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.

Environmental Legislationkeyboard_arrow_down
What we expect from suppliers

"Comply with all applicable environmental legislation."
What we do

All contracts with waste management and recycling partners are arranged with the imperative requirement to meet local environmental legislation and the NSG Group data reporting requirements.

Suppliers are assessed and monitored by EcoVadis for incidences of environmental law violation.
Environmental Responsibilitykeyboard_arrow_down
What we expect from suppliers

"Have an environmental policy that is proportionate to the environmental risk of their business."

"Follow procedures that ensure existing plant and equipment are operated in ways which minimise any impact on the environment."

"Train employees and provide the necessary resources to make them aware of their personal environmental responsibilities in protecting the environment."
What we do

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

"Play their part in creating a prosperous and sustainable future by continually seeking to achieve best practice in environmental protection and minimising any detrimental effects from their operations on the environment as far as is reasonably practicable"
What we do

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.

NSG Group uses the EcoVadis platform and their sustainability scorecards to assess its suppliers against predefined critera under the following areas:

Labor & Human Rights
Sustainable Procurement
Hazardous Materialskeyboard_arrow_down
What we expect from suppliers

"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.
Water Convention and Resources Managementkeyboard_arrow_down
What we expect from suppliers

"Make practical efforts to minimise the use of energy and materials."

"Make practical efforts to maximise the efficient use of water and ensure that wastewater is controlled within acceptable quality limits."
What we do

As part of supplier audits, NSG Group reviews suppliers' procedures and objectives to ensure minimum energy usage. Suppliers are also assessed on how they monitor energy usage on their premises.

NSG Group commit to partnership with suppliers on standards and activities to develop best practices in responsible water management.

NSG Group reviews water risks and access to sustainable water sources as a criterion when evaluating relevant suppliers.
Waste Management and Emissionskeyboard_arrow_down
What we expect from suppliers

"Make practical efforts to minimise the generation of waste, including making efforts to reuse and recycle waste where possible.

Take measures to support NSG Group’s Scope 3 greenhouse gas emissions objectives, including the adoption of renewable energy, where possible, and provide NSG Group with information, as requested.

Take action to manage pollutant air emissions within acceptable levels."
What we do

As part of supplier audits, suppliers are asked to provide evidence that all waste materials are disposed of in an efficient and safe manner. Suppliers are also asked to evidence that waste materials are being segregated to optimise reuse, re-cyclability and energy recovery.

NSG Group is working with key suppliers to better understand the CO2 in its supply chain and to identify and share best practices with its partners.

Under the Global Energy Management Programme, NSG Group engages with its supply base in every individual site project to identify a range of projects to reduce energy consumption and CO2 emssions or to introduce renewable energy generation within the Group.

More detailed information can be found on the Supplier Engagement page.
Inclusion & Diversitykeyboard_arrow_down
What we expect from suppliers

"Promote inclusivity and diversity within their business and supply chain."

"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

"Respect national employment law on working hours."

"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. Abuse, harassment or intimidation will not be tolerated under any circumstances nor will the act of pressurising or retaliating against the individual who reports such harassment."

"Operate and maintain an Employee Code of Conduct."
What we do

Suppliers are assessed and conintually monitored by EcoVadis for incidences of human rights violations and employment law violations.
Health & Safetykeyboard_arrow_down
What we expect from suppliers

"Provide a safe and healthy working environment by minimising, as far as is reasonably practical, the causes of hazards inherent in the working environment."

"Minimise the risk of exposure to harmful materials, machinery or operations."

"Operate and maintain an effective safety policy, including ensuring employees and visitors are sufficiently protected in the event of an infectious disease outbreak."

"Comply with local NSG Group Health and Safety policies when working at or visiting NSG Group premises."
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.

Any health and safety concerns related to supplier visits or working on NSG Group premises are reported to the supplier and managed through the NSG Group Supplier Management Escalation Procedure.
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."

"Comply with legislation regarding slavery and human trafficking."

"Undertake appropriate due diligence and ongoing management where recruitment agencies or brokers are used, in order to mitigate the risks of worker exploitation such as debt bondage and unsafe housing."

"Ensure that at a minimum, the legal minimum wage standard is adhered to across the workforce (including employees employed through recruitment agencies or brokers) and that unfair deductions are not made."

"Young people under the age of 15, or older if defined by law, must not be employed."
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

"Ensure that products supplied to NSG Group do not contain metals derived from minerals or their derivatives that finance or benefit armed groups or cause human rights abuses."

"Carry out due diligence with respect to the sourcing of conflict minerals and other minerals from high-risk areas and support NSG Group and our customers in complying with 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.
Risk Managementkeyboard_arrow_down
What we expect from suppliers

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

"Develop and implement procedures to regularly assess and evaluate all risks in their operations and supply chains."

"Implement and execute action plans, where risk is identified."

"Operate their business in a responsible and prudent manner to minimise the risk of financial failure."

"Inform NSG Group of any issues or developments that significantly increase the level of risk in the supply chain to NSG Group."

"Ensure resilience and be prepared for disruptions to its business as a result of emergencies, such as natural disasters, terrorism, civil unrest and pandemics. This should include implementing the appropriate contingency plans and regularly reviewing exposure in the supply chain."

"Ensure that sufficient levels of insurance are maintained."
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

"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

"Accept personal responsibility for behaving professionally ethically, fairly and with integrity."

"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."

"Operate and maintain an employee code of conduct."

"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

NSG Group carries out ABAC screening and due diligence on all new suppliers.

NSG Group carries out due diligence on all suppliers identified as ABAC risks.

Suppliers identified as ABAC risks are monitored by NSG Group for ABAC alerts using a 3rd party software.
Conflicts of Interestkeyboard_arrow_down
What we expect from suppliers

"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

"Comply with the fiscal obligations within all territories in which they operate, including paying taxes whenever and wherever due. Suppliers must not knowingly engage in or assist others in any activity, practice or conduct which could constitute tax evasion."
What we do

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

"Respect and protect intellectual property rights.

Implement and maintain robust cyber security processes within their systems.

Ensure that all uses and storage of personal data are in compliance with applicable laws and regulations, such as the General Data Protection Regulation (GDPR)."
What we do

NSG Group carries out risk assessments for any of its suppliers who process NSG data.

NSG Group maintains robust processes to manage cyber security of all interfaces between NSG Group and its suppliers.

NSG Group trains its employees to recognise and detect cyber fraud and to understand their IP and GDPR responsibilities.
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