Smart Communications Code of Conduct


Corporate integrity, responsible sourcing and the safety and wellbeing of workers in the countries where we do business are of paramount importance to SmartComms SC Limited and its affiliates and subsidiaries (“Smart Communications”, “we”, “us” and “our”). These core principles are reflected in this Supplier Code of Conduct (“Code”), which establishes the minimum standards that must be met by any entity that supplies products or services to Smart Communications.

In this Code:

Worker means any individual whom Smart Communications employs, hires or engages, or otherwise uses to conduct its business.

Representative means Smart Communication’s suppliers, vendors, agents, and subcontractors who are involved in the Smart Communications ‘s supply chain.


Smart Communications shall comply with the Code and shall ensure that its workers are aware of this Code and comply with it.

Smart Communications agrees that:
• It will comply with the requirements in this Code.
• It has appropriate systems in place to ensure continuous compliance and to demonstrate such compliance.

1. Compliance with Laws and Regulations and Priority of Standards

1.1 Smart Communications, shall, in addition to complying with the standards set out in this Code, comply with all applicable laws and regulations including but not limited to the laws and regulations relating to issues addressed in this Code.

1.2 Competing standards shall be addressed as follows:

      • a) If there is a conflict between the provisions of your agreement with Smart Communications and the provisions of this Code, Smart Communications shall meet the more stringent standard.
      • b) If there is a conflict between any applicable laws or regulations, the provisions of your agreement with Smart Communications and the provisions of this Code, Smart Communications shall meet the most stringent standard.

2. Updating this Code
Smart Communications has the right to modify this Code from time to time.

3. Workforce Issues
Smart Communications has the right to modify this Code from time to time.

3.1 Slavery, Human Trafficking and Child Labour. Smart Communications shall comply with all applicable anti-slavery and human trafficking laws, statutes, regulations and codes from time to time in force including but not limited to the Modern Slavery Act 2015 in any part of its supply chain. This includes, but is not limited to, not supporting or engaging or requiring any forced labour, the use of child labour, bonded labour, indentured labour and prison labour. Smart Communications Modern Slavery Statement is available at

3.2 Human Rights. Smart Communications shall comply with all internationally recognised human rights understood, at a minimum, as those expressed in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organisation’s Declaration on Fundamental Principles and Rights at Work from time to time in force.

3.3 Equal Opportunities Smart Communications is an equal opportunities employer and Smart Communications shall not discriminate in hiring, compensation, training, advancement or promotion, termination, retirement or any employment practice based on race, caste, colour, national origin, gender, gender identity, sexual orientation, religion, age, marital or pregnancy status, disability, union membership or political affiliation or any other characteristic other than the worker’s ability to perform the job subject to any accommodations required or permitted by law

3.4 Freedom of Association and Collective Bargaining. Smart Communications shall respect, and shall not interfere with, the right of workers to decide whether to lawfully associate with groups of their choice, including the right to form or join trade unions and to engage in collective bargaining.

3.5 Working Environment. Smart Communications provides a safe, healthy, and sanitary working environment and comply with UK health and safety laws and any other relevant laws where it operates. This includes, but is not limited to, implementing general and relevant industry-specific procedures and safeguards to prevent workplace hazards and work-related accidents and injuries. Where such hazards cannot be adequately prevented or controlled, Smart Communications provides workers with appropriate personal protective equipment to protect against hazards typically encoutered in that scope of work.

3.6 Wages and Remuneration. Smart Communications compensates all workers with wages, including overtime premiums, and benefits that at a minimum meet the higher of:

    • a) the minimum wage and benefits established by applicable law;
      b) collective agreements;
      c) industry standards; and
      d) an amount sufficient to cover basic living requirements.

3.7 Grievance Mechanism. Smart Communications has in place a process through which workers can raise workplace concerns without fear of retaliation. This mechanism should be transparent and understandable to workers and should ensure the protection of the whistle-blowers.

4. Confidentiality

4.1 Smart Communications undertakes that it shall not at any time, disclose to any person any confidential information concerning the business, affairs, customers, clients or suppliers of the other party or of any member of the group of companies to which the other party belongs, except as permitted by Clause 4.1

4.2 Smart Communications may disclose confidential information:

    • a) to its employees, officers, representatives, contractors, subcontractors or advisers who need to know such information for the purposes of exercising the party’s rights or carrying out its obligations under or in connection with this agreement. The Supplier shall ensure that its employees, officers, representatives, contractors, subcontractors or advisers to whom it discloses the other party’s confidential information comply with this Clause 4; and
      b) as may be required by law, a court of competent jourisdiction or any governmental or regulatory authority.

4.3 Smart Communications shall not use confidential information for any purpose other than to exercise its rights and perform its obligations under or in connection with its supplier agreement.

5. Business Continuity

5.1 Smart Communications ensures that there are plans and procedures to resume business in the event of any physical disaster (e.g., fire, flood, wind, earthquake, explosion, etc.) or work stoppage of any kind (e.g., labour strike, economic/social structure breakdown, etc.). Subject to mutual agreement on business continuity plan terms by both parties, Smart Communications shall resume services within committed timelines following a disaster or work stoppage event.

6. Data Protection and Information Security

6.1 Smart Communications complies with all data protection laws and requirements (including to the extent applicable: (a) General Data Protection Regulation ((EU) 2016/679) as it forms part of the EU’s General Data Protection Regulations (EU Regulation 2016/679) (“GDPR”); (b) any further applicable data protection laws or regulations such as (i) the UK’s Data Protection Act; (ii) the Federal Data Protection Act in Germany (BDSG); (iii) the Swiss Federal Act on Data Protection and the Swiss Ordinance to the Federal Act on Data Protection (together the “Swiss DPA”); (c) California Consumer Privacy Act (“CCPA”); (d) the CAN-SPAM Act; and (e) any laws or regulations ratifying, implementing, adopting, supplementing or replacing such legislation in each case to the extent in force and as updated, amended or replaced from time to time) when processing any personal data.

6.2 Smart Communications has in place appropriate measures to:

  • a) protect the integrity and confidentiality of information held on its systems (which include physical and online or electronic systems); and
  • b) ensure that there is no unauthorised access of the information by third parties, including its Representatives.

6.3 Smart Communications shall inform you without undue delay of becoming aware, if Smart Communications is subject to a security incident or data breach involving your data.

7. Environmental Responsibility

7.1 Smart Communications ensures that:

  • a) its operations comply with all applicable environmental laws, including laws and international treaties relating to (but not limited to) waste disposal, emissions, discharges and the handling of hazardous and toxic materials;
  • b) any goods it manufactures (including the inputs and components that it incorporates into its goods) comply with all applicable environmental laws and treaties; and
  • c) it will only use packaging materials that comply with all applicable environmental laws and treaties.

7.2 Smart Communications has in place a suitable environmental management system for managing its environmental risks. The system includes and addresses the following:

  • a) an assessment of the environmental impact of all historical, current and likely future operations;
  • b) steps to continuously improve environmental performance, reduce pollution, emissions and waste;
  • c) measures to reduce the use of all raw materials, energy and supplies, and;
  • d) raising awareness and training workers in environmental matters.

8. Bribery and Corruption

8.1 Smart Communications complies with all applicable laws, statutes, codes and regulations relating to the prevention of bribery and corruption (including but not limited to the Bribery Act 2010 and U.S. Foreign Corrupt Practices Act (“FCPA”)). To that end, Smart Communications shall not accept, offer, promise, pay, permit or authorise:

        • a) bribes, facilitation payments, kickbacks or illegal political contributions;
          b) money goods, services, entertainment, employment, contracts or other things of value, in order to obtain or retain improper advantage; or
          c) any other unlawful or improper payments or benefits.

9. Unfair Business Practices

Smart Communications complies with all applicable competition laws (including but not limited to the Competition Act 1998), including but not limited to those relating to teaming and information sharing with competitors, price fixing and rigging bids.

10. Conflicts of Interest

Smart Communications shall disclose all actual or potential conflicts of interest.

11. Procuring and Managing Representatives

11.1 With regard to prospective Representatives, Smart Communications shall carry out appropriate due diligence on prospective Representatives that will form part of Smart Communications’ upstream supply chain. At a minimum, the due diligence shall include the following:

    • Investigations into prospective Representatives’ stance, public statements and actions on human rights, treatment of workers, bribery, ethical behaviour and environmental outlook;
    • risk assessments for countries from which materials, components or finished goods are sourced; and
    • the prospective Representative’s ability to meet the requirements and principles that are covered in this Code.

    11.2 In its dealings with Representatives, Smart Communications shall:

        • Ensure that agreements with Representatives include provisions that require the Representatives to comply with applicable provisions of this Code, having due regard to the risk profile of the transaction, the Representative’s ability to comply with those provisions and the consequences where the Representative fails to meet those requirements;
        • Ensure that it has measures to monitor that those Representatives are complying with those compliance-related provisions and that it has systems in place to address any deficiencies or breaches of those requirements; and
        • Pay its Representatives promptly.

    12. Training

    12.1 Smart Communications implements a system of training for its workers to ensure that they are aware of the requirements of this Code.

    12.2 Smart Communications shall keep a record of all training offered and completed by its workers and shall make a copy of such record available on request.

    13. Anti-tax Evasion and Anti-facilitation of Tax Evasion

    13.1 Smart Communications does not tolerate unlawful tax evasion or the facilitation of unlawful tax evasion. Smart Communications will not directly or indirectly engage in or facilitate the engagement of others in the deliberate and fraudulent diversion of funds from a tax authority.

    14. Certifying Compliance

    14.1 Smart Communications shall provide written confirmation, on request, that:

          • a) it has appropriate systems in place to monitor its compliance with this Code; and
            b) it is able to comply with this Code for the duration of its relationship with Smart Communications.

    15. Self-Monitoring

    15.1 Smart Communications shall monitor its compliance with this Code.

    15.2 Smart Communications shall not retaliate or take disciplinary action against any worker that has, in good faith, reported breaches of this Code or questionable behaviour, or who has sought advice regarding this Code.

    16. Breach, Remediation and Termination

    16.1 Where Smart Communications becomes aware of a breach of this Code by the Supplier or its workers, Smart Communications may either:

          • a) terminate its business relationship with Smart Communications (including any contracts); or
            b) remedy that incident (or incidents) with that Representatives.