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 expects suppliers to have robust management information systems and processes to ensure that they are able to appropriately manage and mitigate the relevant risks within their organisation.
The Group expects vendors to provide a safe, healthy, and sanitary working environment and comply with UK health and safety laws and any other relevant laws where it operates.
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. By acquiescing to this Code, vendors are expected to comply with all applicable relevant laws and regulations.
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 reserves its right to modify the Code from time to time.
The Group’s culture when engaging with third party suppliers is driven by its ESG strategic commitment to encourage and support its value and supply chain with their transition to an ESG strategy that aligns to the Group’s ambitions. The Group’s ESG strategic commitments are as follows:
Net Zero commitment: Net Zero across our operational emissions by 2030 and our total emissions by 2050.
Customers: The Group’s approach will be appropriately inclusive for our customer base, ensuring that the social mobility of our customer base is not compromised through our products or decisions.
Colleagues: We will retain, recruit and train the best talent, enabling all employees to maximise their ambition and seek to embed a diverse, inclusive and equitable culture.
Communities: A strategic and coordinated program will be defined and delivered, supporting our communities and wider social economic environment, through collaboration, partnerships and volunteering.
Supply chain: We will encourage and support our value and supply chain with their transition to an ESG strategy that aligns to the Group’s ambitions.
The Group’s culture is also guided 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 adheres to the International Labour Organisation Fundamental Conventions. The Group also respects freedom of association and the rights of employees to be represented by trade unions or work councils. 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 health and safety laws, 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 on agreed contractual terms 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 does not engage individuals directly on zero hours contracts and is supportive of suppliers who adopt a similar stance.
The Group endorses the UN Declaration of Human Rights and supports the UN Guiding Principles of Business and Human Rights.
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.Vendors shall comply with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes from time to time in force including but not limited to the Modern Slavery Act.
The Group is formally accredited as a UK living wage employer and expects regular third party suppliers to ensure that their employees are paid the relevant UK national living wage.
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 remains cognisant of the effect that structural defects within society can have on individuals reaching their full potential and recognises that everyone starts from a different position. 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 union membership or 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 and promotion 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.
The Group expects suppliers to maintain robust whistleblowing processes but any person concerned about unethical working practices or a breach of this Code may report their concerns on a confidential basis by email to email@example.com.
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. Suppliers shall not take any form of retaliation or discriminatory actions in response to good faith reported breaches.
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
Telephone: 0207 066 9200
Address: Intelligence Department (Ref PIDA) Financial Conduct Authority, 12 Endeavour Square, London
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 expects suppliers to not indulge in unfair business practices or anti-competitive behaviour.
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 tax evasion, 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. The Group expects suppliers to comply with all applicable laws, statutes, codes and regulations relating to the prevention of tax evasion, bribery and corruption (including but not limited to the Bribery Act 2010). Therefore, suppliers must ensure that they have policies in place to stop all types of bribery, corruption and corporate tax evasion that their employees, contractors and suppliers abide by local laws and legislation including but not limited to any sanctions in place.
When processing data on the Group’s behalf, suppliers shall comply with all data protection laws and requirements including the UK GDPR and the Data Protection Act 2018.
Suppliers are expected to have robust security measures in place to safeguard against unauthorised access to their systems and to ensure the confidentiality and integrity of their data and any data processed on the Group’s behalf.
The Group is committed to environmental stewardship and delivering a positive impact on the environment, accelerating the transition to a low carbon economy and achieving Net Zero emissions across our value chain by 2050. We recognise the role we must play in addressing the impacts of climate change.
Our strategy focuses on reducing the carbon impact of our Operations, Financing activities and Supply Chain
What we mean by net zero
Achieving net zero means that we have reduced carbon emissions wherever possible and balanced the remaining emissions with removals. We recognise that this transition will take time, but that action is required now to mitigate the impacts of climate change and align towards a low carbon economy that delivers prosperity for our customers, colleagues, communities and the planet.
Working in collaboration with our valued suppliers we can support the decarbonisation journey.
The following requirements should be taken in the context of a supplier’s own business activities, size and impact. Where minimum requirements are stated these apply to all suppliers.
What OSB Group is doing:
We have committed to achieving net zero in our own operations (scope 1 and 2) by 2030 or sooner.
Working in partnership with our supply chain to reduce carbon emissions.
Making regular, transparent disclosures on how we are progressing toward net zero.
What we expect of suppliers:
Have a clear ambition to reducing their own emissions (initially Scope 1 and 2).
Have an appropriate plan in place or a plan in development that supports OSB Group’s ambition to reducing supply chain emissions.
We would encourage suppliers to:
Robustly measure and publically disclose their emissions related to products and services.
Consider setting and disclosing science-based targets for their most material emissions sources.
What OSB Group is doing:
Operate Environmental Management Systems (EMS) using internationally recognised standards to identify and manage environmental impacts.
Reducing the consumption of resources and materials and using them responsibly and efficiently where unavoidable.
managing the waste created through business operations and applying the waste hierarchy principles of reduce, reuse and recycle.
promoting positive environmental behaviours by all employees.
Minimum requirements of suppliers:
Comply with all applicable environmental legislation and regulations.
A written environmental policy must be in place that is relevant to the size of the supplier and its business activities.
A management system should be in place to effectively implement the requirements of the Policy and address significant aspects and impacts of the goods and/or services that re provided.
The management system will include:
the identification of environmental impacts.
management programmes to address significant impacts.
procedures to support the ongoing management of risk and improving of performance.