Ethical & Sustainable Sourcing Policy – Applicable to the complete Supply Chain.
Ethical & Sustainable Sourcing Policy – Effective from 1st January, 2021.
K M Group and its composite business units ('K M Group'), takes all relevant social and environmental factors into consideration, alongside relevant financial factors, in making Procurement decisions on the purchase of goods, materials, etc. and the commissioning of any services. K M Group’s purchasing decisions should, where practicable, always consider whole life cost and the associated risks, impact and implications for society and the environment of that purchase. K M Group endeavours to buy wisely, prudently and responsibly at all times.
Our own Procurement activity can make a significant contribution to our wider organisational goals of sustainable economic development and resource minimisation, via ensuring that the goods and services we purchase, consider and deliver, provide optimum environmental performance and minimising negative environmental impact. As such, we actively seek out sustainable products and remove or minimise the use of single use or damaging items.
Our Procurement activity has an additional critical role to play in minimising any risk of social exploitation within the Supply Chain. We believe that this not only makes business sense, but that it also has the potential to positively impact the living and working standards of other people in other countries, in various regions around the world.
This Policy standard sets out the detailed requirements and minimum expectations of our policy of Sustainable and Ethical Procurement. Specifically, it addresses the expectation that our staff and suppliers have a natural respect for our ethical standards in the context of their own particular culture and that relationships with our suppliers are based on the principle of fair and honest dealings at all times.
The same principle of fair and honest dealings must be extended to all others with whom our suppliers do business, including employees, subcontractors and other third parties and their local communities.
K M Group Plant Hire & Groundworks Ltd.’s Ethical and Sustainable Sourcing and Supply Chain Management ethos and the associated policy, seeks to cover the ethical issues and social responsibility within Supply Chains when managing business to business supplier relationships and the purchasing of goods and services from our suppliers.
Upholding the principles of this policy is a shared responsibility between K M Plant and its suppliers and the policy will be adopted at senior and director level within the company. K M Plant expects its suppliers to assign and accept similar responsibility.
All K M Plant personnel involved in the Procurement of goods and services, have a personal responsibility to be aware and have a thorough understanding of the ethical issues referred to in this policy. We all have a part to play and a responsibility to perform that role justly.
Our sustainability objective is to ensure a continuous improvement in procurement decisions measured against delivering sustainable and ethical trading. More specifically, we seek to avoid adverse social and environmental impact in the Supply Chain, the reduction of environmental impact from service operations and the purchase of products that meet recognised environmental standards.
Our ethical objective is to ensure that people in the Supply Chain are treated with respect and have rights with regard to employment including the rights to freely choose employment, freedom of association, payment of a living wage, working hours that comply with national laws, equal opportunities, recognised employment relationship, freedom from intimidation and to a safe and healthy working environment.
Sustainable Procurement Standard
Working in collaborative partnership
We will seek out organisations that share our commitment to sound environmental performance and improvement. Where applicable, we will offer assistance to our suppliers in raising their environmental awareness. We will develop partnerships with our suppliers and contractors and work together to minimise the environmental and social impacts of our Supply Chain.
Sustainability requirements will be considered and where appropriate will be specified in our initial Pre-Qualification Questionnaires (PAS-91) and Tender related documentation for both suppliers and contractors, to ensure suppliers and contractors are fully aware of our environmental and social criteria at an early stage in the Tender or Supplier onboarding process.
Small firms, voluntary and community organisations, social enterprises and ethnic minority businesses are all considered as potential members of our Supply Chain, as they play an important role in the local economy and contribute to social cohesion.
Environmental Impact Minimisation
Where practicable, we will purchase goods that have a minimal impact upon the environment, both local and global. Factors taken into consideration will include:- sustainability of resource production, transportation, full life energy/raw material consumption and waste production, reuse potential, percentage recycled content, sustainable packaging and production processes.
Wherever possible we will consume and purchase less by identifying and eradicating, wasteful practices within our own operation and those operations upon which or where we have applicable influence.
Where possible, will re-cycle goods at the end of their life, where this is viable and where it is not possible, we will ensure disposal in the most environmentally sound manner. We will purchase products and services that meet at least the minimum environmental standards.
To promote and embed the adoption of sustainable services, we will develop and support through appropriate awareness programmes, new methodologies for identifying needs; appraising options; agreeing design and specification; supplier selection; tender evaluation; contract management and supplier development.
We will use our and the supplier’s collective purchasing power, wherever practicable, to positively influence and encourage their suppliers and manufacturers, to adopt sustainable practices and but from sustainable sources, in order to create a more reliable market for environmentally and ethically produced products and services.
Environmental and social factors shall be considered in the purchasing process. Specifically this includes considering what the product is made from, the product durability, where it is made and by whom, the efficiency of the product during use and the processes involved in its production and distribution, what the disposal requirements are and if it can be reused, repurposed, upcycled or recycled, etc.
We will add sustainability into the Procurement lifecycle: identifying needs; appraising options; design and specification; supplier selection; tender evaluation; contract management and supplier development. Sustainable development concepts will be embedded into purchasing functions through internal collaboration and where required appropriate training.
Monitoring and measuring
We will seek to establish KPI’s (Key Performance Indicators) for sustainable Procurement where appropriate, and monitor and measure the performance of our Supply Chain against them, also utilising the principles of OTIFIC supplier performance measurement for general performance propensity. Where applicable, environmental Law is given effect through Procurement decisions, including international obligations on climate change and sustainable development. We will support National policy and Legislation to proactively work to reduce CO2 emissions, eradicate ozone-depleting substances from our utilised resources and protect biodiversity wherever possible.
Ethical Procurement Standard
We expect our suppliers to comply with all relevant legal requirements and to also adopt the following moral principles:
Regulatory & Legislative Compliance
Suppliers shall comply with all National and other applicable Law and Regulations. Where the National law and this regard are in conflict, the highest standards consistent with National Law should be applied. Where the provisions of Law and this policy are not in conflict, but address the same subject, the provision, which affords the greatest protection to people and the environment, is encouraged to be applied.
K M Group will endeavour to ensure there is no forced, bonded, involuntary, prison or any form of slavery labour within the organisation or its Supply Chain. All employees without any distinction, have the right to join or form trade unions of their own choosing should they so wish, and, where a significant proportion of the workforce agree, to bargain collectively and utilise collective representation. Employees’ representatives will not be discriminated against, and will have all appropriate access to carry out their representative functions in the workplace.
Elimination of Child Labour
The long-term elimination of Child Labour should take place in a manner consistent with the best interests of the children concerned, should this be identified. Suppliers should develop or participate in and contribute to policies and programmes that provide for the transition of any child found to be performing Child Labour, to enable her or him to attend and remain in quality education until they are no longer considered to be a child. Children and young persons under 18 years of age shall not be employed at night or in hazardous conditions.
Right to a Living Wage
Wages paid for a standard working week meet or exceed national (or, where applicable, local) required minimum legal levels and standards. In any event, wages should not be paid in kind and should be enough to meet basic needs. No deductions shall be made from any wage without mutual consent.
All workers are to be provided with written and comprehendible information about their employment conditions in respect to wages before they enter employment, and the particulars of their wages for the pay period concerned each time that they are paid.
Avoidance of Excessive Working Hours
Standard working hours must comply with National laws and National benchmark industry standards; whichever affords greater protection to the employee. All Employees should not on a regular basis be required to work in excess of 48 hours per week without mutual agreement (unless having already ‘opted out’ of the Working Time Regulations 1998), and should be provided with at least one day off for every 7-day period on average. Overtime requested by the employer must be voluntary and must not be requested on a regular basis, unless mutually agreed as guaranteed overtime.
No Discrimination or Bias
A policy of equality for all should be in place and there should be no discrimination whatsoever in hiring, compensation level, access to training, promotion opportunities, required training, termination process, or retirement, based on race, caste, nationality, ethnic origin, religion, age, disability, gender, marital status, sexual orientation, sexual status, religious beliefs, union membership or political affiliation.
Provision of Regular Employment
To every extent possible work performed must be on the basis of recognised employment relationship established through National Law and practice. Obligations to employees under labour or social security Laws and regulations arising from the regular employment relationship should not be avoided.
Examples include the abuse of labour-only contracting, sub-contracting, or home-working arrangements, through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, or the excessive use of fixed-term contracts of employment.
No Harsh or Inhuman Treatment
Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse of other forms of intimidation shall be prohibited.
Safe and Healthy Working Conditions
We expect our suppliers:
We expect our suppliers:
We will use the following ‘Best Practice’ principles to guide the implementation of our Policies:
Principle 1: Working together
Principle 2: Making a difference
We will, and we expect our suppliers to:
Use an environmental and social risk-based approach to the implementation of this policy standard;
Focus attention on those parts of the Supply Chain where the risk of not meeting this policy standard is at its highest, and where the maximum difference can be made with resources available.
K M Group (and its composite business units and divisions) suppliers should:
Be prepared to demonstrate the basis of their approach with regard to the above.
Principle 3: Awareness raising and training
We will, and we expect our suppliers to:
Principle 4: Monitoring and independent verification
Recognise that implementation of this standard may be assessed/reassessed through monitoring and independent verification, and that these methods will be developed as our understanding grows.
We will expect our suppliers to:
Principle 5: Continuous improvement
We will, and we expect our suppliers to:
Ultimately, K M Group will refuse/decline to do business with a supplier where serious breaches of this policy standard are identified and where the supplier consistently fails to take corrective action within mutually agreed timescales. This will result in the supplier’s removal from the Supply Chain until demonstrably corrected and remedied.
Supplier Management Ethos
Evidence of Compliance
K M Plant’s Procurement and Supply Chain Management personnel will have the right to carry out regular monitoring of the implementation of Ethical and Sustainable Procurement commitments and ethical standards of practice by suppliers and business units to enable us to identify trends and ensure that environmental and social factors are being considered appropriately in Procurement decisions and functions.
Additional guidance and details of relevant Legislation is available from the following sources:
DEFRA (www.sustainable-development.gov.uk) Guidance on EC public procurement rules and best practice including OGC/Defra note on environmental issues in purchasing.
OFFICE OF GOVERNMENT COMMERCE (www.ogc.gov.uk) Guidance on procurement and estate management can be found on the framework for sustainable development on the government estate.
ENVIRONMENT AGENCY (www.environment-agency.gov.uk) Legislation and good practice approach.
This remains in force until otherwise countermanded or superseded by a replacement Policy, sanctioned by the Managing Director, and is mandatory upon all suppliers, and is applied universally across the Supply Chain.
The Document represents an official Policy of K M Group and its composite business units, and forms the basis of Contractual Terms of Trade, and has been instigated and implemented by the Procurement and Supply Chain Department, upon the instruction of the Managing Director of K M Group.
Monitoring and Review
The Managing Director is responsible for engaging Internal Audit to independently assess compliance with this Policy. The Managing Director will report annually on compliance with this policy, which will make an independent assessment of the adequacy of the policy and disclose any material non-compliance. The Managing Director may also make an independent assessment of the adequacy of the Policy in response to an event such as an instance of non-compliance.
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