Groundsure Limited: Third Party Code of Conduct
- Introduction
At Groundsure Limited (“Groundsure”, “we”, “us” or “our”) we are committed to conducting our business operations in an ethical and legal manner. We expect our suppliers, partners and other organisations we collaborate with (“you”, “your”) to uphold the same high standards of business integrity, data security, ethical conduct, commitment to environmental protection and staff wellbeing, health and safety.
You are expected to be familiar with the business practices of your own suppliers, agents, subcontractors and other third parties and to ensure that these entities operate with integrity and mutual respect and uphold high standards of ethics and behaviour.
By entering into a working relationship with us, you agree to adhere to this Third Party Code of Conduct (“The Code”) and ensure necessary checks are carried out in your own business and operations. The Code outlines the minimum standards of ethical and responsible conduct expected in all aspects of your business and operations.
The Code will be reviewed from time to time in line with our evolving standards. This version is dated 1st October 2024.
2. Compliance with the Code, Laws and Regulations
You are required to comply with all applicable laws and regulations governing your industry and the jurisdictions in which you operate when delivering your service or product to us. This includes, but is not limited to, regulations on environmental protection, health and safety, security, labour practices, anti-money laundering, competition, and corruption.
Groundsure may require you to complete self-assessments or, if proportionate, to allow us or our selected partner, to audit your performance in the topic areas described in The Code. If you are found not to comply with The Code, we will try to work with you to resolve the issue at hand. However, we reserve the right to terminate business relationships if breaches of The Code persist.
3. Business Practice
3.1 Business Integrity
We expect you to conduct business transparently, honestly and fairly. Any involvement in financial crimes, such as bribery, corruption, breach of sanctions, money laundering or other unethical practices is strictly prohibited. Therefore, you must comply with the Bribery Act 2010 or any other relevant local laws.
You must not attempt to influence others, directly or indirectly, through the offer, promise or payment of a bribe or anything else of value to gain or retain a business advantage, regardless of local law or custom. Any and all forms of illegal or inappropriate activity by you, including, but not limited to, corruption, misrepresentation, extortion, embezzlement or bribery are strictly prohibited and may result in the termination of any or all agreements with us.
3.2 Gifts and Hospitality
We recognise that offering or receiving responsible hospitality, gifts or items are sometimes necessary to meet, network and improve relationships with clients, suppliers and contacts This is often recognised as a normal part of business. However, you must not offer or accept gifts or hospitality that could be perceived as a bribe or create a sense of obligation or an incentive to behave in a certain way.
All gifts or hospitality offered or accepted in connection with the performance of your agreement with us must be appropriate, reasonable, proportionate and not aimed at influencing business decisions unfairly.
3.3 Competition
We expect you to compete fairly and always comply with applicable competition and antitrust laws. You must avoid any conduct that prevents, distorts or restricts the free and fair trade of markets. When dealing with competitors, you must not seek, exchange or accept commercially sensitive information (for example: pricing, costs, margins, trading terms, marketing plans or new product launches), agree, discuss or engage in price fixing, bid rigging, limitation of production, coordinating with a view to restricting business, or allocating customers, markets or territories.
3.4 Conflict of Interest
You should avoid engaging in any activity that would conflict, interfere or even create the appearance of a conflict with your business dealings with us. For the purposes of The Code, a conflict of interest occurs when personal interests interfere with objective decision-making.
You must disclose any potential conflicts to us in writing as soon as they arise. Depending on the situation at hand, we may request that you address the conflict of interest by introducing appropriate measures.
3.5 Risk Management
You are expected to have up-to-date contingency plans in place to mitigate any significant risks posed to the services you deliver to us. These plans should cover potential business interruptions such as natural disasters, supply chain disruptions, cyber-attacks, or operational failures. Additionally, you should be prepared to demonstrate these plans to us upon request.
3.6 Prompt Payment
You are required to pay your suppliers in accordance with the agreed terms. Consistent failure to meet your payment demands could jeopardise the stability of your supply chain, which in turn puts the services you provide to us at risk. Prompt payment is critical to maintaining trust with your suppliers and ensuring the uninterrupted delivery of products and services.
4. Data Protection and Information Security
4.1 Confidentiality and Data Protection
You must protect any confidential or proprietary information belonging to Groundsure, our clients or any other third party with whom we partner. This includes ensuring that any non-public information is not disclosed without authorisation, unless required to do so by law. Such disclosures could provide a commercial advantage to our competitors or equally create a commercial disadvantage to us.
4.2 IT Security Measures
You must comply with all data protection laws and requirements (including UK GDPR) when processing personal data on our behalf. You are responsible for implementing appropriate technical and organisational measures:
- to prevent accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to data (which, for these purposes, shall include personal, Groundsure business and client confidential data);
- to protect the integrity and confidentiality of information (including information belonging to or supplied by us) held on your systems (which include physical and online or electronic systems); and
- to ensure that there is no unauthorised access to the information by your own suppliers, agents, subcontractors and other third parties.
If you or your suppliers process Groundsure data outside of the United Kingdom or the European Economic Area, you must notify Groundsure immediately. Additionally, you must outline the specific steps you have taken to ensure the protection of our data in accordance with applicable data protection laws.
5. Ethical Behaviour
5.1 Human Rights
We respect the human rights of all individuals and recognise the importance of promoting individual health and welfare, economic development and political stability, as well as preventing crimes and corruption. We follow all laws and regulations governing our employment practices and the treatment of employees, and we expect you to follow the same standard.
You must comply with the Modern Slavery Act 2015 or any other relevant anti-slavery and human trafficking laws and regulations. You must not, under any circumstance, use, support or engage with any form of forced or involuntary labour in any part of your supply chain.
5.2 Respectful Workplace
We expect you to foster an environment where everyone is treated with respect and dignity and provide equal opportunities in the workplace. All employment-related decisions should be based on performance and ability, in accordance with the Equality Act 2010.
Ensure that you maintain a workplace where harassment of any kind is not tolerated. Harassment includes, but is not limited to, unwanted physical contact; displaying, making or distributing offensive pictures, videos and spoken or written remarks; and any other unwelcome conduct that could create an intimidating or hostile workplace.
You should provide your staff with formal mechanisms to raise workplace concerns and implement working hours and staff wages which are compliant with relevant laws and jurisdiction.
6. Environment, Health and Safety
6.1 Environmental Responsibility
We expect you to minimise damage to the environment in all aspects of your operations and supply chain.
For example, this may include the following reasonable steps:
- Complying with all relevant environmental legislation and regulations.
- Using resources efficiently and reducing waste.
- Managing hazardous materials used in the creation, distribution and use of your products and services appropriately.
- Prioritising sustainable procurement practices.
- Monitoring and planning to reduce emissions and pollution to air, water and soil.
We intend to set a net zero target and as a supplier, we may request you to work with us to reduce the greenhouse gas emissions within our supply chain.
6.2 Health and Safety
We commit to fostering a safe and healthy workplace for our employees and any third party in our business operations.
You are also expected to provide a healthy and safe working environment. At a minimum, you should comply with all relevant legislation involving health and safety. You should take appropriate measures to address safety hazards, prioritise safe working behaviour and provide adequate protective equipment, if necessary.
7. Continual Improvement
Third parties are encouraged to continuously improve their operations, adopting best practices and innovations to enhance efficiency, quality, and sustainability.
8. Communications and Reporting
We expect you to promptly notify us of any questions or concerns regarding The Code, or if you become aware of a situation that violates, or appears to violate, our Code.
Date 1 December 2024