Supplier Code of Conduct

Supplier Code of

Conduct

Issued March 2011; Updated May 2018; Updated November 2018; Updated April 2020 1

Background: Our purpose is to build a better working world. To stay true to that purpose, we will continue to

enhance the way we engage with our suppliers to encourage the continual improvement of the way we, and our

supplier base, address and manage important issues. Our revised expectations and minimum standards within the

enclosed document are the product of not only the increasing regulatory environment globally with respect to

particular issues, but also the increasing expectations of our clients and the wider community.

EY Organizations (EY) values our supplier relationships and is committed to working with, and supporting, our

suppliers to achieve mutual objectives. A supplier’s performance and adherence to high business standards is an

important and integral part of the value chain for EY. EY promotes and expects the application of high legal,

ethical, environmental and employee-related standards within our own business and among our suppliers.

Our commitment to integrity and professionalism is set forth in our Global Code of Conduct, which provides a clear

set of standards for all of our business conduct. Our Global Code of Conduct can be found on ey.com. We believe

that deviations from, or violations of, the Global Code of Conduct are unacceptable, and that our clients or

suppliers should feel able to raise issues without any fear of retaliation or discrimination. To that end, we provide

an ethics hotline to deal with sensitive ethical issues.

This Supplier Code of Conduct sets forth the minimum standards of business conduct that we expect from all of our

suppliers:

1. Compliance with laws: Suppliers shall comply fully with all laws and regulations applicable to them.

2. Environmental sustainability: EY expects its suppliers to demonstrate a clear understanding of the

environmental risks, impacts and responsibilities associated with the products and services they provide:

2.1 Suppliers should have in place an effective environmental policy, statement or program to mitigate

environmental risks, the implementation of which should be evident throughout all levels of the company.

2.2 Suppliers should have processes in place to ensure that their operations conform to all applicable

environmental legislation. All required environmental permits, approvals and registrations are to be obtained,

maintained and complied with in accordance with the conditions and requirements defined therein.

2.3 Environmental performance should be measured, monitored and reviewed regularly. The supplier should

endeavor to make continuous improvements in environmental performance through practicable measures and

employ leading practices where possible.

2.4 Suppliers should make practical efforts to minimize the use of energy, water and raw materials. Where

possible, these should be renewable or sustainably sourced.

2.5 Emissions to air that are likely to cause pollution or contribute to climate change should be monitored,

controlled and minimized where possible.

2.6 Suppliers shall make practical efforts to eliminate or reduce levels of generated waste and should reuse

and recycle waste materials wherever possible. The handling, storage, movement, treatment and disposal of

all waste must be carried out in accordance with applicable regulations and in an environmentally responsible

manner.

2.7 Suppliers should consider the environmental credentials and performance of vendors within their own

supply chain and require them to operate to a minimum set of standards.

Issued March 2011; Updated May 2018; Updated November 2018; Updated April 2020 2

2.8 Products and services provided to EY should include options that offer reduced environmental impact by

utilizing environmentally sound technologies, processes and sustainable materials, etc.

3. Human rights and social sustainability: Policies should be in place to confirm the supplier’s commitment to

points 3.1—3.12, and improvement programs should be in place where relevant:

3.1 Freedom from forced labor, bonded labor and human trafficking:

• All employment shall be freely chosen by the worker. Workers shall be free to leave their employment at

any time (subject to reasonable and paid notice periods) and shall not be subject to any coercion or

restriction through, for example, the holding of original copies of employee passports, identity documents

or monetary deposits.

• There shall not be any use of bonded labor. Work must be undertaken for fair compensation and must not

be undertaken to repay a debt incurred (i.e., as a result of deceptive recruiting practices).

3.2 Recruitment agencies: Where recruitment agencies/brokers are used by the supplier, appropriate due

diligence and ongoing management must be undertaken to ensure that risks of worker exploitation, such as

debt bondage, are effectively mitigated. Reasonable evidence of these activities is to be available to EY upon

request, within a reasonable notice period.

3.3 Child labor: Suppliers should adhere to local laws relating to the minimum working age and not engage in

the employment of child labor, directly or indirectly. According to the International Labour Organization (ILO)

minimum age convention (C138) of 1973, child labor refers to any work performed by children under the age

of 12, non-light work done by children aged 12—14 and hazardous work done by children aged 15—17.

Suppliers should also ensure that working hours for those of school age are not exceeding the maximum hours

on a school day. In cases where child labor is found, programs should be in place to support the child into

education.

3.4 Wages and benefits: At a minimum, the legal minimum wage standard must be adhered to across the

entire workforce, employees should receive clear information on their wages, and unfair deductions from

wages as a disciplinary measure are not permitted.

3.5 Working hours: Working hours must be limited according to national or local law, including breaks.

Overtime should be voluntary, should not replace regular employment and must be fairly compensated.

3.6 Freedom of association, collective bargaining or parallel means: Employees have the right to join or form a

trade union without facing discrimination or intimidation. Where freedom of association and collective

bargaining is restricted under law, employees should have the right to develop parallel means.

3.7 Health and safety and working conditions: A safe and hygienic working environment should be provided

with an awareness of any industry-specific hazards. Relevant training should be provided to employees.

3.8 Regular employment: All employees should be provided with a written employment contract setting out

their terms and conditions in accordance with the local relevant legal jurisdiction. We expect all employment

and the termination of employment to be carried out in a fair manner.

3.9 No harsh or inhumane treatment: Abuse, threat of abuse, and sexual or other harassment or intimidation

should be prohibited by suppliers. Suppliers shall make available to all workers within their operations and

supply chain a mechanism for which grievances relating to labor practices can be anonymously raised, without

fear of retribution. Suppliers shall investigate and take appropriate action to remedy all grievances raised.

Issued March 2011; Updated May 2018; Updated November 2018; Updated April 2020 3

3.10 Subcontracting: Where authorized subcontracting is used to support the execution of services for EY,

the supplier shall confirm that the subcontractor meets the minimum expectations set out in Section 3 of this

document through the following controls:

• Supplier shall take necessary steps to obtain and maintain visibility over labor rights risks within the

operations and supply chains of subcontractors.

• Supplier shall attain the right to audit over subcontractor operations.

• Records of audits undertaken of subcontractors shall be available on request.

• Supplier shall have written agreements in place with subcontractors to ensure that any further

subcontracting by the subcontractor company (a) is authorized and (b) meets the standards set out in this

document.

3.11 Right to audit: Suppliers shall attain the right to audit over their suppliers to assess the working

conditions and extent to which workers’ labor rights are being upheld. Records of audits undertaken of the

suppliers’ supply chain shall be available on request.

3.12 Incident response: Suppliers shall take the following actions, at a minimum, when an incident of forced

labor, bonded labor, human trafficking or child labor is identified:

• Disclosing the incident/high risk to relevant authorities

• Disclosing the incident/high risk to EY

Taking appropriate actions to remedy the incident

3.13 Demonstration of reasonable modern slavery due diligence: EY expects that our suppliers will maintain

an active view on the inherent risk of modern slavery in their supply chain (this includes third-party

certifications in relation to human rights and social compliance standards). Among other modes of inquiry, we

would expect this to include engaging human rights specialists to perform validation audits of high-risk

suppliers on an intermittent, but no less than annual, basis.

In addition to the above minimum requirements, the supplier shall define a minimum standard of human

rights that applies across all jurisdictions and demonstrate how compliance to this is encouraged and

observed. Such standards should refer to, at a minimum, the UN Guiding Principles on Business and Human

Rights.

4. Diversity and inclusiveness: Our sourcing decisions, contracts and management of supplier relationships will

reflect and promote the principles of the EY Diversity and Inclusiveness policy (incorporating equal

opportunities) in that they will seek to ensure that suppliers do not victimize, harass or discriminate against

any employee or party to the contract due to their sex, gender identity/expression, marital or civil partnership

status, race, ethnicity or national origin, disability, religion, sexual orientation, age or part-time status.

Suppliers will be required to meet the requirements of any applicable discrimination legislation. Our suppliers

will be treated fairly and equally during the tendering and purchasing process, with decisions made on the

basis of clear selection criteria:

4.1 EY expects suppliers to have a policy in place to consider usability by, and inclusion of, individuals with

disabilities when designing products and/or delivering services to EY. As part of the policy, there are

accessibility standards and/or processes in place that conform to disability guidelines when suppliers are

designing products and/or delivering services.

4.2 EY expects suppliers to have a policy that explicitly bans discrimination/bullying and harassment based on

sexual orientation, race, gender or gender identity/expression. In addition, suppliers are also encouraged to

have evidence of diversity and inclusiveness training that is inclusive of sexual orientation and gender

identity/expression.

Issued March 2011; Updated May 2018; Updated November 2018; Updated April 2020 4

4.3 Our Inclusive Procurement strategy’s key objective is to identify, develop and utilize certified diverse

businesses (defined below) that can enhance our competitive advantage and provide innovative and cost-

effective products and services for us and our clients. It is our expectation that all suppliers use their best

efforts themselves to procure diverse businesses to compete for goods and services to become preferred

suppliers to the supplier and/or as its subcontractor(s). In accordance with the terms of its agreement with an

EY entity, suppliers commit to comply with all relevant regulatory agency requirements, as well as with any

local diversity regulations and programs.

4.4 For the purposes of this Supplier Code of Conduct, a “diverse business” is a company that is certified to be

at least 51%-owned, -operated and -controlled by one or more minority, woman, LGBT+ person, person with a

disability, veteran, service-disabled veteran, or aboriginal or indigenous person. In addition, historically

underutilized business and social enterprises as defined by the local country will be included in the diverse-

business classification.

4.5 It is our commitment that diverse business enterprises shall have equal opportunity to compete for all

goods and services to become preferred suppliers and/or subcontractor(s) for the organization. EY is

committed to the development and growth of diverse business enterprises to build a better working world and

to expand networks to build trusted and enriched relationships.

4.6 EY expects suppliers to have equivalent policies to promote diversity in their supply chains and purchase

from diverse businesses. Suppliers agree to make a reasonable effort to utilize diverse suppliers and provide

evidence to EY upon request.

5. Ethics: The highest standard of integrity is expected in all of our business dealings. Any and all forms of

corruption, extortion, bribery (including facilitation payments), and embezzlement are strictly prohibited and

may result in immediate termination and legal action:

5.1 Suppliers will not offer or provide money or anything of value to any person if the circumstances indicate

that it is probable that all or part of the money or other thing of value is being given to another individual or

entity to influence official action or to obtain a business advantage.

5.2 Suppliers are expected to understand relevant EY gift and hospitality policies before offering or providing

EY personnel with any gift and/or business entertainment. Gifts or entertainment should never be offered to

EY personnel or representatives under circumstances that create the appearance of impropriety.

5.3 Suppliers must comply with all applicable trade control laws and regulations in the import, export,

re-export or transfer of goods and services (including software and technology). All invoices and any customs

or similar documentation submitted to EY or governmental authorities in connection with transactions

involving EY must accurately describe the goods and services provided and the price thereof.

5.4 Suppliers shall not share or exchange any prices, costs or other competitive information, or undertaking of

any collusive conduct with any other third party to EY with respect to any proposed, pending or current EY

procurement.

5.5 Suppliers will use only subcontractors or other third parties who comply with all applicable laws and

regulations, and who adhere to the same (minimum) standards set forth in this guide.

6. Monitoring: EY may conduct annual compliance surveys to confirm compliance with this Supplier Code of

Conduct. However, EY expects that suppliers will actively audit and monitor their day-to-day management

processes with respect to the EY Code of Conduct and provide evidence to EY upon request.

EY | Assurance | Tax | Transactions | Advisory

About EY

EY is a global leader in assurance, tax, transaction and advisory services. The insights and quality services we deliver help

build trust and confidence in the capital markets and in economies the world over. We develop outstanding leaders who

team to deliver on our promises to all of our stakeholders. In so doing, we play a critical role in building a better working

world for our people, for our clients and for our communities.

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organization, please visit ey.com.

EYG no. 002141-20Gbl

This material has been prepared for general informational

purposes only and is not intended to be relied upon as accounting,

tax or other professional advice. Please refer to your advisors for

specific advice.

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