Supplier Code of Conduct

Odgers Berndtson’s global business is committed to the highest standards of social and environmental responsibility. We expect our suppliers and business partners to share our aim to promote lawful, professional, fair practices that respects human rights, have the highest business ethics and sustainability, and to support and contribute to our aim of maintaining and improving our environmental and social commitments. 

We recognise both the opportunity and responsibility we have, in partnership with our suppliers, to take a lead in addressing pressing global issues. Therefore, environmental, social and economic considerations are embedded in our decision-making. This applies to the suppliers we use as well. We believe sustainable procurement will help us achieve sustainable growth by managing risk, maximising efficiency and driving value. 

This Supplier Standards of Conduct exists to promote and ensure safe and fair working conditions and the responsible management of environmental and social issues in our supply chain. 

We require agreement with these “Standards” from all those involved in our supply chain. The Standards describes our expectations of how all our suppliers conduct their business and applies to all suppliers providing products or services to us. All suppliers are expected to act in accordance with the Standards, including aligning policies, practices and guidelines and communicating and enforcing the Standards throughout their organisation and across their supply chain. 

We expect our suppliers to operate in accordance with all applicable laws and regulations. This includes those respecting individuals' human rights, and mindful of environmental and safety impacts of products and services. When differences arise between standards set out in the Standards and legal or regulatory requirements, the stricter standard applies, in compliance with applicable law or regulation. 

OUR VALUES 

We're committed to adhering to the following core values in all our dealings with our clients, our people and our communities: 

• Excellence; 
• Respect; 
• Connected; 
• Integrity. 

We expect all our suppliers to support these values through the products and services they provide to us. 

HUMAN RIGHTS 

We recognise our responsibility to protect human rights. We expect our business partners and suppliers to respect human rights and to have in place policies and processes to meet their responsibility to protect and respect human rights that apply to all workers, suppliers, and their supply chains and to comply with all relevant legislation, regulations and directives in countries where they operate. 

Suppliers sourcing goods or services in geographies with high risk of human rights violations should notify us immediately and provide information on the steps the supplier has taken to ensure risk of violation of human rights in relation to this purchasing activity are being fully mitigated. Countries with high risk of human rights violations can be identified via public sources. 

We have obligations under the Modern Slavery Act 2015 to ensure compliance and we take this responsibility seriously. 

FORCED LABOUR 

Suppliers and business partners will not use or permit their subcontractor to use child, slave, forced or obligatory labour, including prison labour, indentured labour, bonded labour or other forms of forced labour. 

These practices, identified by the International Labour Organization (ILO), include withholding of wages, retention of identity documents, and restriction of movement. For full guidance from the ILO please see: The 8 ILO Fundamental Conventions. 

Suppliers should put into place measures that ensure workers are not exploited by third-party labour providers. 

Additionally, suppliers must not engage in or support human trafficking and are encouraged to implement due diligence measures to ensure that no human trafficking exists in their extended supply chains. Suppliers must also fully comply with requirements of applicable slavery, forced labour and human trafficking laws without limitation. 

Child Labour 

Suppliers and business partners will ensure that no person under the age of 15 or under the age for completion of compulsory education, whichever is higher, is employed. The necessary preventive measures to ensure this include age-verification systems, training for managers, and communicating with sub-contractors and suppliers on child labour issues. Suppliers must also comply with local laws regarding the minimum age of employees and all other applicable child labour laws. 

COMPENSATION 

Our suppliers and business partners must pay workers regularly and on time at least the minimum wage or the appropriate prevailing wage, whichever is higher and comply with all legal requirements on wages. Odgers Berndtson in the UK is a signatory of the Living Wage Foundation. All other types of legally mandated benefits must be provided as required by law, including, as applicable, paid leave, pension, statutory insurance, health benefits, maternity leave, parental leave, family care leave, and childcare benefits. All overtime work must be performed and compensated in accordance with the law and the individual's employment contract or other applicable contract or collective agreement. 

WORKING HOURS 

Our suppliers must ensure that workers are not required to work more than the relevant legal limits on working hours, overtime hours and number of working days per week. All overtime work must be consensual. Workers must be granted and correctly compensated for any types of paid leave or time off to which they are legally entitled under applicable law, which may include holidays, maternity/parental leave, family care leave and sick leave. While it is understood that overtime may be required, suppliers must carry out operations in ways that limit overtime to a level that ensures humane and productive working conditions 

FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING 

Our suppliers and business partners must recognise and respect the right of employees to freedom of association and collective bargaining without interference, discrimination, retaliation or harassment and must meet or exceed relevant requirements of local law. 

HEALTH AND SAFETY 

We are committed to providing our people with a safe and secure working environment that safeguards their health, and promotes physical and mental wellbeing, regardless of where in the world they work. Our suppliers are expected to support our commitments by ensuring they comply with all applicable health and safety laws and regulations in the jurisdictions in which they operate, have the appropriate arrangements in place for managing health and safety, and be able to provide their goods and services safely, without risks to health. 

As a minimum, we expect our suppliers and business partners to: 

• comply with our health and safety requirements while on our premises; including, but not limited to agreed method statements and permit to work arrangements including signatures, time and dates; 
• report all incidents and near misses related to the contract; 
• provide their health and safety policy statement, management arrangements, and insurances on request. 

ENVIRONMENT 

We are fully committed to minimising the environmental footprint of our business operations while contributing globally to the evolving societal goals for sustainable development. We require our contractors, suppliers and service providers to have environmental sustainability commitments and operating standards comparable to our own or at the very least to be working towards achieving them. 

We are signed up to Science Based Targets to reduce our carbon emissions substantially by 2030 and to move to net-zero by 2050.   

We prefer to work with suppliers that have the greatest potential to influence our sustainability performance and to support us in delivering our environmental commitments, including but not limited to: 

• minimising the use of resources such as electricity, gas, water, paper; 
• reducing the carbon footprint associated with our services in line with what science says is necessary to achieve a 1.5°C degree world; 
• diverting all waste generated by our offices away from landfill. 

ETHICAL BUSINESS PRACTICE 

Integrity is vital for a sustainable relationship with suppliers and we will not tolerate corruption or bribery in any form. We expect all suppliers to uphold the highest standards in ethical business practice and comply with requirements of all applicable anti-corruption laws. Our zero-tolerance approach requires all suppliers and business partners to have in place policies, systems and/or procedures to ensure zero tolerance towards, but not limited to, human rights abuses, money laundering, fraud, bribery, tax evasion, conflicts of interest, corruption and other improper payments, benefits gifts or other inducements. 

CONFIDENTIALITY AND INFORMATION SECURITY 

Our suppliers and business partners must have robust cybersecurity processes and controls in place to protect data and confidential information. Suppliers must adopt and maintain processes to provide reasonable protections for personal, proprietary and confidential information, including information that they access, receive or process on behalf of Odgers Berndtson. In addition, suppliers must comply with all applicable privacy/data protection and information security laws and regulations. 

PRIVACY AND DATA PROTECTION 

We expect our suppliers to protect personal information they process on our behalf. Suppliers must adopt and maintain processes to ensure compliance with applicable data protection and privacy laws and provide reasonable protections for personal information, including information that they access, receive or process on our behalf. Suppliers should recognise that unauthorised use and/or disclosure of such information may have severe, legal, reputational and financial consequences  

FACILITATION OF TAX EVASION 

Our suppliers and business partners shall not engage in any activity, practice or conduct which would constitute or facilitate tax evasion (including but not exclusively the UK offences under sections 45(1) and 46(1) of the UK Criminal Finances Act 2017 (Act). 

Our suppliers and business partners must have and maintain in place such policies and procedures as are both reasonable to prevent the facilitation of tax evasion by another person (including without limitation all employees) and to ensure compliance with this clause. 

Suppliers and business partners will ensure the same of any affiliates, retained agents, subcontractors, intermediaries or workers performing services or providing goods to us. 

PHYSICAL SECURITY 

Our suppliers, clients and business partners must comply with our security requirements when working with us and commit to the protection of our people, property, assets and reputation. Visitors on our premises must be escorted as far as reasonably practicable; not enter working floors without authorisation; not take any photography or video without prior written approval; comply with all applicable legislation and relevant regulatory requirements; take responsibility for their personal items; comply with any ad hoc requirements that may be implemented depending on their scope of work. 

INSURANCE 

Our suppliers and business partners must have adequate and relevant insurance including, but not limited to, public and product liability and professional indemnity insurance which is current for the duration of the contract. They must comply with any request to provide proof of insurance or other related information and keep the firm abreast of any material changes. 

SUB-CONTRACTING 

Our suppliers and business partners must seek the our written consent before any sub-contracting. 

INCLUSIVITY 

Inclusion is in our DNA.  

We expect our suppliers to share the same commitment to being diverse and inclusive, both in their operations and supply chains. 

In return, our suppliers will be treated fairly and equally during the tendering and purchasing process, with decisions made based on clear selection criteria. 

Suppliers should take all steps required to be inclusive in their operations, which include but are not limited to: 

• treating workers with dignity and respect at all times; 
• ensuring that all laws and any applicable discrimination legislation are complied with regarding the fair treatment of people; 
• providing a fair and transparent recruitment and hiring processes; 
• providing a workplace free from discrimination, bullying, harassment or inappropriate behaviour; 
• ensuring that no person experiences disadvantage based on (but not limited to) the following: 
• age, disability, ethnicity, faith, gender, gender identity, marital status, parental status or pregnancy, sexual orientation, social origin or any other underrepresented group; 
• having a stated commitment to being diverse and inclusive and being able to demonstrate active compliance if requested. 

SUMMARY 

These Standards set out our expectations for current and future suppliers. We expect all new and existing suppliers to meet our minimum expectations as noted. 

We encourage suppliers to institute effective management systems that use the best available techniques and practices to adhere to these Standards and continuously improve their performance. This should include a process for the identification and proactive mitigation of risks associated with compliance to these Standards, as well as a process for ongoing monitoring and review of risk controls, and prompt and accurate reporting of all incidents. 

Failure by a supplier to comply with these Standards may lead to a review of our relationship or possibly termination of our relationship. We reserve the right to audit our suppliers in accordance with these Standards. 

We are committed to continuously review and updating these Standards. Therefore, this document is subject to modification from time to time. 

The contents of this Standards are additional to and do not in any way affect or prejudice any of Odgers Berndtson’s rights and remedies under the relevant contracts with each supplier, if any. In the event of any non-compliance with the requirements of this Standards or breach of contract, we reserve the right and retain the sole discretion to exercise any rights under this Standards, any relevant contract and/or local laws and regulations. 

The failure or omission to comply with the requirements of these Standards may constitute a breach of contract. In the event of any conflict or ambiguity between any provision of these Standards and the provisions of any relevant contract with any supplier, the provisions of that contract will prevail.