Business Partner Code of Conduct

This document was last updated September 2024.

Corporate integrity, responsible sourcing and the safety and well-being of workers in the countries where we do business are of paramount importance to 4most. These core principles are reflected in this Code of Conduct for our Business Partners (Code), which establishes the minimum standards that must be met by any entity that we work with. 

In this Code: 

Business Partner means a company, partnership or individual that (1) provides goods or services to one or more members of the 4most group of companies or (2) receives goods or services from one or more members of the 4most group of companies. 

Representative means a Business Partner’s suppliers, agents, and subcontractors who are involved in 4most’s supply chain. 

BUSINESS PARTNER’S COMMITMENT 

The Business Partner agrees that: 

• It will comply with the requirements in this Code. 
• It has appropriate systems in place to ensure continuous compliance and to demonstrate such compliance.  
• Any breach of this Code will allow 4most to terminate its relationship with the Business Partner with immediate effect.

1. Compliance with laws and regulations and priority of standards 

In carrying out its agreement(s) with 4most, the Business Partner shall, in addition to complying with the standards set out in this Code, comply with all applicable UK laws and regulations (and if applicable, the laws and regulations of any other jurisdiction where it or its Representatives operate) including but not limited to the laws and regulations relating to issues addressed in this Code.  

2. Updating this Code 

4most has the right to modify this Code from time to time on giving the Business Partner at least 7 days’ notice in writing (writing includes email). 

3. Workforce issues 

3.1 Slavery, human trafficking and child labour. The Business Partner shall comply with all applicable anti slavery and human trafficking laws, statutes, and regulations from time to time in force including but not limited to the Modern Slavery Act 2015 in any part of its supply chain. This includes, but is not limited to, not supporting or engaging or requiring any forced labour, the use of child labour and prison labour. 

3.2 Human rights. The Business Partner shall comply with all internationally recognised human rights understood, at a minimum, as those expressed in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work from time to time in force in any part of its supply chain. 

3.3 Equal opportunities. 4most is an equal opportunities employer and Business Partners shall not discriminate in hiring, compensation, training, advancement or promotion, termination, retirement or any employment practice based on race, caste, colour, national origin, gender, gender identity, sexual orientation, religion, age, marital or pregnancy status, disability, union membership or political affiliation or any other characteristic other than the worker’s ability to perform the job subject to any accommodations required or permitted by law.  

3.4 Freedom of association and collective bargaining. The Business Partner shall respect, and shall not interfere with, the right of workers to decide whether to lawfully associate with groups of their choice, including the right to form or join trade unions and to engage in collective bargaining. 

3.5 Working environment. The Business Partner shall provide a safe, healthy, and sanitary working environment  and comply with UK health and safety laws and any other relevant laws where it operates. This includes, but is not limited to, implementing general and relevant industry-specific procedures and safeguards to prevent workplace hazards and work-related accidents and injuries. Where such hazards cannot be adequately prevented or controlled, the Business Partner shall provide workers with appropriate personal protective equipment to protect against hazards typically encountered in that scope of work. 

3.6 Wages and remuneration. The Business Partner must compensate all workers with wages, including overtime premiums, and benefits that at a minimum meet the higher of: (a) the minimum wage and benefits established by applicable law (b) collective agreements (c) industry standards and (d) an amount sufficient to cover basic living requirements.

3.7 The Business Partner shall ensure workers are able to raise good faith concerns and have protection under whistleblowing laws.

4. Data protection and information security 

4.1 The Business Partner shall comply with all data protection laws and requirements (including the UK GDPR) when processing any personal data on 4most’s behalf.  

4.2 The Business Partner shall have in place appropriate measures to: 

(a) protect the integrity and confidentiality of information (including information belonging to or supplied by 4most) held on its systems (which include physical and online or electronic systems); and  

(b) ensure that there is no unauthorised access of the information by third parties, including its Representatives.  

5. Environmental responsibility 

5.1 The Business Partner shall ensure that: 

(a) its operations comply with all applicable environmental laws, including laws and international treaties relating to (but not limited to) climate change, waste disposal, emissions, discharges and the handling of hazardous and toxic materials;  

(b) the goods it manufactures (including the inputs and components that it incorporates into its goods) comply with all applicable environmental laws and treaties; and  

(c) it will only use packaging materials that comply with all applicable environmental laws and treaties. 

5.2 The Business Partner shall have in place a suitable environmental management system for managing its environmental risks. As a minimum, the system should include and address the following: 

(a) an assessment of the environmental impact of all historical, current and likely future operations;

(b) steps to continuously improve environmental performance, reduce pollution, emissions and waste;

(c) measures to reduce the use of all raw materials, energy and supplies; and

(d) raising awareness and training workers in environmental matters.  

6. Bribery and corruption 

6.1 The Business Partner shall comply with all applicable laws, statutes and regulations relating to the prevention of bribery and corruption (including but not limited to the Bribery Act 2010). To that end, the Business Partner shall not accept, offer, promise, pay, permit or authorise: 

(a) bribes, facilitation payments, kickbacks or illegal political contributions; 

(b) money, goods, services, entertainment, employment, contracts or other things of value, in order to obtain or retain improper advantage; or 

(c) any other unlawful or improper payments or benefits.

6.2 The Business Partner shall adhere to all international trade and economic sanctions administered by His Majesty’s Treasury of the United Kingdom, the European Union, the United Nations Security Council and the Office of Foreign Assets Control of the U.S. Treasury Department.

7. Unfair business practices 

7.1 The Business Partner shall comply with all applicable competition laws (including but not limited to the Competition Act 1998), including but not limited to those relating to teaming and information sharing with competitors, price fixing and rigging bids.

7.2 The Business Partner shall not use sensitive or privileged information that has not yet been released to the market in order to take advantage of the market.

8. Procuring and managing Representatives  

8.1 With regard to prospective Representatives, the Business Partner shall carry out appropriate due diligence on prospective Representatives that will form part of 4most’s upstream supply chain. At a minimum, the due diligence must include the following: 

(a) investigations into prospective Representatives’ stance, public statements, compliance with applicable laws and other actions on human rights, treatment of workers, bribery, ethical behaviour and the environment;  

(b) risk assessments for countries from which materials, components or finished goods are sourced; and 

(c) the prospective Representative’s ability to meet the requirements and principles that are covered in this Code.  

8.2 In its dealings with Representatives, the Business Partner shall: 

(a) ensure that agreements with Representatives include provisions that require the Representatives to comply with applicable provisions of this Code, having due regard to the risk profile of the transaction, the Representative’s ability to comply with those provisions and the consequences where the  Representative fails to meet those requirements; 

(b) ensure that it has measures to monitor that those Representatives are complying with those compliance-related provisions and that it has systems in place to address any deficiencies or breaches of those requirements; and 

(c) pay its Representatives promptly, with the maximum payment period being 30 days. 

9. Training 

9.1 The Business Partner shall implement a system of training for its workers to ensure that they are aware of the requirements of this Code. 

10. Certification and audit  

10.1 The Business Partner shall provide written confirmation to 4most upon request that:

(a) it has appropriate systems in place to monitor its compliance with this Code; and

(b) it is able to comply with this Code for the duration of its relationship with 4most.  

10.2 In addition to the written confirmation at 10.1, 4most may conduct audits and inspections to verify the Business Partner’s compliance with this Code. 4most has no obligation to conduct such audits or inspections.  

11. Breach, remediation and termination 

11.1 Where 4most becomes aware of a breach of this Code by the Business Partner or its workers, 4most may either: 

(a) immediately terminate its business relationship with the Business Partner (including any contracts); or 

(b) require the Business Partner to produce a remediation plan specifying the actions that the Business Partner will take that will lead to compliance with the Code. If the Business Partner fails to produce the remediation plan within an agreed timeframe or fails to implement it within a reasonable time, 4most may immediately terminate its business relationship with the Business Partner (including any contracts). 

11.2 Where 4most becomes aware that a Representative has been involved in an incident (or incidents) that would constitute a breach of any of the requirements under this Code, were they bound directly by it, 4most may either: 

(a) terminate its business relationship with the Business Partner (including any contracts); or 

(b) require the Business Partner to remedy that incident (or incidents) with that Representative. If the Business Partner is not able to remedy such incident with that Representative within a reasonable time, 4most may immediately terminate its business relationship with the Business Partner (including any contracts).