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Supplier and Business Partner Code of Conduct

Introduction

Enhesa is the leading provider of regulatory and sustainability intelligence. As such, Enhesa’s mission consists of empowering businesses to create a more sustainable future, and that is why we also take action.

Enhesa recognizes that everyone plays a role in conducting responsible business and that is why Enhesa embeds the UN Global compact Principles in its business as well as the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct. These internationally recognized principles and guidelines call upon businesses to abide by and respect the applicable national legislation and regulations as well as international Conventions.

Enhesa expects Suppliers and Business Partners to conduct business in a responsible way, respecting the principles and guidelines set out in this Code of Conduct.

Scope

This Code of Conduct applies to all of our Suppliers and Business Partners and integrates the fundamental international principles and guidelines with the aim of preventing and ending the violation of human rights and the infringement of environmental obligations in supply chains.

 

Purpose

The aim of this Code is to define Enhesa’s principles and requirements of enterprise for its Suppliers and Business Partners when supplying goods or services or when working together. It is also expected that suppliers and partners require at least the same standard for their own suppliers and partners in the following areas.

Responsible Business Conduct

Anti- corruption, bribery, fraud, conflict of interest, and anti-money laundering

Suppliers and Business Partners are expected to comply with national laws and international conventions regarding anti-corruption, -bribery and -fraud; anti-money laundering; and anti-tax evasion.

All forms of corruption, including bribery and embezzlement, are prohibited, and Suppliers and Business Partners need to put in place prevention mechanisms such as company policies, employee training, and specific procedures to identify and prevent such events.

Conflicts of interest should be avoided and any presumption of a conflict of interest should be disclosed to Enhesa without undue delay.

Competition

Suppliers and Business Partners are expected to do business with full respect of rules and regulations ensuring fair competition, as well as complying with applicable anti-trust laws.

Data Protection and privacy

Suppliers and Business Partners must comply with applicable data protection regulations and have a system in place to proactively protect personal data and to prevent data breaches, using best industry practices

Any information relating to customers, employees, or any third party to which Suppliers and Business Partners have access during the business relationship is strictly confidential. No confidential business-related information may be disclosed in violation of contractual agreements and no personal information must be disclosed without the proper consent of the individual in question.

Respect and Protection of intellectual property

Suppliers and Business Partners are expected to comply with applicable intellectual property legislation. Access to Enhesa’s or Enhesa customers’ intellectual property must be legal and must not breach any contractual agreement.

Foreign trade / economic sanctions

A process must be established to ensure Suppliers’ and Business Partners’ transactions with third parties do not violate economic sanctions, import or export controls, or provisions against the suppression of terrorist financing.

Environment

Climate action

Suppliers and Business Partners shall measure and disclose annually their direct and indirect greenhouse gas emissions using an international recognized standard such as the Greenhouse Gas Protocol, a corporate Accounting and Reporting Standard, or ISO 14064. It is recommended that the greenhouse gas emissions inventory is validated by an independent third party.

Additionally, it is expected that Suppliers and Business Partners take steps to reduce their greenhouse gas emissions against credible and ambitious targets, aligned with the Paris Agreement. To that end Suppliers and Business Partners shall have a greenhouse gas emissions reduction target which is science based and validated by a third party (e.g. Science Based Targets Initiative).

Environmental compliance and prevention of pollution

Suppliers and Business Partners must comply with applicable environmental legislation and shall have a system to manage their environmental performance.

Preventing pollution to air, water, and soil must be embedded in their company policies and procedures.

Waste

Suppliers and Business Partners must aim to reduce generation of waste, comply with binding regulations on waste reduction and must align to the strategic principles of the waste hierarchy through prevention, re-use, recycling and recovery, as well as through best practices in environmentally sound waste disposal.

Furthermore, Suppliers and Business Partners are encouraged to embrace circular economy principles, such as eliminating or reducing to the achievable minimum waste and pollution, circulating products and materials, and have policies in place that aim to regenerate nature.

Use of natural resources

Suppliers and Business Partners must make use of natural resources in accordance with legislation. The aim is to use the least possible natural resources.

Human Rights and Labor Practices

Human rights

Suppliers and Business Partners must respect all internationally recognized human rights as set out in the Universal Declaration of Human Rights. This includes safeguarding freedom of expression and opinion and having a zero-tolerance policy on any and all types of discrimination, violence or harassment. Suppliers and Business partners must also ensure equal treatment of all and respect the right to privacy.

No forced labor or modern slavery practices

Suppliers and Business Partners shall not use, promote or allow forced labor in any form, including human trafficking or modern slavery practices. Forced labor includes slave-like practices and various forms of debt bondage, as well as new forms of forced labor, such as human trafficking/modern-slavery, as defined by the International Labor Organization.

Suppliers and Business Partners shall implement due diligence procedures to help identify, prevent and mitigate any instances of modern slavery within their value chain and where necessary include enforceable provisions in agreements and contracts. In addition, Suppliers and Business Partners should have in place a grievance mechanism to allow employees to file complaints on human- or labor rights. The grievance mechanism must be effective in addressing these complaints.

No child labor

Suppliers and Business partners must not employ minors below the legal age to work according to the national laws applicable to the place and by no means in work that interferes with their education or which could put at risk their health, safety, and normal development.

Fair wages and good working conditions

Suppliers and Business Partners must comply with applicable laws and regulations on wages as well as working conditions such as working time, rest periods, annual leave, overtime, and remuneration.

Health and Safety

Suppliers and Business Partners must comply with applicable health- and safety laws and regulations and must ensure effective management of their health and safety performance within their facilities. Regular risk assessments shall be carried to identify hazards, followed by action plans to implement the appropriate measures to eliminate, mitigate, or prevent any risks to health and safety of their employees.

Freedom of association and collective bargaining

Suppliers and partners must respect the right of workers to join trade unions and representative organizations for the purpose of collective bargaining within the applicable national law and international conventions.

Reporting Breaches

Enhesa values cooperation and a culture of speaking up. Suppliers and Business Partners are encouraged to address any deviation from this Code of Conduct. Additionally, suppliers and partners as well as their employees can report any breach through our Whistleblowing procedure.

Enhesa reserves the right to act upon a potential breaches of this Code of Conduct by carrying out training and, with prior agreement from the supplier and partner, conducting audits, or taking measures, such as, suspension or termination of any contract or agreement between Enhesa and the Supplier or Business Partner committing the breach.

References