8Se7en’s code of conduct and business ethics
8Se7en LLC’s Expectations from suppliers, contractors and sub-agents:
8Se7en LLC has certain expectations from its suppliers, subcontractors and sub-agents and a Code of Business Ethics to which they are expected to conform in order to maintain and sustain the relationship with 8Se7en LLC.
8Se7en LLC may go through a process, which will be communicated to its suppliers, subcontractors and sub-agents in order to verify adherence to those standards. Our expectations and policies may be updated or amended from time-to-time and our registered network will receive those updates as they occur.
1. Health, Safety & Environment
8Se7en LLC has an Environmental, Health and Safety policies by means of which we aim to provide our customers with the necessary support relating to the sound management of environmental, health and safety performance issues in addition to providing our team members with a working environment that is safe and conducive to high levels of performance. Similarly, the health and safety of all personnel working in cooperation with 8Se7en LLC on joint projects through suppliers, subcontractors and sub-agents is of priority to us.
It is therefore expected of our suppliers, subcontractors and sub-agents within our network to:
- Be vigilant against complacency that often results when incidents are infrequent. We stress caution, compliance with our health, safety and environment policies, the use of protective clothing and equipment when tasks warrant it, in areas where this is required by the customer or the relevant authorities and regulations e.g. port authorities. They are expected to report near misses, accidents and action taken for compliance purposes and in order to continue to improve protective measures.
- Have a quality and HSSE representative appointed as a Point of Contact (POC) for every project undertaken in cooperation with 8Se7en LLC who will provide oversight to this area on joint projects and ensure adherence to 8Se7en LLC’s policies by the supplier, subcontractor, or sub-agent and coordinate and report to 8Se7en LLCs HSSE appointed representative and near misses, injuries, accidents, risks and health, safety and environment concerns.
- Have a policy, procedure and practice periodic HSSE risk assessments.
- Provide their employees with a safe and healthy working environment and take active measures towards incident and accident prevention. In addition to the implementation of Health, Safety and Environment policies and procedures compliant with the Health, Safety and Environment regulations within their countries of operations and consistent with international human rights standards and regulations. This applies to offices, project locations, and staff accommodation if provided by their employers.
- Report past accidents and injuries that have occurred within their operations 6 months prior to any engagement with 8Se7en LLC, the reasons and circumstances that led to it and corrective actions that ensued.
- Ensure that accommodation provided by suppliers, subcontractors and sub-agents are regularly inspected by them for any risks or breaches of health and safety regulations and standards.
- Conduct their activities in an environmentally safe and friendly manner consistent with local environment laws and with 8Se7en LLC’s policies which shall be provided to our suppliers, subcontractors and sub-agents prior to the commencement of work or updated on our website.
Risks to health, safety and environment will be treated very seriously by 8Se7en LLC and may lead to severing relationships based on the level of severity of health and safety risks or breaches.
1.1 Health When Travelling
8Se7en LLCs employees, suppliers, subcontractors and sub-agents are responsible for seeking advice on health and safety risks before travelling overseas ensuring that all inoculations are up to date.
1.2 Storage of Hazardous Materials and Disposal of Hazardous Waste
- Suppliers, subcontractors and sub-agents are expected to be vigilant in ensuring responsible and safe disposal of all hazardous materials in accordance with their different classifications, categories, risk factors and depending on the office or projects environments they are working in.
- They are expected to adhere to Environmental and Storage and Disposal of Hazardous Materials Regulations in their countries of operations, international standards and any additional precautionary measures specified by the customer.
- They are expected to ensure that all chemical and hazardous materials are correctly labelled at their facilities and on project sites. The labels should clearly identify the materials and contain a Material Safety Data Sheet (MSDS) reference. All materials should be stored in accordance with regulations and standards in the respective countries of operations.
- Scheduling periodic waste pick-ups, properly segregating hazardous waste, ensuring that this is not mixed with other waste materials and disposing of hazardous waste in a safe manner consistent with standards and regulations. In addition, suppliers, subcontractors and sub-agents are required to label any hazardous waste material containers so that they are clearly identifiable by waste management services and needs to be highlighted to any waste management company used by the supplier, subcontractor and sub-agent.
- Conduct employee training regarding hazardous materials used, stored and disposed of by their employers and clearly highlight chain of custody, as well as the use of protective materials.
- Document the quantities and types of materials picked up by the waste management company where one is used in any joint projects with 8Se7en LLC, retaining copies for a 12-month period, providing 8Se7en LLC with copies of this documentation and ensuring that the waste management company is disposing of such material in a responsible, ethical, safe and legal manner.
Threats to the security and environment are treated very seriously. Developing a culture of security awareness is key within 8Se7en LLC’s network. 8Se7en LLC’s employees, suppliers, subcontractors and sub-agents are provided with specific details on the security requirements of the ports and all facilities they are operating in and areas of responsibilities.
8Se7en’s suppliers, subcontractors and sub-agents are required to do the same and are required to take all measures to do security checks consistent with 8Se7en’s policies and local regulations in the countries of operations ensuring:
- Vigilance and consistency
- Implementation of a formal process for security
- Formal process for handling complaints and proactive measures to be taken in the event of security risks.
- Continuous improvement in security procedures
- Sound environmental policies and procures implementation management
- Accountability is assigned with management oversight
3. Recruitment and Employment
Suppliers, subcontractors and sub-agents within the 8Se7en LLC network are expected to implement ethical employment practices and standards, this includes but is not limited the examples below that will prevent 8Se7en LLC from dealing with organizations that implement these practices:
- Make fraudulent claims, using misleading communication in their employment process.
- Charge fees from candidates/employees towards their recruitment by the Company or recruiting through agencies that charge fees from candidates/employees towards their hiring.
- Non-payment of wages
- Employ children or conduct their operations through companies that employ children.
- Practice illegal salary deductions
- Have excessively long working hours without payment of compensation as specified in the regulations
- Deny the right to holiday and holiday compensation
- Providing an unsafe, unsanitary and unhealthy working and living environment
- Denying access to medical care
- Breaches local employment regulations
4. Business Ethics
4.1 Conflict of Interest
8Se7en LLC’s employees, suppliers, subcontractors, and sub-agents and their family members must not:
- Act on behalf of 8Se7en LLC in any transaction involving persons or organizations with whom they or their family have any connection or financial interest.
- Derive any personal profit, gain, or benefit, directly or indirectly, financial or otherwise by reason of his/her employment or appointment as employees, suppliers, subcontracts or sub-agents of 8Se7en LLC. Even a modest financial interest held by an employee or a family member should be considered significant and must be disclosed.
- If an 8Se7en employee supplier, subcontractor or sub-agent believes that a conflict of interest exists or may develop, the circumstances should be fully disclosed and discussed with 8Se7en’s Management.
- Any disclosure shall identify and fully detail the affiliation with any supplier, subcontractor or sub-agent before becoming involved in that business transaction. Disclosure shall include descriptions of any arrangement, agreement, investment, or other activity, including disclosure of relatives working for, or having other financial interests in, or with, any vendor, supplier, or other party doing business with 8Se7en LLC.
- Any situation which has resulted or could result in personal benefit to party(ies) involved needs to be immediately disclosed. Disclosure shall also include details of any salary payments, loans, gifts of anything beyond nominal value, any free service or discounts or other fees from or on behalf of any person or organization engaged in any transaction with 8Se7en LLC.
- No employee, supplier, subcontractor or sub-agent shall have a direct or indirect interest in any Company with which 8Se7en LLC does business with.
4.2 Bribery Prevention
8Se7en LLC has a zero tolerance Policy for bribery. Bribery is directly or indirectly giving or promising to give anything considered of value to a third party to influence an action.
- 8Se7en’s employees, subcontractors and sub-agents or their employees or agents, shall not make any payment or give anything of value to any official or customer representative to influence his or its decision to award 8Se7en LLC any business, or to gain any other advantage in connection with the work performed as sub-agents.
- This includes making or promising a payment as well as solicitation or receipt of any payment, gifts, free vacations/hotel stays on reduced prices, free seminars where others are not provided with free access, reciprocal favours, travel expenses, gift baskets, hospitality, employment of relatives, loans, political or charitable contributions or contribution to Company events, directly or indirectly is entirely prohibited.
- 8Se7en LLC will use internal channels to communicate the application of prevention policies in order raise awareness of the risks and ramifications of actions described under this Article (4.2).
- Any employee, supplier, subcontractor or sub-agent discovered to have engaged in such practices or breaches of Anti-Bribery and Corruption policies, laws and regulations will result in 8Se7en LLC immediately severing the relationship with that party.
- 8Se7en LLC will regularly monitor the effectiveness of their bribery prevention procedures and adapt them as necessary which will keep up to date with governmental modifications in countries of operations.
4.3 Money Laundering Prevention
8Se7en LLC’s employees, suppliers, subcontracts and sub-agents are expected to follow all applicable laws for money laundering prevention and are required to report any suspicious transactions and activities.
4.4 Fair Dealing
- Competitive advantage must be gained through high standards of performance consistent with 8Se7en’s 7 values. 8Se7en LLC expects its suppliers, subcontractors and sub-agents to compete fairly and honestly.
- 8Se7en’s employees are expected to deal fairly with suppliers, other employees and any individual with whom they come in contact with through the course of their duties as representatives of the Company.
- Employees involved in procurement and dealing with service providers have a special responsibility to adhere to the principles of fair competition and to make business decisions based solely on quality, cost, responsiveness, availability and quick access to products and services, service, performance and reliability, not on the receipt of any special favours or benefits.
4.5 Work with Government Entities
8Se7en LLCs suppliers, subcontracts and sub-agents engaged in any work or projects with Government entities or international organizations are expected to follow all policies, procedures, rules and regulations that apply to their scope of services.
4.6 General Ethical Guidelines
The protection of the company and its customers’ interests are of paramount importance. It should be the aim of 8Se7en’s representatives in any capacity to ensure that the most prompt and highest standards of service is provided to 8Se7en’s customers as cost efficiently as possible.
- If, for any reason a relationship is severed between 8Se7en LLC and a supplier, subcontract or sub-agent, it is expected that the supplier, subcontractor or agent will continue to treat as private, privileged and confidential any sensitive or confidential information and not release any information to any person, firm, or institution without the express written consent or authorization of 8Se7en LLC’s Management. 8Se7en LLC may pursue legal remedies for unauthorized disclosure of any sensitive, privileged, confidential or proprietary information.
- 8Se7en LLC has language in most of its contracts with customers stating that 8Se7en LLC shall maintain as strictly confidential, any and all information related to the activity and business(es) of the companies represented. Maintaining such confidentiality is vital.
4.8 Reporting and Financial Integrity
The integrity of corporate and business records depends on the validity and accuracy of the information supporting the entries to books of account. Therefore, financial records should be completely accurate and must not contain any false or misleading information whether relating to financial or business results or productivity.
4.9 Protection and Proper Use of Company Assets
8Se7en LLCs employees, suppliers, subcontractors and sub-agents are bound by their duty to the Company to protect Company resources and assets and ensure their efficient use for business purposes. Company assets include:
- Facilities, computers, software, office equipment and supplies, and official documentation.
- Security passes and items issued for identification to assist them in the performance of their duties
- Keys and passwords
- Vehicles and equipment
Theft, waste, and negligence have a direct impact on the Company and are taken seriously by the Company. Company property is expected to be used only for legitimate business purposes.
4.10 Ethics Checklist
- Would anyone’s life, health, or safety be endangered or at risk by this act or decision?
- Is this action legal? If so, is it ethical?
- Does this action comply with Company values, policies, procedures and practices?
- Is this or can this activity be handled honestly and transparently in all respects?Would I be compromised or embarrassed if this action was known to my peers, supervisor, fellow employees, subordinates, friends or the public?
- Does this act have the appearance of an inappropriate act or course of behaviour?
- Does this act meet my own personal code of behaviour?
- Am I comfortable doing this?
- Should I ask my supervisor before proceeding?
When in doubt always ask!”