Supplier Code of Conduct                          

Issue 1.0      April 2022

1.0 INTRODUCTION

At Seventy7 Group Ltd how we source and procure goods and services is central to our commitment to improving the sustainability of our operations and contributing to the wellbeing of our local communities, in Manchester, London and Mumbai.

As part of this commitment we encourage our suppliers to adopt to the same high standards for sustainability and corporate social responsibility as ourselves. That’s why we have created this ‘Supplier Code of Conduct’, which sets out the standards expected of any Supplier doing business with Seventy7.

1.1 Definitions

1. ‘Supplier’ means any firm or individual that provides a product or service or undertakes any activity for or on behalf of Seventy7 Group, either directly or indirectly.
2. ‘Supplier Representative’ means any individual who works for a Supplier, whether under a contract of employment or any other contract (written or oral) where an individual undertakes to personally do any work or services for the Supplier and includes, without limitation, Supplier’s principals, officers, directors, employees, and independent contractors.

2.0 USE OF SEVENTY7 GROUP PROPERTY AND EQUIPMENT

The Supplier is responsible for the proper use of Seventy7 Group property, and must safeguard it against loss, damage, misuse or theft.  Seventy7 Group property is provided to Supplier for Seventy7 Group business purposes only.  Personal use of Seventy7 Group equipment such as phones and computers should be kept to a minimum.  Any unauthorised duplication and use of software is a violation of copyright laws of the United Kingdom.  All Internet, intranet and e-mail activities using Seventy7 Group systems are to be conducted for legitimate business purposes that are directly related to the services the Supplier is performing for Seventy7 Group.  The Supplier may not post or discuss business information concerning Seventy7 Group with the media or on the Internet. 

3.0 DATA SECURITY AND CONFIDENTIALITY 

Suppliers must comply with applicable privacy and data protections laws and regulations in the respective countries of operation, as well as secure Seventy7 Group confidential data and individual personal data and prohibit its unauthorised access or use.

4.0 ETHICAL STANDARDS

Seventy7 Group chooses to work with Suppliers that conduct business with ethical standards consistent with its own.  The Supplier should abide by the following ethical standards and guidelines:

1. Obey all relevant laws
2. Treat each other fairly, with dignity and respect
3. Prepare all records of financial transactions carefully and accurately
4. Report financial conditions and results of operations, honestly and promptly
5. Deal honestly and fairly with clients, customers, suppliers, and financial partners
6. Avoid actual and potential conflicts of interest
7. Avoid the improper giving and receiving of gifts
8. Safeguard Seventy7 Group’s assets
9. Protect Seventy7 Group’s reputation
10. Separate personal political activities from Seventy7 Group’s business
11. Report observed violations of legal and ethical standards

5.0 HEALTH & SAFETY

Seventy7 Group expects its Suppliers to strive to implement the standards of occupational health and safety at a high level.  The Supplier shall therefore comply with applicable occupational health and safety regulations and provide a work environment that is safe and conducive to good health in order to preserve the health of employees and prevent accidents, injuries and work-related illnesses.

Seventy7 Group maintains a drug and alcohol-free work environment. No Supplier or Supplier Representative is permitted to possess, consume, sell, or be under the influence of alcohol and illegal drugs (and legal drugs that are not used in a manner consistent with dosage requirements) while in any Seventy7 Group facility.  Any Supplier Representative who is using prescribed drugs, and who brings them onto the Company’s premises must inform their Seventy7 Group contact. Failure to do so could endanger the Supplier and Seventy7 Group colleagues. All information regarding prescribed drugs will (where reasonably possible) remain confidential. Any Supplier or Supplier Representative found to be in violation of this policy may be removed from company premises and not allowed to re-enter a Seventy7 Group facility.

Violent or abusive behaviour will not be tolerated at Seventy7 Group. Any Supplier Representative engaging in such conduct may be removed from the premises and not allowed to re-enter a Seventy7 Group facility. 

6.0 DISCRIMINATION AND HARASSMENT

Seventy7 Group does not tolerate unlawful discrimination or harassment in the workplace.  The Supplier must not engage in any unlawful discriminatory or harassing conduct on Seventy7 Group’s facilities or directed at anyone in the workplace.  Discrimination or harassment based on age, sex, race, religion, belief, creed, colour, nationality, ethnic or national origin, marital or civil partnership status, pregnancy, maternity or paternity, sexual orientation, gender reassignment, disability, or other protected characteristic or status is strictly prohibited.

Examples of harassment include:

1. unwanted physical conduct or “horseplay”, including touching, pinching, pushing, grabbing, brushing past someone, invading their personal space, and more serious forms of physical or sexual assault;
2. unwelcome sexual advances or suggestive behaviour (which the harasser may perceive as harmless), and suggestions that sexual favours may further a career or that a refusal may hinder it;
3. continued suggestions for social activity after it has been made clear that such suggestions are unwelcome;
4. sending or displaying material that is pornographic or that some people may find offensive (including e-mails, text messages, video clips and images sent by mobile phone or posted on the internet);
5. offensive or intimidating comments or gestures, or insensitive jokes or pranks;
6. mocking, mimicking or belittling a person’s disability;
7. racist, sexist, homophobic or ageist jokes, or derogatory or stereotypical remarks about a particular ethnic or religious group or gender;
8. outing or threatening to out someone as gay or lesbian; or
9. ignoring or shunning someone, for example, by deliberately excluding them from a conversation or a workplace social activity.

Seventy7 Group may, in its sole and absolute discretion, remove from the premises any Supplier who engages in offending conduct.

The Supplier must promptly report any offending behaviour, whether such behaviour is directed to the Supplier or to employees of Seventy7 Group, by notifying any member of Seventy7 Group management.

7.0 COMPLIANCE WITH LABOUR LAWS AND STANDARDS

Supplier shall comply with all laws applicable to its business and adhere to the following:

7.1 Child Labour

Suppliers are prohibited from using workers under the legal age of employment in any country or local jurisdiction where Supplier performs work for Seventy7 Group. If the minimum age of employment is not defined, the minimum age of employment shall be 15 years of age. In cases where minors are authorised to work, we expect our Suppliers to observe all legal requirements, particularly those pertaining to hours of work, wages, minimum education and working conditions.

7.2 Forced Labour

Suppliers shall not employ or use any form of forced, bonded or compulsory labour, or other forms of slavery or human trafficking and will take all reasonable steps to ensure that there is no form of forced, bonded or compulsory labour, or other forms of slavery or human trafficking employed or used within its business or in its supply chains.

7.3 Compensation and Working Hours

Suppliers shall comply with the respective national laws and regulations regarding working hours, wages and benefits.

7.4 Disciplinary Practices/Coercion

Seventy7 Group firmly believes that everyone should be treated with dignity. Suppliers shall not inflict or threaten to inflict corporal punishment or any other forms of physical, sexual, psychological or verbal abuse or harassment on any employees.

7.5 Freedom of Association

Supplier Representatives shall be free to join organisations (e.g. Trade Unions) of their own choice. Suppliers shall respect and recognise the right of employees to join and organise associations of their own choosing.  Employees shall not be subject to intimidation or harassment in the exercise of their right to join or to refrain from joining any organisation.

8.0 ENVIRONMENT

Suppliers shall comply with all applicable environmental laws, regulations and standards. Suppliers shall identify and reduce those aspects of their operations which have the potential to cause a significant negative impact on the environment and promote greater environmental responsibility through initiatives such as:

• Responsible waste management and disposal
  • Reduction of greenhouse gas and other emissions harmful to the environment
  • Conservation of non-renewable natural resources

9.0 COMMUNITY INVOLVEMENT AND DEVELOPMENT

Seventy7 Group seeks to work with Suppliers that build relationships with local communities to support and improve the education, cultural, economic, and social well-being of the communities which they operate in. Suppliers shall provide employees with a living wage, at a minimum.

10 GIFTS, HOSPITALITY AND CONFLICTS OF INTEREST

Seventy7 Group does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes, such as building relationships, maintaining the Company’s image or reputation, or marketing products and services.

A gift or hospitality will not be appropriate if it is unduly lavish or extravagant or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process). The Supplier shall refrain from giving any gifts, payments or the like that would, or could be perceived to violate this policy. 

The Supplier should further refrain from accepting or giving any gifts, favours, payments, entertainment, loans or the like with a purpose of obtaining any improper advantage or influence for the Supplier, Seventy7 Group or any third party with any client, prospective client or other third party or that create any appearance of impropriety.

The Supplier must disclose all potential conflicts of interest, including those in which the Supplier may have been placed inadvertently due to either business or personal relationships with customers, suppliers, business associates, or competitors of Seventy7 Group, or with other Seventy7 Group employees.

Employees of the Supplier may not act on behalf of Seventy7 Group in any transaction or business relationship involving themselves or members of their family, or other persons or organisation with which they or their family have any significant personal connection or financial interest.

11 ANTI-BRIBERY AND CORRUPTION

It is Seventy7 Group’s policy to conduct all our business in an honest and ethical manner. We take a zero-tolerance approach to corruption, bribery, extortion, embezzlement, and money laundering in any form.

Suppliers shall not violate the UK Bribery Act, any international anti-corruption conventions, and applicable anti-corruption laws and regulations of the countries in which they operate, and shall not engage in corruption, bribery, extortion, embezzlement, or money laundering in any form.

Suppliers shall not offer or accept bribes or other means to obtain an undue or improper advantage. Suppliers must uphold fair business standards in advertising, sales, and competition.

12 REPRESENTATION OF SEVENTY7 GROUP

The Supplier may not represent itself as an employee of Seventy7 Group or enter into any agreement on Seventy7 Group’s behalf or in Seventy7 Group’s name.

13 COMPLIANCE

Seventy7 Group reserves the right to ask the Supplier to re-affirm compliance with this Code of Conduct periodically, to investigate compliance by Supplier with this Code of Conduct at any time and to immediately remove the Supplier from Seventy7 Group premises and/or terminate the related services contract with Supplier in the event of noncompliance.

14 COMMUNICATION

The Supplier should take appropriate steps to ensure that the principles of this Code are communicated to their employees and throughout their own supply chains. The Supplier should also take appropriate steps to ensure that the principles of this Code are adopted and applied by their employees, suppliers, agents, and contractors to the extent applicable.

15 ENFORCEMENT

If Seventy7 Group determines that any Supplier has violated this Code, Seventy7 Group may either terminate its business relationship or require the Supplier to implement a corrective action plan. If corrective action is advised, but not taken, Seventy7 Group will suspend placement of future orders and shall terminate its business relationship with Supplier.

16 WHISTLEBLOWING POLICY – REPORTING CONCERNS 

Severty7 Group operates a whistleblowing policy and encourages a culture of openness and accountability within the organisation. In accordance with this policy any actual, or suspected, material violations by a Supplier of this Supplier Code of Conduct or any other severe violations potentially harming our clients, Seventy7 Group’s employees or Seventy7 Group as a firm should be raised to your Seventy7 Group contact.

Similarly, if you are a Supplier to Seventy7 Group and suspect that a Seventy7 Group employee, or anyone acting on behalf of the firm, has engaged in illegal or otherwise improper conduct, you should report the matter to your Seventy7 Group contact.

17 CHANGES TO THE SUPPLIER CODE OF CONDUCT

This Supplier Code of Conduct may be revised or updated by Seventy7 Group from time to time. To the extent there is a conflict between this Supplier Code of Conduct and any applicable law or provision of any agreement between Seventy7 Group and Supplier, the applicable law or agreement shall apply.