1. INTRODUCTION AND PURPOSE
This Supplier Code of Conduct establishes the minimum standards that M365Group SIA requires all suppliers, vendors, contractors, consultants, and other third parties providing goods or services to our company (collectively referred to as “Suppliers”) to acknowledge and adhere to when conducting business with or on behalf of M365Group SIA. As a responsible business operating in the recruitment services sector, we are committed to conducting our operations in accordance with the highest ethical, social, and environmental standards, and we expect the same commitment from all organizations within our supply chain.
The principles and requirements set forth in this Code reflect our commitment to international standards including the United Nations Global Compact principles, the International Labour Organization’s Fundamental Conventions, the Universal Declaration of Human Rights, and applicable laws and regulations in all jurisdictions where we operate. Suppliers are expected not only to comply with all applicable laws and regulations but to strive to exceed legal requirements and embrace best practices in corporate responsibility. This Code supplements, but does not replace, any specific obligations set out in contracts between M365Group SIA and its Suppliers.
2. BUSINESS ETHICS AND INTEGRITY
Suppliers must conduct their business with the highest standards of integrity, honesty, and transparency in all business interactions. This fundamental requirement encompasses zero tolerance for any form of corruption, bribery, extortion, embezzlement, or any other form of unethical business practice. Suppliers shall not offer, promise, give, or accept any bribes, facilitation payments, kickbacks, or other improper advantages, whether directly or through intermediaries, to obtain or retain business or gain any improper advantage. This prohibition extends to interactions with government officials, M365Group SIA employees, and any other parties in both the public and private sectors.
Suppliers must maintain accurate and transparent records of all business transactions and make these available for inspection by M365Group SIA or its designated representatives upon reasonable request. Financial records must be maintained in accordance with applicable accounting standards and must accurately reflect all transactions. Suppliers must implement and maintain adequate internal controls to prevent and detect bribery, corruption, and other forms of financial misconduct. Any gifts, entertainment, or hospitality offered to M365Group SIA employees must be modest in value, infrequent, and appropriate to the business relationship, and must never be offered with the intent to improperly influence business decisions.
3. LABOR STANDARDS AND HUMAN RIGHTS
M365Group SIA requires all Suppliers to respect and uphold fundamental human rights in all their operations and to treat all workers with dignity and respect. Suppliers must not use or benefit from forced labor in any form, including prison labor, indentured labor, bonded labor, military labor, slave labor, or any form of human trafficking. All work must be voluntary, and workers must be free to leave their employment upon reasonable notice. Suppliers must not require workers to surrender any government-issued identification, passports, or work permits as a condition of employment, and must not charge workers recruitment fees or require them to pay deposits.
Child labor is strictly prohibited in accordance with International Labour Organization conventions and local laws. Suppliers must not employ anyone under the age of 15 or the local minimum age for employment, whichever is higher. Young workers between the minimum age and 18 years must not perform hazardous work and must be protected from work that is likely to harm their health, safety, or moral development. Suppliers must maintain documentation verifying the age of all workers and must implement robust age verification procedures in their recruitment processes. Working hours must comply with applicable laws and industry standards, and workers must be provided with reasonable rest periods, leave entitlements, and overtime compensation in accordance with local laws.
4. ANTI-DISCRIMINATION AND FAIR TREATMENT
Suppliers must provide a workplace free from discrimination, harassment, and abuse. Employment decisions, including hiring, promotion, compensation, training opportunities, and termination, must be based solely on merit, qualifications, and business needs, without regard to race, color, religion, sex, sexual orientation, gender identity, national origin, age, disability, pregnancy, marital status, political affiliation, union membership, or any other characteristic protected by law. Suppliers must implement clear policies prohibiting discrimination and harassment, provide training to prevent such conduct, and establish effective grievance mechanisms for workers to report concerns without fear of retaliation.
All workers must be treated with respect and dignity, and any form of harsh or inhumane treatment is prohibited, including sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, verbal abuse, or the threat of any such treatment. Suppliers must respect workers’ rights to freedom of association and collective bargaining in accordance with local laws. Workers must be able to communicate openly with management regarding working conditions without fear of reprisal, intimidation, or harassment. Where local law restricts freedom of association, Suppliers should facilitate alternative means for workers to express their concerns and protect their rights.
5. HEALTH, SAFETY, AND WELLBEING
The health, safety, and wellbeing of workers must be a primary concern for all Suppliers. Suppliers must provide a safe and healthy working environment that meets or exceeds all applicable laws and regulations relating to occupational health and safety. This includes implementing and maintaining management systems to identify, assess, and mitigate health and safety risks; providing appropriate personal protective equipment at no cost to workers; ensuring access to clean toilet facilities, potable water, and sanitary food preparation and eating facilities; and maintaining emergency preparedness plans and conducting regular drills.
Suppliers must provide workers with appropriate health and safety training in a language they understand, including information about hazards in the workplace and proper procedures for safe work. Workplace injuries and illnesses must be properly recorded, investigated, and reported in accordance with applicable laws. Suppliers must implement measures to prevent workplace accidents and occupational diseases, including regular safety inspections, maintenance of equipment and machinery, and implementation of safe work procedures. Where Suppliers provide worker accommodation, such facilities must meet all applicable laws and regulations and provide a safe, clean, and healthy living environment with reasonable personal space, adequate ventilation, heating and lighting, clean sanitary facilities, and reasonable entry and exit privileges.
6. ENVIRONMENTAL RESPONSIBILITY
Suppliers must conduct their operations in an environmentally responsible manner and strive to minimize their environmental impact. This includes compliance with all applicable environmental laws, regulations, permits, and reporting requirements; implementation of measures to reduce greenhouse gas emissions, energy consumption, and water usage; minimization of waste generation and maximization of recycling and reuse; proper management and disposal of hazardous materials and waste; and protection of natural resources and biodiversity. Suppliers should implement environmental management systems appropriate to the size and nature of their operations and should strive for continuous improvement in environmental performance.
Suppliers are encouraged to set science-based emission reduction targets and to work toward carbon neutrality in their operations. The use of renewable energy sources should be prioritized, and energy efficiency measures should be implemented throughout operations. Suppliers must ensure that any chemicals or hazardous materials used in their operations are properly labeled, stored, and handled in accordance with applicable laws and safety standards. Environmental incidents must be promptly reported to appropriate authorities and to M365Group SIA, and corrective actions must be implemented to prevent recurrence.
7. DATA PROTECTION AND INFORMATION SECURITY
Given the nature of our business in recruitment services, data protection and information security are of paramount importance. Suppliers who process personal data on behalf of M365Group SIA or who have access to M365Group SIA’s confidential information must implement and maintain appropriate technical and organizational measures to protect such data against unauthorized access, disclosure, alteration, or destruction. Suppliers must comply with all applicable data protection laws and regulations, including the General Data Protection Regulation (GDPR), and must process personal data only in accordance with M365Group SIA’s instructions and applicable data processing agreements.
Suppliers must ensure that all personnel with access to personal data or confidential information are subject to appropriate confidentiality obligations and have received adequate training on data protection requirements. Any data breaches or security incidents must be immediately reported to M365Group SIA, and Suppliers must cooperate fully in any investigation and remediation efforts. Suppliers must not transfer personal data outside the European Economic Area without appropriate safeguards as required by applicable law and must delete or return all personal data upon termination of their relationship with M365Group SIA or upon request.
8. COMPLIANCE MONITORING AND AUDITING
M365Group SIA reserves the right to verify Suppliers’ compliance with this Code through various means, including self-assessments, documentation reviews, announced and unannounced audits, and third-party verifications. Suppliers must maintain appropriate documentation to demonstrate compliance with this Code and must make such documentation available to M365Group SIA or its designated representatives upon request. Suppliers must cooperate fully with any compliance assessments and must provide accurate and complete information.
Suppliers must promptly notify M365Group SIA of any actual or potential violations of this Code, whether by the Supplier or by any of its subcontractors or agents. Such notification should be made to compliance@m365connect.com or through other designated reporting channels. Suppliers must implement their own monitoring systems to ensure compliance throughout their operations and supply chains and must take prompt corrective action to address any identified non-conformances. Where Suppliers engage subcontractors to provide goods or services related to their relationship with M365Group SIA, the Supplier remains fully responsible for ensuring such subcontractors comply with the requirements of this Code.
9. WHISTLEBLOWING AND NON-RETALIATION
Suppliers must establish mechanisms that allow workers and other stakeholders to report concerns about potential violations of this Code, illegal activities, or unethical behavior without fear of retaliation. These reporting mechanisms should include multiple channels for raising concerns, provisions for anonymous reporting where legally permitted, prompt and thorough investigation of all reports, and protection of whistleblowers from any form of retaliation. Suppliers must not discharge, demote, suspend, threaten, harass, or in any manner discriminate against any worker who in good faith reports concerns or cooperates with investigations.
M365Group SIA provides a confidential reporting mechanism for anyone to report concerns about potential violations of this Code or other ethical concerns related to our supply chain. Reports can be made to ethics@m365connect.com or by contacting our Chief Compliance Officer directly at +4915203824573. All reports will be treated confidentially to the fullest extent possible, and M365Group SIA will not tolerate any retaliation against individuals who raise concerns in good faith.
10. CONSEQUENCES OF NON-COMPLIANCE
Compliance with this Code is a mandatory requirement for doing business with M365Group SIA. Failure to comply with any aspect of this Code may result in corrective action requirements, suspension of business relationships, termination of contracts, or legal action, depending on the severity and nature of the violation. M365Group SIA will work with Suppliers who demonstrate genuine commitment to addressing identified issues through appropriate corrective action plans. However, we reserve the right to terminate relationships immediately in cases of severe violations, particularly those involving modern slavery, child labor, corruption, or significant environmental damage.
Suppliers who identify non-conformances in their own operations are expected to develop and implement corrective action plans with clear timelines for resolution. M365Group SIA may require evidence of corrective actions and may conduct follow-up assessments to verify that issues have been adequately addressed. The cost of any remediation efforts, including compensation for affected workers where appropriate, shall be borne by the Supplier. M365Group SIA’s decision regarding the adequacy of corrective actions and the continuation of the business relationship shall be final.
11. IMPLEMENTATION AND TRAINING
Suppliers are responsible for ensuring that this Code is communicated to and understood by all relevant personnel within their organization, including management, employees, and subcontractors involved in providing goods or services to M365Group SIA. Suppliers should provide appropriate training to ensure personnel understand and can implement the requirements of this Code in their daily operations. Training should be provided in languages understood by all workers and should be documented.
Suppliers should integrate the requirements of this Code into their own policies, procedures, and management systems to ensure sustainable compliance. This includes establishing clear accountability for compliance, implementing appropriate controls and monitoring mechanisms, and regularly reviewing and updating policies and procedures to reflect changes in laws, regulations, and best practices. Suppliers are encouraged to extend similar standards throughout their own supply chains and to work collaboratively with their suppliers to improve social and environmental performance.
12. CONTINUOUS IMPROVEMENT
M365Group SIA expects Suppliers to embrace a philosophy of continuous improvement in all areas covered by this Code. Suppliers should regularly assess their performance against the requirements of this Code and industry best practices, identify opportunities for improvement, and implement appropriate measures to enhance their social, environmental, and ethical performance. Suppliers are encouraged to set ambitious targets for improvement, to measure and report on their progress, and to engage with stakeholders to understand and address their concerns.
We recognize that achieving full compliance with all aspects of this Code may be a journey for some Suppliers, particularly smaller organizations or those operating in challenging environments. M365Group SIA is committed to working collaboratively with Suppliers who demonstrate genuine commitment to improvement and who are transparent about challenges they face. We encourage Suppliers to engage with us on sustainability initiatives and to share best practices that can benefit our entire supply chain. Through partnership and continuous improvement, we aim to create positive social and environmental impact throughout our value chain.
