We aim for high ethical standards and expect all our employees to operate in an ethical, legally- compliant and professional manner. We expect all our suppliers and potential suppliers to work to the same standards by adhering to this Supplier Code of Conduct and promoting similar standards in their own supply chain.

Business Standards

Suppliers are expected to operate using principles that adhere to industry best practice standards, observe, and remain compliant with all laws, rules, and regulations to which they are subject in all countries in which they operate. The business of our suppliers should be carried out in a transparent, responsible and respectful manner and in a way which maintains high standards of ethical conduct.

Human Rights

Suppliers should have in place a policy recognising and protecting the human rights of their workforce, and those of their suppliers, business partners and communities affected by the suppliers’ operations.

Personnel

Members of the suppliers’ personnel:

• Should be free to choose to work for the supplier and to leave the company upon reasonable notice;

• Must be provided with a clear contract of employment, which complies with local legislation;

• Must be treated in a fair and equal manner and with dignity and respect;

• Should not be subject to any form of discrimination, victimisation, or harassment on the grounds of marital or civil partnership status, sex (including gender reassignment), race (including colour, ethnic and national origin, nationality), disability, sexual orientation, having or not having dependants, religious belief or political opinion, age, or trade union activity;

All applicable laws and industry standards on employee wages, benefits, working hours and minimum age should be adhered to in all countries of operation, without any unauthorised deductions. Suppliers should not engage any persons under the age of to work at night or to carry out hazardous duties. Such engagement should not harm the young person’s education, health or physical, mental, moral or social development.

Modern Slavery and Human Trafficking

Suppliers should ensure compliance with all slavery and human trafficking laws including, but not limited to, the UK Modern Slavery Act 2015. The business operations of the supplier must be free from slavery and human trafficking practices whether in the UK or elsewhere, and this principle should be reflected in their supply chains and external business relationships.

Anti-Bribery and Corruption

All anti-bribery and anti-corruption laws applicable to the supplier’s business must be complied with including, where applicable, the UK Bribery Act 2010. Suppliers must maintain policies and procedures that prohibit and prevent:

• Any offer, promise, gift, or solicitation of an advantage as an inducement or reward to a person for the improper performance of that person’s position or as an attempt to influence a person in that person’s capacity as a public official; and

• Participation in any other form of corrupt practice (such as theft, fraud, conspiracy to defraud, blackmail, bribery, participation in criminal activities and money laundering) under any

Health and Safety

All applicable local and national laws and regulations relating to health and safety should be complied with in all countries in which the supplier operates.

A safe working environment should be provided for all of the supplier’s workforce in accordance with international standards and national laws. Necessary precautions should be taken to prevent accidents and injury to health arising out of or associated with the conduct of the supplier’s business activities.

Suitable policies and procedures relating to health and safety should govern conduct and operations in the workplace, which are either provided to, or easily accessible by the supplier’s workforce. Appropriate training on health and safety should be provided to all members of the supplier’s staff.

Environmental and Social Considerations

Local and national laws and regulations relating to the protection of the environment should be complied with in all countries in which the supplier operates.

The supplier’s business operations should be managed in line with industry best practice standards and in a responsible and sustainable manner.

Any negative impact on the environment as a result of the supplier’s activities should, where possible, be continuously reduced and, where possible, the supplier should encourage recycling and the use of recycled materials.

Employees should be educated about and encouraged to reduce their impact on the environment whilst at work.

Suppliers should strive to improve the communities within which they operate.