1. OverviewSiteMinder is one of the world’s leading travel technology companies, supplying a suite of cloud software-as-a-service (SaaS) products to hoteliers and other temporary accommodation providers.
SiteMinder is listed on the Australian Securities Exchange. As a public company, we are accountable to our shareholders and are committed to conducting our business in an ethical manner in compliance with all applicable laws and regulations.
2. Application of the CodeThis Supplier Code of Conduct (Code) is a formal documentation of SiteMinder’s commitment to conducting business in an honest and ethical manner and adhering to national and international laws relating to:
- the environment;
- labour and human rights standards, including obligations relating to the prevention of modern slavery;
- corporate governance; and
- business relationships and integrity.
By becoming a Supplier, Suppliers are committing to meeting and exceeding the minimum requirements outlined in this Code. This Code does not however replace any specific legal obligations or contractual requirements our Suppliers may have.
Where applicable laws and regulations conflict with the requirements of this Code, Suppliers should follow the law while still endeavouring to abide by the principles set out in the Code. Where a contractual term is more stringent than this Code, the Supplier should meet the contractual requirement.
All existing and new Suppliers must commit to and ensure that their supply chains meet the standards set out in this Code. Additionally, Suppliers are obliged to communicate the requirements of this Code to their related entities, as well as any subcontractors or suppliers who support them in supplying services to SiteMinder.
3. EnvironmentSiteMinder recognises the increasing importance of taking a proactive approach to managing its carbon footprint and energy consumption and is committed to promoting sustainable business practices in its supply chain.
We expect our Suppliers to:
- adhere to all national and international laws regarding the environment;
- strive to improve environmental and resource management;
- maintain appropriate policies and procedures that ensure environmental risks are effectively managed and employees are trained in such policies and procedures;
- use resources efficiently, apply energy-efficient and environmentally friendly technologies and reduce waste, as well as emissions to air, water and soil;
- minimise their negative impact on biodiversity, climate change and water scarcity; and
- establish programs that seek to reduce the environmental impact of their operations and supply chain.
4. Labour and Human RightsSuppliers must maintain and demonstrate a commitment to adhering to fair and legal human rights practices and labour standards, including those contained within the Universal Declaration of Human Rights, the United Nations Global Compact and the International Labour Organisation’s Decent Work Agenda.
SiteMinder expects its Suppliers to:
- comply with all national and international laws and regulations regarding labour and human rights;
- ensure compliance with any workplace rights and entitlements that may be applicable to their employees, including in respect of wages, working hours, superannuation, insurance requirements, and allowing workers to join trade unions and to bargain collectively;
- provide an equal opportunity workplace for their staff that is free from bullying, discrimination and harassment; and
- notify SiteMinder if they become aware of any risks within their supply chain that may not comply with the labour and human rights standards in their relevant jurisdiction.
5. Modern SlaverySiteMinder is committed to identifying, addressing, and mitigating any modern slavery risks within our operations and supply chain.
We expect our Suppliers to:
- comply with all relevant laws and regulations of the jurisdictions in which they do business regarding modern slavery;
- take reasonable efforts to ensure that their supply chain and any associated businesses do not engage in modern slavery practices. This includes trafficking in persons, slavery, servitude, forced marriage, forced labour, debt bondage, deceptive recruiting for labour or services and the worst forms of child labour;
- ensure that any recruitment agencies engaged by the Supplier are compliant with both this Code and all laws and regulations in their relevant jurisdictions regarding modern slavery;
- ensure that all employees, contractors and consultants are paid a wage compliant with the laws and regulations of the jurisdictions in which they do business; and
- notify SiteMinder as soon as they become aware of any instances of modern slavery taking place in their supply chain or the supply chain of any of their related entitles, subcontractors or suppliers.
6. Corporate GovernanceSiteMinder is committed to developing and implementing effective risk management policies for its business and expects its Suppliers to do the same.
We expect our Suppliers to:
- comply with all relevant national and local laws and regulations relating to data protection and privacy;
- have an appropriate risk management framework which incorporates the honest and ethical business practices set out in this Code, including incorporating environmental, ethical and safety risks into their risk management processes;
- report on certain elements of this Code when requested to by SiteMinder; and
- ensure that they disclose all legal, social, environmental and ethical matters that may adversely affect SiteMinder.
7. Business Relationships and IntegrityWe require our Suppliers to conduct their business in compliance with the law, with integrity and with high ethical standards regarding conflicts of interest, anti-bribery and corruption, anti-competitive behaviour and trade sanctions and export controls.
Additionally, we expect our Suppliers to:
- actively avoid any actual, potential or perceived conflicts of interest with SiteMinder employees, contractors and other suppliers to SiteMinder, and to notify SiteMinder of any conflicts of interest that may arise;
- not offer to make or authorize any payment, bribe or thing of value, or engage in any kickbacks, pay-offs or obtain any benefit inappropriately or unethically in relation to SiteMinder’s business;
- comply with all laws that apply to the promotion of fair competition and antitrust; and
- comply with all trade and export control laws and regulations, particularly those that are relevant to the supply of products and services to SiteMinder.