Supplier Relationship Management & Supplier Code of Conduct

4C Associates Limited and its group of companies, including its subsidiaries and affiliates (“4C”, “We” or “the Company”), is dedicated to aspiring to the highest standards and ensuring they are reflected throughout its supply chain with its suppliers.

4C engages with a range of suppliers for one-off or continuous supplies – around 150 – with the suppliers ranging in size from local companies and SMEs to multinationals. As a matter of practice, it favours using – wherever possible – UK-based suppliers to mitigate or eradicate the risk of modern slavery or poor sustainability practices entering its supply chain. We strive to be open and transparent in our selection of suppliers and reach decisions based on value for money and best proposition, rather than subjective criteria or it’s not what you know but who you know.

The character of our suppliers is diverse and ranges from a handful of universities which, operating in the public sector, champion and demonstrate the best practice in terms of modern slavery and sustainability, to individual contractors whose global impact is limited in scope, with an inevitable number of multinationals providing software and hotel supplies, but which have the critical mass to have implemented their own modern slavery and sustainability plans.

Where 4C has had cause to use resource in territories that have a reputation for labour law abuse or do not have a minimum wage, 4C has engaged with individuals directly to ensure that they are fairly remunerated and do not earn less than the living wage by the standards promoted by the Living Wage Foundation. There is flexibility with the contractors that 4C engages over the hours that individuals work, fair compensation, no child labour, no restrictions on association, no discrimination and no health and safety concerns.

4C does not operate in the most high risk sectors such as fashion, toys and electronics. But, in its engagement with suppliers (or clients), businesses will be contractually obliged to observe high ethical standards including in relation to modern slavery standards in the relationship. 4C is not involved in the manufacture of goods and so is not accountable for the provenance of those items or their impact on the environment; as a management consultancy, its capital is people and it ensures that they are fairly remunerated whichever territory they are deployed in.

4C operates an Environment Policy which, among other things, addresses use of materials and promotes responsible use of transportation, an Ethics Policy which combats financial irregularity including any behaviour that indicates or suggests the taking of bribes, money laundering or tax evasion and encourages individuals to speak out where they detect or suspect wrongdoing. 4C also voluntarily publishes a Modern Slavery Statement although its turnover does not mandate this requirement. These polices are freely available to suppliers and clients to view and 4C’s expectation is that its partners will comply with those standards and impose similar throughout their supply chains.

The Company expects that its suppliers and clients will look after 4C’s interests and will deliver on the promises that they make. 4C expects that suppliers will behave ethically and treat the end users of their service, employees and subcontractors fairly and with respect, and that they will be fair and transparent in their dealings with them, not least in ensuring prompt payment of invoices along the supply chain in order to support smaller and more vulnerable businesses and maintain a buoyant economy. The relationship is reciprocal and so 4C would expect to uphold the values towards its business partners that it expects from them in return.

Our employees, those of our suppliers, and service users have the right to respectful treatment. We will not tolerate discrimination, harassment or victimisation in the workplace or in connection with any service. We expect our suppliers to provide the same commitment, including to their own employees. The Equality Act 2010 protects against discrimination, harassment and victimisation.

In our commitment to delivering the best possible standards across our business, we endeavour to manage stakeholder relations with clients and suppliers alike and, in doing so, aspire to hold regular meetings with partners with whom we have regular engagement in order to ensure that suitable standards are upheld or improved and that risks or shortcomings are mitigated or eradicated. This is conducted in conjunction with our Risk Management Policy and checks, both internal and external, to ensure continuing quality in our offering. Any disputes are handled in a collaborative rather than combative fashion. We strive for value throughout our supply chains, whether that be for our clients or suppliers and value is not exclusively based on monetary value, but will never compromise on standards and ethical practices in order to achieve it.

We expect suppliers not to exploit an incumbent or monopoly position, an urgent situation or an imbalance of capability or information to impose opportunistic pricing. We will engage
constructively with suppliers in relation to any required changes and we expect suppliers to reciprocate. We expect suppliers to work in good faith to resolve any disputes promptly and fairly during the life of a contract through good relationship management and, where appropriate, contractual dispute resolution mechanisms, recognising our respective interests are rarely best served by protracted litigation.

4C communicates its expectations of suppliers by publishing this code of conduct (as updated from time to time) on its website and by drawing it to the attention of any existing and new suppliers that it engages.

Signed by

Simon Terry, Chief Executive Officer

Dated 14th April 2022