Ethical Procurement Statement

Ethical Procurement

‘Ethics’ in purchasing and supply management can relate to a wide range of issues from supplier business procedures and practices to bribery and corruption. The common areas relate to ethical behaviour in companies such as fair-trade, ethical trading, ethical sourcing, social accountability, social auditing, corporate social responsibility, corporate citizenship, codes of conduct and reputation assurance.

This statement is based on the following principles and includes information as to how they will be implemented:

1. safe working conditions;
2. non-excessive working hours;
3. employees are paid at least a minimum living wage;
4. training is provided;
5. diversity, equality and good workforce practices are encouraged;
6. elimination of child labour; and
7. elimination of inhumane treatment.

The principles set out in our Sustainability Charter explain the basis from which these policies derive. The minimum requirement expected from suppliers and their supply chains is as follows:

Safe working conditions

• Suppliers will operate appropriate health and safety policies and procedures and agree to the Company’ Health and Safety Policy before commencing work. Responsibility for monitoring and ensuring compliance with these policies and procedures will rest with a senior manager. Responsibility also extends to ensuring that employees have received the necessary training and that they have the necessary health and safety equipment.
• Suppliers will provide comfortable and hygienic working conditions with necessary provisions (such as clean drinking water, washroom facilities etc.). Such provisions also extend where accommodation/housing is provided.

Non-excessive working hours

• Suppliers must comply with national and international laws or industry standards on employee working hours, whichever affords the greater protection. Employees should not be expected to work more than 48 hours a week on a regular basis and on average receive one day off at least every seven days.
• Overtime should be voluntary and not demanded on a regular basis and where required it should be reimbursed at an appropriate rate and not exceed 12 hours in any week.
• Suppliers should provide clear, easily understood disciplinary, grievance and appeal procedures; these must be lawful and appropriate. Suppliers must ensure that they do not deprive their employees of their legal or contractual rights.

Employees are paid at least the minimum living wage

• Suppliers delivering contracts are requested to pay employees at least the Living Wage for that area, demonstrate it and this forms part of the contract.
• Suppliers should provide their employees with easy to read contracts of employment.
• Any deductions must not be made unless in accordance with relevant law or agreed with the employee, and without duress.

Training is provided

• Suppliers are expected to invest in their employees by providing training opportunities which seek to raise skills required for their role.

Non discrimination

• Suppliers are not to practice any discrimination in the hiring, compensation, training, promotion, termination or retirement either directly or indirectly of any employees.

Elimination of child labour

• Suppliers are expected to support the elimination of child labour both directly and indirectly through its supply chains.
• Suppliers shall provide for any children found to be performing child labour to attend and remain in quality education until no longer a child.
• Suppliers shall ensure that no children or young persons are employed at night or in hazardous conditions as defined by the International Labour Organisation.

Elimination of inhumane treatment

• Suppliers must prohibit physical abuse or coercion, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation.

Modern Slavery Act 2015

• The Act is designed to combat modern slavery in the UK and consolidates previous offences relating to trafficking and slavery.
• In conformance with our own Modern Slavery Policy, procurement must consider modern slavery in its supply chain and suppliers must demonstrate an ethical commitment to the eradication of slavery (modern or otherwise) of any type in its supply chain.
• Suppliers bidding for contracts are requested to disclose whether the Modern Slavery Act 2015 is applicable in terms of compliance with annual reporting.
• If applicable, Modern Slavery statements are checked and logged on the contracts register.

Technical specifications and standards

Where relevant to the contract, the Company will use technical specifications and standards to integrate ethical considerations into procurement, such as standards for IT systems to ensure that they are accessible to people with disabilities and interoperable with software and hardware intended for disabled users.

The specification must be relevant to the requirement and must not discriminate against other products or providers from other member states, nor must it restrict competition. Unnecessary use of these principles may place an undue burden on small businesses and other organisations, which might have a disproportionate impact on their ability to compete and therefore be unlawful. In all cases, contracting authorities must be prepared to consider equivalent standards from suppliers from other countries (with different national standards) that meet the underlying requirement. The onus is on the supplier to prove that the solution being offered meets the requirements.

Sustainable and Responsible Procurement

Sustainable procurement is “a process whereby organisations meet their needs for goods, services, works and utilities in a way that achieves value for money on a whole life basis in terms of generating benefits not only to the organisation, but also to society and the economy, whilst minimising damage to the environment” (Department for Environment, Food and Rural Affairs, 2006).

The Company recognises that it has a duty to use every opportunity to support wider social, economic and environmental objectives, in ways that offer real long term benefits and reduce negative impacts on environmental and social wellbeing.

Sustainable procurement is one of the most tangible, visible and simple ways in which the Company can have a positive influence and work towards its vision and the Climate Change Mitigation Strategy.

Buying ‘green’ not only contributes to improving the Company’s environmental performance, but also drives greater sustainability and innovation within the market place. There can be significant cost savings as modern green products are in many cases more energy efficient and cost less on a ‘whole life cycle cost basis’. It may take time to realise these benefits as buying green currently can incur additional costs.

The Company is committed to managing its supply chain so in particular looks to:

• Reduce the consumption of scarce natural resources, including fossil fuels, water and tropical timber
• Reduce the emission of greenhouse gases and other environmental pollutants
• Reduce packaging at source
• Reduce residual waste
• Reduce landscape degradation and impact upon wildlife habitat
• Reduce traffic congestion
• Reduce workforce exploitation

Procurement will continue to show its commitment to embedding sustainable development considerations into procurement decisions. This means minimising negative impacts of the supply chain and the product/service, maximising social benefits and buying resource-efficient products. Furthermore, procurement recognises that, as an organisation spending money on goods, works and services, it has a duty to investigate environmentally acceptable alternatives and wherever practicable, purchase products and services that have minimal impact on the environment.

The Company will particularly look at the energy efficiency rating of all equipment and buildings, as part of its purchasing decisions. When seeking tenders for the design and construction of any new Company building, it will expect to see designs that meet best practice in the context of current building regulations.

The Company will look to work with its partners and stakeholders to share good practice in relation to sustainable procurement wherever possible.

Procurement will look to adopt mechanisms and indicators for improving, monitoring and reviewing the environmental and sustainable performance related to procurement.