Supplier Code

Foreword

At Gregory Group we are extremely proud of our 100-year heritage. Our people are fundamental to everything we have achieved. They understand the strength of working in partnership – whether that is working in partnership with our customers, supply partners, or local communities. They do so with integrity and a continual drive to improve. From reducing our impact on the planet to finding more efficient ways of working, we never rest on our laurels.

As a key Gregory Group supply partner, we expect you to demonstrate the same values. By doing so, together, we will achieve our primary purpose of delivering “visionary logistics for our customers”.

To facilitate this, I am pleased to endorse our Supplier Code which sets out the key social, ethical and environmental values we expect of you.

The Supplier Code highlights the aspects that are important to us; from supporting an inclusive and ethical supply chain to ensuring everyone works in a manner which is safe, healthy, and environmentally aware.

We would like you to share this Code with those in your team who work with Gregory Group so they can understand our values and aspirations and contribute to our mutual success.

As with all partnerships, they are at their strongest when we work collaboratively. If you have thoughts on ways we can work more effectively, or more sustainably, please do share them.

Angela Butler - Managing Director

Contents

1. Introduction

• Our Approach to Responsible Business and Sustainability

• What you need to do

2. What We Expect of You

• Human Rights

• Health & Safety

• Supply Chain

• Diversity and Inclusion

• Doing Business Responsibly

• Environmental Sustainability

3. What We Will Do

• Our Commitment to you

• Compliance with this Code

1. Introduction

Our Approach to Responsible Business and Environmental Sustainability

It is crucial to us that we, and all our partners, act in a responsible, sustainable, and inclusive manner.

At Gregory Group we pride ourselves on leading the way in making the UK logistic sector more sustainable. We recognise the importance of understanding and mitigating climate risks and the moral and commercial imperative for organisations to reduce their environmental impact.

You can read more about our Group and our Corporate Responsibility and Sustainability strategy here.

This Supplier Code is for all supply partners. It defines what we expect from you in terms of responsible business, sustainability practice and behaviour.

What You Need to Do

You are expected to:

Comply with this Code (and any future revisions);

Explain the principles of this Code to your employees and key sub-contractors that support the Group or work on our projects;

Ensure fair and honest business with all your stakeholders, including employees, sub-contractors and other third parties;

Inform us if anything changes and you are unable to comply with this Code.

You are encouraged to:

Speak up if you are concerned about any actions or decisions that contravene the standards set out in this Code;

Let us know if you would like to collaborate on any specific areas relating to Responsible Business or Sustainability.

2. What We Expect of You

Our expectations of our supply partners in terms of responsible business, sustainability practice and behaviour are grouped into six key areas –

• Human Rights

• Health & Safety

• Supply Chain

• Diversity & Inclusion

• Doing Business Responsibly

• Environmental Sustainability

In each case, we describe our minimum expectations using the term “we expect”. In some areas, we aspire to meet certain standards, and, in this case, we use the term “we encourage”.

Human Rights

We expect all our supply partners to respect human rights, both of your own workforce but also those in your supply chain.

We expect you to:

• Treat people equally and fairly without discrimination on the basis of age, disability, gender, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality and ethnic or national origins), religion or belief, sex or sexual orientation;

• Ensure all employees are able to work freely and be paid for their work regularly and timely as agreed. Employees have the right to leave employment if they choose;

• Not engage in or allow child labour. Ensure the minimum age for admission to employment will not be lower than the age of completion of compulsory schooling, unless as part of an Apprenticeship arrangement;

• Ensure that all employees are paid at least the statutory minimum wage with no unauthorised deductions;

• Ensure employees have freedom of choice to be represented by a Trade Union without fear of retaliation;

• Ensure all forms of discrimination, harassment, victimisation or bullying are not tolerated in the workplace and are addressed adequately through clear and uniformly applied disciplinary and grievance procedures;

• Ensure working hours are in accordance with local regulation and industry practice and voluntary overtime is at a manageable level;

• Have a written Modern Slavery Policy where required by the Act.

We encourage you to:

• Have a written Modern Slavery Policy, even where you do not meet the statutory minimum turnover requirement;

• Provide your employees with awareness training of human rights and modern slavery.

Health & Safety

We expect all our supply partners and their employees to operate in a manner which is safe.

We expect you to:

• Provide a workplace free from harm preventing injury and ill health where everyone goes home safely every day which means we put health and safety first.

• Have a written Health and Safety Policy.

Supply Chain

We expect all our supply partners to manage their own suppliers in a responsible and sustainable manner.

We expect you to:

• Manage your own suppliers appropriately to mitigate supply chain risks;

• Have reasonable payment policies covering your own suppliers;

• Consider the ethical and sustainable practices of your supply chain and proactively work with suppliers to mitigate such risks.

Diversity & Inclusion

We expect all our supply partners to understand our vision in relation to diversity and inclusion.

We expect you to:

• Treat all employees fairly and not discriminate against any group in your employment practices, in particular on the basis of gender, race, age, sexual orientation, gender identity, disability, faith, or family circumstances;

• Proactively support the development of a diverse and inclusive workforce including fair representation of women, disabled people, LGBT+ and BAME employees.

We encourage you to:

• Have a documented Diversity & Inclusion statement or set of statements within your Policy framework;

• Encourage positive mental health at work and have a documented mental health and wellbeing strategy.

Doing Business Responsibly

We expect all supply partners to act with honesty and integrity, managing their business ethically and responsibly.

We expect you to have identified and understand the risks in your business and to:

• Have a written Responsible Business strategy which sets out your approach, governance and the steps you take to ensure you are doing business responsibly;

• Adopt your own Supplier Code, or a similar policy or statement that covers:

  • Adherence to local laws;

  • Bribery and corruption;

  • Business integrity (including improper payments, conflicts of interest, fraud, competition, gifts and hospitality, and brand and intellectual property protection).

Environmental Sustainability

All businesses have a responsibility to be proactively managing and reducing their environmental impact.

We expect you to understand these impacts and to:

• Abide by all legislation and regulations related to environmental protection;

• Have a written Environmental Policy and/or Sustainability Policy which is appropriate and relevant for your operations;

• Have a sustainability strategy which sets out how your organisation is working to reduce your environmental impacts and support the transition to a low-carbon economy;

• Collaborate with us to help reduce our environmental impacts (which include carbon reduction, energy consumption, travel, water consumption and economy practices that reduce resource use and operational waste).

3. What We Will Do

Our Commitment to You

We commit to:

• Work closely with you to share expertise in developing innovative, high-quality products and services and in effectively managing risk;

• Engage with you and others in your markets in ways that ensure we achieve the best value for customers in terms of price, quality and social impact;

• Build strong, collaborative relationships with our supply partners and help them to understand the environment in which we operate so that they can meet our needs and those of our customers;

• Review this Code regularly and revise it over time as our approach to responsible sourcing evolves.

Compliance with the Code

We expect all our supply partners to meet or exceed all the provisions of this Code. Our goal is to work with you on developing our approach to responsible sourcing and sustainable procurement.

We reserve the right to review your policies, procedures or any other documentation related to this Code. In some higher risk instances, we may undertake an on-site audit to validate your adherence to this Code and applicable Third-Party Policies.

In situations where you are not yet compliant with the expectations set out in this Code, you must let us know. We will work with you on the development of an improvement plan.

However, if the issue is serious enough or cannot be resolved in a reasonable time frame, we may undertake a formal review. This may include order reduction or, ultimately, in accordance with any applicable contractual right, termination.

The provisions in this Code are in addition to and not in lieu of any legal agreement or contract.