Supplier Code of Conduct

Introduction 

Ultimate Finance (“the Group”) is committed to ethical, sustainable, and socially responsible procurement and we expect the same high standards of our suppliers. We view our suppliers as our partners, and we care about the way they do business when providing the Group goods or services.

This Supplier Code of Conduct (“the Code”) describes the minimum expectations in the areas of: integrity, ethics and conduct; conflict of interest, gifts, benefits and hospitality; labour and human rights; working hours, wages and health and safety; and environmental management.

We expect you, as a supplier to the Company, to follow this Code, and to be committed to, and to demonstrate, the highest standard of ethical behaviour.

Suppliers to the Group, whether new or existing, are advised to review the Code and ensure that relevant areas of their business and supply chain meet these standards.

We expect our suppliers to communicate this Code to their employees, parent company, subsidiaries, and subcontractors. Likewise, we will communicate it to our employees.

Fundamental to this Code is an expectation that all our suppliers operate in full compliance with all laws, rules, and regulations.

If you do not understand anything in this Code, or are not sure how to apply it, please raise this with your contact at Ultimate Finance. We are willing to work with you to ensure that this Code is being followed.

Integrity, ethics, and conduct

The Group expects high standards of ethical conduct and compliance with all applicable laws. Suppliers are expected to be ethical in their business activities, including relationships, practices, sourcing and operations.

Business integrity

Suppliers are expected to comply with all anti-bribery, anti-corruption, anti-money laundering regulations and child labour, modern slavery, or human trafficking under the UK’s Modern Slavey Act 2015. Suppliers must not engage in, either directly or indirectly, fraudulent, corrupt, exploitative, or collusive activities.

Professional conduct

Suppliers are expected to conduct themselves in a manner that is fair and professional.    Treat others as you would like to be treated with dignity and respect, and act in an ethical and honest way.

Confidentiality

Suppliers must not improperly use any private, confidential, or commercially sensitive information in its possession relating to or in connection with its dealings with the Group. Suppliers must protect the information we provide to you against loss, damage, theft, inappropriate access, and misuse always, especially if it contains personal data.

Conflict of interest; gifts, benefits, and hospitality

The Group believes that all business activities should be undertaken with impartiality and any conflict of interest should be raised and managed.

Conflict of interest

Suppliers must declare to their contact any situation that raises an actual, potential, or perceived conflict of interest related to or in connection with its dealings with the Group and avoid financial, business or other relationships which may compromise the performance of their duties under their business arrangement with the Group.

Gifts, benefits, and hospitality

Genuine hospitality or other similar promotional business expenditure is unaffected by this policy, if it is small in scale and reasonable and proportionate to the business in question.  The Group maintains a register of gifts and reviews hospitality given to and by staff regularly.

You should never promise, offer, give, ask for, agree to receive, or accept any bribes, and ensure that none of your staff, or any parties working on your behalf, do so.

We have trained our staff to recognise and avoid the use of bribery by themselves and others and we would take firm action against any individual involved in bribery. The Group’s Anti-Bribery policy is available to all our staff and is reviewed and updated regularly.  We expect our suppliers to have   the same view and to undertake similar training.

Where there is any doubt as to whether a potential act connected to your work for us constitutes bribery, to the extent you are legally able to do so we expect you to consult with us without delay.

Labour and human rights

The Group believes that all workers in its supply chain deserve to be treated with dignity and respect. We are committed to following the principles for Equality, Diversity, and Inclusion, to respecting and valuing each other’s differences, promoting equality, diversity, and inclusion, and encouraging individuals to develop and maximise their true potential.

Suppliers are expected to provide a fair and ethical workplace, which upholds high standards of human rights and integrates appropriate labour and human rights policies and practices into its business.  Suppliers are expected to provide goods and services in a manner consistent with any applicable human rights obligations.

Anti-discrimination

Subject to applicable laws, suppliers are expected not to discriminate against any worker based on age, disability, ethnicity, gender, marital status, political affiliation, race, religion, sexual orientation, gender identity, union membership, or any other status protected by law, in hiring and other employment practices.

Anti-harassment

Suppliers are expected to commit to a workplace free from workplace bullying, harassment, victimisation and abuse. Suppliers are expected not to bully workers or threaten workers with, or subject them to, unlawful or inhumane treatment. This includes, but is not limited to, abuse and harassment which can be verbal, physical, sexual or psychological.

Working hours, wages and health and safety            

The Group expects that:

• all remuneration owed to your staff without delay, and in accordance with current applicable laws;
• the deduction of wages is not used as a disciplinary measure;
• all overtime is expected to be expected to be reasonable and paid at the rate and in accordance with the applicable laws; and
• suppliers to provide a healthy and safe work environment and integrate sound health and safety management practices into its business.

Modern Slavery

The Group takes a zero tolerance approach to modern slavery and maintains a current modern slavery statement which can be found on our website https://ultimatefinance.co.uk/modern-slavery-statement.

Our commitment ensuring our suppliers do not engage in modern slavery is demonstrated by the Group:

• checking supply chains to ensure the potential for slavery and human trafficking is significantly reduced;
• telling the companies we do business with that we are not prepared to accept any form of exploitation;
• reviewing and negotiating our supplier contracts to ensure that, where it is appropriate, the contract contains an anti-slavery clause. Any such wording, will be drafted to the effect that prohibits suppliers and their employees from engaging in slavery or human trafficking; and
• trying, where possible, to account for each step of our supply processes—we know who is providing goods and services to us.

Society and the Environment

The Group, in its Responsible Business Report https://ultimatefinance.co.uk/static/b87160b2aba086ab7a7250ae1473283c/Responsible-Business-Report-July-2024.pdf explains how it aims to minimise its environmental impact and be an advocate for sustainability.  We expect our suppliers to have a similar policy on reducing the impact of their business on the environment and promoting a positive impact on their local communities.