Our extensive and flexible supply chain offers our customers the opportunity to choose from a wide range of products to meet their commercial needs. Our supply chain management processes ensure these products are manufactured and sourced responsibly. We intend to develop and maintain supplier relationships that are ethical, based on mutual benefit and focused on a shared commitment to meet our customers’ requirements.
We regard suppliers as partners and work with them to help us achieve our corporate responsibility (‘CR’) policy aspirations in the delivery of our products and services. We are committed to working with our key suppliers of products to ensure that adequate standards are maintained in all areas of CR.
This policy is intended to ensure that Engineers Mate® sources products in an ethical and consistent manner while working with suppliers to improve their social and environmental practices.
It contains the following elements:
Risk Assessment
We periodically complete a risk assessment of our global supplier base to establish social risks, including modern slavery and bribery risks in our supply chain. This allows us to focus our attention and resources on the areas of greatest exposure to risk. We undertake adverse media screening on a regular basis to proactively identify emerging modern slavery risks in the key sectors and key countries in which Engineers Mate® operates and the potential implication of our key suppliers in modern slavery incidents.
We aim to improve our understanding of the social and environmental impacts of our supply chain. To achieve this, we will actively work with our supply chain to collect information on the impact of the materials used and the origin of the materials.
Supplier Standards
The Supplier code of conduct establishes our expectations for suppliers in the areas of labour and human rights, environment, health and safety, ethics and management systems. The Code applies to the selection and retention of all suppliers that provide products and services to Engineers Mate® worldwide. By trading with Engineers Mate®, we expect suppliers to accept and apply our standards. This also applies to subcontractors.
The key elements of the Supplier code of conduct are as follows:
- We require compliance with internationally recognised minimum requirements for workers’ welfare and conditions of employment as defined by the International Labour Organisation or the Ethical Trading Initiative, which specifically prohibit child labour, forced labour (including slavery and human trafficking), unfair wages and working hours, discrimination and denying freedom of association.
- We expect our suppliers to be honest in their dealings with others, obeying all applicable laws and corresponding regulations governing fraud and anti-bribery and corruption. Our suppliers should follow the principles of fair competition and must comply with the antitrust and competition laws of the countries in which they conduct business.
Where contractual agreements exist with suppliers, it is expected that they will contain clauses that require the relevant supplier to comply with our Supplier code of conduct. Suppliers that are based in countries with elevated risks of modern slavery and bribery will be expected to confirm compliance with the Supplier code of conduct by completing and returning to Engineers Mate® a statement of conformity.
Supplier Evaluation & Auditing
We take a risk-based approach towards supplier auditing. We selectively audit supplier performance in the areas of human rights, corruption, legal compliance and quality standards. Suppliers that, based on risk assessment, are categorised as ‘high-risk’ will be audited on social risks at the facilities used for the manufacture of Engineers Mate® products.
Suppliers who are unable to meet all the requirements after an initial assessment/audit will be given the opportunity to comply fully within a period which is deemed appropriate for the circumstances. If a serious breach is identified, an action plan should be documented and the supplier will be expected to commit to addressing all the areas where discrepancies have been identified. The process of improvement is principally down to the commitment of the supplier’s management team/ owner/agent to ensure that all areas are addressed. If we have reason to believe that the supplier is not making sufficient or committed progress, then this could lead to a suspension in the relationship until such time that we are confident that all areas were being satisfactorily addressed.
Engineers Mate® reserve the right to cease a relationship with a supplier if it is found that unacceptable practices are being employed at any sites used for producing or sourcing Engineers Mate® products. Such practices include but are not limited to the use of child labour, forced or bonded labour, physical abuse or discipline and intimidation as well as non-compliance with anti-bribery legislation.
Partnerships with Suppliers
Where appropriate, we aim to work with our suppliers to improve work practices in our value chain, for example through knowledge transfer and continued education and training about environmental and social standards.
Staff Training
All of our senior procurement staff are required to complete the CR training on bribery, modern slavery and other social risks. The training helps these employees to understand and recognise risk issues that might occur in our supply chain and informs them of the appropriate actions that should be taken if such issues are found.
Where contractual agreements exist with suppliers, it is expected that they will contain clauses that require the relevant supplier to comply with our Supplier code of conduct.
Supplier Evaluation & Auditing
Engineers Mate® QA/QC is responsible for implementing and maintaining a supplier audit programme. The audit process and audit locations will be reviewed periodically to ensure these reflect changes in regulations, industry standards, supplier base and Engineers Mate® ethical sourcing requirements.
New Suppliers
Alterations from original design on and after first approval including alteration in style of construction will be charged extra. Samples of all work may be submitted for customer’s approval and no responsibility will be accepted for any errors in samples which may be passed by him. The Customer shall be solely responsible for any design or construction which EM executes on the instruction or at the request of the customer whether the same shall have been supplied by EM or by the customer and solely responsible for any claim or proceedings made or brought by a third party arising thereon.
Training
All businesses should ensure that all senior staff, including managers and procurement and sales executives, complete the CR training modules on business ethics and modern slavery with a minimum frequency of at least once every three years. Completion of the training will be recorded and reported to Group HR annually.
Reporting
Engineers Mate® QA/QC will report periodically to business area management a summary of the critical social risk issues that have been identified during the audits.
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