Background

XTEL and its companies operate in many markets and countries throughout the world. In all instances, we respect national laws and any other laws with an international reach, such as the UK Bribery Act, the US Foreign Corrupt Practices Act and the UK Modern Slavery Act, where relevant, and industry codes of conduct. We are committed to acting ethically in all aspects of our business and to maintaining the highest standards of honesty and integrity.

Our Expectations

We expect and require all our business partners, including suppliers, to have the same commitment to ethical behaviour and therefore ask you to confirm your agreement with our Code of Business Conduct (in the first column) as amended where necessary for non- XTEL entities (in the second column).

We expect all our suppliers to use appropriate systems to facilitate and monitor compliance with these standards and adherence to local and applicable international laws.

We expect our suppliers to demonstrate their commitment to the principles of this code and to have an on-going process of risk management to identify the environmental, health and safety, and labour practices and ethics risks associated with the suppliers’ operations.

  • Suppliers should encourage their staff to report concerns without fear of threat or reprisal. Suppliers should take appropriate action as required.
  • Suppliers should put in place equivalent standards to this Code for their own Supply Chain.

XTEL’s Code of Conduct

What XTEL expects from its suppliers

We, the officers, and staff of all companies in the XTEL Group (“the Group”), recognise our obligations to all who have a stake in our success including share owners, clients, staff, and suppliers.

You confirm that you recognise our obligations and will not act detrimentally to these obligations.

Information about our business shall be communicated clearly and accurately in a non- discriminatory manner and in accordance with local regulations.

You confirm that you will treat information about the XTEL Group as described.

We believe that a workplace should be safe and civilised, and that employment must be freely chosen.

We will not tolerate sexual harassment, discrimination, or offensive behaviour of any kind. This includes:

  • The persistent demeaning of individuals through words or actions.
  • The display or distribution of offensive material.
  • The use or possession of weapons on XTEL or client premises.

You confirm that you have equivalent policies in your organisation and for your supply chain, and that you will respect our workplace and people as described.

In particular:

  • Employment must be freely chosen; forced or bonded labour or any other form of modern slavery must not be used.
  • Workers must not be forced to submit passports or government issued identities as a condition of employment.
  • Child labour is not to be used.
  • Compensation paid to workers must comply with all applicable wage laws.
  • Work weeks are not to exceed the maximum set by local law.
  • There is to be no inhumane treatment of workers including sexual harassment, sexual abuse, corporal punishment, physical coercion, or verbal abuse.
  • XTEL expects its suppliers to create and foster safe working conditions for all workers.
  • Worker exposure to physical hazards must be eliminated wherever possible, or, if not, must be controlled.
  • Suppliers must have adequate procedures in place to handle emergencies that may affect workers.
  • Systems must be in place to manage, track and report occupational injuries and illness.

We will not tolerate the use, possession or distribution of illegal drugs, or our people reporting for work under the influence of drugs or alcohol.

You confirm that you have equivalent policies in your organisation and that you will respect our workplace and people as described.

We will treat all information relating to the Group’s business, or to its clients, as confidential. In particular, “insider trading” is expressly prohibited and confidential information must not be used for personal gain.

You confirm that you agree to our policy in respect of our information.

No corporate contributions of any kind, including the provision of services or materials for less than the market value, may be made to politicians, political parties, or action committees, without the prior written approval of the XTEL Board.

You should have your own policy regarding such contributions, together with appropriate authorisation procedures.

We will continue to strive to make a positive contribution to society and the environment by:

  • Maintaining high standards of marketing ethics.
  • Respecting human rights in our business, supply chain and through our client work.
  • Respecting the environment.
  • Supporting community organisations; supporting employee development.
  • Managing significant sustainability risks in our supply chain.

You should have equivalent policies in your organisation. In particular:

  • Suppliers must comply with the requirements of the UK’s Modern Slavery Act.
  • Suppliers must obtain all relevant environmental authorisations, including for waste and emissions.
  • Suppliers must endeavour to prevent pollution by implementing conservation measures in their facilities and processes, by recycling, reusing, and substituting materials.

Your Declaration

By signing this document you confirm that you  adhere to the XTEL Code of Business Conduct as amended for yout organisation. If we become aware of any breaches, particularly in respect of bribery or inappropriate gifts or services to or from your organisation or any other third party, or in respect of other matters that could harm XTEL’s reputation directly or by association, we will inform you immediately.