We only use cookies for website functionality and security.

Supplier Code of Conduct

Introduction

As a responsible business, our purpose and values are embedded throughout Paragon, underpinning how we operate, what we stand for and how we work together to achieve our goals. We take our responsibilities seriously and are focused on doing business the right way. We expect these standards to be upheld throughout our supply chain.

We actively promote good practice on a range of important issues and expect the same from our suppliers and other business partners. We know that collaborating effectively with our suppliers is essential, not only for our business but also for our customers and our people. At the highest level, we expect our suppliers to:

  • work in line with all relevant regulations, legislation and guidelines that apply to your activities
  • consider the impacts of your products, operations and working practises and to have measures in place to manage these
  • maintain high levels of corporate conduct, and respect the welfare and wellbeing of your employees and the communities in which you operate

As a regulated organisation, we must have controls in place when choosing and working with suppliers. This is particularly important if suppliers have access to our systems and data, and engage directly with our customers. In these circumstances, we need to make sure we have identified and managed any possible risks.

We expect our suppliers to be able to demonstrate compliance with our Supplier Code of Conduct and therefore may audit your adherence to our Code. If we consider that you are operating in a higher risk supply chain, we may ask you to explicitly agree to our Code or work with you to help you make improvements to align with our Code. If it isn’t possible for you to adhere to our Code, we may adjust our supply chain, including the possible termination of contractual agreements.

This page sets out how we do business and what we expect from our suppliers.

Our commitment and expectations

Bribery and corruption

Bribery and corruption

Our commitment Our expectation of you
We value our reputation for ethical behaviour and financial probity. We do not condone bribery and corruption. We recognise that, over and above commission of any crime, any involvement in bribery reflects adversely on the Group. All our employees are required to complete mandatory training to recognise and respond appropriately to bribery and corruption. We expect you to have the relevant controls in place to prevent any kind of bribery and corruption. This includes adhering to international laws and regulations and implementing the standards of this Code with your own suppliers.
Gifts and hospitality

Gifts and hospitality

Our commitment Our expectation of you
We don’t accept gifts or hospitality during, or for a period of three months after, any contract negotiations. This includes during the procurement process, awarding and/or variations to the contract. Gifts and/or hospitality outside these circumstances are subject to internal approval. We expect you to adopt your own code policies or statements including not accepting gifts or hospitality that could create a sense or appearance of obligation.
Protecting our data

Protecting our data

Our commitment Our expectation of you
We are committed to ensuring data held across the Group is protected. We have policies and procedures in place to make sure we comply with all UK data protection legislation. Our data protection risk policy applies to all applicable data acquired, held, used and managed across our business. We expect you to comply with UK data protection legislation and treat data protection as seriously as we do. This includes being vigilant to anything suspicious which may lead to a data breach, taking swift action and advising us immediately.
Modern slavery

Modern slavery

Our commitment Our expectation of you
We have a zero-tolerance approach to slavery and human trafficking. We measure the effectiveness of combatting slavery and trafficking in any part of our business and supply chain including whistleblowing reports, supplier reviews and modern slavery online training modules. Our Modern Slavery Statement provides further detail. We require you to comply with all relevant legislation, regulations and directives, including awareness and mitigation of the risk of modern slavery in the countries and communities in which you operate and, where relevant, compliance with the UK Modern Slavery Act.
Where you don’t have an obligation to produce your own annual statement on Modern Slavery, we will ask you to attest to your internal approach.
Conflicts of interest

Conflicts of interest

Our commitment Our expectation of you
We make sure we act with integrity and take the necessary measures to demonstrate impartiality in our engagement with suppliers and in decision-making. We expect you to disclose all potential conflicts of interest as soon as you are aware of them. For example, family relations or business relationships.
Equal opportunities

Equal opportunities

Our commitment Our expectation of you
We are fully committed to eliminating unfair and unlawful discrimination. We believe that everyone should be able to work in an environment free from discrimination, harassment and bullying, and that employees, along with job applicants, customers, business introducers and suppliers should be treated fairly. We have policies to make sure all employees and every worker and contractor we work with meet the highest integrity and professional conduct standards. We expect you to commit to eliminating unfair and unlawful discrimination.
Equality, Diversity and Inclusion (EDI)

Equality, Diversity and Inclusion (EDI)

Our commitment Our expectation of you
We value the differences that a diverse workforce brings to our organisation and the community, and promote a culture that welcomes equality, diversity and inclusion. We promote this through a dedicated EDI Network which works alongside our senior leadership team. We expect you to understand our vision in relation to equality, diversity and inclusivity. We also expect you to proactively support the development of your own inclusive and diverse workforce.
Living wage

Living wage

Our commitment Our expectation of you
We are an accredited employer with the Living Wage Foundation and support its principle of a real living wage being good for business, good for the individual and good for society. Where you contract people on our behalf, we expect you to also pay the real living wage in line with the Living Wage Foundation.
Health and safety

Health and safety

Our commitment Our expectation of you
The health and safety of our employees, suppliers, customers and anyone else affected by our work activities, is our priority. We work hard to identify and manage any health and safety risks and make sure we comply with relevant legislation. We expect you to provide your people with a safe workplace which complies with all applicable laws and regulations.
Environment

Environment

Our commitment Our expectation of you
In terms of our own operational footprint, we take care to identify, manage and minimise our impact on the environment, complying with all applicable laws and regulations. We also operate a Green Charter to raise our employees’ awareness of our impact on the environment. As a minimum, we expect you to comply with all applicable environmental regulatory requirements and mitigate any adverse impacts your products and services may have on the environment.
If we classify you as having a high or medium environmental impact, you must have policies and procedures in place to manage the risks.
Prompt and fair payment

Prompt and fair payment

Our commitment Our expectation of you
We are a signatory to the UK’s Prompt Payment Code (‘PPC’), administered by the Office of the Small Business Commissioner and as such commit to paying invoices within 60 days, unless there is good reason for non-payment, and within 30 days for small businesses unless under query. We expect you to adopt similar principles in respect of the fair treatment and prompt payment for services or goods provided within your own supply base.
Financial crime

Financial crime

Our commitment Our expectation of you
We work hard to prevent all aspects of financial crime and to comply with regulatory obligations. We have policies covering all aspects of financial crime and all employees undertake regular training. You should be aware of, understand and adhere to the obligations and requirements imposed on you in relation to money laundering and the prevention of financial crime in general, and be committed to preventing and detecting any instances.
Whistleblowing

Whistleblowing

Our commitment Our expectation of you
We want our people to feel able to raise concerns about wrongdoing or misconduct safely and without fear of recrimination. We have an established whistleblowing procedure in place and a hotline, operated by Protect, a third-party charity, available to all employees who have any concerns about wrongdoing within the business. We expect you to adopt your own approaches for whistleblowing and to ensure that your employees have the ability to raise concerns without fear of recrimination.

Contact us

If you’d like more information about our Supplier Code of Conduct or have any questions, you can contact us at [email protected].