Supplier Code of Conduct Purpose and Scope
In our own business, Marex applies high legal and ethical standards and promotes and expects them amongst our suppliers. Marex’s Supplier Code of Conduct reflects evolving regulations, Marex’s own principles and values, and the expectations of our stakeholders.
The Marex Supplier Code of Conduct (the ”Code of Conduct”) lays out the minimum standards and expectations for all suppliers which Marex engages with and uses on a one-off or continuing basis (‘Suppliers’). Suppliers are deemed to have read, understood, and consented to this Code of Conduct when contracting with Marex.
The principles of Marex’s Code of Conduct will be integrated within our procurement decisions, supplier due diligence, contracts, and oversight of supplier relationships.
Governance
Ethical Business Practices
The highest standards of integrity, honesty, and ethical conduct are expected by Marex in all our Suppliers’ business practices and dealings. Suppliers are expected to have policies, systems, and/or procedures in place to ensure the prevention of unethical business practices.
Gifts and Hospitality
Suppliers shall not offer or accept any gift or anything else of value to obtain improper advantages or influence for the Supplier, Marex (including Marex employees and/or their family members and associates), or for any third party. Such gifts may include but are not limited to benefits, fees, commissions, dividends, cash, gratuities, services, or any inducements.
Conflict of Interest
If there is a pre-existing relationship between a person linked to/associated with the supplier and a Marex employee holding a decision making or managerial position, a conflict of interest may arise. Any potential conflict of interest between Marex and a supplier (including their relatives, friends, agents, or associates) must be declared and reviewed by Marex accordingly.
Business Operations
Resilience, continuity, and contingency planning
To ensure that there will be no significant disruption to Marex’s business operations and/ or damage to Marex’s reputation, Marex expects Suppliers to have business resilience, continuity and contingency plans in place for their critical operations in the event of a disaster, for their business and services to continue with minimal interruption in the event of a crisis situation, emergency, weather or natural disaster, pandemic or epidemic, terrorist or security related event, strikes, labour or other resource constraints, facilities and/or system unavailability or outage , power outage, and/or telecommunications unavailability or outage.
Suppliers may be requested to share with Marex their business resilience, continuity and contingency plans and status of their Disaster Recovery (DR) testing or from time-to-time promptly assist with answering any further questions.
Exit Management
Suppliers, where requested, shall have plans as to how in the event of contract termination (planned and unplanned) Marex transition to an alternative supplier. These plans should consider how to ensure that any transition, Marex’s ability to deliver continuous and satisfactory services to its customers and clients would be managed, how Marex will retrieve its data and other assets, and how any transferred workforce will be affected.
Suppliers may be requested to provide evidence that these plans are in place and tested to ensure effectiveness.
Regulatory Due Diligence and Performance Management
Marex is subject to regulatory requirements to identify, monitor and audit the performance of Suppliers that are deemed material and critical and to Marex’s operations.
In line with Marex’s regulatory requirements, Marex is responsible for conducting appropriate due diligence on its Suppliers, who shall respond to requests promptly. It is expected that Suppliers shall likewise conduct appropriate due diligence on their supply chain and subcontractors.
Suppliers shall provide all performance management information and participate in reviews when requested.
Compliance with Marex’s Supplier Code of Conduct
By entering into and continuing a relationship with us, Marex’s Suppliers are required to agree to comply with this Code of Conduct. Marex may at any time audit observance or conduct surveys to confirm compliance with this Code of Conduct, and Marex expects Suppliers to actively audit and monitor their day-to-day management processes as relates to this Code of Conduct and, upon request, provide evidence.
Marex will take whatever action is deemed necessary against a supplier if any breach is found. Such action could result in termination of the business relationship.
Whistleblowing and Raising concerns.
Marex’s whistleblowing policy enables concerns to be raised confidentially, including criminal behaviour, failure to comply with a legal obligation, damage to the environment, regulatory breaches or deliberate concealment of information concerning these.
Suppliers should immediately raise concerns about inappropriate conduct by Marex, its employees or supply chain either to Whistleblowing@marex.com or to their contact at Marex.
Legal Compliance
Marex expects all its Suppliers to comply with all applicable regulations in the regions and jurisdictions in which they operate.
Anti-money Laundering and Counter-Terrorist Financing
Suppliers shall comply in all respects with any applicable anti-money laundering regulations relating to any jurisdiction in which it is established or in which it undertakes its business activities and shall ensure it has in place appropriate corresponding policies and procedures reasonably designed to facilitate compliance.
Anti-bribery and Anti-Corruption
Suppliers shall comply in all respects with any applicable anti-bribery and anti-corruption laws relating to any jurisdiction in which it is established or in which it undertakes its business activities, including but not limited to relevant acts such as the U.S. Foreign Corrupt Practices Act or the UK Bribery Act. Suppliers shall ensure they have in place appropriate corresponding policies and procedures designed to facilitate compliance. Suppliers shall take appropriate steps to ensure that all who act for or on their behalf also comply with such obligations.
Maintaining Confidential Information
Suppliers to recognise that confidential and proprietary information may be disclosed to them by Marex in the normal course of business and to respect and protect the confidentiality of our data and communications.
Information Security and Data Privacy
Suppliers must ensure all Marex information and data are protected from any unauthorised access, destruction, use, modification, and disclosure, through appropriate organisational and technical measures and controls. If identified as a requirement, Suppliers must evidence relevant certification and commit to maintaining this certification throughout any contractual relationship with Marex.
Suppliers must comply with data privacy and information security laws and regulations in the jurisdictions in which they operate, including the EU and UK General Data Protection Regulation (GDPR), the Singaporean Personal Data Protection Act and the Australian federal Privacy Act 1988.
Suppliers must protect all Marex information and adapt appropriate security protocols, systems processes, and practices to do so. Should any form of Data Protection breach occur and other types of incidents affecting Marex data, users, or its clients, Marex must be notified immediately by contacting dpo@marex.com and irs@marex.com.
Suppliers are required to maintain a documented human resources policy, including such procedures that are necessary to ensure the policy is applied consistently within Suppliers organization, is maintained relating to employee hiring and vetting, orientation, training, evaluating counselling, and termination.
Tax Evasion
Suppliers must comply fully with all their obligations in relation to all taxes due within the territories in which they operate or provide services. Suppliers must not participate in tax evasion nor facilitate tax evasion by others. Suppliers shall ensure they have in place appropriate corresponding policies and procedures designed to prevent the facilitation of tax evasion. Suppliers shall take appropriate steps to ensure that all who act for or on their behalf also comply with such obligations.
Prevention of Fraud
Suppliers shall comply fully with all their obligations to prevent fraud. Suppliers must be vigilant regarding fraud risks to which they may be exposed and must not engage in any acts of fraud. Suppliers shall ensure they have in place appropriate corresponding policies and procedures designed to prevent fraud. Suppliers shall take appropriate steps to ensure that all who act for or on their behalf also comply with such obligations.
Financial Sanctions and Embargoes
Suppliers shall comply with any applicable law executing foreign policy, security, sanction, trade embargo or anti-terrorism objectives or similar restrictions imposed, administered or enforced from time to time by: (i) the United Kingdom of Great Britain and Northern Ireland, the United Nations, the European Union, the United States of America or other applicable local regimes as relevant to Marex’s subsidiaries and branches in the countries in which the company operates; (ii) any of their successors; (iii) any other relevant governmental authority; and / or (iv) the relevant authority of any jurisdiction in which the Supplier operates.
Social
Human Rights and Labour practices
Marex supports the protection of human rights and labour practices across the world and complies with all applicable laws and regulations (including but not limited to the UK Modern Slavery Act 2015).
Suppliers are expected to adhere to appropriate human rights and labour practices in any jurisdictions in which it is established, undertakes its business activities, or provides services to Marex. All Suppliers are expected to have the appropriate policies, processes, and procedures in place to comply with labour and human rights regulations which should apply to all employees, subcontractors, and supply chain providers.
Wages, Working Hours, and Benefits
Suppliers shall comply with all applicable laws regarding wages, working hours, and benefits requirements (including but not limited to pension, statutory insurance, health benefits, paid leave, parental leave, maternity leave, family care leave, childcare benefits, and overtime compensation). Marex, where applicable, encourages our supply chain to use living wage standards relevant to their jurisdiction / country, to pay all wages in a timely manner and to ensure that working hours and overtime is limited to humane and productive working conditions.
Anti-Human Trafficking and Modern Slavery
Suppliers shall act in accordance with anti-human trafficking and modern slavery jurisdictional laws. Marex will not knowingly work with Suppliers who commit abuses of anti-human trafficking and/ or modern slavery laws or allow their supply chain or subcontractors to abuse these laws, or use forced or bonded labour. Individuals hired by Suppliers or in their supply chain shall freely choose all employment and be free to leave at any time, subject to reasonable and paid notice periods, and shall not be subject to any unlawful restrictions or coercion practice.
Child Labour Practices
Suppliers should have the appropriate processes, policies, and procedures in place to mitigate abuse of child labour practices in their organization and supply chain. Suppliers, their supply chain, and their subcontractors, must not use child labour and Suppliers must constantly ensure all employees are over the relevant legal minimum age of employment in the relevant country in which they work.
Freedom of Association
Suppliers are expected to meet relevant jurisdictional requirements on workers’ rights to freedom of association and collective bargaining.
Workplace Health and Safety
Suppliers shall comply with applicable Health and Safety laws, for example but not limited to the UK Health and Safety at Work Act 1974. Suppliers should have systems, policies, and procedures in place, and share policies upon request, to support safety for all workers (including subcontractors).
Marex expects Suppliers to provide safe, healthy, and hygienic working environments for employees and visitors, including access to toilet facilities and clean water, adequate safety, and fire safety measures to minimize the risk of injury to health, and appropriate first aid emergency facilities.
Risk and Incident Monitoring, Management and Right to Audit
Suppliers are expected to monitor social risks in their supply chain including but not limited to human trafficking, modern slavery, child labour and workplace health and safety.
Suppliers are expected to be able to audit their supply chain to assess the extent to which workers’ human and labour rights are being upheld and working conditions. When an incident of human trafficking, forced labour, bonded labour, child labour or a breach of workplace health and safety is identified, Suppliers shall take appropriate action to remediate the incident and disclose the incident and/or high risk to the relevant authorities and Marex.
Insurance:
Suppliers should hold and evidence upon request adequate insurance to cover the losses that Marex might experience from Suppliers’ and/or their subcontractor’s(s’) supply chain failure to perform its obligations.
Diversity, Equity, and Inclusion
Marex expects our Suppliers to respect human rights and the diversity of cultural, social, and political norms around the world.
Marex expect Suppliers to promote diversity, equity and inclusion and equal opportunities. Marex expect Suppliers to have policies in place to protect against discrimination, harassment or victimisation including but not limited to sex, race, colour, ethnicity, religion, nationality, sexual orientation, marital or civil partnership status, pregnancy or maternity, gender reassignment, age, or disability.
Suppliers will be required to meet the requirements of any applicable discrimination legislation.
Suppliers may be required to disclose their Diversity, Equity & Inclusion data and performance dependent on jurisdictional requirements and policies to Marex and its’ ESG platform upon request.
Marex expects Suppliers to promote diversity in their supply chain. Suppliers should make their best efforts to provide opportunities from a diverse range of companies, based on nature of the enterprise (for example, social enterprise) and/or size (for example, small and medium sized enterprises).
Environment
Marex is committed to support the green transition, including becoming a Net Zero business by 2050 and reducing our environmental impact and carbon footprint.
Suppliers must comply with relevant environmental legislation or regulatory requirements and must demonstrate to Marex an understanding of the environmental risks, impacts and responsibilities associated with the products and services they provide.
Responsible Sourcing
Marex encourages its Suppliers and their supply chain to source their products and services whilst considering their social and environmental responsibilities.
Energy and Greenhouse Gas Emissions
Suppliers should for their operations measure scope 1, 2 and 3 greenhouse gas (“GHG”) emissions and set reduction targets, to be realised through efficiency measures and other initiatives.
Water
Suppliers are encouraged to conserve and reduce the use of water within their, and their supply chains,’ operations.
Waste
Marex expects Suppliers to minimise or eliminate waste during their, and their supply chains,’ operations.
Waste, including hazardous waste, must be managed in a responsible manner including handling, storage, movement, recycling, and disposal. Suppliers, including their supply chain and subcontractors, must comply with all relevant laws, and workers should be trained comprehensively.
Suppliers will be required upon request to disclose their energy, GHG emissions, Water and Waste performance and targets to Marex and Marex’s ESG platform for emissions measurement, reduction, and reporting.