Supplier Code of Conduct
1. General Requirements for Prospective Suppliers
Prospective Suppliers shall keep all pre-contract data, negotiations, and tender progress strictly confidential and, where requested by Temple Partners, enter into a more detailed non-disclosure agreement on agreed terms.
Prior to entering into any contract, Temple Partners may carry out due diligence on each prospective Supplier in order to comply with relevant law and to assess the suitability of the prospective Supplier to meet Temple Partners’ business requirements. Prospective Suppliers shall cooperate fully and promptly with such due diligence enquiries.
All activity between Temple Partners and prospective Suppliers will be conducted with integrity. Contracts will be awarded based on merit and at the discretion of Temple Partners. Hospitality or other inducements intended to encourage or reward a positive outcome for the prospective Supplier must not be offered to Temple Partners or to its staff members. The offering and acceptance of any such inducements (e.g., gifts or hospitality) by us during a competitive tender or negotiation phase is strictly prohibited.
2. General Requirements for Current Suppliers
Where Temple Partners enters into a contract with a Supplier, the relationship will be governed by agreed terms and conditions. In addition, the Supplier shall comply with the principles contained in this Supplier Code of Conduct and all laws applicable to the Supplier.
As part of Supplier management, Temple Partners may carry out due diligence on each Supplier to ensure compliance with relevant law and to ensure the Supplier continues to meet Temple Partners’ business requirements. Suppliers shall cooperate fully and promptly with such due diligence enquiries.
It is recommended that each Supplier’s policies and procedures are regularly reviewed to ensure that changes in regulations, technology, and industry best practice are captured, as well as changes within each Supplier’s organisation. Regular review will ensure that sound governance is instilled within each Supplier’s organisation which will, in turn, demonstrate continuous improvement.
3. Priority of Standards and Updates
Competing standards shall be addressed as follows:
If there is a conflict between applicable law, the provisions of an agreement with Temple Partners and this Supplier Code of Conduct, the Supplier shall comply with applicable law. Where the agreement or this Code imposes additional requirements that are not inconsistent with applicable law, the Supplier shall comply with those requirements.
Temple Partners has the right to modify this Supplier Code of Conduct from time to time and the modified Code will be available to Supplier on Temple Partners’ website.
4. Supplier Employment & Supply Chain Ethics
Suppliers shall respect the human rights of their employees, other personnel and local communities and shall comply with all relevant law pertaining to human rights including compliance with the Equality Act 2017 where applicable.
Suppliers shall take appropriate steps to identify and eradicate modern slavery, in all its forms, including slavery, servitude, forced and compulsory labour and human trafficking, whether of adults or children, all forms of which have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain.
Temple Partners is committed to transparency in its approach to preventing modern slavery throughout its supply chains and expects its Suppliers to adopt appropriate measures to identify and address modern slavery risks. We expect the same commitment from all our Suppliers and we expect that our Suppliers will hold their own suppliers to the same high standards.
Suppliers shall implement appropriate due diligence practices and provide training to their own staff to identify the risk of and/or actual instances of modern slavery.
Freedom of association and collective bargaining: The Supplier shall respect, and shall not interfere with, the right of workers to decide whether to lawfully associate with groups of their choice, including the right to form or join trade unions and to engage in collective bargaining.
Wages and remuneration: The Supplier must compensate all workers with wages, including overtime premiums, and benefits that at a minimum meet the higher of:
the minimum wage and benefits established by applicable law;
collective agreements;
industry standards; and
an amount sufficient to cover basic living requirements.
Equal opportunity and non-discrimination: The Supplier shall comply with all applicable equality and anti-discrimination laws and shall not unlawfully discriminate against any job applicant, worker, employee or other individual. Suppliers shall have appropriate policies and procedures to promote equal opportunity in recruitment, remuneration, access to training, promotion and termination of employment and shall comply with the protected characteristics and other requirements applicable under the Equality Act 2017, as amended from time to time.
All terms and conditions of employment must be made clear to the Supplier workforce in a manner which is easily understood by that workforce.
Suppliers must provide workers with clear, fair and uniformly applied disciplinary practices and grievance procedures.
Suppliers shall provide sufficient evidence, promptly upon request by Temple Partners, that they have implemented appropriate procedures to manage all labour related issues within their supply chain to ensure that they comply with relevant law and this Supplier Code of Conduct.
Suppliers shall demonstrate, through the transparency of their supply chain that people are dealt with ethically and lawfully, and that goods are traded fairly and meet the environmental aims detailed in this Supplier Code of Conduct.
5. Community and Supplier Diversity
We expect Suppliers to understand how their activities impact their local area and wider community, and we encourage them to make positive contributions and investments. For example, providing appropriate local employment opportunities, workforce volunteering and charity activities. We expect our Suppliers to minimise disruption to communities. We aim to provide small and local businesses, minority ethnic, women owned and diverse business enterprises, with an equal opportunity to participate in our procurement and sourcing processes. We have developed and implemented processes to ensure these businesses have an opportunity to participate in the procurement process, which will include extending this policy through our supply chain.
6. Prevention of Financial Crime
‘Financial Crime’ includes bribery, corruption, money laundering, terrorist financing, tax evasion and the failure to prevent the criminal facilitation of tax evasion.
Suppliers shall comply with all relevant laws addressing Financial Crime and shall not do or omit to do anything which would cause Temple Partners, or any of Temple Partners’ affiliates or branches to be in breach of relevant law.
Suppliers shall put in place an appropriate policy and procedures which prohibit workers from:
the offering, giving, soliciting or receiving of a bribe at any time (including the making of facilitation payments or the bribery of public officials) whether for the benefit of the Supplier or for the benefit of a worker, a member of a worker's family, or a worker’s friends, associates or acquaintances;
the use of a gift or hospitality to induce a fraud or other wrongdoing to secure a personal or business benefit;
the use of sponsorship or advertising agreements to exercise undue influence; or
unapproved or unauthorised charitable donations or political donations of any kind.
Suppliers shall put in place appropriate policies and procedures which:
verify the legitimate origin of goods and services within their supply-chain; and
verify the identity and the legitimate nature of the businesses with which the Supplier contracts.
Suppliers shall adopt or have adopted a tax strategy that demonstrates a willingness to pay the right amount of tax, in the right place, at the right time.
Unfair business practices: Suppliers shall comply with all applicable competition laws, including the Competition Act 2021 where applicable competition laws (including but not limited to the Competition Act 2021), including but not limited to those relating to teaming and information sharing with competitors, price fixing and rigging bids.
Suppliers shall implement mandatory training for staff members, appropriate oversight, regular risk assessments, appropriate due diligence and procedural audits to prevent, identify, detect and eradicate Financial Crime.
Suppliers shall encourage staff members to report to an appropriate senior manager if they know of or suspect any business activity that is in contravention of the Supplier's own Financial Crime procedures. Suppliers shall implement disciplinary action for any staff member failing to comply with such procedures.
Suppliers shall make sure that their staff members do not suffer any adverse consequences for making a report under the Financial Crime policies, whistleblowing or refusing to pay a bribe, even if such refusal may result in the Supplier losing business.
Suppliers shall keep sufficiently detailed records relating to the identification and prevention of Financial Crime and shall promptly notify Temple Partners upon becoming aware of any instance or suspected instance of Financial Crime connected to the business relationship between Temple Partners and the Supplier or which might impact upon Temple Partners’ reputation.
Suppliers shall comply with all applicable anti-bribery and anti-corruption laws, including the Bribery Act 2013 where applicable.
7. Environmental and Social Responsibility
Suppliers shall comply with all relevant laws pertaining to the environment and shall operate their businesses in an environmentally responsible way.
Suppliers shall take a proactive approach when working with Temple Partners towards reducing Temple Partners’ environmental impact when providing Supplier’s services.
Suppliers shall:
adopt such practices and utilise such systems that minimise the use of resources, e.g., water efficiency, energy efficiency, etc.;
ensure that they and their own suppliers use environmentally friendly working practices, tools and equipment, consumables and replacement parts, wherever possible;
ensure, where practicable, that all consumables originate from a sustainable or recycled source;
ensure there are facilities or arrangements in place, either directly or through their own suppliers, to ensure Temple Partners can return used packaging for recycling, reuse or environmentally friendly disposal; and
ensure that any hazardous or toxic waste produced is properly identified and disposed of by licensed and competent bodies via authorised and/or licensed means.
Suppliers shall have a written Environmental and Sustainability Policy appropriate to the size and nature of their operation which addresses preventing, mitigating and controlling serious environmental and health impacts from their operations.
Each Supplier shall carry out annual reviews and audits of its environmental performance and that of its own suppliers, and they shall keep a record of all findings and process and procedure improvements or remediation made to reduce any negative environmental impact. Such records shall be provided to Temple Partners on request.
8. Information Security & Data Protection
Suppliers shall comply with all relevant laws pertaining to data protection and shall not do or omit to do anything which would cause Temple Partners to be in breach of such relevant laws.
To the extent that a Supplier will be processing personal data on behalf of Temple Partners, it will do so only in accordance with the terms set out in the relevant contract between Temple Partners and the Supplier.
To the extent that a Supplier will be collecting personal data in situations where Temple Partners will be a controller or joint controller with the Supplier shall provide, or assist Temple Partners in providing, appropriate privacy information to individuals as required by applicable data protection legislation and the applicable Contract.
To the extent that a Supplier will be processing personal data as a processor and Temple Partners will be a controller, the Supplier agrees to process personal data only in accordance with the documented instructions and purposes set out in the applicable Contract and to return or delete personal data at the end of the relevant services or contract, unless applicable law requires its continued retention. The Supplier agrees to ensure that all sub-processors used by them adhere to the same levels of protection for any data provided to them by Temple Partners.
Each Supplier will comply with the information security requirements set out in Temple Partners’ Information Security Policy for Suppliers, to the extent relevant to the Supplier’s business and the provision of the services.
9. Resilience and Business Continuity
Temple Partners expects all businesses in our supply chain to have business continuity arrangements in place to ensure that you can continue to provide your services to us in the event of any disruption to your operations. As a minimum, these resilience arrangements should consider: people, premises, process (information and technology) and providers. More detail will be provided through the procurement process and contained within individual contracts, where business continuity arrangements may be subject to review as part of the ongoing management of the contract.
Temple Partners expects all businesses in our supply chain to have Business Continuity Management (BCM) systems in place which are defined, implemented and executed in a sustainable way, to ensure that you can continue to provide your services to us in the event of any disruption to your operations.
The scope of the Supplier’s BCM should be determined by a Business Impact Analysis (BIA) which covers products and/or services delivered to Temple Partners e.g., critical employees, IT applications and systems, infrastructure and third-party suppliers.
The Supplier’s Business Continuity Plans (BCPs) must be regularly tested, reviewed and updated. They must also be comprehensively taught to the supplier’s personnel relevant to the products and/or services supplied to Temple Partners.
Temple Partners’ Suppliers must have a communication plan and process to inform customers in due course on business disruptions.
Temple Partners may, as part of ongoing contract management, request information on a Supplier’s BCM framework, processes and documentation.
10. Security
We are committed to ensuring effective controls are in place to protect people, property and services. Compromises of physical or cyber security can result in disruption, with potentially serious social and economic consequences. We require our supply chain partners to demonstrate a similar commitment to security and have appropriate policies and procedures in place to provide a continued safe and secure work environment. Security related controls should be proportionate to the risk, the detail of which will be contained within, and managed through individual contracts.
11. Cyber Security
Temple Partners is committed to delivering safe, secure, reliable and sustainable operations. This includes ensuring all reasonably practicable cyber security controls are in place to prevent unauthorised access, damage or interference to our information assets or data. Failing to protect information can also have a serious reputational impact.
Suppliers shall take steps to reduce the risk of a cyber security breach. Suppliers must ensure that their own cyber security arrangements and those within their supply chain are appropriate to the requirements of the information assets concerned, and any contractual obligations to us. This must include appropriate governance and risk management processes, ensuring access to data is maintained on a need to know, least privileged basis and that processes are in place to respond effectively to any incidents. Suppliers should inform us if they become aware of any cyber security incident that could or has compromised our data or services.
Suppliers should implement mandatory Cyber Security and Data Protection training for staff members, appropriate oversight, regular risk assessments, appropriate due diligence, and procedural audits to protect the availability, integrity, and confidentiality of the data.
Suppliers shall ensure that workers promptly report any actual or suspected personal data breach or information-security incident in accordance with the Supplier's incident-response procedures and the requirements of the applicable contract. Suppliers shall cooperate fully with Temple Partners in assessing and managing any such incident, including any notification to a supervisory authority or other regulator where legally required.
Suppliers shall keep sufficiently detailed records relating to the data breach and security incidents and shall promptly notify Temple Partners upon becoming aware of any instance connected to the business relationship between Temple Partners and the Supplier or which might impact upon Temple Partners’ reputation.
12. Data Protection
We require that all businesses within our supply chain must design their organisational structure in such a way that it meets our data protection standards and all applicable data protection legislation, including the data protection legislation in the Isle of Man. In support of this Suppliers must ensure that they are able to demonstrate compliance with:
▪ Our data privacy policy which is available on our website.
▪ As a contractual requirement, Suppliers must notify Temple Partners within 24 hours of becoming aware of any actual or suspected personal data breach. These notifications should be sent to sbroom@templepartners.co.uk and where legally permitted and appropriate, Suppliers should notify Temple Partners as soon as reasonably practicable before notifying a governmental or regulatory authority, where doing so will enable Temple Partners to undertake remedial work and prepare any notifications required by law.
▪ Any additional requirements contained within individual contracts, master service agreements or statement of work including where data protection obligations may be subject to review as part of the ongoing management of the contract.
Suppliers must ensure they follow the following data privacy principles:
▪ Purpose Limitation - you only process personal data for the sole purposes of the performance, management, and monitoring of the contract
▪ Lawfulness, fairness, and transparency – you ensure any personal data is processed transparently, fairly, and clearly as stated in the contract
▪ Data Minimisation – you ensure the use of personal data is necessary for the performance of the contract
▪ Accuracy – you ensure that personal data is recorded accurately and rectify or erase personal data if required
▪ Integrity and Confidentiality – you ensure personal data is kept secure by (a) using secure methods of transfer/ delivery/ access to data; (b) using encryption methods to ensure that data cannot be lost, read, copied or erased without authorisation; and (c) Suppliers shall not transfer personal data outside the Isle of Man or other applicable jurisdiction without ensuring that the transfer complies with applicable data protection legislation and without obtaining any consent or approval required under the relevant contract.
▪ Storage Limitation - you must delete personal data when it is no longer required for the contractual purposes and ensure the transfer/return any personal data to the data controller if required
▪ Accountability - you must report any data breach, potential data breach, or concerns regarding personal data related to us to sbroom@templepartners.co.uk
13. Health & Safety
Temple Partners requires that a safe and healthy workplace is provided for all Supplier personnel in accordance with applicable health and safety legislation in the jurisdiction in which the Supplier operates and, where relevant, the Isle of Man and such laws are complied with at all times.
Clear documented procedures must be in place to ensure regulated occupational health, safety and wellbeing standards are adhered to.
Health and safety in the workplace shall be the responsibility of a senior member of the Supplier's management where the Supplier is contracted to carry out delivery of goods or services within the Temple Partners workplace.
14. Training
The Supplier shall implement a system of training for its workers to ensure that they are aware of the requirements of this Supplier Code of Conduct.
The Supplier shall keep a record of all training offered and completed by its workers and shall make a copy of such record available to Temple Partners on request.
15. Certifying compliance and audit
The Supplier shall provide written confirmation to Temple Partners at least once per year that:
it has appropriate systems in place to monitor its compliance with this Supplier Code of Conduct; and
it is able to comply with this Supplier Code of Conduct for the duration of its relationship with Temple Partners.
In addition to the written confirmation required above, Temple Partners may conduct audits to verify the Supplier's compliance with this Supplier Code of Conduct and Supplier will provide all reasonable access and assistance to Temple Partners to conduct such audits. Temple Partners has no obligation to conduct such audits.
16. Self-monitoring and reporting breaches
The Supplier shall monitor its compliance with this Supplier Code of Conduct and shall report any breaches (actual or suspected) of this Supplier Code of Conduct as soon as possible to sbroom@templepartners.co.uk
The Supplier shall not retaliate or take disciplinary action against any worker that has, in good faith, reported breaches of this Supplier Code of Conduct or questionable behaviour, or who has sought advice regarding this Supplier Code of Conduct.
17. Breach, remediation, and termination
Where Temple Partners becomes aware of a breach of this Supplier Code of Conduct by a Supplier or its workers, Temple Partners may exercise its contractual rights, which may include requiring the Supplier to produce a remediation plan specifying the actions it will take to achieve compliance. The Supplier shall provide such remediation plan within 5 working days of being requested to do so. If the Supplier fails to produce the remediation plan within that timeframe, or fails to implement it within a reasonable period, Temple Partners may exercise its contractual rights, which may include termination of the relevant contract.if the Supplier fails to produce the remediation plan within this timeframe or fails to implement it within a reasonable time, Temple Partners may exercise its contractual rights, which may include termination of the relevant contract.