°ÅÀÖÊÓƵ

We aim for high ethical and environmental standards, within °ÅÀÖÊÓƵ and its subsidiaries (together “°ÅÀÖÊÓƵ”) and throughout our supply chain. Our people and our suppliers are required to operate in an ethical, legally-compliant and professional manner. We require all our Suppliers to commit to our Code of Ethics for Suppliers (“Code”) and to promote the same high standards in their supply chains.

The Code covers commitments against corrupt practices and commitments to ethical and environmental standards. The Code is based on statutory requirements and internationally recognised standards set out in the UN Universal Declaration of Human Rights and the International Labour Organisation Conventions.

This Code relates to all suppliers to our global operations and forms part of our approach to corporate responsibility in °ÅÀÖÊÓƵ. The Code is mandatory for all suppliers. It exists to protect the relationship between °ÅÀÖÊÓƵ and our suppliers and to help us maintain the high standards we expect.

°ÅÀÖÊÓƵ’s Ethical Standards:

• We work to the highest standards of professional competence and integrity.
• We operate a purchasing process which is fair and equitable to all parties.
• We aim to protect °ÅÀÖÊÓƵ people from exposure to, or the appearance of, participation in collusive or unethical practise.
• We recognise the legitimate interests of all parties and operate our purchasing process in good faith.
• We do not accept or give gifts, hospitality or entertainment which might affect, or which are intended to affect, business judgement. This prohibition applies equally to cash gratuities, goods and services, in kind or at preferential rates.
• °ÅÀÖÊÓƵ people do not accept gifts, hospitality or entertainment outside the scope of their employment which might affect, or which is intended to affect, their judgement on a matter that is within the scope of their employment. This prohibition applies to cash gratuities, personal discounts, gift vouchers, loans, favourable terms on any product or service intended for personal use, share options, to name just a few.
• We only accept hospitality offered in a business context, and this must be offered on a reciprocal basis.
• We do not seek to influence business decisions by offering gifts, hospitality or entertainment or by any other inappropriate means.
• We are committed to complying with all anti-bribery and anti-corruption laws applicable to our business, including the English Bribery Act 2010, the Criminal Finances Act 2017 and the US Foreign Corrupt Practices Act.
• We respect the confidentiality of our suppliers’ information and expect our suppliers to keep confidential all aspects of our relationship.
• We do not conduct any business activity with any company, entity, person or country that is the subject of financial or economic sanctions as determined by the US Office of Foreign Assets Control or any other relevant US, UK or EU agency or department.

Supplier Commitments Against Corrupt Practices:

We expect that your organisation:

• Works and will, in all its dealings with °ÅÀÖÊÓƵ, work to the highest standards of professional competence and integrity;
• Operates in a fair and equitable manner;
• Aims to protect its people from exposure to, or the appearance of, participation in collusive or unethical practise;
• Recognises the legitimate interests of all parties and, in all its dealings with °ÅÀÖÊÓƵ, acts in good faith;
• Does not accept or give gifts, hospitality or entertainment which might affect, or which is intended to affect, business judgement. This prohibition applies equally to cash gratuities, goods and services, in kind or at preferential rates;
• Shall procure that your people do not accept gifts, hospitality or entertainment outside the scope of their employment which might affect, or which is intended to affect, their judgement on a matter that is within the scope of their employment. This prohibition applies to cash gratuities, personal discounts, gift vouchers, loans, favourable terms on any product or service intended for personal use, share options, to name just a few
• Will only accept hospitality offered in a business context, and only if offered on a reciprocal basis;
• Does not seek to influence business decisions by offering gifts, hospitality or entertainment or by any other inappropriate means
• Does not and will not offer or give any °ÅÀÖÊÓƵ person any personal gift, hospitality or entertainment which might affect, or which is intended to affect, the business judgement of that °ÅÀÖÊÓƵ person. This prohibition applies to cash gratuities, personal discounts, gift vouchers, loans, favourable terms on any product or service intended for personal use, share options, to name just a few
• Is committed to complying with all anti-bribery and anti-corruption laws applicable to your business, including, where relevant, the English Bribery Act 2010 and the US Foreign Corrupt Practices Act; and
• Respects the confidentiality of our information and keeps confidential all aspects of our relationship.

Supplier Commitments to Ethical Standards:

i. Compliance with all laws:

As a supplier or potential supplier to °ÅÀÖÊÓƵ , we expect you to comply with all national, European Union and International laws and regulations in relation to ethical employment and trading. We also expect you to comply fully with the Modern Slavery Act.

ii. Exploitative child labour is eliminated:

We believe giving young people opportunities in the working environment is crucial for their development, and would not wish to limit this; however, we believe it must be done subject to national laws on the employment of minors and in any event in a responsible way.

We expect that your organisation:

• Employs no person below the minimum legal age for employment; 
• Does not employ any young persons (under 18 years) at night or for any hazardous work; 
• Will make the best interests of the young person your primary consideration where a young person of less than 18 years is employed, and will ensure the employment does not adversely harm the young person’s education, health or physical, mental, spiritual, moral or social development; and 
• Supports and develops policies and programmes that assist any child found to be performing child labour to enable the child to remain in education until no longer a child.

iii. Employment is freely chosen

We expect that your organisation:

Does not use forced, bonded or compulsory labour and workers are able to leave their employment after reasonable notice has been served; and does not require workers to lodge deposits of money to secure their position. You must also comply fully with the Modern Slavery Act.

iv. No discrimination is practised

• You must ensure that all workers are treated fairly and with dignity and respect 
• You must ensure that no worker receives less favourable treatment in respect of their employment on the grounds of race, gender, religion or belief, any disability, marital status, national origin, sexual orientation, age or the fact that they are a part time or fixed term worker, or is disadvantaged by conditions or requirements which cannot be shown to be justifiable

These commitments apply to recruitment of persons from outside the workplace and the treatment of contract workers.

v. Freedom of association

• All workers must be free to join, or not to join trade unions or similar external representative organisations 
• All workers must be informed and consulted in accordance with national laws

vi. Working conditions are healthy and safe

We expect your organisation to:

• Provide a healthy and safe working environment for all workers in accordance with international standards and national laws
• Provide access to clean toilet facilities, drinkable water and, if applicable sanitary facilities for food storage 
• Provide a work environment for all workers that is free from health and safety risks as far as is reasonably practical
• Identify hazards at the earliest opportunity and the most effective, preventative action implemented immediately; and 
• Provide the appropriate level of health and safety information, instruction, training and supervision to all workers as and when required to minimise all risks

vii. Appropriate wages are paid

We expect you to:

• Ensure all workers receive written understandable information on their employment conditions prior to entering employment and the particulars of their wages for the pay period concerned each time that they are paid 
• Ensure that wages paid for a standard working week meet or exceed national legal standards; and 
• Prohibit the deductions from wages as a disciplinary measure.

viii. Working hours must not be excessive:

• Standard working hours shall comply with national laws and not be excessive.

ix. Regular employment entitlements

• To every extent possible, we expect you to ensure that any work undertaken is performed on the basis of a recognised employment relationship established through national law and practice 
• We expect you to meet your obligations to employees under labour or social security laws, and regulations arising from the regular employment relationship should not be avoided. Examples include the abuse of labour-only contracting or sub-contracting, excessive repetition in the use of fixed term contracts where there is no intent to provide regular employment

x. Respect for the individual

We expect you to treat your workers with respect and dignity. Physical or verbal abuse or harassment on the grounds of race, gender, religion or belief, disability, marital status, national origin or age and any threats or other forms of intimidation must be prohibited.

Supplier Commitments to Environmental Standards:

Compliance with all environmental laws:

As a supplier or potential supplier to °ÅÀÖÊÓƵ, we expect you to comply with all national, European Union or International laws in relation to the environment.

Environmental Efficiency:

We are committed to proactively managing and reducing the impact of our business on both the local and global environment and to increasing its environmental sustainability.

We expect you to have in place and apply policies and processes to continuously identify and act on opportunities to:

• Reduce your business’ resource consumption including:
• Water
• Energy (gas, electricity and solid fuels)
• Office materials such as paper, toner cartridges, plastic cups and containers, drink cans, fluorescent tubes
• Any other finite raw materials applicable to your business
• Minimise the waste generated by your business and seek to reduce, recover or recycle waste generated by your business
• Where waste from your business is disposed of to seek and use an environmentally sound disposal option; and 
• °ÅÀÖÊÓƵ expects our key production partners to have ISO 14001 certification or be actively working towards this international environmental standard.

Monitoring and Compliance

• This Code is a mandatory requirement for working with °ÅÀÖÊÓƵ . From time to time °ÅÀÖÊÓƵ may conduct ad hoc assessments to ensure the Code is being upheld. 
• We expect our suppliers to provide their people with adequate training and guidelines and to implement the recognised standards reflected in this Code and to have a process in place to ensure the standards are upheld. 
• We expect our production partners to provide environmental data regarding their operations and they will be encouraged to improve if there are any areas of poor performance. 
• If any supplier that falls below the recognised standards and does not adhere to this Code, °ÅÀÖÊÓƵ may work collaboratively with them to achieve these standards where appropriate. 
• If a supplier persistently fails to take corrective action within agreed timescales, thereby failing to show a real commitment to this Code, °ÅÀÖÊÓƵ reserves the right to terminate °ÅÀÖÊÓƵ’s contract with that supplier by giving seven (7) days written notice. 
• If a supplier fails to meet any of the supplier commitments against corrupt practices, °ÅÀÖÊÓƵ reserves the right to terminate °ÅÀÖÊÓƵ’s contracts with that supplier immediately by giving written notice.