active citizens in society.
3. Policies - Have policies that promote equal employment opportunities, diversity and inclusion.
4. Freedom of association - Respect employees' right to freedom of association and collective bargaining and negotiation on key conditions of employment.
5. Rights to privacy - Respect workers’ rights to privacy, including ensuring that any personal information is collected, stored and used/shared appropriately, and in accordance with the requirements of any applicable local laws.
6. Anti-slavery (forced labor) - Comply with anti-slavery laws and policies, and ensure all workers are voluntarily employed, lawfully entitled to work at that location and not under any form of forced, coerced, bonded or involuntary labor or servitude or victims of human trafficking.
7. Child Labor - Not use any child labor (being any person under 15 years of age, entitled/obliged to be completing compulsory education or under the minimum age for employment under local law).
Use reasonable endeavours to ensure no form of forced labour or child labour is used in the supplier’s supply chain.
Health and Safety
The company expects its suppliers to:
1. Maintain high standards and ensure so far as is reasonably practicable, the health and safety of their workers, those who use their products and services, and any other persons who may be affected by their work.
2. Comply with all applicable health and safety laws and regulations and maintain safe and healthy working environments.
3. Develop and maintain a sound health and safety management system that appropriately identifies risks to health and safety associated with the supplier’s work and puts in place effective systems and controls to manage those risks so far as is reasonably practicable.
4. Ensure adequate training and protection of workers within the workplace.
5. Provide health and safety information if and when requested by the company to demonstrate implementation of the health and safety management system.
6. Follow all site rules when visiting the company’s premises and working alongside the company’s employees.
Ethical Business Practices and Social Responsibility
The company expects its suppliers to:
1. Act ethically at all times and be good corporate citizens, contributing positively to their communities.
2. Carry out business with integrity and in a transparent and ethical manner, in accordance with all applicable laws, regulations and standards.
3. Not engage in any form of corruption or bribery of officials.
4. Promote the elimination of discrimination within the workforce.
5. Promote local economic development, including engaging proactively with any indigenous representatives or corporate entities for the betterment of their local communities.
Anti-corruption and bribery
1. The company expects its suppliers will not engage in any form of bribery or corruption, including the offering, requesting, or receiving of bribes, monetary or otherwise. Further, suppliers will not engage in unethical or fraudulent practices. Suppliers must maintain accurate books and financial records, implement internal controls that prevent bribery and fraud, and comply with all applicable anti-corruption laws.
2. The company is committed to collaborating and working with suppliers who share its belief in acting responsibly. If a supplier does not live up to the company’s expectations, prompt action will be taken to address any violation. In cases where a supplier does not rectify a violation, the company reserves the right to terminate the business relationship.
3. Adherence to the principles are to be included in audits carried out at the supplier.
Environmental Management
The company expects suppliers to:
1. Act in an environmentally responsible manner, to promote a sustainable future.
2. Comply with all applicable environmental regulations, laws and standards in the location(s) where they do business.
3. Conduct their business operations in a manner that minimizes negative impact on the environment.
Compliance and Auditing
The company expects its suppliers to:
1. Maintain good records of their compliance with this policy and to be able to provide the company, on its request with evidence demonstrating such compliance.
2. The company reserves the right to audit compliance with this policy in accordance with criteria determined by the company.
3. If the company determines that a supplier has failed to demonstrate adequate compliance with this policy, the company may take any or all of the following steps:
a. Work with the supplier to address areas of non-compliance through remedial measures.
b. Cease future orders for products or services from the supplier either until such a time as compliance with the policy is demonstrated to the company’s reasonable satisfaction or permanently.
Responsibilities
1. All employees and the union representatives are encouraged to be included in the creation, reviewing and operation of the Supplier Code of Conduct policy and any associated documentation.
2. It is the responsibility of the company to ensure that it will promote open and inclusive communication and consultation regarding this policy with employees.
3. The company is bound to follow this policy, and/or any other document and/or an employee’s non-compliance with other policies or procedures.
4. The company will also take ownership over the policies and procedures ensuring clear and relevant information and compliance with any amendments with legislation.
5. All employees are to comply with this policy.
6. If an employee is found to have breached this policy, they may be subject to disciplinary action up to and including termination of employment. The type and severity of the disciplinary action will depend upon the circumstances of the case and the seriousness of the breach.
7. The company will ensure the disciplinary procedures are fair, reasonable and proportionate to the offence.
8. Suppliers, agents or contractors who are found to have breached this policy may have their contracts with the company terminated or not renewed.
9. Serious violations of this policy may lead to legal action if they are proven to be dishonest or do significant harm to company’s interests or reputation.
10. In circumstances where a workplace participant’s behaviour or conduct may be potentially unlawful, the company may notify the police or other relevant authority.
Contact for further information
If there is any uncertainty around a course of action, or further clarification is required, individuals are encouraged to talk to their line manager in the first instance, or the Chief Financial Officer.
Policy Reviews
1. This policy will be reviewed every three years.
2. The company is entitled to amend and vary its policies from time to time at the company’s sole discretion and all employees are required to observe such policies.
Relevant Documentation
1. The Ten Principles of the United Nations Global Compact
2. Universal Declaration of Human Rights
3. The International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work
4. The Rio Declaration on Environment and Development
5. The United Nations Convention Against Corruption
6. Group Code of Conduct policy
Policy Protocol
Policy Owner: VP of Procurement
Approved by: Chief Financial Officer