HSS ProService Group
Supplier Ethics & Conduct Policy
| # | Section | Page |
| 1 | General Principles |
2 |
| 2 | Compliance with Law |
2 |
| 3 | Human Rights |
2 |
| 4 | Discrimination & Harassment |
3 |
| 5 | Health & Safety |
3 |
| 6 | Environmental, Social & Governance |
4 |
| 7 | Supplier Performance & Continuous Improvement |
5 |
| 8 | Sanctions |
5 |
| 9 | Bribery |
6 |
| 10 | Anti-Facilitation of Tax Evasion |
6 |
| 11 | Political Contributions |
6 |
| 12 | Conflicts of Interest & Transparency |
6 |
Revision 1 - 10/12/2024
1. General Principles
This Code acts as a guide to the main practices and policies through which HSS ProService and its subsidiary companies, which includes HSS ProService Limited, HSS Training Limited, HSS ProService Market Place (together “HSS”) conduct their business. HSS requires all its suppliers to adhere to the practices & policies laid out in this document & the HSS Code of Ethics. Available is at https://www.hsshiregroup.com/Sustainability/Governance This Code is fully supported by the Board, and the policies underpinning it are regularly reviewed by senior management in the light of changing business and regulatory requirements. This policy replaces the previous HSS supplier CSR policy.2. Compliance with Law
We will, and expect our suppliers to, act at all times within the letter and spirit of all applicable laws and regulations in the jurisdictions in which we conduct business. This includes open and transparent dealings with all tax and competition authorities, as well as treating all information in our possession, both personal and corporate, as confidential. HSS follows best practice in order to comply with data protection legislation.3. Human Rights
Modern Slavery Act 2015Modern slavery is a crime and a violation of fundamental human rights. HSS has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains. We expect the same high standards from all of our contractors, suppliers and other business partners. We aim to maintain good relationships with all our key suppliers and expect them to adhere to similar ethical standards as ourselves. We apply enhanced supplier criteria, measuring them and holding them to certain standards in the key areas of sustainability, human rights, forced or child labour, equality, employee wellbeing, health & safety and anti-corruption. We aim to trade with all suppliers on terms that are fair and reasonable to all parties, and to adhere to those terms. Our terms and conditions include a requirement to comply with law (including the Modern Slavery Act 2015), maintain and uphold policies and allow us the right to audit and terminate contracts for non-compliance. The requirement under the Modern Slavery Act to publish an anti-slavery statement applies to companies with financial years ending on or after 31 March 2016. HSS is subject to these disclosure requirements and therefore will publish an anti-slavery statement annually.
Employment practices
We aim to be an employer of choice in the hire industry, and to create an environment where employees are valued, and where their full potential can be developed. We have systems of recognition and reward across our business that fairly and appropriately remunerate and promote all colleagues, regardless of their role or seniority.
Whistleblowing
We provide an objective process whereby colleagues of HSS or suppliers can raise, anonymously if they wish, any concerns they have over issues such as health & safety, fraud or theft, harassment or bullying, or any matter damaging to HSS or any of its stakeholders. All reports are fully investigated, with the whistleblower being kept informed throughout (where appropriate). Part of the process is guaranteed confidentiality and is reassuring colleagues that they will never face any form of reprisal or disciplinary action as a result of raising bona fide concerns in this way.
Equality & Diversity
We are committed to providing equal opportunities in all areas of our business to ensure that all colleagues are treated fairly at all stages of their careers and are given equality of opportunity in terms of training and the development of their potential. Discrimination based on gender, religion, age, sexuality, disability or any other reason is not tolerated, as outlined below. We recognise that diversity is a source of strength in the workplace in terms of differing ideas, experience and perspectives, and aim to act in line with the protected characteristics of the Equality Act 2010.
4. Discrimination & Harassment
We do not tolerate either discrimination against any colleague for any reason whatsoever, or harassment in the workplace; instances of either are treated as gross misconduct, that could result in summary dismissal, as well as the potential involvement of the authorities. All colleagues are encouraged to report any instances either to HR or their manager, or via the whistleblowing process.5. Health & Safety
Safety is a core value of HSS, therefore alignment to HSS standards is mandatory. This includes making sure adequate facilities, training and access to safety information is provided. Where applicable, colleagues (both HSS & Suppliers’) are empowered to maintain H&S standards through continual training and management systems designed to drive continual improvement in these areas, with reference to near-misses through to RIDDORs.All colleagues are trained and expected to take ownership in this area and act as individual “safety champions” in their location. All accidents and ‘near misses’ are reported and investigated to prevent re-occurrence. All our hire fleet is tested and maintained to a high standard before each hire to ensure it is safe to use.
Where suppliers work on HSS premises, or on behalf of HSS, for example in the use, handling, transport or disposal of hazardous materials, they must confirm that they understand their obligations. Suppliers must also confirm that management processes and controls are in place and, where applicable, agree to be fully responsible for any liability resulting from their actions. All suppliers, and any third parties on their behalf, who deliver to HSS or to an HSS customer site or location must adhere to mandatory rules regarding Personal Protection Equipment to ensure the protection of relevant persons.
At HSS, we regard colleague well-being and mental health as an important aspect of health and safety and we have implemented and continue to develop a multitude of initiatives in this area, which have been well received. We encourage our suppliers to introduce similar initiatives to support the wellbeing of their colleagues, if not done so already.
Further detail on this is set out in our Annual report & ESG Impact Report down-load at https://www.hsshiregroup.com/Sustainability/Reports
6. Environmental, Social and Governance
As set out in the HSS 2022 ESG Impact & Annual Reports, HSS is looking to accelerate plans to maximise our Environment, Social and Governance (ESG) performance; for more detail please see our latest ESG Impact Report down load at https://www.hsshiregroup.com/Sustainability/ReportsEnvironment
HSS is committing to reduce our scope 1 and 2 emissions by 46.5 % and our scope 3 emissions by 27.5 % by 2030 from a 2019 base year. As part of this, HSS has set near term and net zero company-wide emission reductions in line with science-based targets initiative (SBTi), of which HSS is a member. HSS has responded to the SBTi’s urgent call for corporate climate action by committing to align with 1.5°C and net-zero through the Business Ambition for 1.5°C campaign. To achieve these ambitious goals, it is key that HSS partners with suppliers who share our ESG vision and understand they play an important part in helping us all achieve Net Zero Goals.
Social
HSS understands the importance of creating social value. To maximise the positive impact in the communities we serve it is important that we engage our complete supply chain. Therefore, we encourage and promote initiatives that support community involvement and development and track the collaborative positive impact these initiatives have.
Governance
HSS recognise that customers and investors are increasingly demanding more transparency on how companies are governed. This is especially the case when it comes to climate change, with a clear and scientifically supported consensus on the threat posed by a warming planet and a strong enthusiasm for social value in the business community. HSS has embedded oversight of climate-related risks at the highest level of our company. Responsibility for assessing and managing climate-related risks and opportunities lies with our Board, supported by the Executive Management Team and the Risk and Assurance Director. We encourage our suppliers to strive to develop a similar culture.
For more details on our governance please see our latest Annual report & ESG Impact Report down-load at https://www.hsshiregroup.com/Sustainability/Reports
Collaboration
HSS recognises that organisations are at different stages of their ESG journeys and is committed to a collaborative approach, working with its supply chain to share best practices and ideas to better serve customers and the planet.
7. Supplier Performance & Continuous Improvement
HSS understands that in order to reach the ambitious goals to which we are aligned and that all stakeholders expect from us, it is imperative that we track the performance of our value chain, most importantly our suppliers.In addition to the expectations laid out in our Supplier Terms and Conditions, we track our supply chain’s performance by:
- Performance reviews by HSS Supply Chain/Procurement Managers
- Targeted onsite audits by trained Auditors
- Mandatory annual online ESG Audit
HSS understands that to enable continuous improvement and efficiency from our supply chain, two-way dialogue is crucial. Therefore, it is always our aim to conduct this dialogue in an open and transparent manner with our stakeholders wherever possible.
8. Sanctions
Sanctions are restrictive measures that can be put in place to fulfil a range of purposes. In the UK, these include complying with UN and other international obligations, supporting foreign policy and national security objectives, as well as maintaining international peace and security, and preventing terrorism.The UK implements a range of sanctions regimes through regulations made under the Sanctions and Anti-Money Laundering Act 2018 (the Sanctions Act). The Sanctions Act provides the main legal basis for the UK to impose, update and lift sanctions. Some sanctions measures apply through other legislation, such as the Immigration Act 1971 and the Export Control Order 2008. The Russia (Sanctions) (EU Exit) Regulations 2019 impose financial, trade, transport and immigration sanctions against the Russian state and certain associates specifically as a result of Russia’s actions against Ukraine.
A failure to comply with applicable trade sanctions which could result in civil or criminal liabilities, individual or corporate fines, director disqualification and reputational damage.
HSS carries out risk assessments on a regular basis to identify focus areas in its business and to ensure compliance, principally procurement and supply chains. Monitoring is undertaken via onboarding processes for new suppliers and sporadic checks of existing suppliers to ensure that they have their own processes in place to a satisfactory standard. As is the case for anti-modern slavery compliance set out above, failure by suppliers to comply with applicable laws (including sanctions laws and regulations) provides HSS with a termination right.