Supplier Code of Conduct 

At System C we are committed to conducting business with integrity, transparency, and respect for human rights, the environment, and our stakeholders. This Supplier Code of Conduct sets out the standards and expectations we have for our suppliers. All suppliers must agree to and abide by this Code as well as the standards of their own professional bodies as part of their engagement with System C.  It is expected Suppliers will adopt requirements similar to those contained in this Code in their own organisation and their supply chain.

Compliance with Laws and Regulations

Suppliers must comply with all applicable local, national, and international laws, regulations, and industry standards. This includes laws related to:

• Employment and labour rights
• Health and safety
• Environmental protection
• Anti-bribery and corruption
• Financial sanctions (geographic or thematic)
• Data protection and privacy (such as the UK GDPR)

Labour & Human Rights

Suppliers must uphold the highest standards of human rights, including but not limited to:

• No Forced or Involuntary Labour: We are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business.  Therefore, System C does not tolerate slavery, forced labour, or human trafficking in any form. System C requires Suppliers to fully comply with the applicable legal requirements of slavery, forced labour and human trafficking laws (e.g., UK Modern Slavery Act 2015), and expects Suppliers to enact practices to ensure compliance with such laws.  Suppliers must not engage in any form of forced, bonded, or indentured labour or human trafficking.  View the System C Modern Slavery Act 2015 Statement.
• Child Labour: Suppliers must not employ individuals below the minimum legal working age in their country of operation.
• Fair Working Conditions: Suppliers must ensure fair wages, reasonable working hours, and safe working conditions for all employees.
• Non-Discrimination: Suppliers must provide a workplace free from harassment, discrimination, and abuse, where employees are treated with dignity and respect regardless of race, gender, religion, sexual orientation, or any other protected characteristic.

Health, Safety & Wellbeing

Suppliers are expected to adopt practices to minimise health and safety risks, support accident prevention, and ensure a safe and healthy working environment for their employees. This includes: 

• Compliance with local and international health and safety laws and regulations.
• Providing training, protective equipment, and a culture of health and safety awareness.
• Taking proactive measures to prevent workplace accidents, injuries, and illnesses.

Environmental Responsibility 

Suppliers must demonstrate a commitment to environmental sustainability by:

• Measuring, managing, and addressing energy usage and greenhouse gas (GHG) emissions.
• Minimising waste, emissions, and water and energy consumption.
• Using resources efficiently and responsibly.
• Ensuring the safe handling, storage, and disposal of hazardous materials.
• Avoiding the use of environmentally harmful substances and processes.
• Identifying opportunities to develop/innovate more environmentally friendly products/service solutions and take manufacture, use and disposal into consideration, including the possibility of circular supply chains.
• Complying with all relevant environmental laws and regulations.

 View the System C Environmental Policy.

Business Integrity & Ethics

We expect suppliers to act with integrity in all business dealings. This includes:

• Anti- Corruption and Bribery: Suppliers must not engage in any form of corruption, bribery, or unethical conduct and comply with requirements of all applicable bribery and anti-corruption laws e.g. UK Bribery Act.

• Fair Competition: Suppliers must comply with competition laws and engage in fair and transparent business practices.
• Confidentiality and Data Protection: Suppliers must protect confidential information and comply with relevant data protection regulations, including the UK GDPR.
• Gifts and entertainment: Suppliers must not offer or accept any gift to obtain improper advantages or influence for the Supplier, System C (such as System C’s employees and their family members and associates), or any third party. Gifts include a benefit, fees, commissions, dividends, cash, gratuity, services, or any inducements.

• Diversity, Equity and Inclusion: At System C, we recognise that diversity drives innovation and positive change benefiting us all. Our aim is to build a more equitable and inclusive world, both within and beyond System C, with an aim to positively support communities we work with.  We take collective responsibility to cultivate an empathetic culture where everyone can not only thrive but also feel a sense of inclusion and belonging.  Suppliers must comply with all applicable laws relating to discrimination in recruitment, employment practices, and harassment and retaliation. Suppliers are expected to operate workplaces free of discrimination, harassment, victimisation, and any other abuse on any grounds.

Supply Chain Transparency

Suppliers are responsible for ensuring that their own suppliers, subcontractors, and business partners adhere to similar ethical, environmental, and human rights standards. This includes:

• Conducting due diligence on their supply chain and impacts caused by their activities, and actively seek out ways in which to minimise negative impacts.
• Ensuring transparency in sourcing, production, and labour practices.
• Taking corrective action if any violations are identified.
• Supporting Fairtrade conditions for producers, where applicable

Conflict Minerals

Where applicable, suppliers must ensure that materials and products provided to System C are free from conflict minerals, which contribute to human rights abuses or environmental harm.

Reporting & Compliance 

Suppliers must be transparent in their operations and provide accurate information to System C upon request. Suppliers must report any instances, of illegal or unethical behaviour or any potential breaches of this Code of Conduct in relation to the goods and services being provided to the Procurement Office (Procurement@SystemC.com) without delay, with an action plan to address the situation.

In the event of non-compliance, System C reserves the right to take appropriate action, which may include:

• Working with the supplier to rectify the issue.
• Suspension of the business relationship.
• Termination of the contract.

Monitoring & Audits

System C reserves the right to monitor and audit suppliers to ensure compliance with this Code of Conduct. Suppliers are expected to cooperate fully with any such audits and provide access to relevant documentation and personnel.

Commitment to Continual Improvement 

We encourage our suppliers to continually improve their ethical, environmental, and labour practices. Regular evaluations of practices and seeking innovative ways to improve are strongly encouraged.

Acknowledgment 

By entering into a business relationship with System C, suppliers agree to uphold and adhere to this Supplier Code of Conduct. Suppliers are expected to communicate these standards to their employees, suppliers, and subcontractors.