Supplier Code of Conduct

1.0 Purpose

The purpose of the following document is to describe Novata’s expectations of its suppliers. This document focuses on the E, S, G elements and is a guiding document. It is not intended to be an exhaustive list of integrity expectations and ethics standards but serves as a good initial reference point of what is expected. The scope of this document applies to all suppliers that provide goods and services for Novata and suppliers are expected to adhere to this Code of Conduct when doing business with Novata and its employees.

2.0 Labour Rights & Employment Law

2.1 Business Integrity

Suppliers should not engage in any form of corruption, misrepresentation, embezzlement or bribery to obtain an unfair advantage when dealing with Novata. Gifts should not be given to employees of Novata with the intention of influencing or affecting their business judgment. 

Suppliers are expected to respect the intellectual property of Novata and its customers. All confidential information should thus be safeguarded.

Theme mapped to from UN Global Compact: Anti-Corruption

2.2 Wages and Benefits

Workers should be paid at least the local minimum wage and should be compensated for overtime appropriately as stipulated in local government policy. Suppliers should clearly communicate pay structure and terms to their workers. Novata believes that statutory-minimum wages do not always allow for a decent living, so strongly encourages its suppliers to pay a living wage.

Theme mapped to from UN Global Compact: Living Wage

2.3 Working Hours

Suppliers should ensure its workers are not exceeding the maximum working hours in their respective work jurisdictions and are being given appropriate breaks. For example, in the US, the Department of Labor states that workers may not be employed for more than 40 hours per week without receiving at least one and one-half times their regular rates of pay for the overtime hours. In the UK, the workweek should be restricted to 48 hours, including overtime, as per UK Government working time regulations except for emergencies or unusual circumstances.

Theme mapped to from UN Global Compact: Decent Work and Economic Growth

2.4 Child and Forced Labor

Novata mandates its suppliers to not use child labor. For Novata’s purposes, this will be defined as any person employed under the age of fourteen in line with policy developed by the US Department of Labor. The use of legitimate apprenticeship programmes, which are in line with US Government rules and regulations, is supported. Similarly, Novata expects suppliers not to use labor that is a result of mental or physical coercion, exploitation, or oppressive labor conditions. Suppliers and employees are prohibited from engaging in any form of human trafficking. 

Theme mapped to from UN Global Compact: Child Labor

2.5 Freedom of Association and Collective Bargaining

As legally permitted, suppliers shall respect the rights of workers to associate freely with one another and join or not join organizations of their choice. There should be no threat of discrimination, retaliation, or harassment with respect to freedom of association or collective bargaining. 

Theme mapped to from UN Global Compact: Rule of Law

2.6 Discrimination

No person should be treated differently based on their race, age, disability, genetic information, national origin, pregnancy, race, color, religion, sex, sexual orientation, gender, gender identity, political affiliation, or any other trait protected by law. This will extend to both hiring and ongoing employment practices. Suppliers should not require pregnancy tests, except where required by applicable laws or regulations

Theme mapped to from UN Global Compact: Gender Equality

2.7 Health and Safety

Suppliers should identify occupational and external hazards and have programs in place to actively prevent and mitigate these risks.

Suppliers must have procedures and systems in place that allow for the reporting of health and safety incidents. In addition, Novata stipulates that suppliers should have a system to investigate, classify, track, and manage the reports. The procedures and systems should consider all applicable laws and regulations. 

Theme mapped to from UN Global Compact: Occupational Safety and Health

3.0 Environment

3.1 Compliance with Environmental Laws

Suppliers should comply with all applicable environmental laws. Novata mandates that all relevant licenses, permits should be obtained and that its supplier should comply with expectations stemming from them. 

Themes mapped to from UN Global Compact: Environment and Governance

3.2 Waste and Emissions

Any wastes and emissions outputs stemming from work for Novata should be disposed of with care. The intention is to limit damage to the environment as much as possible. Suppliers must have the infrastructure in place for safe handling, storage, movement, management, and disposal of waste. 

Theme mapped to from UN Global Compact: Water and Sanitation

3.3 Sustainability and Efficiency of Resources

Suppliers should optimize their use of all inputs/resources, including being environmentally friendly and abstracting from waste as much as possible. This will pertain to (among other things) energy, water, and materials. Suppliers should strive to track data on CO2 emissions and water usage, and aspire to set targets that benefit society and the public good.

Furthermore, Novata expects its suppliers to strive to improve performance where possible (as expected by industry standards).

Themes mapped to from UN Global Compact: Supply Chain Sustainability and Governance

3.4 Environmental Consideration in Business Decision-Making

The suppliers should have in place a process that considers the environmental impact of all purchasing and spending decisions. Where possible, resources should be allocated towards the more environmentally beneficial option.

Theme mapped to from UN Global Compact: Corporate Goal Setting

4.0 Management Systems

4.1 Documents, Audits and Assessments

Novata expects its suppliers to maintain documents and records for regulatory compliance. Accordingly, suppliers shall have the processes in place for timely corrections of any oversights as identified by audit, inspection, investigation, or review. 

Theme mapped to from UN Global Compact: Rule of Law

4.2 Reporting Violations

Novata expects its suppliers to be good custodians of society. Any behavior that has potential to harm Novata’s reputation  should be promptly reported and the supplier should have an appropriate plan of action in place to remedy the issue. 

Theme mapped to from UN Global Compact: Rule of Law