Ethics
Capco is committed to doing business with organizations that share our commitment to treat all stakeholders fairly and ethically, ensuring compliance with all applicable laws and regulations in all that they do. In particular, suppliers are expected to:
- Comply with all applicable laws and regulations in place, including those related to Anti-Bribery and Corruption (such as the UK Bribery Act and other similar legislative requirements) when performing any form of service on our behalf and wherever they do business.
- Ensure appropriate policies, procedures and controls are in place to prevent bribery and corruption, money laundering, and any other financial crime activities. Capco has a zero tolerance for any instances of bribery or corruption when acting for or on behalf of Capco.
- Refrain from actions such as offering, giving or receiving fees, gifts, or advantages of any kind that are or could be considered acts of bribery or corruption.
- Avoid any conflicts of interest and never participate in any activities which could reasonably be interpreted as an attempt to improperly influence business decisions.
- Have reasonable and lawful payment terms with their own suppliers and subcontractors.
People and Human Rights
Capco suppliers are expected to respect and uphold human rights in the country or countries in which they operate. We expect our suppliers to operate in accordance with the United Nations Universal Declaration of Human Rights, the Fundamental Conventions of the International Labor Organization (ILO) and the United Nations Guiding Principles on Business and Human Rights. This means that Capco suppliers are expected to:
- Prohibit forced labor, child labor, ill-treatment of employees, and human trafficking, ensuring that third-party employees and contractors have a right to work in the applicable jurisdiction and country.
- Comply fully with anti-slavery legislation and regulations (such as the UK Modern Slavery Act and all other similar applicable laws relating to modern slavey and fair employment.
- Allocate a legal minimum wage sufficient to meet the basic needs of their employees and in compliance with current legal requirements.
- Ensure working hours are appropriate and in line with industry standards and managed and reported, in accordance with local regulation and industry best practice.
- Respect employees’ freedom of association.
Belonging and Inclusion
Our company’s commitment to respect, integrity, belonging and inclusion, is the foundation on which our business and our professional lives are built. We believe that having and sharing diverse perspectives is the glue that binds us together. Belonging and inclusion power the innovation and creativity that enables us to deliver world-class solutions to our clients. Capco suppliers are expected to ensure that all staff in their organization feels included and valued, regardless of their background. In particular, suppliers are expected to:
- Comply fully with any applicable legislation and regulation on diversity and inclusion, equal opportunities, or unfair discrimination (such as the Equality Act 2010 in the UK and all other similar and applicable laws relating to discrimination).
- Have a policy in place which explicitly promotes diversity and inclusion and prohibits unfair and unlawful discrimination, bullying, and harassment based on sexual orientation, race, ethnicity, gender, age, religion, martial/civil partnership status or disability.
- Ensure staff understand the importance of diversity and inclusion to the organization, for example, through diversity and inclusion training to the workforce.
- Have measures in place to monitor and improve diversity appropriate to the size of the organization, such as formal diversity targets related to workforce composition and leadership.
Physical, Cyber and Information Security
Capco’s policy is to ensure that our confidential data, including that of our customers and colleagues, is relevant, secure and appropriately managed. We expect our third-party suppliers to have in place their own policies and control frameworks to ensure:
- The ongoing protection of our information through appropriate cyber and information security controls
- Where Capco data is processed, transmitted, stored or accessed by our third-party suppliers, we expect that this is managed and controlled in line with the applicable data protection laws, regulations and record retention standards provided by us, and additionally to ensure that data subjects’ rights are not infringed.
- Where any breaches are identified, we expect these to be brought to our attention immediately.
- They do not jeopardize Capco’s physical security and assist us in providing a safe working environment for all our staff, customers, and visitors.
Operational Resilience
Environment Sustainability
Capco suppliers are expected to support Capco’s environmental sustainability goals by complying with all applicable environmental laws, rules and regulations while also using resources wisely. Suppliers are expected to align with Capco’s commitments by developing and implementing their own environmental sustainability program focused on conservation of natural resources, including but not limited to:
- Carbon Reduction
- Energy Efficiency
- Reduced Water Usage
- Air Quality Improvement
- Recyclability and Waste Reduction
- Hazardous Material and Chemical Management and Control
- Protecting Biodiversity
- Employee and Supplier Training
Monitoring
Capco may conduct compliance surveys with our suppliers to confirm compliance with this Supplier Code of Conduct on an annual or as needed basis.
Capco expects that all suppliers will familiarize themselves with this Code and ensure they are compliant with it as part of continuing to do business with Capco.
Capco also reserves the right to periodically review and update this Code as may be required from time to time.
Violations and Reporting Concerns
All Capco employees, contractors and relevant third parties are required to adhere to our agreed Capco policies and standards. Violation of Capco policies and/or standards may result in disciplinary action (up to and including termination). Any suspected violation of a Capco policy or standard should be reported to either a management representative, a Human Resource representative or to the Capco Enterprise Risk team, (Capco.risc@capco.com).
An employee who has violated any company policy or otherwise committed misconduct is accountable for his or her actions. Violators may be subject to a full range of penalties, including termination of employment and legal action in accordance with local law.
Capco will not tolerate any kind of retaliation against anyone who, in good faith, reports a suspected violation of its policies and standards, or any applicable laws governing the locations in which Capco conducts business.
Violations may also be reported using the CAPCO Ethics Website (https://report.syntrio.com/capco/). This service is administered in the USA and therefore all personal data you provide to our service provider will be processed in the USA. Capco does not tolerate any retaliation against anyone who, in good faith, reports a violation of Capco policy or law or cooperates with an investigation. More information on the Capco Ethics Website can be found on the Policy Portal or Global Enterprise Risk site on CapcoHub.
Capco “Speak Up” Ethics Website: https://report.syntrio.com/capco/
Reports to the Capco Ethics Website should be made in good faith only. The Company has a strict no retaliation policy. This means you will not be subject to discipline for reporting in good faith that you are concerned about unethical or illegal behavior. Employees should not use the website to report personal grievances.