Sabio Group Supplier Code of Conduct
1. Purpose
Sabio Ltd and its group companies (“Sabio”) are committed to conducting business responsibly, ethically and sustainably.
This Supplier Code of Conduct (the “Code”) sets out the minimum standards that Sabio expects its suppliers, contractors, subcontractors, agents and other business partners (“Suppliers”) to meet or exceed when providing goods or services to, or on behalf of, Sabio.
Suppliers may meet these expectations through their own policies, codes and procedures, provided that these establish equivalent standards.
2. Compliance and responsible business
Suppliers must:
- comply with applicable laws and regulations in the countries in which they operate;
- obtain and maintain the licences, permits and approvals required for their activities;
- conduct business honestly, fairly and with integrity; and
- maintain appropriate policies, procedures and controls having regard to the nature, size and risk profile of their business.
Where applicable law and this Code address the same subject, Suppliers should meet the higher standard to the extent legally permitted.
3. Labour and human rights
Suppliers must respect internationally recognised human rights and treat workers fairly and with dignity.
Suppliers must:
- not use or benefit from slavery, servitude, forced or compulsory labour, human trafficking or child labour;
- ensure that work is undertaken voluntarily and that workers are free to leave their employment in accordance with applicable law;
- comply with applicable laws concerning pay, working hours, rest periods, leave and employment conditions;
- provide workers with clear and understandable information about their employment terms;
- provide a working environment free from unlawful discrimination, harassment, bullying, abuse and inhumane treatment;
- respect lawful rights of freedom of association and collective bargaining; and
- ensure that recruitment practices are responsible and do not involve workers paying improper or exploitative recruitment fees.
Suppliers should identify and address material labour and human-rights risks within their operations and supply chains.
4. Health, safety and wellbeing
Suppliers must provide a safe and healthy working environment and comply with applicable health and safety laws.
Suppliers should identify and manage workplace risks, provide appropriate information and training, maintain suitable emergency arrangements and take reasonable steps to prevent work-related injury and ill health.
Where Suppliers work at Sabio or client premises, they must comply with applicable site-specific health, safety and security requirements.
5. Modern Slavery
Sabio has zero tolerance for slavery and human trafficking in its business and supply chains.
Suppliers must take proportionate steps to:
- identify, assess and address Modern Slavery risks in their operations and supply chains;
- maintain appropriate controls to prevent forced labour, human trafficking and other forms of exploitation;
- investigate credible concerns and take appropriate remedial action; and
- communicate equivalent standards to relevant suppliers and subcontractors.
Suppliers must not knowingly source goods or services produced using slavery, forced labour, human trafficking or unlawful child labour.
6. Bribery, corruption and ethical conduct
Suppliers must not engage in bribery, corruption, fraud, extortion, embezzlement, facilitation payments, kickbacks or other improper business practices.
Suppliers must:
- comply with applicable anti-bribery and anti-corruption laws;
- maintain proportionate controls to prevent bribery and corruption;
- ensure that gifts, hospitality, expenses and charitable or political contributions are not offered or accepted to secure an improper advantage;
- maintain accurate books, records and accounts;
- avoid conflicts of interest and disclose to Sabio any actual or potential conflict relevant to the Supplier’s work for Sabio; and
- compete fairly and comply with applicable competition laws.
Suppliers must not offer Sabio personnel any payment, gift, hospitality or other benefit intended, or reasonably capable of being perceived as intended, to improperly influence a business decision.
7. Environmental responsibility
Suppliers must comply with applicable environmental laws and manage the material environmental impacts of their activities.
Having regard to their size, activities and environmental impact, Suppliers should seek to:
- use energy, water and raw materials efficiently;
- reduce greenhouse-gas emissions and other harmful emissions;
- prevent pollution and minimise waste;
- promote reuse, recycling and responsible disposal;
- manage hazardous materials and electronic waste safely;
- consider environmental performance when sourcing goods and services; and
- maintain appropriate environmental information and records.
Where relevant to the goods or services provided, Suppliers should be able to provide reasonable information about their environmental impacts, initiatives and performance.
8. Information, confidentiality and privacy
Suppliers must protect Sabio’s and its clients’ confidential information, personal data, systems and other assets.
Suppliers must:
- comply with applicable data-protection and privacy laws;
- use confidential information and personal data only for authorised purposes;
- maintain security measures appropriate to the nature and sensitivity of the information concerned;
- restrict access to individuals who require it for legitimate business purposes; and
- notify Sabio promptly of any actual or suspected security or personal-data incident affecting Sabio, its clients or the services provided to Sabio.
Suppliers must respect intellectual-property rights and must not use Sabio’s name, branding, information or materials without appropriate authorisation.
9. Supply-chain standards
Suppliers should communicate standards equivalent or superior to this Code to relevant suppliers, subcontractors and other third parties supporting the goods or services provided to Sabio.
The measures adopted should be proportionate to the nature of the relationship and the associated risks.
10. Evidence and due diligence
Suppliers are expected to cooperate reasonably with Sabio’s supplier due-diligence process.
Sabio may request information and supporting evidence relevant to this Code:
- when the Supplier is first considered or onboarded;
- when due diligence is reviewed or refreshed;
- where the goods, services or associated risks materially change; or
- where Sabio becomes aware of a relevant concern.
Supporting evidence may include relevant policies, procedures, certifications, training records, risk assessments, reports or other information appropriate to the Supplier’s size, activities and risk profile.
Suppliers should provide accurate, complete and current information. Sabio will take a proportionate approach to the information and evidence requested.
11. Concerns, breaches and corrective action
Suppliers should maintain suitable channels through which workers and other relevant persons can raise concerns confidentially and without retaliation.
A Supplier must promptly notify its usual Sabio contact if it becomes aware of an actual breach of this Code that affects, or could reasonably affect:
- goods or services provided to Sabio;
- Sabio’s or a client’s information, systems, personnel or premises;
- Sabio’s compliance with applicable law; or
- Sabio’s reputation or responsible-business commitments.
The Supplier should investigate the circumstances, take appropriate steps to stop or contain the issue and implement reasonable corrective action.
Sabio will consider identified concerns proportionately, taking account of their seriousness, the Supplier’s response and the adequacy of any corrective action.
12. Review and continuous improvement
Sabio recognises that responsible and sustainable supply-chain practices develop over time. Suppliers are expected to review their relevant policies and controls periodically and to make reasonable improvements where risks, gaps or relevant changes are identified.
Sabio may update this Code from time to time to reflect changes in law, recognised good practice and Sabio’s responsible-business and sustainability commitments.