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Third Party Code of Conduct

Introduction

Groundsure (“We”) are committed to conducting business in an ethical and legal manner. We expect that our partners and third parties maintain similar standards to Groundsure (“us“), with the same focus on ethics, integrity, the environment, and social responsibility that we value. Groundsure’s (“Our“) partners and third parties are expected to conduct business with integrity and mutual respect and to uphold high standards of ethics and behaviour.

Our Third-Party Code of Business Conduct and Ethics (“Code of Conduct”) describes the minimum standards of ethical and responsible conduct that we require of our partners and third parties. Third parties include, suppliers, subcontractors and any other third parties that work for or with us. Any third party providing a service or product to us is subject to this Code of Conduct. Failure to follow any of the provisions of this Code of Conduct can result in termination for cause of any and all agreements with us.

Third parties are also expected to be familiar with the business practices of their own suppliers, agents, subcontractors and other third parties, and to ensure that these entities also operate with integrity and mutual respect and to uphold high standards of ethics and behaviour

Compliance with Laws and Regulations

All third parties must comply with all applicable laws and regulations applicable to their industry and the jurisdictions in which they operate. This includes, but is not limited to, laws and regulations relating to environmental and occupational health and safety, security, trade law compliance, labour practices, anti-money laundering, competition, and corruption.

Compliance

We reserve the right to periodically review any third party’s compliance with this Code of Conduct, including by conducting questionnaire based assessments. In exceptional cases, in response to reasonable concerns, we reserve the right to perform a more detailed review of any third party’s environmental, supply chain, labour practices, and other business practices described in this Code of Conduct. 

Ethics and Standards of Conduct

Business Integrity

Any and all forms of illegal or inappropriate activity by a Groundsure third party, including, but not limited to, corruption, misrepresentation, extortion, embezzlement or bribery, are strictly prohibited and can result in the termination of any or all agreements with us.

Confidential Information

Groundsure’s third parties must protect any confidential or proprietary information that belongs to us or any other third party with whom we partner. This includes any non-public information that might provide a commercial advantage to Groundsure’s competitors or equally create a commercial disadvantage to us if disclosed. 

Data Protection and Information Security

Third parties shall comply with all data protection laws and requirements (including UK GDPR) when processing any personal data on our behalf. Third parties shall have in place appropriate technical and organisational measures (to include information security measures):

  • Designed 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 its systems (which include physical and online or electronic systems); and
  • To ensure that there is no unauthorised access of the information by your own suppliers, agents, subcontractors and other third parties. 
Conflicts of Interest

Third parties should avoid engaging in any activity that would conflict, interfere or even create the appearance of a conflict with their business with us. Third parties must disclose any potential conflicts to us in writing as soon as they recognise them. 

Gifts and Hospitality

We recognise that offering or receiving responsible hospitality to meet, network and improve relationships with clients, suppliers and contacts is often recognised as a normal part of business, however it is illegal to receive something (including gifts and hospitality) which may be perceived as a bribe or where it may create a feeling of obligation or an incentive to behave in a certain way.     

Third Parties (“You“) must ensure that any gifts or hospitality offered or accepted in connection with the performance of your agreement with Groundsure are appropriate, reasonable, proportionate and not for the purposes of achieving, or being seen to achieve, undue influence.

Bribery and Competition

Bribery and Corruption

We expect third parties to conduct business transparently, honestly and fairly. To that end, third parties must not engage in any form of financial crime, including bribery, corruption, facilitation of tax evasion, breach of sanctions, money laundering or other unethical practices and comply with the Bribery Act 2010 or any other relevant local law . 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. 

Competition

We expect third parties to compete fairly and always comply with applicable competition and antitrust laws. You should 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, limit production, coordinating with a view to restricting business, or allocating customers, markets or territories.

Labour Practices

Human Rights

We are committed to respecting the human rights of all individuals and recognizes the importance of promoting individual health and welfare, economic development and political stability, and preventing crimes and corruption. We follow all laws and regulations governing its employment practices and acceptable treatment of employees, and we expect our third parties to follow the same standard.

Third parties should not use, support or engage with any form of forced or involuntary labour in any part of its supply chain and comply with the Modern Slavery Act 2015 or any other relevant anti-slavery and human trafficking laws and regulations.

Respectful Workplace

We expect third parties to foster an environment where everyone is treated with respect and dignity, and provide an equal opportunities workplace where employment-related decisions are based on performance and ability. 

We expect our third parties to maintain a workplace where no harassment of any kind is 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.

Third parties should provide their staff with mechanisms to raise workplace concerns, implement working hours and pay their staff wages which are compliant with relevant laws and jurisdiction.

Environmental Health and Safety

Environmental Compliance

Our third parties must maintain a workplace that complies with all applicable laws and regulations, regarding operational and environmental responsibility, including the use, storage and disposal of any hazardous and toxic materials. 

We encourage our third-party partners to employ business processes that manage its environmental risks and reduce the third party’s adverse impact on the environment by minimising waste and conserving natural resources.

Third parties should have regard to the impact that their business has on the environment and take reasonable measures to reduce or offset any damage to the environment.

Health and Safety

We expect third parties to foster a safe, healthy and sanitary workplace for all. Third parties should take appropriate measures to address safety hazards, comply with all applicable laws and regulations, involving health and safety, and promote safe working habits.

Communications and Reporting

We expects third parties to promptly notify us of any questions or concerns regarding the Code of Conduct, or if they become aware of a situation that violates, or appears to violate, our Code of Conduct.

We have the right to modify this Code of Conduct from time to time on written notice.

Last Revised – January 2023