POL00448718 - Extract from Minutes of POL Board Meeting
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Post Office - Supplier Code of Conduct
We are the Post Office and there is no-one like us. From our travel and financial services,
passports to postage, the Post Office network is serving communities across the UK. We have
a network of more than 11,500 branches across the UK and every one of our branches is at the
heart of its community.
Maintaining our reputation for ethical business integrity is absolutely vital and we need to make
sure that all of our suppliers work to our values. This short supplier code provides an
explanation of the standards of behaviour that we expect when working for Post Office in
support of our Ways of Working. Working in partnership as one team we deliver amazing
results.
The requirements for you as a supplier are clear - comply with legislation, follow Post Office
policy and procedures (including this Code), and if ever you are asked to do anything which
sits outside of these parameters then please do tell us about it.
Responsibilities
Suppliers must comply with any terms and conditions that they have agreed with Post Office,
and must ensure that all activities are undertaken safely, with no detriment to the well-being
of your employees, our staff or the public. All work must be undertaken with care for the
environment.
You must ensure that your employees are aware of their duties and are trained and competent
to undertake the tasks they are employed for, and suitably supervised where required.
Suppliers should be mindful that the activities of their organisation and staff can impact not
only their own reputation, but that of the Post Office too. We expect suppliers at all times to
ensure that the values and the good name of the Post Office are upheld.
This Supplier Code of Conduct is not a substitute for entering into a written contract with Post
Office. It is an advisory document to explain our expectations of responsible behaviour from
our suppliers, and to ensure that our standards are understood.
Bribery and Corruption
Suppliers must ensure that bribery or corruption are not tolerated and strict rules for the
offering or acceptance of gifts and hospitality are adhered to. You must not offer bribes, kick-
backs, gifts or hospitality to a Post Office employee in an attempt to gain a commercial
advantage, or to any other employee or organisation to secure an advantage on behalf of Post
Office, or to any other employee or organisation to secure an advantage on behalf of Post
Office. Any conflicts of interest (for example a family connection between a supplier and the
Post Office) need to be disclosed immediately.
Tax Evasion and the Facilitation of Tax Evasion
Tax evasion and the facilitation of tax evasion are both a criminal offence that can be punishable
with imprisonment and /or unlimited financial penalties depending on the seriousness of the
offence. Suppliers must not ask or encourage a Post Office employee to engage in a relationship
which could result in the reduction or diversion of any taxes from any collecting authority.
Please read our GUIDANCE - Criminal Finances Act 2017 document on our website
http://corporate. postoffice.co.uk/our-suppliers.
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Human Rights
Suppliers are expected to adhere to all Human Rights legislation. Specifically, this will include
no child or forced labour, threat of violence, harassment, intimidation, debt bondage, bonded
labour, or compulsory overtime when providing services. Disciplinary and grievance procedures
should be fair and transparent, and include the right of appeal.
Employees should be allowed to terminate employment on reasonable notice, enjoy freedom
of movement, incur no hiring fees, and be paid and work hours in accordance with national
regulations including applicable minimum wage legislation. Where applicable, suppliers are
expected to publish their annual statement on Human Trafficking and Modern Slavery in
accordance with the Modern Slavery Act 2015.
Non-Discrimination
Suppliers are expected to practice a diversity and equality agenda in line with the Post Office
values - with no discrimination on race, religion and belief, disability, gender reassignment,
sexual orientation, age, pregnancy /maternity or marriage and civil partnership.
Freedom of Association
Suppliers should respect the rights of workers to associate or not to associate with any group,
as permitted by and in accordance with all applicable local and national laws and freedom of
association and collective bargaining. Suppliers shall not interfere with or discriminate against
workers choosing to belong to them. Where the right to freedom of association and collective
bargaining is restricted under national law, suppliers should facilitate, not hinder, alternative
means of independent and free association and bargaining.
Confidentiality
Suppliers must ensure that they respect the confidentiality of Post Office information. They
must not share any confidential information unless specifically authorised to do so by Post
Office, and only process Post Office Personal Data in accordance with Post Office's instructions
and as required by law.
Suppliers should notify the Post Office promptly (within 24 hours) if it becomes aware of any
actual, suspected or threatened unauthorised exposure, access, disclosure, Processing, use,
communication, deletion, revision, reproduction or transmission of any component of Post
Office Personal Data, unauthorised access or attempted access or apparent attempted access
(physical or otherwise) to Post Office Personal Data or any loss of, damage to, corruption of or
destruction of Post Office Personal Data (Security Incident).
The Post Office is subject to the requirements of the Freedom of Information Act (FOIA) and
the Environmental Information Regulations and suppliers will be required to assist and
cooperate with Post Office to enable us to comply with our information disclosure obligations.
Insurance
Suppliers must maintain policies of insurance to provide a level of cover sufficient for the work
that they intend to provide, and relevant for their own legal jurisdiction and any other
jurisdictions they intend to work in with Post Office. This should include all risks that may be
incurred by the supplier if any Purchase Order is issued, be it electronically, verbally, written
or expressed. This includes cover for death or personal injury, loss of or damage to property,
and professional advice. Levels of insurance shall be set within any contract, where no contract
has be issued then insurance payable will be unlimited.
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No purchase order, no payment
We want our suppliers to be paid in a timely manner for the work they do in supplying Post
Office with the important goods and services. Our standard terms are 30 days from receipt of
a valid and accurate invoice entry onto our systems. To achieve this, we require the cooperation
and assistance of suppliers to ensure that we have an efficient and controlled payment process.
This includes a “No purchase order, no payment” policy.
This means that any Post Office employee placing an order with any of our suppliers must
provide a valid purchase order (PO) number, and which must be quoted on all supplier
invoices. Any request to change an order from a Post Office employee must be supported
with a revised supplier quotation and an amended purchase order (PO) document from the
Post Office. Suppliers should note that requests to change the goods or services ordered
should not be accepted without this evidence.
Invoices not showing a valid PO number will be returned to the supplier for evidence of a PO,
which may result in delayed payment. A PO number demonstrates to Post Office that the
goods/services have been authorised by the business.
Supplier Audits
We will conduct audits of our suppliers that will look at all aspects of behaviour and legislative
compliance. We will focus specifically on:
Modern Slavery - Where we would expect all suppliers to have taken steps within their
organisation to:
e ensure all UK workers receive minimum wage and robust immigration checks
map supply chains to identify where there is highest risk and exposure to modern slavery
undertake site inspections
provide training to employees and local suppliers on modern slavery risks and compliance
review supplier contracts to include obligations to comply with the Modern Slavery Act
2015
¢ prepare a statement outlining the steps you are taking to tackle modern slavery and
publish it if required to do so by the Act.
Anti-Bribery and Corruption - Where we would expect all suppliers to have taken steps to:
e have an Anti-Bribery and Corruption policy in place
« give employees awareness training in Anti-Bribery and Corruption
* operate a hospitality register to track offers and invitations
e have a method to enable staff to raise concerns if they have any suspicions.
What do I do if something isn’t right?
At the Post Office, we apply a zero tolerance for unsafe working practices, discrimination, fraud,
bribery, tax evasion and the facilitation of tax evasion or corruption. We have a whistleblowing
policy and we encourage our staff and suppliers to raise concerns with us. If you are ever asked
to be involved in anything unethical or illegal, then you must do the right thing - please “speak
up”. The same applies if you or your colleagues are treated unfairly while working for the Post
Office. There are two ways in which suppliers can report a concern:
1. By contacting their Procurement contact or Vendor Manager or
2. By contacting the Grapevine confidential reporting service on 0345 603 4004