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Compliance

Purpose

Bonnier Publications International AS, hereafter referred to as BPI, is committed to delivering our goods and services in a sustainable manner. We strive to live up to international standards and regulations for human rights, the environment, economic development, and the good of all.

To that end, we wish to collaborate with suppliers and partners with similar objectives, who can deliver their services in a way that aligns with the United Nations’ 17 goals for a better world.

This document is meant to serve as a set of minimum requirements for suppliers to meet in order to live up to the standards of BPI. The document is furthermore intended to be applicable to the entire supply chain, meaning supplier will be expected to similarly collaborate with sub-contractors in a way that aligns with the values presented.

The is primarily based on the latest versions of the following declarations:

  • The UN’s Universal Declaration of Human Rights
  • The Ten Principles of the UN Global Compact
  • OECD Guidelines for Multinational Enterprises
  • OECD Due Diligence Guidelines for Responsible Business Conduct

To the extent the document conflicts with other documents stipulating similar rights and environmental protections, the document providing the strongest protections shall apply.

Code of Conduct

The supplier shall at the minimum:

  • Comply with applicable laws and regulations,
  • Refrain from actively engaging in criminal or militant activities,
  • Refrain from supporting corrupt activity, including, but not limited to, the offering and accepting of bribes,
  • Adhere to the human rights standards as defined by the United Nations in all parts of their business activities,
  • Ensure a safe and healthy work environment for their employees, as well as fair and timely compensation for work provided,
  • Refrain from using child labor, as well as any forms of forced labor
  • Refrain from workplace harassment and discrimination based on, but not limited to, gender, race and ethnicity, religious and political affiliation, sexual orientation, and social class,
  • Uphold the rights to privacy as set by the EU GDPR,
  • Respect the right to information and freedom of expression, in particular with regards to journalistic purposes,
  • Assist BPI in assessing the standards of the supply chain in accordance with this document, including informing about known/possible infringements and assisting in stopping the infringement and/or reducing the risk of such,
  • Reduce negative environmental impact as much as possible,
  • Generally strive to meet the United Nations’ 17 goals for sustainable development as much as possible.

Principles of the code of conduct

The basis of BPI’s business practices is rooted in the democratic principles apparent in the United Nations’ foundation, and so we ask our suppliers to act under a level of transparency and adherence to fundamental human rights that aligns with our principles, to the greatest degree possible.

Business integrity

BPI is aware that laws and regulations differ across countries and cultures and there is a limit to exactly how much a company can adhere to. At the same time, we do not wish to exclude any company based solely on nationality, unless specific mandated sanctions have been set in place.

For this reason we will perform due diligence with our suppliers and business partners, in order to ensure that a good relationship can be established with respect to all the regulations that might be involved. It is therefore imperative that a potential supplier shows good faith, transparency, and cooperation to the best of their ability.

Should it be apparent that the supplier has been acting in bad faith with this document, or otherwise been engaging in criminal or militant activities, BPI is entitled to end any cooperation with the supplier.

Corruption

As BPI employees are expected not to consent to or engage in any form of bribes or otherwise corrupt dealings, suppliers are expected not to engage in such activities. This includes direct as well as indirect bribery, including gifts, travel and housing, political and charitable donations, private dealings between acting agents of the parties, and similar improper benefits depending on a variety of factors regarding the relationship, such as positions in the company, political affiliations, level of business insight, etc.

Cooperation between the parties

In order to perform due diligence in relation to the contract, suppliers are expected to cooperate with BPI to the best of their ability to ensure adherence to this code of conduct, both before, during, and to some extent after a business relationship has ended.

A supplier will be presented with this document before a contract is formally entered into and will be expected to have read and agreed to the terms presented. The supplier will also be required to provide identifying information regarding the company, including standard information such as name of the company, contact information, contact persons, country of registration and registration number. Information regarding additional trade names, parent company, and, depending on circumstances, names of beneficiaries will also be required.

Suppliers are responsible for performing their contractual obligations in accordance with the principles of this document to the greatest possible extent. Should a supplier experience a change that is likely to markedly affect their adherence to these principles, or should BPI receive information likely to cause suspicion of such affect, the supplier must act in good faith and inform on the change in a way that gives BPI a proper understanding of the situation. Suppliers must cooperate with BPI in order to rectify discrepancies between their practices and these principles. Suppliers are also responsible for ensuring their sub-contractors, subsidiaries, and independent contractors adhere to these principles at minimum, and are afforded the same rights and protections.

In some instances, suppliers would also be needed to comply with these principles for a period after a contract has ended, for example with regards to personal data, a supplier has processed on behalf of BPI.

Processing of personal data

The EU General Data Protection Regulation (GDPR) affords EU citizens additional protection with regards to their personal data, regardless of where in the world the data is processed. BPI therefore requires the suppliers to comply with the GDPR, whether they act as controllers or processors, depending on the nature of their activities.

Suppliers may be required to sign and adhere to additional contractual obligations, including a data processing agreement and/or the standard contractual clauses as provided by the EU commission, depending on the nature of their processing of data.

Human rights

All supplier employees are entitled to their fundamental human rights, in accordance with the United Nations’ Declaration on Human Rights, and the supplier is required to respect these rights in all parts of their business.

Workplace conditions

Suppliers should take all reasonable steps to ensure that employees are working in a reasonably maintained and healthy work environment. Where the nature of the work involves an increased risk for employee health, suppliers should take reasonable safety precautions suitable to eliminate involved risks and secure employee health.

The physical premises would need to live up to reasonable standards, including, but not limited to, a safe and robust structure, clean working spaces, and adequate lighting and ventilation.

Similarly, suppliers should take steps to ensure workers do not reach an unhealthy level of fatigue during their daily chores, including, but not limited to, regular breaks, access to water and food to the degree that is necessary, bathroom availability, and supplier should refrain from utilizing abusive techniques to spur on employees in their daily functions.

Social protection

Employees are entitled to compensation for work provided, which is effective in meeting the local costs of living and ensuring a reasonable daily living standard. Salaries must be provided on schedule as declared in a proper employment contract, and must not be used or withheld for any form of disciplinary action against the employee.

Suppliers must make certain that employee rights are respected both in and outside of the physical work premises and regular working hours. This includes, but is not limited to, reasonable working hours, respect for sick days and free time, proper overtime compensation, and protection against termination of employment without reasonable cause.

Protection of the employee

Employees must not be subject to abuse at their place of work or by anyone under supplier’s management, including relevant sub-contractors. This includes any and all forms of harassment and discrimination, from both employer and other employees, where suppliers should take reasonable steps to protect the employee.

Child labor is prohibited, by which is meant children below the age of 14 or 15, depending on the country involved, as according to International Labour Organization’s convention number 138.

Forced labor, collective punishment, as well as physical and mental abuse as punishment is prohibited.

Suppliers must respect the employee’s right to convey reasonable complaints about workplace conditions, and must rectify where the employee’s concerns are of a serious nature. Furthermore, the supplier must not interfere with employees, who wish to organize for a political cause, whether or not directly related to supplier’s core business, unless specific, valid reasons call for interference.

Protection outside the workplace

Suppliers must act in accordance with fundamental human rights in all parts of the supply chain. This includes not only employees, but journalists, company agents, politicians, or any other civilian that might be directly or indirectly affected by supplier’s business or dealings.