Supplier code of conduct
ABOUT THIS CODE
Corporate integrity, responsible sourcing and the safety and wellbeing of workers in the countries where we do business are of paramount importance to Pragmatic. These core principles are reflected in this Supplier Code of Conduct (“Code”), which establishes the minimum standards that must be met by any entity that supplies products or services to Pragmatic.
DEFINITIONS AND SCOPE
In this Code:
“Supplier” means a company, partnership or individual that provides goods or services to one or more members of the PragmatIC group of companies.
“Supply Chain Company” means any of the Supplier’s suppliers, agents, and subcontractors who are involved in PragmatIC’s supply chain.
“Worker” means any individual whom the Supplier employs, hires or engages, or otherwise uses to conduct its business.
WHO MUST COMPLY WITH THIS CODE?
The Supplier shall comply with the Code and shall ensure that its Workers are aware of this Code and comply with it.
The Supplier agrees that:
• it will comply with the requirements in this Code;
• it has appropriate systems in place to ensure and demonstrative continuous compliance; and
• any breach of this Code will allow Pragmatic to terminate its relationship with the Supplier with immediate effect.
1. Compliance with laws and regulations and priority of standards
1.1 In providing goods and/or services to Pragmatic, the Supplier shall, in addition to complying with the standards set out in this Code, comply with all applicable UK laws and regulations (and if applicable, the laws and regulations of any other jurisdiction where it or its Supply Chain Companies operate) including but not limited to the laws and regulations relating to issues addressed in this Code.
1.2 Competing standards shall be addressed as follows:
(a) If there is a conflict between any applicable laws or regulations, the provisions of an agreement with Pragmatic and the provisions of this Code, the Supplier shall meet the most stringent standard.
(b) If there is a conflict between the provisions of an agreement with PragmatIC and the provisions of this Code, the Supplier shall meet the more stringent standard.
2. Updating this Code
Pragmatic has the right to update this Code from time to time. Updates will be posted on our website.
3. Workforce issues
3.1 Slavery, human trafficking and child labour. The Supplier shall comply with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes from time to time in force including but not limited to the UK’s Modern Slavery Act 2015 in any part of its supply chain. This includes, but is not limited to, not supporting or engaging or requiring any forced labour, the use of child labour, bonded labour, indentured labour and prison labour.
3.2 Human rights. The Supplier shall comply with all internationally recognised human rights understood, at a minimum, as those expressed in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work from time to time in force.
3.3 Equal opportunities. PragmatIC is an equal opportunities employer and Suppliers shall not discriminate in hiring, compensation, training, advancement or promotion, termination, retirement or any employment practice based on race, caste, colour, national origin, gender, gender identity, sexual orientation, religion, age, marital or pregnancy status, disability, union membership or political affiliation or any other characteristic other than the Worker’s ability to perform the job subject to any accommodations required or permitted by law.
3.4 Freedom of association and collective bargaining. The Supplier shall respect, and shall not interfere with, the right of Workers to decide whether to lawfully associate with groups of their choice, including the right to form or join trade unions and to engage in collective bargaining.
3.5 Working environment. The Supplier shall provide a safe, healthy, and sanitary working environment and comply with UK health and safety laws and any other relevant laws where it operates. This includes, but is not limited to, implementing general and relevant industry-specific procedures and safeguards to prevent workplace hazards and work-related accidents and injuries. Where such hazards cannot be adequately prevented or controlled, the Supplier shall provide Workers with appropriate personal protective equipment to protect against hazards typically encountered in that scope of work.
3.6 Wages and remuneration. The Supplier must compensate all Workers with wages, including overtime premiums, and benefits that at a minimum meet the higher of:
(a) the minimum wage and benefits established by applicable law;
(b) collective agreements;
(c) industry standards; and
(d) an amount sufficient to cover basic living requirements.
3.7 Whistleblowing, protection of identity and non-retaliation. The Supplier must comply with all applicable laws that protect employees against unlawful discrimination or retaliation as a result of their reporting information regarding corporate fraud or other violations of law, policies, procedures, or codes of practice. The Supplier should encourage its employees to report any suspicion of improper or wrongful activity.
4. Data protection, confidentiality, and information security
4.1 The Supplier shall comply with all applicable privacy and data protection laws and requirements when processing any personal data. The Supplier shall respect and maintain the confidentiality of all confidential information it receives.
4.2 The Supplier shall have in place appropriate measures to:
(a) protect the integrity and confidentiality of information (including information belonging to or supplied by Pragmatic or a member of its group of companies) held on its systems (which include physical and online or electronic systems);
(b) ensure that there is no unauthorised access of the information by third parties, including its Supply Chain Companies;
(c) ensure that hardware, software, data and other electronic files provided to Pragmatic are virus-free (and that the date of virus scanning all such materials is no greater than seven (7) days prior to delivery to Pragmatic); and
(d) acknowledge and comply with Pragmatic’s information security policy as notified to it from time to time, and certify such compliance upon request.
5. Environmental responsibility
5.1 The Supplier shall ensure that:
(a) its operations comply with all applicable environmental laws, including laws and international treaties relating to (but not limited to) waste disposal, emissions, discharges and the handling of hazardous and toxic materials;
(b) the goods it manufactures (including the inputs and components that it incorporates into its goods) comply with all applicable environmental laws and treaties; and
(c) it will only use materials that comply with all applicable environmental laws and treaties and, if applicable, it shall ensure the responsible sourcing of minerals.
5.2 The Supplier shall have in place a suitable environmental management system for managing its environmental risks. As a minimum, the system should include and address the following:
(a) an assessment of the environmental impact of all historical, current and likely future operations;
(b) steps to continuously improve environmental performance, reduce pollution, emissions and waste;
(c) measures to reduce the use of all raw materials, energy and supplies; and
(d) raising awareness and training Workers in environmental matters
6. Bribery and corruption
6.1 The Supplier shall comply with all applicable laws, statutes, codes and regulations relating to the prevention of bribery and corruption (including but not limited to the Bribery Act 2010). To that end, the Supplier shall not accept, offer, promise, pay, permit or authorise:
(a) bribes, facilitation payments, kickbacks or illegal political contributions;
(b) money, goods, services, entertainment, employment, contracts or other things of value, in order to obtain or retain improper advantage; or
(c) any other unlawful or improper payments or benefits.
7. Unfair business practices, advertising, and intellectual property
The Supplier shall comply with all applicable competition laws (including but not limited to the Competition Act 1998), including but not limited to those relating to teaming and information sharing with competitors, price fixing and rigging bids.
The Supplier shall ensure that its advertising and marketing complies with applicable laws, codes of conduct, and standards.
The Supplier shall respect all third-party intellectual property and shall ensure that it complies with third party licensing requirements (including, without limitation, software licence compliance).
8. Procuring and managing Supply Chain Companies
8.1 When assessing the Supplier’s performance against the requirements set out in this paragraph, Pragmatic shall have due regard to the risk profile of the transaction, the Supplier’s ability to comply with the requirements and the consequences where the Supplier fails to meet those requirements.
8.2 With regard to prospective Supply Chain Companies, the Supplier shall carry out appropriate due diligence on prospective Supply Chain Companies that will form part of PragmatIC’s upstream supply chain. At a minimum, the due diligence must include the following:
(a) investigations into prospective Supply Chain Companies’ stance, public statements and actions on human rights, treatment of Workers, bribery, ethical behaviour and environmental outlook;
(b) risk assessments for countries from which materials, components or finished goods are sourced; and
(c) the prospective Supply Chain Company’s ability to meet the requirements and principles that are covered in this Code.
8.3 In its dealings with Supply Chain Companies, the Supplier shall:
(a) ensure that agreements with Supply Chain Companies include provisions that require the Supply Chain Companies to comply with applicable provisions of this Code, having due regard to the risk profile of the transaction, the Supply Chain Company’s ability to comply with those provisions and the consequences where the Supply Chain Company fails to meet those requirements;
(b) ensure that it has measures to monitor that those Supply Chain Companies are complying with those compliance-related provisions and that it has systems in place to address any deficiencies or breaches of those requirements; and
(c) pay its Supply Chain Companies promptly, in accordance with a contractually agreed payment period.
9.1 The Supplier shall implement a system of training for its Workers to ensure that they are aware of the requirements of this Code.
9.2 The Supplier shall keep a record of all training offered and completed by its Workers and shall make a copy of such record available to Pragmatic on request.
10. Certifying compliance and audit
10.1 The Supplier shall provide written confirmation to PragmatIC on request that:
(a) it has appropriate systems in place to monitor its compliance with this Code; and
(b) it is able to comply with this Code for the duration of its relationship with PragmatIC.
10.2 In addition to the written confirmation at paragraph 10.1, PragmatIC may conduct audits and inspections to verify the Supplier’s compliance with this Code.
11. Self-monitoring and reporting breaches
11.1 The Supplier shall monitor its compliance with the Code and shall report any breaches (actual or suspected) of this Code as soon as possible to firstname.lastname@example.org.
11.2 The Supplier shall not retaliate or take disciplinary action against any Worker that has, in good faith, reported breaches of this Code or questionable behaviour, or who has sought advice regarding this Code.
12. Breach, remediation and termination
12.1 Where Pragmatic or a member of its group of companies becomes aware of a breach of this Code by the Supplier or its Workers, Pragmatic (or the relevant group company) may either:
(a) immediately terminate its business relationship with the Supplier (including any contracts); or
(b) require the Supplier to produce a remediation plan specifying the actions that the Supplier will take that will lead to compliance with the Code, and present it to Pragmatic within five (5) days of being requested to do so (unless a longer period is agreed in writing with Pragmatic). If the Supplier fails to produce the remediation plan within this timeframe or fails to implement it within a reasonable time, Pragmatic may immediately terminate its business relationship with the Supplier (including any contracts).
12.2 Where Pragmatic or a member of its group of companies becomes aware that a Supply Chain Company has been involved in an incident (or incidents) that would constitute a breach of any of the requirements under this Code, were they bound directly by it, Pragmatic (or the relevant group company) may either:
(a) terminate its business relationship with the Supplier (including any contracts); or
(b) require the Supplier to remedy that incident (or incidents) with that Supply Chain Company. If the Supplier is not able to remedy such incident with that Supply Chain Company within a reasonable time, PragmatIC may immediately terminate its business relationship with the Supplier (including any contracts).
Last updated: 11th November 2022