Supplier code of conduct

Introduction

As we continually strive to deliver exceptional service for our clients, Crisp is committed to upholding the highest ethical and professional standards consistent with our Values and our Code of Conduct.

The relationship between Crisp and its suppliers is an important component to achieving a high performance in our business.

Crisp suppliers must also operate in full compliance with all applicable laws and regulations of the countries in which they operate.

In selecting suppliers, Crisp works hard to choose reputable business partners who are committed to ethical standards and business practices compatible with those of Crisp.

This Code formalises Crisp’s practices and makes clear that, recognising differences in cultures and legal requirements, we expect that wherever our suppliers are located, producing products for us or delivering services for us, that they are provided in a manner compatible with the high standards that contribute to Crisp’s reputation.

Suppliers are required to comply with this Code and to have and maintain practices compatible to those contained in this Code. Crisp is committed to helping its suppliers comply with these standards. Crisp expects its suppliers to apply these standards to the suppliers they, in turn, work with in providing goods and services to Crisp.

Crisp strongly encourages suppliers to exceed the requirements of this Code and promote best practice and continuous improvement throughout their operations. If there is no local legal requirement, or if a local legal requirement is not as strict as the requirement included in this Code, Crisp Suppliers are required to follow this Code in order to continue to supply to and partner with Crisp.

Our Code promotes “doing the right thing” as well as “doing things right”.

Our People

Crisp has a diverse workforce and supply base. We all have different skills and capabilities and come from many cultures. This diversity has helped make the company what it is today and is important for shaping our future. Our success is a reflection of our people and those we work with.

Fair Treatment and Equal Opportunity

We want Crisp to be a place of mutual trust and respect, which embraces diversity and values everyone for their merits. A place where people’s rights are honoured and where they are treated fairly and consistently.

We expect our suppliers to do the same. Crisp Suppliers must ensure employment – including hiring, payment, benefits, advancement, termination and retirement – is based on ability and not on beliefs or any other personal or protected characteristics.

This includes discrimination based on sex, race, colour, national or ethnic origin, sexual orientation, gender identity or expression, religion, political beliefs, trade union activity, marital status, caring responsibilities, disability, age or citizenship.

Respectful Workplace

Every Crisp employee has the right to respect and freedom from harassment. Violence at work is unacceptable, regardless of the reason. We will not tolerate harassment or violence against, or perpetrated by, an employee. We equally expect our suppliers to provide the same commitment.

Crisp suppliers must treat all workers with respect and dignity. No worker shall be subject to corporal punishment, physical, sexual, psychological or verbal harassment or abuse, nor is there to be the threat of any such treatment. In addition, Crisp suppliers will not use monetary fines or deductions from wages as a disciplinary practice.

Human Rights

Respect for human rights is a fundamental part of how Crisp conducts business and is a key value. Our commitment to respecting human rights acknowledges all internationally recognised Human Rights and means wherever we work in the world, we will seek to respect and uphold the fundamental Human Rights and freedoms of everyone who works for us or with us, and of the people and communities we work among.

Crisp suppliers will identify, prevent or mitigate any adverse human rights impacts caused by, or contributed to, their operations to avoid any infringement on the rights of others and also identify impacts that are directly linked to their operations where they are acting for or in connection with our operations.

We expect our suppliers to share this commitment and specifically meet the following:

• Child Labour

  Crisp is dedicated to the protection of children both through the work it does and its business practices and prohibits the use of child labour and it expects its suppliers to do the same. We expect our suppliers to comply with local laws regarding the minimum age of employees. The minimum age for workers shall not be less than the age of completion of compulsory schooling, and in any case not less than 16 years of age. In addition, Crisp suppliers must comply with all legal requirements for the work of authorised young workers, particularly those pertaining to hours of work, wages and safe working conditions.

  Additionally, all young workers must be protected from performing any work that is likely to; interfere with their education, be hazardous or that may be harmful to their health, physical, mental, social, spiritual or moral development.

  We encourage our suppliers to participate in legitimate workplace apprenticeship programmes that comply with applicable local laws and regulations.

• Forced Labour

  In line with our own commitment, Crisp suppliers must not use any type of involuntary or forced labour, including indentured, bonded, slave or human trafficked labour, and never engage in any form of procurement of commercial sex acts.

  All work must be voluntary, and workers should have the freedom to terminate their employment in accordance with established laws, regulations, and rules.

  Workers shall not be charged any fees or costs for recruitment, directly or indirectly, in whole or in part, including costs associated with travel, processing official documents and work visas in both home and host countries.

  When the subcontracting of recruitment and hiring is necessary, companies shall ensure that the labour agencies they engage operate legally, are certified or licensed by the competent authority, and do not engage in fraudulent behaviour that places workers at risk of forced labour or trafficking for labour exploitation.

  Crisp suppliers should also not mandate that workers hand over government-issued identification, passports or work permits as a condition of employment. The retention of personal documents shall not be used as a means to bind workers to employment or to restrict their freedom of movement.

  Written contracts of employment shall be provided to workers in a language they understand, clearly indicating their rights and responsibilities with regard to wages, working hours and other working and employment conditions. This should be provided prior to deployment.

  No worker shall be required to lodge deposits or security payments at any time. Crisp expects its suppliers to put in place adequate procedures to ensure that they are not directly or indirectly, through their supply chain, involved in any form of involuntary or forced labour.

  The workplace shall be free of any form of harsh or inhumane treatment. Disciplinary policies and procedures shall be clearly defined and communicated to all workers, and shall not include any inhumane disciplinary measure, including any corporal punishment, mental or physical coercion, or verbal abuse of workers; nor shall they include sanctions that result in wage deductions, reductions in benefits, or compulsory labour.

  The use or threat of physical or sexual violence, harassment and intimidation against a worker, his or her family, or close associates, is strictly prohibited.

• Wage and Benefits

  Crisp suppliers must pay workers at least the minimum compensation required by local law and provide all legally mandated benefits. In addition to payment for regular hours of work, workers must be paid for overtime hours at such premium rate as is legally required or, in those countries where such laws do not exist, at least equal to their regular hourly payment rate.

• Working hours

  Crisp suppliers must ensure that on a regularly scheduled basis, except in extraordinary business circumstances, workers are not required to work more than 60 hours a week, including overtime. Suppliers must ensure that all overtime work is voluntary and compensated at the prevailing overtime rates. In addition, except in extraordinary business circumstances, all workers are entitled to at least one day off in every seven day period.

• Freedom of Movement and Personal Freedom

  Workers’ freedom of movement shall not be unreasonably restricted. Workers shall not be physically confined to the workplace or related premises, such as employer or recruiter operated residences; nor shall any other coercive means be used to restrict workers’ freedom of movement or personal freedom. Mandatory residence in employer-operated facilities shall not be made a condition of employment.

• Freedom of Association and Collective Bargaining

  Crisp recognises the importance of open communication and direct engagement between workers and management and expects its suppliers to do the same. Crisp Suppliers are to respect the rights of workers to associate freely and communicate openly with management regarding working conditions without fear of harassment, intimidation, penalty, interference or reprisal. We also expect our suppliers to recognise and respect any rights of workers to exercise lawful rights of free association, including joining or not joining any association of their choosing. Crisp Suppliers also must respect any legal right of workers to bargain collectively.

Our Values

Crisp is committed to the highest standards of integrity, honesty, openness and professionalism in all its activities wherever they are undertaken, we respect local laws and do not engage in any form of corrupt practices, including extortion, fraud, or bribery, at a minimum.

We expect our suppliers to demonstrate a similar commitment by understanding and complying with all applicable laws. Our suppliers should inspire trust by taking responsibility, acting ethically and encouraging honest and open debate.

Bribery, Corruption and Facilitation Payments

Bribery is offering, providing or receiving something of value – including cash, gifts, hospitality or entertainment – as an inducement or reward for something improper. Usually, but not always, it’s to obtain or retain business or some other illegitimate advantage. Bribes are against the law and against our code, no matter what the “local custom” may be. A facilitation payment refers to the practice of paying a small sum of money to (usually) an official as a way of ensuring they perform their duty. UK legislation forbids facilitation payments anywhere in the world.

Corruption involves any of these activities: bribery, extortion, fraud, deception, collusion, cartels, abuse of power, embezzlement and money laundering.

Engaging in bribery and corruption and making facilitation payments can seriously damage our reputation and business relationships.

We never offer, give or receive bribes or improper payments, or participate in any kind of corrupt activity, either directly or through any third party.

We expect our suppliers to apply the same stringent principles. Crisp suppliers should not engage in any form of commercial bribery or kick-back scheme. Suppliers acting on behalf of Crisp must comply with applicable anti-bribery laws as well as all local laws dealing with bribery of government officials.

In connection with any transaction related to the manufacture, distribution or delivery of goods or services to Crisp, the supplier must not offer, promise, authorise, give, demand or accept any gift, loan, fee, reward or other advantage to or from any person as an inducement; to do something which is dishonest, illegal or a breach of trust; to obtain, retain or direct business (except as otherwise permitted at paragraph 3.2 below); or to secure any other improper advantage.

Under these standards, improper payments include offers, promises, authorisations or payments of anything of value to expedite routine government actions.

We expect our suppliers to implement appropriate and adequate procedures for their employees to comply with applicable anti-corruption laws and these standards.

The help, advice and local knowledge of agents and other consultants or contractors can sometimes be essential. However, we require them to operate at all times in accordance with our standards, particularly in relation to bribery and corruption.

Gifts and Hospitality

Crisp develops long-term business relationships based on trust and respect. Exchanging gifts and hospitality can build goodwill, but may, or may appear to, create improper influence. Any gift or hospitality we accept or give in connection with business should always be customary and reasonable in terms of value and frequency.

Crisp suppliers should not provide any gift, meal or entertainment to a company employee in any situation in which it might influence or appear to influence any employee decision in relation to the supplier. In other situations, suppliers may provide modest gifts, meals or entertainment to company employees if they are:

• not cash or cash equivalent
• consistent with customary business practice and supplier company policy
• not frequent or expensive
• do not violate any law.

Equally we do not want our suppliers to be influenced or pressurised in turn through the acceptance of inappropriate gifts or hospitality. If someone tries to do this to you, always tell us.

We require our staff to record gifts and hospitality given or received by them.

Conflicts of Interest

Conflicts of interest run counter to the fair treatment we expect. They can also break the law and seriously damage our integrity and reputation.

A conflict of interest occurs when your private interests interfere, or appear to interfere, with the best interests of Crisp.

Crisp suppliers should avoid any interaction with any Crisp employee that may conflict or appear to conflict with that employee acting in the best interests of Crisp. By way of example, suppliers should not employ or otherwise make payments to any Crisp employee during the course of any transaction between the supplier and Crisp (other than pursuant to the company contract). If a supplier employee is a family relation to any Crisp employee or if a supplier has any other relationship with a Crisp employee that might represent a conflict of interest, the supplier should disclose this fact to the company or ensure that the Crisp employee does so.

Competition and Anti-Trust

Competition and anti-trust laws prohibit a variety of business practices that restrict free and fair competition, such as bid rigging, price fixing, cover pricing or market sharing. Violations of such laws are very serious, and can result in significant fines and other penalties, including debarment. Individuals can face prison.

We are committed to free and open competition in our markets. We compete fairly and ethically, and support laws that promote and protect competition. The decisions we make about pricing, customers, bids and markets are taken by us alone.

We expect that when our suppliers are preparing proposals or bids for Crisp that all statements, communications and representations are accurate and truthful. Equally, Crisp suppliers who serve us across national borders will understand and comply with all applicable export laws and regulations.

Our suppliers will not share with us information they receive from or about our competitors or their bids, or the bids they are making to our competitors.

You should always report anti-competitive behaviour if you see it or suspect it.

Our suppliers should inspire trust by taking responsibility, acting ethically and encouraging honest and open debate.

Our World

We recognise Crisp’s impact on society, the economy and the planet, and aim to make a positive difference. This is embedded in the way we do business. We are committed to maintaining a safe, healthy and sustainable working environment. Everyone in Crisp is responsible for making this a reality and we look to our suppliers to help us deliver this commitment.

Health and Safety

We require Crisp suppliers to provide workers a clean, safe and healthy work environment in compliance with all legally mandated standards for workplace health and safety in the countries in which they operate.

We require everyone who works for or with us to understand the health and safety risks of their activities and apply good health and safety management systems, training and practices in all they do. They should also take the necessary precautions to protect everyone from workplace injuries and occupational disease.

Environment

We work with our stakeholders to continuously assess and reduce our environmental impact. We aim to prevent environmental damage and minimise our use of energy and resources.

Crisp suppliers must comply with all local environmental laws applicable to the workplace, the products produced, and the methods of manufacture and should encourage the use of processes and materials that support sustainability of the environment throughout their supply chain.

Our Assets

Crisp is committed to being a sustainable and reputable business. Our physical and intangible assets – including money, property, time and information – are key to achieving this. How we use and protect our assets has a strong bearing on how we perform and how well prepared we are for the challenges we will face. Our suppliers can play an important part in this.

Financial Integrity

Our policies are clear, no employee will engage in any activity that is designed, or can be reasonably construed, to perpetuate a fraud or evade taxes. We expect our suppliers to meet these same standards.

Fraud is a criminal offence in most countries. Whilst its definition varies across these countries, fraud always involves deception and dishonesty. It’s fraud when you deliberately try to deceive someone, act dishonestly or abuse your position to gain any kind of material advantage, or use or involve anyone else to do so. Fraud is usually carried out for profit, or to obtain money, property or services unjustly. It can involve defrauding the company or a third party.

Crisp suppliers will never knowingly seek to gain any advantage of any kind by acting fraudulently, deceiving people or making false claims, or allow anyone else to do so on your or our behalf. This includes:

• defrauding or stealing from Crisp, a customer or any third party
• any kind of misappropriation of property
• any kind of misreporting of time or expenses
• tax evasion or deliberately or dishonestly taking action to help someone else to evade tax
• money laundering

Always act honestly, fairly and openly, carefully checking or inspecting things that you are responsible for.

Confidential Information and Records

Information for us is confidential if it has value to Crisp and is not publicly available. You might also obtain confidential information from our employees, customers, partners and others.

Crisp employees and suppliers have a responsibility to keep confidential information safe and take every necessary precaution to protect the confidentiality of information.

Crisp suppliers must take all due care in handling, discussing or transmitting sensitive or confidential information that could affect Crisp, its employees, its group companies, the business community or the general public. Disclosure of financial information could influence the actions of shareholders and potential investors and possibly violate security law.

Suppliers’ responsibility to hold the Crisp’s confidential information as confidential is a continuing obligation even after the contract with Crisp has ended. If a Crisp supplier believes that it has been given access to confidential information in error they should immediately notify their contact at the company and refrain from further distribution.

To protect others confidential information, Crisp suppliers similarly should not disclose to anyone at Crisp company information related to any other company if the supplier is under contractual or legal obligation not to share that information.

Personal Information

Crisp recognises its duty to respect personal information and ensure it is protected and handled responsibly and only used for the purposes for which it is provided.

Crisp suppliers must ensure that all personal information is controlled in accordance with, and their data and information systems comply with, applicable laws and regulations, in particular the European Union’s General Data Protection Regulations 2016/679.

Crisp expects its suppliers to manage personal information in accordance with the following Data Protection Principles. They will:

• Process personal information fairly and lawfully
• Obtain personal information only for specified, explicit and legitimate purposes
• Ensure personal information is adequate, relevant and not excessive
• Ensure personal information is accurate and, where necessary, kept up to date
• Not keep personal information for longer than is necessary
• Process personal information in accordance with rights of the individual
• Keep personal information secure
• Not transfer personal information unless there is adequate protection in place

Screening of workers

Crisp suppliers must ensure that criminal records and identity verification checks are completed for any and all workers deployed to work on Crisp contracts. Such checks must be retained and refreshed a minimum of every 3 years.

Crisp reserves the right to audit such checks and request sight of screening results.

Communication, Monitoring and Compliance

Crisp suppliers should communicate, through its existing ethical operating standards/practices or through this Code that its workers, supervisors and its permitted subcontractors are aware of the requirements detailed in this Supplier Code of Conduct. Crisp reserves the right to do such things as announced and unannounced inspections of facilities, to ensure compliance with this Code. Crisp suppliers must maintain at each facility all documents necessary to demonstrate compliance with the Code. Crisp suppliers must allow representatives from Crisp and, if requested, Crisp’s customers, full access to facilities, documents, worker records and workers for confidential interviews in compliance with local laws.

Crisp suppliers are expected to take necessary corrective actions to promptly remedy any identified non-compliance. Crisp reserves the right to terminate its business relationship with any Crisp supplier who is unwilling or unable to comply with this Code when termination is allowed by local laws.

We encourage Crisp suppliers to communicate to us any actions taken to improve its business practices and to send us suggestions about how Crisp can best contribute to the implementation of the principles set out in this Supplier Code of Conduct.

Raising Concerns

Crisp suppliers who believe that any employee or anyone acting on its behalf has engaged in illegal or otherwise improper conduct should report the matter immediately.

Crisp suppliers similarly should report any potential violation of this Code by email.

A supplier’s relationship with the company will not be affected by an honest report of potential misconduct.

If you are aware of any violations of this Code you must report it.