Procurement Policy and Supplier Code of Conduct
Our Procurement Policy
The Procurement Policy and Supplier Code of Conduct outline the Relocately ethos, our aspirations for how our business operates and the expectations we have of our suppliers and partners. It is integral to our business strategy and success that we have a positive impact when dealing with our customers, suppliers, employees and wider society wherever and whenever we do business.
As such, the Procurement Policy describes the company's commitment to ensuring that all procurement activities carried out by Relocately are conducted in an honest, competitive, fair and transparent manner, and that incumbent suppliers are appropriately managed on an ongoing basis
Understanding and commitment
ensure consistent understanding of business ethics across the organisation at all levels;
continually enhance knowledge of all relevant laws and regulations in the countries in which the organisation operates, either directly or indirectly
commit to eradicating unethical business practices including bribery, fraud, corruption and human rights abuses, such as modern slavery and child labour.
conduct all business relationships with respect, honesty and integrity, and avoid causing harm to others as a result of business decisions;
treat all stakeholders fairly and impartially, without discrimination or favor
avoid any business practices which might bring the procurement profession into disrepute.
use procurement strategies to drive unethical practices from the supply chain;
ensure procurement decisions minimise any negative impact on human rights and the environment whilst endeavouring to maximise value and service levels;
put ethical policies and procedures in place, regularly monitored and updated, and ensure compliance;
mandate the education and training of all staff involved in sourcing, supplier selection and supplier management to professional standards;
practise due diligence in all business undertakings.
Relocately leadership will:
accept accountability and take ownership of business ethics;
foster a culture of leadership by example;
take steps to prevent, report and remedy unethical practices;
provide a safe environment for the reporting of unethical practices.
Relocately is committed to working with our suppliers to ensure that the principles set out in our Procurement Policy and Standard are met and that the Supplier Code of Conduct is adhered to by all of our suppliers and, as far as possible, throughout the supply chain.
Supplier Code of Conduct
1.1 The Supplier Code of Conduct sets out our expectations of suppliers, generally in terms of business practices, and specifically with regard to:
ethical supply and people practices including diversity and inclusion;
prevention of financial crime;
data protection and information security;
health and safety.
1.2 Relocately procures services from a large number of suppliers, internationally, and we recognise that each supplier may have their own standards and ambitions for the above. We expect all of our suppliers to meet the requirements set out in legislation, regulation, and good industry practice and to ensure that their suppliers do the same.
1.3 In combination, the Procurement Policy and Supplier Code of Conduct set out the commitments of Relocately and expectations we have of our suppliers, and the results we aim to achieve by working together. No organisation that shares our values should be precluded from working with Relocately. Working together across our supply chains, we will encourage and enable sustainability and long-term positive impacts on the global community.
1.4 The Procurement Policy and Supplier Code of Conduct are reviewed periodically (annually as a minimum), and will be revised as necessary to ensure that this document helps us become a more sustainable business, delivering continuous improvement for our clients, our stakeholders and the communities in which we operate.
1.5 Changes to the Supplier Code of Conduct will be notified to all suppliers from time to time and all suppliers shall comply with new requirements that are relevant to their business, as soon as practicable.
2 General Requirements
2.1 General requirements for all suppliers
2.1.1 Relocately expects its suppliers to behave ethically, apply high standards of corporate conduct and to fully comply with all relevant law.
2.1.2 Relocately has a zero tolerance approach to improper business conduct of any sort and all our suppliers are required to confirm that their business practices meet the standards set out in this Supplier Code of Conduct, as a minimum.
2.2 General Requirements for prospective suppliers
2.2.1 Prospective suppliers shall keep all pre-contract data, negotiations and tender progress strictly confidential and shall, at our request, enter into a more detailed non-disclosure agreement.
2.2.2 Prior to entering into any contract, Relocately carries out due diligence on each supplier in order to comply with relevant law and to assess suitability of the supplier to meet our business needs. Suppliers must co-operate fully and promptly with due diligence enquiries. Suppliers may be required, at the discretion of and where deemed appropriate by Relocately, to share exit plans, business continuity plans, disaster recovery plans and/or other similar documents when entering into contract or where tendering, in order that the firm can appropriately plan for and mitigate against potential future issues.
2.2.3 All activity between Relocately and potential suppliers will be conducted with integrity. Contracts will be awarded based on merit. Hospitality or other inducements which seek to encourage or reward a decision must not be offered to our employees or any other individuals associated with Relocately.
2.3 General requirements for current suppliers
2.3.1 Where Relocately enters into a contract with a supplier, the relationship will be governed by agreed terms and conditions. In addition, the supplier shall comply with the requirements of this Supplier Code of Conduct only to the extent that such requirements are:
not already expressly agreed in the contract between us; and
relevant to the supplier and/or the services being provided, given all the circumstances.
2.3.2 It is recommended that suppliers' policies and procedures are reviewed regularly to ensure that changes in regulations, technology, and industry best practice are captured, as well as changes within the organisation. Regular review will ensure that sound governance is encouraged and instilled which will demonstrate continuous improvement.
3 Ethical Supply – people practices
3.1 Suppliers shall respect the human rights of their employees, other personnel and local communities and shall comply with all relevant law pertaining to human rights.
3.2 Suppliers shall take appropriate steps to identify and eradicate modern slavery, in all its forms, including slavery, servitude, forced and compulsory labour and human trafficking, whether of adults or children, all forms of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.
3.3 Suppliers shall implement appropriate due diligence practices and provide training to identify the risk of and/or actual instances of modern slavery.
3.4 Suppliers shall document all the steps taken to tackle modern slavery and shall, on request, provide a report to Relocately setting out all policies and procedures implemented, including due diligence undertaken, risk areas identified, how risks have been mitigated, training provided and consequences for third parties of non- compliance.
3.5 All suppliers shall ensure that, within their own organizations and throughout the supply chain:
child labour shall not be used and relevant law pertaining to minimum working age legislation shall be strictly complied with;
forced labour, in any form, shall not be used and supplier workers shall not be required to lodge papers or deposits on starting work; and
physical abuse, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation or inhumane practice shall not take place, whether as part of a disciplinary process or otherwise, and shall be prohibited.
3.6 Relocately is committed to a policy of equality opportunity in our employment practices in order to ensure that no job applicant, employee or any other individual is discriminated against and less fairly treated because of gender or marital status, race (including colour, castes, nationality or ethnic origin), disability, religion, age, sexual orientation, union membership, political affiliation, being a member of a protected class under international human rights law or any other conditions not justified in relevant law or relevant to the performance of the job.
3.7 Relocately is committed to creating an inclusive workplace where individuals are able to be themselves, irrespective of their gender, race (including colour, castes, nationality or ethnic origin), disability, religion, age and sexual orientation. As such, we encourage our suppliers to be committed to the same principles and encourage them to have policies in place to promote diversity within their own organizations and supply chain.
3.8 All terms and conditions of employment must be made clear to the workforce in a manner which is easily understood by that workforce. The supplier shall ensure that:
employee wages comply with relevant law pertaining to the minimum wage and that minimum wage or the prevailing industry wage (whichever is higher) shall be paid to workers as a minimum;
each employee shall be provided with all benefits under relevant law and no non- statutory deductions shall be made from wages;
the employment terms of young workers must adhere to International Labour Organization Standards, the OECD Guidelines for Multinational Enterprises and relevant law;
relevant law pertaining to working time and the maximum hours of work permitted to be undertaken by any employee in any period of time, must be complied with, and any overtime shall be on a voluntary basis and at manageable levels;
all employees, whether local or migrant, have the right and ability to leave employment when they choose; and
obligations to direct employees under relevant law arising from regular employment shall not be avoided through the use of labour-only contracting, sub- contracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment.
3.9 Suppliers must provide workers with clear, fair and uniformly applied disciplinary practices and grievance procedures.
3.10 Suppliers shall recognize the rights of workers to form or join trade unions which are free to meet without hindrance and to bargain collectively. Suppliers shall adopt an open attitude towards the activities of trade unions and where it is not practicable for unions to operate, recognize other means of association, such as Works Councils.
3.11 Training, including that required under relevant law and industry specific training (whether mandatory or best practice) shall be provided by Suppliers to their workers and regular refresher training will be provided on a timely basis.
3.12 Suppliers shall provide sufficient evidence, promptly upon on request from Relocately, that they have implemented appropriate procedures to manage all labour related issues within their supply chain to ensure that they comply with relevant law and this Code of Conduct.
3.13 Suppliers shall demonstrate, through supply chain transparency, that people are dealt with ethically and lawfully and that goods are traded fairly and meet the environmental aims detailed in this Code of Conduct.
4 Prevention of Financial Crime
4.1 In this section, Financial Crime shall include bribery, corruption, money laundering, terrorist financing, tax evasion and the failure to prevent the criminal facilitation of tax evasion.
4.2 Suppliers shall comply with all relevant law pertaining to Financial Crime and shall not do or omit to do anything which would cause Relocately to be in breach of such relevant law.
4.3 With regard to anti-bribery and anti-corruption measures, suppliers shall put in place an appropriate policy and procedures which prohibit workers from:
the offering, giving, soliciting or receiving of a bribe at any time (including the making of facilitation payments or the bribery of public officials) whether for the benefit of the supplier or for the benefit of the worker, a member of the worker's family, friends, associates or acquaintances;
the use of a gift or hospitality to induce a fraud or other wrongdoing to secure a personal or business benefit;
the use of sponsorship or advertising agreements to exercise undue influence; or unapproved or unauthorized charitable donations or political donations of any kind.
4.4 With regard to anti-money laundering and counter terrorist financing measures, suppliers shall put in place an appropriate policy and procedures which:
verify the legitimate origin of goods and services within their supply chain; and
verify the identity and the legitimate nature of the businesses with which the supplier contracts.
4.5 With regard to tax evasion, suppliers shall have adopted a tax strategy that demonstrates a willingness to pay the right amount of tax, in the right place at the right time.
4.6 With regard to measures to prevent the criminal facilitation of tax evasion, suppliers shall put in place an appropriate policy and procedures which:
regularly assess the opportunity, motive and means within their business for the criminal facilitation of tax evasion;
implement reasonable preventative measures by developing procedures that are appropriate to the mitigate the identified risks; and
effectively communicate the expectations of management, being that compliance with such policy and procedures is mandatory and that the business takes a zero- tolerance approach to any breach.
4.7 As part of the prevention, identification and detection of Financial Crime issues, suppliers shall implement mandatory training for workers, appropriate oversight, regular risk assessments, appropriate due diligence and procedural audits.
4.8 Suppliers shall encourage workers to promptly report to an appropriate senior manager if they know of or suspect any business activity that is in contravention of the supplier's Financial Crime procedures and shall implement disciplinary action for any worker failing to comply with such procedures.
4.9 Suppliers shall make sure that workers do not suffer any adverse consequences for making a report under the Financial Crime policies, whistleblowing or refusing to pay a bribe, even if such refusal may result in the supplier losing business.
4.10 The supplier shall keep sufficiently detailed records relating to the identification and prevention of Financial Crime and shall promptly notify Relocately upon becoming aware of any instance or suspected instance of Financial Crime connected to the business relationship between Relocately and the supplier.
5 Environmental Responsibility
5.1 Suppliers shall comply with all relevant law pertaining to the environment and shall operate their business in an environmentally responsible way.
5.2 Suppliers shall take a proactive approach to working with Relocately towards reducing our environmental impact.
5.3 Suppliers shall:
adopt such practices and utilize such systems that minimise the use of resources e.g. water efficiency, energy efficiency;
ensure that it and its suppliers use environmentally friendly working practices, tools and equipment, consumables and replacement parts, wherever possible;
ensure where practicable that all consumables originate from a sustainable or recycled source;
ensure there are facilities or arrangements in place, either directly or through its suppliers to ensure we can return used packaging for recycling, reuse or environmentally friendly disposal; and
ensure that any hazardous or toxic waste that is produced must be properly identified and disposed of by licensed and competent bodies via authorized and/or licensed means.
5.4 Suppliers shall have a written environmental / sustainability policy appropriate to the size and nature of their operation which addresses preventing, mitigating and controlling serious environmental and health impacts from their operations. This policy will be:
signed and dated by senior management; and
provided to Relocately on request.
5.5 Suppliers shall carry out annual reviews and audits of its environmental performance and the environmental performance of its suppliers and shall keep a record of all findings and any remedial action or improvements in processes or procedures that can be made to reduce any negative environmental impact. Such records shall be provided to Relocately on request.
5.6 Suppliers shall identify and make know to us, a senior manager within their organization who shall have overall responsibility for the supplier's environmental performance.
5.7 Suppliers must have an effective internal environmental management program, with adequately trained staff, responsible for environmental impact control and collating and communicating data on key environmental indicators.
6 Data Protection and Information Security
6.1 Suppliers shall comply with all relevant law pertaining to data protection and shall not do or omit to do anything which would cause Relocately to be in breach of such relevant law.
6.2 To the extent that the supplier will be processing personal data on behalf of Relocately, it will do so only in accordance with the terms set out in Appendix 1.
7 Health & Safety Code of Conduct
7.1 Relocately acknowledges and accepts our responsibilities under relevant law for securing and maintaining high standards of health, safety and welfare for all who are directly employed or contracted to work.
7.2 Health and Safety in the workplace shall be the responsibility of a senior member of the Supplier's management.
Definitions and Interpretation
In this Procurement Policy & Supplier Code of Conduct, the following words shall have the following meanings:
Relocately or ‘we’ : Any one or more of the entities comprising our organization, and any other entity owned or controlled by Relocately
Contract : Any one or more of the entities comprising our organization, and any other entity owned or controlled by Relocately
Data Protection Law : Relevant law applicable to data protection, the processing of personal data and privacy in force anywhere in the world from time to time including GDPR and the Data Protection Act 2018
GDPR : The General Data Protection Regulations ((EU) 2016/679) and Controller, Processor, Data Subject, Personal Data, process/processing/processed, Personal Data Breach, Data Protection Officer take the meaning given to each of these terms in the GDPR
Processing Notice : Information required to be provided to a Data Subject where Personal Data has been collected from or obtained in respect of such Data Subject, as set out in Articles 13 and 14 of the GDPR or any similar requirement under Data Protection Law
Relevant law : In any jurisdiction in which Icon or the Supplier provides services, applicable: (a) common law; (b) case law; (c) legislation, enactment, statute, statutory instrument, regulation, by-law; ordinance or subordinate legislation; and (d) binding statutory, industry or other professional regulations, rules, codes, guidance, regulations, practice directions, instruments and provisions
Services : The services provided under the Contract
Supplier : The person, company or entity supplying, or wishing to supply, goods or services to the customer and / or Relocately
Appendix 1 - Data Protection Definitions
Data Loss Event: any event that results, or may result, in unauthorised access to Personal Data held by the Supplier under the Contract, and/or actual or potential loss and/or destruction of Personal Data in breach of the Contract, including any Personal Data Breach.
Data Protection Impact Assessment: an assessment by Relocately of the impact of the envisaged Processing on the protection of Personal Data.
Data Subject Access Request: a request made by, or on behalf of, a Data Subject in accordance with rights granted pursuant to the Data Protection Law to access their Personal Data.
Personal Data Record means the record setting out the subject-matter and duration of the Processing, the nature and purpose of the Processing, the type of Personal Data and categories of data Subjects.
Protective Measures: appropriate technical and organizational measures which may include: pseudonymising and encrypting Personal Data, ensuring confidentiality, integrity, availability and resilience of systems and services, ensuring that availability of and access to Personal Data can be restored in a timely manner after an incident, and regularly assessing and evaluating the effectiveness of such measures adopted by it.
Sub-processor means any third party appointed to process Personal Data on behalf of the Supplier related to the Contract
The Parties acknowledge that the Supplier will be processing Personal Data on behalf of Relocately in connection with the Services. The only processing that the Supplier is authorised to do is detailed in the Personal Data Record and may not be determined by the Supplier.
The Supplier shall notify Relocately immediately if it considers that any of Relocately's instructions infringe Data Protection Law.
The Supplier shall provide all reasonable assistance to Relocately in the preparation of any Data Protection Impact Assessment prior to commencing any processing. Such assistance may, at the discretion of Relocately, include:
systematic description of the envisaged processing operations and the purpose of the processing;
an assessment of the necessity and proportionality of the processing operations in relation to the Services;
an assessment of the risks to the rights and freedoms of Data Subjects; and
the measures envisaged to address the risks, including safeguards, security measures and mechanisms to ensure the protection of the Personal Data to be processed.
The Supplier shall, in relation to any Personal Data processed in connection with its obligations under the Contract:
process such Personal Data only in accordance with this Appendix 1, unless the Supplier is required to do otherwise by Relevant Law. If it is so required the Supplier shall promptly notify Relocately before processing the Personal Data, unless notification is prohibited by Relevant Law;
ensure that it has in place Protective Measures, which have been reviewed and approved by Relocately as appropriate to protect against a Data Loss Event, having taken account of the:
nature of the data to be protected;
harm that might result from a Data Loss Event; o state of technological development; and
cost of implementing any measures.
The Supplier shall ensure that:
Supplier personnel do not process Personal Data except in accordance with the Contract (and in particular this Appendix 1);
it takes all reasonable steps to ensure the reliability and integrity of any Supplier
personnel who have access to the Personal Data and ensure that they:
are aware of and comply with the Supplier’s duties under this paragraph;
are subject to appropriate confidentiality undertakings with the Supplier or any Sub- processor;
are informed of the confidential nature of the Personal Data and do not publish, disclose or divulge any of the Personal Data to any third party unless directed in writing to do so by Relocately or as otherwise permitted by the Contract; and
have undergone adequate training in the use, care, protection and handling of Personal Data; and
not transfer Personal Data outside of the EU unless the prior written consent of Relocately has been obtained and the following conditions are fulfilled:
Relocately or the Supplier has provided appropriate safeguards in relation to the transfer as determined by Relocately;
the Data Subject has enforceable rights and effective legal remedies;
the Supplier complies with its obligations under the Data Protection Law by providing an
adequate level of protection to any Personal Data that is transferred (or, if it is not so bound, uses its best endeavours to assist Relocately in meeting its obligations); and
the Supplier complies with any reasonable instructions notified to it in advance by Relocately
with respect to the processing of the Personal Data;
at the written direction of Relocately, delete or return Personal Data (and any copies of it) to Relocately on termination of the Contract unless the Supplier is required by Relevant Law to retain the Personal Data.
The Supplier shall notify Relocately immediately if it:
receives a Data Subject Access Request (or purported Data Subject Access Request);
receives a request to rectify, block or erase any Personal Data;
receives any other request, complaint or communication relating to either Party's obligations under Data Protection Law;
receives any communication from any regulatory authority in connection with Personal Data processed under the Contract;
receives a request from any third Party for disclosure of Personal Data where compliance with such request is required or purported to be required by Relevant Law; or • becomes aware of a Data Loss Event.
The Supplier shall maintain complete and accurate records and information to demonstrate its compliance with this Appendix 1.
The Supplier shall allow for audits of its Data Processing activity by Relocately or Relocately’s designated auditor.
The Supplier shall designate a Data Protection Officer if required by the Data Protection Law.
Before allowing any Sub-contractor to process any Personal Data related to the Contract, the Supplier must:
notify Relocately in writing of the intended Sub-contractor and processing;
obtain the written consent of Relocately;
enter into a written agreement with the Sub-contractor which give effect to the terms set
out in this Appendix 1 such that they apply to the Sub-contractor; and
provide Relocately with such information regarding the Sub-contractor as Relocately may reasonably require.
The Supplier shall remain fully liable for all acts or omissions of any Sub-contractor.
The Parties agree to take account of any guidance issued by the respective regulatory authority. Relocately may, on not less than 30 Working Days’ notice to the Supplier, amend the Contract to ensure that it complies with any guidance issued by the Information Commissioner’s Office.