AltoVita Supplier Code of Conduct

It is AltoVita’s policy to: 

• Conduct our business with honesty, transparency and integrity;
• Comply with all laws and regulations that apply to our business in all territories in which we operate, including, without limitation, employment, health and safety and environmental laws;
• Promote ethical conduct and principles to govern our suppliers’ activity; and
• Take a zero-tolerance approach to bribery and corruption and adhere to all sanctions restrictions. 
  
  
  These core principles are reflected in this Supplier Code of Conduct (the Code), which establishes the minimum standards that must be met by any entity that supplies products or services to AltoVita.
  
  

Definitions and Scope

In this Code:

Supplier means a company, partnership or individual that provides goods or services to AltoVita.

Worker means any individual whom the Supplier employs, hires or engages, or otherwise uses to conduct its business.

Representative means the Supplier's suppliers, vendors, agents, and subcontractors who are involved in AltoVita's supply chain.

Who must comply with this code?

The Supplier will at all times comply with the Code and will ensure that its workers are aware of this Code and comply with it.

1. Compliance with laws and regulations and priority of standards

In carrying out its agreement(s) with AltoVita, the Supplier will, in addition to complying with the standards set out in this Code, comply with all applicable UK laws and regulations (and, if applicable, the laws and regulations of any other jurisdiction where it or its Representatives operate) including but not limited to the laws and regulations relating to issues addressed in this Code.

1.2 Competing standards will be addressed as follows:

(a) If there is a conflict between any applicable laws or regulations, the provisions of an agreement with AltoVita and the provisions of this Code, the Supplier will meet the most stringent standard.

(b) If there is a conflict between the provisions of an agreement with AltoVita and the provisions of this Code, the Supplier will meet the more stringent standard.  

 
2. Updating this Code

AltoVita has the right to modify this Code from time to time by giving the Supplier at least 30 days' notice in writing (writing includes email).  

3. Workforce issues

3.1 Slavery, human trafficking and child labour. The Supplier will comply with all applicable anti-slavery and human trafficking laws, statutes, regulations from time to time in force including but not limited to the Modern Slavery Act 2015 in any part of its supply chain. This includes, but is not limited to, not supporting or engaging or requiring any forced labour, the use of child labour, bonded labour, indentured labour and prison labour.

3.2 Human rights. The Supplier will comply with all internationally recognised human rights understood, at a minimum, as those expressed in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organisation's Declaration on Fundamental Principles and Rights at Work from time to time in force in any part of its supply chain.

3.3 Equal opportunities. AltoVita is an equal opportunities employer and Supplier will not discriminate in hiring, compensation, training, advancement or promotion, termination, retirement or any employment practice based on race, caste, colour, national origin, gender, gender identity, sexual orientation, religion, age, marital or pregnancy status, disability, union membership or political affiliation or any other characteristic other than the worker's ability to perform the job, subject to any accommodations required or permitted by law.

3.5 Working environment. The Supplier will provide a safe, healthy, and sanitary working environment and comply with UK health and safety laws and any other relevant laws where it operates. This includes, but is not limited to, implementing general and relevant industry-specific procedures and safeguards to prevent workplace hazards and work-related accidents and injuries. Where such hazards cannot be adequately prevented or controlled, the Supplier will provide workers with appropriate personal protective equipment to protect against hazards typically encountered in that scope of work.

3.6 Wages and remuneration. The Supplier must compensate all workers with wages, including overtime premiums, and benefits that at a minimum meet the higher of:

(a)   the minimum wage and benefits established by applicable law;

(b)   collective agreements;

(c)   industry standards; and

(d)   an amount sufficient to cover basic living requirements.

4. Data protection and information security

4.1 The Supplier will comply with all data protection laws and requirements (including the UK GDPR) when processing any personal data on AltoVita’s behalf.

4.2 The Supplier will have in place appropriate measures to:

(a) protect the integrity and confidentiality of information (including information belonging to or supplied by AltoVita) held on its systems (which include physical and online or electronic systems); and

(b) ensure that there is no unauthorised access of the information by third parties, including its Representatives.

5. Environmental responsibility

5.1 The Supplier will ensure that:

(a) its operations comply with all applicable environmental laws, including laws and international treaties relating to (but not limited to) climate change, waste disposal, emissions, discharges and the handling of hazardous and toxic materials; and

(c)  it will only use packaging materials that comply with all applicable environmental laws and treaties. 

5.2 The Supplier will have in place a suitable environmental management system or roadmap for managing its environmental risks. As a minimum, the system should include and address the following:

(b) steps to continuously improve environmental performance, reduce pollution, emissions and waste; and

(d) raising awareness and training workers in environmental matters.

6. Anti-facilitation of Tax Evasion

6.1 At AltoVita we take a zero-tolerance approach to the facilitation of tax evasion, whether under UK law or the law of any foreign country. The Supplier will comply with all applicable laws, statutes and regulations in the jurisdictions in which it operates relating to the prevention of the facilitation of tax evasion and related offences (including but not limited to the Criminal Finances Act 2017). 

7. Bribery and corruption

7.1 The Supplier will comply with all applicable laws, statutes and regulations relating to the prevention of bribery and corruption (including but not limited to the Bribery Act 2010). To that end, the Supplier will not accept, offer, promise, pay, permit or authorise:

(a) bribes, facilitation payments, kickbacks or illegal political contributions;

(b) money, goods, services, entertainment, employment, contracts or other things of value, in order to obtain or retain improper advantage; or

(c) any other unlawful or improper payments or benefits.

8. Sanctions

8.1 AltoVita is committed to complying with, and to conducting all its business in the spirit of, all sanctions laws and regulations. 

8.2 The Supplier will comply with all sanction laws and regulations applicable to its business in all jurisdictions in which it operates, and will have appropriate policies and procedures in place to identify and mitigate sanction risks in its operations which are proportionate to the level of risk to its specific location, operations and business.

9. Training

9.1 The Supplier will implement a system of training for its workers to ensure that they are aware of the requirements of this Code to the extent that comprehensive training is not already in place for its workers in respect of each area covered by this Code.
 
9.2 The Supplier will keep a record of all such training offered and completed by its workers and will make a copy of such record available to AltoVita on request. 

10. Certifying compliance and audit

10.1 The Supplier will provide written confirmation to AltoVita at least once per year that:

(a)  it has appropriate systems in place to monitor its compliance with this Code; and

(b) it is able to comply with this Code for the duration of its relationship with AltoVita.

10.3 The Supplier will provide any additional third-party or self-certifications that are reasonably required to demonstrate compliance with all applicable laws and frameworks relevant to this Code within 30 days of a written request from AltoVita. 

10.4 AltoVita may conduct audits and inspections to verify the Supplier's compliance with this Code. AltoVita has no obligation to conduct such audits or inspections.

11. Self-monitoring and reporting breaches

11.1 The Supplier will monitor its compliance with the Code and will report any breaches (actual or suspected) of this Code as soon as possible to privacy@altovita.com.

11.2 Speaking up about unethical behaviour protects you as our Supplier, AltoVita, our clients and communities. If you ever have an ethical question or concern related to this Code, please do not hesitate to let us know.

11.3 You agree not to retaliate or take disciplinary action against any worker that has, in good faith, reported breaches of this Code or questionable behaviour, or who has sought advice regarding this Code.

11.4 By complying with this Code, you as our Supplier enable AltoVita to provide a consistently excellent standard of service for our clients and to uphold the highest standard of ethics and integrity across our business.

12. Breach, remediation and termination

12.1  Where AltoVita becomes aware of a breach of this Code by the Supplier or its workers, AltoVita may either:

(a) immediately terminate its business relationship with the Supplier (including any contracts); or

(b) require the Supplier to produce a remediation plan specifying the actions that the Supplier will take that will lead to compliance with the Code, and present it to AltoVita within 10 days of being requested to do so. If the Supplier fails to produce the remediation plan within this timeframe or fails to implement it within a reasonable time, AltoVita may immediately terminate its business relationship with the Supplier (including any contracts). 

12.2 Where AltoVita becomes aware that a Representative has been involved in an incident (or incidents) that would constitute a breach of any of the requirements under this Code, were they bound directly by it, AltoVita may either:

(a)  terminate its business relationship with the Supplier (including any contracts); or

(b) require the Supplier to remedy that incident (or incidents) with that Representative. If the Supplier is not able to remedy such an incident with that Representative within a reasonable time, AltoVita may immediately terminate its business relationship with the Supplier (including any contracts).