1. INTRODUCTION
At Smollan, we are committed to upholding the highest standards of ethical conduct, social responsibility, and environmental stewardship across all our operations. This commitment extends to our entire supply chain. With extensive operations and entities, we recognise our responsibility to partner with suppliers who share our values and contribute to sustainable and responsible business practices.This Supplier Code of Conduct (the "Code") outlines the fundamental principles and minimum requirements that Smollan expects all its suppliers of goods and services, including their employees, agents, and sub-contractors to adhere to when conducting business with or on behalf of Smollan. This Code supplements, and does not supersede, any specific terms and conditions agreed as part of our supply relationships.
We expect our Suppliers to not only comply with this Code but also to implement their own systems, processes and employee training programmes to ensure compliance within their own supply chains.
This Code draws from internationally recognised standards, including the UN Global Compact, ILO Conventions, OECD Guidelines for Multinational Enterprises and ISO 20400 relating to Sustainable Procurement.
2. OUR CORE VALUES AND PRINCIPLES
This Supplier Code of Conduct is fundamentally rooted in the core values and principles that guide our entire organisation. This Code establishes the essential, foundational expectations we hold for all our suppliers. By adhering to the standards outlined here, you commit to operating with integrity, fostering a culture of respect and fairness, maintaining environmental responsibility, and upholding all relevant laws and regulations. The spirit of ethical and responsible partnership detailed herein remains the constant, non-negotiable standard for engaging with Smollan.3. LABOUR AND HUMAN RIGHTS
Smollan is committed to respecting and promoting human rights throughout its operations and supply chain, in line with legislative statutes and regulations.3.1. Modern Slavery and Forced Labour: Zero Tolerance
Suppliers must have a zero-tolerance approach to all forms of modern slavery, forced labour, bonded labour, indentured labour, human trafficking, or involuntary prison labour.- All work must be voluntary, and workers must be free to leave their employment after reasonable notice as required by contract or law.
- Suppliers must not engage in or support trafficking of persons, nor use any form of physical restraint, threats, intimidation, or other forms of coercion.
- Workers must not be required to surrender government-issued identification, passports, or work permits as a condition of employment.
- Suppliers must not charge workers recruitment fees or other related fees for employment.
3.2. Child Labour: Zero Tolerance
Suppliers must not employ child labour. The term "child" refers to any person under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is higher. Lawful apprenticeship and internship programmes are permitted if they comply with all laws and regulations.3.3. Wages, Benefits, and Working Hours
Suppliers must compensate all workers with wages and benefits that meet or exceed the legal minimum requirements and recognised accredited industry standards.- Working hours must comply with applicable laws and industry standards.
- Workers must be granted rest and time away from work as legally required.
3.4. Non-Discrimination and Diversity
Suppliers must foster a workplace free from discrimination and harassment. Employment decisions must be based on merit, qualifications, and abilities, without discrimination based on race, colour, religion, gender, sexual orientation, gender identity, national origin, age, disability, marital status, or any other characteristic protected by applicable law.3.5. Freedom of Association and Collective Bargaining
Suppliers must respect the rights of all workers to form and join trade unions of their own choosing, to bargain collectively and to engage in peaceful assembly, without fear of retaliation, intimidation, or harassment.3.6. Safe and Healthy Workplace
Suppliers must provide a safe and healthy working environment for all their workers, preventing accidents, injuries, and health risks.- Compliance with all applicable occupational health and safety laws and regulations.
- Providing appropriate personal protective equipment (PPE).
- Implementing effective safety training programs and emergency preparedness procedures.
- Ensuring access to clean drinking water, sanitary facilities, and adequate lighting and ventilation.
4. ENVIRONMENTAL STEWARDSHIP
Smollan is committed to minimising its environmental footprint and working towards a more sustainable future. We expect our Suppliers to share this commitment and actively manage their environmental impact.4.1. Environmental Compliance
Suppliers must comply with all applicable environmental laws, regulations, and standards in their operations and the provision of goods and services.4.2. Resource Efficiency and Emissions
- Suppliers are encouraged to implement environmental management systems.
- Suppliers should actively work to reduce their consumption of energy, water, and natural resources.
- Suppliers are encouraged to set science-based climate targets.
- Smollan supports suppliers working toward carbon reduction and sustainability.
4.3. Waste Management
Suppliers must implement robust waste reduction, reuse, and recycling programmes. All unavoidable waste must be disposed of responsibly and in compliance with applicable regulations.4.4. Chemical and Hazardous Substances Management
Suppliers must safely manage, handle, store, and dispose of chemicals and hazardous substances in accordance with applicable laws and regulations.4.5. Sustainable Sourcing and Materials
- Sourced responsibly and ethically.
- Recycled, recyclable, or made from renewable resources.
- Low-impact throughout their lifecycle.
4.6. Supplier Diversity and Inclusion
Suppliers are encouraged to support the inclusion of diverse enterprises within their own supply chains.5. ETHICAL BUSINESS PRACTICES AND GOVERNANCE
Smollan conducts its business with the highest standards of integrity and expects its Suppliers to do the same.5.1. Anti-Bribery and Anti-Corruption
Suppliers must strictly prohibit and have a zero-tolerance policy for all forms of bribery, corruption, extortion, and embezzlement.5.2. Fair Competition
Suppliers must conduct their business in accordance with all applicable antitrust and fair competition laws.5.3. Data Privacy and Security
Suppliers who collect, process, store, or otherwise handle personal data on behalf of Smollan or its clients must comply with all applicable data protection laws.- Cooperate with Smollan security reviews and audits.
- Execute Data Processing Agreements where required.
- Notify Smollan of breaches within 24 hours.
- Maintain records of jurisdictions where data is stored or processed.
5.3.1. Artificial Intelligence Processing
- Smollan data may not be used to train AI models without written agreement.
- Suppliers must ensure AI systems do not expose Smollan data improperly.
- Transparency regarding AI usage must be provided upon request.
- Human oversight must remain in place for AI-generated outputs.
- Suppliers must comply with applicable AI regulatory frameworks.
5.4. Intellectual Property Rights
Suppliers must respect the intellectual property rights of Smollan and third parties.5.5. Confidentiality
Suppliers must protect the confidential information of Smollan and its clients.5.6. Responsible Sourcing and Supply Chain Due Diligence
Suppliers are expected to implement due diligence processes to identify and mitigate risks related to human rights, environmental impact, and ethical practices.5.7. Conflict of Interest
Suppliers must avoid any actual or perceived conflicts of interest when doing business with Smollan.6. BUSINESS CONTINUITY AND DISASTER RECOVERY
Suppliers providing critical goods and services to Smollan must demonstrate that they have robust business continuity and disaster recovery plans in place.- Identify critical services and recovery objectives.
- Outline procedures for data backup and system recovery.
- Include communication protocols for disruptions.
- Be regularly tested and reviewed.