Ethical Business Code
1.1 This Ethical Business Code (EBC) sets out Suppliers’ and B2B Clients’ obligations in relation to social, environmental and ethical compliance. The purpose of the EBC is to promote responsible management of social, ethical and environmental issues in HoIP Telecom’s business dealings.
2. General Requirements
2.1 ‘Supplier’ and ‘Client’ in this Code shall, where relevant, also include all officers, employees, contractors, subcontractors and agents of any Supplier and/or Client.
2.2 ‘Client’ in the context of this EBC means a business entity supplied by HoIP Telecom.
2.3 Suppliers and Clients shall comply with all relevant laws, regulations and standards in all of the countries in which they operate.
2.4 Suppliers and Clients are encouraged to take all reasonable endeavours to promote this Code to their suppliers, subcontractors and clients.
3. Monitoring, Corrective Action and Reporting
3.1 Suppliers and Clients are expected to identify, notify and correct any activities that fall below EBC standards.
3.2 Suppliers and Clients shall promptly notify HoIP Telecom of serious EBC breaches and agree corrective action.
3.3 A breach of this EBC may be considered to be a material breach of contract with HoIP Telecom.
3.4 Suppliers and Clients shall provide HoIP Telecom with reasonable access to relevant information for the purposes of monitoring EBC compliance, and use reasonable endeavours to ensure that their suppliers and clients do the same.
4.1 Child Labour
4.1.1 Suppliers and Clients shall strictly prohibit child labour. No person shall be employed who is below the minimum legal age for employment.
4.1.2 The minimum age for employment shall be the age for completing compulsory education in the relevant country or not less than 15 years of age (or not less than 14 years, in countries where educational facilities are insufficiently developed, in accordance with international principles), whichever is higher.
4.1.3 Children (persons under the age of 18) shall not be employed for any hazardous or night work, or work that is inconsistent with the child’s personal development.
4.1.4 In the event a Supplier or Client discovers a child is employed, the best interests of the child shall be the primary consideration. Suppliers and Clients shall contribute, support and/or develop policies and programmes that assist any child found to be performing child labour.
4.2. Forced Labour
4.2.1 Suppliers and Clients shall not use any form of forced, bonded, compulsory labour, slavery or human trafficking.
4.2.2 Suppliers’ and Clients’ employees shall be entitled to leave work or terminate their employment with reasonable notice. Employees shall be free to leave work after such reasonable notice period expires. All employment shall be voluntary. Suppliers and Clients shall provide each of their employees with an employment contract which contains such a reasonable notice period.
4.2.3 Suppliers and Clients shall not require employees to lodge deposits of money or withhold payment or place debt upon employees or require employees to surrender any government-issued identification, passports, or work permits as a condition of employment.
4.3 Working Hours
4.3.1 Suppliers and Clients shall ensure working hours of Suppliers’ and Clients’ employees do not exceed the maximum set by local law and each employee’s working week does not exceed 60 hours per week including overtime.
4.3.2 Suppliers and Clients shall allow each of its employees at least one day off following every six consecutive working days.
4.3.3 Suppliers and Clients shall grant its employees the right to paid vacation.
4.3.4 In exceptional circumstances, when these hours may be exceeded by Suppliers’ and Clients’ employees, working hours shall in any event not be excessive.
4.3.5 Suppliers and Clients should compensate overtime at a premium to the relevant employee’s standard hourly rate.
4.4.1 Suppliers and Clients shall ensure their employees understand their employment conditions and give employees fair and reasonable pay as well as any legally entitled or agreed benefits.
4.4.2 Suppliers and Clients shall not use deductions from wages as a disciplinary measure. Employees must be paid in a timely manner, and Suppliers and Clients must clearly convey to their employees, the basis on which they are paid.
4.5 Disciplinary Practices
4.5.1 Suppliers and Clients will treat all employees with respect and dignity. Physical or verbal abuse or other harassment and any threats or other forms of intimidation are prohibited.
4.6.1 Suppliers and Clients shall not engage in or support any form of discrimination in hiring, employment terms, remuneration, access to training, promotion, termination, retirement procedures or decisions including but not limited to: race, colour, age, veteran status, gender identification, sexual orientation, pregnancy, ethnicity, disability, religion, political affiliation, trade union membership, nationality, indigenous status, medical condition, HIV status, social origin, social or marital status and union membership.
4.6.2 Suppliers and Clients shall ensure no form of discrimination is present at any stage of employment, from the selection of suitable applicants, their interview and assessment; to the terms of their employment, payment and grounds for dismissal.
4.7 Freedom of Association & Right to Collective Bargaining
4.7.1 Suppliers and Clients shall respect the rights of employees to join or not to join trade unions or similar representative bodies and the rights of employees to collective bargaining to the extent permitted by applicable law. Suppliers and Clients shall allow open communication and direct engagement between its employees and management in building employee relations and for the resolution of any issues.
4.8 Anti-bribery, Corruption and Individual Conduct
4.8.1 Suppliers and Clients shall not tolerate or enter into any bribery, including improper offers or payments to or from employees, customers, suppliers, organisations or individuals.
4.8.2 Suppliers and Clients shall:
have an anti-bribery policy that sets out the principle of zero tolerance to any form of bribery or corruption within their organisation, including facilitation payments;
not give, promise, receive or request any bribes (financial or other advantage), including but not limited to in relation to any public official;
ensure its employees, contractors and sub-contractors are aware of its anti- bribery policy and how to comply with its requirements.
4.9 Fraud and money laundering
4.9.1 Suppliers and Clients shall:
act in accordance with all applicable international standards and laws on fraud and money laundering;
not do or omit to do anything likely to cause any party to be in breach of any of such international standards and laws;
maintain an effective anti-fraud and (where appropriate) an anti-money laundering compliance programme, designed to ensure compliance with the law including the monitoring of compliance and detection of violations.
4.10 Health & Safety
4.10.1 Suppliers and Clients shall provide a healthy and safe working environment for employees, contractors, partners or others who may be affected by Suppliers’ and Clients’ activities, in accordance with international standards and national laws.
4.10.2 Suppliers and Clients shall put in place mechanisms to ensure that health and safety obligations are communicated and applied to parties under their control.
4.10.3 Suppliers and Clients shall ensure they meet general principles of health and safety risk prevention. General principles include identifying, minimising and preventing hazards, using competent and trained people, providing and maintaining safe equipment and tools, including personal protective equipment as required.
4.10.4 Suppliers and Clients shall have mechanisms and shall implement them to ensure that all their employees are competent to carry out the health and safety aspects of their responsibilities and duties. This shall include the nomination and training of persons at an appropriate level (and in particular executives), who are responsible for discharging Suppliers’ and Clients’ health and safety obligations.
4.10.5 Suppliers and Clients shall ensure facilities and amenities, including employee accommodation where provided, shall be hygienic, safe and meet the basic needs of employees.
4.10.6 Suppliers and Clients shall have systems and training to prepare for and respond to accidents, health problems and foreseeable emergency situations. Suppliers and Clients shall have means and procedures in place for recording, investigating and implementing learning points from accidents and emergency situations.
4.11.1 Suppliers and Clients shall comply with relevant legislation and international standards, and in countries where environmental legislation is not evident or enforced, ensure reasonable practices for managing environmental impacts are in place.
4.11.2 Suppliers and Clients shall implement an internal environmental management system to the extent applicable to their business.
4.11.3 Suppliers and Clients shall obtain, maintain and keep current all necessary environmental permits (e.g. waste management, transportation), approvals and registrations.
4.11.4 Suppliers and Clients shall respect all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances. Hazardous chemicals and other materials included in products, especially those included in the substances of Very High Concern list of the REACH regulation, must be identified and managed by Supplier to ensure their safe use, recycling or re-use and disposal. The use of such chemicals and materials by Suppliers and Clients must be avoided (and if not possible to avoid, minimised). Where required, Suppliers and Clients must ensure electrical or electronic equipment is in line with all relevant European Union regulations such as but not limited to RoHS and REACH.
4.11.5 Suppliers and Clients shall identify, minimise, monitor, control and treat all hazardous air pollutants and all emissions should be avoided in accordance with international standards and applicable laws.
4.12 Climate Change and Sustainability
4.12.1 Suppliers and Clients should endeavour to minimize Greenhouse Gas emissions, energy and water consumption from their own operations.
5.1 Breaches of this EBC should be promptly reported to HoIP Telecoms Chief Information Officer.
Last reviewed 25 May 2018.