May 2018 | Version 1.0
CPA Global is the world’s leading IP management and technology company. We empower professionals to achieve excellence today and deliver strategic value for the future with an integrated suite of IP technology, services and information, underpinned by an outstanding global team of over 2000 people.
CPA Global’s fundamental principle when conducting its business is to operate in accordance with the highest ethical, social and ecological business standards. It is CPA Global’s uncompromising expectation that its suppliers and third parties shall respect these key elements of CPA Global’s values and principles and shall abide by the rules of this Supplier Code of Conduct. Such understanding forms the basic rules of engagement for continuing commercial relationship between CPA Global and its suppliers and third parties.
This Supplier Code of Conduct does not replace local law. CPA Global expects suppliers and third parties to operate in compliance with applicable laws, rules, and regulations in addition to the standards contained herein.
MONITORING AGAINST OUR STANDARDS
CPA Global expects its suppliers and third parties to adhere to applicable legal standards and work toward the higher standards contained herein.
CPA Global also expects its suppliers and third parties to communicate these principles and higher standards to their subcontractors and subsuppliers and take these standards into account when selecting subcontractors and subsuppliers.
Under some circumstances, where the suppliers or third parties have shown and continue to show a material commitment to improvement, CPA Global is willing to work with them to bring about improvements through engagement and collaboration. This may include audits, development and progress monitoring of corrective action plans, referring suppliers to external experts and other reasonable improvement plans.
1.1 BUSINESS INTEGRITY / ANTI-BRIBERY ANTI-CORRUPTION
CPA Global is committed to its Anti-Bribery and Corruption Programme, which is designed to prevent, detect, and address bribery; meet the requirements of the ISO 37001 - Anti-Bribery Management Systems standard; and act in accordance with all applicable laws and regulations, including but not limited to the UK Bribery Act of 2010, the US Foreign Corrupt Practices Act and all other applicable anti-bribery and anti-corruption laws.
CPA Global expects the same commitment from suppliers and third parties (including but not limited to any subcontractors, consultants, agents, representatives or other companies or individuals acting on our behalf), as well as those acting on your behalf or in connection with any work for or related to CPA Global.
CPA Global has a corporate policy that strictly prohibits its employees, subcontractors, consultants, agents, representatives or other companies or individuals acting on behalf of CPA Global, from directly or indirectly accepting, soliciting, offering or paying a bribe or providing any payment or benefit of any kind to any person or entity (including but not limited to any government or public sector official) with or in any way connected with the purpose of improperly influencing that person or entity (including but not limited to any government or public sector official), to gain any form of unfair business or other advantage, or to secure any particular decision (including but not limited to the decision of any governmental or other public sector body or official).
Under CPA Global’s policies, “government official” is broadly interpreted and includes Patent and Trademark officials. CPA Global recognises that bribery and corruption can also occur in non-government, business-to-business relationships that do not include government officials. Many countries have laws which prohibit offering, promising, giving, requesting, receiving, accepting, or agreeing to accept money or anything of value in exchange for an improper business advantage. Examples of prohibited conduct could include, but are not limited to, the provision of inappropriate gifts or hospitality, kickbacks, or investment opportunities offered to improperly induce the purchase of goods or services. CPA Global employees are not permitted to offer, give, solicit or accept bribes.
CPA Global expects its suppliers and third parties to strictly comply (and shall procure that its employees, subcontractors, consultants, agents, representatives or other companies or individuals acting on its behalf comply) with all applicable laws and regulations (as amended from time to time), including but not limited to the UK Bribery Act of 2010, the US Foreign Corrupt Practices Act and all other applicable anti–bribery and anti–corruption laws.
CPA Global expects its suppliers and third parties to specifically note and ensure compliance with the UK Bribery Act, which has extra-territorial reach, and which includes provisions that prohibit and criminalize the following:
- Active bribery: promising or giving a financial or other advantage
- Passive bribery: agreeing to receive or accepting a financial or other advantage
- Bribery of foreign public officials
- Failure to prevent a bribe
- Facilitation or “grease” payments
Further, CPA Global expects its suppliers and third parties not to conduct any financial or any other type of transaction or dealing with any individual or entity identified on any US Government, UK Government, or EU denied persons or entities listings on behalf of CPA Global. The suppliers and third parties shall disclose any alleged or actual violations of applicable law to CPA Global without delay to allow CPA Global to assess its compliance with applicable regulatory requirements.
1. 2 TAX COMPLIANCE
Criminal Finances Act 2017 requires CPA Global to ensure all suppliers, third parties and subcontractors have in place reasonable prevention procedures to prevent “associated persons” (as defined in the Criminal Finances Act 2017) from committing tax evasion, unless it is unreasonable to have such prevention mechanism in place or if the Criminal Finances Act 2017 does not apply to you.
1. 3 FAIR COMPETITION / ANTI-TRUST
CPA Global expects its suppliers and third parties to conduct their business consistent with fair competition and business practices, and comply with applicable fair competition and anti-trust laws and regulations.
2. DATA PRIVACY AND INFORMATION SECURITYCPA Global expects its suppliers and third parties to comply with applicable data protection laws and industry best practices; and have the proper organisational structure, processes and procedures to ensure the protection of personal information against accidental, unauthorised or unlawful loss, destruction, alteration, disclosure, use or access.
CPA Global also expects its suppliers and third parties to have adequate policies and procedures in place which address technical and organisational security and take reasonable steps to confirm compliance with those.
3. HEALTH, SAFETY AND ENVIRONMENT
CPA Global expects its suppliers and third parties to:
- Fully comply with applicable national statute governing health and safety at work.
- Take adequate steps to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimizing, so far as is reasonably practicable, the causes of hazards inherent in the working environment.
- Assure that procedures and standards for waste management, handling and disposal of chemicals and other dangerous materials, emissions and affluent treatment meet or exceed minimum legal requirement.
- Obtain, maintain and keep current all relevant environmental permits and registrations required under local regulations and follow their operational and reporting requirements.
4. LABOUR PRACTICES AND MODERN SLAVERY
4. 1 LABOUR PRACTICES
CPA Global expects its suppliers and third parties to:
- Not use forced, bonded or involuntary prison labor.
- Not use child labor. The employment of young workers below the age of 18 shall only occur in non-hazardous work and when young workers are above a country’s legal age for employment.
- Provide a workplace free of harassment and discrimination. Discrimination for reasons such as race, color, age, gender, sexual orientation, ethnicity, disability, religion, political affiliation, union membership or marital status is not tolerated.
- Provide a workplace free of and with no threat of harsh and inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers.
- Pay workers according to applicable wage laws, including minimum wages and mandated benefits.
- Ensure open communication and direct engagement with workers to resolve workplace and compensation issues. Suppliers shall respect the rights of workers, as set forth in local laws, to freely join or not join labor unions, seek representation and join workers’ councils. Workers shall be able to communicate openly with management regarding working conditions without threat of reprisal, intimidation or harassment.
4.2 MODERN SLAVERY ACT 2015.
CPA Global Limited is committed to preventing acts of modern slavery and human trafficking from occurring within its business and supply chain, and requires the same high standards from its suppliers and third parties.
CPA Global expects its suppliers and third parties to supplement its efforts to monitor and reduce the risk of slavery and human trafficking occurring within its supply chain. To that end, CPA Global expects its suppliers and third parties to adopt procedures and policies that are designed to:
- Establish and asses areas of potential risk in its business and supply chain
- Monitor potential risk areas in its business and supply chain
- Reduce the risk of slavery and human trafficking occurring in its business and supply chain
- Provide adequate protection for whistle-blowers
CPA Global further expects its suppliers and third parties to invest in educating its staff to recognize the risk of modern slavery and human trafficking in its business and supply chain. Through training programs, employees shall be encouraged to report any potential breaches of the supplier’s or third party’s anti-slavery and human trafficking policy. Employees are taught the benefits of stringent measures to tackle slavery and human trafficking, as well as the consequences of failing to eradicate slavery and human trafficking from business and supply chains.
5. SECURITY REQUIREMENTS