Supplier Code of Conduct

Introduction

• At Saffery, we recognise our success as an organisation comes in part from developing strong business partnerships with our Suppliers. We treat our Suppliers fairly and expect them to operate with integrity in their relations with us.
• The purpose of this Code is to communicate the core principles that we expect all Suppliers to adhere to in their operations. These principles reflect our commitment to act as a responsible business (A responsible business – Saffery) and support our compliance with our own Code of Conduct (Saffery-Code-of-conduct.pdf) which sets out the shared values, principles and behaviours that underpin everything that we do as a Firm.

Scope

• In this Supplier Code of Conduct:
  • “Code” refers to this Supplier Code of Conduct.
  • “Supplier” refers to officers, employees, contractors, subcontractors, and agents of any Supplier, vendor, third party, or provider providing goods and/or services to the Firm. It includes any sub-suppliers of Suppliers and Suppliers should make sub-suppliers aware of the Code where relevant.
  • “We”, “our” or “Firm” refers to Saffery LLP and its affiliate entities.

Applicability

• This Code sets out the principles that underpin the Firm’s operations and the ethical standards we expect Suppliers to adhere to. The Code is not intended to replace, supercede or conflict with any express contractual obligations, or any applicable legal and/or regulatory requirements.  However, it is expected that all Suppliers working with the Firm will comply with the spirit of the Code across all markets and jurisdictions within which that Supplier operates.
• In assessing whether to commence or continue working with a Supplier, we will consider the Supplier’s compliance with the principles set out in this Code. Supplier should respond to any due diligence requests truthfully and comprehensively.
• The Code is a statement of principles. We acknowledged that it cannot address every circumstance and the Code is not intended as substitute to a Supplier’s responsibility to apply good judgement in managing its operations.

General Requirements

• Legal compliance
  • Supplier will comply with all applicable laws, rules and regulations in the jurisdictions where it carries out business activities.
• Sub-Suppliers
  • Supplier will undertake appropriate due diligence into all parties in its supply chain to ensure that such parties comply with the principles set out in the Code and will ensure it has appropriate controls in place requiring ongoing compliance.
• Business Continuity Plan
  • Supplier will have in place a business continuity plan in accordance with good business practice designed to minimise the impact on its clients (including the Firm) of any incident that affects Supplier’s business.

Ethical Matters

• Anti-corruption
  • Supplier must not engage in or tolerate any form of corruption, bribery, extortion or embezzlement. Supplier must not offer or accept any benefits or other means to obtain any undue or improper advantage. Such improper benefits may comprise cash, non-monetary gifts, inducements or services and amenities of any other nature.
  • Under the UK Bribery Act 2010, the Firm may be liable if it fails to prevent an act of bribery committed with the intent to obtain or retain business or gain an advantage for the commercial organisation. The Firm might also be liable if its associated persons (which includes Suppliers) commit any act of bribery whilst performing services for the Firm.  It is a defence to any such allegations if the parties have reasonable procedures in place to prevent acts of bribery arising. Suppliers must on an ongoing basis consider what procedures it should have in place in this regard.
• Conflict of interest
  • Supplier will not allow conflict of interest, bias or inappropriate influence to override its professional judgement so to how it should act. Supplier will avoid conflicts of interest that may compromise the Supplier’s integrity or credibility. Supplier will disclose to the Firm whenever a situation arises in which there appears to be a conflict of interest involving or affecting the Firm or its underlying clients.
• Tax Evasion
  • Supplier must not engage in or tolerate any form of criminal tax evasion, whether in the UK or elsewhere.
  • Under the UK Criminal Finances Act 2017, the Firm may be liable if it criminally facilitates tax evasion as part of its operations. The Firm might also be liable if its associated persons (which includes Suppliers) commit criminal tax evasion whilst performing services for the Firm.  It is a defence to any such allegations if the parties have reasonable procedures in place to prevent the facilitation of criminal tax evasion arising. Suppliers must on an ongoing basis consider what procedures it should have in place in this regard.
• Fraud
  • Supplier must not engage in or tolerate any form of fraud, regardless of whether it benefits as a consequence.
  • Under the UK Economic Crime and Corporate Transparency Act 2023, the Firm may be liable if it fails to prevent the commission of a fraud that benefits itself or its clients. The Firm might also be liable if its associated persons (which includes Suppliers) commit such a fraud whilst performing services for the Firm.  It is a defence to any such allegations if the parties have reasonable procedures in place to prevent in relation to the prevention and detection of fraud across their operations.  Suppliers must on an ongoing basis consider what procedures it should have in place in this regard.
• Fair competition
  • Supplier will respect and comply with all applicable competition laws and regulations and not enter into discussions or agreements with competitors concerning pricing, market sharing or other similar activities.
• Environmental
  • Supplier will operate in full compliance with applicable environmental legislation. Supplier is expected to have effective environment management policies and procedures in place, aimed to continuously monitor and improve Supplier´s environmental standards and performance.
  • Supplier will manage its environmental impacts responsibly and with a view to supporting efforts to reduce greenhouse gas emissions associated with its operations, products, and services.
• Confidentiality and Data Protection
  • Supplier will have in place appropriate measures to:
    • protect the integrity and confidentiality of information (including information belonging to or supplied by us) held on its systems (which include physical and online or electronic systems); and
    • ensure that there is no unauthorised access of the information by third parties, including Supplier’s workers.
  • Supplier will comply with all data protection laws and requirements (including the UK General Data Protection Regulations and the Data Protection Act 2018) when processing any personal data on the Firm’s behalf.
• Responsible and ethical usage of Artificial Intelligence (AI)
  • Supplier will ensure that any AI systems used in their delivery of goods and services comply with all applicable laws and regulations. The Firm is required to ensure that the usage of any AI systems employed in the delivery of services to its clients is transparent and data relating to its clients is not used for any purpose other than delivery of services (use of data relating to the Firm’s clients must not be used to train or develop any AI systems).
  • Supplier must ensure that governance controls are in place to ensure that AI systems are appropriately monitored.

Human Rights and Labour Rights

We recognise that human rights (as articulated by the Universal Declaration of Human Rights) are a basic right that every individual should enjoy.  Supplier will maintain working rights and conditions for all their workers in accordance with internationally proclaimed human rights and standards.

Requirements set out in the Code will apply to all the Supplier’s workers including temporary, migrant, student and contract workers as well as direct employees.

• Child labour and authorized minors
  • Supplier must adhere to local laws in relation to the minimum working age of workers and will ensure that age-appropriate working conditions, hours of work and wage are provided for workers who are minors (being worked under the age of 18 years).
• Modern slavery and human trafficking
  • Supplier will not participate in, or benefit from any form of forced labour, including bonded labour, involuntary prison labour, slavery, servitude, trafficking or work performed under the menace of a penalty or coercion. All work, including overtime work, will be non-mandatory and workers will be free to leave work or terminate their employment with reasonable notice.
  • Supplier will not require that workers hand over government-issued identification, passports or work permits to be kept by Supplier as a condition of employment.
• Health and safety of employees
  • Supplier will provide a safe and healthy working environment in accordance with applicable local law as a minimum.
• Non-discrimination
  • We recognise and respect diversity and cultural differences. Illegitimate grounds for discrimination include but are not limited to: race, colour, gender, age, language, property, nationality or national origin, religion, ethnic or social origin, caste, economic grounds, disability, pregnancy, belonging to an indigenous people, trade union affiliation, political opinion, sexual orientation.
  • Supplier’s workers will be treated strictly according to their abilities and qualifications in any employment decisions, including but not limited to hiring, advancement, compensation, benefits, training, layoffs and termination.
• Harassment, harsh or inhumane treatment
  • Supplier will ensure that no worker is subject physical, sexual, psychological or verbal harassment, intimidation or abuse.
• Disciplinary practices
  • Disciplinary actions by Supplier will be conducted in a manner to ensure the fair and humane treatment of workers.
• Working hours
  • We recognise the need for a healthy balance between work and free time. Supplier’s workers will not, on a regularly scheduled basis, be required to work a standard workweek of more than 48 hours per week or a total workweek of more than 60 hours (including overtime). Except in extraordinary business circumstances, all workers will be entitled to at least one day off in every seven-day period.
• Compensation and benefits
  • Supplier will ensure that, wages, including overtime compensation and benefits, equal or exceed the minimum level required by applicable law.
• Freedom of association and collective bargaining
  • Supplier’s workers will be free to exercise their legal rights to form, join, or refrain from joining organizations representing their interests as employees. No worker will be subject to intimidation or harassment in his or her peaceful exercise of these rights.

Monitoring and compliance

• While this Code does not have contractual force, it is important for us to work with Suppliers who comply with the principles set out here. With prior notice, we may require Suppliers to cooperate with us in allowing audits and/or completing surveys in relation to their compliance with the Code.
• Suppliers are requested to report to us any activity they witness or suspect whether committed by of our staff or a third party which is in breach of this Code. Please contact [email protected].

Variations to the Code

• We reserve the right to modify the Code from time to time. We acknowledge that any changes we make to the Code should be commercial reasonable and for the purpose of ensuring the Code continues to uphold compliance with high ethical, societal and environmental standards.
• Updated versions of the Code will be published on the Firm’s website and Supplier acknowledges that it should check this website regularly.