Sunday understands that suppliers are independent entities, but the business practices and actions of a supplier may significantly impact and/or reflect upon us, our reputation and our brands, which are our most important assets. Because of this, Sunday expects all suppliers and their employees, agents and subcontractors (their representatives) to adhere to the Sunday Code of Conduct while they are conducting business with and/or on behalf of Sunday. All suppliers should educate their representatives to ensure they understand and comply with the Code.
It is essential that the employees of We Are Sunday Ltd (“Sunday” or the “Company”) conduct themselves at all times with integrity and in full compliance with the laws and regulations that govern our business practices and regulatory compliance. Sunday expects that its suppliers will share and embrace the letter and spirit of our commitment to integrity. By “supplier” we mean any firm or individual that provides a product or service to Sunday or indirectly to any of its clients.
Legal and regulatory
All Sunday suppliers and their representatives shall conduct their business activities in full compliance with the applicable laws and regulations of their respective countries while conducting business with and/or on behalf of the Company. In addition to any specific obligations under the supplier’s agreement with the Company, all suppliers shall, without limitation:
- Comply with the anti-corruption laws of the countries in which it does business, including the UK Anti-Bribery Act, and not make any illegal direct or indirect payments or promises of payments to government officials or any other person for the purpose of inducing the individual to misuse his or her position to obtain or retain business.
- Conduct business in full compliance with anti-trust, fair competition and data protection laws that govern the jurisdictions in which they conduct business.
- Comply with all applicable environmental laws and regulations regarding hazardous materials, air emissions, waste and wastewater discharges, including the manufacture, transportation, storage, disposal and release to the environment of such materials.
- Comply with all applicable laws prohibiting slavery, servitude or the use of forced or compulsory labour and human or labour trafficking.
- Be honest, direct and truthful in discussions with regulatory agency representatives and government officials.
- Comply with current and future data protection laws, including all national, foreign, state or local, regulation or ordinances, guidelines or other government standards or industry best practices relating to the data protection, privacy, confidentiality, integrity, availability or security of Sunday data.
- Comply with applicable tax laws and not request any employee within Sunday to assist with, or be complicit in, the evasion of tax.
Sunday suppliers and their representatives shall conduct their business interactions and activities with integrity and in accordance with their obligations under their specific agreements with the Company.
In addition to those obligations, all of our suppliers shall, without limitation:
- Honestly and accurately record and report all business information and comply with all applicable laws regarding their completion and accuracy.
- Create, retain and dispose of business records in full compliance with all applicable legal and regulatory requirements.
- Protect and responsibly use both the physical and intellectual assets of Sunday, including its property, data and equipment when authorised by the Company to use such assets.
- Accommodate Sunday Third-Party Risk Management assessments, as necessary.
- Use Sunday-provided information technology and systems (including email) only for authorised Company business-related purposes. Sunday strictly prohibits suppliers and their representatives from using Company-provided technology and systems to create, access, store, print, solicit or send any material that is intimidating, harassing, threatening, abusive, sexually explicit or otherwise offensive or inappropriate and/or send any false, derogatory or malicious communications using Company-provided information assets and systems.
- Speak to the press on Sunday’s behalf only if the supplier and/or representative is expressly authorised in writing to do so by Sunday’s Managing Director.
- Use good judgment, discretion and moderation when offering gifts or entertainment to Sunday employees. In any event, no supplier may ever offer a bribe, kickback, bartering arrangement for goods or services and/or any other incentive to a Company employee in order to obtain or retain Sunday business.
- Avoid the appearance of or actual improprieties or conflicts of interests. Suppliers or their representatives shall not deal directly with any Sunday employee whose spouse, domestic partner or other family member or relative holds a significant financial interest in the supplier. Dealing directly in the course of negotiating the supplier agreement or performing the supplier’s obligations with a spouse, domestic partner or other family member or relative who is employed by Sunday is also prohibited.
- Maintain insurance and provide evidence of such insurance, as requested, with the policies and at the levels required by the Company.
- Inform Sunday of any changes to the supplier’s tax status that may have an impact on Sunday or might mean that the supplier is no longer acting in accordance with applicable tax laws.
Privacy, security and data protection
Sunday suppliers shall maintain the privacy and security of any and all data or information the supplier creates, obtains, accesses, hosts, uses or receives from or on behalf of Sunday, or its clients, in the course of its performance of services (“Sunday data”) provided to Sunday, and its clients. In addition to any specific obligations under the supplier’s agreement with the Company, all suppliers shall, without limitation:
- Not disclose or transfer Sunday data to any third party without Sunday’s express prior written consent.
- Assist Sunday in meeting its obligations under data protection or privacy laws, including, but not limited to, notification of individual rights requests received, assistance with responding to such individual rights requests and assistance with any investigation by any law enforcement body or regulator, including a data protection or similar authority.
- Dispose of Sunday data no longer necessary to provide goods or services to Sunday.
- Immediately, and within 24 hours, notify Sunday of any actual or suspected privacy and/or security incident after becoming aware of the incident, including collaborating in investigation and remediation efforts, unless otherwise stated in the supplier’s agreement with the Company.
- Develop, implement, maintain, monitor and, where necessary, update a comprehensive written information security programme that contains appropriate administrative, technical and physical safeguards to protect Sunday data.
Sunday expects its suppliers to share its commitment to human rights and equal opportunity in the workplace. Sunday suppliers shall conduct their employment practices in full compliance with all applicable laws and regulations, and shall, without limitation:
- Cooperate with Sunday’s commitment to a workforce free of harassment and unlawful discrimination. While we recognise and respect cultural differences, we believe that supplier companies should not engage in discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership, political affiliation or any other category protected by applicable law.
- Provide a safe and healthy work environment and fully comply with all applicable safety and health laws, regulations and practices. Adequate steps shall be taken to minimise the causes of hazards inherent in the working environment. While in Sunday-owned, -leased or -managed property, suppliers shall comply with all rules and regulations concerning the operation of the property and the interaction with other individuals with access to the property, whether Sunday, its clients, or other suppliers, employees or guests.
- Prohibit the use, possession, distribution and sale of illegal drugs while on Sunday-owned, -leased or -managed property.
- Use only voluntary labour. The use of forced labour, whether in the form of indentured labour, bonded labour, prison labour, or any other behaviour constituting slavery or servitude by a Company supplier or its subcontractors is prohibited and engaging in or the use of human or labour trafficking by a Company Supplier or its subcontractors is prohibited.
- Workers should not be required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice without penalty.
- Comply with all local minimum working age laws and requirements and not utilise child labour. Employees shall not be under the legal minimum working age of the respective region or shall not be less than 16 years of age (whichever is higher). We only support the development of legitimate workplace apprenticeship programmes for the educational benefit of younger people and will not do business with those who abuse such systems.
- Not engage in physical discipline or abuse. Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation is prohibited.
- Pay living wages under humane conditions. All workers shall be provided with clear, written information about their employment conditions with respect to wages before they enter employment and as needed throughout their term of employment. Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the express permission of the worker concerned. All disciplinary measures should be recorded. Wages and benefits paid for a standard working week must meet, at a minimum, national legal standards.
- Not require workers to work more than the maximum hours of daily labour set by local laws and ensure that overtime is paid in accordance with local laws and regulations.
- Keep employee records in accordance with local and national regulations.
Sunday expects its suppliers to share the same social responsibility of growing business in a sustainable fashion. At Sunday, we believe that environmental stewardship and local business development are of utmost importance, and we constantly seek new ways to fulfil our responsibilities to the environment.
- Adopt an environmentally friendly policy and share our commitment to sustainability. Comply with all applicable environmental laws and regulations.
Supplier diversity practices
Sunday expects its suppliers to share its commitment to supplier diversity. Sunday suppliers shall implement supplier diversity programmes that provide opportunities for minority and women-owned suppliers.
- Cooperate with Sunday’s commitment to encourage and recognise joint ventures and subcontracting of work between majority suppliers and minority-owned and women-owned suppliers.
Compliance with this code of conduct
It is the responsibility of the supplier to ensure that its representatives understand and comply with the Sunday Code of Conduct and to inform its Sunday contact (or a member of Company management) if any situation develops that causes the supplier to operate in violation of the Code set forth in this document. Sunday suppliers are expected to self-monitor their compliance with this Supplier Code of Conduct. In addition to any other rights Sunday may have under its agreement with the supplier, Sunday may request the immediate removal of any representative who behaves in a manner that is unlawful or inconsistent with this Code or any Company policy. Sunday retains the rights to audit suppliers at its sole discretion.
Reporting of questionable behaviour or possible violations
If you wish to report a questionable behaviour or possible violation of this Supplier Code of Conduct, Sunday has a variety of resources available to assist you. You are encouraged to work with your primary Company contact in resolving a business practice or compliance concern. However, Sunday recognises that there may be times when this is not possible or appropriate. In such instances, please contact either of the following:
Sunday will not tolerate any retribution or retaliation taken against any individual who has in good faith sought out advice or has reported questionable behaviour or a possible violation.