Supplier code of conduct

The Fundamental Group of companies (“Fundamental”, “We”, “Our” “Us”) is committed to acting ethically, achieving the highest standards of quality, honesty, openness and accountability in all of Our business activities, including in the appointment of suppliers. We expect suppliers to operate in compliance with all applicable law and regulations and the values which underpin them. These expectations are documented in this code which is reflective of the principles laid out in the UN Global Compact and the UN’s Guiding Principles on Business and Human Rights. Therefore, and as a minimum, We require that suppliers:

• Treat those who work for them with dignity and respect, ensuring a working environment free from all forms of discrimination, harassment, victimization and abuse;
• Employ workers on a voluntary basis and do not use any bonded, forced or compulsory labour of any kind, or engage in any other forms of slavery, human trafficking, illegal or inhumane labour practices or any form of ill-treatment. Suppliers shall make appropriate checks to identify and mitigate any such issues in their supply chain and commit to reporting on the steps they have taken to address them;
• Do not use underage workers in any part of their operations ensuring that they comply with all applicable legal minimum working age requirements. Suppliers should pay decent wages sufficient to meet basic needs and in compliance with all applicable employment laws including on working hours and minimum wage requirements;
• Employ workers on written terms, incorporating reasonable notice terms with no requirement to lodge deposits or payments of any kind or pay any sort of worker-paid recruitment fees. Suppliers shall check their workers right to work in the country where they operate in compliance with applicable immigration regulations;
• Respect workers’ rights of association and collective bargaining, subject to and in accordance with applicable law and maintain a route for workers to report any concerns about wrongdoing in the workplace free of any interference, harassment or otherwise. Suppliers shall take all reasonable steps to ensure that its working relationship between with Fundamental is free from any form of harassment, including sexual harassment;
• Provide and maintain a safe working environment in compliance with all applicable health and safety regulations. Suppliers shall obtain and maintain all required licences and permits and record and investigate any health and safety concerns, promptly implementing corrective action where required. In particular suppliers shall follow local and/or national government policies in response to any public health issue and pay statutory sick pay to employees where applicable;
• Comply with all applicable environmental laws. Suppliers shall also maintain environmentally responsible business practices which focus on sustainability and seek to control and minimise the supplier’s impact on the environment (in terms of their consumption, emissions, pollution and waste and in the products and services they provide). Suppliers shall obtain and maintain all required environmental permits and licenses;
• Carry out their business in an ethical manner in compliance with all applicable legislation and with respect to third party intellectual property rights, confidential information and data privacy. Suppliers shall take appropriate steps to adequately protect Fundamental’s intellectual property and confidential information (and that of Fundamental’s clients, where applicable) and shall employ appropriate security in relation to any personal data they hold. Personal data shall only be transferred with appropriate safeguards in place.
• Comply with all legislation preventing bribery and corruption including the UK Bribery Act 2010 and the US Foreign and Corrupt Practices Act, ensuring that they do not engage in any form of corruption or bribery, including offering, giving, asking for or taking any form of bribe, kick-back or facilitation payment. Suppliers shall maintain appropriate Anti-Bribery policies and ensure their workers are adequately trained;
• Do not engage in collusive bidding, price fixing, price discrimination, or other unfair trade practices in violation of fair competition laws or antitrust laws that govern the jurisdictions in which it conducts business;
• Are transparent in their dealings with Us and maintain accurate financial books and business records in accordance with all legal requirements and accepted accounting practices;
• Do not subcontract their obligations to Us without Our consent. Suppliers shall not act as a representative or agent of, or as an intermediary appointed by, the ultimate supplier without prior notification to Us in writing. Suppliers who act as a representative or intermediary shall ensure that payments made by Us for services rendered by the ultimate supplier are made expeditiously to the ultimate supplier;
• Promote and ensure compliance with the principles of this code across their supply chain. Suppliers shall establish processes to enable their identification of any issues having a detrimental environmental or social impact across their supply chain;
• Comply with all applicable law and regulations in the countries and jurisdictions in which they operate together with the requirements of this code. Suppliers agree to cooperate with any query or enquiry relating to any matter covered by this code and in Our verification of their compliance; and
• Ensure that they provide employees and their own suppliers with accessible ways to report any concerns or non-compliance such that appropriate mitigation and remediation can take place.

November 2024