Compliance
The risks of becoming a target of unlawful behavior when initiating or performing business transactions and providing services are increasing.
The risks of becoming a target of unlawful behavior when initiating or performing business transactions and providing services are increasing.
Despite stricter penalties, corruption and money laundering remain a constant threat for companies acting in good faith to becoming involved in the criminal activities of others.
The rapid development of national and international legal regulations affecting the business areas of Sparks AS also requires constant monitoring, control of compliance and timely and appropriate responses to identified violations.
Through the implementation of appropriate measures for prevention, clarification, monitoring and, where necessary, penalties, unlawful and unethical behavior should be avoided to prevent any economic and reputational damages.
The compliance with legal regulations, guidelines, our principles and code of conduct towards all relevant stakeholders has the highest priority for Sparks AS.
Since our corporate success is based on integrity and rule conformity.
In order to comply with this requirement, it is important to detect, evaluate and, if necessary, prevent potential misconduct on the part of our own employees, partners or suppliers.
All employees, business partners and third parties are hereby given the opportunity to report violations.
An independent and impartial external whistleblowing officer deals confidential with all reports in the whistleblowing system.
Further information on the whistleblowing process is available here.
Requirements for Sparks suppliers regarding ethics and sustainability
Sparks is committed to supporting ethical and sustainable development. We expect our suppliers of goods and services to also base their operations and value chains on these principles, and we therefore set requirements accordingly.
Sparks sets requirements for our suppliers of goods and services in the following areas:
1. Business ethics and compliance with applicable laws, regulations, and conventions
2. Human rights and labor conditions
3. Environment and climate
4. Traceability
5. Quality
6. Compliance
We expect suppliers to take a proactive and positive role in these areas, working together with Sparks to find effective solutions.
1. Business Ethics and Compliance with Applicable Laws, Regulations, and Conventions
Suppliers must maintain high ethical standards, conduct business in good faith, and not act contrary to applicable laws and regulations, key UN declarations and conventions, ILO conventions, and national labor laws within the value chain.
Where conventions, national laws, and regulations cover the same issue, the highest standard should always apply.
In cases where subcontractors assist in fulfilling contracts, the supplier is obligated to extend these requirements to them.
1.1 Zero Tolerance for Corruption
Sparks has a zero-tolerance policy towards corruption. Suppliers must comply with all
applicable laws and regulations regarding corruption, bribery, fraud, and other forms of prohibited business practices. Suppliers must not accept, request, receive, or offer any services, gifts, or hospitality of significant value to retain, gain, or secure any business advantage. Suppliers must not provide or accept benefits that could be considered an unacceptable reward for obtaining, retaining, or managing business operations. Such benefits may include cash, goods, travel, or other services. Furthermore, suppliers must have their own anti-corruption policies in place within their operations and value chain.
1.2 Anti-Money Laundering
Suppliers must comply with all applicable laws and regulations concerning the prevention of money laundering and take active measures to ensure that their financial transactions are not exploited for this purpose.
1.3 Fair Business Practices
Suppliers must operate in accordance with laws and regulations in a fair and ethical manner and promote healthy competition.
1.4 Conflict of Interest
Suppliers must avoid any conflicts of interest with Sparks. Suppliers should immediately inform all relevant parties if any actual or potential conflicts of interest arise.
2. Human Rights and Labor Conditions
Suppliers to Sparks are committed to respecting human and worker rights in their operations and throughout their supply chain, in accordance with the UN Guiding Principles on Business and Human Rights. Suppliers must comply with all applicable laws, international standards, and other legislation related to the protection of human rights and labor rights. Suppliers must have policies and practices in place to minimize violations of human and labor rights.
2.1 Wages and Working Conditions
Employees of suppliers and subcontractors directly involved in fulfilling the contract must have wages and working conditions in line with the regulation on universally applicable collective agreements. In areas not covered by the regulation, wages and working conditions must not be inferior to what is stipulated in the relevant nationwide collective agreement, or, in the absence of such an agreement, to what is customary in the relevant locality and profession. This applies to work conducted abroad as well.
2.2 Work Environment and Employment Conditions
Suppliers must promote an inclusive and diverse environment free from any form of
harassment, bullying, or discrimination, whether direct, indirect, or verbal. Suppliers must provide equal opportunities for all employees. At a minimum, suppliers must comply with applicable laws regarding working conditions and compensation, and all employees must have a clear and understandable employment contract.
Suppliers must have appropriate whistleblowing, complaint, and termination procedures in place.
2.3 Health, Safety, and Welfare
Suppliers must ensure the health, safety, and welfare of workers and visitors, and protect the public from health and safety risks in accordance with all relevant laws and regulations.
Suppliers must ensure that their workers understand the safe practices and hazards of their work and provide regular and adequate training.
2.4 Modern Slavery, Child Labor, or Forced Labor
Suppliers must not participate in, use, or tolerate the use of child labor, forced labor, or human trafficking. Child labor is defined by the International Labour Organization (ILO) as any work undertaken by individuals under 15 years of age, or under the age for completing compulsory schooling, whichever is higher. Children between the ages of 13 and 15 may perform light work, provided it does not threaten their health and safety, or interfere with their education orvocational training.
2.5 Freedom of Association and Collective Bargaining
Suppliers must respect the rights of employees to join trade unions, organize, and engage in collective bargaining.
3. Environment and Climate
In the delivery of goods and services, efforts must be made to proactively reduce negative environmental and climate impacts. Suppliers must ensure low raw material and energy consumption, minimal impact on biodiversity, and minimal pollution and waste during the lifecycle of goods and services. Suppliers are obligated to comply with all applicable environmental laws and regulations and obtain necessary environmental approvals, permits, and registrations. Upon request, suppliers must be able to document key input factors, emissions, and waste management related to their deliverie
4. Traceability
Suppliers must ensure full traceability of materials, products, and services where a significant risk of negative impacts on human rights, labor rights, or the environment has been identified.
5. Quality
Suppliers must have a satisfactory quality assurance system tailored to the delivery and must be able to document that defined quality requirements are integrated into the company’s operations.
6. Compliance
Sparks’ requirements for suppliers apply to all contracts in which Sparks is a party.
Failure to comply may result in breach sanctions.
In the event of significant breaches of these requirements, Sparks may terminate the contract.
In assessing whether a breach is significant, the potential for serious harm to people/loss of life, significant environmental damage, or economic loss, and/or reputational damage, or the risk of such reputational loss will be central.
The above is accepted by the supplier upon signing the agreement.