Supplier code of conduct
Supplier code of conduct
Introduction – Almac’s Commitment to Ethical Business
Section 1: Business Integrity
1. Business Ethics in General and Adherence to Applicable Laws and Regulations
2. Anti-Bribery and Anti-Corruption
3. Accuracy of Business Records
4. Conflicts of Interest
5. Sanctions and Trade Compliance
6. Financial Crime
7. Debarment
8. Fair Competition and Anti-Trust
9. Confidential Information and Data Privacy
10. Intellectual Property
Section 2: Labour and Human Rights
11. Modern Slavery; Human Trafficking; Fair Workplace Practices
12. Non-Discrimination and Anti-Harassment
13. Diversity
Section 3: Environment, Health and Safety
14. Health and Safety
15. Environment
Section 4: Management Systems
16. Commitment and Accountability
17. Subcontracting and Risk Management
17. Business Continuity and Disaster Recovery
19. Audits and Inspections
Section 5: Transparency and Reporting
20. Reporting and Investigation
Almac’s Commitment to Ethical Business
Expectations and Scope of this Code
The Almac Group (“Almac”) is committed to conducting business by reference to the highest ethical standards. This involves conducting business honestly and in compliance with all applicable laws and regulations. Ethical business conduct is everyone’s responsibility. As such, this Supplier Code of Conduct (the “Code”) communicates Almac’s expectations of its suppliers, ensuring that anyone who provides services to Almac and its customers shares Almac’s values and works to the highest ethical standards.
This Code sets out the principles and requirements for establishing and maintaining a business relationship with Almac under the following five headings: (1) Business Integrity; (2) Labour and Human Rights; (3) Environment, Health and Safety; (4) Management Systems; and (5) Transparency and Reporting. This Code applies to any company or person who provides goods or services to Almac (“suppliers” or “you”). Suppliers are responsible for ensuring that they and their employees, agents, officers and management understand and comply with the principles in this Code, and that any third parties engaged by them also apply the same or substantially similar principles. As such, Almac requires its suppliers to read and understand the Code in full and to ensure that their conduct is substantially in alignment with this Code. In continuing to do business with us, you confirm your acceptance of this Code, and we reserve the right to monitor your ongoing compliance with the Code. This Code may not address every situation which suppliers may face when providing goods or services to Almac. If you are unsure as to how the Code applies in a particular situation, please contact Almac’s Corporate & Legal Affairs team by email to: [email protected].
In operating its business around the world, Almac takes steps to comply with the law wherever it does business. In practice, this means (among other things) complying with all applicable local and international anti-corruption laws and regulations which apply to Almac’s business, including but not limited to the U.S. Foreign Corrupt Practices Act, the UK Bribery Act and the UN Guiding Principles on Business and Human Rights. If any country where Almac does business sets out requirements which are more stringent than those detailed in this Code, we follow the more stringent rules in that place. Almac expects its suppliers to do likewise.
Almac believes that a strong relationship with each of its suppliers is critical both for its and its suppliers’ success. Almac aims to select business partners who, like Almac, operate their businesses with professionalism and integrity, who share Almac’s environmental and social values, and who acknowledge Almac’s ethical culture.
We look forward to continuing positive partnerships with you.
Alan Armstrong Chairman and CEO
Section 1: Business Integrity
1. Business Ethics in General and Adherence to Applicable Laws and Regulations
Almac is committed to fostering an open and honest culture of trust and integrity, interacting responsibly, ethically and transparently with all stakeholders. Almac expects its suppliers to conduct their business in an ethical manner and act with integrity.
Almac’s suppliers must comply with all applicable laws, rules, regulations and industry standards of the countries in which they operate, as well as this Code. Compliance with laws and international standards for responsible business conduct inspires trust between us and establishes a culture of integrity.
2. Anti-Bribery and Anti-Corruption
Almac takes a zero-tolerance approach to bribery and corruption. Almac is bound to comply with applicable anti-bribery legislation in the jurisdictions where it does business, including the Bribery Act 2010 in the UK and the Foreign Corrupt Practices Act 1977 in the US. Almac requires its suppliers to comply with applicable anti-bribery legislation in the jurisdictions in which they operate.
In particular, suppliers must not pay or accept bribes or participate in other illegal inducements to obtain improper advantages, and corruption in any form is strictly prohibited. Corruption includes, but is not limited to, fraud, bribery, kickbacks, facilitation payments and extortion. It may involve cash payments or non-monetary items of value (such as improper gifts, products or hospitality). Of course, in the normal course of business, occasions of infrequent business-related entertainment or gifts of nominal value may be appropriate.
Almac’s suppliers may only offer or accept such a gift or entertainment where it is permissible by local law, is infrequent, is not intended to influence decision-making or obtain an unfair advantage and where it is of customary and reasonable value. Almac requires its suppliers to keep financial records and have appropriate controls in place to prevent bribery and corruption.
3. Accuracy of Business Records
Suppliers are required to maintain organised and accurate up-to-date books and records in connection with the goods and/or services which they provide to Almac. Such records must include proper accounting for all payments and expenses made on behalf of or from funds provided by Almac to demonstrate compliance with applicable laws and regulations and International Financial Reporting Standards (IFRS) and/or Generally Accepted Accounting Practices (GAAP). Almac requires its suppliers to have accounting and financial internal controls to ensure records are accurate and complete in all material respects.
4. Conflicts of Interest
Almac’s suppliers must avoid situations which present, or create the appearance of, a conflict between their interests and their obligations to Almac and Almac’s obligations to its customers and other business partners. If a supplier becomes aware of any actual, apparent or potential conflict of interest between the supplier’s interest, duties, obligations or activities (including that of an individual employee of the supplier), Almac must be notified without delay.
5. Sanctions and Trade Compliance
Compliance with applicable sanctions laws and relevant import and export controls is a key part of what it means to do business ethically.
As such, Almac’s suppliers must not, during the course of doing business with Almac, (directly or indirectly) use or engage in any capacity any person or entity who or which is included in a sanctions list published by the United Kingdom, the European Union, any EU member State, the United States of America or the United Nations (each a “Sanctions Authority”), or resident or established in any sanctioned country, or otherwise violate any sanctions laws or regulations enacted by any Sanctions
Authority. If, in the course of performing services for Almac, a supplier becomes owned or controlled (directly or indirectly) by a person (or persons) who is (or are) listed on any published sanctions list or otherwise targeted by any applicable sanctions laws, or otherwise becomes aware of any potential breach of applicable sanctions laws in the course of their dealings with Almac, it must notify Almac (by confidential email to Almac’s Corporate & Legal Affairs team [email protected]) without delay.
Furthermore, suppliers must comply with all applicable laws and regulations with respect to import and export controls, licensing, denied parties, embargoes, antiboycotts and other trade restrictions which have been approved by national and international authorities. Suppliers must maintain complete and accurate import and export records.
6. Financial Crime
Almac is committed to the prevention of financial crime in all forms. In particular, Almac is committed to complying with applicable laws which seek to combat money laundering activities and to prevent the funding of terrorist or criminal activities, and it expects its suppliers to demonstrate similar commitments. Almac actively takes steps to prevent fraud occurring in its business activities and expects those doing business with or for Almac to report instances of fraud or potential fraud without delay. Furthermore, Almac seeks to uphold all laws relevant to countering tax evasion in the jurisdictions in which it operates, including the UK Criminal Finances Act 2017, and Almac expects that its suppliers will do likewise.
7. Debarment
Almac will not engage the services of any supplier who has been debarred or is subject to debarment pursuant to the Generic Drug Enforcement Act of 1992, 21 U.S.C. §335a(a) or any other applicable law. Furthermore, suppliers are not permitted to use any individual or entity in connection with the supply of the goods/services to Almac who has been debarred. If, during the course of its business relationship with Almac, a supplier or any individual or entity utilised by a supplier to supply the goods/ services, becomes the subject of a debarment, it must notify Almac (by confidential email to Almac’s Corporate & Legal Affairs team [email protected]) without delay.
8. Fair Competition and Anti-Trust
Almac firmly believes that fair competition is in everyone’s best interest. Fair competition in open markets can encourage businesses to be innovative in how they develop their business and make the best use of the resources which are available to them. As such, Almac requires its suppliers to abide by global fair competition and anti-trust laws and to compete fairly.
9. Confidential Information and Data Privacy
Confidentiality is crucial to Almac and its customers. Suppliers must have processes in place to ensure that the confidentiality of all information is guaranteed by them and their representatives, and the sharing of such information with authorised recipients must only be on a ‘need to know’ basis.
If a supplier is given access to Almac’s or any customer’s confidential information (including but not limited to intellectual property, study data and documents and personal data) the supplier must respect the confidentiality of such information and must not use any such confidential information for their own purposes. Suppliers must ensure that confidential information disclosed to them during the course of their relationship with Almac is protected and remains confidential, and that such information is used only as appropriate for the delivery of goods and services to Almac. In particular, if such confidential information includes personal data, the supplier must process any such data in accordance with Almac’s and the customer’s instructions.
Almac respects the personal data which it collects in the ordinary course of its business and is committed to complying with all applicable laws related to data privacy. Suppliers must have adequate data privacy and security measures in place to ensure that personal data is protected and remains confidential. Such personal data must not be disclosed or transferred without Almac’s written permission. Almac requires that its suppliers comply with all applicable data privacy laws and regulations.
10. Intellectual Property
Suppliers shall respect Almac’s and Almac’s customers’ intellectual property rights (including processes, information, copyrights, trademarks, patents, trade secrets, logos, brands and know-how). Almac requires that its suppliers take all necessary precautions to safeguard intellectual property which they develop or process on behalf of Almac.
Section 2: Labour and Human Rights
11. Modern Slavery; Human Trafficking; Fair Workplace Practices
Suppliers shall respect all internationally recognised human rights, avoid infringing on the human rights of others and address adverse human rights impacts with which they are involved.
Suppliers must ensure that all of their employees work on a voluntary basis and furthermore must prohibit all forms of human rights abuses in any part of their supply chain including child labour; forced, involuntary or indentured labour; slavery; human trafficking; and physical punishment.
Suppliers shall also comply with all internationally recognised human rights understood, at a minimum, as those expressed in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work from time to time in force. Furthermore, suppliers shall promptly investigate any reports received outlining concerns or illegal activities in the workplace and additionally shall comply with all applicable wage and hour laws and regulations. We expect our suppliers to remunerate their employees fairly and competitively relative to their industry and to offer opportunities for employees to develop their skills and capabilities.
Almac supports fair employment practices which are consistent with Almac’s commitment to human rights in its workplaces. Almac seeks to do the following:
(i) Establish a strong and direct relationship with employees through open and honest communications.
(ii) Treat all employees with fairness, dignity and respect.
(iii) Abide by applicable local labour laws (including those which address working hours, remuneration, discrimination and third-party representation).
(iv) Hold each other accountable for performance at the highest levels.
(v) Provide opportunities for employees to develop personally and
professionally.
Almac’s suppliers must follow applicable laws and similar standards and principles to the ones outlined above in the countries in which they operate.
12. Non-Discrimination and Anti-Harassment
Suppliers shall provide a workplace free from discrimination (e.g., on the grounds of race, colour, ethnicity, religion, gender, pregnancy, age, sexual orientation, marital status, disability, veteran or military status, nationality or political affiliation) or harassment (e.g., physical, verbal, visual, psychological, sexual harassment or any other conduct that creates an intimidating, offensive or hostile work environment).
13. Diversity
Suppliers shall seek to build and promote an environment which is inclusive of all people and their abilities, strengths and differences. Inclusion means creating a workplace where people can be themselves regardless of gender, gender identity, race, colour, ethnicity, cultural affiliation, sexual orientation, age, religion or beliefs.
Section 3: Environment, Health and Safety
14. Health and Safety
All suppliers are required to comply fully with applicable Health, Safety and Environmental laws as well as any related regulations and approved codes of practice applicable to their jurisdiction.
Suppliers shall conduct regular risk assessments of their operations and take appropriate measures to mitigate identified risks, ensuring a safe working environment for those who may be impacted such as employees, contractors and neighbours. All employees, contractors and agents of the supplier should be adequately trained and informed about health and safety requirements specific to their roles and functions and be supplied with the necessary protective equipment. Accidents, incidents and near misses should be reported with corrective actions taken to prevent a recurrence.
Equipment and machinery must meet the relevant safety standards and be adequately maintained. Appropriate emergency response plans and arrangements are to be implemented with regular testing and training performed.
Suppliers are expected to maintain accurate records of their health and safety systems and, if requested, make available for audit and inspection.
15. Environment
Suppliers shall seek to create a sustainable environment and to operate in a manner which minimises adverse impacts on the environment. In particular, suppliers should strive to us resources (water, energy, raw materials) efficiently and they are encouraged to recycle and reuse wherever possible. Suppliers should set targets to minimise energy use and greenhouse gas emissions, implement plans for waste reduction, increase recycling, and reduce water use.
Suppliers must comply with all relevant environmental laws and take steps to improve their environmental performance. Suppliers must ensure they obtain and maintain any requisite environmental permits and comply with applicable reporting requirements. Suppliers should monitor, control, and treat emissions, wastewater, and waste generated from their operations as required by applicable regulations, and they must safely handle, store, and dispose of hazardous materials. Proper documentation and disclosure regarding the use and disposal of hazardous materials are expected.
In relation to climate change, suppliers are encouraged to measure, report, and reduce greenhouse gas emissions and to set reduction targets in line with global standards. In terms of biodiversity, suppliers operating near protected or sensitive areas should take steps to ensure that their operations do not harm local biodiversity. Suppliers are encouraged to implement an Environmental Management System, such as ISO 14001 or an equivalent system, to identify, manage, monitor and reduce environmental impact, and they should maintain accurate records of their environmental practices, incidents, and improvement measures. We encourage our suppliers to collaborate with us, other suppliers and relevant authorities to promote and advance sustainable environmental practices in the supply chain.
Section 4: Management Systems
16. Commitment and Accountability
Almac expects that its suppliers will demonstrate commitment to this Code and the principles outlined in it by allocating appropriate resources and maintaining adequate documentation to demonstrate conformance with its principles and values.
17. Subcontracting
Should a supplier intend to use a subcontractor in providing goods and/or services to Almac, the supplier must ensure that the subcontractor performs in an ethical and lawful manner and in accordance with this Code.
18. Business Continuity and Disaster Recovery
Almac’s suppliers should implement, and maintain, business continuity and disaster recovery plans for all operations which support the provision of any goods and/or services to Almac and/or Almac’s customers. Almac requests that its suppliers take steps to identify, assess and manage relevant risks faced by their businesses (including supply chains) on an ongoing basis. This includes assessing risks associated with subcontractors and other persons or entities acting on a supplier’s behalf.
19. Audits and Inspections
Almac reserves the right to audit its suppliers upon reasonable notice to ensure compliance with the standards set out in this Code. Suppliers should provide Almac with necessary information when requested and allow Almac (or its representatives) to have access to a supplier’s relevant premises and documentation to enable Almac to verify that such supplier, its employees and subcontractors (if any) comply with this Code. Suppliers must fully investigate any non-compliances and incidents which are identified and take corrective and preventative actions as needed.
Section 5: Transparency and Reporting
20. Reporting and Investigation
Almac encourages openness and transparency in its business dealings. Suppliers should report any breach or potential breach of this Code (or of any applicable laws), to Almac without delay by confidential email to Almac’s Corporate & Legal Affairs team [email protected].
Suppliers must not retaliate or take disciplinary action against any individual who has, in good faith, reported breaches (or potential breaches) of this Code or who has sought advice regarding this Code.
Where a potential violation of this Code has been reported, Almac will investigate the report to the fullest extent possible and will respond appropriately, which may include terminating our relationship with the supplier concerned.