SUPPLIER CODE OF CONDUCT
1. APPLICATION OF THIS CODE
L.C. Dyson’s Bus Services Proprietary Limited (“herein referred to as “Dysons”) seeks to work with its suppliers to meet and exceed minimum expectations as outlined in this Code and continuously strives to improve the standard of its business practices.
Supplier means any entity that supplies goods or services, including construction works and services, to Dysons.
Where the Code refers to workers, it includes employees, contractors, agency and temporary staff of the Supplier and its related entities.
Where the Code refers to the law it means the laws in the jurisdiction that apply where the goods are procured, or services are performed. Fundamental to this Code is an expectation that all suppliers operate in full compliance with all laws, rules and regulations of the jurisdictions in which they do business.
The expectations outlined in the Code are not intended to supersede or alter the Supplier’s regulatory and contractual obligations. Dysons expects all existing and new suppliers to commit to the Code. Suppliers should check their respective contracts, agreements and purchase orders as they may contain additional obligations or higher standards than those set out in this code.
Dysons expects suppliers to communicate the Code to their related entities, suppliers and subcontractors who support them in supplying goods and services to Dysons, so that they are aware of, understand and comply with the Code.
2. REFERENCES
• Gifts and Benefits Register
• Modern Slavery Policy
3. INTEGRITY, ETHICS AND CONDUCT
Dysons expects high standards of ethical conduct and compliance with all applicable laws. Suppliers are expected to be ethical in their business activities, including relationships, practices, sourcing and operations.
3.1 Business Integrity
Suppliers are expected to comply with all anti bribery, anti-corruption, anti-money laundering, and modern slavery laws.
Suppliers must not engage in, either directly or indirectly, fraudulent, corrupt, exploitative or collusive activities.
3.2 Record Keeping and Documentation
Suppliers are expected to maintain adequate records that accurately record all financial transactions and information regarding its business activities, labour, health and safety and environmental practices in accordance with applicable laws, policies and procedures.
Disclosure of information is expected to be undertaken without falsification or misrepresentation.
3.3 Professional Conduct
Suppliers are expected to conduct themselves in a manner that is fair, professional and that will not bring Dysons into disrepute.
3.4 Confidentiality
Suppliers must not improperly use any private, confidential or commercially sensitive information in its possession relating to or in connection with its dealings with Dysons.
4. CONFLICT OF INTEREST: GIFTS, BENEFITS AND HOSPITALITY
Dysons believes that all business activities should be undertaken with impartiality and any conflict of interest should be raised and managed.
4.1 Conflict of Interest
Suppliers must:
a) declare to Dysons procurement representative, any situation that raises an actual, potential or perceived conflict of interest related to or in connection with its dealings with Dysons; and
b) avoid financial, business or other relationships which may compromise the performance of their duties under their business arrangement with Dysons. Under Dysons’ policies, employees are expected to avoid actual, perceived and potential conflicts of interest wherever possible. Any conflicts of interest that cannot be avoided are expected to be declared and managed appropriately.
4.2 Gifts, Benefits and Hospitality
Dysons personnel must:
a) conduct themselves with the highest standards of integrity, impartiality and accountability; and
b) perform duties without favouritism, bias or for personal gain.
The appropriate handling of offers of gifts, benefits and hospitality is critical to earning and sustaining public trust. As such, Suppliers shall not entice or obtain any unfair or improper advantage when offering gifts, benefits or hospitality to Dysons personnel.
Gifts valued at over $100 (excluding GST) are to be published in the Gifts and Benefits Register. The register will record the date received, the gift or item received, who received the gift, who presented the gift, the occasion for the gift and the estimated value of the gift.
5. CORPORATE GOVERNANCE
Commitment to sound management administration, risk and corrective action systems, are key to a reliable supply chain for Dysons. Suppliers are expected to maintain sound administration processes.
5.1 Risk Assessment and Management
Suppliers should develop and maintain a process to identify, manage and control relevant risks associated with its operations. These include supply chain risks and risks relating to labour and human rights, health and safety, the environment, business ethics, and corporate governance.
5.2 Critical Incident Management
Suppliers should:
a) identify and assess potential critical incident, emergency situations and business continuity risks; and
b) develop and implement emergency plans and response procedures that minimise harm to life, environment and property, while minimising disruption to business continuity.
5.3 Audits and Assessments
To ensure compliance with this Code and the applicable laws, Suppliers are expected to:
a) perform periodic evaluations of their facilities and operations, and the facilities and operations of their subcontractors; and
b) cooperate openly and honestly with any Dysons audit, assessment or review.
6. LABOUR AND HUMAN RIGHTS
Dysons believes that all workers in its supply chain deserve to be treated with dignity and respect.
Suppliers are expected to provide a fair and ethical workplace, which upholds high standards of human rights and integrates appropriate labour and human rights policies and practices into its business.
6.1 Anti-discrimination
Subject to applicable laws, Suppliers are expected not to discriminate against any worker based on age, disability, ethnicity, gender, marital status, political affiliation, race, religion, sexual orientation, gender identity, union membership, or any other status protected by law, in hiring and other employment practices.
6.2 Anti-harassment
Suppliers are expected to commit to a workplace free from workplace bullying, harassment, victimisation and abuse. Suppliers are expected not to bully workers or threaten workers with, or subject them to, unlawful or inhumane treatment. This includes, but is not limited to, abuse and harassment which can be verbal, physical, sexual or psychological.
6.3 Human Rights
Suppliers are expected to provide goods and services in a manner consistent with any applicable human rights obligations.
Consistent with relevant modern slavery legislation, Suppliers are expected to proactively identify, address and – where required by legislation – report on risks of modern slavery practices (defined broadly to include all forms of human trafficking, forced labour and slavery-like practices) in their business operations and supply chains.
6.4 Prevention of Involuntary and Underage Labour
Suppliers are expected to:
a) ensure that all work is undertaken without coercion;
b) not use any form of forced, bonded or indentured labour; and
c) employ only workers who are the applicable minimum legal age.
All use of temporary and outsourced labour should be within the limits of the law. Suppliers are therefore expected to:
a) use all reasonable endeavours to ensure that the third-party recruitment agencies it uses are compliant with the provisions of this Code and applicable law; and
b) be responsible for payment of all recruitment related fees and expenses in recruiting foreign contract workers either directly or through third party agencies.
6.5 Working Hours, Wages and Benefits
Suppliers must:
a) follow all applicable laws and regulations with respect to wages, working hours and workers compensation insurance;
b) ensure that all workers receive their legally mandated minimum wages, benefits, superannuation, leave entitlements and time off for legally recognised holidays; and c) pay workers’ wages as required under applicable laws in a timely manner and not be expected to use wage deductions as a disciplinary measure. All overtime is expected to be reasonable and paid at the rate and in accordance with the applicable laws
6.6 Freedom of Association and Collective Bargaining
Suppliers are expected to freely allow workers to associate with others, form and join (or refrain from joining) industrial organisations or associations of their choice and bargain collectively, or engage in any lawful industrial activity without interference, discrimination, retaliation or harassment.
7. HEALTH AND SAFETY
Worker health, safety and wellbeing is important to Dysons. Suppliers are expected to provide a healthy and safe work environment and integrate sound health and safety management practices into its business.
7.1 Workplace Health and Safety Management
Suppliers must comply with all applicable laws relating to workplace health and safety. Suppliers are expected to:
a) manage occupational health and safety hazards; and
b) provide workers with job related training and consult with employees in relation to the provision of information and training.
8. ENVIRONMENTAL MANAGEMENT
Dysons is committed to promoting environmental responsibility. Suppliers are expected to minimise the environmental impact of their operations and maintain environmentally responsible policies and practices.
8.1 Environmental impacts
Suppliers must comply with all applicable laws and regulations relating to the environment, including any management and reporting obligations. Suppliers are expected to manage the environmental impact of their operations by:
a) ensuring the safe storage, transportation and disposal of hazardous substances including hazardous waste;
b) maintaining policies and practices for the efficient use of energy, water and natural resource consumption; and
c) maintaining policies and practices that reduce the risk of pollution, loss of biodiversity, deforestation, damage to ecosystems and greenhouse gas emissions.