Introduction
Wescom Group (Wescom) is committed to the highest standards of integrity and social responsibility, and Wescom expects all Suppliers engaged in providing products and services to Wescom (“Suppliers”) to have, or to make, a similar commitment. The Wescom Supplier Code of Conduct (“Code”) describes Wescom’s expectations for how its Suppliers conduct business. Wescom requires Suppliers to act in accordance with the Code and with all applicable laws and regulations within the geographies in which they operate, and to be open and cooperative with regulators that enforce such laws. Suppliers must impose substantially similar obligations to those set forth herein on their own suppliers, subcontractors, and agents.
Overview
The Code reflects Wescom’s values and sets forth what is required and expected of its Suppliers with respect to the following topics:
Ethics and integrity
Wescom is committed to upholding the highest ethical standards and complying with all applicable laws, rules, and regulations. Wescom requires Suppliers to do the same, and at a minimum, to adhere to the following:
Anti-bribery and anti-corruption
Suppliers must fully comply with all applicable anti-bribery and anti-corruption laws including but not limited to relevant acts such as the U.S. Foreign Corrupt Practices Act or the UK Bribery Act.
Gifts and entertainment
Suppliers must not offer or accept any gift or anything else of value to obtain improper advantages or influence for the Supplier, for Wescom (including Wescom employees and/or their family members and associates), or for any third party. Gifts include but are not limited to benefits, fees, commissions, dividends, cash, gratuities, services, or any inducements.
Non-retaliation for reports of concern
Wescom expects Suppliers to have a policy and process in place for reporting of workplace concerns. The policy and process should be transparent and understandable and must provide protection from retaliation, for both reporters and for those participating in any related investigations.
Trade and sanctions
Suppliers must comply with all applicable trade and sanctions laws and regulations.
Data privacy and security
Wescom treat all personal information (meaning any data from which an individual can be identified, including their name, address, email address, etc.) that is provided to us, or that we obtain, in accordance with the provisions of the Data Protection Act 2018 and the UK General Data Protection Regulation that came into force 1st January 2021.
Under the Data Protection Act 2018 and the UK General Data Protection Regulation, we have a legal duty to protect any data we collect from you, inform you what we use it for, and provide you with access to the data we hold about you. We use leading technologies and encryption software to safeguard your data, and we maintain strict security standards to prevent any unauthorised access to it.
Wescom requires its Suppliers to protect the privacy of individuals, including but not limited to employees, customers, other trade partners, and the security of confidential assets and information.
Confidential assets and information
Suppliers must protect Wescom’s and its clients’ confidential assets and information. Suppliers must design and maintain processes to provide appropriate protections for this information.
Personal information and privacy
Wescom requires Suppliers to protect personal information in compliance with all applicable laws and regulations. Personal information provided by or on behalf of Wescom must only be used, accessed, and disclosed as permitted by the Supplier agreement and in compliance with all applicable laws and regulations.
Inclusion and diversity
Wescom fosters an inclusive culture and believes that diversity should be celebrated, and discrimination of any form will not be tolerated.
Non-discrimination and workplace diversity
Suppliers must comply with all applicable laws and regulations relating to discrimination in hiring, employment practices, and harassment and retaliation.
Suppliers must operate workplaces free of unequal treatment in employment, discrimination, harassment, victimisation, and any other abuse on any grounds including but not limited to age, health status, disability, ethnic or social origin, gender, gender identity, nationality, race, sexual orientation, marital status, parental status, pregnancy, political convictions, religion or beliefs, union affiliation, or veteran status. Unequal treatment includes the payment of unequal remuneration for work of equal value.
Supplier diversity
Wescom’s long-standing commitment to advancing diversity and inclusion includes actively promoting relationships with diverse and underrepresented businesses in Wescom’s strategic sourcing and procurement processes. Wescom searches for Suppliers that similarly value diversity in Suppliers’ own supply chain and that support Wescom’s goals with respect to supplier diversity.
Wescom expects Suppliers to:
(i) utilise search and assessment processes that are both unbiased and transparent,
(ii) ensure that Suppliers’ procurement teams proactively provide diverse businesses with fair access to bids, and
(iii) where practicable, actively seek out and provide opportunities for diverse suppliers to participate in business opportunities.
Employment, working conditions, and human rights
Wescom supports the Ten Principles on human rights, labour, environment, and anti-corruption; the Universal Declaration of Human Rights; the International Labour Organisation’s (ILO) Declaration on Fundamental Principles and Rights at Work; and the UN Guiding Principles on Business and Human Rights. Wescom strives to adhere to the principles set forth in these standards and expects its Suppliers to do the same.
Modern slavery / human trafficking
Wescom does not tolerate slavery, forced labour, or human trafficking in any form at any stage of its supply chain. Suppliers must similarly prohibit all forms of forced labour, child labour, and human trafficking. Wescom requires Suppliers to fully comply with the applicable legal requirements of human rights, slavery, forced labour and human trafficking laws and regulations, such as those outlined in the UK Modern Slavery Act of 2015 and the Australian Modern Slavery Act of 2018, as well as requirements related to supply chain due diligence, such as those outlined in the German Act on Corporate Due Diligence Obligations in Supply Chains. Wescom requires Suppliers to enact practices to ensure compliance with such relevant laws and regulations.
Child labour
Wescom does not tolerate child labour in any form at any stage of its supply chain. The term “child,” unless otherwise specified by applicable laws regarding minimum working age, refers to any person employed below the age of 15 or below the age for completing compulsory education. Workers under the age of 18 should also not be engaged to perform hazardous work.
Human rights
Wescom is committed to respecting human rights in Wescom’s internal operations and requires the same from Suppliers. Wescom does not tolerate human rights violations in any form at any stage of its supply chain. Wescom requires Suppliers to enact practices to maintain a respectful and safe workplace. Wescom requires Suppliers to not tolerate physical violence, threats, corporal punishment, mental coercion, verbal abuse, disrespectful behaviour, bullying, or harassment of any kind.
Freedom of association
Wescom requires Suppliers to respect workers’ rights with respect to freedom of association, including the right to form or join labour or trade unions or to join workers’ councils in accordance with local laws. Workers must be free to engage in these activities without retaliation, harassment, or intimidation.
Employment laws
Suppliers must comply with all applicable wage and labour laws and regulations within the regulatory employment frameworks of their respective countries. Wescom requires Suppliers to adhere to their financial and legal requirements with respect to the provision of a timely and understandable wage statement that includes sufficient information to verify accurate compensation for work for their employees. All use of temporary, dispatch, and outsourced labour shall be in accordance with all applicable laws and regulations and Wescom reserve the right to review this at any time.
Hiring or use of private or public security forces
Suppliers that hire or use private or public security forces for protection must provide sufficient instruction and oversight to avoid torture, cruel, inhumane, or degrading treatment, damages to life or limb of individuals, and the impairment of workers’ freedom of association.
Wellbeing, health, and safety
Wescom expects Suppliers to implement sound health and safety practices across business operations.
Health and safety
Suppliers must comply with all applicable health and safety laws and regulations within the regulatory employment frameworks of their respective countries. Wescom requires Suppliers to adopt practices to minimise health and safety risks, support accident prevention, and ensure a safe workplace for all workers, including employees and/or contractors and other third parties.
A safe and hygienic working environment shall be provided, and occupational health and safety practices, which prevent accidents and injury in the course of work or as a result of the operation of employer facilities, shall be promoted. This includes protection from fire, accidents, and toxic substances. Lighting, heating and ventilation systems should be adequate. Employees should have access at all times to sanitary facilities, which should be adequate, clean and in good working order. The workplace must have safety and health policies that are clearly communicated to the workers. These should apply to employee residential facilities, where provided by employers.
Personal Protective Equipment
Suppliers shall provide the appropriate personal protective equipment, free of charge, to all employees working in any harmful or potentially harmful work area(s). Suppliers must ensure that the personal protective equipment is maintained. Suppliers shall ensure that all employees wear the personal protective equipment when working in, or in close proximity to, any harmful or potentially harmful work area(s).
Training and Records
Suppliers shall ensure all employees are aware of the safety risks associated with the supplier’s production facility. Safety instructions must be available and easily accessible. Employees shall be given the necessary and adequate safety training before operating machinery and other equipment (e.g. as one part of an introduction programme). Suppliers shall keep records of training. Where there is an audit, inspection or concern, Suppliers must agree to provide evidence of such training as and when requested by Wescom in line with Data Protection legislation, within the timeframe directed by Wescom.
First Aid Equipment
The first aid equipment shall be available to all employees. The extent of the first aid equipment shall be based upon the size of the facility, the extent of the activities performed as well as the potential risk of injury. As a general rule, each floor and each building should have at least one first aid box.
First Aid Training
Suppliers shall have at least one first aid trained employee present during working hours covering all shifts.
Environmental, Social and Governance (ESG)
Wescom is committed to integrating Environmental, Social, and Governance (ESG) principles into our investment process and operating philosophy where these efforts can contribute to value creation. This ESG commitment outlines our approach to integrating ESG in our business and investment activities.
Environmental
Suppliers must
• Commit to the protection of the environment through continuously reducing the environmental footprint of the Company.
• Actively explore initiatives to improve their energy efficiency and to develop on-site renewable generation where practical and economic to do so.
• Ensure that the Company’s transport operations utilise fuel-efficient vehicles and explore alternative energy sources where practical and economic to do so.
• Ensure all staff consider the environmental consequences of their actions and seek to minimise the impact where reasonably practicable.
• Consideration and monitoring of key environmental metrics material to the Company, including energy, greenhouse gas emissions, water and waste.
• Comply with all applicable biodiversity laws, regulations and contractual obligations.
• Commit to sustainable operating and commercial practices.
Social
Suppliers must
• Encourage a culture of diversity with the highest ethical standards, respect human rights, promote gender equality and act against incidents and grievances in a systematic manner.
• Support a culture in which all employees are valued and respected, with regular employee engagement to collect feedback.
• Promote the Company’s commitment to the wider society and community development.
• Provide adequate control of health and safety risks in order to prevent any incidents occurring in the workplace or through any of the Company’s operations for their employees, contractors, supply chain and users.
• Report on H&S incidents, promote a continuous improvement philosophy with a zero accidents ambition.
• Commit to provide a work environment where no-one experiences discrimination or disadvantage, free of harassment and bullying, where everyone is treated with dignity and respect in line with core values.
Governance
Suppliers must
• Ensure compliance with regulations and guiding principles governing the protection of human rights, operational and occupational health and safety, environmental and business practices in the jurisdictions in which we operate.
• Identify the relevant legislative and regulatory requirements and ensure that the scope of their business operations is compliant with these requirements.
• Ensure appropriate mitigation measures and procurement of relevant IT software to minimise the risk and impact of cyber security breaches.
• Adopt appropriate measures and guidelines to prevent the incident of fraud and ensure data protection and privacy.
• Ensure availability of whistle blower and grievance processes throughout the organisation where required.
• Adopt the highest standards of governance and ethics of business conduct and practice
Compliance with the Code
Reporting Violations
Suppliers are required to promptly report to Wescom any legal violations or violations of this Code or other Wescom policy.
Suppliers must promptly forward to Wescom, if permitted by law, any subpoenas, regulatory requests, media inquiries, or other third-party requests concerning Wescom.
Wescom’s Rights
Wescom reserves the following rights to ensure and enforce Suppliers’ compliance with the Code.
Supplier selection
Wescom will evaluate Suppliers’ compliance with the Code during the Suppliers’ evaluation, selection, or onboarding process, and/or at any other time during the Supplier’s relationship with Wescom.
Supplier assessment
Supplier assessment supports Wescom’s commitment to broader professional standards, and to managing risks across the supply chain. Supplier assessment is a critical element of due diligence to identify, prevent, mitigate, account for, and enable the remediation of adverse impacts in the supply chain related to topics addressed in this Code, including but not limited to environmental sustainability, human rights, labour, and ethics.
During the Supplier onboarding or Supplier certification process, Suppliers will be required to affirm their acceptance and compliance with the Code. Suppliers may be asked to re-affirm compliance with the Code periodically. Upon request, Suppliers will be required to provide written information on its policies and practices related to compliance with the Code.
In addition, Wescom may at times request that certain Suppliers complete an evidence-based assessment scored by a third party or allow an on-site audit to monitor conformance with and encourage continuous improvement against this Code and other relevant issues.
Wescom is committed to working with Suppliers to improve performance on topics addressed by this Code and may at times request that Suppliers take specific corrective actions related to this Code and other relevant issues. Wescom expects Suppliers to agree to work together to jointly address applicable and relevant topics.
Non-compliance, violations, and termination
Each Supplier shall ensure that all suppliers, subcontractors, and agents it uses to fulfil obligations or commitments to Wescom to comply with the Code or impose substantially similar obligations. Suppliers shall acknowledge that if they become aware of a violation, including its suppliers’, subcontractors’, and agents’ violations, they must report to Wescom and address it. In the event of non-compliance with, or a violation of the Code, Wescom may provide the Supplier a reasonable opportunity to remedy the issue through agreed-upon corrective actions, unless the violation is severe or incurable, or constitutes a violation of law. In the case of violation of this Code or law, Wescom may suspend or terminate its relationship with the Supplier. In the case of a violation of the law, Wescom will also disclose the matter to the appropriate authorities.
Order of Precedence
If a conflict exists between this Code and applicable law, Suppliers must comply with the applicable law. Where this Code requires obligations beyond applicable laws, Suppliers must follow these requirements within the bounds of applicable law.