WEP Supplier Code of Conduct

PURPOSE 

The purpose of this Supplier Code of Conduct policy (“Code of Conduct”) is to establish the ethical, legal, and quality standards required by all suppliers, vendors, contractors, consultants, and service providers (hereinafter referred to as “Suppliers”) are expected to uphold when conducting business with WEP Clinical.

The Code of Conduct ensures that all goods and services provided, support WEP Clinical’s mission to deliver safe, effective, and compliant medicinal products, devices and clinical services whilst maintaining the highest standards of integrity, social responsibility, and environmental stewardship.

The Code of Conduct is essential as it forms part of the contractual agreement between WEP Clinical and Suppliers, failure to comply with this Supplier Code of Conduct may result in corrective action requirements, suspension of services, termination of contracts, or removal from WEP Clinical’s approved supplier network.

SCOPE

This policy applies to:

  • All suppliers providing medicinal products, devices, materials, components, I.T. services, equipment or support WEP Clinical, including those involved in pharmaceutical distribution, manufacturing, packaging, logistics, warehousing, or professional services.

  • All supplier personnel, subcontractors, and agents engaged in work for or on behalf of WEP Clinical.

KEY PRINCIPLES AND REQUIRMENTS  

1. Ethics, Business Integrity and Compliance

Compliance with Laws and Regulations

  • Suppliers must identify and comply with the applicable internationals, national and local laws, regulations, and internationally recognized standards applicable to their operations that may be underpinned within contractual agreements. This includes but is not limited to labor laws, environmental regulations, health and safety standards, and any other legal requirements pertinent to the business activities. Suppliers must also conform to the standards required in their industry and where applicable, shall obtain and maintain and operate within the applicable permits, certificates, licenses and registrations.

Ethical Conduct

  • Suppliers must uphold the highest standards of ethical conduct, including honesty, fairness and transparency in their interactions. Any form of abuse, bribery, corruption or unethical behavior will not be tolerated.

Anti-bribery and anti-corruption

  • Supplier will comply with all relevant anti-bribery and anti-corruption laws and will never engage in bribery and corruption. Suppliers and their employees, contractors, or agents will not offer, promise, give (including facilitation payments), demand or accept bribes or other improper advantage, including excessive gifts and entertainment, in order to obtain, retain or give business.
  • Suppliers must immediately notify WEP Clinical if they become aware of any such payment, offer, promise or authorisation made whether indirectly or directly. Suppliers must also adhere to WEP Clinical’s policies on gifts and hospitality when engaging with WEP Clinical employees or representatives.

Speaking Up and Non-Retaliation

  • Suppliers shall ensure that individuals are able to report concerns relating to misconduct, harassment, discrimination, unethical behavior, or legal violations without fear of retaliation. Suppliers must not prevent or discourage any individual from making protected disclosures or reporting concerns to WEP Clinical or relevant regulatory authorities.
  • No agreement, confidentiality provision, policy, or contractual arrangement implemented by a Supplier shall prevent, restrict, or discourage any individual from reporting or disclosing allegations of harassment, discrimination, retaliation, unlawful conduct, or other protected disclosures to WEP Clinical, law enforcement, regulators, or other appropriate authorities.

Fair Competition

  • Suppliers must conduct their business ethically and in full compliance with all applicable antitrust and fair competition laws. They are expected to engage in fair and vigorous competition, uphold honest and transparent business practices, and ensure that all advertising and representations are accurate and truthful.

Data Protection and Confidentiality

  • Suppliers shall protect all personal, confidential, and proprietary information obtained through their relationship with WEP Clinical and handle such data in compliance with applicable data protection laws, including but not limited to the UK Data Protection Act 2018 and UK GDPR , EU General Data Protection Regulation (GDPR)  HIPAA (as amended, re-enacted or extended from time to time), and as required by WEP Clinical in accordance with the agreement. Personal data must be collected and processed only for legitimate business purposes, safeguarded through appropriate technical and organisational measures commensurate with the Supplier business operations, and disclosed solely as authorised. Any actual or suspected data breaches involving WEP Clinical information must be reported to WEP Clinical without delay, in accordance with the relevant Data Protection Agreement and by emailing: [email protected].

Avoidance of Conflict of Interest

  • Suppliers will conduct all business with integrity and transparency and must take reasonable steps to avoid a situation that could create, or appear to create, a conflict of interest in their dealings with WEP Clinical. Suppliers will promptly disclose to WEP Clinical any actual, potential, or perceived conflicts of interest that could improperly influence business decisions. All such situations must be managed in an open and ethical manner. Suppliers shall inform WEP Clinical immediately, in any event within 48 hours of any conflict of interest by emailing: [email protected].

Trade Compliance

  • Suppliers will conduct all business in full compliance with applicable trade, export control, and sanctions laws and regulations applicable to their business operations. All products, services, and technologies supplied to WEP Clinical must be sourced, exported, and transferred in accordance with relevant legal and regulatory requirements.

2. Employment Standard and Human Rights

Anti-Discrimination & Fair Treatment

  • Suppliers will promote a work environment and culture founded on respect, equality, and inclusion that is free from harassment, harsh and inhumane treatment, including sexual harassment, sexual abuse, corporal punishment, mental or physical coercion, discrimination, verbal or physical abuse of employees. Suppliers must ensure that all employment practices — including recruitment, compensation, promotion, and working conditions — are conducted fairly, ethically, and in compliance with applicable labour and human rights laws and adequate policies are also in place.
  • Suppliers must prohibit and take appropriate measures to prevent all forms of harassment, including sexual harassment, bullying, victimisation, and inappropriate conduct within their workforce and in interactions with third parties, including WEP Clinical employees, clients, patients, contractors, and business partners. Suppliers shall maintain appropriate policies, reporting procedures, investigation processes, and training programs designed to prevent and address such conduct.

Third-Party Harassment and Workplace Conduct

  • Suppliers are expected to ensure that their employees, contractors, agents, and representatives conduct themselves professionally and respectfully at all times when interacting with WEP Clinical personnel or any third party connected to WEP Clinical business activities.
  • Suppliers must take all reasonable and proactive measures to prevent harassment, discrimination, intimidation, retaliation, or other inappropriate behaviour by their personnel. Any allegation or incident involving inappropriate conduct impacting WEP Clinical employees or representatives must be reported to WEP Clinical promptly and investigated appropriately.
  • Suppliers shall cooperate fully with WEP Clinical in relation to any investigation concerning workplace misconduct, harassment, or discrimination involving Supplier personnel.

Freedom of Association

  • Suppliers will recognise and respect the rights of their employees to freely choose whether to join, form, or refrain from joining trade unions or other lawful worker organisations of their choice, in accordance with applicable laws. Suppliers, within applicable laws and regulations, allow employees to engage in collective bargaining and worker representation without fear of intimidation, discrimination, retaliation, or harassment.

Working Time, Wages and Benefits

  • Suppliers will ensure that all employees work in compliance with applicable laws and industry standards governing working hours, rest periods, and overtime. Wages and benefits must meet or exceed legal requirements and provide for a decent standard of living. All workers shall be compensated promptly, fairly, and transparently, with clear communication of employment terms and conditions. Deductions from wages must be lawful and never used as a disciplinary measure.

Forced Labour, Slavery and Human Trafficking

  • Suppliers will prohibit practices that could lead to forced labour and will not use, participate in, or benefit from any form of forced, bonded, indentured, or involuntary labour. All work must be freely chosen, and employees shall be free to leave their employment upon reasonable notice. Suppliers must ensure that no form of human trafficking, servitude, or exploitation occurs within their operations or supply chains, and shall maintain measures to identify, prevent, and address such practices in compliance with applicable laws.

Child Labor

  • Supplier will prohibit practices use of child labor in any part of their business operations or supply chains. No person shall be employed under the minimum legal working age as defined by applicable laws and international labor standards. Where young workers are lawfully employed, Suppliers must ensure that their work does not interfere with schooling, is not hazardous, and is appropriate to their age, physical, and mental development.

3. Health, Safety and Environment

Health & Safety

  • Suppliers will provide a safe, healthy, and hygienic working environment in compliance with applicable laws and regulations. Adequate measures and policies must be in place to prevent workplace injuries, accidents, and exposure to health and safety risks. Suppliers will ensure that employees receive appropriate training, protective equipment, and access to necessary welfare facilities, and that any incidents are reported, investigated, and addressed promptly.

Environmental

  • Suppliers will conduct their business operations in an environmentally responsible manner and in compliance with all applicable environmental laws and regulations. They must strive to minimise adverse environmental impacts by managing waste responsibly, reducing emissions, conserving energy and natural resources, and promoting sustainable practices throughout their operations and supply chains. Suppliers will ensure that, where applicable, all required environmental permits, licensed and registrations will be obtained for business operations.

4. Quality, Product and Patient Safety

Documentation and Accurate Record Keeping

  • Suppliers will maintain complete, accurate, and transparent records of all business activities, in compliance with applicable legal, regulatory, and contractual requirements. All documents, statements, and reports provided to WEP Clinical must be truthful, traceable, and verifiable. Records shall be retained for the required period and provided upon request.

Quality of Services

  • Suppliers will deliver products and services that meet agreed quality standards, specifications, and regulatory requirements applicable to the relevant sector.

SUPPLIER’S ACKOWLEDGEMENT 

By establishing a business partnership with WEP Clinical, Suppliers acknowledges WEP Clinical Code of Conduct and will confirm that they will conduct operations and engagement with WEP Clinical in accordance with the Supplier Code of Conduct.