Supplier Code of Conduct
Principles
At Schroders, we are committed to our values of excellence, innovation, teamwork, passion and integrity. These are the guiding principles that everyone at Schroders uses to navigate the investment world and deliver value to our clients. Our values define our reputation; determine the behaviours we expect of our employees and shape how we do business.
Schroders aims to work with suppliers who align with our values and support our goals. We expect our suppliers and their subcontractors to adhere to all relevant legislation and to act responsibly, fairly, ethically and safely at all times. These principles form an integral part of our sourcing activities and decisions.
Our Supplier Code of Conduct sets out the behaviours and minimum standards we expect from our third-party suppliers and their subcontractors.
Legal and Regulatory Standards
We require our suppliers and their subcontractors to comply with all laws and regulations applicable to our business in the countries in which they operate and seek commitments from their own supply chain to also meet this requirement.
Human rights, ethical behaviour and business transparency
Schroders enters into relationships based on the principle of fair, open and honest dealings at all times. This is whether in our role as an employer, as a buyer of goods and services or when carrying out our fiduciary duties as a provider of financial services and an investor in companies. We expect all our suppliers and their subcontractors to operate in a responsible, ethical, and transparent way whilst maintaining standards that reflect our commitment to accountability, respect and good governance
Schroders is committed to upholding all laws relating to the protection of human rights including, but not limited to, the UN’s Universal Declaration of Human Rights (UDHR)[1]. In line with our Group Human Rights Position Statement and annual Modern Slavery Statement we are committed to respecting and upholding the human dignity and fair treatment of all those individuals within our supply chain and addressing human rights and addressing any human rights violations (including slavery and human trafficking) found in any part of our supply chain.
We expect our suppliers and their subcontractors to:
- Commit to transparency and disclosure of relevant social, environmental and governance information upon request. Where potential risks or concerns are identified, suppliers / subcontractors must fully cooperate with Schroders in any investigation or further enhanced assessments.
- Have policies in place that require their employees to adhere to all relevant regulation and legislation acting ethically and with integrity.
- Treat their own employees fairly and ethically, providing a safe and hygienic workplace, free from bullying, harassment or discrimination.
- Support and encourage freedom of association and collective bargaining[2] in line with local regulations.
- Demonstrate the procedure(s) in place and actions taken to identify, prevent and mitigate human rights violations such as modern slavery (including forced or child labour and human trafficking) in their operations and supply chain, notifying Schroders of any identified concerns using the whistleblowing service, Safecall (section 6).
We encourage our suppliers and their subcontractors to provide training on worker welfare in proportion to the scale and nature of their operations.
Inclusion, diversity and fair wages
At Schroders, we are focused on delivering excellence, supported by a high-performing, client-centric culture. We believe diverse talent empowered in an inclusive environment will help us achieve this aim as it allows all our people to thrive, helps drive innovation, and ensures resonance with all our clients across the globe. In seeking excellence, we are a proud equal opportunities employer. We are focused on developing talent and having the right people in the right roles. A commitment to fair treatment is reflected throughout our people processes, from recruitment, progression to pay determination. We believe in fair pay for performance, providing a good work environment that prioritises wellbeing, and providing personal growth opportunities. This helps us attract and retain exceptional employees. We are accredited living wage employers in both the United Kingdom (UK) and the United States of America (USA) and pay at least 10% above the minimum wage in all our locations globally.
We expect our suppliers and their subcontractors to:
- Abide by all relevant equality legislation in the countries in which they operate
- Be transparent, fair and consistent through any employment or hiring practices, ensuring there is no discrimination on the basis of age, sex or sexual orientation, gender identity, disability, origin, race, colour, religion or belief
- Embrace diversity, fairness and inclusion in their workforce/workplace, free from discrimination
- Comply with all applicable wage and working regulations and encourage suppliers to go beyond compliance with local minimum wages and, where applicable, pay a living wage to all direct employees and contractors. We also encourage our suppliers to support the adoption of the local living wage throughout its supply chain
We will not tolerate harassment or discrimination in our working environment including that of our suppliers or their subcontractors. When working at and for Schroders, if suppliers or their subcontractors experience or witness any discriminatory actions or comments, we encourage these to be reported using the whistleblowing process detailed in section 6 below.
Health and safety
Schroders is committed to ensuring all employees and on-site suppliers to Schroders are provided with a safe working environment which meets the requirements of all local legislation globally.
We expect our suppliers and their subcontractors to provide a safe and healthy working environment for their employees which meets the requirements of all applicable occupational health and safety regulations and to abide by all local laws and regulations.
Where suppliers or their subcontractors are working on our site with our equipment, we expect them to comply with all health and safety training and guidance issued and to help maintain a safe working environment by reporting any issues promptly. Suppliers or their subcontractors delivering a service using their own equipment, or servicing on-site equipment, must provide appropriate documentation in advance, for review and approval, to demonstrate how the health and safety issues of the task will be managed and how the safety of our staff and the premises will be maintained.
Suppliers and their subcontractors should ensure their employees receive the appropriate safety instruction and training to keep them safe and well in the workplace and have business management practices in place
to address:
- Health and Safety policy creation, implementation and assurance.
- Hazard identification, risk assessments and relevant procedures
- Fire safety, emergency evacuation and any other relevant emergency procedures
- First aid and accident reporting procedures
- Ergonomics and manual handling procedures where required
- Adequate training to ensure they are competent for the tasks they need to perform in their role
Whistleblowing
Honesty and integrity are deeply ingrained in our culture, and it is everyone's responsibility to ensure that this remains the case. Like all organisations, we face the risk of things going wrong or of unknowingly harbouring illegal or unethical behaviour.
We believe that it is important that our employees, suppliers and any third party can raise any issues or concerns, with confidence that all reports will be taken seriously and investigated fully. We provide everyone access to our global reporting service, Safecall.
Safecall global reporting service
If you suspect wrongdoing, impropriety, unethical behaviour or have concerns regarding Schroders’ business practices or the business practices related to the product or service provided to Schroders, you may raise them confidentially and anonymously via the online portal or 24 hour phone Line. Reports can be made in local languages as well as English and Schroders will receive an anonymous summary of issues raised to address the concerns appropriately.
Climate and environment stewardship
We believe in leading by example; by managing and reducing the climate impact we have as a business. We have embarked on an ambitious plan to improve our own environmental performance, and in the process, engage our people and suppliers to support our climate goals.
In 2021, Schroders made the commitment that 67% of its supply chain, by emissions, will have set science-based targets by 2026. We actively monitor progress against this target and, to support its achievement, we expect all suppliers to:
- Comply with all applicable local and national environmental legislation and regulations
- Maintain policies to support effective environmental management
- Collaborate with their supply chain to minimise the environmental impact of the goods and services they provide, including reducing emissions, energy use and waste
- Minimise waste through recycling and responsible disposal practices, thereby supporting a circular economy
If not already in place, all suppliers are expected to develop the means to measure and report, at a minimum, their Scope 1 and Scope 2 greenhouse gas emissions, establish an emissions reduction plan and provide updates on their progress to Schroders, as requested. Where suppliers may lack immediate capacity or expertise in this area, Schroders can provide guidance to support the implementation of effective data collection, reporting and management processes.
Schroders recognises that certain suppliers have a greater potential to influence Schroders overall environmental impact. Schroders will identify these suppliers and communicate enhanced expectations proportionate to their impact, such as setting science-based carbon reduction targets. Where appropriate, these expectations will be formally set out through contractual provisions or other formal communications.
Financial Crime
Schroders expects its suppliers and their subcontractors to operate with integrity, comply with the UK Bribery Act 2010, the UK Criminal Finances Act 2017, UK Proceeds of Crime Act 2002, the UK Money Laundering Regulations, the UK Economic Crime and Transparency Act 2023, and UK, (UN), European Union and US sanctions. Our suppliers and their subcontractors should have policies in place to prevent fraud, bribery and corruption, market abuse, money laundering, tax evasion and any other improper payments, or inducements within their businesses, and seek to work only with suppliers that demonstrate similar commitments. Suppliers or their subcontractors must not directly or indirectly offer improper payments or inducements to Schroders employees that may give rise to actual, potential, or perceived conflicts of interest, or engage in any other unethical behaviour.
Confidential information
Schroders expects any information received by a supplier from Schroders to be held securely with appropriate technical and organisational security in place to safeguard that information to ensure there is no disclosure of the data to any other party without our permission including subcontractors.
Data protection
Schroders expects suppliers and their subcontractors to comply with all applicable data protection requirements. Where a supplier or subcontractor is processing personal data on Schroders’ behalf, the supplier or subcontractor must enter into appropriate contractual terms governing such data processing (including, among other things, in relation to appointment of sub-processors, audit rights and transfers of personal data outside the UK or European Economic Area (EEA)), in each case as required by applicable data protection laws.
Physical security
Schroders expects suppliers and their subcontractors to maintain appropriate physical security arrangements. Suppliers’ personnel with access to Schroders’ premises must:
- Be screened by the supplier prior to access being granted. This must include (where legally permissible): ID verification; Right to Work Check; Proof of Current Address; and a Criminal Record Check. For specific roles Schroders may additionally require a check of employment history and qualifications
- Take responsibility for their own personal safety and take reasonable steps to safeguard the physical security of assets and information for which they are responsible, both in the office and whenworking remotely
- Ensure that all business paperwork (including confidential papers and other working papers) and valuable or attractive items are removed from desks and put in appropriate overnight storage, secured under lock and key
- Ensure that building access credentials (e.g. pass, key, fob, alarm code) are secure at all times and are not shared; any lost access credentials must be reported promptly. Be aware of unauthorised individuals attempting to tailgate through Schroders’ access control and report such incidences immediately
- Be responsible for the safety and security of any visitors they are hosting in Schroders’ offices and ensure the timely return of any issued visitor pass
- Report security incidents to their line manager and local security administrator at the earliest opportunity
Acceptable use policy
Suppliers or their subcontractors who have access to a Schroders IT network will be asked to attest to the principles of our Acceptable Use policy. This policy sets out individuals’ responsibilities in relation to the security and use of:
- Schroders’ information: in whatever form, relating to Schroders’ business activities globally, and to all information handled by Schroders relating to organisations with whom we deal
- Information systems and information communications facilities operated by Schroders or on our behalf, including the use of messaging, internet, voice, and mobile IT equipment
Suppliers who do not have access to our network, but are hosting Schroders data externally, or send data to us may be subject to an annual security review.
Compliance and measurement
Suppliers must be able to demonstrate compliance with Schroders’ Supplier Code of Conduct. Such compliance includes documented evidence and cooperation, upon reasonable notice, with any certification activity to demonstrate compliance with the Code Schroders undertakes.
Where local laws and regulations do not meet the same standards as Schroders Supplier Code of Conduct, Schroders terms take precedence where they do not incur a breach of such local regulation.
Supplier adherence and commitment to this Code of Conduct forms an integral part of Schroders sourcing and monitoring activity and is used along with all other relevant decision criteria when (i) selecting new suppliers; (ii) renewing current contractual relationships; or (iii) monitoring incumbent supplier relationships. In addition, failure to comply with our Supplier Code of Conduct and/or local laws and regulation may result in termination as a Schroders supplier.
To download our Supplier Code of Conduct in full, please click here.
Should you have any questions regarding this Code of Conduct please contact:
Craig Hill
Chief Procurement Officer