OSB India Private Limited (OSBI, a subsidiary of OSB GROUP PLC “the Group”) is committed to operating its business in an ethical and honest way. This Vendor Code of Conduct (the Code) reflects the social, environmental and economic steps that it expects those who provide goods and services within India to OSBI to abide by.
A separate code exists and applies to those providing goods and services to OSB GROUP PLC and its subsidiaries within the UK. Details of which can be found at https://www.osb.co.uk/sustainability/vendor-code-of-conduct-and-ethics/
This Code applies to:
- Third party suppliers; and
- Any sub-contractors and business partners of third party suppliers.
who provide good and services to OSBI, also referred to as “Vendor”.
In the case of a Vendor who has already entered into a contract with OSBI to supply goods and services to OSBI, he/she/it agrees to make this Code as an integral part of such contract.
In the event of any conflict between clauses of this Code and the Contract between OSBI and the Vendor, the clauses of this Code shall prevail over the Contract.
OSBI expects vendors to request and enforce the same standards of their own employees, agency staff, contractors, sub-contractors, suppliers and business partners. Suppliers are expected to be able to demonstrate their compliance with this Code by way of relevant processes, codes, policies and statements. OSBI reserves its right to audit a third party supplier’s including their sub-contractors’ and business partners’ adherence to this Code. However, non-commissioning of such an audit by OSBI cannot be held as an excuse for non-compliance to “the Code”.
Where there are issues within the supply chain, OSBI may work with the supplier to embed an improvement plan. Failing that, steps may be taken to adjust the supply chain accordingly including the terminations of contractual agreements where relevant.
Values
OSBI’s culture when engaging with third party suppliers is driven by the Group’s values which it expects all employees to adhere to:
We collaborate to create a culture in which we all share goals and values. We aim to build trust, respect and openness across the Company.
We take ownership of what needs to be done as well as our personal and professional development, helping to achieve the collective goals of the business.
We set the bar high for ourselves and our customers. They are the ones who know when we are going above and beyond and remember the promises we keep.
We treat all others fairly and communicate in a way that respects an inclusive and diverse culture, listening to all voices and ensuring opinions are offered and heard.
We act with conscience and take social, environmental and ethical factors into consideration when making decisions.
Diversity and Inclusion
OSBI believes that a diverse and inclusive workforce brings benefits to the business as people work better when they can be themselves and feel that they belong. OSBI is committed to providing an inclusive working environment that is free from discrimination, harassment or victimisation and ensuring that no one is treated less favourably due to any protected characteristic according to but not limited to the Maternity Benefit Act, 1961, the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, the Equal Remuneration Act, 1976, the Rights of Persons with Disabilities Act, 2016 and the Transgender Persons (Protection of Rights) Act, 2019
OSBI expects all suppliers to:
- encourage and abide by principles of diversity and inclusion in all aspects of their operational activities including but not limited to pre-employment, recruitment and promotion practices, continuation of employment, equal remuneration for same work or work of a similar nature, and relevant diversity training for all employees;
- have operational processes in place to ensure reasonable adjustments are made for those who require them under disability discrimination laws including the Rights of Persons with Disabilities Act, 2016;
- remain cognisant of socio-economic conditions in the local communities including safeguarding against the displacement of indigenous people; and
- Foster a culture of inclusiveness at all stages of the employment/engagement relationship including but not limited to pre-employment, recruitment and promotion practices.
Whistleblowing
OSBI is committed to the highest standards of openness, probity and accountability. All of OSBI’s employees and stakeholders are encouraged to voice any concern about wrongdoing or suspected wrongdoing in the workplace. OSBI’s whistleblowing arrangements endeavour to manage whistleblowing cases fairly, consistently and in a way which protects individual whistleblowers. It is not necessary for an employee to have worked for OSBI for a certain amount of time before raising a concern.
Any person, including vendors and third-party suppliers and business partners, their contractors, sub-contractors and their respective employees who have been engaged to work for or with OSBI, concerned about unethical working practices or a breach of this Code may report their concerns on a confidential basis by email to whistleblowing@osb.co.uk. Individuals who raise concerns are encouraged to provide as much detail as possible, so that the issues that they raise can be investigated. Employees including vendors and third-party suppliers and business partners, their contractors, sub-contractors and their respective employees who have been engaged to work for or with OSBI can raise their concerns about wrongdoing or malpractice within OSBI, without fear of victimisation, subsequent discrimination or dismissal. We recognise that whistleblowers may be worried about possible repercussions from raising a concern and will only be prepared to raise their concerns on an anonymous basis. We commit to investigate anonymous allegations as thoroughly as possible taking remedial action where necessary.
Suppliers are widely encouraged to ensure their employees and sub-contractors feel supported to contact the whistleblowing hotline. Suppliers should make employees aware of how they can report issues within the supply chain.
As OSBI is a regulated entity, all individuals and management within the supply chain are reminded that they are able to disclose a reportable concern either simultaneously or consecutively to the Financial Conduct Authority (FCA) and/or Prudential Regulation Authority (PRA). Individuals are encouraged to raise any concerns with OSBI in the first instance but this does not preclude them from making a disclosure directly to the
FCA and/or PRA using the details set out below.
Financial Conduct Authority
Email: whistle@fca.org.uk
Tel: 0207 066 9200
Address: Intelligence Department (Ref PIDA) Financial Conduct Authority, 12 Endeavour Square, London, E20 1JN
Prudential Regulation Authority
Email: whistleblowing@bankofengland.co.uk
Tel: 0203 461 8703
Address: IAWB team, Legal Directorate, Bank of England, Threadneedle Street, London, EC2R 8AH
Human Rights
OSBI expects each member of its workforce and other stakeholders to be treated with dignity and respect. OSBI publishes the Group’s annual Modern Slavery Statement on its website in accordance with the Modern Slavery Act 2015. OSBI endorses the UN Declaration of Human Rights and supports the UN Guiding Principles of Business and Human Rights. OSBI adheres to the International Labour Organisation Fundamental Conventions. OSBI does not tolerate any form of forced or child labour and strictly adheres to laws on the subject matter including but not limited to the Bonded Labour System (Abolition) Act, 1976 and the Child Labour (Abolition and Regulation) Act, 1986, and as such expects third party suppliers to adhere to the following principles:
- Workers shall not be subject to forced, prison, bonded, indentured, slave, trafficked or compulsory labour in any form. This includes any form of child labour.
- Workers shall be treated in accordance with all applicable national and local laws and regulations at all times. This extends to local or national government policies, orders, notifications, circulars, advisories and guidelines, including any relating to a pandemic outbreak which may include social distancing, vaccination, testing, regular cleaning and sanitization of the workplace, and the payment of statutory sick pay to workers who are having to isolate.
- Workers must have the right to terminate their employment freely, as appropriate, following a reasonable period of notice in accordance with applicable laws and collective agreements and without the imposition of any improper penalties.
- Workers must be paid at least the minimum wages including overtime wages prescribed under applicable laws and such payment should be done on time, without any unauthorized deduction.
- Social security contributions are made correctly and timely with respect to the workers and all welfare benefits are provided in terms of applicable laws. vi. Workers shall not have their identity or travel permits, passports or other official documents or any other valuable items confiscated or withheld as a condition of employment.
- Fees or costs associated with the recruitment of workers (such as fees related to work visas, travel costs and document processing costs) should not be charged to workers; and workers must not be required to repay debt through labour. Workers are still entitled to receive wages for completed work regardless of any order cancellations during and after a pandemic outbreak.
- Workers shall not be under the minimum age requirement in accordance with applicable national laws.
- Workers shall not be discriminated against or harassed on the basis of any characteristic contained within the applicable laws including age, gender, disability, gender reassignment, marital status, race, religion or belief, caste, sex or sexual orientation.
- Workers shall not be subject to harsh or inhumane treatment including, but not limited to, physical punishment, physical, psychological or sexual violence or coercion, verbal abuse, harassment, intimidation or discrimination.
- Workers shall be able to access and be free to file grievances to their employers about the employer's treatment of them. Workers shall not suffer detriment, retaliation, or victimisation for having raised a grievance. New and adapted procedures should be implemented if necessary.
- Where it is necessary to recruit workers who are engaged via a third party or where workers are sourced to be employed directly, only reputable employment agencies shall be engaged. Rigorous checks during the recruitment process should take place to ensure that workers are not being exploited in a period of high demand.
Anti-Bribery and Corruption
OSBI is committed to acting professionally, fairly and with integrity in all its business dealings and relationships; and expects the same of its suppliers.
OSBI takes its responsibility to act in accordance with the law and to prevent bribery and corruption extremely seriously and promotes zero tolerance to any form of bribery, corruption or irregularity which would include directly or indirectly authorizing, offering, promising, paying, giving, soliciting or accepting money or anything else of value in order to wrongfully influence the recipient (including but not limited to any family member, relative, friend, colleague, acquaintance or close business associate of such recipient), induce a person to misuse a position of authority or trust, or obtain an advantage or secure any improper interest and can take many forms, including but not limited to cash, cash equivalents, gifts, entertainment, hospitality, employment opportunities, consultancy fees/commissions, sponsorships, negotiable instruments and donations. OSBI expects suppliers to take its responsibilities equally seriously and ensure that they adopt a zero tolerance approach to bribery and corruption within its workforce and relationships with customers and suppliers. Therefore, suppliers must ensure that they have policies in place to stop all types of bribery and corruption and that their employees, contractors and suppliers abide by local laws and legislations including but not limited to any sanctions in place.
Environmental
OSBI is committed to operating sustainably and to continually reducing its environmental impact by not only promoting awareness of environmental issues amongst its employees, but also by adhering to its plan to become a greener organisation. OSBI is committed to meeting all relevant legal and regulatory environmental obligations. As such, OSBI expects all suppliers to recognise that everyone is responsible for protecting the environment and as such should strive to reduce energy and finite material consumption by using renewable or recyclable materials, wherever possible.
OSBI expects all suppliers to integrate environmental considerations including the use of paper, energy and transportation into their operational processes. All suppliers are expected to continually monitor and improve their environmental performance by ensuring that their policies and processes are appropriate for the sector within which they operate.
