Code of Ethics: Supply Chain Partners

INTRODUCTION

Our values underpin how we operate and define the behaviours expected across our organisation. These principles extend to our supply chain and form the basis of our partnerships. REDS10 UK is committed to operating as a responsible business, conducting all activities safely, ethically, and with integrity.

This Code of Ethics, which supports our wider Code of Conduct, sets out the standards we expect from our supply chain partners. Suppliers are expected to review and understand this Code, communicate its requirements within their organisations, and apply its principles in their day-to-day activities. While this Code provides clear guidance, it cannot address every situation. Suppliers are encouraged to exercise sound judgement and consider questions such as: “Is this the right course of action?” and “Would I be comfortable if this was visible to REDS10 UK?”

We are committed to working collaboratively with our suppliers to continuously improve ethical standards and ways of working. We seek to build partnerships with organisations that share these values and are committed to upholding them.

WHO DOES THE SUPPLIER CODE OF ETHICS APPLY TO?

REDS10 UK’s Supplier Code of Ethics (“the Code”) underpins our Code of Conduct. It sets out standards and practices that REDS10 UK expects all its suppliers, subcontractors and consultants to follow. REDS10 UK expects you, as a supplier, to apply these same standards and practices to the suppliers and contractors that you work with throughout your supply chain.

WHAT IS EXPECTED OF YOU?

You are required to adhere to the principles outlined in this Code and to implement practices that are aligned with the standards expected by REDS10 UK. Non-compliance with these principles may lead to REDS10 UK reviewing or terminating its business relationship with you.

REDS10 UK is committed to conducting its operations in full compliance with all applicable laws and regulations in the regions where it operates. In circumstances where there is a conflict between local legislation and the standards set out in this Code, you are expected to apply whichever requirement sets the higher standard.

You should ensure that this Code is carefully reviewed and clearly understood. Adequate consideration should be given to how these principles are implemented and maintained within your organisation, as well as across your wider supply chain.

RAISING CONCERNS

We encourage all suppliers to raise any concerns relating to compliance with this Code, applicable laws, or the Code of Conduct where such concerns involve or impact REDS10 UK.
In the first instance, concerns should typically be discussed with your organisation’s senior management, who should feel empowered to escalate the matter to REDS10 UK’s senior leadership where appropriate.

REDS10 UK treats all reported concerns with seriousness and is committed to handling them in a confidential manner.

We do not tolerate any form of retaliation, victimisation, or discrimination against individuals who raise concerns or report suspected breaches in good faith.

BRIBERY AND CORRUPTION

REDS10 UK operates a strict zero-tolerance policy towards bribery and corruption in all aspects of its business activities. Suppliers are expected to maintain appropriate controls and procedures to prevent bribery and corrupt practices within their organisation, including among employees and any associated parties.

Suppliers and their employees or representatives must not:

  • Offer, promise, or provide bribes to any REDS10 UK employees, contractors, or representatives;
  • Engage in any form of bribery or corrupt activity that could directly or indirectly benefit REDS10 UK;
  • Provide or offer gifts, hospitality, financial incentives, contracts, or any other personal benefits:
    • With the intention of influencing a REDS10 UK employee or representative to act in favour of the supplier or contrary to REDS10 UK’s best interests;
    • To improperly influence any third party (for example, a client, consultant, or contractor
      connected to REDS10 UK) in relation to a project or agreement;
    • To influence a public official or securing an improper advantage.

PROTECTING OUR REPUTATION

REDS10 UK’s reputation is built on trust, integrity and the consistent delivery of high standards. Suppliers play a critical role in upholding and protecting this reputation through their actions and behaviours.

Suppliers will act in a way which always protects and promotes REDS10 UK’S good reputation.

Suppliers must not:

  • Make disparaging or damaging remarks about REDS10 Uk or any of its employees or stakeholders, whether verbally, in writing, electronically via email or the internet or social media; or
  • Engage in any activities outside of work which may reflect adversely on REDS10 UK’s reputation.

GIFTS AND HOSPITALITY

To support positive and professional working relationships, employees may offer or accept gifts and hospitality, provided these are in line with accepted business practices and are neither excessive nor inappropriate. Any gifts or hospitality must be reasonable and proportionate, considering their value, frequency, and timing. Suppliers are responsible for understanding and adhering to any applicable limits set by the recipient’s organisation and must ensure that such limits are not exceeded.

CONFLICTS OF INTEREST

Suppliers are required to avoid any situations that may give rise to a conflict of interest. Where a potential or actual conflict arises, it must be promptly disclosed to REDS10 UK’s senior management. Disclosed conflicts may be assessed and, where appropriate, managed. Failure to declare a conflict of interest will be treated as a serious breach of this Code.

Suppliers must:

  • Avoid any dealings or relationships with REDS10 UK employees or contractors that could compromise, or be perceived to compromise, their ability to act in the best interests of REDS10 UK. For example, suppliers must not enter contracts with businesses owned or controlled by a REDS10 UK employee, or their family member, spouse, or partner, without prior disclosure and written approval from REDS10 UK;
  • Notify REDS10 UK if any of your employees have a familial or close personal relationship with a REDS10 UK employee, or if any other relationship exists that could give rise to a potential conflict of interest.

ACCURATE RECORDS

Suppliers are required to maintain and provide accurate, complete, and transparent records in all dealings with REDS10 UK and its clients. Fraudulent, misleading, or deceptive practices will not be tolerated under any circumstances.

Suppliers must not:

  • Submit invoices or expense claims that are inaccurate, exaggerated, or unsupported;
  • Engage in any form of duplicate or double counting of materials or costs;
  • Allocate costs or expenses to incorrect projects or contracts;
  • Provide any documentation or records that are false, misleading, or intended to misrepresent the true nature of transactions with REDS10 UK or its clients.

ANTI-FACILITATION OF TAX EVASION

REDS10 UK adopts a strict zero-tolerance stance on tax evasion and the facilitation of tax evasion by its employees or associated parties. Suppliers are expected to meet all applicable tax obligations in full and to implement appropriate controls and procedures to prevent the facilitation of tax evasion within their organisation, including by employees and any associated persons.

COMPETITION LAW AND FAIR TRADING

REDS10 UK is committed to promoting open and fair competition and complying with all applicable competition laws (also known as anti-trust laws in certain jurisdictions) wherever it operates. These laws prohibit agreements, arrangements, or practices between organisations – whether formal or informal – that restrict or distort competition, as well as any conduct that abuses a position of market power.

Suppliers are expected to comply fully with all relevant competition laws and to maintain appropriate procedures to prevent any breaches.

Suppliers must not:

  • Share with REDS10 UK any information obtained from or relating to REDS10 UK’s competitors, including details of bids, pricing, pricing structures (such as discounts, premiums, or credit terms), contract terms, or other commercially sensitive information;
  • Disclose to REDS10 UK any information regarding bids or proposals you are submitting to REDS10 UK’s competitors;
  • Share with any third party information relating to REDS10 UK’s bids, pricing, pricing components (including discounts, premiums, or credit terms), contract terms, or any other
    commercially sensitive information;
  • Engage in bid rigging practices, including bid suppression, cover or complementary bidding, bid rotation, or any other activity that undermines fair competition in tendering processes involving REDS10 UK or its competitors;
  • Participate in cartel behaviour with competitors, including market or customer allocation, pricefixing, or any other arrangements that restrict competition.

INFORMATION SECURITY AND CONFIDENTIALITY

All documents, data, and information relating to REDS10 UK, its clients, or business partners must be treated as confidential and handled securely in accordance with contractual and legal obligations. Any such information obtained while working with REDS10 UK must not be disclosed to any third party outside of your organisation without prior authorisation. Suppliers are expected to continue to protect and maintain the confidentiality of this information even after their contractual relationship with REDS10
UK has ended.

Any actual or suspected breach of confidentiality or data security must be reported to REDS10 UK within 24 hours of becoming aware of the incident.

DATA PROTECTION AND PRIVACY

REDS10 UK is committed to safeguarding personal data and upholding the privacy rights of individuals.

The misuse or mishandling of personal information is not tolerated. REDS10 UK maintains a Data Protection Policy supported by appropriate operational and technical controls and expects its suppliers to uphold equivalent standards.

Suppliers must:

  • Comply with all applicable data protection and privacy legislation;
  • Ensure personal data is processed lawfully, fairly, and in a transparent manner;
  • Only collect and use personal data that is necessary to deliver the services being provided, and not use it for purposes that are incompatible with those services;
  • Implement appropriate technical and organisational measures to protect the integrity, security, and confidentiality of personal data;
  • Support and cooperate with REDS10 UK in relation to data protection impact assessments and any compliance requirements associated with processing activities carried out on REDS10 UK’s behalf.

EQUALITY, DIVERSITY, BULLYING AND HARRASSMENT

REDS10 UK is committed to fostering a working environment where all individuals are treated fairly, with dignity and respect, and have equal access to opportunities. Any form of discrimination, harassment, bullying, or victimisation is not tolerated. This includes discrimination on the basis of age, disability, sex, gender identity, pregnancy or maternity, race (including colour, nationality, and ethnic or national origin), sexual orientation, religion or belief, or marital or civil partnership status.

Suppliers are expected to uphold the same standards within their own organisations and to actively promote an inclusive workplace culture in which all individuals are respected and valued, regardless of their role, seniority, qualifications, skills, or experience.

Suppliers must not:

  • Discriminate against employees, or any other individuals you meet whilst conducting business, on the grounds of race, nationality, gender, sexual orientation, martial status, gender identity, religion, political belief, disability, age or otherwise;
  • Display behaviour which offends, humiliates or threatens others.

MODERN SLAVERY AND HUMAN RIGHTS

REDS10 UK conducts its business in line with the principles of the Universal Declaration of Human Rights and is committed to upholding fundamental human rights across its operations. Modern slavery and human trafficking are serious crimes and clear violations of human rights.

REDS10 UK adopts a zero-tolerance approach to all forms of modern slavery within its business and supply chain. We are committed to implementing and maintaining effective policies, procedures, and controls to prevent such practices from occurring.

Suppliers are expected to uphold the same standards and to take appropriate steps to ensure that modern slavery and human trafficking do not take place within their own operations or supply chains.

HEALTH, SAFETY, WELLBEING AND ENVIRONMENT

REDS10 UK is committed to achieving industry-leading standards in health and safety management and to maintaining a safe, clean, and sustainable working environment. Suppliers are expected to proactively manage and reduce risks to their workforce and to anyone affected by their activities. This includes fostering a culture where safety is prioritised, ensuring that people remain safe, healthy, and supported both now and in the future.

Suppliers must comply with all applicable health and safety and environmental legislation, as well as any relevant policies, procedures, and site-specific requirements relating to their work.

SANCTIONS AND EXPORT CONTROLS

REDS10 UK complies with all applicable financial sanctions and export control regulations. Suppliers are expected to have appropriate systems and controls in place to ensure compliance with these requirements.

Suppliers must:

  • Notify REDS10 UK if any goods, equipment, or technology being supplied are subject to export control restrictions that may require REDS10 UK to obtain a licence for their use, transfer, or export;
  • Inform REDS10 UK if the supplier, or any of its directors, shareholders, parent companies, or subsidiaries, is listed on any UK, EU, or other applicable sanctions register;
  • Refrain from engaging in business with any individual, organisation, or entity that is subject to sanctions or trade embargoes.

COMPLIANCE AND ETHICS

REDS10 UK seeks to partner with suppliers who demonstrate a strong commitment to legal compliance and ethical business practices. We will support suppliers who are actively working towards meeting the standards set out in this Code, provided there is openness and transparency in how these improvements are being implemented.

However, where there is evidence of deliberate non-compliance with this Code, or a lack of cooperation in addressing concerns, REDS10 UK reserves the right to suspend or terminate its business relationship with the supplier.