Eton Bridge Partners Supplier Conduct Policy

1. Introduction

People are at the heart of everything we do. Whether placing permanent or interim senior hires or delivering large scale transformation through our experienced consultants, we are driven to create meaningful impact for business performance and for individuals’ careers. Our values of Excellence, Trust and Spirit are the qualities that define us as a business and underscore everything we do. Building a deep level of trust is critical to fostering a culture of respect and transparency, and it is down to every one of our stakeholders, including our suppliers, to bring them to life in the work we do and the relationships we build. We expect our suppliers and their supply chain, including sub-contractors, to share our commitments and approach as defined in the guidelines set out below. This policy applies to suppliers to Eton Bridge Partners Limited (the “Company”) and any associated companies.

2. Laws and regulations

Suppliers will comply with all applicable local and national laws, rules, regulations and requirements in the provision of products and services manufactured and provided to Eton Bridge Partners Limited. This includes compliance with the International Labour Organisation (ILO) Core Conventions. It is the supplier’s responsibility to maintain and enforce these standards within its own supply chain.

3. Underage labour

Suppliers shall ensure that no underage labour has been used in the production or distribution of goods and services to Eton Bridge Partners Limited. The Company considers any child under the age of 14 underage labour. If 14 years of age or more, then a child is any person under the minimum employment age according to the laws of the country where the product (or parts of) or services are sourced from, or in the absence of law, under the minimum age for completed mandatory education.

4. Forced labour

Eton Bridge Partners Limited is committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses. We are committed to ensuring that our staff and any workers we supply (directly or indirectly) are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses. Suppliers are expected to adhere to the terms of Eton Bridge Partners Limited’s Modern Slavery Statement and the Modern Slavery Act 2015.

• Suppliers will not use or tolerate in their supply chain any form of slavery, servitude, indentured, bonded, involuntary prison, military or compulsory labour or any form of human trafficking.
• All work must be conducted voluntarily and without threat of any penalty or sanctions.
• No employee’s government-issued identification, passports or work permits will be retained by the supplier as a condition of employment.
• Workers’ rights to leave the workplace after their shift or to terminate their employment after reasonable notice and receive owed salary must be recognised by the supplier. This applies to local or migrant employees.
• We require our suppliers to address modern slavery concerns in their policies and we reserve the right to conduct spot-checks of the businesses who supply us in order to investigate any complaints.

5. Freedom of association

Suppliers shall respect the rights of workers to associate or not to associate with any group, as permitted by and in accordance with all applicable local and national laws and freedom of association and collective bargaining. Suppliers shall not interfere with or discriminate against workers choosing to belong to them.

Where the right to freedom of association and collective bargaining is restricted under national law, suppliers will facilitate, not hinder, alternative means of independent and free association and bargaining.

6. Discrimination

Our suppliers are expected to adhere to the Equality Act 2010 which protects against discrimination, harassment and victimisation. In addition:

• An inclusive and diverse work environment is encouraged, with equal opportunities for all workers.
• All employees of our suppliers must be treated fairly and not discriminated against in any form of employment.
• Suppliers must not discriminate against any employee based on age, gender, sexual orientation, race, ethnicity, colour, disability, religion, political affiliation, union membership, national origin, marital or pregnancy status during any recruitment or employment activities.
• Suppliers must commit to a workforce free of any harassment or threat of harassment. Any forms or threats of harassment, physical, mental, sexual or verbal, must be prohibited and not tolerated.

7. Wages and benefits

Wages and benefits must meet legal minimums and industry standards without unauthorised deductions.

8. Working hours

Suppliers must ensure working hours comply with national laws and standards and should not expect workers to work (including overtime) in excess of hours set out in relevant working time legislation or other national legal limits unless an opt out has been voluntarily chosen by the employee with appropriate supporting written evidence.

9. Health and safety working conditions

• Suppliers must provide safe and clean conditions for workers at sites of working and residential facilities.
• Clear procedures must be in place to ensure regulated occupational health, safety and wellbeing standards are adhered to.
• We expect our suppliers, their supply chains and sub-contractors to adhere to the Health and Safety at Work Act 1974 or any similar legislation in the country where they operate.

10. Environment

We encourage our suppliers to have clear procedures in place to ensure direct and indirect environmental impacts associated with the goods and services they provide are understood, measured and managed.

11. Business integrity

It is our policy to conduct our business in an honest and ethical manner and we expect the same from our suppliers. We take a zero-tolerance approach to bribery and corruption, and we are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate. This includes implementing and enforcing effective systems to counter bribery. We expect our suppliers to manage the prevention, detection and reporting of bribery in their businesses and supply chain. We invite our suppliers to report any breach of bribery and corruption guidelines to Eton Bridge Partners Limited and we reserve the right to terminate our contractual relationship with our suppliers if they breach this policy.

Eton Bridge Partners Limited is committed to the prevention of the criminal facilitation of tax evasion in the workplace and in all its business dealings. We will not tolerate any form of criminal facilitation of tax evasion by any employee, supplier or third party dealing with the Company. No supplier should feel pressured into offering or agreeing to provide assistance to enable another person to unlawfully evade tax in order to secure business on behalf of or with Eton Bridge Partners Limited and no supplier will suffer adverse consequences in their dealings with us for refusing to agree to facilitate tax evasion or for taking steps to report any concerns that an offence has been committed. All suppliers must adhere to the Government’s guidance for tackling tax evasion or any similar legislation in the country in which they operate. Breaches of this legislation are regarded seriously by Eton Bridge Partners Limited and may result in the Company seeking appropriate legal, contractual or other remedies.

12. Discipline and grievances

Suppliers must provide a grievance mechanism for workers and their organisations to enable workers to anonymously raise workplace concerns. The mechanism must be transparent, set out clearly how grievances will be assessed, and feedback provided. Workers and their representatives must be informed clearly how the scheme operates and its scope and that it is equally accessible to all workers.

Disciplinary procedures shall be clearly documented, communicated and easily accessible to all workers. All disciplinary matters shall be recorded including evidence that the worker knew and understood what the individual was accused of and given the right to trade union or other appropriate representation at disciplinary meetings which may lead to significant disciplinary penalties or dismissal.

13. Compliance with Supplier Conduct Policy

If asked, suppliers must be able to demonstrate compliance with Eton Bridge Partners Limited’s Supplier Conduct Policy. This includes documented evidence and the right of the Company or a designated firm to conduct audits. Audits may include facility inspections, review of supplier records and business practices, and conducting employee interviews. By stating acceptance of an order from us, suppliers confirm their acceptance and compliance with this policy.

14. Reporting concerns

Suppliers are invited to report any area of concern to Eton Bridge Partners Limited. Any concerns can be reported directly to the Finance Director of Eton Bridge Partners Limited.