Responsible Procurement Policy of the OHL Group - December 2011
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Responsible
Procurement Policy of
the OHL Group
December 2011Table of Contents
Introduction .................................................................................................................................. 3
Origins ....................................................................................................................................... 3
Objectives .................................................................................................................................. 3
Scope ......................................................................................................................................... 3
OHL's Commitment to Responsible Purchasing ............................................................................ 5
OHL Group's commitment to suppliers and contractors .......................................................... 5
Criteria aimed at Suppliers and Contractors ................................................................................. 7
What the OHL Group expects from suppliers and contractors: Basic guidelines ..................... 7
Declaration .................................................................................................................................. 11
2
OHL Group | Responsible Procurement PolicyIntroduction
Origins Group, without exception. This Code is
seen as the cornerstone of the company's
The proper management of the supply ethical system and is one of the key
chain is a key function in any multinational elements of the management of Corporate
company. Globalization and the growing Social Responsibility (CSR) in OHL. The
outsourcing of those production stages with Code includes some general principles that
lower value-added has made supply a should guide the relationship of Group
complex and critical task in many employees with contractors and suppliers
businesses. and demonstrates the company's interest
in basing this relationship on the principles
In our times it is also a fact that the of CSR.
efficient and competitive supply chain
management involves much more than Objectives
purely economic, logistical or
administrative aspects. Accordingly, The main objectives of the Responsible
proper purchasing management has not Procurement Policy of the OHL Group are:
only become more complex, but has also
acquired increasing strategic importance a) Establish and publicize the
due to its ability to create value for Group's commitment in the
companies. relationship with suppliers and
contractors throughout the
The OHL Group is undergoing a purchasing management process.
diversification and internationalization
process that began in 2002. One of the b) Promote compliance with basic
most direct consequences of this process is standards and criteria among
the emergence of significant changes in the suppliers and contractors related
size of the Group as well as of the need to to human and labor rights, the health
understand and manage increasingly and safety of workers, respect for the
diverse scenarios and groups, on which the environment and ethical behavior.
success of the company also depends.
c) Disseminate and ensure
Mindful of the new challenges, while awareness and the implementation
maintaining our commitment to responsible of the Principles of the United
business management and an effective Nations' Global Compact among
contribution to sustainable development, in suppliers and contractors.
2010 the Sustainability Committee of the
OHL Group developed and approved the Based on these objectives, this policy
Corporate Social Responsibility Master establishes two requirement levels: Inward
Plan 2010-2014, establishing the roadmap ('OHL's commitment to responsible
that the company would follow from that procurement') and Outward ('Criteria aimed
moment. As part of this strategy, the at suppliers and contractors').
purchasing function and the relationship
with the supply chain has been declared Scope
a priority area for the OHL Group.
The Responsible Procurement Policy
Also in 2010, the company published its applies to all purchases of products and
Code of Ethics, an express statement of services made by any of the companies or
values, principles and standards of conduct entities of the OHL Group, thus covering all
for the performance of professional suppliers and contractors of the Group. We
activities applicable to everyone in the also request that suppliers and contractors
3
OHL Group | Responsible Procurement Policytransmit the contents of this policy among
their own subcontractors. In other words,
the content of the Responsible
Procurement Policy addresses both
direct and indirect suppliers of the
Group.
4
OHL Group | Responsible Procurement PolicyOHL's Commitment to
Responsible Purchasing
As noted, the OHL Group's Code of Ethics Generate and disseminate a
explains how to transfer the values, procurement policy based on
principles and standards of conduct that all sustainability criteria to be applied
Group employees should adopt and follow across the entire Group.
to the unique relationship that the Group's Create spaces for dialog with
purchasing departments have with different supplier groups to transmit
suppliers and contractors. And it does so in the Company's commitments to
the following terms: sustainability and the collaboration of
the supply chain for these purposes.
"The processes for selecting suppliers
and contractors of the Group shall Similarly, the application of this policy will
carried out in under strict criteria of facilitate compliance with the Code of
fairness and objectivity. Ethics by all Group employees involved in
the relationship with suppliers and
Everyone in the Group shall apply the contractors, given that it translates the
necessary criteria of quality, timeliness basic principles and rules of behavior
and cost in these processes, always contained in the Code that affect this
acting on behalf of the Group's best relationship into this context.
interests.
Similarly, the Group shall promote
knowledge of this Code among OHL Group's commitment to
suppliers and contractors for the best suppliers and contractors
application of the principles contained
therein. The relationships of OHL with suppliers and
contractors are based on respect for the
When establishing business business and professional project that
relationships with other companies or these organizations legitimately represent
professionals, one of the selection independent of the Company. At the same
criteria will be that said businesses time, OHL seeks to build positive links that
have assumed similar principles of enable both the Group's business success
management and ethical behavior to and that of its collaborators.
those set forth in this Code "
To this end, the following commitments
The Group's CSR Master Plan 2010-2014 have been established for the purchasing
specified the management of the supply departments of the OHL Group in its
chain as a core activity and establishes the relationships with suppliers and contractors:
the following framework objective: "Know,
control and establish collaborations under
the basis of sustainability with the Group's Behavioral integrity and conflicts of
supply chain." interest
This policy is inspired by this objective and The OHL Group, and all persons acting on
contributes to two lines of work defined in its behalf, shall maintain strict compliance
the CSR Master Plan: with current legislation in all territories
5
OHL Group | Responsible Procurement Policywhere the Group operates and in all Group personnel who have access to this
dealings with suppliers and contractors. information in the relationship with suppliers
and contractors shall ensure its
Similarly, those who hold the relationships confidentiality and shall not disclose or
with suppliers and contractors shall misuse it.
undertake this role with the professional
integrity and business ethics that
characterize the professional conduct of the Local sourcing
Group's employees, avoiding conflicts of
interest, illicit payments, extortion, bribery The OHL Group, to the extent possible, will
or any other form of corruption. promote and encourage the local sourcing
pf suppliers and contractors to foster the
development of the business and create
Promotion of sustainable business jobs in the communities where our work is
practice undertaken.
The OHL Group promotes stable business
relationships that will enable suppliers and Dialog and communication
contractors to meet their needs and
economic, social and environmental The OHL Group will develop the fluid
commitments. communications with its suppliers and
contractors, ensuring they receive timely,
To this end the Group shall monitor the clear and truthful information about matters
established delivery times and payment that are of the most direct interest. The
terms to ensure that they do not prevent Group shall also welcome those claims and
meeting basic labor standards and suggestions that suppliers and contractors
environmental law or otherwise jeopardize present to further the continuous
financial sustainability. Likewise, The Group improvement that characterizes the
shall also avoid any drastic changes to the company and the rest of the management
agreed terms and condition during the areas.
course of the business relationship.
Lastly, the OHL Group will facilitate
responsible performance by its suppliers
Equal opportunity, transparency and and build a mutually beneficial relationship
accuracy of information with them through the dissemination of the
Code of Ethics of the company and this
The OHL Group will promote free Responsible Procurement Policy and the
competition in its procurement processes, Global Compact Principles.
providing clear information on the
conditions of participation and evaluation
criteria and applying objective, transparent
and balanced supplier selection criteria.
Confidentiality and protection of
personal data
Non-public information is considered
privileged and confidential within the OHL
Group, applying the necessary mechanisms
to preserve its integrity, availability and
confidentiality.
6
OHL Group | Responsible Procurement PolicyCriteria aimed at Suppliers
and Contractors
The OHL Group recognizes and values this policy to avoid exceeding these
those business organizations that, like standards.
OHL, are committed to creating economic
and social value. The goal of the supply In addition to the application of these basic
chain management developed by the Group standards, companies are expected to
is to establish areas of collaboration and comply with such legislation as is
cooperation in which, based on an attitude applicable in each case (local, regional,
of respect and dialog, it is possible to work national, international, etc.). In the event
together towards gradual and continuous that the provisions of the law and these
improvement. basic standards address the same subject,
that proving greater worker protection shall
The Group thereby strives to maintain apply in each case.
relations with suppliers and contractors
based on the following: Lastly, the identification of any failure in any
field by companies should preferably be
Mutual respect and trust. accompanied by the development of
Dialog and exchange of clear corrective actions that pursue continuous
information, so that both parties know improvement in all areas as highlighted
and are aware of the commitments below.
acquired.
A common interest in promoting
and developing innovation applied Respect for basic human and labor
to improving quality of life, work rights
quality, and sustainability.
OHL considers respect, protection and
promotion of human rights as one of the
What the OHL Group expects cornerstones of its CSR efforts and is
formally committed to the following
from suppliers and contractors: initiatives and international organizations
Basic guidelines working in this field.
The OHL Group recognizes those suppliers The Group respects and publicly supports
and contractors that are able to the content of the United Nations Universal
demonstrate that they apply similar Declaration of Human Rights and the
principles to those of the company. Tripartite declaration of principles
concerning multinational enterprises and
In any case, and based on the above- social policy of the International Labour
mentioned attitude of respect and Organization. Similarly, the Group has
cooperation, the OHL Group expects its included the OECD Guidelines for
suppliers and contractors to fulfill the Multinational Enterprisesin its principles by
following basic standards of ethical committing to this initiative to develop
behavior, labor and human rights, health responsible business conduct consistent
and safety at work and respect for the with applicable laws.
environment. The standards listed below
are minimum standards, not maximum. The OHL Group has signed Ten Principles
That is, suppliers and contractors of the United Nations Global Compact and
(hereinafter, "the companies") shall not use is a founding member of the Spanish Global
7
OHL Group | Responsible Procurement PolicyCompact Network since its creation in international labor standards
2004. (whichever provides the highest level
of protection).
Based on this commitment, which the Respect for freedom of
Group assumes the development of all its association and collective
activities, OHL expects all its suppliers and bargaining rights. Workers, without
contractors to take the basic criteria relating distinction, are entitled to join or form
to business ethics and respect for human unions of their own choosing and to
and labor rights into account in their bargain collectively if a significant
operations, as highlighted below: percentage of them so agree. The
company will adopt an open attitude
Fight against forced labor:
to the activities of trade unions. The
Employment shall be freely chosen.
workers' representatives shall not be
No worker in prison shall be hired
discriminated against, harassed,
against h or her will and the company
intimidated or repressed and can
shall not use forced or enslaved
perform their representation functions
labor. The company shall not employ
in the workplace. In the event that
any coercive action against its
legislation restricts the right to
workers in order to force them to
freedom of association and collective
continue working.
bargaining, the employer must
Ban harsh or inhumane treatment:
facilitate, and not hinder, the
The company shall not allow the
development of parallel legal means
intimidation of workers through verbal
for independent and free association
abuse, physical discipline or abuse,
and bargaining.
threats or sexual or other
Non-discrimination. No
harassment.
discrimination will be tolerated in
Elimination of Child Labor1. The
hiring, compensation, access to
company shall not allow illegal child
training, promotion, termination or
labor or any form of exploitation of
retirement based on race, caste,
children. If the supplier encounters
birth, sex, age, family responsibilities,
children working on its behalf or on
religion, disability, marital status,
the behalf of the suppliers thereof, it
ethnicity, nationality, sexual
shall undertake such measures as
orientation, trade union membership
may be necessary which take into
or political affiliation.
account, first and foremost, the
Payment of a living wage. Wages
interests of the child. If the company
and benefits paid shall, at least, meet
employs young workers2, such
national legal standards or local
employees shall not be in used in
regulations or industry benchmarks,
any dangerous activity or which
whichever is higher. In any event,
otherwise compromises their health,
wages, less and payment in kind,
safety or morals.
shall be sufficient to meet the basic
Legal employment. The work
needs of workers. All workers must
should be based on a recognized
receive written and understandable
employment relationship established
information about their working
through national law and practice or
conditions in respect to wages before
1 the start of the employment
A child is considered as any person under 15
years of age unless local law establishes a higher relationship and the details of their
age for work or mandatory schooling, in which case wages during the pay period
the greater age shall apply. In cases where local
law sets the minimum working age at 14, the lower
concerned each time that they are
age will apply as specified in ILO Convention 138 paid. No reduction in wages shall be
for developing countries. used as a disciplinary measure.
2
Young workers are considered as all those
between the maximum age of a child (as defined
Non- excessive working hours.
above) and 18 years old. Standard working hours shall comply
8
OHL Group | Responsible Procurement Policywith national legislation and The accommodations, if necessary,
standards of the industry, with that shall be clean, safe, and will address
affording the greatest protection for the basic needs of workers.
the employee prevailing. The company will provide standards
and procedures for the management
of waste, emissions and waste
Occupational health and safety treatment, handling and disposal of
conditions chemicals and other hazardous
materials.
The OHL Group has followed a specific The company shall confer the
Occupational Risk Prevention Policy since responsibilities for occupational
2007, establishing ORP as a priority all the health and safety management on an
company's activities. This policy includes employee with sufficient seniority in
those basic principles that the company has the organizational hierarchy.
committed to follow in the development of
its activity and OHL actively urges its
collaborators to apply the principles in their
own activities3.
Respect for the environment
In any case, the minimum criteria OHL
OHL is firmly committed to the preservation
expects suppliers and contractors to take
of the environment in all its activities,
into account in the field of occupational
establishing sustainable environmental
health and safety are:
management, the promotion of a low
The company will provide a safe and carbon economy and conservation of
healthy work environment. ecosystems among the core objectives of
The company will take effective its CSR policy.
measures to prevent accidents or
In addition to the necessary internal
potential harm to the health of its
strategic tools and management, the Group
workers that are associated or join
has various declarations and policies that
during the course of the work.
allow it to meet this commitment. The most
The company will minimize, to the
important are the aforementioned
extent possible, the causes of
adherence to the Ten Principles of the
hazards inherent to the specific work
United Nations Global Compact, the Quality
environment.
and Environment Policy Declaration and the
Workers shall receive regular
Commitment to Fight Climate Change.
information and training on safety,
health and hygiene. This information Therefore, OHL expects from its suppliers,
and training will be repeated for new in addition to strict compliance with the
workers. environmental laws applicable in each
The company will provide necessary case, performance similar to that of the
and adequate personal protection company in terms of respect for the
equipment. environmental.
The company will provide access to
clean water and clean restrooms.
3
Ethical behavior
Also in this line and to facilitate that these
principles are taken into account, the Group Besides the aforementioned compliance
provides employees of collaborating companies
(suppliers and contractors) all the information with applicable law in each case, OHL
needed to ensure compliance with the expects its suppliers and contractors carry
management plans. For example, documentation out their activities under a commitment to
such as files, work instructions and guidelines for
environmental management practices and safe ethical behavior based on professional
working environments, detailing the guidelines to integrity and ethics, avoiding conflicts of
follow in different subjects.
9
OHL Group | Responsible Procurement Policyinterest, extortion, bribery or any other form
of corruption and also avoiding any unfair
competition.
OHL's commitment to ethical behavior in
relation to its own workers is reflected
mainly in the Group'sCode of Ethics, which
can provide guidance to suppliers and
contractors in the application of the
principles contained therein to their own
business principles and standards.
10
OHL Group | Responsible Procurement PolicyDeclaration
We the undersigned hereby confirm that we have received, read and understood the
Responsible Procurement Policy of the OHL Group.
Date: …………………………………………………
Signature: ………………………………………………….
Name: ……………………………………………….
Position: …………………………………………………
Company name: …………………………………….
Company seal:
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