Baringa Supplier Code of Conduct

• Prospective Suppliers shall keep all pre-contract data, negotiations, and tender progress strictly confidential and, where requested by Baringa, enter into a more detailed non-disclosure agreement on agreed terms.
• Prior to entering into any contract, Baringa may carry out due diligence on each prospective Supplier in order to comply with relevant law and to assess the suitability of the prospective Supplier to meet Baringa’s business requirements. Prospective Suppliers shall cooperate fully and promptly with such due diligence enquiries.
• All activity between Baringa and prospective Suppliers will be conducted with integrity. Contracts will be awarded based on merit and at the discretion of Baringa. Hospitality or other inducements intended to encourage or reward a positive outcome for the prospective Supplier must not be offered to Baringa’s staff members. The acceptance of any such inducements (e.g. gifts or hospitality) by our staff members during a competitive tender or negotiation phase is strictly prohibited.

1.2 General Requirements for Current Suppliers

• Where Baringa enters into a contract with a Supplier, the relationship will be governed by agreed terms and conditions. In addition, the Supplier shall comply with the principles contained in this Supplier Code of Conduct and all laws applicable to the Supplier.
• As part of Supplier management, Baringa may carry out due diligence on each Supplier in order to ensure compliance with relevant law and to ensure the Supplier continues to meet Baringa’s business requirements. Suppliers shall cooperate fully and promptly with such due diligence enquiries.
• It is recommended that each Supplier’s policies and procedures are regularly reviewed to ensure that changes in regulations, technology, and industry best practice are captured, as well as changes within each Supplier’s organisation. Regular review will ensure that sound governance is instilled within each Supplier’s organisation which will, in turn, demonstrate continuous improvement.

1.3 Priority of Standards and Updates

• Competing standards shall be addressed as follows:

If there is a conflict between any applicable laws or regulations, the provisions of an agreement with Baringa and the provisions of this Supplier Code of Conduct, the Supplier shall meet the most stringent standard.

• Baringa has the right to modify this Supplier Code of Conduct from time to time and the modified Code will be available to Supplier on Baringa’s website.

1.4 Supplier Employment & Supply Chain Ethics

• Suppliers shall respect the human rights of their employees, other personnel and local communities and shall comply with all relevant law pertaining to human rights.
• Suppliers shall take appropriate steps to identify and eradicate modern slavery, in all its forms, including slavery, servitude, forced and compulsory labour and human trafficking, whether of adults or children, all forms of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.
• Baringa is committed to ensuring there is transparency in our approach to tackling modern slavery throughout our supply chains, consistent with our legal disclosure obligations worldwide. We expect the same commitment from all our Suppliers and we expect that our Suppliers will hold their own suppliers to the same high standards.
• Suppliers shall implement appropriate due diligence practices and provide training their own staff to identify the risk of and/or actual instances of modern slavery.
• 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.
• Wages and remuneration: The Supplier must compensate all workers with wages, including overtime premiums, and benefits that at a minimum meet the higher of:

• the minimum wage and benefits established by applicable law;
• collective agreements;
• industry standards; and
• an amount sufficient to cover basic living requirements.

• We require our Suppliers to be committed to a policy of equality opportunity under which no job applicant, staff member or other individual is discriminated against and less fairly treated because of gender, marital status, race (including colour, castes, nationality or ethnic origin), disability, religion, age, sexual orientation, union membership or political affiliation. All Suppliers shall ensure that they apply the same policy of equality of opportunity including in relation to recruitment, compensation, access to training, promotion and termination of employment.
• All terms and conditions of employment must be made clear to the Supplier workforce in a manner which is easily understood by that workforce.
• Suppliers must provide workers with clear, fair and uniformly applied disciplinary practices and grievance procedures.
• Suppliers shall provide sufficient evidence, promptly upon request by Baringa, that they have implemented appropriate procedures to manage all labour related issues within their supply chain to ensure that they comply with relevant law and this Supplier Code of Conduct.
• Suppliers shall demonstrate, through the transparency of their supply chain that people are dealt with ethically and lawfully, and that goods are traded fairly and meet the environmental aims detailed in this Supplier Code of Conduct.

1.5 Community and Supplier Diversity

• We expect Suppliers to understand how their activities impact their local area and wider community, and we encourage them to make positive contributions and investments. For example, providing appropriate local employment opportunities, workforce volunteering and charity activities. We expect our Suppliers to minimise disruption to communities. We aim to provide small and local businesses, minority ethnic, women owned and diverse business enterprises, with an equal opportunity to participate in our procurement and sourcing processes. We have developed and implemented processes to ensure these businesses have an opportunity to participate in the procurement process, which will include extending this policy through our supply chain.

1.6 Prevention of Financial Crime

‘Financial Crime’ includes bribery, corruption, money laundering, terrorist financing, tax evasion and the failure to prevent the criminal facilitation of tax evasion.

• Suppliers shall comply with all relevant laws pertaining to Financial Crime and shall not do or omit to do anything which would cause Baringa or any of the Baringa Group entities to be in breach of relevant law.
• Suppliers shall put in place an appropriate policy and procedures which prohibit workers from:
  • the offering, giving, soliciting or receiving of a bribe at any time (including the making of facilitation payments or the bribery of public officials) whether for the benefit of the Supplier or for the benefit of a worker, a member of a worker's family, or a worker’s friends, associates or acquaintances;
  • the use of a gift or hospitality to induce a fraud or other wrongdoing to secure a personal or business benefit;
  • the use of sponsorship or advertising agreements to exercise undue influence; or
  • unapproved or unauthorised charitable donations or political donations of any kind.
• Suppliers shall put in place appropriate policies and procedures which:
  • verify the legitimate origin of goods and services within their supply-chain; and
  • verify the identity and the legitimate nature of the businesses with which the Supplier contracts.

• Suppliers shall adopt or have adopted a tax strategy that demonstrates a willingness to pay the right amount of tax, in the right place, at the right time.
• Unfair business practices: Suppliers shall comply with all applicable competition laws (including but not limited to the Competition Act 1998), including but not limited to those relating to teaming and information sharing with competitors, price fixing and rigging bids.
• Suppliers shall implement mandatory training for staff members, appropriate oversight, regular risk assessments, appropriate due diligence and procedural audits to prevent, identify, detect and eradicate Financial Crime.
• Suppliers shall encourage staff members to report to an appropriate senior manager if they know of or suspect any business activity that is in contravention of the Supplier's own Financial Crime procedures. Suppliers shall implement disciplinary action for any staff member failing to comply with such procedures.
• Suppliers shall make sure that their staff members do not suffer any adverse consequences for making a report under the Financial Crime policies, whistle-blowing or refusing to pay a bribe, even if such refusal may result in the Supplier losing business.
• Suppliers shall keep sufficiently detailed records relating to the identification and prevention of Financial Crime and shall promptly notify Baringa upon becoming aware of any instance or suspected instance of Financial Crime connected to the business relationship between Baringa and the Supplier or which might impact upon Baringa’s reputation.

1.7 Environmental Responsibility

• Suppliers shall comply with all relevant laws pertaining to the environment and shall operate their businesses in an environmentally responsible way.
• Suppliers shall take a proactive approach when working with Baringa towards reducing Baringa’s environmental impact when providing Supplier’s services.
• Suppliers shall:
  • adopt such practices and utilise such systems that minimise the use of resources, e.g. water efficiency, energy efficiency, etc.;
  • ensure that they and their own suppliers use environmentally friendly working practices, tools and equipment, consumables and replacement parts, wherever possible;
  • ensure, where practicable, that all consumables originate from a sustainable or recycled source;
  • ensure there are facilities or arrangements in place, either directly or through their own suppliers, to ensure Baringa can return used packaging for recycling, reuse or environmentally friendly disposal; and
  • ensure that any hazardous or toxic waste produced is properly identified and disposed of by licensed and competent bodies via authorised and/or licensed means.
• Suppliers shall have a written Environmental and Sustainability Policy appropriate to the size and nature of their operation which addresses preventing, mitigating and controlling serious environmental and health impacts from their operations.
• Each Supplier shall carry out annual reviews and audits of its environmental performance and that of its own suppliers, and shall keep a record of all findings and process and procedure improvements or remediation made to reduce any negative environmental impact. Such records shall be provided to Baringa on request.
• Suppliers shall have a process for measuring, recording, reporting their scope 1,2,3 emissions alongside meaningful targets to reduce them.   These targets should be supported by a transition plan or equivalent to demonstrate how those targets will be achieved.  This information will be made available to Baringa upon request.
• Suppliers shall either be in possession of an ISO 14001 accreditation, be demonstrably working towards ISO 14001 accreditation or operating in accordance with the standards of ISO 14001 throughout the contracting period with Baringa.