Pat Druken, Chief Operating Officer
‘At Bell Procurement Management we hold ourselves to high standards and these standards reflect our internal values and the expectations of our external stakeholders such as customers, suppliers, and the public. We seek relationships with suppliers who share a common commitment to comply with applicable laws and regulations, behave ethically, sustainably and with integrity and amongst other things promote the safety, health and well-being of employees.
Our partners are essential contributors to our success and this Charter helps you to understand the standards that we hold ourselves to and our expectations of you.
We look forward to welcoming you into our rapidly growing partnership network.’
This Charter is formally incorporated into our contracts with all our suppliers. To the extent that our contractual arrangements contain more detailed requirements in respect of any principles covered in this Charter, this Charter is intended to supplement (and not override) those contractual obligations.
In some circumstances, we may require our suppliers to complete self-assessments and/or an annual declaration which confirms their compliance with this Charter. Our suppliers must promptly notify us if they, or another party in their supply chain, become aware or reasonably suspects that it is unable to comply with the principles in this Charter.
If a supplier, or another party in its supply chain, is unable to, or fails to, comply with this Charter, we will discuss this issue with the supplier and may require the supplier to take such steps as we consider necessary to address the impact of, and remediate, the non-compliance.
If local legislation, regulation, or laws provide a higher level of protection than which is included in this Charter, the local legislation will take precedence. We reserve the right to amend the Charter from time to time.
Compliance with Laws
We expect our suppliers to comply with all relevant laws, codes and regulations, and to act in an ethical manner.
As such, suppliers must:
- Comply with all applicable laws, codes and regulations wherever they operate;
- Promptly notify us of any significant criminal or civil legal actions brought against them; and
- Promptly notify us of any fines or administrative sanctions brought against them which relate in any way to the requirements set out in this Charter.
Health and Safety
Our suppliers must maintain a safe workplace and implement continuous improvement and management systems to ensure compliance and effective controls. We may require suppliers to demonstrate that they have relevant practices and policies in place.
We expect our suppliers to take all reasonable steps to protect the emotional and physical health and wellbeing of their workforce and provide all necessary supervision, training, instruction, equipment, appropriate flexible working arrangements, and information to their workforce and consult on issues that may affect health and safety. Suppliers must comply with local site rules for visits, deliveries or provision of services.
Environment and Sustainability
Suppliers are expected to operate in a sustainable and environmentally responsible manner, complying with all regulations, reporting requirements and/or laws that are best practice for their industry. We may require suppliers to demonstrate that they have relevant practices and policies in place.
Suppliers are expected to support the delivery of our environmental, social and governance (ESG) objectives by promoting socially responsible, sustainable procurement and supply chain management practices, and by agreeing to integrate ESG considerations into their design and/or provision of services.
We encourage our suppliers to engage the community to help foster social and economic development, contributing to the sustainability of the communities in which they operate and to offer solutions that improve the resilience of our operations, whilst also understanding how their own business needs to adapt to a changing climate.
Suppliers are expected to treat people with dignity and respect. As such, they shall:
- Comply with our Anti-Slavery Human Trafficking Policy.
- Not engage in any form of human trafficking, procure commercial sex acts or use forced labour.
- Not use misleading or fraudulent recruiting practices, use recruiters that do not comply with local labour laws in the country where the recruiting takes place, expect workers to pay for a job, provide housing that does not meet the standards of the country where work is performed, or fail to provide an employment contract or recruitment agreement if required by law.
- Ensure that workers have freedom of movement and are free to leave their employment after reasonable notice.
- Return immediately any workers’ government-issued identification, passports or work permits once they have confirmed workers’ identities or working rights (to the extent that this is required).
We may require suppliers to demonstrate that they have policies relevant procedures in place.
Child and Underage Labour
Suppliers shall not use child labour. “Child” means any person under the age of 15, or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest.
Children under the age of 18 must not be employed for any hazardous work or work that is inconsistent with the child’s personal development.
Working Hours, Wages and Benefits
Suppliers shall ensure the working hours of the supplier’s workforce does not exceed the maximum set by local law and shall include the minimum breaks, and rest periods and time off between the end of one shift and the start of another, set by law. Workers shall be allowed at least one day off every seven days.
Suppliers shall be considerate to the type of work performed and the acceptable working hours for the role concerned.
Suppliers shall ensure its workers are provided fair wages and benefits that are in accordance with applicable laws, industry standards and collective agreements and paid in a timely manner.
Suppliers shall not use deductions from wages as a disciplinary measure.
We require our suppliers to ensure that all members of their workforce understand their employment conditions and when determining these, consideration should be given to the type of work to be performed, the market rate for that type of work and any statutory minimum wage in that country.
Freedom of Association
Our suppliers must respect the rights of members of their workforce to be free to decide on joining unions or other similar workers’ associations, to the extent permitted by applicable law, and to be free of any discrimination, harassment, intimidation or victimisation for their choice to join these organisations or engage in other lawful industrial activity.
Discrimination, Harassment and Abuse
We require our suppliers to build an inclusive work environment that is free of harassment and unlawful discrimination and to take prompt action against inappropriate workplace behaviour.
Suppliers shall ensure equal opportunities at any stage of employment, from the selection of suitable applicants, their interview and assessment, to the terms of their employment, payment and grounds for dismissal.
Gender Diversity and Inclusion
Our Suppliers must foster an inclusive workforce and a culture of respect toward differences in gender, sexual orientation/identity, age, disability, ethnicity or appearance, marital or family status, religious or cultural background or other protected attribute.
Our Suppliers must encourage women’s equality and safety and we may require Suppliers to demonstrate that they have the necessary support arrangements in place to promote gender equality, equal access, and the empowerment of women.
Anti-bribery, Corruption and Whistleblowing
Bribes or other means of obtaining undue or improper advantage shall not be promised, offered, authorised, given, or accepted, this includes facilitation payments. This prohibition covers promising, offering, authorising, giving or accepting anything of value, either directly or indirectly through a third party, in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage.
Monitoring and enforcement procedures shall be implemented to ensure compliance with anti-corruption laws.
Suppliers shall not offer our employees any gifts, payments, fees, services, discounts, valued privileges or other favours where these would, or might appear to, improperly influence them in performing their duties. Our employees can be offered common courtesies normally associated with accepted business practices, so long as these are offered openly and not in a form that could be construed as a bribe, payoff, or secret compensation.
Competition and Antitrust
Our suppliers should ensure they conduct their business in compliance with all applicable antitrust and competition laws designed to guarantee free and open competition; and prohibit anti-competitive behaviour by either individual players acting alone or multiple players acting together.
Suppliers certify that their prices and methods for calculating prices have been arrived at independently, that the information has not been and will not be shared with any other competitor, and that the supplier has not induced and will not induce any other concern to submit or not to submit an offer for the purpose of restricting competition.
Fraud and Money Laundering
- Act in accordance with all applicable international standards and laws on fraud and money laundering
- Not do or omit to do anything likely to cause any party to be in breach of any of such international standards and laws.
- Maintain an effective anti-fraud and (where appropriate) an anti-money laundering compliance programme, designed to ensure compliance with the law including the monitoring of compliance and detection of violations.
- Comply with and have, since 30 September 2017 complied, with all applicable laws, statutes, regulations, guidance, recognised practice and codes, relating to the prevention of tax evasion and/or the prevention of the facilitation of tax evasion (whether within, or outside of, the United Kingdom) including but not limited to the UK’s Criminal Finances Act 2017 (“CFA 2017”)
Suppliers should ensure they conduct their business in compliance with all lawful international sanctions’ regimes, and that they do not engage with any sanctioned parties. As such, suppliers must:
- Be aware of, and fully comply with, all lawful sanctions regimes affecting their business; and
- Implement effective internal controls to minimise the risk of breaching sanctions, and provide training and support to ensure their workers understand them and implement them effectively, particularly where their work involves international financial transfers or cross-border supply or purchase of products, technologies or services.
Data Protection, Privacy and Security
Information Security is paramount, and we require our suppliers to be committed to protecting the systems and data they store or access and to respect the privacy rights of their workforce, and all parties they deal with. This includes complying with applicable privacy and information security laws and regulations.
Under no circumstances may our employees accept money from suppliers.
Suppliers shall report any instances of illegal or unethical behaviour or breaches of this Charter (in relation to the goods and services being provided to us) in accordance with our whistleblowing policy.
We require that our suppliers have processes in place to ensure that workers may report concerns or illegal activities in the workplace in good faith without threat of reprisal, intimidation, or harassment.
Intellectual Property Rights
We require our suppliers to respect all our confidentiality and intellectual property rights, and to safeguard against improper use of intellectual property, including disclosure of confidential or sensitive information, including pricing. Suppliers should only use our or our third-party confidential information and intellectual property in accordance with their contractual arrangements with us and seek permission from us before sharing any information externally.
It is important that our suppliers respect the legal land rights of individuals, indigenous people, and local communities. Suppliers must be the legal and rightful owner or user of the property on which they operate. Developments and acquisitions of agricultural and forestry land are subject to free, prior, and informed consent of the affected local communities, including women or indigenous peoples and other marginalised stakeholders.
We support ethical sourcing of all minerals and Suppliers must comply with all applicable laws concerning responsible sourcing and conflict minerals. We expect all our suppliers to conduct the necessary due diligence and provide proper verification of the country of origin and source of the materials used in the products they supply.
We require our suppliers to act with the highest of ethical standards and with professionalism, honesty, integrity, and fairness in every aspect of their business and to apply this Charter across its supply chain.
Suppliers must make us aware of any potential conflicts of interest as soon as they are known.
We require all our suppliers to ensure that the workforce they provide to Bell PM are engaged in accordance with applicable laws and deduct or pay tax and benefits.
Publicity and Advertising
Our suppliers must uphold standards for fair business practices including accurate and truthful advertising, and fair competition.
Suppliers must not use our or our customers’ name or logos in publicity or advertising or use the suppliers’ business relationships with us or its customers to imply any endorsement by us of the supplier’s goods or services without our written consent.
Resilience and Business Continuity
We require our suppliers to have a sufficiently robust resilience and business continuity program, appropriate to their business and good industry practice, to protect their business operations from disruptive events that may impact the supply of goods and/or services to Bell and its customers.
Additional risk controls and resilience requirements may be communicated to suppliers depending on the nature of goods or services being supplied.