SHOP DIRECT HOME SHOPPING LIMITED
CODE OF CONDUCT FOR THE SUPPLY OF GOODS AND SERVICES
This document deals with the standards of conduct and behaviour, which we see as fundamental in our procurement of goods and services.
It explains our requirements regarding ethical standards, and although our dealings with suppliers often take place in cultures, which are different from our own and have a different set of norms and values which we respect, certain standards are universally valid and must apply to all of our commercial activities.
In general, all goods and services procured by Shop Direct Home Shopping Limited must be produced and provided in conformity with the United Nations Charter, Chapter 1X, Article 55, governing international economic and social co-operation with specific reference to workers rights and working conditions.
More specifically, this Code adopts the following principles: –
- Supplier Relationships
We seek to develop long-term business relationships with our suppliers who should have a natural respect for our ethical standards in the context of their own particular culture. Our relationships with suppliers are based on the principle of fair, open and honest dealings at all times and in all ways. We specifically require our suppliers to extend the same principle to all those with whom they do business, including employees, sub-contractors and other third parties.
We require all suppliers to translate our Code of Conduct into the appropriate language(s) and to display these translations prominently on notice boards throughout their business and supply chains.
- Employment Conditions
We have specific requirements relating to employment conditions based on a fundamental respect for human rights.
(i) Forced Labour
We will not tolerate forced labour, bonded labour or labour which involves physical or mental abuse. This means that suppliers must not use or threaten workers with any physical punishment, verbal or sexual harassment, or dominate or restrain workers by force, authority or threats.
Workers must not be required to lodge “deposits” or their identity papers with their employer, and they must be free to leave their employer after reasonable notice.
- Child Labour
Exploitation of child labour is totally unacceptable under any circumstances.
Suppliers must not employ any person under the minimum legal working age applicable to their country, and under no circumstances must they employ anybody under the age of 14 years.
Wages and benefits paid for a standard week must meet as a minimum, local legal standards or industry benchmark standards, whichever are the higher. In any event wages should always be enough to meet basic needs and to provide some discretionary income.
All workers shall be provided with written and understandable information about their employment conditions with respect to wages before they enter employment, and about the particulars of their wages for the pay period concerned each time that they are paid.
Deductions from wages as a disciplinary measure shall not be permitted, nor shall any deductions from wages not provided for by national law be permitted without the express permission of the worker concerned. All disciplinary measures should be recorded and available for review by all concerned parties.
- Freedom of Association and the Right to Collective Bargaining
Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.
The supplier will adopt an open attitude towards the activities of trade unions and their organisational activities.
Workers’ representatives must not be discriminated against and must have access to carry out their representative functions in the workplace.
Where the right to freedom of association and collective bargaining is restricted under law, the supplier will facilitate and not hinder the development of parallel means for independent and free association and bargaining.
Suppliers must not discriminate in hiring, compensating, access to training, promotion, termination or retirement based on race, caste, national origin, colour, religion, age, disability, gender, sexual orientation, union membership or political affiliation.
- First Aid
All suppliers must provide adequate provision for first aid and must ensure that formally qualified personnel are available at all times.
- Working Hours
Working hours must comply with national laws and benchmark industry standards, whichever affords the greater protection.
In any event, workers shall not on a regular basis be required to work in excess of 48 hours per week and shall be provided with at least one day off for every seven-day period on average. Overtime shall be voluntary, shall not exceed an average of 12 hours per week, shall not be demanded on a regular basis and shall always be compensated at a premium rate.
- Regular Employment
Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour only contracting, sub-contracting, or home working arrangements.
Equally, obligations must not be avoided through the use of apprenticeship schemes where there is no real intent to import skills or provide regular employment, nor shall any obligations be avoided through the excessive use of fixed term contracts of employment.
- Working Conditions
Suppliers must ensure that they abide by all local laws relating to health and safety in the workplace and residentially where facilities are provided. It is imperative that any amendments to these laws are implemented immediately and that all standards of health and safety are maintained at the forefront of local custom and practice or to benchmark industry standards, whichever affords the greater protection.
A safe and hygienic working environment must be provided.
Adequate steps must be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practical, the causes of hazards inherent in the working environment.
Workers must receive regular and recorded health and safety training, and such training must be repeated for new or reassigned workers.
Access to clean toilet facilities and to potable water, and if appropriate, sanitary facilities for food storage must be provided.
Accommodation where provided, must be located separately from the workplace, be clean, safe and meet the basic needs of the workers.
Responsibility for the observation of the code with regard to health and safety must be assigned to a senior management representative.
Suppliers are expected to adhere to all local laws with respect to protection of the environment.
It is a joint responsibility of Shop Direct Home Shopping Limited and our suppliers to actively work to improve the environment and to proactively pursue any local initiatives that bring about that improvement.
- Disclosure and Inspection
We require suppliers to make full disclosure of all facts and circumstances concerning production, use of sub-contractors and the use of other third parties.
We hold you totally responsible for compliance to this Code and require that monitoring is an integral part of the day-to-day management process.
If any supplier is found to be in breach of this Code of Conduct and is not prepared to take corrective action, we will not hesitate to end our business relationship including the right to cancel any outstanding orders without payment of compensation.
The provisions of this Code constitute minimum and not maximum standards, and this Code should not be used to prevent suppliers from exceeding these standards. Suppliers applying this Code are expected to comply with national and other applicable law, and where the provisions of law and this Code address the same subject, to apply that provision which affords the greater employee protection.
- Bribery and Corruption
We have a zero tolerance approach to bribery and corruption in all our dealings with suppliers. We therefore expect our suppliers to comply with all applicable laws, regulations, codes and sanctions relating to anti-bribery and anti-corruption including but not limited to the UK Bribery Act 2010. Such compliance should include but not be limited to the following:
- A clear statement to all your employees that they are not permitted to pay a bribe or make facilitation payments or other cash payments to government officials to secure or speed up processing of official business;
- The requirement to make charitable and/or sponsorship contributions should not form part of contract negotiations;
- We expect that our suppliers, their owners and senior management have not been involved previously in bribery and corruption related matters;
- All your employees are made aware of relevant anti bribery and anti-corruption legislation.
We expect you to procure compliance with this section if you engage the services of any subcontractors or agents or any other associated party in providing goods or services to us.
We have established an independent whistleblowing line operated by a third party to allow anyone to report any instances of bribery or irregularity and to ensure all allegations are suitably investigated. Please contact InTouch on 0800 258 800, www.intouchfeedback.co.uk/shopdirect-supplier
CODE OF CONDUCT ON GIFTS AND ENTERTAINING
The following guidelines are intended to provide both employees and suppliers with clear direction to ensure their compliance with the Code.
- As a basic principle, any transaction resulting from a business relationship and designed to achieve personal gain to a member of staff or their family is expressly forbidden.
- All employees are forbidden to accept gifts from suppliers. This Policy will not apply to small promotional items with a nominal value such as pens, calendars or diaries.
- The following types of payment are strictly prohibited:
(a) Payments to subsidise private events or activities.
(b) Payment of an employee’s normal business travel and accommodation expenses.
(c) Payment of travel and accommodation expenses for family members.
(d) Cash inducements.
- Any goods or services provided by a supplier or contractor at less than their commercial value must be through a Company approved purchase scheme open to all staff.
- The following types of hospitality may not be offered or accepted:
(a) Tickets for any function at which the donor is not present.
(b) Any type or level of entertainment which is outside the bounds of accepted business hospitality.
(c) Extension of business trips for leisure purposes paid for by the host.
(d) Use of donor’s property.
(e) Visits to any location which do not have a genuine business purpose. The only exceptions are modest hospitality such as business lunches which are viewed as a courtesy of a business relationship and which, at some point, where practical should be reciprocated.
- Employees must not be entered for any competition run, administered or in any way controlled by a supplier.
The Supplier confirms and acknowledges that it has read, understood and will comply with the Shop Direct Home Shopping Limited Codes of Conduct for the Supply of Goods and Services and on Gifts and Entertaining and that: –
( 1 ) Neither the Supplier nor any person, organisation or company acting on its behalf will offer or give any benefit to any employee of the Buyer’s Group or their family.
( 2 ) The Supplier and any other person, organisation or company acting on its behalf, will comply with all relevant principles and rules contained in the Shop Direct Home Shopping Limited Codes of Conduct for the Supply of Goods and Services and on Gifts and Entertaining.
( 3 ) Neither the Supplier nor any other person, organisation or company acting on its behalf, has any personal connection with the Buyer’s Group which may materially influence transactions.
( 4 ) In the event of failure to comply with the aforementioned procedure, Shop Direct Home Shopping Limited will be entitled forthwith to terminate all contractual relationships with the Supplier without payment of compensation but without prejudice to any obligation to pay sums owed to the Supplier prior to the date of termination and that in such circumstances all rights of Shop Direct Home Shopping Limited will be reserved.