INTRODUCTION
The Independents Group and each of its affiliated Agencies and Businesses (“The Independents”, “we”, “us” or “our”) aspires to provide the very highest quality of service whilst ensuring that our business is conducted in an ethical way. We commit to meet these ethical standards and to comply with all applicable laws, regulations and national and international conventions, as well as with best practices, in particular regarding labor standards and social responsibility, protection of the environment, and ethics and business integrity. We also, therefore, expect our clients, vendors, suppliers and other business partners and their respective subcontractors (collectively, “Partners”) to share and meet the same ethical standards equivalent to their particular business sector throughout the course of their operations.
The Independents places huge importance on ensuring that Partners share a set of common principles with respect to labour standards and social responsibility, protection of the environment, and ethics and business integrity. Consequently, The Independents establishes and promotes exemplary relations with all its Partners anchored in responsibility, fairness and integrity. The Independents therefore requires its Partners to respect the principles set forth in this Partner Code of Conduct Charter and to ensure that their own suppliers do the same in the conduct of their activities with The Independents.
LAWS AND ETHICAL STANDARDS
Partners shall comply at all times with all national and international laws applicable to their business and will support the principles of the Conventions of the International Labour Organization, the United Nations Global Compact, the UN Universal Declaration of Human Rights, the OECD Guidelines for Multinational Enterprises and the United Nations Women’s Empowerment Principles, as well as the International Labour Organisation Declaration on Fundamental Principles and Rights at Work, in accordance with national laws and practices.
SLAVERY AND CHILD LABOUR
Partners shall take all reasonable steps to ensure that slavery, servitude, human trafficking, forced or compulsory labour and/or child labour do not take place in their supply chains or in any part of their business (including making all necessary enquiries with their suppliers and, to the extent reasonable, other parties in the supply chain).
Partners shall adhere to minimum age provisions set by national laws and shall require the same throughout their supply chain. Where applicable national laws fall short of generally accepted international standards, Partners shall seek to observe international standards.
Partners shall comply with all applicable anti-slavery legislation and any other applicable regulations designed to prevent illegal, clandestine or undeclared employment, in each case as updated from time to time.
HUMAN RIGHTS
Partners are expected to support and respect the protection of internationally proclaimed human rights and ensure that they are not complicit in human rights abuses. Partners shall behave responsibly, treat their workers with respect and dignity and not work with third parties that have poor human rights records.
WORKING HOURS AND WAGE
Partners shall follow all applicable local laws and regulations in relation to working hours, which shall not in any case exceed the maximum set by internationally recognised standards such as the International Labour Organization. Employees must be provided with wages that, as a minimum, comply with the Living Wage relevant to their specific location, as well as under national laws. Wage reductions or additional hours shall not be used as a disciplinary measure. Further, Partners shall grant employees the right to freedom of association and collective bargaining in accordance with all applicable laws and regulations.
NON DISCRIMINATION
The Independents expects its Partners to treat all workers equally and fairly. Partners shall not discriminate on the basis of race, religion, ethnicity, disability, age, sexual orientation, gender, political affiliation, union membership or marital status or otherwise engage in any kind of discrimination. Partners shall provide a workplace free of inhumane and degrading treatment, including sexual harassment, sexual abuse, corporal punishment, bullying, mental, physical or verbal abuses of employees and with no threats of such treatment.
Partners are expected to promote gender equality and women's empowerment, and to take steps to ensure that they are striving for the highest standards of support for employees from minority and/or underrepresented groups.
ANTI-BRIBERY AND CORRUPTION
The Independents has a zero-tolerance approach to corruption. Partners must never, directly or through their intermediaries, offer, promise or receive any personal or improper advantage in order to obtain or retain a business or other advantage from a third party.
Partners must not pay or receive bribes or kickbacks and shall not take any actions to violate, or cause their business partners to violate, any applicable anti-bribery laws and regulations. Particular care should be taken when dealing with public officials in order to ensure that all relevant national laws for dealing with such individuals are complied with.
Partners should have their own anti-corruption policy and related procedures.
The Independents requires its Partners to take all appropriate measures to prevent them or their operations from being used as vehicles for money-laundering.
TRADE RESTRICTIONS AND INTERNATIONAL SANCTIONS
The Independents requires its Partners to respect all applicable international trade restrictions and economic and trade sanctions, taking into account any changes in these measures, as well as all applicable laws and regulations concerning export and import controls.
TAX EVASION
Partners must not evade paying tax or knowingly assist others to evade taxes. "Tax evasion” generally refers to the illegal evasion of taxes where individuals or organisations dishonestly or fraudulently under-declare their taxes.
HEALTH AND SAFETY
We expect Partners at all times to strive for the highest standards of occupational health and safety. Partners shall comply with all applicable occupational health and safety regulations and provide a work environment that maintains the health and welfare of employees and prevents accidents, injuries and work-related illnesses.
ENVIRONMENT
Partners shall comply with all applicable environmental laws, regulations and standards and maintain effective systems to identify and eliminate potential hazards to human health and/or the environment from pollution and waste.
Partners are expected to integrate into their processes systems that are intended to prevent pollution, control raw material usage, avoid unnecessary waste, promote energy efficiency and minimise carbon emissions.
Partners are encouraged to join collaborative, industrywide efforts to share knowledge, with the aim of helping reduce negative effects on the environment and the natural world, in particular with regard to production processes.
Partners shall have in place a procedure for completing Environmental Impact Assessments (EIA) in respect of their operations, so as to identify and mitigate any aspects that are likely to have a significant negative effect on the environment.
ANIMAL WELFARE
We expect Partners to comply at all times with all applicable laws in relation to the welfare of animals, including but not limited to the standards and guidance specified under the any applicable animal welfare legislation.
SUSTAINABILITY
We encourage all of our Partners to use Life Cycle Assessments (LCA) when sourcing materials, products and services to help prevent the deletion of natural or physical resources.
Where possible, Partners should seek to support their local communities and work with local charities and enterprises, and (where applicable and reasonable to do so) should look to use locally-sourced produce.
CONFLICTS OF INTEREST
Partners shall immediately report any situation which, in relation to their business with The Independents, appears to present a conflict of interest with The Independents.
Partners shall immediately inform The Independents if they become aware that any staff member or any professional otherwise under contract with The Independents may have a conflicting interest of any kind in the Partner’s business.
PROTECTION OF PERSONAL INFORMATION
Partners must adhere to relevant data protection and security laws and to respective regulations, in particular with regard to personal data of customers, consumers, employees and shareholders. Partners must comply with all said requirements when personal data is collected, processed, transmitted, used or retained.
BUSINESS CONTINUITY PLANNING
Partners must be prepared for any disruptions of its business (e.g. natural disasters, terrorism, software viruses, illness, pandemics, infectious diseases, worker shortages). This preparedness especially includes business continuity and disaster recovery plans to protect both employees as well as the environment as far as possible from the effects of possible disasters that arise within the domain of operations.
CONFIDENTIALITY
The Independents requires Partners to commit to taking all necessary measures to guarantee the protection and confidence of all professional secrets and other non-public information they receive in the course of their business relationship with The Independents.
ARTIFICIAL INTELLIGENCE TOOLS
The Independents does not generally allow the use of generative Artificial Intelligence tools in connection with the conduct of its business. We do not consider that the current conditions of use of these tools provides a sufficient security framework to make them viable and secure working tools.
To the extent we permit the use of such tools in connection with specific services provided to The Independents, Partners will be required to: (i) inform us of the generative AI tools they would like to use in the context of their assignments for us and allow our security teams to assess the compliance of these tools with our and client security requirements; (ii) ensure that no confidential, secret, proprietary information or information relating to our or clients’ business is disclosed when using any generative AI platform or tool; and (iii) be able to produce the sources of their inspiration for projects submitted.
THIRD PARTY COMMUNICATION
Partners shall communicate the principles stated in this Partner Code of Conduct Charter to their employees and sub-contractors and other business partners who are involved in supplying the products and services described in the main contract to The Independents. Partners shall take reasonable steps to ensure that such parties adhere to the same or similar standards.
The Independents expects all Partners to ensure that adequate and effective management systems, policies, procedures, and training are in place to ensure ongoing compliance with this Partner Code of Conduct Charter.
MONITORING
The Independents will review this Partner Code of Conduct Charter on an ongoing basis and will highlight any areas of improvement, issues or areas of concern.
Partners shall co-operate fully with The Independents in any investigations or reviews relating to their compliance with this Partner Code of Conduct Charter. Partners shall provide upon request any supporting documentation or information attesting full compliance with this Partner Code of Conduct Charter.
This Partner Code of Conduct Charter will be reviewed and updated as appropriate on an ongoing basis and published on our website.
NOTIFICATION
Partners shall notify The Independents immediately in writing if they become aware or have reason to believe that they, or any of the Independents’ or the Partner’s officers, employees, agents or subcontractors, have breached or have potentially breached any of the Partner’s obligations under this Partner Code of Conduct Charter or any similar policies or procedures. Further, Partners shall provide upon request any supporting documentation or information attesting full compliance with this Partner Code of Conduct Charter.
Any material breach of the obligations stipulated in this Partner Code of Conduct Charter may result in The Independents ceasing to work with the Partner in breach.
November 2023