1. Introduction

This document sets out a short Code of Conduct to which we in Orbis Procurement expect suppliers to adhere when bidding for and delivering contracts for goods, works and services for our partners and customers. It is complementary to our Ethical Procurement Statement, which sets out our own standards and commitments.

Our aim is to adopt and ensure ways of working in our supply chains which:

· Respect fundamental international standards against criminal conduct (such as bribery, corruption and fraud) and human rights abuse (such as modern slavery), and respond immediately to such matters where they are identified, and

· Result in improvements to the working lives of people who contribute to our supply chains

Our purpose in doing this is to ensure that contracts are being delivered responsibly by our suppliers, and to build the trust of the public by promoting a culture of high ethical standards that deter or expose poor behaviour and practice.

2. Supplier Code of Conduct

We expect any supplier providing goods, works or services for our Partners or Clients to maintain high standards of integrity and professionalism in their business dealings, adhering to the law and taking action where necessary to minimise negative impacts and potential risks.

We will therefore expect our suppliers to agree to abide with the following principles, where proportionate and directly relevant to the subject matter of the contract. These are not normally included explicitly in the subject matter of contracts as most are governed by employment law and, as such, are legal requirements which if breached would be grounds for excluding the supplier from further contracts for non-compliance.

Further, we expect suppliers to ensure, as far as is proportionate, reasonable and practicable, that these principles are followed by suppliers in their own supply chains.

During a public procurement process we do not set standards which exceed the law, though we may work with suppliers post-award, and on a voluntary basis, to pursue wider ethical issues together to deliver additional improvements or added value.

We expect that:

Acting with integrity and transparency

· Procurement processes are conducted in an transparent and equal way in accordance with the latest Public Contracts Regulations

· There is transparency and honesty in the spending of public money

· Suppliers will have systems and processes in place to ensure public money is used for the purpose it is intended.

· Suppliers will maintain a gifts and hospitality register relating to Coucnil contracts to be made available upon request.

Taxation

· Pay the required taxes responsibly and fairly, and not to seek to evade tax by the use of unethical practices

Working conditions are safe

· Operate appropriate health and safety policies and procedures overseen by a senior manager responsible for compliance and monitoring and ensuring employees have the necessary training and health and safety equipment.

· Provide comfortable and hygienic working conditions with clean toilets and water suitable for drinking and washing. Where worker housing is provided it should meet the same standards for health and safety as the workplace.

Good health is promoted

· Invest in measures for tackling ill health as healthy employees experience a better quality of life and tend to be more productive.

Employment is freely chosen

· Afford employees the freedom to choose to work and not use forced, bonded or non-voluntary labour.

· Afford employees freedom of association with the right to join an independent trades union or other workers’ associations and to carry out reasonable representative functions in the workplace.

· Put in place alternative means of democratic representation for workers where laws restrict freedom of association and collective bargaining.

· Do not use illegal blacklists to deliberately or unfairly exclude some sub-contractors or workers.

Working hours are not excessive

· Comply with national and international law or industry standards on employee working hours, whichever affords greater protection for the employee.

· Employees should not be expected to work more than 48 hours a week on a regular basis and, on average, receive at least one day off in every seven days. Overtime should be voluntary and not be demanded on a regular basis and where required it should be remunerated at an appropriate rate or be recoverable as time off in lieu and not exceed 12 hours in any week.

Performance Management

· Provide clear, easily understood disciplinary, grievance and appeal procedures that are lawful and appropriate. Any disciplinary measures should be recorded and suppliers should not seek to deprive employees of their legal or contractual rights.

Wages and Contracts

· Provide wages and benefits at rates that meet at least national legal standards of the country in which the services are performed.

· Provide employees with an easy to read contract of employment clearly explaining wage levels and other benefits. Where employees are unable to read, the contract should be explained to them by a union representative or another appropriate third party.

· Work with us post-award to ensure zero hours contracts are used only when clearly beneficial to both employer and employee.

· Wages should be monetary and not in kind (e.g. goods, vouchers) with no deductions made unless permitted under national law or agreed by the employee, without duress.

· Ensure that relevant criteria or standards for workers to be treated as self-employed are followed.

Training is provided

· Raise employees’ skills through training and access to professional development as befits their role to improve quality and secure greater value for money.

No discrimination

· In relation to age, disability, gender reassignment, marriage/civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation, to practice no discrimination in hiring, compensation, training, promotion, termination or retirement either directly or indirectly.

Mediation and Disputes procedure

· Provide clear and accessible processes for resolving disputes with employees and follow them.

Child labour is eliminated

· Support the elimination of child labour.

· Provide for any child found to be working to attend and remain in quality education until adulthood

· Ensure no children and young persons are employed at night or in hazardous conditions, as defined by the International Labour Organisation.

No inhumane treatment is allowed

· Prohibit physical abuse, the threat of physical abuse, sexual or other harassment, verbal abuse and other forms of coercion.

Operating sustainably and responsibly for your environmental impact on local communities

· Support the reduction in operational carbon emissions

· Support the switch or further use of renewable energy

· Work towards zero avoidable Single Use Plastic use (wherever possible),

· Encourage and participate in environmental programmes with local groups, schools and colleges,

· Encourage voluntary time to the sustainability of local green areas to increase biodiversity and keep green spaces clean.

3. Monitoring compliance with this Code

We aim to work with our suppliers to make improvements and deliver a more ethically-based supply chain for our partners and customers, taking a positive and supportive approach to compliance.

We will do this in two main ways:

1. As a standard agenda item at existing regular contract review meetings, we will note progress and discuss any issues arising. Clear action plans will be put in place to drive further improvement. Where relevant key performance indicators are agreed in relation to specific contracts we will monitor trends.

2. On an annual basis, we will invite a small number of suppliers to share good practice and case studies, and identify initiatives for continuous improvement

Whistleblowing

Our partners each maintain a Whistleblowing Policy for all employees and supplier, see Surrey County Council, East Sussex County Council, Brighton and Hove City Council. Our suppliers are encouraged to use these policies when appropriate, and also to ensure an appropriate policy is in place in their own organisation.

Orbis Supplier Code of Conduct