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Ethical Sourcing Policy

Panacea Applications Limited (Panacea) is committed to delivering on the principles in this ethical sourcing policy. Our company values and policies require our directors, employees and contractors to work with integrity and to the highest legal, moral and ethical standards. This statement sets out our policy on ethical procurement.

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Purpose

The purpose of this ethical sourcing policy is to identify the minimum expectations that Panacea has of its suppliers, based largely on the following key principals:

• Working conditions are safe and support the health and well-being of employees and stakeholders

• Employment is freely chosen and all workers are paid wages which meet at least the national living wage standards

• Diversity, inclusion, equal opportunity is encouraged and implemented in all employment and management practices

• Operational and business impacts are managed to support environmental protection and deliver carbon reduction

• Confidentiality and privacy are protected

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Scope

This ethical sourcing policy applies to all suppliers of goods and services to Panacea. A ‘supplier’ is defined as any individual, company or other legal entity that sells products or services to Panacea.

Suppliers must comply with the provisions of this policy and must have adequate policies and practices in place to ensure that their subcontractors or agents also comply with the spirit and intention of this ethical sourcing policy.

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Application

Panacea believes that companies have community responsibilities above and beyond the contribution made by their employment and wealth creation activities. We are committed to seeking to make positive economic, social, and environmental contributions in the communities in which we operate and to ensuring that good corporate behaviour is integrated into all aspects of our operations and those of our suppliers.

If non-compliance is detected, the supplier is obliged to take appropriate remedial measures. If appropriate measures are not implemented, or in the case of continued non-compliance or serious breach, we reserve the right to terminate business relationships with the supplier.

We reserve the right to obtain information from our suppliers, including the results of social audits, in relation to their compliance with this ethical sourcing policy.

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Legal compliance

Suppliers shall comply with the laws and regulations of the jurisdictions in which they operate.

Where the content in this ethical sourcing policy and the laws or regulations and jurisdictions in which the supplier operates cover the same topic, whichever affords the greatest protection shall apply.

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Responsible Sourcing

Suppliers must exercise due diligence in souring raw materials to minimise the risk of sourcing materials from jurisdictions and suppliers connected with human rights and/or environmental issues.

Privacy

All personal and sensitive information must be treated and protected in accordance with relevant Privacy laws and regulations.

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Bribery and corruption

Suppliers shall not offer, provide, request, or receive bribes, gifts or facilitation payments in order to influence business partner decisions or gain an improper advantage.

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Intellectual Property

Suppliers must respect the intellectual property rights of Panacea and other third parties. Any transfer of technology and knowhow must be handled in a manner that protects intellectual property rights, with all relevant laws and regulations complied with.

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Access to grievance mechanisms

Workers should have access to a grievance mechanism through which complaints can be made and investigated. These are to be resolved in a fair and equitable manner.

Procedures enabling workers to confidentially communicate concerns relating to noncompliance with this ethical sourcing policy should be in place and communicated to workers, with an avenue for anonymous disclosure and protection against detrimental treatment.

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Labour standards and human rights

Freely chosen employment

The use of forced or involuntary labour, including debt bondage, human trafficking and prison labour is prohibited. Suppliers shall not use deceptive practices, threats, fraud or abduction in the recruitment, transportation or harbouring of workers. Suppliers shall respect workers’ freedom of movement. Workers’ freedom of movement shall not be inhibited by withholding of property, including identify documents such as passports or licenses. Workers shall be free to cease employment after providing reasonable notice their employer.

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Prohibition on the use of child labour

Children shall not be employed. Suppliers must verify the age of all workers prior to their commencing employment.

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No Illegal Labour

Suppliers must be able to verify legal entitlement of the Supplier employees to work in the country of employment.

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Reasonable working hours

Employee working hours shall comply with the laws of the jurisdictions in which they work.

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Payment of fair wages

Suppliers shall pay employees wages and benefits that meet or exceed the minimum standards of the jurisdictions in which they operate. All employees must be provided with written information in a language they understand relating to their employment contract and wages for each pay period. Deductions from wages as a disciplinary measure is not permitted.

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Provision of regular employment

Suppliers shall not avoid providing the obligations and benefits to employees that arise from a regular employment relationship through the use of sub-contracting, the use of apprenticeship schemes, labour-only contracting or home-working arrangements or through the excessive use of fixed-term employment contracts.

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Fair treatment and non-discrimination

Suppliers shall not discriminate against prospective or current employees on the basis of race, gender, age, religion, disability, sexual orientation, marital status or union membership status during the hiring process, when determining compensation, when providing access to training or promotion opportunities or through the termination of employment process.

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Harassment and abuse

Employees of suppliers must be treated with dignity and respect. Employees of suppliers must not be subjected to physical, sexual, psychological, or verbal harassment or abuse.

Suppliers must ensure there is no harsh of inhumane treatment of employees.

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Migrant Workers

Migrant workers shall have the same entitlements as local workers as stipulated by local laws and regulations.

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Healthy and safe working conditions

Suppliers shall meet the requirements of applicable laws and regulations of the manufacturing country and have systems in place to detect and respond to potential risks to the health and safety of employees and visitors to the site. This includes:

• Understanding and responding to occupational hazards – suppliers shall adopt measures to minimise health and safety hazards present in the working environment and shall provide adequate safeguards against them.

• Personal protective equipment and machinery safeguards – this must be supplied, and employees trained in its use.

• Hygienic working environment – suppliers shall provide workers with a clean and hygienic workplace, including providing access to toilet facilities and safe food storage.

• Emergency preparedness – suppliers shall maintain a documented emergency response plan, including worker and emergency service notification procedures, identification of emergency exits and access to emergency response and first aid equipment.

• Provision of training – suppliers shall provide workers with health and safety training, including responding to emergency situations and applying the emergency response plan, emergency drills and employment facility evacuations. Records of training provided shall be maintained.

• Assigning responsibility for health and safety – suppliers shall assign responsibility for managing workplace health and safety to an officer of appropriate seniority.

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Environmental protection

Minimising impact and harm

Suppliers shall adopt reasonable measures to minimise the negative impacts that their operations have on the environment. We also expect that our suppliers encourage their suppliers to minimise negative impacts on the environment throughout their supply chains.

In addition to maintaining compliance with relevant laws and regulations, suppliers shall maintain current permits and licences as required by the jurisdictions in which they operate.

Suppliers shall ensure that their production facilities dispose of solid, liquid and hazardous waste in accordance with local regulations and permit requirements.

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Environmental planning and management

Suppliers shall ensure that all operated production facilities develop and maintain appropriate environmental management systems or plans. These management systems or plans must identify the key environmental impacts of each production facility and document the safeguards, controls or mitigating activities maintained to manage the impacts. Such impacts may include:

• Reducing, reusing, recycling and disposing of waste

• Air emissions and water discharges

• Use and storage of hazardous chemicals

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Reporting issues and obtaining further information

If you require further information or clarification on any aspects of Panacea’s ethical sourcing policy, or wish to inform Accent of suspected or actual breaches of this ethical sourcing policy please contact us at enquiries@panacea-software.com

Individuals can also report concerns about serious misconduct through Panacea’s complaints officer.  Our complaints policy and the contact details can be found on our website via this link: https://panacea-software.com/complaints-policy