Supplier and Subcontractor Code of Conduct

Plexal (City) Limited are the innovation company and workspace solving society’s challenges through collaboration on technology with government, startups and industry.

Plexal strives to lead by example ensuring that the way we do business is fair, transparent and supports startups and SMEs. We achieve this is by partnering with businesses who align to our core values.

As part of our Supply Chain policies and procedures, we require that our Suppliers and Subcontractors comply with all applicable laws, regulations and standards within the geographies in which they operate. In instances where the standards outlined within this Code of Conduct document differ from local laws and customs, we expect our Suppliers and Subcontractors to respect these standards within the specific geography’s customs and local laws.

Plexal strives to:

  • Operate fair, honest, competitive and transparent procurement processes, conducted with integrity
  • Appropriately manage Supplier and Subcontractor related risks
  • To provide support for Subcontractors to ensure highest quality delivery to Plexal customers
  • Protect Plexal’s reputation and meet regulatory requirements

Through this Code of Conduct, we ask our Suppliers and Subcontractors to commit to:

  • Ethical supply chain and people practices
  • Prevention of financial crime
  • Environmental responsibility
  • Data protection and information security
  • Health and safety

This Code of Conduct will be reviewed on a periodic basis, at least annually, and when there are notable changes in laws, regulations and standards.

Definitions

Plexal defines a:

Subcontractor as any company or individual responsible for delivering key components of Plexal’s client contracts.

Supplier as any company or individual who delivers a services or products to Plexal who is not classed as a Subcontractor.

General Requirements

Plexal expects its Suppliers and Subcontractors to behave ethically, apply high standards of corporate conduct, and fully comply with all relevant laws.

Prospective suppliers must keep all pre-contract data, negotiations and tender processes confidential and may be requested to enter into a non-disclosure agreement. Plexal has a responsibility to conduct due diligence on any Supplier or Subcontractor before entering a commercial relationship. This may include reviewing copies of policies, accreditation and financial due diligence. We expect suppliers to cooperate promptly with due diligence enquiries.

Suppliers and Subcontractors are expected to self-monitor their compliance with this Code of Conduct and inform us of any non-compliance – including for any other supply chain partners, subcontractors or suppliers they may contract with. Suppliers and Subcontractors not meeting our requirements or expectations as articulated in this Code of Conduct may be subject to measures, which may include remediation.

Workforce and Human Rights

Plexal is committed to respecting and upholding human rights and labour laws, including preventing acts of modern slavery and human trafficking from occurring within its business. We require our Suppliers and Subcontractors to operate in accordance with these high standards, and in full compliance with all applicable laws and regulations.

Suppliers and Subcontractors must be able to provide sufficient evidence of compliance with all workforce related issues within their supply chain to ensure compliance with the law and this Code of Conduct. We expect our supply chain to support our commitment to human rights by having policies and processes in place to cover the following areas:

  • Occupational Health and Safety: the provision of a safe working environment, with policies in place to ensure appropriate standards according to local regulations.
  • Freely chosen employment: all work is completed voluntarily and free from slavery and human trafficking. Suppliers and Subcontractors should not impose unreasonable restrictions on movement within the workplace, and avoid practices which could lead to worker exploitation. Child labour will not be employed and employment terms for young workers must adhere to International Labour Organisation Standards and relevant law. Employees have the right to leave employment when they choose.
  • Equal opportunities:to ensure no job applicant, employee or other individual is discriminated against and less fairly treated because of their protected characteristics, beliefs, union membership, political affiliation or any other condition not justified in relevant law or relevant to the performance of the role.
  • Freedom of religion or belief: all workers have the right to exercise freedom of thought, conscience, religion and belief.
  • Workplace arrangement and working hours: all workers receive terms and conditions relevant to their employment in their primary language, and are not required to surrender government issued identification as a condition of employment. All workers are entitled to work, and be paid for, a minimum level of working hours. Working hours are not excessive and maximum working hours comply with national laws. Overtime is voluntary, and there should not be a threat of penalisation for not working overtime.
  • Supply chain compliance: ensuring that third parties engaged through your business are compliant with local laws and regulations, including those specified in this Code of Conduct.
  • Employee wages and benefits: responsibility for employee compensation and payment of fair wages – compliant with local law and regulation around minimum wage or the prevailing industry wage (whichever is higher). Employees are provided with all benefits under relevant law and no non-statutory deductions shall be made from wages.
  • Employee freedom of association and collective bargaining: respecting the rights of workers to exercise the freedom of association and collective bargaining, including joining trade unions.
  • Zero tolerance for discrimination, harassment and abuse: Plexal (City) Limited exercises a zero tolerance policy of workplace discrimination, harassment and abuse on any grounds. This includes protected characteristics as defined in the Equality Act 2010. We expect Suppliers and Subcontractors to operate the same zero tolerance stance.
  • Grievances: Suppliers and Subcontractors to have a formal grievance policy or process, for employees to air grievances without fear of perceived or real retaliation.
  • Whistleblowing: Suppliers and Subcontractors to have a formal whistleblowing policy or process, and protect whistleblower confidentiality and prohibit retaliation.
  • Training: where necessary for the role to be executed compliantly, training shall be provided to workers and regular refresher training provided on a timely basis.

Prevention of Financial Crime

Plexal complies with all relevant legislation and regulation around financial crime. Suppliers and Subcontractors shall comply with all relevant law pertaining to financial crime and must not do, or omit to do, anything which would cause to be in breach of such relevant law. Suppliers and Subcontractors must have procedures and/or policies in place which prohibit their employees from:

  • Offering, receiving, giving or soliciting bribes
  • Using gifts or hospitality to induce a fraud or other wrongdoing
  • Use sponsorship or advertising agreements to exercise undue influence
  • Making unapproved or unauthorised charitable or political donations

Suppliers and Subcontractors should have a policy and/or procedure in place to verify the legitimacy of the origin of goods and services within their supply chain and the identity and legitimacy of the businesses contracted.

Suppliers and Subcontractors shall have adopted a tax policy that demonstrates willingness to pay the right amount of tax, in the right place, at the right time. Measures should be in place to monitor the risk and identify mitigations which may prevent breaches from occurring, including a reporting mechanism.

Supplier and Subcontractor employees should receive the appropriate training to prevent, identify and detect financial crime issues.

Environmental Management

Plexal understands that environmental management, and the associated impacts, are integral to business practice. We take a proactive approach to environmental management and encourage our Suppliers and Subcontractors to implement environmental management policies, processes or programmes appropriate to the nature and scale of their businesses. Environmentally friendly working practices should be used wherever possible. We encourage the alignment to, and adoption of, best practices including having the following in place:

  • Environmental Policy: to outline the business’s commitment to reducing harm to the environment, with a framework for environmental management.
  • Environmental Management: processes in place which identify and evaluate the environmental benefits and impacts of their activities. This may include: water, energy, waste management, pollution, greenhouse gas emissions, hazardous waste disposal. There should be processes in place to avoid, mitigate and manage any significant impacts.
  • Reporting and Disclosure: Suppliers and Subcontractors should have objectives and targets for continual improvement in place. Data may need to be disclosed to Plexal to demonstrate performance. Any regulatory breaches and incidents involving a regulator should be disclosed to Plexal, alongside a mitigation plan to rectify or resolve the breach.
  • Carbon Reduction Plan: to articulate the business’s commitment to reducing their carbon emissions aligning to long-term net zero commitments.

Equity, Diversity & Inclusion (EDI)

Plexal is committed to an equitable, diverse and inclusive working environment, to better deliver services to our customers and clients. We have all necessary arrangements in place to comply with the Equality Act 2010. We ensure that current and prospective staff are in no way discriminated against because of any Protected Characteristics or any other reason. We are committed to supply chain diversity, maintaining a culture which enables, supports and provides opportunities for people from all backgrounds.

We expect Suppliers and Subcontractors to have policies, procedures and processes in place to maintain these standards, including:

  • Workplace equity, diversity and inclusion:  demonstrating commitment to equity, diversity and inclusion through policies, workplace operations and management.
  • Supplier diversity: commitment to managing diverse supply chains.

Prompt Payment and Invoicing

Plexal is part of the Prompt Payment Code, and have payment terms for Suppliers and Subcontractors to ensure prompt payment where authorised and compliant invoices have been received. We expect Suppliers and Subcontractors to adhere to local prompt payment legislation or standards.

Suppliers and Subcontractors must supply Plexal with invoices quoting the relevant, valid Purchase Order (PO) number in line with the contracted terms of their delivery. Suppliers and Subcontractors are responsible for ensuring an accurate and valid invoice. Any incorrectly submitted invoices may be returned to Suppliers for correction and resubmission. The standard conditions for purchase of goods and/or services can be viewed here.

Plexal commits to:

  1. Paying Suppliers and Subcontractors on time: within the agreed, contracted terms upon receipt of a valid undisputed invoice
  2. Providing clear instructions and support: on terms and conditions, procurement processes and payment procedures. Plexal will flag errors on incorrect invoices promptly . Plexal will advise Suppliers or Subcontractors promptly of any disputes, and invoices subject to dispute will not be paid until resolution of that dispute
  3. Standard payment terms of 30 days: with two payment runs a month via BACS (Bank Automated Clearing System)
  4. Efficiently handle any complaints: if a Supplier or Subcontractor has an invoice or payment related complaint, they must email accounts@Plexal.com with the relevant supplier reference number and Purchase Order number.

Data Protection and Information Security

Plexal take security of its data and information very seriously. Suppliers and Subcontractors must comply with all relevant laws pertaining to data protection, and must not do (or omit to do) anything which would cause Plexal to be in breach of such relevant law.

If the Supplier or Subcontractor will be collecting personal data on behalf of Plexal, it will only do so in accordance with pre-determined and agreed terms. Likewise, should the Supplier or Subcontractor be collecting data where Plexal will be a controller or joint controller, this must be agreed in advance of collection and in accordance with Plexal’s Data Protection Policy.

Product, Service and Operational Responsibility

Plexal commits to delivering high quality services to our customers and clients. Our Suppliers and Subcontractors are expected to support this commitment through:

  • Meeting delivery acceptance criteria, as set out in agreements with Plexal
  • Avoidance of banned or disputed products and services, including the advertising and marketing of banned or disputed products in accordance with regulatory codes
  • Fair and transparent dealing with customers, including having processes in place to manage vulnerable customers to avoid harm

Raising a Concern (Whistleblowing)

Plexal has a whistleblowing policy, and we expect our Suppliers and Subcontractors to have a whistleblowing policy or process in place, and for their employees to be able to raise any concerns without fear of real or perceived retaliation.