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"Supply chain standards
Our Global Procurement Services team is responsible for executing appropriate due diligence and contract management procedures, such as an established request for proposal (RfP) selection criterion, standard supplier Master Services Agreement (MSA) templates and Engagement Compliance control mechanisms. We expect our suppliers and their supply chain to comply fully with all applicable laws and regulations in the conduct of their business; therefore although respecting human rights and environmental issues in the supply chain is ultimately our suppliers’ responsibility, we take the following steps to communicate clearly our expectations to our suppliers.
Requests for Proposal (RfP)
As part of the supplier RfPprocess managed by our Global Procurement Services team, potential suppliers are asked to confirm whether they have a policy in place prohibiting child and/or forced labor, whether the policy extends to their own suppliers and subcontractors, and to provide a copy of the policy. Those potential suppliers are also asked for information about social compliance audits of their own suppliers and subcontractors, with particular reference to significant risks for incidents of child labor. That due diligence process also seeks information about a potential supplier’s equal opportunity, human rights, anti-corruption, and health and safety policies.
As part of the RfP process, our Global Procurement Servicesteam also specifically asks potential suppliers to confirm their compliance with human rights laws, rules and regulations including the Modern Slavery Act 2015. Those potential suppliers are also asked to provide information about how they monitor and comply with those legal standards.
Supplier contracts
We actively and intentionally include clauses specific to Prohibition on Human Trafficking and Modern Slavery in supplier contracts. Suppliers who are subject to our standard MSA are asked to represent and warrant that they comply with all applicable laws, regulations, and other legal obligations to their personnel specifically including, but not limited to, employment laws, and prohibitions against insider trading, bribery, and corruption.
Additionally, suppliers who are engaged using our standard MSA are asked to confirm that they:
- have not committed or been notified that they have been placed under investigation for any offences relating to human trafficking and/or slavery;
- are not aware of any circumstances within their supply chain that could give rise to an investigation or a prosecution; and
- will comply with the Modern Slavery Act 2015 and other legal standards relating to human trafficking and/or slavery.
Those suppliers are asked to notify us immediately if those circumstances change. Additionally, the standard MSA asks them to provide us with their own UK Modern Slavery Act statement, where applicable, which sets out the steps they have taken to ensure that slavery and/or human trafficking is not taking place in any of their supply chains or in any part of their business."