Supplier Code of Conduct

1. Scope

1.1 Corporate integrity, responsible sourcing, environmental sustainability and the safety and wellbeing of Workers is of paramount importance to OCL London LIMITED. These core principles are reflected in this Code, which establishes the minimum standards that must be met by any Supplier that supplies products or services to OCL London LIMITED.

1.2 This Code is not legally binding agreement between OCL London LIMITED and the Supplier. However, OCL London LIMITED expects Suppliers to read, understand and take reasonable steps to ensure that their business and supply chain adheres to the principles set out within it.

2. Definitions

2.1 The following definitions apply to this Code:

Agreement means a legally binding contract for the provisions of goods or services that is agreed between OCL London LIMITED and the Supplier; Code means this Supplier Code of Conduct; Modern Slavery Statement means OCL London LIMITED’s modern slavery statement available on our website as amended from to time; Privacy Statement means OCL London LIMITED’s privacy statement available on our website as amended from to time; Representative means a Supplier’s suppliers, agents and subcontractors who are involved in OCL London LIMITED’s supply chain; Supplier means a company, partnership or individual that provides goods or services to OCL London LIMITED; and Worker means any individual who a Supplier employs, hires, engages or otherwise uses to conduct its business.

3. Supplier commitments

3.1 Suppliers shall use reasonable endeavours to: (i) comply with the requirements in this Code as amended from time to time; and (ii) ensure they have appropriate systems in place to ensure continuous compliance and to demonstrate such compliance.

4. Workforce issues

4.1 Modern Slavery: OCL London LIMITED’s Modern Slavery Statement outlines OCL London LIMITED’s commitment to eradicating modern slavery and human trafficking. OCL London LIMITED recognises that these issues can affect any sector or industry and takes it responsibility to be alert to the risks in its business and supply chain seriously.

4.2 Suppliers shall comply with all applicable anti-slavery and human trafficking laws and regulations including, but not limited to, the Modern Slavery Act 2015 in any part of its supply chain. This includes supporting, or engaging or requiring any forced labour, the use of child labour, bonded labour, indentured labour and prison labour.

4.3 Human Rights: Suppliers 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 in any part of its supply chain.

4.4 Equal Opportunities: OCL London LIMITED is committed to being a diverse and inclusive company and Suppliers are expected to ensure that there is no discrimination 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. Suppliers are expected to have suitable policies and practices in-place that promotes equality, inclusion, and diversity, as well as creates a harassment and discrimination free organisation. Suppliers are expected to 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.

4.5 Remuneration: Suppliers are expected to compensate all Workers with wages, including overtime premiums, and benefits that, at a minimum, meet the higher of: (i) the minimum wage and benefits established by applicable law and regulations; (ii) collective agreements; (iii) industry standards; and (iv) an amount sufficient to cover basic living requirements.

4.6 Working Environment: Suppliers are expected to provide a safe, healthy, and sanitary working environment and comply with UK health and safety laws and any other relevant laws and regulations. Suppliers must ensure that their Workers understand and follow health and safety policies, standards and procedures that apply to their work.

5. Data protection and information security

5.1 OCL London LIMITED’s Privacy Statement outlines its privacy commitment and explains how it collects, uses, discloses and protects its customers’ personal information. Suppliers shall comply with all data protection laws and regulations and requirements (including the UK GDPR) when processing any personal data on OCL London LIMITED’s behalf. Suppliers shall have in place appropriate measures to (i) protect the integrity and confidentiality of information (including information belonging to or supplied by OCL London LIMITED) held on its systems (which include physical and online or electronic systems); and (ii) ensure that there is no unauthorised access of the information by third parties, including its Representatives.

6. Environmental responsibility

6.1 Suppliers must minimise the adverse environmental impacts of their operations, products and services. Suppliers shall comply with all applicable environmental laws and regulations, standards and notices from regulators.

7.  Bribery and corruption

7.1 Suppliers must comply with all applicable Laws and codes relating to the prevention of bribery and corruption (including but not limited to the Bribery Act 2010). Suppliers shall not accept, offer, promise, pay, permit or authorise (i) bribes, facilitation payments, kickbacks or illegal political contributions; (ii) money, goods, services, entertainment, employment, contracts or other things of value, in order to obtain or retain improper advantage; or (iii) any other unlawful or improper payments or benefits.

8. Unfair business practices

8.1 Suppliers 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.