Supplier Code of Conduct

Introduction

GBST is committed to conducting business ethically, responsibly, and in full compliance with applicable laws and regulations. We expect our suppliers to uphold the same high standards of ethical conduct, sustainability, and social and environmental responsibility.

This Supplier Code of Conduct (“Code”) outlines the minimum standards that suppliers should meet when conducting business with GBST. Suppliers must comply with all applicable laws and regulations in the jurisdictions where they operate and ensure the same standards are upheld across their supply chains.

Application of the Code

This Code applies to all suppliers engaged by GBST, being any third-party organisation which provides goods or services to GBST (“Suppliers”).

Adherence with the Code

Suppliers are expected to uphold the spirit of the Code and ensure their own supply chain does the same. Suppliers should self-assess their adherence and keep evidence of how they meet the standard of this Code. GBST may request information or evidence to assess adherence where appropriate, provided reasonable notice is given.

Non-adherence

Without limiting GBST’s rights, if a Supplier is unable to adhere with the Code, GBST will assess the impact that non-adherence has on its business and may prevent further engagement with the Supplier, or require the Supplier to achieve adherence with the Code, at the Supplier’s cost.

All matters will be taken seriously and addressed on a case-by-case basis. In the event of serious or unlawful conduct, GBST reserves the right to report the matter to the appropriate regulatory or enforcement authorities.

If a Supplier considers or suspects that another party has deviated from or breached their obligations under this Code, the Supplier is encouraged to report their concerns to GBST senior management. Anonymous disclosures may be made via GBST’s whistleblower channel. Please refer to the GBST Whistleblower Policy for details.

Standards

Ethical Business Conduct

Suppliers must conduct their business ethically, in accordance with applicable laws and contracts, and with integrity, acting honestly, transparently, and in good faith in all dealings.

Ethical business conduct includes avoiding bribery, corruption, fraud, and any other form of dishonest or unlawful behaviour.

Suppliers are expected to demonstrate professionalism in their interactions with GBST, its employees, and other stakeholders, and to make decisions guided by fairness and accountability.

Bribery and Corruption

Suppliers must not give, receive, offer, or promise any form of benefit or advantage, such as gifts, hospitality, money, or rewards, with the intent to improperly gain or retain an unfair business advantage.

Suppliers must implement and maintain effective controls to prevent bribery and corruption within their operations and supply chains and must comply with all applicable anti-bribery and anti-corruption laws in the jurisdictions in which they operate.

Fraud

Suppliers must not engage in any form of fraud, including falsifying records, misrepresenting information, concealing facts, or deliberately deceiving others for personal or business gain. Suppliers are expected to implement appropriate controls to detect and prevent fraud within their operations.

Modern Slavery

Modern slavery is an umbrella term used to collectively refer to human trafficking, slavery and slavery-like practices (such as forced labour, forced marriage and servitude).
Suppliers must ensure that employment is freely chosen and voluntary, without any form of coercion. The use of child labour, forced labour, or human trafficking is strictly prohibited, and suppliers are expected to take active measures to prevent such practices within their operations and supply chains.
Suppliers must implement and maintain effective controls to prevent modern slavery within their operations and supply chains and must comply with all applicable laws in the jurisdictions in which they operate and any reasonable GBST requirements.

Data Privacy and Confidentiality

Suppliers must have appropriate controls, or as otherwise required by GBST, to protect the privacy and confidentiality of all data and information provided to them during the business relationship, including appropriate measures to dispose of confidential information as required and in accordance with applicable laws.

Suppliers must not improperly use any private, confidential or commercially sensitive information in their dealings with GBST.

Labour Rights

Safe and healthy working environment

Suppliers should provide a safe and healthy working environment that complies with all relevant health and safety laws and regulations, ensuring that workplace risks are identified, assessed, and effectively managed to prevent accidents and injuries.

Suppliers should promote a safe, diverse and inclusive workplace environment, free from discrimination or harassment based on race, gender, age, religion, disability, pregnancy status, sexual orientation, and ensure appropriate policies are in place to prohibit discrimination.

Employment

Suppliers should comply with all applicable labour laws and regulations, including those relating to wages, working hours, and the appropriate classification of employment based on job level and status.

Freedom of association

Employees should be free to associate, organise, and bargain collectively through unions or other representative bodies without fear of retaliation, interference, or harassment.

Environmental Responsibility

Suppliers should make all efforts to ensure that their operations do not have a negative impact on the environment. Suppliers should maintain environmentally responsible policies and practices in their operations and ensure they comply with environmental laws and regulations in their operating jurisdiction.

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