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Supplier Code of Conduct

SUPPLIER CODE OF CONDUCT

 

ABOUT THIS CODE Corporate integrity, responsible sourcing, environmental sustainability, and the safety and wellbeing of workers are of paramount importance to our group of companies - Optimum Patient Care Global Limited, Optimum Patient Care Limited and Observational & Pragmatic Research International Limited (‘the Company or Companies’). These core principles of advancing social and environmental responsibilities are reflected in this Supplier Code of Conduct (Code).,

 

DEFINITIONS AND SCOPE In this Code:

  • Supplier means a body corporate, partnership or individual that provides goods or services to the Company.

  • 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 form part of the Company's supply chain.

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WHO MUST COMPLY WITH THIS CODE? Any Supplier providing services to any of the Companies shall comply with the Code and ensure that its Workers and Representatives are made aware of and comply with it.

 

SUPPLIER'S COMMITMENT The Supplier agrees that:

  • It will comply with the requirements in this Code.

  • It has appropriate systems in place to ensure continuous compliance and to demonstrate such compliance.

  • Any breach of this Code may result in the Company  terminating its relationship with the Supplier.

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2. Updating this Code

The Companies may modify this Code from time to time, providing the Supplier with at least 30 days' written notice (including by email).

 

3. Workforce Requirements

Suppliers must uphold the human rights of all Workers and ensure they are treated with dignity and respect at all times.

Suppliers must:

  • Prohibit Forced Labour: Not engage in any form of slavery, human trafficking, child labour, forced, bonded, or prison labour.

  • Uphold Human Rights: Respect international human rights standards, including the International Bill of Human Rights and the ILO Fundamental Conventions.

  • Ensure Equal Opportunity: Prohibit discrimination based on race, gender, sexual orientation, religion, age, disability, or any other protected attribute.

  • Provide a Safe Workplace: Comply with all applicable workplace health and safety laws and ensure appropriate protective measures are in place.

  • Pay Fair Wages: Provide remuneration that meets or exceeds the living wage or legal minimum wage in the Supplier’s jurisdiction.

  • Prohibit Harassment: Maintain a zero-tolerance policy for harassment, bullying, or abuse in any form.

 

4. Data Protection and Information Security

Suppliers must uphold the privacy and data protection rights of all individuals and ensure that personal and Company information is handled securely and responsibly at all times.

 

Suppliers must:

  • Comply with Data Protection Laws: Adhere to all applicable data privacy laws, including the UK GDPR, where applicable.

  • Maintain Data Security: Implement appropriate technical and organisational measures to ensure the integrity, confidentiality, and availability of any Company data they access or process.

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5. Artificial Intelligence (AI)

Company acknowledges the importance of the developing role of AI in streamlining and providing services

 

Suppliers must:

  • Disclose AI Usage: Inform the Company in advance if AI will be used in service delivery.

  • Follow Responsible AI Practices: Align AI use with legal standards and the Company’s policies.

  • Ensure Transparency and Accountability: Use AI in ways that are explainable, human-centric, and auditable, with mechanisms for appeal or contesting outcomes.

  • Restrict AI Training: Do not use Company data to train AI systems without prior written consent.

  • Ensure Third-Party Compliance: Ensure any third-party AI providers used also comply with these requirements.

 

6. Environmental Responsibility

Suppliers must conduct their operations in an environmentally responsible way and actively commit to minimising their environmental impact.

 

Suppliers must:

  • Comply with Environmental Laws: Meet all applicable environmental legislation and international agreements regarding emissions, hazardous materials, and waste management.

  • Implement an Environmental Management System that addresses:

  • Environmental impact assessments

  • Pollution and waste reduction

  • Efficient use of resources

  • Worker awareness and training

 

7. Bribery and Corruption

Suppliers shall comply with anti-bribery and corruption laws, including the UK Bribery Act 2010 and Economic Crime and Corporate Transparency Act 2023. This includes:

  • Prohibition of bribery, kickbacks, or facilitation payments

  • Prohibition of tax evasion, money laundering and fraudulent practices

 

8. Unfair Business Practices

Suppliers must comply with competition laws, including the Competition Act 1998, and must not engage in collusion or anti-competitive practices.

 

9. Procuring and Managing Representatives

Suppliers must ensure Representatives and Workers comply with the standards set forth in this Code of Conduct. Suppliers maintain responsibility to Company for their conduct of their Workers and/or Representatives.

 

10. Training

Suppliers must provide adequate training to Workers and Representatives to ensure compliance with this Code.

 

11. Certifying Compliance and Audit

Suppliers must certify compliance upon request and allow the Company or its designee to audit compliance with this Code.

 

12. Self-monitoring and Reporting Breaches

Suppliers must monitor their own compliance and report any breaches of this Code to the Company without delay. If a Supplier cannot comply with any terms of this code of conduct, they must inform the Company as soon as possible, and in any event prior to the provision of services.

 

13. Breach, Remediation and Termination

Any breach by the Supplier of this Code may result in remediation measures or termination of the relationship. The Company reserves the right to determine the appropriate response to breaches.

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