Supplier Code of Business Conduct
Intro
Marrbery maintains the highest standards of integrity and social responsibility. Marrbery suppliers who provide products and services to Marrbery (“Suppliers”) are expected to adhere to the same standards. The Marrbery Supplier Code of Conduct (the “Code”) sets out Marrbery expectations for the way in which its Suppliers conduct business. Marrbery expects its Suppliers to act in accordance with the Code and requires all Suppliers to comply with applicable laws and regulations in the regions in which they operate and to cooperate openly with regulatory authorities that monitor compliance with those laws. In cases where the expectations outlined in the Code differ from the requirements of local laws, Suppliers shall comply with these expectations without going beyond the scope of applicable local laws.
General information about
The Code reflects Marrbery values and sets out its expectations of its Suppliers in the following areas:
1. Ethics and integrity
2. Confidentiality and data security
3. Inclusiveness and diversity
4. Recruitment and working conditions
5. Well-being, health and safety
6. Environmental protection
Ethics and integrity
Marrbery maintains the highest ethical standards and complies with all applicable laws, rules and regulations. In particular, Marrbery requires Suppliers to comply with the following standards:
Fight against bribery
Suppliers are required to fully comply with all applicable anti-bribery and corruption laws (such as the Ukrainian Foreign Corrupt Practices Act, the UK Bribery Act).
Gifts and representative events
Suppliers must not offer or accept any gifts to obtain an undue advantage or influence for themselves, Marrbery (e.g. Marrbery employees and their relatives and associates) or third parties. Gifts include benefits, fees, commissions, dividends, cash, gifts of money, services and any inducement.
Protection from persecution for reporting problems
Marrbery requires Suppliers to have a policy and procedure for reporting workplace concerns. The policy and procedure must be open and clear, and must protect the whistleblower and those involved from retaliation.
Data privacy and security
Marrbery requires its Suppliers to protect the privacy of individuals as well as the security of confidential assets and information.
Confidential assets and information
Suppliers are required to protect the confidential assets and information of Marrbery and its customers. Suppliers shall develop and maintain processes to ensure that such information is adequately protected.
Personal information and privacy
Marrbery suppliers are required to protect personal information in accordance with all applicable local laws. The use, disclosure and access to personal information provided by or on behalf of Marrbery shall be in accordance with the agreement with the Supplier.
Inclusiveness and diversity
Marrbery promotes a culture of inclusion, encourages diversity and does not tolerate any form of discrimination.
Non-discrimination and diversity in the workplace
Marrbery requires that Suppliers’ facilities are free from discrimination, harassment, victimization, and any other form of harassment on any basis, including but not limited to age, disability, ethnic or social origin, gender, gender identity, nationality, race, sexual orientation, marital status, family status, pregnancy, political opinion, religious belief, trade union membership, or military service.
Diversity among Suppliers
As part of Marrbery long-standing commitment to promoting diversity and inclusion, Marrbery actively encourages engagement with diverse and lesser-known companies as part of its strategic sourcing process. Marrbery Suppliers are required to: (i) use objective and open sourcing and evaluation processes; (ii) ensure that their procurement departments proactively provide diverse companies with fair access to tenders; and (iii) where possible, actively seek and provide diverse suppliers with the opportunity to participate in business projects.
Recruitment and working conditions
As a UN Global Compact Company, Marrbery supports the Universal Declaration of Human Rights and the Declaration on Fundamental Principles and Rights at Work of the International Labour Organization. Marrbery strives to uphold the principles set out in these declarations and expects its Suppliers to do the same.
Modern slavery/human trafficking
Marrbery does not tolerate any form of slavery, forced labor or human trafficking. Marrbery requires Suppliers to fully comply with applicable anti-slavery, forced labour and human trafficking laws (such as the Law of Ukraine No. 2222-IV of 08.12.2004 and the UK Modern Slavery Act 2015) and expects Suppliers to have processes in place to ensure compliance with such laws.
Child labour
Marrbery does not tolerate any form of child labor. Suppliers are required to operate in accordance with laws that set the minimum working age for each position, including laws relating to the hiring, work experience and internships of young people and students.
Welfare, health and safety
Marrbery expects Suppliers to implement sound health and safety practices throughout their operations.
Human rights
Marrbery does not tolerate any form of human rights abuse. Marrbery expects Suppliers to have processes in place to maintain a respectful and safe workplace environment. Marrbery expects that Suppliers will not tolerate any form of physical violence, threats, corporal punishment, psychological pressure, verbal abuse, disrespectful behavior, harassment or bullying.
Labour legislation
Suppliers are required to comply with all applicable local wage and labor laws. Marrbery expects Suppliers to provide employees with timely and understandable payslips containing sufficient information to confirm accurate compensation for work. Any use of temporary, piece-rate or freelance labor must comply with local law.
Health and safety
Suppliers are required to comply with all applicable health and safety laws and regulations. Marrbery expects Suppliers to implement measures to reduce health and safety risks, prevent accidents and provide a safe workplace for all employees.
The environment
Marrbery does its best to reduce the environmental impact of its operations and expects its Suppliers to do the same.
Impact on the environment
Suppliers are required to comply with all applicable environmental laws and regulations. Marrbery expects Suppliers to monitor the risk and impact of their activities on the environment. Marrbery Suppliers shall measure, monitor and reduce energy consumption and greenhouse gas (GHG) emissions. Where possible, Marrbery suppliers shall measure, monitor and reduce water consumption and waste as part of their operations.
Compliance with the Code
Violations
Suppliers shall promptly notify Marrbery of legal violations or violations of its Code or other policies. Suppliers are required to promptly submit to Marrbery subpoenas, requests from regulatory authorities, the media or other third parties related to Marrbery, as permitted by law. To report a breach or provide other information, please email noreply@marrbery.com (this email address is monitored 24 hours a day, 5 days a week). Marrbery will maintain the confidentiality of the information received, unless it violates the requirements of the investigation and is permitted by law.
Rights of Marrbery company
Marrbery reserves the following rights to enforce compliance with the Code by Suppliers.
Selection of Suppliers
Marrbery will assess the extent to which Suppliers meet the requirements of the Code as part of the Supplier evaluation and selection process or as requested by Marrbery.
Evaluation of Suppliers
During the certification process, Suppliers will be required to answer questions to self-assess their compliance with the Code. Periodically, Suppliers may be required to reconfirm their compliance with the Code. If requested, Suppliers shall provide written information about their policies and processes related to compliance with the Code. Marrbery works with Suppliers to improve compliance in the areas affected by the Code and expects Suppliers to agree to work with Marrbery to address relevant issues.
Violation and termination of business relations
The Supplier shall ensure that its subcontractors (if any) comply with the Code and acknowledges its responsibility for violations. In the event of non-compliance or violation of the Code, Marrbery may give the Supplier an adequate opportunity to take proposed corrective action, provided the violation is not serious or insurmountable and the law has not been violated. Marrbery may suspend or terminate the relationship with the Supplier and/or report the violation to the appropriate authorities in the event of a violation of the law.
Order of priority; changes in the Code
Marrbery reserves the right to update, amend or change the requirements of the Marrbery Supplier Code of Conduct, and suppliers shall accept such changes and act accordingly. Nothing contained in documents issued by suppliers shall modify or supplement any part of this Code.
Date of initial acceptance: October 15, 2018.
Date of last revision/update: December 1, 2022.
Resources
The requirements given here are developed taking into account the values of MARRBERY, as well as the following documents: