Procurement Policy & Supplier Code of Conduct

Procurement Policy

The Procurement Policy and Supplier Code of Conduct, provide s detail about McMenon Engineering Services Limited ethos, our aspirations for how our business operates and the expectations we have of our suppliers. It is integral to our business strategy and success that we have a positive impact when dealing with our clients, suppliers, employees, and wider society wherever we do business.

As such, the Procurement Policy describes the firm’s commitment to ensuring that all procurement activities carried out by the firm are conducted in an honest, competitive, fair and transparent manner, and that incumbent suppliers are appropriately managed on an ongoing basis. The firm employs a set of internal rules for those involved in procurement activity, to support this commitment.

McMenon Engineering Services Limited consider a variety issue when evaluating potential suppliers over and above service delivery and cost, including: risk management, statutory and regulatory compliance, corporate social responsibility, diversity, sustainability and environmental credentials, and innovation.

McMenon Engineering Services iscommittedtoworkingwithoursuppliersandthattheSupplierCodeofConductisadheredtobyallofthefirm’ssuppliersandthroughoutthesupplychain.

Health & Safety

Safety – of the public, employees, the environment, our clients and Suppliers – is utmost important to McMenon.As a condition of engagement as an McMenon Supplier, McMenon expects all suppliers to understand the health & safety risks of their activities and apply good health & safety management systems, training and practices in all they do. Suppliers are expected to work safely and in compliance with all applicable safety, health and environmental related laws, standards, &procedures.

Environment

McMenon is acutely aware of our responsibility to minimize our impact on the environment through the effective management of our business activities and client project work. Environment is a key focus area at McMenon and strives to embrace its values. McMenon is committed and shall demonstrate this through our actions, including conducting its business in full compliance with all applicable international environmental laws and regulations and operating in an environmentally sensitive manner consistent with our values. We expect all our Suppliers to work with us in minimising environmental impact use materials and processes which support sustainability of the environment through out their supply chain.

Anti-Bribery

McMenon supports international efforts to combat bribery and corruption. McMenon complies with the anti-briberyand anti-corruption laws of the many countries where we operate. We expect the same of our Suppliers. Supplier shall not engage in any form of bribery, corruption, extortion and embezzlement and shall have adequate procedures in place to prevent any such bribery or corruption in their supply chain or by others acting for them. Bribes or other means of obtaining undue or improper advantage are not to be offered or accepted. Behaviors or actions that may negatively influence, or appear to influence, supply management decisions shall be avoided.

It is understood that exchanging gifts and hospitality can be appropriate and customary in some circumstances. However, it must not be such as could or might appear to create any improper influence or obligation.

Suppliers must not provide any gift, meal or entertainment to McMenon personnel (or their family members) in any situation in which it might influence or appear to influence any decision in relation to the Supplier or create a sense of obligation or a perception or appearance of obligation. In other situations, Suppliers may provide modest gifts, meals or entertainment to McMenon personnel(or their family members) if these are: not cash or cash equivalent(e.g storecards, tokens or vouchers redeemable for cash value). Any gift, meal or entertainment should comply with the following:

  • It must be consistent with customary business practices and policies and should not appear extravagant or excessive or improper or frequent;
  • It should not violate any law or policy;
  • It can be supplier-company branded marketing or promotional items which are of minimal value; and
  • It can include normal meals or refreshments in the course of a business meeting or marketingevent

To avoid reputational harm or the appearance of impropriety, no gift, money, loan, entertainment, service or other item of value may be promised or provided to a government official, or the official’s friends or family members, in connection with work for McMenon. For purposes of this Supplier Code, “government official” includes any officer, employee, candidate, agent, representative, official or de facto official of any government, military, government-owned or affiliated company, political party, or any public international organization existing under any international treaty or treaties (e.g. United Nations or World Bank). When government officials are involved, even simple business courtesies such as meals, entertainment or travel may be illegal under international law or the laws of the host country.

In the ordinary course of business, Suppliers may interact with government agencies and employees. However, interactions with government agencies, officials and employees are often regulated by campaign finance, lobby disclosure and government ethics laws. Before attempting to influence any election or government agency decision, or before hiring or making any payment to an individual who is a public official or employee, Suppliers shall confer with McMenon Management for pre-approval.

Conflict of Interest

McMenon expects Suppliers to exercise reasonable care and diligence to prevent any actions or conditions that could result in a conflict with the interests of McMenon or McMenon client, the appearance of a conflict of interest, or that may compromise the exercise of independent judgment during the execution of work for, or on behalf of, McMenon.A conflict of interest can arise if actions are taken or if there are interests that may make it difficult for Supplier to perform McMenon-related work objectively and effectively.

While engaged in McMenon-related work, Supplier shall not engage in any activity that creates a conflict of interest, or the appearance of a conflict of interest, with McMenon or in any way compromises the work that supplier is contracted to perform on behalf of McMenon. Any potential conflicts shall be disclosed to Supplier’sMcMenon business contact and written concurrence obtained that states Supplier is allowed to remain in a situation that could be perceived as a conflict. Any questions about a conflict of interest should be raised with Supplier’s McMenon business contact via email.

Human Rights

McMenon is committed to supporting international human rights, both as part of our commitment to the UNGlobal Compact and in accordance with the UN Guiding Principles on Business and Human Rights. Wherever McMenon works in the world, we seek to respect and uphold the fundamental human rights and freedoms of everyone who works for us or with us, and of the people and communities where we operate. We expect our Suppliers to share this commitment and to respect and uphold the human rights of all persons, especially in Supplier’s workforces, its supply chain and the communities in which it operates.

Supplier will identify and avoid as far as possible any adverse human rights impacts caused or contributed to by their operations or activities. McMenon will cease doing business with a Supplier who engages in abusive labour practices or exploits vulnerable worker groups (eg.: Child labour).In addition to treating all persons with dignity and respect, Supplier will provide workers with safe and humane working conditions. McMenon expects its Suppliers to have adequate procedures in place to ensure they are not directly or indirectly through their supply chain involved in any form of involuntary or forced labour.

Diversity & Inclusion

Due to our principles of respect and collaboration, McMenon is committed to diversity and to equal opportunity in the workplace. We seek to provide a work environment where all persons have the opportunity to reach their full potential and contribute to McMenon’s success. We promote the equal treatment of all persons. As part of our commitment to fair inclusion of all persons, as well as our commitment to diversity, McMenonprohibits discrimination on the basis of race, color, age, religion, sex, gender or gender identity, sexual orientation, national origin, disability, pregnancy, political affiliation, medical condition, veteran status, ancestry, union membership or marital status or under any other category protected under the laws of jurisdictions in which we do business. We expect our suppliers to share and uphold these standards and promote such equal treatment. Suppliers are still expected to conduct business inline with such standards.

Confidentiality

McMenon requires Suppliers to protect the confidential and personal data not only of McMenon and persons who work for McMenon, but also of our clients and persons who work for our clients.

Suppliershallmaintainand protect the confidentiality, integrity and availability of information entrusted to it by McMenon, except when disclosure is legally mandated or is authorized by McMenon. “Confidential and protected Information” is McMenon proprietary information or third-party information intended for use withinMcMenon that, if disclosed to, or modified by, unauthorized individuals, could result in the risk of financial loss, productivity loss or damage to McMenon’s reputation. Confidential and Protected Information includes without limitation, client information, legal documents, contracts, proposals, information about a specific client or employee, intellectual property and trade secrets. Unauthorized disclosure of Confidential and Protected information is a violation of this Supplier Code, McMenon contractual requirements, and, potentially, applicable law. Suppliers shall report any actual or suspected data breach immediately following detection to their contact at McMenon.

McMenoniscommittedtotheprotectionandsecurityofthepersonaldataofourstaff, clients and others inline with EU data protection law, including but not limited to the General Data Protection Regulation and equivalent laws in other jurisdictions where we operate (“Data Protection Law”).“Personal Data” refers to any information describing or relating to an identified or identifiable individual by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

External Communications&Social Media

No Supplier shall represent itself to the media as speaking on behalf of McMenon unless expressly authorized to do so by McMenon. Any media inquiries relating to McMenon shall be immediately referred to your McMenon contact. SuppliershallensurethattheuseofsocialmediabySupplier, their work force or representatives/agents does not negatively affect McMenon’s reputation.

Raising Concerns

The standards of conduct described in this Supplier Code are critical to the ongoing success of McMenon. If Suppliers encounter questionable activities, McMenon encourages them to immediately bring them to McMenon’sattention through Supplier’s McMenon business contact.