SUPPLIER CODE OF CONDUCT
FIH group plc and its subsidiaries* (“the Group”) is committed to maintaining the highest standards of ethics and integrity in conducting its business. It is committed to operating legally, honestly, and fairly across all the businesses within the Group and seeks to work with suppliers who share these values and operate in accordance with these principles.
The Group wishes to work only with those supplying companies that adhere to the same high standards that it seeks to uphold and accordingly the Group requires that all its key suppliers should adhere to and demonstrate by their actions that they in turn share and are committed to operating to these same high standards.
The Group has a zero-tolerance attitude to bribery, fraud, dishonesty, illegal or improper activity amongst its employees, partners, subcontractors, or suppliers.
The Group expects all companies within its supply chain to make sure where appropriate that they have the necessary policies and processes in place to ensure and demonstrate that these same principles are adhered to within their own supply chain.
The Group shall also consider these principles when choosing its suppliers.
Legal Compliance & Ethical Standards
The Group expects its suppliers to comply with all applicable laws, regulations, and standards.
Modern Slavery and Human Trafficking
Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. The Group is committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.
The Group is also committed to ensuring there is transparency in our own businesses and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015.
We expect the same high standards from all of our contractors, suppliers and other business partners, and as part of our procurement processes, we require our suppliers to confirm that they will not use forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.
Bribery, Corruption and Fraud
Suppliers should be compliant with all laws, regulations and best practice relating to anti-corruption, including The Bribery Act 2010.
The Group expects suppliers to have policies in place that prohibit extortion, bribery, facilitation payments or other proper inducements and stake appropriate steps to ensure that their suppliers are also compliant.
Competing Fairly and Conflicts of interest
Suppliers are required to have procedures in place to identify and consider any potential conflicts of interest which may occur in any proposed dealings with the Group. Any such conflicts should be reported immediately. We have zero tolerance for bid rigging or price fixing procedures within our supply chain.
Data protection and information security
We expect our suppliers to fully comply with relevant data privacy laws including UK General Data Protection Regulations where applicable. Any suppliers who process personal information on behalf of the Group must process the information in accordance with our instructions and only for the purpose for which it is provides. Any personal information must not be shared with sub-contractors without express written permission from the Group.
Suppliers must comply with confidentiality clauses as detailed within agreed contracts to protect sensitive Group information.
Tax Evasion
The Group will not be party to tax evasion for the facilitation of tax evasion in any form.
The Group takes a zero-tolerance approach to the criminal facilitation of tax evasion by our people and our suppliers. Suppliers must not participate in tax evasion not facilitate tax evasion by others.
Suppliers should take appropriate steps to ensure that those who act on their behalf also take steps to ensure compliance with these obligations.
Treatment of staff and customers
We are committed to eliminating discrimination in employment and we promote diversity and equal opportunities in the workplace and ensuring a respectful environment for our staff and customers and expect that our suppliers should adhere by these principles.
Suppliers should provide an environment that ensures the health, safety and security of its staff and is compliant with all applicable laws and regulations regarding working conditions.
They should also put in place adequate health and safety protection for customers.
Non-Compliance
Documentation and monitoring of compliance is the responsibility of the supplier. The Group reserves the right to investigate any instances of a supplier’s non-compliance of which it becomes aware.
Non-compliance may result in a supplier having a contract terminated or no longer being selected to supply the Group.
Stuart Munro
FIH group plc CEO
*FIH group plc is an AIM quoted international specialist services group with businesses in the Falkland Islands and the UK. FIH group plc is the parent company of the Falkland Islands Company Limited, the Falkland Islands Trading Company Limited, Falkland Islands Shipping Limited, Erebus Limited, South Atlantic Support Services Limited, Paget Limited, the Portsmouth Harbour Ferry Company Limited, Portsea Harbour Company Limited, Clarence Marine Engineering Limited, Gosport Ferry Limited, Momart International Limited, Momart Limited and Dadart Limited.