Supplier Code of Conduct

Supplier Code of Conduct

Introduction

The Harvey Nash Group including its affiliates (‘Harvey Nash’) engages internationally with suppliers for various services. It is important that suppliers operate to a high standard of business ethics and corporate responsibility that matches the approach of our Group and all its affiliates.

When we engage with a supplier, we expect them to adhere to this code of conduct, and to report non-compliance where this is found within their organisation.

Professional Standards and Ethics

Suppliers should have policies and procedures to prevent corruption, bribery and fraud, including ensuring that staff are adequately trained and able to identify malpractice in the workplace.

We expect suppliers to have in place a whistleblowing policy, including where appropriate, external resources to deliver whistleblowing helplines and other means to ensure effective protections for staff to make disclosures about malpractice, fraud, discrimination and exploitation in the workplace.

Suppliers should ensure they have in place disciplinary policies and procedures to ensure high standards of staff behaviour and reduce the likelihood of malpractice occurring.

Data Processing

Harvey Nash is a data controller according to both the EU and UK iterations of the General Data Protection Regulation (‘GDPR’) and will engage certain suppliers to process personal data on our behalf.

Suppliers who are data processors agree to adhere to our standards of data protection and privacy management and provide a high degree of data security to conform to Article 32 of the GDPR, providing necessary information to verify this.

We require all suppliers who are data processors to sign a data processing agreement, (our version or the supplier’s), EU approved standard contractual clauses where applicable due to cross border transfers of personal data, and to provide details of supplementary measures for transfers to the United States where Executive Order 12.333 or FISA 702 may bind the supplier to provide the US authorities access to our personal data.

Labour Standards

Harvey Nash stands against modern slavery, human trafficking and exploited labour in all its forms. We have a duty to ensure our supply chains are free of exploited labour and modern slavery in all forms.

For more information see our Modern Slavery Statement. Our suppliers are expected to have procedures to assess and mitigate the risks of exploited labour in their own supply chains, and to report any such activity to the relevant authorities as necessary.

Suppliers should consider the age of its workers, worker pay and conditions in its own places of business as well as within its own supply chains.

All places of work should meet health and safety standards, be comfortable to work in and meet standards for worker wellbeing. This could include for example, the use of chairs and desks that promote good posture, and computer screen dimming features, but also more fundamentally, access to clean drinking and eating, and toilet facilities.

Staff should not be expected to work an excess of hours to those set out in working time legislation or where other national or regional limits apply, beyond those limits unless they have freely chosen to opt-out (where this is lawful). Pay(including benefits) should meet minimum national legal and industry standards.

Diversity and Inclusion

Suppliers should promote and welcome a diverse and inclusive workplace, providing equal opportunities for all staff.

There is no place for discrimination and suppliers must have strictly enforced policies governing equal opportunities/diversity and inclusion.

Malpractice must be reported, and whistleblowing policies should be provided to ensure this takes place. Harassment or bullying is completely unacceptable and should not be tolerated.

Environment and Sustainability

Suppliers should operate in an environmentally friendly and sustainable manner, meeting all national and regional legislative requirements for greenhouse gas emissions, working to reduce carbon emissions, and dealing with disposing with waste responsibly (including recycling wherever possible).

Chris Tilley, Director and Group Chief Financial Officer
Last updated July 2021

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