HGC Group Supplier Code of Conduct
HGC Global Communications Investment Holding Limited (“HGCIH” or “the Company”) is firmly committed to maintaining high ethical standards in the conduct of its business. All directors, officers and employees (the “Company Personnel”) of the Company, its subsidiaries and affiliated companies over which it exercises control (“the Group”) are required to fully comply with the Company’s Code of Ethics applicable to them to conduct the Group’s business honestly and ethically and in compliance with the applicable laws and regulations.
The Group expects all suppliers, contractors, and subcontractors (collectively, “Suppliers”) to uphold the same ethical standards. To support this, HGC has established this Supplier Code of Conduct (“SCoC”), which sets out minimum requirements based on internationally recognized frameworks and best practices. These standards reflect HGC’s sustainability priorities across four key areas: Environment, Labor & Human Rights, Ethics, and Responsible Sourcing.
The supplier should ensure that their operations, products and services comply with applicable laws and regulations. This includes, without limitation, laws covering anti-corruption, data protection and information security, trade controls and sanctions, information privacy, personal data privacy, offering or receiving business courtesies, environmental protection and occupational health and safety.
The supplier shall not employ children under the legal age of employment in any country or local jurisdiction. Employees under the age of 18 shall only perform work in accordance with the legal requirements of their country of employment (e.g. with regard to working time and working conditions) and subject to any requirements regarding education or training.
Additionally, all persons under aged 18 must be protected from performing any work that is likely to be hazardous or likely to interfere with their education or that may be harmful to their health, or their physical, mental, social, spiritual or moral development
The supplier shall not use any form of forced, bonded, compulsory labour or modern forms of slavery. All labour must be voluntary. Employees must be allowed to maintain control over their identification documents (e.g. passports, work permits or any other personal legal documents). The supplier shall ensure that employees do not pay fees or make any payment connected to obtaining employment throughout the hiring process and the employment period. The supplier shall be responsible for payment of all fees and expenses (e.g. licenses and levies) relating to employees, where legally required.
Employees should be free to leave employment upon giving reasonable notice.
The supplier shall comply with all applicable local laws and mandatory industry standards regarding working hours, including overtime, rest breaks and paid vacation.
The supplier shall compensate its employees in accordance with local minimum wage legislation and terms of applicable collective bargaining agreements as well as with industry standards. The supplier should pay employees in a timely manner and clearly convey the basis on which employees are being paid (i.e. receive employment documents in a language they understand). Deductions from wages as a disciplinary measure shall not be allowed, if not legally permitted.
Suppliers shall respect workers’ rights to form or join trade unions, to bargain collectively, and to engage in social dialogue in accordance with local applicable law. Where such rights are restricted by law, Suppliers shall facilitate parallel means of worker representation.
The supplier should promote an inclusive work environment that values the diversity of its employees.
The supplier shall be committed to equal opportunities and not discriminate or tolerate discrimination or harassment with respect to gender, ethnic and national origin, race, color, religion, age, disability, sexual orientation and identity, or any other characteristic protected by law.
The supplier should provide a safe working environment, incorporate health and safety in the planning and conduct of their business, comply with applicable health and safety laws and regulations, identify and control hazards associated with their businesses, monitor their health and safety performance, provide adequate health and safety funding, training, reporting and communications and promote a strong safety culture in their organizations.
This includes regular workplace risk assessments and the implementation of adequate hazard control and precautionary measures, including the provision of appropriate Personal Protective Equipment (PPE). Suppliers are encouraged to implement a certified occupational health & safety management system (e.g., ISO 45001) and monitor safety performance indicators such as incident and lost-time rates).
Suppliers must ensure that workers and stakeholders have safe, accessible, and confidential channels to raise concerns or report potential misconduct. Retaliation against anyone who reports in good faith is strictly prohibited. All concerns should be addressed promptly through thorough investigation and appropriate corrective action.
The supplier shall adhere to applicable data protection laws, including security of personal data, as well as to respective regulations, e.g. GDPR, in particular with regard to personal data of customers, consumers, employees and shareholders. The supplier shall comply with all said requirements when personal data is collected, recorded, hosted, processed, transmitted, used or erased.
The supplier should not permit bribery and corruption. To this end, they should have in place policies covering the offer and receipt of advantages, payments to government officials, charitable contributions, entertainment and corporate hospitality and agents, consultants and joint venture partners.
The supplier shall comply with all applicable national and international anti-corruption laws and regulations. The supplier shall not, directly or indirectly, offer, provide, or accept anything of value to improperly influence an official act or to secure an improper advantage to obtain or retain business.
The supplier shall comply with all applicable export and import controls, sanctions and customs laws and regulations, including Prohibitions & Restrictions ("Trade Laws"). The supplier in particular ensures that the supplier, its beneficial owner(s), all its agents and any other subcontractors used by the supplier are not listed on any applicable Denied Party sanctions lists.
The supplier shall comply with applicable laws and regulations designed to combat money laundering activities. The supplier shall maintain financial records and reports according to applicable laws and regulations.
The supplier shall immediately disclose any actual or potential conflict of interest related to its activities with HGC. A conflict of interest is any personal or financial interest, any business or personal activity or relationship, prior or current employment, or any obligation that may interfere with the ability to objectively perform job duties and responsibilities or impair independence and objectivity.
The supplier shall comply with applicable competition and anti-trust laws. The supplier should take all appropriate measures to prevent abuse of dominant positions, as well as anti-competitive agreements or concerted practices such as price-fixing and limitation of production volumes.
The supplier shall comply with all applicable environmental laws, regulations and standards as well as implement an effective system to identify and eliminate potential hazards to the environment. We expect our suppliers to strive to support HGC’s environmental and climate protection commitments through the products and services they deliver, which should be done efficiently by taking the environmental impact into consideration.
The supplier should measure and report on their impact on the environment (in particular their carbon emissions) and should seek to reduce environmental impact. HGC also expects the supplier to report relevant environmental data upon request.
Suppliers are expected to incorporate sustainability principles into their sourcing and procurement practices. This includes extending the requirements of this Code to all sub-suppliers, conducting risk-based evaluations and audits, implementing timely corrective actions where issues arise, and ensuring traceability of high-risk materials while avoiding any illegal or unethical sources. HGC may request suppliers to provide relevant sustainability documentation, performance data, or improvement plans, and will give preference to those demonstrating strong practices and a clear commitment to continuous improvement.
HGC reserves the right to check compliance with the requirements of this SCoC, for example through self-assessments and audits either by HGC or a third party. The supplier shall strive for continuous improvement, such as setting measurable targets for the environment, working conditions or diversity, and reporting on progress for sustainability. In case a breach is identified, the supplier shall create an incident report and present a corrective action plan.
The terms and conditions set forth in this Supplier Code of Conduct reflect HGC’s values and commitment to its customers, the communities which we serve and the protection of the environment. Without prejudice to any other remedies available to HGC under the contract, any failure to promptly rectify such a breach may result in HGC considering the termination of the commercial relationship.
HGC encourages anyone who wishes to report any violations from what is outlined in this SCoC, directly to the Compliance Office of HGC or via EthicsPoint.
All reports will be treated with the utmost confidentiality and be promptly and thoroughly investigated.