Supplier Code of Conduct

The Code of Conduct outlines these behaviors, processes and procedures — in short, the standards we expect from our suppliers.

We have communicated our Code of Coduct to all current and new suppliers and have already obtained agreement to its provisions from the majority of our key contracted suppliers.

ENVIRONMENT
Environmental Legislationkeyboard_arrow_down
What we expect from suppliers

"We expect all our suppliers to comply with all applicable environmental legislation."
What we do

Suppliers are assessed and monitored through 3rd party software for incidences of environmental law violation.
Environmental Responsibilitykeyboard_arrow_down
What we expect from suppliers

"We expect all our suppliers to have an environmental policy that is proportionate to the environmental risk of their business."

"We expect all our suppliers to follow procedures that ensure existing plant and equipment are operated in ways which minimise any impact on the environment."

"We expect all our suppliers to train employees and provide the necessary resources to make them aware of their personal environmental responsibilities in protecting the environment."
What we do

Suppliers' environmental policies are reviewed as part of Supplier Code of Conduct audits.

Suppliers are assessed through on-site audits and process audits on their environment related procedures, as well as the training programs that they have in place to educate employees on their personal environmental responsibilities.
Sustainable Developmentkeyboard_arrow_down
What we expect from suppliers

"In line with our Sustainability Policy, NSG Group will communicate and work constructively with our suppliers and governments, regulatory agencies, the scientific community and other relevant stakeholders as appropriate, to develop and encourage business and community practices that make progress towards the common aim of sustainable development."
What we do

Suppliers are assessed through 3rd party software, which provides ratings on the basis of selected pre-defined criteria including sustainable consumption and development.
Hazardous Materialskeyboard_arrow_down
What we expect from suppliers

"We expect all our suppliers to manage hazardous material through compliance with applicable laws, regulations and standards as well as internal rules and procedures. Suppliers must seek to take every possible measure in order to prevent release of hazardous material, fire, explosion and other major accidents that may cause severe damage to their own employees, premises, surrounding communities and environment."
What we do

Evidence of a supplier’s environmental certification or completed sustainability assessment is a requirement in NSG Group's process for approving new suppliers of materials of potential high environmental impact. Existing suppliers of materials of potential high environmental impact are monitored to ensure their certification/sustainability assessments are valid and up-to-date.

Suppliers are assessed through on-site supplier audits on their management of hazardous materials.
SOCIAL
Inclusion & Diversitykeyboard_arrow_down
What we expect from suppliers

"There should be no intentional discrimination for recruitments, promotions, job transfer, dismissal and other employment related activities on the basis of race, colour, creed, nationality, age, marriage or civil partnership, pregnancy and maternity, gender, gender reassignment, sexual orientation, religion or belief, ethnic or national origins, disability, union membership, political affiliation or other status protected by law."
What we do

Suppliers are assessed through on-site audits, where procedures detailing company rules on discrimination and evidence that there has been no discrimination are reviewed.
Human Rights & Employment Standardskeyboard_arrow_down
What we expect from suppliers

"All suppliers must conform to the relevant International Labour Organisation Labour Standards as a minimum requirement. This means suppliers must strive to apply employment standards which promote the application of human rights."

"We expect all our suppliers to operate and maintain an Employee Code of Conduct."
What we do

Suppliers are assessed and monitored through 3rd party software for incidences of human rights violations.

Suppliers are assessed through Supplier Code of Conduct audits on how they enforce and monitor employment laws in each country in which they operate.
Health & Safetykeyboard_arrow_down
What we expect from suppliers

"We expect all our suppliers to provide a safe and healthy working environment by minimising, as far as reasonably practical, the causes of hazards inherent in the working environment."

"We expect all our suppliers to minimise the risk of exposure to harmful materials, machinery or operations."

"We expect all our suppliers to operate and maintain an effective safety policy."
What we do

Suppliers are assessed through on-site audits, where evidence of induction programs covering health and safety for new employees is reviewed.

As part of our on-site audits, we review suppliers’ safety management certification and assess their safety management systems.

Suppliers' safety policies and processes, as well as their implementation, are assessed and reviewed through Supplier Code of Conducts audits.
Anti-Slavery & Child Labourkeyboard_arrow_down
What we expect from suppliers

"We expect all our suppliers to respect national employment law on working hours. NSG Group will not engage with suppliers who apply or support forced labour. Young people under the age of 15, or older if defined by law, must not be employed."

"We expect all our suppliers to comply with legislation regarding slavery and human trafficking."
What we do

Suppliers are assessed and monitored through 3rd party software for employment law violations and incidences of child labour, slavery and human trafficking.

Suppliers are assessed through on-site audits, where evidence of a formal published employment policy that is in compliance with all applicable laws and stipulates minimum age, standards on labour rights and employment conditions is reviewed.
Conflict Mineralskeyboard_arrow_down
What we expect from suppliers

"We expect all our suppliers to carry out due diligence with respect to the sourcing of conflict minerals and to support our customers in complying with the conflict minerals reporting obligations."
What we do

NSG Group and its subsidiaries support the aims and objectives of the US legislation on the supply of Conflict Minerals.

We are working with the relevant suppliers to determine which of our purchased parts/assemblies incorporate metals derive from the relevant minerals and are therefore subject to the requirements of Dodd–Frank Section 1502.

More information can be found in NSG Group’s Conflict Minerals Statement.
GOVERNANCE
Risk Managementkeyboard_arrow_down
What we expect from suppliers

"We expect our suppliers to demonstrate a responsible attitude towards risk and for them, in turn, to expect the same from their own suppliers."

"We expect all our suppliers to operate their business in a responsible and prudent manner to minimise the risk of financial failure."

"We expect all our suppliers to inform NSG Group of any issues or developments that significantly increase the level of risk in the supply chain to NSG Group."

"We expect all our suppliers to maintain their own supplier risk assessment process."
What we do

Suppliers are assessed and monitored via 3rd party software for financial performance, risk of financial failure, and the integrity of its senior management.

As part of NSG Procurement's Supplier Performance and Risk Management Procedure, suppliers are assessed and rated by levels of risk. Where a supplier is deemed as high risk, action plans are developed and regularly updated in order to mitigate the risk.

Suppliers' performance monitoring systems are reviewed and assessed as part of our on-site audits with suppliers.
Competition Compliancekeyboard_arrow_down
What we expect from suppliers

"We expect all our suppliers to prohibit any actions that falsify or distort free competition or market access or infringe the applicable legal rules concerning competition law."
What we do

Suppliers are assessed and monitored by NSG Group through third party software for incidences of competition law violation.

NSG Group conducts annual compliance training with its employees, which includes how to recognise competition compliance infringements and what actions need to be taken should employees find themselves in a situation with a supplier that threatens free competition.
Anti-Bribery & Corruptionkeyboard_arrow_down
What we expect from suppliers

"We expect all our suppliers to accept personal responsibility for behaving professionally ethically, fairly and with integrity."

"We expect all our suppliers to prevent the offering, promising or giving of a bribe and the requesting, agreeing to receive or accepting of a bribe by any person associated with them."

"We expect all our suppliers to notify NSG Group immediately if they become aware that any of the supplier’s directors, officers or employees act in the capacity of a Public Official where this could be relevant to their relationship with NSG Group."
What we do

Suppliers are assessed and monitored by NSG Group through 3rd party software for incidences of bribery and corruption.

Suppliers are assessed through our Supplier Code of Conduct audit. As part of this audit, we review suppliers’ policies concerning anti-bribery and corruption, and, where applicable, evidence of its enforcement.
Conflicts of Interestkeyboard_arrow_down
What we expect from suppliers

"We expect all our suppliers to notify NSG Group immediately if they become aware that any of the supplier’s directors, officers or employees have a relationship with any NSG Group employee that could result in a conflict of interest."
What we do

NSG Group conducts an annual compliance training program with its employees. As part of this, employees are educated on how to recognise and report a potential conflict of interest.

NSG Group operates an Ethics & Compliance Hotline for its employees and suppliers to report a relationship which could result in a conflict of interest.
Fiscal Obligationskeyboard_arrow_down
What we expect from suppliers

"We expect our suppliers to comply with the fiscal obligations within all territories in which they operate."
What we do

Suppliers are assessed and monitored by NSG Group through 3rd party software for incidences of fiscal misconduct and irregularities.
Continuous Improvementkeyboard_arrow_down
What we expect from suppliers

"We will expect our suppliers not only to operate in compliance with today's expectations but also be aware of and already preparing for tomorrow's anticipated demands for example from NSG Group, its customers or government driven legislation aimed at continually improving peoples’ well being and the environment in which they live."
What we do

Suppliers are assessed through on-site audits, during which ‘Continuous Improvement' targets and actions are reviewed.
 
It is the responsibility of all our suppliers to follow the principles of this code. NSG Group asks that all suppliers agree to our Code of Conduct as a pre-requisite for conducting business with us.

The code is available in several languages below:

 

* The Code is updated periodically to accommodate changes in legislation. The most recent updates include money laundering, modern slavery, human trafficking and Conflict Minerals.

Code of Conduct Key Areas :

Anti-Slavery & Child Labour

All NSG suppliers must conform to the relevant International Labour Organisation Labour Standards as a minimum. NSG will not engage with suppliers who apply or support forced labour or employ young people under the age of 15 or older if defined by law.

We employ the following strategies as part of our due diligence against slavery and trafficking in our supply chain:

  • Defining our expectations in the SCoC
  • Assessing suppliers in conjunction with EcoVadis
  • Supplier Audits

A hotline is available to all NSG Group employees and third parties for reporting of suspected violations of human rights. Reporters may be anonymous in most countries and all reporters are protected from retaliation in any form.

Conflict Minerals

NSG Group supports the goals and objectives of the Dodd-Frank Wall Street Reform and Consumer Protection Act's Section 1502, which aims to prevent the use of conflict minerals that directly or indirectly finance or benefit armed groups in The Democratic Republic of the Congo (DRC) or an adjoining country as defined in the Act.

Identifying suppliers who provide materials that could potentially include these minerals is a very important part of our procedures and due diligence is regularly completed via an online questionnaire.

Please refer to the "Conflict Minerals" under "Governance" section.

Anti-Bribery Anti-Corruption (ABAC)

NSG Group and its subsidiaries do business with a range of persons and entities in the private sector including, but not limited to, agents, consultants, distributors, service providers, freight forwarders and customs clearance agents (collectively, "Third-Parties"). We continually review our suppliers in order to identify those considered to be a high ABAC risk. The NSG Group Ethics and Compliance function carries out due diligence that includes a questionnaire and screening process. The Third-Party may be screened against various lists including sanctions lists, watch lists, PEP (politically exposed persons' lists) and checked for exposure in adverse media.

Supplier Development

Measuring the performance of our suppliers against Key Performance Indicators (KPI's) we strive to continually improve the sustainability of our supply base. Increasing the coverage of CSR assessments through our partner EcoVadis and engaging with suppliers through Improvement Action Plans we strive to shape and improve our supply base in the areas of Environment, Labour & Human Rights, Ethics & Sustainable Procurement. Good progress with EcoVadis assessments can be seen on the Non Financial Highlights section. This progress was recognised by EcoVadis with an award during their 2020 annual conference.

NSG suppliers average score of 47.85 exceeds EcoVadis average for all companies measured;-

■ Overall Score Distribution
■ FY20 Supplier Spend Assessed by EcoVadis (% Annual Spend)

We pay particular attention to suppliers who potentially have a High Environmental Impact (HEI). Our aim is to ensure that these suppliers minimize their potentially negative impacts and work positively on environmental initiatives. 13 of our material categories, see chart below, fall within the sope of HEI, including wooden packaging, batch materials, waste management, contractors and chemicals. We expect that all suppliers in these categories have internationally recognized environmental certification such as ISO14001 or national equivalent and/or EcoVadis assessment. In the case of wooden packaging, paper and cardboard, we look for a recognized chain of custody (e.g. FSC or PEFC) in regard to the raw material supply.

■ HEI Compliance - FY20