Code of Ethics
Our supply chain must be reliable and ethical. We have established internal standards and principles to provide guidance for our employees – and our suppliers. Our diverse group of business partners include: vendors; service providers; consultants; contractors; distributors; and agents.
Four years ago we consolidated and rolled out our Global Code of Business Ethics and Compliance Standards (Code of Ethics), a comprehensive document that each employee must read and sign against the Code of Ethics annually. We have shared this Code of Ethics with our major suppliers and made them aware of our expectation that they adhere to it. In addition, we have updated our Terms & Conditions to include a clause establishing the ethical principles with which we expect our business partners to comply.
In FY2017, we have worked with legal advisors in various regions to customize our Terms & Conditions (T&Cs) of Purchase to address the different local legal requirements. The posted version on our downloads page (pdf, 140KB) is considered the standard. We will begin a similar process with our T&Cs of Sale in FY2018.
Assessing sustainability: our suppliers and us
Sustainable procurement is our target. We review our global feedstock suppliers, using publicly available information. Our suppliers are often subsidiaries of larger companies, who we also evaluate. We encourage our suppliers to audit our own operations and one such audit took place in FY2017 at our plant in Cubatão, Brazil where the supplier audited the facility on our waste and water management, emissions, noise, emergency planning and management systems. Our facility scored highly, achieving 95%, demonstrating the plant’s commitment to environmental stewardship.
Strengthening our supplier due diligence
Birla Carbon’s procurement process is decentralized: procurement is managed locally or regionally. This process promotes the local sourcing of materials and services, but also presents a challenge in terms of risk management.
In FY2017, we partnered with a leading ethics and compliance advisory firm to implement an online third party due diligence screening program. This application evaluates business partners against a series of criteria, including sanctions, adverse media coverage and political exposure. This process will help us globally screen, qualify and approve our suppliers, vendors and service providers, as well as our distributors and agents.
We began in FY2017 by screening over 150 distributors and sales agents with only one identified as potentially conflicted. This company was investigated further and was found to be compliant. We plan to extend the screening to our critical suppliers during FY2018.
Response planning and preparedness
We strive to ensure that our sites and suppliers have inventories available at all times. Difficult global circumstances can impact inventory approaches – for ourselves and our suppliers. Our Business Continuity Plans and Crisis Management Response Guidelines provide solutions for sourcing raw materials and critical spare parts with minimal risk through our contract supplier agreements. We maintain an updated list of approved, assured and certified alternative suppliers for emergencies.