A word from SD Worx’ Head of Procurement

Our definition of a supplier is in accordance with CS3D:

The CS3D applies to SD Worx’s entire supply chain, including

• Upstream business partners and suppliers
• Downstream business partners and suppliers

These are companies that SD Worx has a commercial agreement with, to assist with operating SD Worx as a company, or that perform business operations regardless of if they are related to SD Worx products or services. 

These are companies that act on behalf of SD Worx to distribute, transport, or store products. 

This would apply to any employee, director, subcontractor or supply chain partner in our suppliers entire up or downstream supply chain. 

Points to capture:

SD Worx’ fundamental ethical principles require our suppliers to act at all times: 

- in accordance and in compliance with applicable laws and regulations, 

- with integrity, honesty, loyalty, diligence and respect, 

- while being mindful of the impact that one’s actions may have throughout the value chain

SD Worx expects our suppliers to adhere to all applicable national, European, and global (reporting) standards and Laws in the social, governance, and environmental (“ESG”) areas which may include, among others, the OECD Guidelines for Multinational Enterprises, the European Sustainability Reporting Standards (ESRS) as part of the Corporate Sustainability Reporting Directive (CSRD) and the national legislation implementing the CSRD. 

If our suppliers do not have to comply eg. due to size or location with aforementioned regulations such as the CSRD, we do still expect that they can demonstrate efforts and steps they are taking to ensure they are instilling (corporate) governance standards within their organisation and onwards supply chain.

If an organisation is a member of the UN Global Compact, we also expect those suppliers to adhere with and demonstrate examples where they can show their onwards supply chain for evidence of agreement to the UN Global Compact principles. 

The UN Global Compact 10 principles can be found here: The Ten Principles | UN Global Compact

Human Rights:

As an HR provider, SD Worx is committed to setting a good example for others and we want our suppliers to uphold the same standards. SD Worx expects its suppliers to provide an optimal, healthy, safe, and stimulating working environment where the diversity, integrity, and dignity of each individual are safeguarded. SD Worx requires that you comply with, and respect, internationally recognised human rights, including the fundamental rights embedded in the Universal Declaration of Human Rights, the European Convention on Human Rights, and the Charter of Fundamental Rights of the European Union. 

SD Worx expects our suppliers to not accept or tolerate any violation of human rights. In particular, and without limitation: 

- Our suppliers under no circumstances accept to resort to forced labour in their supply chain. You will only employ workers who are working of their own free will. No worker is required to lodge deposits, and no individual will be deprived of identity papers upon commencing employment. 

- Our suppliers comply with the applicable legal minimum age requirements in all countries in which it is active. 

- Our suppliers understand that no discrimination is engaged in, in particular based on age, gender, birth, ethnicity, social or cultural background, religious/philosophical beliefs, political/syndical opinions, family or marital status, wealth, sexual orientation, physical or mental disability, health circumstances, part-time or alternative working schemes.

Working environment:

It is essential that suppliers’ workers’ right of free association and right to collective bargaining as provided by applicable laws are duly preserved. Compliance with applicable legal provisions ensuring welfare at work and fair working conditions, including those regulating working hours and compensation must be ensured at all times. 

The health, safety, and security of our suppliers’ workers and third parties in the workplace must be ensured at all times. This commitment should be supported by a Health & Safety Policy or document which is communicated to their business.

Conducts such as violence, bullying, abuse of power, harassment (including sexual or moral), intimidations, threats, degrading or disrespectful acts or comments, are all unacceptable. Suppliers have to offer means to employees to communicate concerns.

Diversity, inclusion, and respect

We expect our suppliers to create a working environment where people with different backgrounds and experiences can thrive in both their professional and personal lives. All persons in your organisation  must be treated with respect, dignity and in an inclusive manner. All workers should have the freedom to be open, fair and honest in their professional activities and in the expression of their views and must conduct themselves in accordance with the applicable laws and regulations. 

Corruption and bribery 

Allegations of corruption, bribery, or other related forms of fraud (including influence peddling) – even if eventually unfounded – can significantly damage our suppliers, customers and SD Worx’ business and reputation. SD Worx requires all suppliers to comply with all applicable anti-corruption and anti-bribery laws. SD Worx suppliers may never, directly, or indirectly, give or offer anything to a third party, nor request or accept anything from a third party, that is or could reasonably be viewed as an unfair advantage. 

Suppliers must ensure that SD Worx employees must never be offered/given any excessive or inappropriate offers or gifts and offers that could be seen as a bribe. They can only accept gifts, or hospitality of modest value. Improper payments such as gratuity, kickback, bribe, payoff, or advantage (whether in cash or any other form) should never occur.

Fair competition

Compliance with rules of fair competition and antitrust laws is key. These laws aim at ensuring that businesses compete fairly and honestly and prohibit conducts seeking to reduce or restrain competition. Compliance with these laws is thus ultimately in our suppliers benefit as well. All behaviours constituting a breach to fair competition and/or antitrust laws, including for instance unlawful agreements with competitors or acts/missions amounting to abuse of dominant position, are strictly prohibited.

Economic sanctions 

A number of legal regimes put in place economic sanctions, export controls or similar restrictive measures, which may significantly affect the way SD Worx and our suppliers conduct our activities and/or lead to severe consequences. It is of paramount importance that SD Worx (and hence its suppliers) avoids any transaction with any person or entity / state / industry subject to applicable economic sanctions, or other similar restrictive measures, as may be issued for instance by (i) the United Nations, (ii) the EU and its member states and/or (iii) the United States (to the extent that considerations of US economic sanctions does not contravene the EU Blocking Regulation).

Fraud 

Any act aimed at breaching, deceiving, or circumventing applicable rules with a view to obtain an undue advantage (of whatever nature), whether for oneself or to the benefit of a third party, is strictly prohibited. Such prohibition extends, for instance and without limitation, to stealing or otherwise obtaining undue funds, goods, or data, altering or destroying documents (including financial or accounting documents), laundering proceeds of illegal origin, etc.

Confidentiality and privacy 

During working with SD Worx, suppliers may have access to various confidential information of SD Worx, our employees and our customers (including, customer data, business models, pricing, databases, etc.) or information which SD Worx holds in confidence from third parties. SD Worx aspires to the highest standards in protecting the confidentiality of this data and the data of any individuals it processes. SD Worx suppliers should therefore make sure to always use and handle confidential information in a secure and confidential way. When a supplier receives access to confidential information at SD Worx, it’s up to the supplier to keep it safe and make sure it stays confidential. Personal data held/processed by SD Worx benefits from specific and far-reaching legal protections and any processing thereof is subject to strict laws. It is essential that suppliers always act in compliance with applicable data protection laws and with SD Worx data protection policies. Suppliers must treat personal data in a professional and ethical manner and act with privacy in mind in line with the following principles: 

• Personal data is always considered confidential and may only be accessed or disclosed when authorised and necessary from a professional perspective 

• Personal data is only collected and used for well-defined and legitimate professional purposes • Our suppliers are transparent in its use of our data and returns fair value to customers and staff in return for it.

Conflict of interests 

A conflict of interests’ situation may arise when the business judgment of a supplier may be affected as a result of any relationship, he/she/they has/have with another person or business entity (including, for instance, with employees, customers, partners, competitors, service providers, subcontractors, current/future workers, competitors). When performing his/her/their services or providing goods to SD Worx, every supplier must prevent any form of (apparent) conflict of interests (whether of a financial, personal, or other nature). SD Worx expects each supplier to report to their contact at SD Worx, in advance, and in any event as soon as possible, any situation that may give rise to a suspicion of conflict of interests, , for prompt resolution.

ESG:

We expect suppliers to act in accordance with the evolving EU sustainability legislation instigated by the EU Green Deal. For instance, the EU Taxonomy and Corporate Sustainability Reporting Directive (CSRD) requires companies to report on the impact of corporate activities on the environment and society and requires the audit of reported information. However we do still expect that they can still demonstrate efforts and steps they are taking to ensure they are instilling governance standards within their organization and onwards supply chain.

From 2024 forwards, we expect our suppliers, including large companies and listed small and medium-sized enterprises (SMEs) to comply with these obligations. 

Environment and social:

We expect suppliers to comply with all applicable environmental and social legislation and regulations, including the handling of dangerous and hazardous materials. 

If required by law, suppliers should have an available environmental policy or statement which addresses and seeks to actively reduce CO2e emissions, waste and recycling and other initiatives which support the environment.

We also expect that suppliers take the responsibility and investment within their organisations to have an environmental management system or programme of work, which provides information about key environmental issues. Suppliers should always be conscious of the world around us and be able to demonstrate sustainable business practices which also consider the local and global impact and the communities they work with and among. 

We also expect that our suppliers take the accountability to ensure that they take the necessary steps in their own supply chains to conduct the required due diligence.

As SD Worx is primarily a HR software and services provider, our supply chain is one of our main focuses from an environmental perspective. Therefore, we want to ensure that our providers are actively seeking and can demonstrate the actions that they are taking to mitigate exposure to environmental risks and to reduce carbon emissions (in line with EU legislation)

Governance:

We expect suppliers to be vigilant and exercise recurring due diligence and so have satisfactory governance processes in place to properly manage this duty of care along their supply chain. 

Whistleblowing:

Suppliers are encouraged to speak up about behaviour within your workplace that is illegal or unethical, including violations of national law and regulations and anything that affects the public interest in the field of, for example, conflicts of interest, transgressive behaviour, infringement of ethical policies and misconduct.