Supplier code of conduct

Suppliers will deliver safe and effective goods and services to an agreed high standard. This comprises the following aspects:

Audits and complaints

Quarterly Business Reviews, where performance of delivery and quality will be monitored and KPI around supplier complaint forms (SCF) will be discussed with targets for improvements documented. Open audit actions will also be addressed to determine progress and agree satisfactory timelines.

Quality Requirements

Suppliers shall adhere to quality standards to provide goods and services on a consistent basis that meets Oxford Biomedica’s and its customer’s needs. Suppliers shall take all necessary steps to correct all critical issues that may impact on delivery or performance. We will need to be informed promptly of any change notifications that may impact manufacturing or supply processes that will impact the specification of goods and services provided.

Security and Chain of Custody

Suppliers shall have robust security systems in place to support manufacture, storage, and delivery to our premises. In this way, integrity of each shipment is assured. Suppliers shall ensure that custom made products do not fall outside of the chain of custody allowing third party to discover any proprietary information.

Oxford Biomedica and its suppliers shall conduct their business ethically and act with integrity, which shall include:

Fair Competition

Suppliers shall conduct their business consistent with fair and vigorous competition and with all applicable anti-trust laws.

Anti-Bribery and Anti-Corruption

Suppliers must not engage in any form of bribery, corruption, extortion or embezzlement. Suppliers shall ensure they have adequate systems in place to prevent bribery and corruption and comply with applicable laws. Suppliers shall not offer to Oxford Biomedica employees any kind of gifts or personal benefit which could be perceived as a bribe.

Suppliers must not make payments in cash or cash equivalents (for example, gift cards or vouchers), and never give gifts or any political support (money or resources), on our behalf. In all cases, gifts or entertainment shall not be offered to improperly influence a business relationship and must not violate applicable laws or ethical standards. We do not support the making of a facilitation payment, unless there is a risk of threat to personal safety. Suppliers shall promptly report any requests for facilitation payments to Oxford Biomedica.

Animal Welfare

If no valid alternative is available, (which could compromise the quality or safety evaluation of the test), animal testing should be restricted to minimise the numbers required. Animals shall be treated humanely with pain and stress minimised. We expect that all suppliers will conduct their research and development activities to the highest ethical standards.

Data Privacy and Protection

Suppliers systems that contain Oxford Biomedica’s confidential information shall safeguard and make only proper use of confidential information to ensure that company, worker and patient privacy rights are protected. Suppliers shall comply with applicable privacy and data protection laws and ensure the protection, security and lawful and ethical use of personal data.

Conflicts of Interests

Suppliers shall take reasonable care to avoid and manage conflicts of interest. Suppliers are expected to notify all affected parties if an actual or potential conflict of interest arises. Any Oxford Biomedica personnel having a direct/indirect affiliation with any suppliers’ financial interests would be an example of such a conflict.

Suppliers shall protect the human rights of their employees and treat them with dignity and respect, which shall include the following:

Avoidance of child labour

Suppliers must not use child labour and must only use workers who are above the relevant country’s legal age for employment. Young workers, below the age of 18 shall only engage in non-hazardous work.

Wages, benefits and working hours

Suppliers must pay workers according to applicable wage laws, including minimum wages, overtime hours and mandated benefits. Suppliers should ensure working hours comply with all applicable laws. We expect that all suppliers shall provide their employees with competitive compensation and benefits and to support equal pay for work of equal value.

Freely Chosen Employment

Suppliers shall not use forced, trafficked or enslaved workers. No worker shall be prevented from moving employment due to physical constraint or any restriction on free movement, including any documentation/passports being withheld.

Freedom of Association

Suppliers shall encourage open communication with workers to resolve workplace and compensation issues.

In accordance with local laws, suppliers must allow employees the rights to associate freely, form and join labour unions. Suppliers shall not disadvantage or discriminate employees who act as workers’ representatives.

Diversity and inclusion

Equal treatment of all employees must be a fundamental principle of the supplier’s corporate policy. Typical discriminatory characteristics of an employee such as age, disability, ethnicity, family status, gender, gender expression, gender identity, genetic information, national origin, physical characteristics, political affiliation, pregnancy, religion, social origin, sexual orientation, union membership or any unlawful criterion under applicable law. Suppliers shall ensure that their employees are not harassed in any way.

Fair treatment

Suppliers shall provide a workplace free of harassment, harsh and inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers and no threat of any such treatment.

We expect that suppliers shall not unfairly terminate any employment contractor terminate any employment contract without clear evidence in relation to the working performance of an employee, as permitted by law.

Local Community

Suppliers shall promote responsibility for the communities they operate in. Suppliers should listen to the concerns of local residents and provide for healthy and safe living conditions. The support of local job creation, local sourcing, provision of education provision and infrastructure development is encouraged.

Suppliers shall provide a safe environment for their employees, customers, visitors, contractors, and others who may be affected by their activities. Suppliers shall ensure that:

• their operations comply with all applicable environmental laws, including laws and international treaties relating to (but not limited to) waste disposal, emissions, discharges and the handling of hazardous and toxic materials;
• the goods they manufacture (including the inputs and components that they incorporates into their goods) comply with all applicable environmental laws and treaties; and
• they will only use packaging materials that comply with all applicable environmental laws and treaties

Suppliers shall have in place a suitable environmental management system for managing environmental risks. As a minimum, the system should include and address the following:

• an assessment of the environmental impact of all historical, current and likely future operations;
• steps to continuously improve environmental performance, reduce pollution, emissions and waste;
• measures to reduce the use of all raw materials, energy and supplies; and
• raising awareness and training workers in environmental matters

Suppliers shall use effective management systems to facilitate compliance and continued improvements with all applicable laws, which shall include:

Business continuity

Suppliers are encouraged to implement appropriate business continuity plans for operations supporting Oxford Biomedica’s business.

Continual Improvement

Suppliers are expected to continually improve by setting performance objectives, executing implementation plans and taking necessary corrective actions for deficiencies identified by internal or external assessments, inspections, and management reviews.

Supplier Selection & Monitoring

Suppliers shall apply the principles outlined in this document when selecting their own partners and suppliers. Suppliers shall have or put in place systems to monitor their own supplier and subcontractor compliance.

Commitment and accountability

Suppliers shall demonstrate commitment to the concepts described in this document by allocating appropriate resources and identifying senior responsible personnel.

Legal and Other Requirements

Suppliers shall identify and comply with applicable laws (international, national and local). They shall also ensure their practices conform to accepted industry standards, by obtaining, maintaining all applicable permits, certificates, licenses and registrations.

Documentation

Suppliers shall maintain documentation necessary to demonstrate conformance with these principles and compliance with applicable regulations. These may be reviewed by Oxford Biomedica upon mutual consent.

Training and competency

Suppliers shall have a training program that achieves an appropriate level of knowledge, skills and abilities in management and workers, to address the expectations in these principles.

Transparency and Disclosure

Suppliers are encouraged to report externally about their social and environmental impact in line with the principles set forth in our Supplier Code of Conduct.