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Supplier Code of Conduct

Introduction

Based on the 10 principles of the UN Global compact, the West Brom has developed its Supplier code of conduct. The West Brom expects its suppliers, sub-contractors, consultants and agents to follow this Code. Respect of these principles is a minimum requirement for Suppliers to the West Brom. The four key principles are:

  1. Human Rights and Employment Practice
    Suppliers must respect basic human rights and conduct business ethically with its employees, customers and sub-contractors.
  2. Environmental Management
    Suppliers must respect the environment in which they operate, minimise environmental pollution and promote good energy use by reducing, reusing and recycling.
  3. Occupational Health and safety
    Suppliers must respect the health and safety of its employees and provide a safe workplace.
  4. Business Ethics
    Suppliers must extend the principle of fair and honest dealings to all parties with whom they do business, including sub-contractors and employees.

New and updated contracts will normally include specific reference to compliance with this Code. Small local suppliers may be provided with some exemption relating to the documentation of procedural aspects of compliance but are expected to comply.

Human Rights and Employment Practice

Suppliers must respect the human rights of their employees and comply with all applicable laws and directives in the countries in which they operate. Suppliers must have in place procedures to ensure that their sub-contractors also respect human and labour rights. Suppliers covered by the Modern Slavery Act must produce annual policy statements regarding this legislation. A summary of requirements follows:

Policy of non-discrimination
Suppliers must treat all employees fairly and not discriminate in its employment practices including access to training, promotion or termination. This includes, but is not limited to, age, sexual orientation, marital status, political affiliation, disability, ethnicity, physical attributes, faith, gender identity or nationality.

Respect the right of Freedom of Association
Suppliers must not hinder the right of workers to legally organise and join associations such as labour unions. This includes respecting the right to lawfully stage a protest and participate in a workers’ councils.

Employee Management and Right of Appeal
Suppliers should have transparent disciplinary and grievance procedures that include provisions prohibiting mental, physical or verbal abuse.

Prohibition of Slavery and Human Trafficking
Suppliers should act ethically and with integrity in all business relationships to implement and enforce effective systems and controls to ensure slavery and human trafficking is not taking place anywhere in its supply chain.

Prohibition of forced labour
Suppliers must employ all staff on a voluntary basis and allow workers both the choice and ability to leave their employment.

Prohibition of the use of child labour
The employment of young workers must respect national laws or regulations, and comply with relevant International Labour Organization (ILO) standards.

Appropriate remuneration
Suppliers must pay the legal minimum wage or more and may not practice wage deductions as a disciplinary measure. Overtime working must be voluntary and paid.

Safe regulation of working hours
Suppliers must ensure that working hours are in accordance with local regulation and industry practice.

Environmental Management

The West Brom seeks to work with Suppliers who respect the environment in which they operate.

Overview of environmental issues
Suppliers must have policies addressing areas such as waste management, energy use and carbon emissions. The West Brom expects that the Suppliers’ policy shall be appropriate to the size and nature of the Supplier's business.

Legislative Compliance
Suppliers must abide by all legislation and regulations related to the protection of the environment and the handling of dangerous and hazardous materials.

Supply/Use of Hazardous Materials
Suppliers must keep hazardous materials to a minimum and make Safety Data Sheets available for all hazardous materials.

Responsible sourcing
Suppliers must be committed to sourcing goods and raw materials in an ethical and environmentally responsible way.

Occupational Health and Safety

Suppliers must respect all legislative requirements in the countries in which they operate. As part its duty of care, Suppliers must ensure their employees’ working environment is clean, safe and healthy. Suppliers must respect the following minimum standards:

Occupational Safety
Suppliers must promote safe activities in the workplace. This includes implementing and documenting safe working procedures, identifying potential safety hazards and ensuring appropriate safety training.

Maintain systems relating to occupational injury and illness
Suppliers must manage, monitor and report health and safety risks. This entails recording injury cases, investigating incidents and implementing corrective actions.

Manage Physically Demanding Work
Suppliers must identify worker exposure to potentially hazardous tasks such as manual handling, heavy lifting or tasks requiring the use of force. Tasks must be identified, evaluated, monitored and controlled.

Working with Equipment/Machines
Suppliers must evaluate safety risks involved in the use of production equipment. Training must be undertaken and personal protective equipment issued where required.

Sanitary working conditions
Suppliers must ensure that workers have access to clean lavatory facilities, storage facilities, potable water and adequate heating, cooling and ventilation.

Emergency Management
Suppliers must identify potential emergencies, and minimise their impact by developing response procedures. Examples include reviewing evacuation procedures, fire drills, installing fire suppression equipment and ensuring exit facilities are maintained and signposted.

Business Integrity and Ethical Trading

The West Brom believes commercial dealings need to be both fair and beneficial to all parties and commits to building respectful working relationships with suppliers. The West Brom requires its Suppliers to respect the following:

Code of Conduct
Suppliers must have policies that address business standards and ethical trading. Policies must include commitments to respect applicable legislation, ethical trading and must include the Suppliers position on bribery and corruption.

No abuse of position
Suppliers should have fair and equitable payment policies with their own suppliers and subcontractors.

Gifts and entertainment
Suppliers must not offer or receive inappropriate benefits from the West Brom employees or subcontractors. Suppliers must record offers and exchanges of gifts and entertainment with our employees.

Inside Information
If, in the course of trading, Suppliers become aware of inside information about us or our clients, we expect Suppliers to have in place policies and procedures for the proper handling and use of that information (such as information barriers).

Anti-Corruption
The West Brom expects the Supplier to comply with all applicable laws and regulations on corruption, bribery, prohibited business practices and extortion.

Free Competition
Suppliers must promote free, fair and transparent competition.

Privacy
Suppliers must comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted and shared.

Whistleblowing

Suppliers are actively encouraged to report inappropriate behaviour by the West Brom, its employees and its suppliers.

The West Brom will treat information seriously and, where possible, confidentially. Contractors or suppliers will suffer no consequences for bringing to the West Brom’s attention, in good faith, suspected malpractice.

The Whistleblowing Procedure for Suppliers may be consulted by clicking on this link.

Monitoring

It is an essential element of policy compliance that Suppliers monitor and ensure compliance in the 4 key areas. The West Brom reserves the right to review the policies and documents submitted in response to this Code of Conduct. The West Brom may wish to undertake an on-site audit to validate Supplier compliance. Requests will be made to the Supplier in advance.

Compliance

Suppliers that are fully compliant with this code will be preferred to non-compliant Suppliers. To be fully compliant Suppliers must supply documentation in support of their response.

In the event that a Supplier or a Suppliers’ subcontractor is, or becomes, non-compliant with the code, the West Brom will work with the Supplier to achieve compliance within a reasonable period. If, however, the non-compliance is particularly grave or cannot be resolved in a reasonable period, the West Brom may review the terms of the contract, or terminate it.

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