The Principles specify compliance with all relevant national and international laws and include matters such as anti-corruption behaviours, environmental issues, responsible payment, conflict minerals and how employees are treated.
We use the Principles as a risk management framework to assess new suppliers. They are also used as an integral part of our supplier evaluation, due diligence, request for information, request for proposal, pre-qualification, selection, and approval processes.
A copy of our new Supplier Principles is available in UK English with updated US English, Latin American Spanish, Arabic and Swedish to follow shortly.
In addition we also have four Responsible Trading Principles.
Supplier due diligence
Our procurement teams assess suppliers on a range of ethical, labour, safety, human rights and environmental standards during the selection process and as part of our ongoing assurance activities.
For major suppliers, we conduct an extensive due diligence process, including site visits if needed and supplier self-assessments, to ensure standards are consistent with our expectations. If we identify any potential concerns, we carry out additional screening before we can proceed.
During 2020, we undertook supply chain assurance activity to assess compliance with our Supplier Principles and the UK Modern Slavery Act. Our assessments covered 20% of global spend. 14 low-level risks were identified and resolved. We also continued to collaborate with suppliers during these unprecedented times to facilitate best practice sharing and champion the sustainability agenda.
We continue to engage with major suppliers at all stages of the project lifecycle from planning through to completion. This through-life approach supports our efforts to promote a more sustainable supply chain. We expect our suppliers to conduct their business in a manner that actively manages environmental risk and encourage them to reduce environmental impacts by embracing standards similar to our own and working with them to share best practices.
We have a zero-tolerance policy towards corruption and strict requirements for export control compliance. Our due diligence process for major suppliers helps us understand who we are doing business with and assess whether there are any risks of bribery or corruption associated with that party.
Our screening includes data from media searches, supplier questionnaires, responsible trading characteristics, annual reports and site visits. This also includes a screening for ‘denied parties’ which means a review of the UK government, US government, United Nations or European Union and other relevant denied party lists. These checks identify companies or individuals that are subject to denial orders or where they are otherwise prohibited from dealing with us; the checks are also used as part of our Export Control Procedures. After this process we assess risk through a series of questions designed to raise any potential red flags in relation to corruption or unethical behaviour, including checking any political connections of a supplier and any unusual requests for payment.
Once a supplier has been approved and the contract has been signed, we continue to actively manage and monitor that supplier throughout the life of the contract. This includes managing any significant changes in our relationship with the supplier as well as ongoing risk-based due diligence.
Modern slavery and transparency
We are committed to conducting business responsibly and to maintaining and improving systems and processes to reduce the risk of slavery and human trafficking in our business or supply chain.
Suppliers are regularly reviewed throughout their contractual relationship against such non-financial risks.
Our ‘Supplier Principles – Guidance for Responsible Business’, sets our expectations with regards to human rights, modern slavery and human trafficking, within our supply chain. We require our suppliers to comply with all legislation in the jurisdiction in which they operate and encourage them to meet the same or similarly high standards equivalent to our own on ethical conduct, labour welfare, health and safety, environment, civil liberties and human rights. We conduct assurance activities with our suppliers to ensure awareness and encourage adoption of our Supplier Principles.
If modern slavery or human trafficking were found within our directly contracted suppliers, we would act immediately to work with the supplier and relevant authorities to understand the circumstances of what has been found and to put in place corrective actions that help the affected workers and protect them from further harm. If a supplier is unwilling to address the issue, then corrective action may include termination of contracts and selection of an alternative supplier.
We publish an annual response to the UK Modern Slavery Act and California Transparency in the Supply Chain Act. We are also preparing a response to the Australian Modern Slavery Act.