Overview

Purpose

It is important to us at Paramount Medical Solutions that those we deal with throughout our supply chain maintain the same high standards of compliance as we do. This includes in the key areas of employment law, immigration rules and combatting modern slavery.

This Code sets out the standards we are committed to, and which we ask all our supply chain partners to adhere to as a minimum.

Who this Code applies to:

• Us - all of our employees, workers and contractors
• Our suppliers, sub-contractors and partners
• Your supply chain - we ask that you make sure anyone you work with or sub-contract is given a copy of this Code and commits to the minimum standards set out here

1.  Human Rights & Modern Slavery

Supply Chain Partners Must:

1. Ensure that none of you, your officers or employees, have been convicted of any offence involving slavery and human trafficking, nor (so far as you are aware) been investigated for such offences 
2. Comply with all legal obligations of applicable anti-slavery and human trafficking laws, including the Modern Slavery Act 2015
3. Have in place an Anti-slavery Policy, or if you do not have one, comply with ours. You will notify us if you become aware, or suspect any breach of the Anti-slavery Policy
4. Include in your contracts with your subcontractors and suppliers robust and meaningful anti-slavery and human trafficking provisions
5. Make reasonable enquiries into your subcontractors and suppliers to satisfy yourself that there are no grounds for suspicion of any offence involving slavery and human trafficking
6. Notify us as soon as you become aware of any actual or suspected slavery or human trafficking in a supply chain which has a connection with your agreement with us
7. Comply with the other principles in this Code which all contribute to combatting modern slavery

Guidance:

• Modern slavery in supply chains has been highlighted in recent years through introduction of the Modern Slavery Act 2015. It is estimated that there are in excess of 40 million people living in slavery worldwide. A great proportion of these people work in the supply chains of large multinational companies.
• Modern slavery is an offence which carries heavy criminal sanctions. We take our duties in this area seriously.
• We will not work with parties who breach anti-slavery or human trafficking laws and require our supply chain partners to take steps to ensure that their suppliers are not involved in such activity either.
• Further information about modern slavery, including details on what to do if you suspect someone is a victim of modern slavery, can be found here: https://www.gov.uk/government/collections/modern-slavery

2. Worker Rights

Any workers or employees engaged by supply chain partners must:

1. Be paid at least National/Living Minimum Wage (NMW)
2. Be issued, from day one of their engagement/employment, a statement of terms and conditions which complies with the requirements of the Good Work Plan and Employment Rights Act 1996
3. Receive statutory holiday entitlement as a minimum and be paid for taking holiday at the correct rate of pay
4. Not be subject to any unlawful deductions from pay, for example in relation to PPE which reduces pay below NMW
5. Ensure that workers have access to effective resolution in the event of any grievances and are informed of their rights, where appropriate, to union/colleague companions to meetings
6. Have appropriate grievance and disciplinary procedures in place
7. Ensure that where any worker has received government grants related to COVID-19 (e.g. the Coronavirus Job Retention Scheme), the applicable government rules and guidance are followed

Guidance:

• Workers and employees have various minimum legal entitlements, including to minimum wage, holiday entitlement and pay, rest periods, sick pay and family related leave and pay.
• Where you engage or employ an individual as a worker or employee you must comply with employment laws. As an absolute minimum we expect you to issue workers and employees with a statement of terms and conditions, from day 1 of them working for you, which complies with the requirements of the Good Work Plan and Employment Rights Act 1996. Further information is available from Acas, as follows:
• Template example written terms: https://www.acas.org.uk/templates-for-written-terms-of-employment
• Advice about employment contracts:
  https://www.acas.org.uk/employment-contracts
• There are minimum procedures which must be followed in the event of any grievance or disciplinary matter. For example, employees have the right to be accompanied to certain meetings. Further information can be found here:
  https://www.acas.org.uk/acas-code-of-practice-on-disciplinary-and-grievance-procedures

3.  Right to Work in the UK

All businesses are required to support the aims of the Home Office in tackling illegal working. Supply chain partners must therefore:

1. Ensure that suitable right to work checks are carried out in relation to workers, employees or self-employed individuals
2. Keep appropriate records of right to work checks

Guidance:

• It is imperative that throughout our supply chain all individuals have the right to work in the UK. We expect right to work checks to be carried out on all individuals working in the chain, regardless of employment status.
• You must carry out right to work checks for anyone directly engaged by you, whether as a worker, employee or independent contractor.
• You must ensure that anyone you sub-contract with commits to the Code and in particular to carrying out right to work checks, and ensuring they pass this commitment down the chain to ensure that this duty passes down the entire supply chain so that every individual working in it has had their documents checked.
• Right to work checks must be conducted using the following Home Office checklist: 
  https://assets.publishing.service.gov.uk/government/uploads/system/uplo ads/attachment_data/file/774286/Right_to_Work_Checklist.pdf
• Further guidance about conducting right to work checks is available from the Home Office here: 
  https://assets.publishing.service.gov.uk/government/uploads/system/uploa ds/attachment_data/file/946589/An_employer_s_guide_to_right_to_work_ch ecks.pdf

4. Reporting Concerns:

Supply Chain Partners Must:

1. Have in place a whistleblowing policy that seeks to encourage staff to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate, that their confidentiality will be respected and to reassure staff that they should be able to raise genuine concerns without fear of reprisals, even if they turn out to be mistaken
2. Provide staff with guidance as to how to raise concerns
3. Ensure that whistle-blowers do not suffer any detrimental treatment as a result of raising a concern

Guidance:

• Many of the protections against the other matters covered in the Code are in part dependent on individuals being able to raise legitimate concerns, free from the fear of recrimination. We expect our supply chain partners to have in place policies that encourage staff to report any practice or conduct which gives them cause for concern.
• In order to reassure any reporting member of staff that raising a legitimate concern will not negatively affect them, they should be able to do so confidentially.
• Creating a culture where it is safe to raise concerns requires a strict zero-tolerance policy on recriminations or detrimental treatment against any “whistle-blowers”.
• Further information about whistleblowing, including what to include in a policy, can be found here:  https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attac hment_data/file/415175/bis-15-200-whistleblowing-guidance-for-employers-and-code-of-practice.pdf

5. Equality

Supply chain partners must:

1. Ensure that in their dealings with all and any of their workers, employees or agents, customers, other suppliers and any workers, employees or other representatives of Paramount Medical or other party involved in the supply chain, they do not commit acts of bullying, harassment, victimisation or unlawful discrimination.
2. Ensure a working environment and working practices free from bullying, harassment, victimisation and unlawful discrimination, promoting dignity and respect for all.

Guidance:

• The Equality Act 2010 provides individuals with protection from bullying, harassment and unlawful discrimination relating to the following protected characteristics:
• age
• disability
• gender reassignment
• marriage or civil partnership
• pregnancy or maternity
• race (including colour, nationality, ethnic and national origin)
• religion or belief
• sex
• sexual orientation
• Employees, workers, applicants, contract workers, agency workers, partners, LLP members, office holders are all protected from unlawful discrimination. The Equality Act also protects individuals/the public against discrimination in the provision of goods, facilities and services.
• You should ensure that every individual involved in delivering your services, including sub-contractors, are aware of the minimum standards of behaviour required of them in relation to equality.
• Having an up to date policy in place can help you to promote equality. Additional measures include providing regular training to staff and ensuring staff know how to raise a complaint.
• Further guidance, including an example of an equality policy, is available from Acas here:
  https://www.acas.org.uk/equality-policy-template

6.  Safety 

Safety of workers and contractors is vital. We expect supply chain partners to be responsible for their own safety and the safety of those around them. Supply chain partners must:

1. Operate in a COVID-19 secure and compliant manner, consistent with the latest Government guidance on helping to minimise the risk of spreading COVID-19
2. Work in a safety compliant manner, ensuring individuals have appropriate PPE, are aware of correct safety procedures, handling of equipment, material and tools and the procedure for reporting accidents
3. Ensure that, where required, individuals hold the certification or have received the training required to operate the machinery, tool, material or equipment in question.

Guidance:

• Supply chain partners should ensure they are familiar with the latest government guidance on working in a COVID secure manner, in particular any industry specific guidance which may be available from time to time. Further information can be found here: https://www.gov.uk/guidance/working-safely-during-coronavirus-covid-19
• Health and Safety is the responsibility of every individual and organisation involved in a supply chain. You must ensure you comply with any specific health and safety procedures notified to you in relation to a particular location.
• Where applicable, you should also, in relation to your own workers/contractors, ensure they are equipped with appropriate PPE, that you carry out risk assessments, and have in place a procedure for reporting accidents. Further information about Health and safety requirements determined by what your specific role in the supply chain is can be found here: 
  https://www.hse.gov.uk/guidance/industries.htm

7.  Financial Honesty

Supply chain parterns must:

1. Act with honesty and integrity at all times in their dealings with us and must not misuse property or materials or defraud, deceive or facilitate tax evasion
2. Not receive or give bribes or participate in other financial corruption
3. Ensure that where any government grants related to COVID-19 (e.g. the Coronavirus Job Retention Scheme) have been claimed, the applicable government rules and guidance are followed and the correct amounts claimed and paid
4. Update us if anything about their tax status changes, for example if you become or cease to be VAT registered
5. Have in place policies and procedures to prevent the facilitation of tax evasion by employees or any third parties
6. Notify us as soon as you become aware of any actual or suspected activity from within a supply chain which has a connection with your agreement with us that would be an offence under bribery, money laundering or tax evasion laws.

Guidance:

• It is illegal to offer, promise, give, request, agree, receive or accept bribes. You must never offer to give or receive a bribe for any reason, including to facilitate certain outcomes or to encourage improper practices. Further information about anti-bribery is available on the following government website page:
  https://www.gov.uk/anti-bribery-policy
• Government and HMRC guidance must always be followed when it comes to claiming grants in relation to the COVID-19 pandemic. Further information about support for businesses, linking to applicable guidance, is available here:
  https://www.gov.uk/coronavirus/business-support
• All businesses are under a legal obligation to prevent the facilitation of tax evasion by associated persons, such as your employees and suppliers. In addition to the criminality of tax evasion in itself, it is also a potential indicator of wider criminal activity. Anyone guilty of such an offence may be subject to an unlimited fine. You must ensure that your employees and subcontractors are not exposing you, or us, to potential prosecution. For further information about the failure to prevent tax evasion see here:
  https://www.gov.uk/government/publications/corporate-offences-for-failing-to-prevent-criminal-facilitation-of-tax-evasion

8.  Data Security:

Supply chain partners and any workers or employees engaged by supply chain partners must:

1. Comply with, and not do anything to put us in breach of, any data protection laws
2. Notify us if you are processing any personal data connected to your agreement with us which we haven’t been made previously aware of
3. Have in place and comply with a privacy policy that meets all relevant legal requirements
4. Notify us as soon as reasonably possible in the event of any data breach in relation to your agreement with us

Guidance:

• We are all bound by legal obligations concerning the security and privacy of the personal information of individuals. Particularly in the industry we operate in, we could be handling sensitive personal data. We expect our supply chain partners to comply with all relevant data protection laws and to make us aware of any problems that might arise in this area - in particular, any data breaches.
• If, in the course of our working together with our supply chain partners personal data is exchanged we would cover this in the relevant contract. If circumstances change such that you will come into possession of, or gain access to personal data in a way that had not been anticipated at the time of your appointment, we require you to bring this to our attention so that we can ensure appropriate suitable arrangements are put in place.
• Further information about privacy notices including and example template can be found on the Information Commissioner’s Office website here:
  https://ico.org.uk/for-organisations/make-your-own-privacy-notice/

9.  SUPPORTING SKILLS & DEVELOPMENT

Supply chain partners must

1. Consider whether they can engage apprentices, taking into account the size and resources of their business
2. Monitor their use of apprentices and developing and maintaining skills and be able to provide details of these on request
3. Pay any apprentices at the correct rate and ensure they provide the appropriate training and support to them
4. Provide appropriate training to all staff and ensure, where relevant, details of training provided during employment is set out in their contract with you
5. Suggest an appropriate number of apprenticeships to be created through the performance of our contract with you

Guidance:

• We encourage, and are committed to supporting where we can, the use of apprenticeships and the development of skills in general
• Workers and employees contracts of employment must set out details of any training to be provided during the course of their employment. For further information see section 2 of this Code
• There are is funding available to employers for young workers and skills development. For more information please visit:
  https://www.gov.uk/topic/further-education-skills/apprenticeships https://www.gov.uk/guidance/apply-for-a-kickstart-scheme-grant http://www.govgrantshub.uk/support/government-funded-training/

10.  SUSTAINABLE & ETHICAL PROCUREMENT

We care about the environment and the impact our business may have on it. We expect our supply chain to commit to the same high standards we do.

Supply chain partners must maintain the standards of, or equivalent to, ISO20400.

Guidance

• Sustainable Procurement is 'a process whereby organisations meet their needs for goods, services, works and utilities in a way that achieves value for money on a whole life basis in terms of generating benefits not only to the organisation, but also to society and the economy, whilst minimising damage to the environment‘
• We expect our supply chain partners to consider ways in which they can minimise any negative impact of their work on the environment, and implement these measures where possible. This might include:
• Using materials certified as coming from sustainable sources
• Adopting practices to ensure waste is minimised, for example by only sourcing the amount of material required
• Conscientious use of water, gas and electricity
• Information about ISO20400 is available here: 
  https://www.iso.org/files/live/sites/isoorg/files/store/en/ISO%2020400_Sustainable_procur.pdf

Monitoring and Compliance:

We are dedicated to ensuring the standards set out in this Code are maintained at all times throughout our supply chain. We may therefore carry out audit checks throughout the course of our relationship with you. We will seek to make that process as simple as possible, but it will include you providing us with copies of documents to evidence compliance with the various principles set out in the Code.

Your appointment is conditional upon your compliance with this Code. Whilst we would always seek to give you a reasonable opportunity to remedy, failure to abide by this Code (which includes failure to properly return a signed copy as detailed below) may result in us withholding any amounts otherwise due under an invoice until such time as the failure is rectified.

To confirm your understanding of, and agreement to abide by, this Code please sign, date and return a copy:

Signature:

Your Name:

Company Name:

Date: