SThree plc, including all its subsidiary and associated companies (“SThree, us, we, our”) is committed to conducting its business with integrity when sourcing goods and services responsibly. The safety and wellbeing of Workers in the countries where we do business are of paramount importance to us. This Supplier Code of Conduct (“Code”), reflects these core principles and sets out the minimum standards that must be met by any Suppliers to our business.
Who the Code applies to
This Code applies to all external Suppliers that provide goods and services to SThree.
Our description of “Supplier” includes supplier parties, subcontractors, service providers, professional service providers, consultants, intermediaries and agents, together with their Representatives. “Representatives” means a Supplier’s own suppliers, vendors, agents and subcontractors who are involved in SThree's supply chain.
We require all Suppliers to comply with the Code and to ensure that their Representatives, as well as employees, contractors and temporary workers (“Workers”) of both the Supplier and those Representatives, are aware of the Code and comply with it.
2.1 Compliance with laws
In addition to complying with the standards set out in this Code, when carrying out an agreement with an SThree company, the Supplier shall comply with all applicable laws and regulations of the country where the SThree company is based (and if applicable, the laws and regulations of any other jurisdiction where the Supplier or its Representatives operate), including the laws and regulations relating to issues addressed in this Code. This Code applies to activities in the locations where Suppliers’ goods are produced, where any related services are performed, and where the goods enter the supply chain.
2.2 Application of differing standards
(a) If there is a conflict between any applicable laws or regulations, the provisions of an agreement with SThree and the provisions of this Code, the Supplier shall meet the most stringent standard.
(b) If there is a conflict between the provisions of an agreement with SThree and the provisions of this Code, the Supplier shall meet the standard as set out in the agreement.
2.3 Bribery and corruption
The Supplier shall comply with all applicable laws and regulations relating to the prevention of bribery and corruption. To that end, the Supplier shall not accept, offer, promise, pay, permit or authorise:
(a) bribes, facilitation payments, kickbacks or illegal political contributions;
(b) money, goods, services, entertainment, employment, contracts or other things of value, in order to obtain or retain improper advantage; or
(c) any other unlawful or improper payments or benefits.
2.4 Unfair business practices
The Supplier shall comply with all applicable competition laws, in addition to but not limited to those relating to teaming and information sharing with competitors, price fixing and rigging bids.
2.5 Conflicts of interest
Suppliers must disclose to SThree any situation that may appear to be a conflict of interest. In particular, a Supplier shall notify SThree if it becomes aware that any SThree Worker (or one of their family members) may have an interest of any kind in the Supplier’s business or any kind of economic ties with Supplier.
2.6 Trade Sanctions
Suppliers shall comply with all applicable laws and regulations relating to trade sanctions. They must not purchase goods or services from, or otherwise engage in trade with, any individuals, entities, organisations or countries that are covered by applicable trade sanctions.
Suppliers shall meet their tax obligations, shall not participate in or facilitate unlawful tax evasion or fraud and shall not become involved in any arrangements that might result in their Workers not being taxed appropriately.
We expect Suppliers to take the actions and comply with the standards set out below.
(a) To review and comply with this Code and all required SThree policies;
(b) To seek guidance from their appropriate SThree Procurement counterpart if unclear on any aspect of this Code e.g. offering gifts;
(c) To provide best value, competitive pricing for goods and services that fully meet our requirements;
(d) To uphold their commitments, proactively communicate to resolve any issues and respond positively to help us meet changing needs;
(e) To have management systems in place for delivering compliance within their own operations and those of their Representatives;
(f) To comply with all relevant International Labour Organization (“ILO”) conventions;
(g) To communicate their expectations for compliance on all the issues raised within this Code to all relevant Workers and Representatives;
(h) To provide evidence of the implementation of these requirements by those acting on their behalf and other relevant independent third parties; and
(i) To demonstrate continuous improvement in their approach to sustainable and responsible procurement.
With regard to prospective Representatives, the Supplier shall carry out appropriate due diligence on prospective Representatives that will form part of SThree’s upstream supply chain. At a minimum, the due diligence must include the following:
(a) investigations into prospective Representatives’ stance, public statements and actions on human rights, treatment of Workers, bribery, ethical behaviour and environmental outlook;
(b) risk assessments for countries from which materials, components or finished goods are sourced; and
(c) the prospective Representative’s ability to meet the requirements and principles that are covered in this Code.
In its dealings with Representatives, the Supplier shall:
(a) ensure that agreements with Representatives include provisions that require the Representatives to comply with applicable provisions of this Code, having due regard to the risk profile of the transaction, the Representative’s ability to comply with those provisions and the consequences where the Representative fails to meet those requirements; and
(b) ensure that it has measures to monitor that those Representatives are complying with those compliance-related provisions and that it has systems in place to address any deficiencies or breaches of those requirements.
SThree seeks to ensure that the working conditions at Suppliers meet the standards of the ILO and the Universal Declaration of Human Rights (UDHR). We expect Suppliers to adopt and demonstrate the following standards:
5.1 Slavery, human trafficking and child labour
The Supplier shall comply with all applicable anti-slavery and human trafficking laws and regulations from time to time in force in any part of its supply chain. This includes, but is not limited to, not supporting or engaging or requiring any forced labour, the use of child labour, bonded labour, indentured labour and prison labour.
Suppliers shall treat each Worker with dignity and respect, employ all Workers on a voluntary basis free from any threat of violence, threats of criminal penalty, harassment or abuse or other form of intimidation and restrictions on freedom of movement.
Suppliers shall comply with local minimum working age laws and regulations and not employ child labour.
5.2 Minimum wages and working hours
The Supplier must compensate all Workers with wages, including overtime premiums, and benefits that at a minimum meet the higher of:
(a) the minimum wage and benefits established by applicable law;
(b) collective agreements;
(c) industry standards; and
(d) an amount sufficient to cover basic living requirements.
Working hours should comply with national laws or industry standards and relevant ILO conventions.
Suppliers' Workers should not be expected to work more than 48 hours per week on a regular basis.
5.3 Employment practices
(a) The Supplier shall only employ Workers who are legally authorized to work in their facilities and are responsible for validating Workers’ eligibility to work through appropriate documentation. All Workers shall be free to leave work or terminate their employment upon reasonable notice.
(b) Written Contract. Suppliers, where reasonably possible, must provide all Workers with a written contract in the appropriate language that includes a description of job duties, benefits, disciplinary procedures, and notice periods. Where the provision of a written contract is not reasonably possible or practical, Suppliers shall provide Workers with a verbal description of the terms of their work engagement.
(c) Complaints Mechanism. The Supplier shall provide all Workers with transparent, fair, accessible and confidential procedures for raising complaints or concerns that result in swift, unbiased and fair resolution of difficulties which may arise as part of their working relationship. Workers will be protected from retaliation for submitting such complaints.
5.4 Equal opportunities
SThree is an equal opportunities employer and Suppliers shall not discriminate in hiring, compensation, training, advancement or promotion, termination, retirement or any employment practice based on race, caste, colour, national origin, gender, gender identity, sexual orientation, religion, age, marital or pregnancy status, disability, union membership or political affiliation or any other characteristic other than the Worker's ability to perform the job subject to any accommodations required or permitted by law.
5.5 Diversity, equity and inclusion
Suppliers should have a working policy of equality for all in the working environment which promotes a diverse workforce composition actively embracing workforce age, gender, race, national or ethnic origin, religion, language, political beliefs, sexual orientation, physical ability and promoting supply chain inclusion throughout their own supply chains.
5.6 Freedom of association and collective bargaining
The Supplier shall respect, and shall not interfere with the right of Workers to decide whether to lawfully associate with groups of their choice, including the right to form or join trade unions and to engage in collective bargaining.
5.7 Working environment
The Supplier shall provide a safe, healthy, and hygienic working environment and comply with all applicable health and safety laws and regulations where it operates. This includes, but is not limited to, implementing general and relevant industry-specific procedures and safeguards to prevent workplace hazards and work-related accidents and injuries. In addition, facilities must be constructed and maintained in accordance with the standards set by applicable laws and regulations.
Suppliers should have appropriate health and safety policies and procedures and be able to demonstrate that they have been implemented in the working environment.
Suppliers should monitor compliance with its health and safety policies and procedures.
Suppliers should provide Workers (at the Supplier's expense) with any necessary health and safety equipment, e.g. gloves, masks, helmets.
Suppliers should identify specific hazards, e.g. substances or equipment, and should implement processes to minimise risk.
Where SThree shares confidential or commercially sensitive information with a Supplier, the Supplier must respect the confidentiality of such information.
The Supplier shall comply with all applicable data protection laws and regulations, to the extent applicable) when processing any personal data on SThree’s behalf.
The Supplier shall have in place appropriate physical and technical security measures to:
(a) protect the integrity and confidentiality of information (including information belonging to or supplied by SThree) held on its systems (which include physical and online or electronic systems); and
(b) ensure that there is no unauthorised access of the information by third parties, including its Representatives.
The Supplier must immediately notify SThree of any security breach or data incident, where SThree’s confidential information, or personal data being processed on SThree’s behalf, may have been compromised, lost or damaged.
Suppliers shall ensure their operations comply with all environmental laws and regulations applicable to their operations worldwide.
In all cases Suppliers should be able to demonstrate environmental policies and management systems sufficient to ensure continuous improvement in environmental performance. Therefore, Suppliers should be able to demonstrate:
(a) documented policies regarding environmental management;
(b) the ability to monitor and review environmental performance;
(c) the degree to which operations are covered by recognised environmental management systems or the organisations intentions towards such accreditation;
(d) the awareness of potential environmental risks inherent in their production, service or sourcing activities;
(e) the implementation of mechanisms and processes in place to mitigate or minimise potential environmental risks; and
(f) the degree to which products and services have been designed with environmental considerations in mind.
As a minimum, the environmental management system should include and address the following:
(a) maximising the use of recyclable and renewable materials, including energy, where possible;
(b) making practical efforts to minimise waste and dispose of it in a safe, efficient, and environmentally responsible manner;
(c) steps to continuously improve environmental performance, reduce pollution, emissions and waste;
(d) measures to reduce the use of all raw materials, energy and supplies; and
(e) raising awareness and training Workers in environmental matters.
Suppliers should be able to demonstrate the existence of processes and procedures to implement appropriate staff guidelines and codes of conduct.
As a minimum, Suppliers should ensure that management systems and practices are in place to ensure the prevention of:
(a) money laundering;
(b) insider trading;
(c) conflicts of interest;
(d) fraud, bribery and corruption and other improper payments or gifts; and
(e) unauthorised access to personal and business information.
Suppliers need to ensure they are operating an ethical supply chain, from source to consumption
Suppliers should regularly review their operations to ensure that they continue to comply with this Code. If a Supplier discovers that it is failing to comply with any of the Codes’ standards, it should inform SThree immediately through its main SThree contact.
If SThree has concerns about a Supplier’s level of compliance with this Code, SThree may request information about, or ask to audit, the Supplier’s policies and processes. Alternatively, SThree may ask the Supplier to carry out a self-assessment of its compliance with the Code.
In the event that a Supplier is materially or consistently failing to comply with the standards set out in this Code, SThree reserves the right to terminate its relationship with that Supplier.
This Code is effective from 26th May 2022 and applies to all Suppliers who are working with, or start working with, SThree on or after that date.
The SThree Group Procurement Director is responsible for reviewing this Code periodically to ensure that it meets our requirements and reflects best practice. We may update the Code from time to time to take account of changes in laws or best practice. We will publish any updated version of this Code on our website.
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