This Code applies to:
third party suppliers; and
any sub-contractors of third party suppliers.
The Group expects vendors to request the same standards of their own employees, agency staff, contractors, sub-contractors, suppliers and business partners. Suppliers are expected to be able to demonstrate their compliance with this Code by way of relevant processes, codes, policies and statements.
The Group reserves its right to audit a third party supplier’s adherence to this Code. Suppliers who are deemed as operating within higher risk supply chains will be specifically asked to acknowledge their agreement to the Code.
Where there are issues within the supply chain, the Group may work with the supplier to embed an improvement plan. Failing that, steps may be taken to adjust the supply chain accordingly including the terminations of contractual agreements where relevant.
The Group’s culture when engaging with third party suppliers is driven by its values which it expects all employees to adhere to:
We collaborate to create a culture in which we all share goals and values. We aim to build trust, respect and openness across the Company.
We take ownership of what needs to be done as well as our personal and professional development, helping to achieve the collective goals of the business.
We set the bar high for ourselves and our customers. They are the ones who know when we are going above and beyond and remember the promises we keep.
We treat all others fairly and communicate in a way that respects an inclusive and diverse culture, listening to all voices and ensuring opinions are offered and heard.
We act with conscience and take social, environmental and ethical factors into consideration when making decisions.
The Group believes that a diverse and inclusive workforce brings benefits to the business as people work better when they can be themselves and feel that they belong. The Group is committed to providing an inclusive working environment that is free from discrimination, harassment or victimisation and ensuring that no one is treated less favourably due to any protected characteristic according to the Equality Act 2010.
The Group expects all suppliers to:
encourage and abide by principles of diversity and inclusion in all aspects of their operational activities including but not limited to recruitment practices and relevant diversity training for all employees;
have operational processes in place to ensure reasonable adjustments are made for those who require them under disability discrimination law;
remain cognisant of socio-economic conditions in the local communities including safeguarding against the displacement of indigenous people; and
foster a culture of inclusiveness at all stages of the employment/engagement relationship including but not limited to recruitment practices.
The Group is committed to the highest standards of openness, probity and accountability. All of the Group’s employees and stakeholders are encouraged to voice any concern about wrongdoing or suspected wrongdoing in the workplace. The Group’s whistleblowing arrangements endeavour to manage whistleblowing cases fairly, consistently and in a way which protects individual whistleblowers. It is not necessary for an employee to have worked for the Group for a certain amount of time before raising a concern.
Any person concerned about unethical working practices or a breach of this Code may report their concerns on a confidential basis by email to firstname.lastname@example.org. Individuals who raise concerns are encouraged to provide as much detail as possible, so that the issues that they raise can be investigated. Employees can raise their concerns about wrongdoing or malpractice within the Group, without fear of victimisation, subsequent discrimination or dismissal.
We recognise that whistleblowers may be worried about possible repercussions from raising a concern and will only be prepared to raise their concerns on an anonymous basis. We commit to investigate anonymous allegations as thoroughly as possible taking remedial action where necessary.
Suppliers are widely encouraged to ensure their employees and sub-contractors feel supported to contact the whistleblowing hotline. Suppliers should make employees aware of how they can report issues within the supply chain.
As the Group is a regulated entity, all individuals and management within the supply chain are reminded that they are able to disclose a reportable concern either simultaneously or consecutively to the Financial Conduct Authority (FCA) and/or Prudential Regulation Authority (PRA). Employees are encouraged to raise any concerns with the Group in the first instance but this does not preclude them from making a disclosure directly to the FCA and/or PRA using the details set out below.
Financial Conduct Authority
Tel: 0207 066 9200
Address: Intelligence Department (Ref PIDA) Financial Conduct Authority, 12 Endeavour Square, London, E20 1JN
Prudential Regulation Authority
Tel: 0203 461 8703
Address: IAWB team, Legal Directorate, Bank of England, Threadneedle Street, London, EC2R 8AH
The Group expects each member of its workforce and other stakeholders to be treated with dignity and respect. The Group publishes its annual Modern Slavery Statement on its website in accordance with the Modern Slavery Act 2015. The Group endorses the UN Declaration of Human Rights and supports the UN Guiding Principles of Business and Human Rights. The Group adheres to the International Labour Organisation Fundamental Conventions. The Group does not tolerate any form of forced or child labour and as such expects third party suppliers to adhere to the following principles:
Workers shall not be subject to forced, prison, bonded, indentured, slave, trafficked or compulsory labour in any form. This includes any form of child labour.
Workers shall be treated in accordance with all applicable national laws and regulations at all times. This extends to local or national government policies including any relating to a pandemic outbreak which may include social distancing and the payment of statutory sick pay to workers who are having to isolate.
Workers must have the right to terminate their employment freely, as appropriate, following a reasonable period of notice in accordance with applicable laws and collective agreements and without the imposition of any improper penalties.
Workers shall not have their identity or travel permits, passports or other official documents or any other valuable items confiscated or withheld as a condition of employment.
Fees or costs associated with the recruitment of workers (such as fees related to work visas, travel costs and document processing costs) should not be charged to workers; and workers must not be required to repay debt through labour. Workers are still entitled to receive wages for completed work regardless of any order cancellations during and after a pandemic outbreak.
Workers shall not be under the minimum age requirement in accordance with applicable national laws.
Workers shall not be discriminated against or harassed on the basis of any characteristic contained within the Equality Act 2010 including age, disability, gender reassignment, marital status, race, religion or belief, sex or sexual orientation.
Workers shall not be subject to harsh or inhumane treatment including, but not limited to, physical punishment, physical, psychological or sexual violence or coercion, verbal abuse, harassment, intimidation or discrimination.
Workers shall be able to access and be free to file grievances to their employers about the employer's treatment of them. Workers shall not suffer detriment, retaliation, or victimisation for having raised a grievance. New and adapted procedures should be implemented if necessary.
Where it is necessary to recruit workers who are engaged via a third party or where workers are sourced to be employed directly, only reputable employment agencies shall be engaged. Rigorous checks during the recruitment process should take place to ensure that workers are not being exploited in a period of high demand.
The Group is committed to acting professionally, fairly and with integrity in all its business dealings and relationships; and expects the same of its suppliers.
The Group takes its responsibility to act in accordance with the law and to prevent bribery and corruption extremely seriously and promotes zero tolerance to any form of bribery, corruption or irregularity.
The Group expects suppliers to take its responsibilities equally seriously and ensure that they adopt a zero tolerance approach to bribery and corruption within its workforce and relationships with customers and suppliers. Therefore, suppliers must ensure that they have policies in place to stop all types of bribery and corruption and that their employees, contractors and suppliers abide by local laws and legislation including but not limited to any sanctions in place.
The Group is committed to operating sustainably and to continually reducing its environmental impact by not only promoting awareness of environmental issues amongst its employees, but also by adhering to its plan to become a greener organisation. The Group is committed to meeting all relevant legal and regulatory environmental obligations. As such, the Group expects all suppliers to recognise that everyone is responsible for protecting the environment and as such should strive to reduce energy and finite material consumption by using renewable or recyclable materials, wherever possible.
The Group expects all suppliers to integrate environmental considerations including the use of paper, energy and transportation into their operational processes. All suppliers are expected to continually monitor and improve their environmental performance by ensuring that their policies and processes are appropriate for the sector within which they operate.