Supplier Code of Conduct
1. OVERVIEW
1.1 “NETS”, “we”, “us”, “our” means, as the context requires, Network for Electronic Transfers (Singapore) Pte Ltd, its subsidiaries and affiliates.
1.2 As a leading provider of digital payment services and related technology solutions in Singapore, NETS is committed to upholding the highest standards of ethical and sustainable business conduct and compliance with the applicable laws. This extends to all our third party suppliers, vendors, consultants, agents, contractors and their respective employees, personnels or subcontractors, including corporate bodies or individuals (“Suppliers”), who provide goods and/or services to us and form part of our supply chain.
2. SCOPE
2.1. This Supplier Code of Conduct (“Code”) sets out the foundational principles and minimum standards of conduct that NETS expects Suppliers, including their respective subcontractors, to adhere to in providing goods and services to us.
2.2. This Code should be read in conjunction with the contractual agreements governing our relationship with the respective Supplier and such other policies as we may adopt from time to time, including our Anti-Slavery and Human Trafficking Policy and Anti-Bribery and Corruption Policy and such other policies as may be accessible on our website at https://www.nets.com.sg/policies.
2.3. Suppliers shall familiarise themselves with all provisions of this Code and ensure compliance with this Code at all times. This includes the creation and enforcement of their own policies and procedures and making reasonable efforts to train, monitor and ensure that their own employees, personnel and subcontractors uphold the principles set out hereunder.
2.4. The ability and commitment to comply with this Code is a material consideration in our procurement process. Failure by a Supplier, or its subcontractors, to comply with or adhere to this Code and the principles hereunder may impact the ability of a Supplier to do business with NETS or the continuity of any existing engagements of such Supplier by us. While we will strive to work with our Suppliers to take remedial actions where possible, NETS reserves the right to terminate the engagement of the Supplier in the event of severe or repeated non-compliance.
3. COMPLIANCE WITH LAWS
3.1. Suppliers must ensure that their operations and all goods and services supplied to NETS comply with all laws and regulations that apply to it or the goods and services which it supplies to NETS (“Applicable Laws”). This includes, without limitation:
(a) compliance with all applicable anti-money laundering and counter-terrorism financing, anti-bribery and corruption, competition, labour and employment, environmental, health and safety, tax, intellectual property and personal data protection laws;
(b) maintenance of proper business and financial records in accordance with the requirements of the Applicable Laws and generally accepted accounting principles; and
(c) cooperation with regulatory inquiries and investigations relating to its business operations and practices.
3.2.Where reasonably required, Suppliers are expected to provide full cooperation and assistance to NETS to ensure compliance with the Applicable Laws.
3.3. For the avoidance of doubt, where any Applicable Laws, legal or other obligations of the Supplier and the provisions of this Code address the same subject matter, Suppliers are expected to conform with the higher or stricter standards, as may be applicable.
4. BUSINESS INTEGRITY AND ETHICS
4.1. Anti-Bribery and Corruption
(a) Suppliers must comply with all applicable anti-bribery and corruption laws and must not facilitate or engage in, whether directly or indirectly, bribery or corrupt practices.
(b) Suppliers and those acting on their behalf must not directly or indirectly offer, promise, authorise, recommend, give, solicit or receive any bribes (or any other form of facilitation payments) or anything of value that is intended, or could reasonably appear as intended, to influence improper action or to obtain or retain an improper advantage for NETS, the Supplier, or a third party.
(c) Without prejudice to the generality of the foregoing, Suppliers are expected at all times to conduct themselves in compliance with our Anti-Bribery and Corruption Policy.
4.2. Conflicts of Interest
(a) Conflicts of interest include situations where the interests of a Supplier, its personnel, employees or subcontractors, may oppose those of NETS or its respective customers, including but not limited to the existence of personal or business relationships, external interests, personal investments, political engagements or such other interests which may compromise the Supplier’s ability to act in an independent and objective manner.
(b) Suppliers shall implement such policies and procedures to identify and address any potential or actual conflicts of interest that may arise in connection with or in relation to its dealings with NETS. Upon the discovery of any potential or actual conflicts of interests, a Supplier must immediately notify NETS of the same and take prompt measures in consultation with NETS to address or resolve the same.
4.3. Improper Conduct
(a) Suppliers must uphold the highest standards of integrity and ethics and conduct their business dealings in an honest and transparent manner. Suppliers are expected to maintain proper and accurate accounts of their dealings.
(b) Supplier must not facilitate or engage, directly or indirectly, in any fraudulent or dishonest practices, including without limitation improper accounting practices, improper alternation of business records, tax evasion, money-laundering or any other form of financial crimes.
(c) Suppliers shall compete fairly and in accordance with all applicable competition laws, including prohibitions against abuse of dominance, bid-rigging, price-fixing or any other form of anti-competitive behaviour.
4.4. Intellectual Property Rights
(a) Suppliers shall acquire, use and deal in intellectual property rights in a lawful manner and shall not use any intellectual property that may result in the infringement of the rights of a third party or any intellectual property laws.
(b) Suppliers shall, in the course of providing its goods and services to NETS, safeguard and take all reasonable steps to identify and protect any intellectual property rights owned by or licensed to NETS in compliance with the relevant contractual agreements.
4.5. Confidential Information and Personal Data
(a) The Supplier must ensure that information accessed or used in the Supplier’s business relationship with NETS that is non-public, confidential and proprietary must be safeguarded and protected against unauthorised use or disclosure, loss or theft. The Supplier shall limit the use of any confidential or proprietary information disclosed to it by NETS solely to the purpose for which it was disclosed and the provision of the relevant goods or services which it supplies to NETS.
(b) The Supplier shall safeguard all personal data of individuals that it has access to and shall only process, use or disclose the same in compliance with the applicable personal data protection laws. The Supplier shall not process any personal data disclosed to it by NETS other than in accordance with its contractual obligation to NETS or for the purposes for which it was disclosed.
5. COMMITMENT TO SUSTAINABILITY
5.1. Suppliers shall implement an effective environmental policy and/or an environmental management system to mitigate the environmental risks, impacts and dependencies of their products and/or services and promote greater environmental responsibility throughout its supply chain.
5.2. Suppliers shall conduct their business in a manner that protects the environment by making reasonable efforts to meet industry best practices and standards with respect to the reduction of energy use, greenhouse gas emissions, waste and water use and to mitigate potential adverse effects on the environment and the health, safety and security of any affected communities.
5.3. Suppliers shall ensure that all products supplied by it to NETS are compliant with the Applicable Laws, any and all requirements set out in the relevant contract between NETS and the Supplier and all applicable industry standards and requirements applicable to such products.
6. HUMAN RIGHTS AND LABOUR PRACTICES
6.1. Workplace Environment
(a) Suppliers shall ensure a positive, safety and inclusive environment, free of physical, sexual or other forms of harassment and ensure that respective employees and other members of its workforce are treated with respect and dignity.
(b) Suppliers shall comply with all applicable labour laws and regulations, including without limitation requirements pertaining to minimum age for employment, minimum and overtime wage, working hours and leave entitlements.
(c) Suppliers shall not engage in, promote or be complicit in any form of violation or abuse of human rights, including without limitation modern slavery, human trafficking or forced labour. Please refer to our Anti-Slavery and Human Trafficking Policy.
(d) Suppliers shall ensure that employees and other members of its workforce are not subject to discrimination of any form, whether based on race, religion, ethnicity, age, gender, sexual orientation, disabilities, marital status or political affiliation.
6.2. Safety and Health
(a) Suppliers shall provide a safe and healthy work environment for their employees in adherence with the workplace safety standards required by the Applicable Laws. To that end, Suppliers shall implement adequate precautions, including work procedures and policies, employee training and safety measures, to protect the health and safety of their workers.
(b) Suppliers are to regularly monitor and review the performance and effectiveness of their workplace health and safety measures. Where lapses in health and safety precautions are found, Suppliers are to promptly take appropriate corrective measures to address these lapses.
7. ADMINISTRATION OF THE CODE
7.1. In the event of any breach of any of the provisions of the Code, be it by the Supplier, its employee(s), or a third party, including its subcontractors, the affected Supplier shall promptly notify NETS, and provide accurate and transparent reporting regarding the breach. That Supplier shall immediately take prompt and appropriate measures to investigate, address and resolve the issue, including implementing corrective actions to prevent recurrence.
7.2. NETS strictly prohibits intimidation or retaliation against anyone who makes a good faith report about a potential or actual violation of the Code, supporting policies, or any Applicable Laws. Any such reports may be reported through the NETS Group Whistleblowing Channels as set out in our Whistleblowing Policy, and will be treated and assessed in accordance with our Whistleblowing Policy.
7.3. NETS reserves the right to request for evidence or compliance or to audit Suppliers to verify compliance with the Code. This includes audits of the Supplier’s, or its subcontractor’s, policies and procedures or business practices. Suppliers shall provide reasonable cooperation and access to NETS for the purposes of undertaking such audits.
7.4. To ensure the continued effectiveness of this Code, NETS will undertake periodic reviews of and, where necessary, revise the provisions of this Code. Such revisions will be communicated to Suppliers and made available on our website. Suppliers are expected to stay informed of and comply with such revisions.