23red Supplier Code of Conduct
January 2024
1. Introduction
We set high standards for the way we do business and continually strive to deliver high performance for our clients. This helps our clients know that we can be trusted to deliver excellence across a range of services. This includes services that represent good value to the client; development work that is delivered on budget and to brief; and policies that fulfil our manifesto commitments.
Our Supplier Code of Conduct (the Code) sets out the minimum behaviours, standards and practices we expect to see from our Suppliers, all of which are based on our own code of conduct, policies and standards.
We expect our Suppliers to be ethical, responsible and to fully adhere to the principles set out in this Code in addition to the provisions of any commercial terms agreed between our agencies and the Supplier and all applicable laws and regulations of the countries in which they operate.
The Code is applicable to all Suppliers, partners and affiliates who supply products or services related to contracts or purchase orders. Suppliers are expected to have and maintain practices similar to those in the Code and must apply these standards to the Suppliers they work with.
We expect our employees to treat suppliers with fairness and respect and to work jointly with suppliers to build trusting, collaborative and constructive working relationships. In return we expect suppliers to treat our employees in the same way, and to work with us to build those similar relationships that are focused on delivering for the client.
2. Our People
All Suppliers must comply with applicable international and national laws and standards in relation to labour practices and human rights:
2.1 Fair Treatment and Equal Opportunity
We recognise the need to reward fairly for skill, contribution and performance. We want our workplace to be a place of mutual trust and respect, which embraces diversity and values everyone for their merits where people are treated fairly and consistently. Suppliers must not discriminate in hiring, compensation, access to training, promotion, termination or retirement based upon (but not limited to) race, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.
2.2 Respectful Workplace
We believe that all our employees have the right to respect and freedom from harassment. Violence or the threat of violence at work is unacceptable. Suppliers are expected to promote equal opportunities for all and value diversity and must treat all workers with respect and dignity and are prohibited from engaging in physical, mental, verbal, sexual or other abuse, inhumane or degrading treatment, corporal punishment or any form of harassment.
2.3 Accessibility
It is important that contracts with our suppliers meet the needs of service users. We will work together with suppliers to articulate these outcomes to ensure that the goods and services being provided meet the needs of users and we expect fully reciprocal behaviour from suppliers.
2.4 Human Rights
Respect for human rights is a fundamental part of how we do business and we refuse to do business with any Supplier that violates the standards and principals of basic human rights. We expect our Suppliers to share this commitment.
2.5 Child Labour
We do not accept child labour or any practice that inhibits the development of children and expect our Suppliers to comply with local laws regarding the minimum age of employees.
2.6 Forced Labour
In line with our own commitment, Suppliers must not use any type of involuntary or forced labour, including bonded, slave or human trafficked labour. Individuals must be free to terminate their employment in accordance with established laws, regulations and rules. Suppliers should not mandate that workers hand over passports or work permits as a condition of employment.
2.7 Migrant Workers
Suppliers must ensure migrant workers are treated with dignity and in accordance with the same standards that apply to other workers.
2.8 Fair Pay & Benefits
Suppliers must pay workers the minimum compensation recommended by the Living Wage Foundation, or equivalent in their local territory. They must also pay all legally mandated benefits required by local. Any worker overtime must be voluntary and as a minimum compensated inline with their standard wage. Suppliers must ensure that working hours, including any overtime do not exceed legal limits.
3. Our Business
High standards of ethical behaviour and compliance with laws and regulations are essential to protecting the reputation and long term success of our business. We are committed to the highest standards of integrity, honesty, openness and professionalism in our global activities and have the highest respect for local laws and regulations. We expect Suppliers to behave ethically and appropriately in all dialogue as well as act in compliance with legal and industry requirements and seek to implement best practice in their industries.
3.1 Anti Bribery Corruption and Facilitation Payments
We have a zero-tolerance policy for Bribery and Corruption. Suppliers are expected to behave ethically in all business dealings. They must not offer, promise, authorise, give demand or receive any bribes, improper payment, gift, loan, fee, reward, other advantage or anything of value which may be viewed as or have the effect of improperly influencing business decisions or participate in any kind of corrupt activity, either directly or indirectly (through a third party). Suppliers, representatives and their employees must comply with all applicable antibribery and corruption laws and regulations of the countries in which they operate and implement appropriate and adequate procedures for their employees to comply with applicable anticorruption laws and these standards. Facilitation payments are small payments or fees requested by government officials to speed up or facilitate performance of routine government actions. Suppliers must not make facilitation payments or permit them to be made on our behalf.
3.2 Gifts and Hospitality
We develop long term business relationships based on trust and respect. Exchanging gifts and hospitality can build goodwill but may appear to create improper influence. Any gift or hospitality we accept or give in connection with our business dealings should always be customary and reasonable in terms of value and frequency. Suppliers should not provide any gifts, hospitality, meal or entertainment to our employees in any situation which may influence or appear to influence any business decisions. In other situations, Suppliers may provide modest gifts, meals or entertainment to our employees where they do not violate any laws and are customary and reasonable in terms of value and frequency (never cash or cash equivalent).
3.3 Conflicts of Interest
We seek to avoid conflicts of interests in our business dealings but where they do occur, we manage them. Suppliers should make us aware of any potential conflict of interest that may affect our business dealings as soon as they are known.
3.4 Data Protection
Suppliers must protect consumer, client and employee data in accordance with The General Data Protection Regulation 2016/679 when relevant, local laws and best practice. Suppliers must respect the privacy of their employees as well as those whose personal data we entrust to them to provide products or services. We expect external business partners to legally process and protect personally identifiable information where applicable and to train their employees and subcontractors’ employees assigned to work on our accounts to ensure they understand the requirements and their personal liabilities for protecting personal information and as well as all our confidential information.
3.5 Cyber Security
It is essential that suppliers safeguard the integrity and security of their systems and comply with the relevant government standards and guidance. Suppliers must inform the 23red IT manager (Alexandra.davis@23red.com) if they become aware of any cyber security incident that affects or has the potential to affect any of 23red or their clients data.
3.6 Confidentiality
23red and suppliers are both expected to comply with the provisions in our contracts and any legal requirements to protect commercial and sensitive information. 23red and suppliers may both also be party to confidential information that is necessary to be effective partners. This information, even if it is not covered by contractual provisions, should be handled with the same care as if it were information of contractual sensitivity.
3.7 Treatment of Supply Chain
We expect suppliers to deal fairly with the subcontractors and suppliers in their supply chain. We expect suppliers to avoid passing down unreasonable levels of risk to subcontractors who cannot reasonably be expected to manage or carry these risks. We expect suppliers not to create barriers to the use of small and medium-sized enterprises who are qualified to provide goods or services, and to encourage innovation in their supply chains to increase the value or quality of supply.
3.8 Prompt Payment
We expect both 23red and suppliers to be fair and reasonable in their payment practices. Suppliers should pay subcontractors within 30 days on 23red contracts and comply with the standards set out in the Prompt Payment Code (https://www.23red.com/ppc)
3.9 Corporate Governance and Corporate Social Responsibility
We expect our suppliers to adhere to the UK Corporate Governance Code or follow equivalent good corporate governance principles underpinned by robust processes. We also expect our suppliers to be good corporate citizens by upholding the values of this Supplier Code of Conduct, taking into consideration social value legislation in delivering goods and services and supporting key government corporate social responsibility policy. This includes areas such as diversity and inclusion, sustainability, prompt payment, small and medium sized enterprise engagement, the Armed Forces Covenant, apprenticeships and skills development and addressing the gender pay gap.
4. Suppliers
4.1 Health & Safety
We have a strong focus on Health & Safety in the workplace. We require everyone who works for us or with us to understand the health and safety risks of their activities and apply good Health & Safety management systems in accordance with the applicable legal framework, training and practices for employees, contractors, visitors and those in community affected by their activities. They should also take the necessary precautions to protect everyone from work place injuries. Suppliers are expected to take personal and collective responsibility to help fulfil our Health & Safety goals and care for the environment through a commitment to good environmental practices.
4.2 Corporate Social Responsibility and the Environment
We aim to reduce our environmental impact, prevent environmental damage and minimise our use of energy and resources. Suppliers must comply with all applicable environmental legislation and must not use material considered harmful to the environment.
4.3 Community Engagement
We support and contribute to the social and economic well-being of the communities we work in. We are committed to building positive relationships with the communities in which we live and work and Suppliers are encouraged to take a similar views.
4.4 Skills Development
We are committed to a programme of skills development and apprenticeships for our employees to help raise skills and deliver sustainable growth of the workforce. We encourage our suppliers to take similar views however require suppliers where contracts may be delivered in excess of £10million.
5. Code Adherence
Suppliers must conform to all aspects of the Code (as amended from time to time) and make their employees and subcontractors aware of the Code. We reserve the right to verify Suppliers compliance with the Code and Suppliers must maintain documentation necessary to demonstrate compliance with this Code. We reserve the right to terminate business relationships in the event of material breach of the principles set out in the Code. Suppliers are encouraged to disseminate these expectations throughout their own supply chain and incorporating the principles set out in the Code as part of routine business practice. If Suppliers have an actual or potential ethical concern related to the Code or any engagement or relationship with us, they are encouraged to make us aware immediately.