Suppliers’ Code of Conduct Policy

At Intersys we expect the same high ethical standards and commitments to sustainability within our supply base that we apply to ourselves. The intent of this policy is to ensure that all suppliers working for Intersys are informed of our requirements and are able to demonstrate their plans to achieve them on request.

This policy does not cover the Cyber Security and Data Protection standards that we expect of our suppliers; those requirements are detailed in our ISO 27001 Supplier Management Policy.

This policy applies to all suppliers identified by Intersys’ Supplier Management Policy as key or critical to the business.

In the event that there is any conflict between the requirements of this policy and commercial terms agreed between Intersys and the Supplier, then the terms of commercial agreement will take precedence.

This policy aims to help Intersys’ suppliers understand the importance of providing services, hardware and products that comply with our requirements. This document sets out the minimum standards for compliance. In cases where suppliers cannot satisfy those requirements, an improvement plan will be agreed to map out a path to compliance.

Suppliers must also comply with all applicable standards, regulations and directives relevant to the products and services supplied to Intersys.

Where specified in contracts, Intersys will retain the right to audit suppliers in order to verify compliance.

Environmental care – in accordance with our Environmental Policy Statement, Intersys is committed to reducing any negative impact on the environment and making positive contributions to the world around us. From a supplier perspective, this includes requiring suppliers to:

- Comply with all environmental laws, regulations and codes of practice relevant to the industry sectors in which we operate. As a minimum, we expect our suppliers to comply with the UK Environment Act 2021.

- Follow energy efficient practices, with respect to their premises, equipment and transportation practices.

- Offset carbon footprints with reputable schemes.

- Encourage members of staff to use public transport and remote working.

- Comply with the Waste Electrical and Electronic Equipment Directive (WEEE).

Compliance with all applicable laws and regulations is mandatory. Suppliers must operate within the legal frameworks of the jurisdictions in which they operate, including adherence to the Companies Act 2006.

Anti-Bribery & Corruption; Suppliers must adhere to the highest ethical standards, including strict anti-bribery and anti-corruption policies. It is essential to prevent any form of bribery, corruption, or unethical conduct in all business dealings. Suppliers should implement robust internal controls and training programs to ensure compliance with relevant anti-bribery laws and regulations, such as the UK Bribery Act 2010.

Corporate Hospitality: Intersys’ own policy defines Corporate Hospitality as hospitality or gifts of any kind provided by Intersys or its staff to individuals who are not employees of the company, in connection with the lawful business of Intersys. It requires advanced approval of any significant corporate hospitality expenses. It also covers receiving corporate hospitality from customers, client, suppliers or contractors. We expect equivalent standards of internal control from our suppliers including ensuring that any gifts and hospitality is lawful and consistent with reasonable marketplace customs and practices.

Donations: Suppliers shall avoid any political contributions, charitable donations, or sponsorships that would aim at or give the appearance of aiming at gaining an unfair competitive advantage or exercising improper influence.

Conflicts of Interest; Suppliers must avoid any actions or decisions that could lead to conflicts of interest. Any potential conflict should be disclosed immediately, ensuring it does not compromise the integrity of business operations. By maintaining transparency and impartiality, suppliers can ensure trust and fairness in their dealings with us and other stakeholders.

Anti-Trust & Competition Laws: Suppliers are required to adhere to anti-trust and other competition laws.

Foreign Trade/Sanctions: Suppliers must adhere to applicable national and international foreign trade control laws pertaining to business transactions with countries, companies and persons (sanctions), and the transfer of goods and services, software or technology between countries (export controls).

Intersys’ Suppliers are required to respect all applicable laws, regulations and international standards related to labour practices and protection of human rights.

Health & Safety. In its Health and Safety Policy, Intersys recognises its duty to protect the health and safety of contractors.

Suppliers must adhere to strict health and safety regulations, such as the Health and Safety at Work etc. Act 1974, providing a safe working environment that prevents accidents and harm. Regular training, risk assessments, and safety audits should be conducted to ensure ongoing compliance with the law.

Employment Conditions: Suppliers are expected to treat all employees with dignity and respect, ensuring fair employment practices. This includes fair wages, working hours, and conditions aligned with legal requirements and international standards. Human rights must be upheld in all business operations, protecting workers' rights in accordance with the UK Human Rights Act 1998. Suppliers shall establish and enforce fair disciplinary, grievance and termination procedures.

Equal opportunities. In its Equal Opportunities Policy, Intersys commits to being an equal opportunity employer, including its contractors. Suppliers must embrace equal opportunity policies, prohibiting discrimination based on race, gender, age, religion, disability, or any other protected characteristic as outlined in the Equality Act 2010. A diverse workforce should be fostered and maintained.

Modern Slavery which includes Human Trafficking, Forced or coerced labour. Intersys commits to complying with its own Modern Slavery Policy statement which states that Intersys will not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

Child labour: Child labour is prohibited within Intersys’ supply chain. Suppliers must ensure that no underage workers are employed, following international labour standards such as the ILO conventions and local child labour laws. Regular audits and age verification processes should be in place to prevent exploitation and ensure compliance with legal standards.

Suppliers shall take due care to ensure their work product meets Intersys’ quality standards and specifications.

Strict Financial Controls: Suppliers must maintain strict financial controls, ensuring transparency, accuracy, and integrity in financial reporting. Regular audits and financial reviews should be conducted, in line with the UK Companies Act 2006 requirements.

Due Diligence: Processes must be in place to evaluate and manage risks associated with suppliers' operations and supply chains, ensuring compliance with all relevant standards and regulations.

As part of our due diligence processes, we run supplier and client credit checks which include Directors’ histories. We do not engage with business owners who repeatedly liquidate businesses in order to avoid debts.

The underlying objective of this Policy is to establish a basis for positive development of responsible procurement practices through regular dialogues and ongoing working relationships. Failure to observe the requirements of this Policy will be reported to the supplier’s management for their attention and, if necessary, for corrective action. Furthermore, non-compliance may be considered a material breach of the agreement with the supplier and may lead to termination of the agreement with the supplier