Supplier Code of Conduct
We provide tailored data solutions across various sectors including automotive, finance, healthcare, and more.
1. Introduction
Creative ITC is a leading infrastructure and cloud enablement company that provides managed service and cloud solutions across five continents.
Creative ITC is committed to engaging in and developing responsible ways of operating. The integrity of our suppliers, as well as their supply chain, is critical to Creative ITC’s success.
Creative ITC’s suppliers, contractors, subcontractors and representatives, as well as anyone working for them or acting on their behalf, must therefore adhere to the principles expressed in this Supplier Code of Conduct (the “Code”). For the purpose of this document, the term “supplier” includes all such parties.
This Code establishes the minimum principles and standards that we expect from suppliers. All suppliers must enforce obligations as strict as those set out in this Code throughout their own supply chain and must provide their employees with sufficient information and training to ensure that they understand and comply with the obligations set out in this Code.
It is critical that the principles within this Code are maintained at all times, and we therefore ask our suppliers to inform us if they encounter a situation which may raise concerns about integrity or misconduct, including any breach of this Code. The reporting process is set out in the last section of this Code.
Suppliers must confirm in writing that they will comply with the principles set out within this Code.
2.Laws and Regulations
Suppliers must comply with all applicable local and national laws, regulations and requirements, including any international trade restrictions and economic and trade sanctions, as well as all laws and regulations concerning export and import controls. It is the supplier’s responsibility to maintain and enforce these standards within its own supply chain.
3.Human Rights
Creative ITC is committed to supporting the protection and preservation of human rights throughout our operations. To that end, we will work only with suppliers who respect human rights, diversity and equal opportunity in the workplace. Suppliers must always:
- Treat workers with respect and dignity, meeting the standards set out in the United Nations Universal Declaration of Human Rights. Any form of offensive behaviour, including insulting, violent, abusive, demeaning, harassing or bullying conduct towards workers, is prohibited;
- Keep workplaces free from discrimination, violent or inhumane treatment;
• Refuse to tolerate disrespectful or unprofessional usage of social media (whether or not such usage relates to Creative ITC, its business, clients, employees or business partners) such as posting content that is abusive, malicious, obscene, threatening or intimidating, or that contains ethnic, religious, gender or other derogatory statements in any message or post;
• Respect the diversity of the workforce and seek an environment where all individuals have equal opportunities and are treated with respect and dignity regardless of race, religion, gender, age, nationality, disability, personal relationship, union membership, sexual orientation, political opinion or any other personal characteristics. Employment shall be based upon individual merit and qualifications directly related to professional competence;
•Ensure that its workers are above the applicable minimum age requirement to work in the country or countries in which they operate. Child labour in any form is prohibited, and if the supplier employs someone who is under 18 years old, their work must not jeopardise their education, health or safety.
•Comply with the Modern Slavery Act 2015 and not use or tolerate in its supply chain any form of slavery, servitude, human trafficking, bonded labour or forced labour, regardless of local legislation and/or customs;
•Ensure that all individuals’ work is voluntary and that workers are able to terminate their employment in accordance with their employment contract, which shall be compliant with applicable laws and regulations.
•Provide its employees with training to help them recognize situations where a risk of modern slavery exists, and ensure that its supply chain is free of any form of modern slavery by requiring that its own suppliers do the same.
4.Avoiding conflicts of interest
When working for or on behalf of Creative ITC, suppliers must always make every effort to prevent the occurrence of situations which create (or could create) an actual, potential or perceived conflict of interest (financial or otherwise) within the scope of their business relationship with Creative ITC.
Suppliers must:
•Act in the best interests of Creative ITC;
•Before entering into negotiations and/or a business relationship with Creative ITC, disclose in writing to Creative ITC any actual, potential or perceived conflicts of interest (financial or otherwise);
•Promptly disclose in writing any conflicts of interest which may arise during its business relationship with Creative ITC;
•Avoid any conflicts of interest, whether actual, potential or perceived, that are not properly disclosed and mitigated;
•Not do or omit to do anything which may be capable of harming Creative ITC’s (or its customers’) reputation.
5.Anti Bribery and Anti-Corruption
Suppliers must not offer, give or receive any gift or payment that is or may under applicable laws and regulations be deemed as a bribe (this includes gifts, entertainment, employment, contract or benefits of any kind), nor make or accept any improper payments, including facilitation payments, to obtain an improper or unfair advantage, obtain or retain new business or influence a third party’s actions.
The prohibition on facilitation payments includes any type of facilitation payment (being an unofficial payment made for the purposes of obtaining, securing or accelerating the taking of a decision or performance of a service to which the person/company paying is already entitled), whether large or small, even where such payments are perceived as a common part of local business practice or are acceptable under local law.
Suppliers must always avoid any kind of violation of the Organisation for Economic Cooperation and Development (OECD), Convention of Combating Bribery of Foreign Officials in International Business Transactions, Canada’s Corruption of Foreign Public Officials Act, the United Kingdom Bribery Act 2010, the United States Foreign Corrupt Practices Act, and any analogous legislation of these and any other jurisdictions.
Suppliers must always comply with the following principles when offering, accepting or exchanging gifts, hospitality or entertainment.
Suppliers must always:
•Make sure that benefits comply with all applicable laws and regulations;
•Make sure that benefits comply with this Code;
•Obtain prior authorization, in writing, from Creative ITC if they have any uncertainty as to the legality of giving or receiving any such benefit on behalf of Creative ITC;
•Make sure that benefits are reasonable in value, auditable and appropriate to the occasion and the roles of those involved;
•Be honest and transparent when exchanging benefits;
•Record given benefits accurately in their books and records; and
•Exercise good judgment, especially when offering benefits to government officials, as they are subject to stricter rules, regulations and laws.
Suppliers must never:
•Accept or offer benefits that are illegal, indecent or offensive in any way, involve gambling, or otherwise violate this Code;
•Exchange benefits for any improper advantage or influence over a business relationship;
•Request illegal benefits from anyone;
•Exchange benefits when it raises questions about conflicts of interest; or
•Offer, accept or exchange cash or cash equivalents on behalf of Creative ITC.
6.Antitrust and competition
Creative ITC is committed to free and open competition in all the markets in which it operates. Creative ITC competes fairly and ethically, and requires its suppliers (and their supply chains) to also commit to comply with applicable competition law. Suppliers must take all appropriate measures to engage in fair and honest competitive business practices and comply with antitrust and competition legislation.
Suppliers must not:
•Discuss, collude or agree to fix or control prices, terms or conditions;
•Restrict competition or dealings;
•Share confidential information with current or potential competitors, or any other relevant party;
•Divide or allocate clients, markets or territories;
•Choose not to submit a bid, withdraw a bid or submit an artificial bid to influence the outcome of a bidding process; or
•Include any clause within a contract that would have the effect of illegally boycotting trade with a country.
7.Money Laundering and Tax Evasion
Suppliers must always:
•Comply with all applicable anti-money laundering laws and regulations;
•Comply with all applicable tax laws and regulations;
•Undertake all appropriate measures to prevent Creative ITC from being involved or implicated in money laundering, tax evasion or other criminal activities; and
•Recognize and monitor potential warning signals that could help detect unusual or suspicious activity in the supplier’s operations and supply chain.
8.Health, Safety and the Environment
At Creative ITC, we are committed to doing business in a safe, ethically, environmentally and socially responsible manner. Suppliers must always:
•Ensure that compliance with applicable workplace health, safety and environmental laws and regulations are treated as the minimum standard everywhere it operates to avoid questionable practices;
•Focus on hazard recognition, risk assessment and elimination of hazards. The supplier must implement work safety guidelines and procedures andeducate its employees to reduce and prevent accidents and occupational illness;
•Protect anyone who takes part in its operations (including Creative ITC personnel) and/or who come into contact with the supplier’s work sites and offices
•Be prudent when making decisions that affect the environment and have clear procedures in place to ensure that the direct and indirect environmental impacts associated with the goods and/or services provided by the supplier are understood, measured and managed.
9.Confidentiality and Data Privacy
Suppliers shall take appropriate steps to safeguard and maintain Creative ITC’s confidential and proprietary information and use such information only for the purposes authorised within its contractual agreement(s) with Creative ITC. Suppliers must always (at a minimum):
•Properly protect confidential information belonging to Creative ITC, (including that of Creative ITC’s customers and suppliers);
•Obtain written consent from Creative ITC before disclosing any such confidential information to any third party, other than in accordance with its contractual rights.
•Limit access to confidential information to those who have a need to know such information in the performance of their work for Creative ITC
•Protect personal data and private information in accordance with applicable data protection and privacy laws;
•Have appropriate policies and procedures in place to ensure that information is kept protected, secure and confidential;
•Continue to protect confidential information and personal data, even after the termination or expiry of its business relationship with Creative ITC, in accordance with contractual requirements and applicable law; and
•Ensure that it has appropriate technical and security controls in place to protect such confidential information and personal data.
10.Accounting Practices and Record Keeping
Suppliers must always:
•Maintain complete and accurate books, records and documents, in accordance with generally accepted record keeping principles;
•Afford Creative ITC, upon reasonable notice, the right to audit and access all the supplier’s books, records and documents as may be relevant to evidence the supplier’s compliance with its obligations under this Code; and
•Grant such access during the term of its contractual engagement with Creative ITC and for a period of six (6) years after its termination or expiration.
11.Reporting Suspected Misconduct and Concerns
The Supplier must immediately report any non-compliance (or suspected non-compliance) with this Code to Creative ITC. The Supplier may report its concerns confidentially by emailing: [email protected]
In the event Creative ITC determines that the supplier does not meet the requirements and expectations set out in this Code, Creative ITC will offer guidance to correct or improve the supplier’s procedures. Without undue delay, the supplier must take all corrective actions as reasonably advised by Creative ITC
