Appendix 6: Responsible Procurement Policy

Policy statement

Our Responsible Procurement Policy is the foundation of our responsible procurement program. It outlines the standards we require of our suppliers, in particular regarding key social, ethical and environmental topics, including modern slavery, discrimination and diversity, and workplace conditions. The policy sets out how we monitor adherence to our requirements and the consequences of a supplier not adhering to all requirements. We review the effectiveness of our policy and its associated procedures on an annual basis.

Supply chain verification and audit

We have implemented a risk-based management system, which helps us to identify and manage potential social, ethical, and environmental risks, including modern slavery risks, across our supply chain. Our approach is to verify our supply chains and audit suppliers.

Desktop risk assessment

Each year we conduct an in-depth risk assessment on a selection of suppliers. We take multiple factors into consideration when deciding which suppliers to focus on, including their industry, location and the risk of human rights abuses (such as modern slavery). We also continually monitor media sources to ensure that we remain alert to potential risks within our supply chains. Suppliers are reassessed regularly, every 1 to 3 years, with the frequency of this reassessment determined by the outcome of the previous risk assessment.

Onsite Assessments & Third-Party Audits

Based on the outcome of the desktop risk assessment, a supplier may be required to undergo an on-site assessment conducted by one of our representatives. The assessment includes content related to modern slavery.

Certification

To ensure that our suppliers respect and enforce our standards, including as regards ethical trading, our key supply contracts require suppliers to comply with all applicable laws and regulations and take appropriate steps to ensure there is no modern slavery in their business.

Accountability

Our policies, apply to all our staff, all joint ventures in which we are involved, and all third parties working on our behalf. All our staff are aware of our policies and their obligations, and certify that they have read, understood and agree to comply with the policy on employment.  We encourage all staff to report any concerns, including those regarding modern slavery, to their Manager.  We do not tolerate any violations of our policies. In the event of violations, we take appropriate disciplinary actions in accordance with applicable law, which may include termination of employment. In addition, we may bring violation of criminal laws to the attention of the appropriate law enforcement authorities. Our Responsible Procurement Policy applies to all our procurement activities.

Responsibility and Effectiveness

We remain committed to upholding human rights and safety in our supply chain and we review our progress and effectiveness in combatting slavery and human trafficking on an annual basis.