Supplier Code of Conduct

Introduction

At Zebra North, we are committed to upholding the highest standards of integrity, fairness, and sustainability. Our Supplier Code of Conduct outlines the values we expect our suppliers to embrace and reflects our commitment to ethical business practices. This code applies to all suppliers, vendors, and contractors involved in providing goods and services to Zebra North.

1. Compliance with Laws and Regulations

Suppliers must comply with all applicable local, national, and international laws, regulations, and standards. This includes laws related to labour, health and safety, environmental protection, data privacy, and anti-corruption. Suppliers operating in the UK and EU must adhere to relevant regulations such as the UK Modern Slavery Act 2015, the UK Bribery Act 2010, the UK Equality Act 2010, the EU General Data Protection Regulation (GDPR), and the EU Directive on Corporate Sustainability Due Diligence (CSDD).

2. Labour Standards and Human Rights

Zebra North is committed to respecting the fundamental rights of all workers. Suppliers must ensure that:

– No Forced or Child Labour: All forms of forced, bonded, or involuntary labour are strictly prohibited. Suppliers must not employ anyone under the legal minimum age or any age that would compromise their health, safety, or education, in line with the International Labour Organisation (ILO) conventions and the EU Directive on the protection of young people at work.

– Fair Treatment: All workers must be treated with respect and dignity. Discrimination, harassment, abuse, or any form of intimidation is unacceptable. Suppliers must comply with the UK Equality Act 2010 and applicable EU anti-discrimination laws.

– Freedom of Association: Workers must have the right to associate freely, join or not join trade unions, and engage in collective bargaining without fear of retaliation, as protected under ILO conventions, the European Convention on Human Rights, and the UK Trade Union and Labour Relations (Consolidation) Act 1992.

– Wages and Working Hours: Suppliers must adhere to local laws governing wages, benefits, and working hours. Compensation should meet the legal minimum and allow workers to support a reasonable standard of living. This includes compliance with the UK National Minimum Wage Act 1998 and the EU Working Time Directive (2003/88/EC).

– Humane Treatment: Suppliers must ensure that all workers are treated humanely, without the use of physical punishment, coercion, or threats. Mechanisms should be in place to report abuse, discrimination, or violations safely and without fear of reprisal.

3. Health and Safety

Suppliers must provide a safe and healthy working environment, ensuring compliance with all relevant laws and standards. This includes addressing potential hazards, providing safety training, and ensuring that facilities are equipped with adequate safety measures. Suppliers in the UK must comply with the Health and Safety at Work etc. Act 1974, and those in the EU must comply with the EU Occupational Safety and Health (OSH) Framework Directive (89/391/EEC). Suppliers should also maintain emergency preparedness plans and conduct regular safety audits.

4. Environmental Responsibility

Suppliers are expected to take reasonable steps to minimise the negative environmental impact of their activities. This includes reducing energy consumption, managing waste responsibly, conserving natural resources, and adhering to relevant environmental regulations. Compliance with the UK Environmental Protection Act 1990 and EU regulations such as the Waste Framework Directive (2008/98/EC) is mandatory. UK suppliers should also be aware of and adhere to the UK’s Net Zero Strategy for reducing carbon emissions. Suppliers are also encouraged to adopt climate-related strategies, including setting emission reduction targets and publicly reporting progress, aligned with a 1.5°C climate pathway.

5. Ethical Business Practices

– Anti-Bribery and Anti-Corruption: Suppliers must operate with integrity. The giving or receiving of bribes, kickbacks, or any other form of undue influence is strictly prohibited. Suppliers must comply with the UK Bribery Act 2010 and EU anti-corruption standards. Suppliers may not engage in activities that could be perceived as corrupt or that would violate anti-money laundering and anti-terrorism regulations.

– Fair Competition: Suppliers must conduct business in a manner that respects free and fair competition, avoiding any anti-competitive practices. Suppliers must adhere to UK competition law, including the Competition Act 1998, as well as EU competition law, including Articles 101 and 102 of the Treaty on the Functioning of the European Union (TFEU).

– Confidentiality: Suppliers must protect the confidentiality of any proprietary or sensitive information shared by Zebra North, using it only for its intended purpose, in line with the GDPR and other applicable data protection laws. Suppliers must have technical and organisational security measures in place to safeguard information.

6. Diversity, Equity, and Inclusion

We value diversity and expect our suppliers to promote an inclusive environment where every individual is treated with dignity and respect. Suppliers should make hiring and employment decisions based on qualifications, skills, and performance, without discrimination on the basis of race, gender, religion, or other protected characteristics, as defined by the UK Equality Act 2010 and the EU Charter of Fundamental Rights.

7. Monitoring and Compliance

Zebra North reserves the right to audit supplier facilities and practices to ensure compliance with this Code of Conduct. Suppliers must be transparent in their practices and cooperate fully with any assessments or audits conducted by Zebra North. This may include adherence to the reporting requirements outlined in the EU Corporate Sustainability Reporting Directive (CSRD). Suppliers are also expected to cooperate with audits carried out in compliance with UK standards under the Companies Act 2006.

8. Reporting Violations

Suppliers are encouraged to report any suspected violations of this Code of Conduct to Zebra North without fear of reprisal. We believe in open communication and encourage our partners to uphold the highest ethical standards. Reports should comply with the EU Whistleblower Protection Directive (2019/1937) as well as the UK’s Public Interest Disclosure Act 1998.

9. Sustainability and Corporate Responsibility

Zebra North expects its suppliers to take an active role in supporting sustainability initiatives. Suppliers must work towards reducing their greenhouse gas emissions, and where applicable, adopt science-based emission-reduction targets. Environmental management should focus on reducing waste, promoting resource efficiency, and using renewable energy wherever possible. Suppliers should also promote the responsible use of water and prevent pollution to safeguard local water sources. Compliance with relevant global standards, such as the United Nations Sustainable Development Goals (UN SDGs), is encouraged.

10. Conflicts of Interest

Suppliers must avoid situations that create conflicts of interest that could impair their ability to make objective business decisions. Any potential or actual conflicts of interest must be promptly disclosed to Zebra North. Suppliers are expected to have policies in place to identify, manage, and mitigate such conflicts to maintain transparency and integrity in business dealings.

Conclusion

Zebra North is committed to working with suppliers who share our values and dedication to ethical business practices. We believe that by working together, we can promote sustainable, responsible, and inclusive growth. As a UK-registered company, we hold ourselves and our suppliers to the highest standards of compliance with both UK and EU regulations, promoting a culture of integrity and responsible business.