Euro Pool System International B.V. and its subsidiaries (herein jointly referred to as âEuro Pool Groupâ or âEPGâ) are committed to offering high quality services to its customers. Euro Pool Group is also committed to execute its business in compliance with applicable laws and regulations in the countries in which it operates, ensuring that the parties that supply Euro Pool Group with services and products (herein individually referred to as a âSupplierâ) do the same, maintaining a high standard of business ethics and regard for human rights throughout its supply chain. The EPG Supplier Code of Conduct sets out minimal standards for Suppliers that are designed to ensure that Euro Pool Group has visibility into all aspects of its supply chain and meets these objectives.
Euro Pool Group requires its Suppliers to comply with all applicable laws and regulations as well as the rules set forth in this Supplier Code of Conduct and relevant policies, as may be implemented and/or amended from time to time. Contracts concluded with a Supplier may contain more specific and detailed provisions addressing the same issues as included in this Supplier Code of Conduct. If so, the relevant provisions of the specific contract supersede the relevant provisions of this Supplier Code of Conduct and, in case of any inconsistency between this Supplier Code of Conduct and any other provision of a particular contract, the provisions of the particular contract will prevail.
Wherever applicable laws and regulations are in conflict with the provisions of this Supplier Code of Conduct, Suppliers must seek ways to abide by the principles that provide the highest protection to the workers and the environment while at the same time complying with applicable laws and regulation.
Suppliers are expected to be able to provide evidence of their compliance with this Supplier Code of Conduct and all applicable laws and regulations upon request. In the event that a Supplier fails to comply with any of the provisions of this Supplier Code of Conduct, the Supplier must take corrective actions without delay.
Any Supplier not complying with any of the provisions of this Supplier Code of Conduct will be in material breach of any agreements or contracts it may have with Euro Pool Group and Euro Pool Group will have all rights under such agreements or contracts to terminate such agreements or contracts. Euro Pool Group reserves the right to terminate its relationship with any Supplier in the event of violations of this Code of Conduct by such Supplier or any of its subcontractors involved in the provision of services to Euro Pool Group or production of products purchased by Euro Pool Group. If Euro Pool Group terminates its relationship (including one or more of its agreements or contracts) with a Supplier due to the fact that such Supplier or any of its subcontractors involved in the provision of services or the production of products fails to meet the provisions of this Supplier Code of Conduct, no damages whatsoever shall be payable by Euro Pool Group in connection with such termination.
If a Supplier hires or engages a subcontractor in connection with the provision of goods or services to Euro Pool Group, the Supplier shall cause its subcontractor to comply with this Supplier Code of Conduct as if Euro Pool Group entered into an agreement with the subcontractor directly.
Euro Pool Group reserves the right to conduct, with or without prior notice, audits or assessments to monitor Suppliersâ compliance with the provisions of this Supplier Code of Conduct. This may include the inspection of the premises of Suppliers and / or interviews with their employees. Suppliers must collaborate with any such inspection and must also provide information necessary for Euro Pool Group to monitor compliance.
Suppliers shall provide Euro Pool Group with high-quality products and services. All products and services delivered by the Supplier shall meet the quality, safety and food safety standards required by applicable laws and shall comply with the Euro Pool Groupâs requirements, as may be implemented and/or amended from time to time.
Suppliers are required to immediately report to Euro Pool Group any concerns concerning product safety and / or product quality related to the Supplierâs products or services.
Suppliers shall adhere to all applicable laws and regulations on occupational health and safety and must develop and follow strong internal procedures and measures regarding occupational health and safety. Workplace practice and conditions in residential facilities (and during commuting) provided by the Supplier which violate human rights are forbidden.
Suppliers must develop a robust and effective internal health & safety management system with the aim of minimising the risks associated to their operations and the causes of hazards inherent in their working environment. All of Supplierâs workers must timely receive all necessary and adequate health & safety training and must be re-trained as required by local law and when any new or additional need or risk is identified.
Suppliers must provide safe and healthy working environments, considering the prevailing knowledge of the industry and of any specific hazards, to prevent accidents and injuries and protect workersâ health.
Suppliers shall identify and take necessary measures to be prepared for emergency situations. Suppliers shall regularly train their employees on emergency planning, responsiveness as well as medical care.
Suppliers will have to guarantee workers access to clean sanitary services and safe drinking water and, if applicable, hygienic-sanitary equipment must be provided.
Suppliers will respect the Universal Declaration of Human Rights and the eight fundamental Conventions of the International Labour Organisation (ILO). In particular, each Supplier must observe within their organisations as well as in their supply chains:
(i) that no forced or bonded labour shall take place and that all the Suppliersâ employees, including contract workers, will be able to work freely;
(ii) that they will not engage in or allow child labour within their facilities or in those of their subcontractors and that they will respect the rights of the child as stated in the Convention on the Rights of the Child. Suppliers will adhere to the ILO definition of the minimum age for admission to employment or work;
(iii) that they will not discriminate and shall promote equal opportunity in hiring and in employment practices on the grounds of ethnic origin, gender, race, religious beliefs, sexual orientation, age, disability, nationality, social-economic status, political orientation or other ideologies and union membership;
(iv) that it will treat their employees and workers fairly, with respect and dignity, guaranteeing equal opportunities for all. Therefore, workers must never suffer sexual, physical, or psychological, harassment or any other form of intimidation at work. Suppliers shall recognize and promote the positive value of diversity;
(v) that they recognize the workersâ right to join workersâ organizations and collective bargaining. Similarly, Suppliers acknowledge the importance of direct commitment between workers and management and should encourage open communication regarding working conditions without workers being afraid of harassment, intimidation or reprisals;
(vi) that they will act in compliance with national regulations and international labour standards and industry standards concerning working hours and rest periods, including the right to maternity leave, sick leave and any other leave to the extent permitted by applicable law and industry standards;
(vii) they will comply with the applicable laws and regulations and collective labour agreements concerning salaries and benefits;
(viii) that their workers will have legal contracts and that they establish recognized work relationships with their workers according to applicable laws and regulations and industry standards; and
(ix) that they will do anything to ensure that their workers can enjoy their legal and contractual rights.
6.1. ANTI-BRIBERY
Euro Pool Group does not accept or allow any form of bribery. Suppliers shall not engage in any form of bribery, including but not limited to the promising, offering, giving or accepting of any improper monetary or other incentive.
6.2. GIFTS AND ENTERTAINMENT
Invitations, diners and gifts can be used by our Suppliers in line with local business practices to show appreciation, to develop the business relationship and/or to create goodwill. This only when appropriate. Appropriate here means well-timed, moderate, and not in excess of locally acceptable business practices (and always in conformity with the law – local and European- and policy of the recipientâs organization).
Euro Pool Group does not offer or accept gifts or entertainment to influence a business decision and expects its Suppliers to behave similarly.
6.3. FAIR TRADE AND COMPETITION
Euro Pool Group requires its Suppliers to conduct their activities and business using competitive and fair market practices and in accordance with the requirements of applicable national, European Union and international antitrust and competition laws.
Suppliers will not engage in illegal cartels, price fixing, unlawful exchanges of information with competitors or other unfair trade practices.
6.4. ASSETS PROTECTION
If during or as part of the supply of goods and/or services, the Suppliers have control over or use Euro Pool Groupâs assets, Suppliers have a duty to safeguard them and to prevent damage to and loss of such assets.
Such assets must be used by Suppliers solely for the supply of the services and/or products agreed upon and in accordance with Euro Pool Groupâs policies and instructions that may be applicable from time to time. Suppliers shall not use Euro Pool Groupâs assets for any form of personal benefit or for the supply of services and/or products to third parties.
6.5. CONFLICTS OF INTERESTS
Situations may arise where Supplierâs interests could conflict with those of Euro Pool Group or its stakeholders.
Suppliers must:
6.6. CONFIDENTIALITY AND INFORMATION SECURITY
Suppliers who receive or manage information related to Euro Pool Group, its stakeholders or its business operations shall implement adequate measures to guarantee the confidentiality, integrity and availability of the information shared with them by or on behalf of Euro Pool Group. The Suppliers shall treat all business, commercial and financial information relating to Euro Pool Group and its business partners as confidential.
6.7. INTELLECTUAL PROPERTY
Products and services supplied to Euro Pool Group by Suppliers shall respect all industrial and/or intellectual property rights of third parties and shall comply applicable laws and regulations in that respect.
Suppliers may use company name, signs, brands, logos, trademarks or registered symbols owned or licensed to Euro Pool Group only when such is explicitly agreed upon in writing in the specific contract entered into with Euro Pool Group. However, no right or license is granted on or in respect of any Euro Pool Group intellectual property right. In case of termination of any agreement or contract between Euro Pool Group and Supplier, the Supplier will immediately cease any contractually permitted use of Euro Pool Group intellectual property.
Suppliers may not register brands, trade names, trademarks or signs similar to those of Euro Pool Group.
Suppliers must immediately report to Euro Pool Group any action contrary to the interests of Euro Pool Group of which they become aware. Suppliers will provide Euro Pool Group with the necessary assistance for any matter relating to the protection of Euro Pool Groupâs intellectual property rights before the competent judicial authority.
6.8. DATA PROTECTION
Suppliers shall comply with all relevant laws and regulations pertaining to data protection and shall not do or omit anything which would cause Euro Pool Group to be in breach of any such laws and/or regulations.
To the extent that Suppliers are processing personal data on behalf of Euro Pool Group, they will only do so in accordance with the terms set out in Euro Pool Group’s privacy statement set out on Euro Pool Groupâs website (see: https://www.europoolgroup.com/privacy-page.html).
Euro Pool Group is committed to pursue environmental responsibility throughout its entire supply chain and aims to cooperate with business partners with the same environmental commitment, which effectively search for new ways to preserve resources and reduce environmental impact.
Suppliers must comply with all applicable environmental standards, laws and regulations in all countries in which they operate; primarily by obtaining and maintaining environmental permits and approvals for carrying out regulated activities.
Suppliers shall act in accordance with the sustainability policy of Euro Pool Group as may be amended from time to time.
Suppliers shall establish a robust and resilient supply chain and adequate processes to ensure uninterrupted supply of products and/or services. The Suppliers shall implement and administer appropriate plans to ensure business continuity.
If Suppliers have any concerns regarding a possible violation of this Supplier Code of Conduct or any applicable rules and regulations, they are encouraged to addressing this in accordance with the Euro Pool Group Whistle-Blower Policy for Third Parties set out on Euro Pool Groupâs website (see : https://www.europoolgroup.com/governance.html).
Euro Pool Group reserves the right to modify this Supplier Code of Conduct from time to time.