Wild Circle Dynamics LTD is committed to doing business ethically, legally and responsibly. This Supplier Code of Conduct sets out the minimum standards we expect from our suppliers, contractors, consultants, agents and other business partners. By doing business with us, suppliers agree to comply with this Code, applicable laws and internationally recognised standards of responsible business conduct.
1. Purpose and scope
This Code applies to all suppliers and business partners that provide goods or services to Wild Circle Dynamics LTD, including direct and indirect suppliers, subcontractors, freelancers and intermediaries. Suppliers are expected to communicate the principles of this Code to their own employees, subcontractors and suppliers.
2. Legal compliance
Suppliers must comply with all applicable laws, regulations and legal requirements in the jurisdictions where they operate. This includes, but is not limited to, laws relating to:
- employment, labour and human rights;
- health, safety and the environment;
- data protection and privacy;
- anti-bribery, anti-corruption and fraud prevention;
- competition and trade practices;
- tax, customs and sanctions;
- intellectual property and confidentiality.
3. Forced labour and human trafficking
Suppliers must not use forced, bonded, indentured, trafficked or involuntary labour of any kind. All work must be voluntary. Workers must be free to leave employment after reasonable notice and must not be required to surrender identity documents, pay recruitment fees or be subject to unreasonable restrictions on their movement.
4. Child labour
Suppliers must not employ children below the minimum legal working age or below the age for completing compulsory education, whichever is higher. Young workers must not be exposed to hazardous working conditions and must have access to education where required by law.
5. Wages, benefits and working hours
Suppliers must pay workers at least the minimum wage required by law or the prevailing industry standard, whichever is higher. Wages must be paid regularly, on time and in a transparent manner. Suppliers must comply with legal requirements relating to working hours, overtime, rest days and holiday entitlement. Overtime must be voluntary and compensated in accordance with applicable law.
6. Freedom of association and collective bargaining
Suppliers must respect workers' rights to freedom of association, collective bargaining and the peaceful assembly permitted under applicable law. Workers should be able to raise workplace concerns without fear of harassment, intimidation, retaliation or discrimination.
7. Non-discrimination and respect
Suppliers must provide a workplace free from discrimination, harassment and abuse. Employment decisions must be based on merit, qualifications and performance, and not on characteristics such as race, colour, nationality, ethnic origin, gender, age, disability, religion, sexual orientation, marital status, pregnancy, trade union membership or political opinion.
8. Health and safety
Suppliers must provide a safe and healthy working environment, including:
- safe buildings, equipment, machinery and work practices;
- appropriate personal protective equipment where required;
- training on health and safety risks and emergency procedures;
- access to clean drinking water, sanitation and first aid;
- measures to prevent accidents, injuries and occupational illness;
- compliance with applicable fire safety and building regulations.
9. Anti-bribery and corruption
Suppliers must comply with the Bribery Act 2010 and all other applicable anti-bribery and anti-corruption laws. Suppliers must not offer, promise, give, authorise or accept bribes, kickbacks, improper gifts, hospitality or any other unlawful advantage. All business dealings must be transparent, fair and accurately recorded.
10. Gifts, hospitality and conflicts of interest
Suppliers must not offer gifts, hospitality or other benefits to Wild Circle Dynamics LTD staff that could influence business decisions or create the appearance of impropriety. Suppliers must disclose any actual or potential conflicts of interest that could affect their relationship with us.
11. Data protection and confidentiality
Suppliers that handle personal data, confidential information or intellectual property belonging to Wild Circle Dynamics LTD or our customers must protect it in accordance with applicable data protection laws, including the UK GDPR and the Data Protection Act 2018. Suppliers must:
- process personal data only for the purposes specified by us;
- implement appropriate technical and organisational security measures;
- restrict access to authorised personnel on a need-to-know basis;
- notify us promptly of any actual or suspected data breach;
- return or securely delete all confidential information upon termination of the relationship;
- not use or disclose confidential information except as necessary to perform the contract.
12. Financial integrity and transparency
Suppliers must maintain accurate and complete books and records relating to their business and transactions with us. Suppliers must be transparent about their ownership, structure and beneficial owners where required. We do not engage in transactions that conceal the true nature of payments or that facilitate tax evasion.
13. Sanctions and trade controls
Suppliers must comply with applicable sanctions, export controls and trade restrictions. Suppliers must not use Wild Circle Dynamics LTD funds, goods, services or technology for activities that are prohibited by UK, EU, UN, US or other applicable sanctions regimes.
14. Environmental responsibility
Suppliers should operate in an environmentally responsible manner, comply with environmental laws and regulations, and strive to reduce their environmental impact. This includes minimising waste, conserving energy and water, reducing emissions and using resources efficiently. Suppliers should maintain appropriate environmental permits and licences where required.
15. Quality and delivery
Suppliers must deliver goods and services that meet the agreed specifications, quality standards and timelines. Suppliers should have effective quality management processes, communicate proactively about risks or delays, and cooperate with our reasonable requests for information and performance review.
16. Subcontractors and supply chain
Suppliers are responsible for ensuring that their subcontractors, agents and lower-tier suppliers comply with the standards set out in this Code. We may require suppliers to disclose information about their subcontractors and to flow down equivalent requirements throughout their supply chain.
17. Monitoring and audit rights
We reserve the right to monitor supplier compliance with this Code through self-assessments, questionnaires, audits and site visits where appropriate. Suppliers must cooperate with reasonable requests for information and provide access to relevant records, facilities and personnel.
18. Reporting concerns
Suppliers and their workers are encouraged to report any actual or suspected violations of this Code or applicable law. Reports can be made confidentially by email toinfo@wildcircledynamicsltd.com or through our Speak Up Policy. We will not retaliate against anyone who reports a concern in good faith.
19. Consequences of non-compliance
Failure to comply with this Code may result in:
- a request for a corrective action plan within a specified timeframe;
- enhanced monitoring, audits or inspections;
- suspension of orders or delivery of services;
- termination of the business relationship;
- legal action to recover losses or enforce contractual rights;
- reporting to relevant authorities where required by law.
20. Code review
We may update this Supplier Code of Conduct from time to time to reflect changes in law, industry standards or our business requirements. The latest version will be published on our website.
21. Contact
Wild Circle Dynamics LTD
71-75 Shelton Street, Covent Garden, London, WC2H 9JQ, United Kingdom
Company number: 17371923
Email: info@wildcircledynamicsltd.com