The Redwood Group takes care to ensure it conducts its business in compliance with various laws and regulations globally in order to ensure it operates in an ethical, responsible and sustainable manner, with respect to both people and the environment. It is important that any supplier to The Redwood Group can demonstrate that their business aligns with our objectives. This Code of Conduct document sets out the minimum requirements with regard to the ethics and compliance that The Redwood Group expects of each supplier it employs within its supply chain. Suppliers, their affiliates, subsidiaries and employees must adhere to this Supplier Code of Conduct while conducting its business. This Code of Conduct applies to all suppliers, their affiliates and subsidiaries and their subcontractors (collectively “Supplier”).

1. Compliance with Laws:

In addition to the expected behaviours and standards contained within this Code of Conduct, Supplier shall comply with all applicable laws, regulations, directives and decrees in all territories and countries in which it does business and provides goods and/or services.

2. Labour Practices:

2.1 Equal Opportunities and Dignity at Work:
Supplier shall ensure that it implements and maintains a policy which is effective in ensuring equal opportunities and preventing discrimination, harassment or bullying of employees in the workplace.
a. Supplier recruitment of new staff will be based on the job requirements and the individual’s suitability and ability to do, or to train for, the job in question and no other reason.
b. Supplier shall ensure that the recruitment process is carried out consistently for all jobs at all levels within the Company and that it is seen to be fair and non-discriminatory.
c. Supplier shall not in the recruitment process discriminate on the basis of race, colour, ethnic origin, nationality, national origin, religion or belief, sex, sexual orientation, gender, age, marital or civil partnership status, disability, children and/or domestic obligation.
d. Supplier shall respect the rights of employees to decide if they wish to be represented by and engage in activities with any applicable trade unions.
e. Supplier shall be committed to comply with all international labour laws. Specifically in regards to the use of child labour and shall in any event ensure that no employees are below the age of sixteen (16).
f. Supplier shall ensure that all employee working hours comply with all applicable laws and that employees are compensated in line with all applicable wage laws.
g. Supplier shall comply with applicable health and safety laws and regulations, and identify, evaluate and control employee exposure to safety and health hazards by ensuring all steps are taken to create a safe and hygienic working environment.
h. Supplier shall have policies and procedures in place to ensure employees do not suffer harassment in the workplace, for any reason, including on the grounds of an employee’s race, colour, ethnic origin, nationality, national origin, religion or belief, sex, sexual orientation, gender reassignment, age, marital or civil partnership status or disability, which has the purpose or effect, whether intentional or not, of violating the employee’s dignity at work, or of creating an intimidating, hostile, degrading, humiliating or offensive work environment for the employee.

2.2 Prevention of Slavery and Human Trafficking
a. Supplier shall, at all times, comply with the provisions of the Modern Slavery Act 2015.
b. Supplier shall ensure that all its subcontractors have a zero tolerance policy to forced or slave labour. Specifically Supplier shall ensure that it does not, and the Supplier’s in its own supply chain do not:
1) Engage in any slavery or servitude or any other forced or compulsory labour anywhere in the world.
2) Facilitate or arrange the travel of another person or people with a view to that person or people being exploited anywhere in the world. Arranging or facilitating shall include recruiting, transporting or transferring, receiving or harbouring, exchanging or transferring control over a person or people.

3. Environment Protection and Compliance

Supplier shall strive to create regenerative processes and minimize adverse effects on the environment and wider community. Supplier shall ensure it has all proper environmental permits in place to conduct its business, where required. Supplier should make principal environmental commitments to:

a. ensure that the Company continues to comply with present and future environmental standards and legislation, codes of practice, regulatory controls and Client and insurance requirements;
b. minimise practically avoidable pollution or nuisance that may be caused by our activities;
c. minimise the use of all materials, supplies and energy and wherever possible to use renewable or recyclable materials;
d. adopt an environmentally sound transport policy;
e. minimise the generation of waste and to dispose of unavoidable waste in a responsible manner;
f. consider the environmental implications of change to products, processes, materials and facilities when business decisions are made;
g. actively promote, where possible, those products which contribute to energy conservation and do not damage the environment
h. continually improve our environmental performance through the setting and reviewing of realistic and achievable objectives and targets;
i. communicate these environmental standards to staff and encourage them to participate in the achievement of these goals;
j. provide appropriate resources for the implementation of these standards.

In addition, Supplier should adhere to all applicable environmental legislation and regulations, including but not limited to the Restriction of Hazardous Substances (RoHS) directive of the European Union.

4. Anti-Bribery and Corruption

Supplier shall conduct all business in an honest and ethical manner. Supplier shall have a zero tolerance policy to corruption and bribery and commit to acting professionally, fairly and with integrity in all business dealings and relationships, wherever they operate, implementing, and enforcing effective systems to counter bribery. Supplier shall uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which they operate

a. Supplier and Supplier’s representatives will not make, offer, solicit or accept any payments or transfers of value, including but not limited to material rewards, gifts or services of any kind, made with the intention of public or commercial bribery, or acceptance or acquiescence in extortion, kickbacks or other unlawful or improper means of obtaining or retaining business, either for or on behalf of Supplier or The Redwood Group.
b. The practice of Supplier or Supplier’s representatives accepting gifts beyond the normal amenity of customer/business practice is considered neither desirable nor ethical and is in direct violation of various anticorruption laws, rules, regulations and decrees applicable to the respective party (collectively, “Legislation”), including the United States Foreign Corrupt Practices Act, as amended (the “FCPA”), the United Kingdom Bribery Act 2010 (the “Bribery Act”) and any implementing legislation under the OECD Convention Against the Bribery of Foreign Government Officials in International Business Transactions (“OECD Convention”).

5. Privacy and Confidentiality and Transfer of Data

Supplier will at all times respect and protect any and all confidential information and/or personal data it controls, processes or has access to and in any event comply with all applicable confidentiality and data privacy laws in all territories in which it does business and provides goods or services. Supplier warrants that it has robust mechanisms in place to ensure adherence to this provision and applicable privacy laws.

6. Conflict of Interest

Supplier and their representatives will avoid any improprieties and conflicts of interest between the interests of Supplier on the one hand, and personal, professional, and business interests on the other. This includes avoiding actual conflicts of interest as well as the appearance of conflicts of interest. Supplier should ensure there are mechanisms and procedures in place to protect the integrity of Supplier’s decision-making process, to enable stakeholders to have confidence in Supplier’s integrity, and to protect the integrity and reputation of staff and Directors.

7. Management System

The Redwood Group believes that sound management systems and commitment are key to enriching the social and environmental well-being of our supply chain. Therefore, Supplier is expected to adopt or establish a management system to carry out the responsibilities outlined in this Code of Conduct. The management system should be designed to ensure Suppliers’ operations:
a. Comply with The Redwood Group’s requirements and applicable laws and regulations;
b. Conform to the responsibilities listed in this Code of Conduct; and
c. Identify and mitigate operational risks related to these responsibilities.