Our Supplier Code of Conduct.

Purpose

Pametan Ltd (“Pametan”, “we”) believes the way our suppliers conduct their business matters as much as the way we conduct ours. The work we do is regulated; our clients’ work is regulated; our suppliers stand inside both. This Code of Conduct sets out the standards we expect from any business that supplies us with goods or services, and from the people who work in those businesses.

The Code is grounded in three external frameworks we believe set the right floor:

• The ten principles of the UN Global Compact on human rights, labour, environment and anti-corruption.
• The UN Guiding Principles on Business and Human Rights.
• The applicable laws of every jurisdiction where you do business with us — particularly, for UK work, the Modern Slavery Act 2015, the Bribery Act 2010, the Equality Act 2010 and UK GDPR.

Where any of those frameworks conflicts with local law, we expect you to apply whichever standard is higher.

Who this applies to

This Code applies to every company and individual who supplies Pametan with goods or services, of any value, in any jurisdiction. That includes:

• Companies under direct contract with us — software vendors, cloud and infrastructure providers, professional-services firms, agencies.
• Individual freelancers and contractors providing services to Pametan.
• Sub-contractors engaged by any of the above where Pametan is the ultimate beneficiary of the work (see §Sub-contractors).
• Hosts and venues we use occasionally — co-working spaces, event venues.

We do not run a tendered procurement process. Most of our supplier relationships are direct and small. The proportionality of this Code matches that: we expect you to apply it in good faith, with the seriousness it warrants, but we are not asking you to operate a bank’s third-party-risk regime to supply us.

Our expectations, in one paragraph

You must act ethically and lawfully. You must treat the people who work for you well — fair pay, fair hours, no coercion, no discrimination, no forced or child labour, freedom of association. You must take human rights seriously. You must not give or accept bribes or kickbacks. You must protect any Pametan or Pametan-client data we share with you. You must comply with applicable environmental law and take reasonable steps to minimise environmental impact. And you must extend these expectations to anyone you sub-contract with on Pametan-related work. The rest of this document is the detail.

Ethics and integrity

You must conduct your business honestly. Specifically:

• Anti-bribery. Comply with all applicable anti-bribery and anti-corruption laws, including the UK Bribery Act 2010, the US Foreign Corrupt Practices Act and equivalent legislation in any jurisdiction where you operate. Do not offer, give, request or accept any bribe — whether in cash, kind, hospitality, services or anything else — in connection with your relationship with Pametan or our clients. Our own approach is set out in our Anti-bribery and corruption policy and is the floor we expect from you.
• Conflicts of interest. Tell us in writing about any actual or potential conflict of interest that could reasonably affect work you do for or with us.
• Fair dealing. Compete on the merits of your offer. Do not engage in price-fixing, market allocation, bid rigging or any other anti-competitive practice.
• Accurate records. Keep accurate records of work done and money received from Pametan. Invoices should reflect what was actually delivered.
• Sanctions. Comply with all applicable trade-control and sanctions regimes (UK, EU, US, UN). Tell us promptly if you become aware of any sanctions exposure relevant to Pametan or our clients.

Human rights

You must respect internationally recognised human rights — at minimum, those expressed in the International Bill of Human Rights and the ILO Declaration on Fundamental Principles and Rights at Work. We expect you to:

• Identify and act on adverse human-rights impacts your business may cause, contribute to or be directly linked with — proportionate to the size of your business and the severity of the risk.
• Provide or cooperate in legitimate remediation when you cause or contribute to adverse human-rights impacts.
• Take particular care in higher-risk contexts: operations in conflict-affected areas, use of migrant labour, security arrangements involving private contractors, products that could be used for surveillance or repression.

Labour standards

Across your operations and your supply chain, you must:

• Eliminate all forms of forced or compulsory labour. Workers must be free to leave employment with reasonable notice and must not have identity documents, deposits or wages withheld in ways that restrict their freedom of movement.
• Not engage child labour in violation of ILO Conventions 138 and 182 or applicable local minimum-age law.
• Respect freedom of association and the right to collective bargaining in line with applicable law.
• Pay at least the legal minimum wage in each jurisdiction. We strongly prefer suppliers that pay at or above the real living wage where one is defined.
• Comply with applicable working-time law, including limits on weekly hours and entitlements to rest and paid leave.
• Not discriminate in recruitment, employment or termination on the basis of any protected characteristic under applicable law (including the UK Equality Act 2010).
• Treat workers with dignity. No physical, verbal, sexual or psychological abuse, no harassment, no humiliating treatment.

Modern slavery

You must not, and you must take reasonable steps to ensure that nobody in your supply chain does, engage in any form of modern slavery — including forced labour, debt bondage, human trafficking, child exploitation or any other practice prohibited by the UK Modern Slavery Act 2015 or equivalent law in your jurisdiction.

If you are subject to the section 54 reporting obligation under the Modern Slavery Act 2015, we expect you to publish a current statement. If you are not, we expect you to take proportionate steps appropriate to the nature and scale of your business and to inform us promptly if you become aware of any modern-slavery risk linked to work you do for Pametan. Our own Modern Slavery statement sets out our approach.

Health and safety

Provide a safe and healthy working environment for everyone who works for you, in line with applicable health-and-safety law (in the UK, the Health and Safety at Work etc Act 1974 and supporting regulations). Where your work for Pametan involves visiting our or our clients’ premises, you must comply with the on-site health-and-safety arrangements in force at the time.

Diversity, equity and inclusion

We expect you to recruit, retain and develop a diverse workforce, and to maintain a culture of inclusion and belonging. Specifically:

• Do not discriminate on the basis of any characteristic protected by applicable law.
• Take reasonable steps to make adjustments for disabled workers and applicants.
• Where you have one, maintain a documented anti-harassment policy and a working mechanism for raising concerns.
• Pametan particularly values working with suppliers who are themselves diverse-led businesses. Where two suppliers are comparable on cost and quality, we will prefer the one whose ownership reflects under-represented backgrounds.

Environment

Comply with all applicable environmental laws in every jurisdiction where you operate. Take proportionate steps to:

• Measure and reduce your direct (Scope 1) and indirect (Scope 2) greenhouse gas emissions, and — where it is reasonable for the size of your business — your value-chain (Scope 3) emissions.
• Use energy and other resources efficiently.
• Reduce, reuse and recycle waste.
• Avoid the use of substances that are restricted or banned under applicable law.

Our own approach is in our Sustainability policy. We do not yet require suppliers to publish a sustainability statement, but where two suppliers are comparable, we’ll prefer the one with a published policy and / or a B Corp certification.

Data protection and confidentiality

Where you handle Pametan information, Pametan-client information or personal data on our behalf, you must:

• Comply with all applicable data-protection laws, including UK GDPR and the Data Protection Act 2018 — and, where applicable, the EU GDPR, CCPA, PIPEDA, Quebec Law 25 or other equivalent regimes.
• Process personal data only on documented instructions from Pametan, except where required by law.
• Maintain appropriate technical and organisational security measures, proportionate to the sensitivity of the data and the risk of harm.
• Restrict access to personal data and to confidential Pametan information to those who genuinely need it.
• Notify us without undue delay (and in any case within 24 hours where reasonably practicable) of any personal-data breach, security incident or unauthorised disclosure affecting Pametan data.
• On termination of our relationship, return or securely destroy all Pametan information in your possession in line with our written instructions.

If your contract with Pametan involves processing personal data, you will be required to enter into a written data-processing agreement consistent with UK GDPR Article 28. This Code does not replace that agreement; it sits alongside it.

Sub-contractors

You may sub-contract work you do for Pametan only with our prior written agreement. Where you do, you must:

• Flow the standards in this Code down to your sub-contractors, either by direct adoption or by ensuring their own policies and contractual commitments achieve substantively the same outcome.
• Take reasonable steps to monitor sub-contractor compliance with the cascaded standards.
• Remain primarily responsible to Pametan for the sub-contractor’s performance and conduct, as if the work had been performed by you.

Reporting concerns

If you become aware of any breach of this Code — by yourself, by your sub-contractors, by anyone at Pametan, or by anyone acting on Pametan’s behalf — please raise it. You can:

• Email the Founder at hello@pametan.co.
• Use our Whistleblowing procedure. Suppliers are explicitly within scope of that procedure, which includes a route directly to a prescribed external regulator under PIDA 1998.
• Contact a prescribed external regulator. We will not retaliate against you for doing so.

We commit to take any concern raised seriously, to investigate proportionately, and not to take adverse action against you for raising a concern in good faith.

Compliance and consequences

Compliance with this Code is a condition of doing business with Pametan. From time to time we may ask you for confirmation of compliance, for relevant policies, for evidence of practices described in this Code, or for the right to audit specific elements where the value of our relationship or the risk involved makes this reasonable. We will give reasonable notice.

We treat non-compliance proportionately. For a minor or inadvertent breach we will normally agree a remediation plan with you. For a material or unremediated breach we may:

• Suspend purchase orders or work in flight until the breach is remediated.
• Require a documented corrective action plan with timelines we agree.
• Terminate our contract with you and disengage from the relationship.
• Where required by law or by our regulators, report the breach to a relevant authority.

We expect to use the lighter responses far more often than the heavier ones. We don’t want to disengage from a supplier who is willing to fix something; we’d rather work together to fix it.

Acceptance and review

By accepting a purchase order from Pametan or entering into a contract or engagement with us, you confirm that you have read and will comply with this Code. We may incorporate this Code into our contracts with you by reference.

We review this Code at least annually. We will tell you in writing if there is a material change. Continued supply to Pametan after a notified material change is your acceptance of the updated Code.

Contact

Questions about this Code, requests for an alternative format, or anything else: hello@pametan.co. We aim to respond to supplier queries within five working days.

Pametan Ltd · Companies House No. 16023621 · Registered office: 20 Wenlock Road, London N1 7GU. This Code is published in plain English; if you need it in an alternative format, write to hello@pametan.co. Other Pametan policies referenced in this document: Anti-bribery and corruption policy, Whistleblowing procedure, Modern Slavery statement, Sustainability policy, Privacy Policy.