Supplier Code of Conduct

Introduction

BGF is the UK and Ireland’s most active and dynamic investor of equity capital in growing companies, backing entrepreneurs and innovators.

We are an established, independent investment company, with a balance sheet of £2.7bn supporting earlier stage and established private businesses, and smaller listed companies.

With 14 offices in the UK and Ireland, we invest across all regions and industry sectors, backing founders and management teams who are powering the future of the economy.

Scope

We are committed to ensuring that our business is conducted sustainably and responsibly. Corporate integrity, environmental and social impact, responsible sourcing and the safety and wellbeing of workers in our business and supply chain are of the utmost importance to BGF. We look to work with suppliers who align with our values.

This Supplier Code of Conduct (“Code”) establishes the minimum principles, standards and rules which are paramount to BGF and which we expect from all of the suppliers we engage with. We expect our suppliers to ensure that the principles in this Code are reflected within their own supply chain.

Where we refer to a “supplier” in this Code, this should be read to include that supplier’s workers, officers, consultants, subcontractors and agents.

We have the right to update this Code at any time.

Key Principles

Compliance with laws and regulations

Our suppliers should comply with all applicable laws and regulations which apply to their business and to that of their wider group.

Ensuring an ethical approach to business

We expect our suppliers to act ethically, responsibly and with integrity in all matters relating to their business and to ensure that they have appropriate controls and systems in place to monitor such behaviours. Key principles to be followed include:

(a) Modern slavery

Suppliers must comply with all applicable modern slavery laws and regulations which apply to their business and in any part of their supply chain (including but not limited to the Modern Slavery Act 2015). This includes, but is not limited to, not supporting or engaging or requiring any forced labour, the use of child labour, bonded labour, indentured labour and prison labour.

If a supplier is required to publish a modern slavery statement in accordance with the Modern Slavery Act 2015, they shall ensure that this requirement is complied with. We may request a copy of this statement from time to time. A copy of BGF’s modern slavery statement is available online.

(b) Human rights

Suppliers must ensure compliance 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 relation to workers, suppliers should comply with all applicable wage and working regulations.

At BGF we recognise the critical role of equality, diversity and inclusion in our mission of creating sustainable business growth. We are proud to be an equal opportunities employer.

Suppliers should comply with all relevant equality legislation (including the Equality Act 2010) in the areas in which they operate and should ensure there is no discrimination in any employment or hiring 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.

(d) Anti-money laundering and competition

Suppliers must comply with all applicable anti-money laundering laws and regulations.

Suppliers must also comply with all applicable competition laws (including but not limited to the Competition Act 1998).

Health and safety

BGF is committed to ensuring that all of our workers and any suppliers who provide services at our offices are provided with a safe working environment.

We require that our suppliers maintain a safe, healthy, and sanitary working environment and comply with applicable health and safety laws (including the Health and Safety at Work Act 1974). This should include implementing general and relevant industry-specific procedures and safeguards to prevent workplace hazards and work-related accidents and injuries. We may request documentation from our suppliers in connection with health and safety (such as copies of the supplier’s health and safety policy and/or risk assessments).

Suppliers should ensure that workers are provided with adequate training relating to health and safety, along with appropriate personal protective equipment to protect against hazards typically encoutered in that supplier’s business and any other locations in which their workers operate.

Environment

We recognise that we have an important role to play in championing sustainable practices not only within our own business but also that of our portfolio companies.

Suppliers must ensure compliance with all applicable environmental laws in connection with their business and the services they provide or the products/goods they manufacture (including how such products/goods are disposed of).

We expect suppliers to have an appropriate environmental policy and/or management system in place for managing environmental risks within their business.

We also expect suppliers to identify and actively seek to minimise their impact on the environment, including in the areas of water, waste, energy and carbon.

Suppliers should also monitor sustainability and environmental practices within their wider supply chain.

Bribery and corruption

We conduct our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and corruption.

Our suppliers should comply with all applicable laws and regulations relating to prevention of bribery and corruption (including but not limited to the Bribery Act 2010) and should ensure they have appropriate policies in place and adequate procedures to prevent bribery occurring. If no such laws or regulations apply to the supplier (or apply to a lesser extent than that of the Bribery Act 2010), the supplier must comply with the Bribery Act 2010.

Suppliers should not offer or accept gifts and/or entertainment where to do so would constitute, or would be perceived as constituting, corrupt activity. Suppliers should not engage in deliberate illegal tax evasion or facilitate such evasion and should ensure open transparency with tax authorities.

Suppliers should report any incident within their business and/or their wider supplier chain which could breach anti-bribery and corruption laws to us. We may ask for additional information/documentation in respect of such incident.

Data protection and confidential information

Suppliers must comply with all data protection laws and requirements relating to their business.

We expect suppliers to ensure; (i) that all information received from us (or on our behalf) is held confidentially and securely and (ii) compliance with all contractual provisions and any applicable laws in relation to confidential information.

Suppliers are expected to maintain appropriate risk-based technical and organisational security measures to protect the integrity and confidentiality of information, including Personal Data as defined in the UK GDPR, within their business and supply chains. We may request proof of any formal certifications or standards a supplier has obtained in connection with security of data and associated technology platforms, such as ISO27001 or SOC-2. We reserve the right to audit security controls and processes related to the management of our business confidential data, including the Personal Data the supplier may process on our behalf.

Any breach or suspected breach of data protection and/or confidential information should be reported to us immediately.

Managing risk within the supply chain

Suppliers are expected to carry out appropriate due diligence on prospective suppliers/contractors and to continually monitor this during their engagement. Suppliers should ensure that any agreements entered into with their suppliers/contractors reflect the requirements of this Code.

Training

Suppliers should ensure that their workers are aware of this Code and that appropriate training is delivered to their workforce to enable them to comply with the principles set out in this Code. Suppliers should keep a record of the training which is given to their workers.

Compliance with the Code

Suppliers are responsible for their compliance with this Code and that of their workforce and wider supply chain. We expect our suppliers to:

have effective procedures in place to enable their employees and contractors to ask questions, raise concerns and/or report suspected or actual breaches of the requirements of this Code and/or any illegal activity that may impact BGF;
promptly investigate any credible concerns about suspected or actual breaches of the requirements of this Code and take appropriate action to minimise any actual impact; and
report any suspected or actual breaches of this Code (whether by the supplier, their workforce or within their wider supply chain) to BGF as soon as possible.

A supplier should not take disciplinary action against an employee who has reported a breach of this Code, or who has sought advice in respect of this Code.

We reserve the right to request documentation to verify a supplier’s compliance with this Code. If we find that there has been non-compliance with this Code (whether relating to the supplier or their wider supply chain), we reserve the right to request that the supplier takes remedial action (which may involve us asking to see a remedial plan).

Where we find that there has been serious non-compliance with this Code, we may consider terminating our relationship with the supplier.

Should you have any questions regarding this Code, please let us know.

December 2022