Supplier Code of Conduct

The Risk Advisory Group Ltd (“Risk Advisory”) is a leading global risk consultancy providing intelligence, investigations and security services. Risk Advisory strives to operate its worldwide business to the highest ethical and professional standards in every business relationship and to comply with the applicable laws of the United Kingdom and any other jurisdictions in which the Company operates.

We expect the very highest standards from our suppliers. The quality of the goods and services you provide to us must match up to the quality of service we provide to our clients. We also encourage our suppliers to play their part in building a fair and sustainable global economy.

All of our key suppliers are expected to comply with the requirements set out in this Code.

1. Complying with the law

It is your obligation as a supplier to Risk Advisory to obey all applicable laws and regulations when supplying or providing goods and/or services to us. This includes ensuring that your personnel and subcontractors have the legal right to work in the jurisdictions in which they are operating.

2. Conflicts of interest

Due to the sensitive nature of our consultancy services we will not provide services in situations where conflicts of interest may arise, and expect our suppliers to do the same. A conflict of interest exists when a supplier’s loyalties or actions are divided between Risk Advisory’s interests and those of another, such as a competitor, supplier or customer.

You must ensure that you consider conflict of interest each time we place an order with you and report immediately to Risk Advisory should you consider that a conflict is possible.

For example, if you are engaged to conduct an assignment on a matter where you are currently or have been previously engaged by a competitor or other connected party you should disclose that fact to your point of contact at Risk Advisory. If a potential conflict arises after you have been engaged you must notify Risk Advisory immediately to allow us to evaluate the conflict together.

3. Bribery and corruption

We expect our suppliers to act, in all their dealings with us or on our behalf, with honesty and integrity. Our suppliers must work with us to ensure that they remain untainted by bribery or corruption.

This means that you must not:

• accept bribes or any improper payments from any contractors, subcontractors or other suppliers you recommend to us or manage on our behalf
• offer bribes or any improper payments with a view to securing business for us or with us
• give gifts of any significance (i.e. more than £50 in value) to anyone who works for us
• with the exception of occasional drinks and ordinary business lunches, entertain anyone who works for us unless you are confident that they have first cleared the matter with their manager/supervisor

If you have a question as to whether an activity is prohibited by the Code please speak to your point of contact at Risk Advisory.

4. Fair employment practices

Risk Advisory is committed to the principles of equality, respect for diversity and inclusion. We expect our suppliers to be similarly committed.

You must adopt fair employment practices which comply with employment laws and with legislation relating to freedom of association, data protection and information security, collective bargaining, immigration, working time and remuneration, equality of treatment, health and safety and which prohibit “modern slavery” (by which, in summary, we mean slavery or servitude, forced or compulsory labour and child labour).

Furthermore, you should not engage in any practices that are known to contribute to the risk of modern slavery. These include, for example, charging workers recruitment fees (so they are effectively paying for the opportunity of employment), retaining workers’ identity documents (such as their passports) or requiring workers to lodge deposits or bonds (which are effectively “runaway insurance”).

5. Non-collusion

You must never propose or enter into any agreement with another supplier or potential supplier of Risk Advisory or others in your sector to fix prices, terms and conditions of sale, costs, profit margins or anything similar.

6. Ensuring compliance

It is your responsibility to ensure that:

• your staff are informed about this Code
• all your directors and employees and any subcontractors you appoint comply with the standards described in this Code

To facilitate this, we also expect you to support whistle-blowing within your organisation and to have internal policies and procedures in place which encourage your personnel to speak up whenever they have a genuine concern about a legal or ethical issue.

7. Monitoring

We must be able to assess your continuing compliance with this Code. You will need to fully and promptly answer any queries we have about the matters covered by it and support any audit we wish to carry out to assess your compliance. This might include allowing us to make unscheduled visits to your premises and to speak directly to your workers in the course of any such visit.

8. Your supply chain

It is important to us that our supply chains also meet our ethical standards. We expect you to carry out due diligence on your own suppliers and to require them to adhere to standards which are similar to those described in this Code. You will let us have, on request, details of the due diligence you actually undertake.

We also expect you to avoid treating or making demands of your suppliers that might in any way lead them to violate human rights. Examples of this might include you making late payments or placing late orders as a matter of routine.

Your understanding and commitment

In summary, we expect you to share the aims and commitments described in this Code and to comply with the obligations and responsibilities in it. We also expect you to understand that this is fundamental to you being appointed as a supplier of, and continuing to supply goods and/or services to, The Risk Advisory Group.