SUPPLIER CODE OF CONDUCT
Introduction
OQC is committed to conducting all its business dealings in a professional and ethical manner, whilst maintaining high standards of social and environmental responsibility. The purpose of this Supplier Code of Conduct is to share our expectations and fundamental principles, which should extend into your own supply chain. We value our business relationship with you, as you play an essential part in helping create a more socially and environmentally responsible supply chain.
As a statement of good practice, this Code of Conduct should be read by OQC’s current and aspiring suppliers, and by their subcontractors in their supply chains. Recognising that there are different legal and cultural environments in which suppliers operate, this document outlines the core requirements to which suppliers must comply in order to do business with OQC. We expect our suppliers to communicate this Code of Conduct to employees, their parent company, subsidiaries and subcontractors, as it will form part of any contract agreement.
Forced and Child Labour
We expect our suppliers to never engage in or use child, slave, forced or obligatory labour. Any form of compulsion or coercion is strictly prohibited and will be reported to the appropriate authorities. We expect our suppliers to comply with legislation to this effect, including but not limited to, the Modern Slavery Act 2015. This Act is designed to tackle slavery and human trafficking. For more information in relation to this legislation please click here. We also require our suppliers to report any concerns or suspicions they may have concerning any activities of slavery, human trafficking, the minimum age of employees and any contravention of applicable child labour laws.
Wages and Minimum Age
Employing workers younger than the legal minimum age is strictly prohibited. We also expect our suppliers to ensure that working hours, wages and overtime pay follow all applicable laws with the purpose and intention of the relevant law. Workers must be paid at least the minimum legal wage or a wage that meets local industry standards, whichever is greater.
Health and Safety
At OQC the health and safety of our employees is our number one priority, and we expect our suppliers to do the same. Suppliers must ensure that they observe all health and safety legislation and regulations, and continuously analyse any risks involved in their daily operations. As a minimum we expect our suppliers to provide a clean, safe, and healthy working environment to prevent any occupational hazards from arising; ensuring that the right measures are in place and providing appropriate health and safety training and certifications.
Anti-Bribery, Money Laundering and Corruption
We have a zero-tolerance approach to any type of bribery, fraud, or corrupt business practices. Integrity, honesty, and ethical conduct is paramount to us and is expected in all business dealings. Suppliers must have policies and procedures in place to prevent any unethical business practices including systems and procedures in place; and are required to adhere to relevant legislation including but not limited to, The Money Laundering, Terrorist, Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
We expect our suppliers to maintain ethical controls over their procurement activity which ensures no risk of bribery or corruption within their personnel and their supply chains. Suppliers must also comply with anti-bribery and anti-corruption law, including but not limited to, the Bribery Act 2010.
Data Protection
We expect our suppliers to protect personal data fully and comply with all relevant data protection legislation, including but not limited to, the Data Protection Act 2018 (which incorporates the General Data Protection Regulations). Suppliers are required to safeguard and not seek personal advantage from confidential, proprietary, commercially sensitive and personal information held by them or in their possession. Where disclosures of confidential or sensitive information is required, it must only be done so with those who have been authorised to receive such information. In the event that confidential or sensitive data has been disclosed or leaked, a supplier(s) must inform us immediately and co-operate with any remediation efforts that we may have. Suppliers must also reasonably cooperate and assist us should we need to conduct any data protection audit(s), impact assessment(s) or appropriate compliance matters.
Cyber security
It is essential that suppliers safeguard the integrity and security of their systems and comply with relevant government standards and guidance. Suppliers must inform us immediately should they become aware of any cyber security incident that affects or has the potential to affect the integrity of data. We recommend that our suppliers continually assess their cyber security and are actively updating their policies and procedures with new technology to minimise threat(s).
Intellectual & Other Property Rights
We expect our suppliers to protect and respect the intellectual property rights of others, including OQC. In that regard, a OQC supplier shall (i) Only use OQC information and property (including tools, drawings and specifications) for the purpose for which they are provided to the supplier and for no other purposes; (ii) Take appropriate steps to safeguard and maintain the confidentiality of OQC proprietary information, including maintaining it in confidence and in secure work areas and not disclosing it to third parties (including other customers, subcontractors, etc.) without the prior written permission of OQC or as stipulated within an agreement. (iii) Observe and respect all OQC patents, trademarks and copyrights and comply with such restrictions or prohibitions on their use.
Environment and Carbon Net Zero
All suppliers must comply with any relevant environmental laws or regulations. This includes, for example, obtaining the necessary environmental permits in the conduct and pursuit of their business goals. Where we classify a supplier as having either a high or medium environmental impact, they must have policies and procedures in place to manage these risks.
OQC is also committed to trying to achieve ‘Net Zero’ in line with the UK Government’s 2050 goal. We understand that this may be difficult to achieve; but are hopeful that with the support of our suppliers, this can be realised together. We encourage our suppliers and their supply chains to demonstrate their commitment and help us try to minimise our carbon footprint during any contract periods that we may share.
Export Controls & Customs Matters
Each OQC supplier is responsible for ensuring that they comply with all applicable export control laws and regulations. This includes, but it is not limited to: (i) adhering to any restrictions on access and use applicable to outside nationals (ii) ensuring that all invoices and any customs or similar documentation are submitted to OQC or governmental authorities in connection with transactions involving OQC (iii) accurately describing the goods and services provided or delivered and the price thereof.
Raising a Concern and Reporting Violations
The foregoing standards are subject to modification at the discretion of OQC. Each supplier is responsible for ensuring it complies with such standards. If, for whatever reason, it feels that it cannot, the supplier is obligated to inform us immediately. If you have any questions in relation to this document or the requirements, please contact your OQC point of contact or the OQC legal team who will always be happy to assist.
In the event that there are any material violations of this Code of Conduct, Suppliers should report them immediately to [email protected]. Similarly, any concern(s) regarding the ethical conduct of an individual employed by OQC or acting on OQC’s behalf, should also be reported. Where we receive such a report we will engage with the individual/supplier to develop an appropriate solution and address the matter.
