Upholding Excellence and Integrity

Privacy Policy

Nomia is committed to safeguarding the privacy of visitors to our websites.

This Privacy Policy was last updated on April 2024

We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you how we look after your Personal Data when you visit the Website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

Who we are and how to contact us:

www.nomia.com (the “Website”) is a website operated by Bell Procurement Management Limited t/a Nomia (“we”/ “our”/ “the Website”). We are registered in England and Wales under company number 09989553 and have our registered office at 125 Wood Street, London, England, EC2V 7AW. Our VAT number is GB 297 8663 27.

This privacy policy should be read along with our Terms of Use and Cookies Policy. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1.Glossary

• “Personal Data” means all information that you submit to Nomia via the Website. This definition incorporates, where applicable, the definitions provided in the Data Protection Laws.
• “Data Protection Laws” means any applicable law relating to the processing of personal Data, including but not limited to GDPR, and any national implementing and supplementary laws, regulations and secondary legislation.
• “Data Controller” is a person, company or other body that determines the purpose and means on Personal Data processing.
• “GDPR” means the General Data Protection Regulation which governs the way in which Personal Data is gathered and handled in the European Union.
• “User” or “you” means any third party that accesses the Website and is not either (i) employed by Nomia and acting in their course of employment or (ii) engaged as a consultant providing services to Nomia and accessing the Website in connection with the provision of such services.

2. Scope of this Privacy Policy

2.1 This Privacy Policy applies only to the actions of Nomia and users with respect to this Website. It does not extend to any other website that can be accessed from this website including, but not limited to any links we provide to any other website.

2.2 For the purpose of the applicable Data Protection Laws Nomia is the Data Controller, this means that Nomia determines the purposes for which, and the manner in which, your Personal Data is processed.

3. Personal Data Collected

3.1 We may collect, use, store and transfer different kinds of Personal Data which we have grouped together as follows:

• Identity Data – e.g. first name, last name, username, or similar identifier.
• Contact Data – e.g. billing address, delivery address, email address and telephone numbers.
• Transaction Data – e.g. details about payments to and from you and other details of products and services your company has purchased from us.
• Technical Data – e.g. internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website.
• Profile Data – e.g. your username and password, purchases or orders made by you, feedback and survey responses.
• Usage Data – e.g. information about how you use our Website, products and services.
• Marketing and Communications Data – e.g. your preferences in receiving marketing from us and our third parties and your communication preferences.
• Location Data – e.g. Region, country, state, and coarse and precise geolocation data.
• We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Data. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature.

4.How we collect Personal Data

4.1 We may collect Personal Data in the following ways:

• Direct Interactions: You provide your personal information when you interact with us, such as when you register for services, fill in forms, communicate with us.
• User Contributions: We collect your personal information when you or others upload, share, send, or input that information through our services or networks, or when you or they communicate with us.
• Automatically: We automatically collect personal information about you when you interact with us, such as when use our services, visit our offices or events, open emails or view advertisements from us, or communicate with us. We may collect some of this personal information by using cookies and other similar technologies, and we recommend you review our Cookies Policy for more information.
• Third Party or Publicly Available Sources: We may receive your personal information from third parties, such as our third party business partners (including data brokers and advertising partners), your organizations, governmental agencies who publish public records, and other publicly or generally available sources (including online websites).

5. How we use your Personal Data

5.1 We may use your Personal Data, based on the different legal reasons (also called legal basis) for processing that Personal Data being performance of a contract, legitimate interest, as outlined in your consents or to protect your vital interests or those of another person are as follows:

• To fulfil our contractual obligations
• Communicate with you about our services and process related transactions.
• For any purpose with your consent or to follow your instructions.
• To operate, improve, and/or personalize our services, corporate networks and devices, offices, events, and related infrastructure.
• Develop new products, services, content, and other offerings.
• Monitor the usage of our services, corporate networks and devices, offices, events, and related infrastructure.
• Audit usage of our services, corporate networks and devices, offices, events, and related infrastructure, including consumer interactions.
• Ensure the security of our services, corporate networks and devices, offices, events, and related infrastructure.
• Detect fraud and abuse, including for our services, corporate networks and devices, offices, events, and related infrastructure.
• Manage our internal operations (such as account administration, corporate asset deployment, billing, troubleshooting, repair).
• Provide our services to third parties where our services and content includes your personal information. Under some local privacy laws, this may constitute a “sale” of personal information.
• Exercise our rights and/or protect our or others’ rights or property.
• Effectuate the sale, merger, acquisition, or other disposition of our business.
• Advance our other commercial and economic interests as permitted by law.

If you have consent to receive advertising and marketing information from us, but then later change your mind and no longer wish to receive marketing, please inform us so we can remove you from our distribution lists. You can contact us on info@nomia.com or the contact details below in section 7.2.

6. Disclosure of Personal Data

6.1 We may share your Personal Data with third parties to fulfil the purposes as set out in section

6.2 Where we do share Data with such third parties we will require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

7. How we keep your Personal Data secure

7.1 We will use technical and organisational measures to safeguard your Personal Data and we will store your Personal Data on secure servers.

7.2 Technical and organisational measures include measures to deal with any suspected data breach.  If you suspect misuse or unauthorised access to your Personal Data, please let us know immediately by contacting us as per details below:

Address:           125 Wood Street, London, England, EC2V 7AW

Email:               info@nomia.com

7.3  In the event that it is necessary for us to transfer your Personal Data out of the UK or EU, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data (i.e. where there is an adequacy decision).
• Where we use certain service providers, we may use specific contracts approved for use in the UK or EU which give personal data the same protection it has in the UK or EU.

8. Data Retention

8.1 Unless a longer retention period is required or permitted by law, we will only hold your Personal Data on our systems for the period of time required to fulfil the purposes outlined in this Privacy Policy, where we have a legal reason to retain it, or until you request that the Personal Data be deleted and we have no other reason to retain it.

8.2 Please note that even if we delete your Personal Data, it may persist on backup or archival media for legal, tax or regulatory purposes.

9. Your rights

9.1 Your local privacy laws may grant you rights regarding your personal information, and we will not knowingly discriminate against you because you have exercised any of your privacy rights. These rights differ based on the local laws that apply to you, but could include one or more of the following:

• Right to access. The right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information.
• Right to correct. The right to have your Personal Data corrected if it is inaccurate or incomplete.
• Right to erase.  The right to request that we delete or remove your Personal Data from our systems.
• Right to restrict our use of your Personal Data.  The right to limit the ways in which we use your Personal Data.
• Right to Personal Data portability. The right that we move, copy or transfer your Personal Data.
• Right to object.  The right to object to our use of your Personal Data including where we use it for legitimate interest.

9.2 To make enquiries or to exercise any of your rights set out above please contact us.

9.3 If you are not satisfied with the way your request in relation to your Personal Data has been handled you may be able to refer your request to the relevant data protection authority.  For the UK, this is the Information Commissioners Office (ICO), the ICO’s contact details can be found at https://ico.org.uk/.

10. Links to other websites

10.1 This Website may provide links to other websites.  We have no control over third party websites and we are not responsible for the content of these websites. This Privacy Policy does not extend to the use of any other websites, and you are advised to read the Privacy Policy or statement of those websites before using them.

11. General

11.1 We may need to change this Privacy Policy from time to time. When we make changes, we will indicate this by updating the “Last Updated” date and posting the updated Privacy Policy on this page. We may send you e-mail notifications where there are changes to our Privacy Policy, but you should check our website frequently to see the current Privacy Policy and any changes made to it.

Cookie Policy

We need your permission to use cookies
If your browser is set to accept cookies, and you continue to use our website, we assume that we have your permission to use cookies. Should you wish to remove or not use cookies from our site you can learn how to do this below, however, doing so will likely mean that our site will not work as you would expect.

Our website uses cookies, as almost all websites do, to help provide you with the best experience we can. Cookies are small text files that are placed on your computer or mobile phone when you browse websites.

Nomia uses a small number of cookies for session continuity and for the purposes of collecting statistics about site usage. These cookies do not give us access to your computer and do not reveal any information other than whatever data you choose to provide us with via web forms or other inputs.

We do not use cookies to:

• Collect any personally identifiable information (without your express permission)
• Collect any credit card information
• Pass data to advertising networks
• Pass personally identifiable data to third parties
• Pay sales commissions

We use Google Analytics cookies to collect information about how visitors use this site and when issues are encountered (such as broken links). Google analytics stores information about what pages you visit, how long you were on the site, how you got here and what you click on. We do not store your personal information so this information cannot be used to identify who you are. We do not allow Google to use or share our data. Google provides more details on the Google privacy and cookie policy page. Google also provides a browser add-on which allows you to opt out of Google Analytics across all websites.

If you want to delete any cookies already on your computer, please refer to your browser vendors instructions by clicking Help in your browser menu. You can also find out more about cookies and how to delete and control them at www.allaboutcookies.org or click Help in your browser menu.

Web browsers are usually set to accept all cookies automatically, but you can modify your browser to decline or query cookies. This site may not work properly if cookies are disabled.

Anti-Slavery Policy

Introduction from the Chief Executive Officer

Modern Slavery is an umbrella term to refer to situations of exploitation that an individual cannot refuse or leave because of threats, violence, coercion, deception, or abuse of power.

We are committed to complying with all applicable international human rights standards, labour and employment laws, rules and regulations, and working to mitigate the risks of modern slavery and human trafficking in our business operations and supply chains.

This statement covers the period 1 April 2022 to 31 March 2023, in compliance with the UK’s Modern Slavery Act.

This statement assesses our risk, outlines our efforts and sets commitments for the coming year.

Section 1. Organisational structure, operations and supply chains

Founded in 1995, Bell Microsystems Limited (“BML”) has two main businesses:

• Systems integrator (trading as “Bell Integration”) delivering IT hardware and IT services, consulting and supporting organisations to develop the workspace that suits their needs by providing flexible and innovative solutions to help them move to up to date IT services and to streamline their operations.
• Procurement management services (trading as ‘Bell Procurement Management’) including the sale of deliverables to its customers purchased from its vetted supplier base located predominantly in Europe and the Asia Pacific region. Bell Procurement Management is a subsidiary of Bell Microsystems Limited.

As of 21 September 2023, Bell:

• Employs 574 full and part time workers in Bell Integration and 64 full and part time workers in Bell Procurement Management.
• More information can be found about Bell on our websites.

Our supply chains in the last financial year

Bell Integration

• Bell Integration have approximately 900 third party suppliers from 23 countries.
• The majority of Bell Integration’s direct suppliers (tier 1) are registered in Europe.

Bell Procurement Management

• Bell Procurement Management work with over 300 third party suppliers in 18 countries (UK, Europe and South East Asia).
• The majority of Bell Procurement Management direct suppliers (tier 1) are registered in low risk countries but some of their operations and supply chains are global.

Section 2 – Risk Assessment and Due diligence

Based on the nature of our business, we consider the risks of modern slavery and human trafficking to be low in our direct business operations.

However, we are aware that inherent and potential risks of modern slavery and human trafficking could be present in our supply chain, and we recognise that we have a role to play in the global effort to eliminate modern slavery and human trafficking.

Suppliers go through an onboarding process in which they are asked to comply with a minimum set of requirements in order to be included in our supplier base. This includes financial due diligence and acceptance of Bell’s Supplier Charter.

In the last year, Bell Integration have initiated a new automated Supplier Management platform to ensure that we are conducting thorough checks on all Bell’s suppliers (including all strategic and principal suppliers). This includes a risk-based questionnaire/screening tool to be used when onboarding all new suppliers which includes assessing modern slavery risks.

Whilst instances of modern slavery were not identified in Bell’s operations and supply chain for the period of this report, Bell intends to work with any parties found to have instances of modern slavery in their operations or supply chain by providing education, guidance, and assistance as required.

No whistleblowing complaints were received.

Section 3. Training and awareness raising

Increasing the skills and capability of our people is fundamental to our ability to conduct effective modern slavery due diligence on our supply chains.

Training is delivered through e-learning courses, face-to-face line manager events, webinars, and induction programmes for new employees.

Our commitment to ensuring our staff have received the necessary training throughout the financial year is evidenced by 95% of our active employees having completed the e-learning training in Modern Slavery (figure correct on 31 August 2023).

We expect all our suppliers to operate in a responsible, ethical, open, and transparent way and in compliance with all applicable laws and regulations. Our global teams work closely with suppliers to communicate our standards and help suppliers build their capacity to provide working environments that are safe, respectful of human rights, and free of modern slavery.

All employees are required to familiarise themselves with our Anti-Slavery and Human Trafficking Policy.

Section 4. Key performance indicators to measure effectiveness of steps being taken

In September 2022, our performance on environmental, social and governance matters was recognised by the renewal of a Gold EcoVadis assessment for the Bell Procurement Management business (an independent sustainability ratings agency providing transparency into an organisations’ sustainability practices).  In December 2022, Bell Integration business was awarded a Silver EcoVadis rating.

Since its launch, 100% of applicable suppliers have accepted the terms of Bell’s Supplier Charter. Our Supplier Charter requires our Suppliers to treat people with dignity and respect. All suppliers commit to:

• Comply with our Anti-Slavery and Human Trafficking Policy.
• Not engage in any form of human trafficking, procure commercial sex acts or use forced labour.
• Not use misleading or fraudulent recruiting practices, use recruiters that do not comply with local labour laws in the country where the recruiting takes place, expect workers to pay for a job, provide housing that does not meet the standards of the country where work is performed, or fail to provide an employment contract or recruitment agreement if required by law.
• Ensure that workers have freedom of movement and are free to leave their employment after reasonable notice.
• Return immediately any workers’ government-issued identification, passports or work permits once they have confirmed workers’ identities or working rights (to the extent that this is required).

In addition, we may require suppliers to demonstrate that they have relevant policies and procedures in place.

Bell seeks to continuously improve its own purchasing practices. We understand that we can have a profound impact on the conditions of workers in supply chains through our own purchasing practices. Aggressive pricing, short lead times and late payments are just a few examples of purchasing practices that can unintentionally create modern slavery risks.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015. This Statement has been approved by the board of directors of Bell Microsystems Limited and its relevant subsidiaries on 20 September2023.

21 September 2023

Code of Conduct

Introduction

Nomia is committed to maintaining high standards in the conduct of all its business activities. It expects and requires all its employees to become stakeholders in the commitment to meeting these standards.

These standards are borne out of the core principles and values that underpin our business, that of integrity, honesty, and openness so that our customers can rely on Nomia’s One Version of Events ethos.

We appreciate and understand the commercial reality of our customer and that circumstances change.  As a procurement partner, we operate in an agile and responsive manner so that we can always deliver value to our customers. Our commitment is to do all this in a friendly and engaging manner.

Purpose of this Code

In the spirit of transparency, and openness the Code of Conduct (“the Code”) is a public statement designed to help employees and others make informed, ethical decisions and to demonstrate our commitment to doing the right thing.

While this Code addresses a wide variety of topics, Nomia relies on you to use your judgement, experience and above all common sense as it cannot, and does not, address every possible situation.

Operating in many countries, as we do, means there may be times when international or local laws, regulations, or customs present a challenge to applying the Code. Whenever there is a choice between applying the Code or adhering to the spirit of the Code and local customs, you are expected to apply the strictest standard and not follow customs that violate the Code. If in doubt, you are expected to seek advice before taking any action that may compromise yourself or Nomia.

Nomia’s reputation as an ISO certified, customer-centric, innovative, and agile business, focused on sustainability is integral to its ongoing growth and success. Please take the time to read this Code, keeping in mind that over time as Nomia grows and evolves, this Code will necessarily evolve as well.

Who must follow this code?

Our Code applies to all Nomia employees, officers, and members of the Board.

Business partners, including third parties, can have a direct impact on our reputation through their actions.  For this reason, we want to work with business partners that share our values and expectations and encourage all our contractors and their employees to act in a way that is consistent with the Code. Where we find or believe that our business partners have breached the values in the Code, we will always take steps to preserve its integrity.

Each of us has a personal responsibility to incorporate, and to encourage each other to integrate, these principles into our work. All suggestions as to how this Code can be improved will be welcomed.

Our Expectations

Quality

We deliver our services and internal processes securely and in line with industry best practices, to provide prudent and commercially pragmatic solutions for our customers. We pride ourselves on our integrity and reliability and as a sound commercial partner on whom others can rely. To facilitate this, you should understand and manage risks well by:

• Conducting your work in a professional manner and in a way that follows our quality control standards and, where quality measures don’t exist, by defining them.
• Maintaining any professional registrations and certifications needed to ensure that customers receive the most competent and contemporaneous professional service.
• Continuing your own personal professional development by seeking to develop skills, learn new ones and further improve your understanding of your subject area. You can do this by taking advantage of Nomia’s numerous learning options; and
• Not making promises or commitments that you or Nomia cannot, or do not intend to, honour.

Buying responsibly

Nomia supports industry-wide professional standards and encourages all buyers to adhere to the CIPS Code of Ethics and Professional Conduct 2022.

Nomia’s team of Buyers has developed a reputation for working with our business partners in an honest, transparent, and ethical way, always respecting diversity, local cultures, and customs.

Our suppliers and business partners are essential to our ability to do business and meet our stakeholders’ expectations. That is why we choose carefully to seek to work with others who share the same approach as us.

Make sure you know and follow the Nomia customer-related requirements that apply and communicate our policies and procedures regularly to suppliers.

Report to the Director, Procurement Services, or use the Whistleblowing procedure, any indications that a supplier or business partner is not complying with applicable laws or their contractual obligations.

Collaborate with suppliers to foster effective Integrated Management Systems and consider human rights, anti-bribery, and corruption policies in the relevant supply chain, as well as environmental and social performance as part of an evaluation of the supplier.

Ensure that the reports and records used to assess supplier’s performance are treated as confidential and not disclosed to any third party without the supplier’s written consent.

Fair competition

The international nature of the Nomia business means that we are subject to a variety of laws and regulations around the world that prohibit anti-competitive practices.  At a general level you must not communicate competitively sensitive information directly with any of our competitors or indirectly through an intermediary.  This includes information like costs, prices, discounts, sales, terms of business.  Information is more likely to be competitively sensitive if it is not public.  Caution should be exercised when attending any trade association event to make sure you are not participating in any discussions that could be considered anti-competitive.

Under no circumstances should you agree with a customer, supplier, distributor, or reseller the price at which goods or services should be re-sold and any exclusivity arrangements or restrictions on re-sale into another territory or market should be subject to legal approval.

Competition and antitrust laws are complex. If you have any doubts or questions consult the Legal team.

If you have reason to believe that there may have been anti-competitive behavior, then you should make this known to your line manager unless that is not practical in which case follow the Whistleblowing policy and procedure.

Respecting international trade laws

We abide by the trade laws of all countries in which we operate including trade embargos, economic sanctions as well as import and export laws.

Most countries in which Nomia operates impose a certain level of restriction on the movement of products across borders; this can often be a complex area with wider commercial and legal ramifications.

If you have any questions speak to your manager or the Legal team.

Preventing money laundering

Money laundering is the process of hiding the source and/or the provenance of funds or moving those funds from one person/organisation to another when there is a reasonable expectation that those funds have been obtained because of illegal activity. The process of making these funds appear legitimate is known as ‘washing’ and is also illegal. Laundered money often benefits organised crime groups and can even fund terrorism.

The law surrounding money laundering is necessarily stringent and covers individuals and organisations alike. You should familiarise yourself with our due diligence procedures.

If you have any questions always raise them immediately with your line manager and remember to never let the person or organisation in question know that you have concerns or that you have raised your concerns with your line manager.

Solicitation and distribution

Solicitation is any form of request for money, support or participation for products, groups, organisations or causes which are unrelated to our operations. Distribution means disseminating literature or material for commercial or political purposes.

We don’t allow solicitation and distribution in the workplace unless it is to seek support for a cause, charity or fundraising event sponsored, funded, organised, or authorised by Nomia.

Political activity

In accordance and in compliance with applicable laws, Nomia exercises its right and responsibility to make its position known on relevant issues. As an individual, you have the right to personally participate in the political process, including making personal political contributions. However, you need to make it clear that your personal views and actions are personal and not reflective of Nomia.

Do not use company funds or resources to support any political candidate or party. Obtain approval before engaging in any lobbying activities.

Personal political activities can sometimes create a conflict with Nomia. Talk to your manager if you or a close relative are planning to accept or seek a position in public office, or if any other political activity might have an impact on Nomia or on your job.

Sustainability and environmental protection

Use your skills and expertise to deliver our services in a sustainable manner and to find opportunities to make a positive impact on the planet.

Encourage the use of local workforces, suppliers, and goods where feasible and appropriate.

Do not disrespect or deliberately ignore local customs or traditions.

Personal Declaration

Nomia continued reputation and success depend, to a very large extent, upon all of us playing an active role in caring about our work, our customers, and our communities.

Be familiar with this Code, understand and comply with it.

Speak up when you see something you don’t think is right, when you have an idea, a question, or a concern.

Security Statement

Data Protection, Privacy and Security
Information Security is paramount, and we require our suppliers to be committed to protecting the systems and data they store or access and to respect the privacy rights of their workforce, and all parties they deal with. This includes complying with applicable privacy and information security laws and regulations.

Under no circumstances may our employees accept money from suppliers.

Suppliers shall report any instances of illegal or unethical behaviour or breaches of this Charter (in relation to the goods and services being provided to us) in accordance with our whistleblowing policy.

We require that our suppliers have processes in place to ensure that workers may report concerns or illegal activities in the workplace in good faith without threat of reprisal, intimidation, or harassment.

Supplier Charter

‘At Nomia we hold ourselves to high standards and these standards reflect our internal values and the expectations of our external stakeholders such as customers, suppliers, and the public. We seek relationships with suppliers who share a common commitment to comply with applicable laws and regulations, behave ethically, sustainably and with integrity and amongst other things promote the safety, health and well-being of employees.

Our partners are essential contributors to our success and this Charter helps you to understand the standards that we hold ourselves to and our expectations of you.

We look forward to welcoming you into our rapidly growing partnership network.’

This Charter is formally incorporated into our contracts with all our suppliers. To the extent that our contractual arrangements contain more detailed requirements in respect of any principles covered in this Charter, this Charter is intended to supplement (and not override) those contractual obligations.

In some circumstances, we may require our suppliers to complete self-assessments and/or an annual declaration which confirms their compliance with this Charter. Our suppliers must promptly notify us if they, or another party in their supply chain, become aware or reasonably suspects that it is unable to comply with the principles in this Charter.

If a supplier, or another party in its supply chain, is unable to, or fails to, comply with this Charter, we will discuss this issue with the supplier and may require the supplier to take such steps as we consider necessary to address the impact of, and remediate, the non-compliance.

If local legislation, regulation, or laws provide a higher level of protection than which is included in this Charter, the local legislation will take precedence. We reserve the right to amend the Charter from time to time.

Compliance with Laws

We expect our suppliers to comply with all relevant laws, codes and regulations, and to act in an ethical manner.

As such, suppliers must:

• Comply with all applicable laws, codes and regulations wherever they operate;
• Promptly notify us of any significant criminal or civil legal actions brought against them; and
• Promptly notify us of any fines or administrative sanctions brought against them which relate in any way to the requirements set out in this Charter.

Health and Safety
Our suppliers must maintain a safe workplace and implement continuous improvement and management systems to ensure compliance and effective controls. We may require suppliers to demonstrate that they have relevant practices and policies in place.

We expect our suppliers to take all reasonable steps to protect the emotional and physical health and wellbeing of their workforce and provide all necessary supervision, training, instruction, equipment, appropriate flexible working arrangements, and information to their workforce and consult on issues that may affect health and safety. Suppliers must comply with local site rules for visits, deliveries or provision of services.

Environment and Sustainability
Suppliers are expected to operate in a sustainable and environmentally responsible manner, complying with all regulations, reporting requirements and/or laws that are best practice for their industry. We may require suppliers to demonstrate that they have relevant practices and policies in place.

Suppliers are expected to support the delivery of our environmental, social and governance (ESG) objectives by promoting socially responsible, sustainable procurement and supply chain management practices, and by agreeing to integrate ESG considerations into their design and/or provision of services.

We encourage our suppliers to engage the community to help foster social and economic development, contributing to the sustainability of the communities in which they operate and to offer solutions that improve the resilience of our operations, whilst also understanding how their own business needs to adapt to a changing climate.

Modern Slavery
Suppliers are expected to treat people with dignity and respect. As such, they shall:

Comply with our Anti-Slavery Human Trafficking Policy.

• Not engage in any form of human trafficking, procure commercial sex acts or use forced labour.
• Not use misleading or fraudulent recruiting practices, use recruiters that do not comply with local labour laws in the country where the recruiting takes place, expect workers to pay for a job, provide housing that does not meet the standards of the country where work is performed, or fail to provide an employment contract or recruitment agreement if required by law.
• Ensure that workers have freedom of movement and are free to leave their employment after reasonable notice.
  Return immediately any workers’ government-issued identification, passports or work permits once they have confirmed workers’ identities or working rights (to the extent that this is required).
• We may require suppliers to demonstrate that they have policies relevant procedures in place.

Child and Underage Labour
Suppliers shall not use child labour. “Child” means any person under the age of 15, or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest.

Children under the age of 18 must not be employed for any hazardous work or work that is inconsistent with the child’s personal development.

Working Hours, Wages and Benefits
Suppliers shall ensure the working hours of the supplier’s workforce does not exceed the maximum set by local law and shall include the minimum breaks, and rest periods and time off between the end of one shift and the start of another, set by law. Workers shall be allowed at least one day off every seven days.

Suppliers shall be considerate to the type of work performed and the acceptable working hours for the role concerned.

Suppliers shall ensure its workers are provided fair wages and benefits that are in accordance with applicable laws, industry standards and collective agreements and paid in a timely manner.

Suppliers shall not use deductions from wages as a disciplinary measure.

We require our suppliers to ensure that all members of their workforce understand their employment conditions and when determining these, consideration should be given to the type of work to be performed, the market rate for that type of work and any statutory minimum wage in that country.

Freedom of Association
Our suppliers must respect the rights of members of their workforce to be free to decide on joining unions or other similar workers’ associations, to the extent permitted by applicable law, and to be free of any discrimination, harassment, intimidation or victimisation for their choice to join these organisations or engage in other lawful industrial activity.

Discrimination, Harassment and Abuse

We require our suppliers to build an inclusive work environment that is free of harassment and unlawful discrimination and to take prompt action against inappropriate workplace behaviour.

Suppliers shall ensure equal opportunities at any stage of employment, from the selection of suitable applicants, their interview and assessment, to the terms of their employment, payment and grounds for dismissal.

Gender Diversity and Inclusion
Our Suppliers must foster an inclusive workforce and a culture of respect toward differences in gender, sexual orientation/identity, age, disability, ethnicity or appearance, marital or family status, religious or cultural background or other protected attribute.

Our Suppliers must encourage women’s equality and safety and we may require Suppliers to demonstrate that they have the necessary support arrangements in place to promote gender equality, equal access, and the empowerment of women.

Anti-bribery, Corruption and Whistleblowing
Bribes or other means of obtaining undue or improper advantage shall not be promised, offered, authorised, given, or accepted, this includes facilitation payments. This prohibition covers promising, offering, authorising, giving or accepting anything of value, either directly or indirectly through a third party, in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage.

Monitoring and enforcement procedures shall be implemented to ensure compliance with anti-corruption laws.

Suppliers shall not offer our employees any gifts, payments, fees, services, discounts, valued privileges or other favours where these would, or might appear to, improperly influence them in performing their duties. Our employees can be offered common courtesies normally associated with accepted business practices, so long as these are offered openly and not in a form that could be construed as a bribe, payoff, or secret compensation.

Competition and Antitrust
Our suppliers should ensure they conduct their business in compliance with all applicable antitrust and competition laws designed to guarantee free and open competition; and prohibit anti-competitive behaviour by either individual players acting alone or multiple players acting together.

Suppliers certify that their prices and methods for calculating prices have been arrived at independently, that the information has not been and will not be shared with any other competitor, and that the supplier has not induced and will not induce any other concern to submit or not to submit an offer for the purpose of restricting competition.

Fraud and Money Laundering

Suppliers shall:

• Act in accordance with all applicable international standards and laws on fraud and money laundering
• Not do or omit to do anything likely to cause any party to be in breach of any of such international standards and laws.
• Maintain an effective anti-fraud and (where appropriate) an anti-money laundering compliance program, designed to ensure compliance with the law including the monitoring of compliance and detection of violations.

Tax Evasion

Suppliers shall:

• Comply with and have, since 30 September 2017 complied, with all applicable laws, statutes, regulations, guidance, recognised practice and codes, relating to the prevention of tax evasion and/or the prevention of the facilitation of tax evasion (whether within, or outside of, the United Kingdom) including but not limited to the UK’s Criminal Finances Act 2017 (“CFA 2017”)

Trade Sanctions
Suppliers should ensure they conduct their business in compliance with all lawful international sanctions’ regimes, and that they do not engage with any sanctioned parties. As such, suppliers must:

Be aware of, and fully comply with, all lawful sanctions regimes affecting their business; and
Implement effective internal controls to minimise the risk of breaching sanctions, and provide training and support to ensure their workers understand them and implement them effectively, particularly where their work involves international financial transfers or cross-border supply or purchase of products, technologies or services.

Data Protection, Privacy and Security
Information Security is paramount, and we require our suppliers to be committed to protecting the systems and data they store or access and to respect the privacy rights of their workforce, and all parties they deal with. This includes complying with applicable privacy and information security laws and regulations.

Under no circumstances may our employees accept money from suppliers.

Suppliers shall report any instances of illegal or unethical behaviour or breaches of this Charter (in relation to the goods and services being provided to us) in accordance with our whistleblowing policy.

We require that our suppliers have processes in place to ensure that workers may report concerns or illegal activities in the workplace in good faith without threat of reprisal, intimidation, or harassment.

Intellectual Property Rights
We require our suppliers to respect all our confidentiality and intellectual property rights, and to safeguard against improper use of intellectual property, including disclosure of confidential or sensitive information, including pricing. Suppliers should only use our or our third-party confidential information and intellectual property in accordance with their contractual arrangements with us and seek permission from us before sharing any information externally.

Land Rights
It is important that our suppliers respect the legal land rights of individuals, indigenous people, and local communities. Suppliers must be the legal and rightful owner or user of the property on which they operate. Developments and acquisitions of agricultural and forestry land are subject to free, prior, and informed consent of the affected local communities, including women or indigenous peoples and other marginalised stakeholders.

Conflict Minerals
We support ethical sourcing of all minerals and Suppliers must comply with all applicable laws concerning responsible sourcing and conflict minerals. We expect all our suppliers to conduct the necessary due diligence and provide proper verification of the country of origin and source of the materials used in the products they supply.

Business Integrity
We require our suppliers to act with the highest of ethical standards and with professionalism, honesty, integrity, and fairness in every aspect of their business and to apply this Charter across its supply chain.

Suppliers must make us aware of any potential conflicts of interest as soon as they are known.

We require all our suppliers to ensure that the workforce they provide to Nomia are engaged in accordance with applicable laws and deduct or pay tax and benefits.

Publicity and Advertising
Our suppliers must uphold standards for fair business practices including accurate and truthful advertising, and fair competition.

Suppliers must not use our or our customers’ name or logos in publicity or advertising or use the suppliers’ business relationships with us or its customers to imply any endorsement by us of the supplier’s goods or services without our written consent.

Resilience and Business Continuity
We require our suppliers to have a sufficiently robust resilience and business continuity program, appropriate to their business and good industry practice, to protect their business operations from disruptive events that may impact the supply of goods and/or services to Nomia and its customers.

Additional risk controls and resilience requirements may be communicated to suppliers depending on the nature of goods or services being supplied.

Terms and Conditions Third Party Vendors

COM24 -General Terms and Conditions of Purchase of Goods and Services Bell Integration PTY ltd

COM4 – General Terms and Conditions of Purchase of Goods and Services Bell-TSII Limited

COM17 – General Terms and Conditions of Purchase of Hardware (Bell-TSIV Limited)

COM18 – General Terms and Conditions of Purchase of Software (Bell-TSIV Limited)

COM19 – General Terms and Conditions of Purchase of Services (Bell-TSIV Limited)

COM20- General Terms and Conditions of Purchase of Maintenance (Bell-TSIV Limited)

COM21 – General Terms and Conditions of Purchase of Cloud Services (Bell-TSIV Limited)

COM22 – General Terms and Conditions of Purchase of Recruitment Services (Bell-TSIV Limited)

COM23 – General Terms and Conditions of Purchase of Goods (Bell-TSIV Limited)

COM3 – General Terms and Conditions of Purchase of Goods and Services (Bell TSII-Limited)

COM32 – General Terms and Conditions of Purchase of Services (Bell Group Asia Pte Ltd)

COM33 – General Terms and Conditions of Purchase of Software (Bell Group Asia Pte Limited)

Whistle-Blowing Policy

Anti-bribery, Corruption and Whistleblowing
Bribes or other means of obtaining undue or improper advantage shall not be promised, offered, authorised, given, or accepted, this includes facilitation payments. This prohibition covers promising, offering, authorising, giving or accepting anything of value, either directly or indirectly through a third party, in order to obtain or retain business, direct business to any person, or otherwise gain an improper advantage.

Monitoring and enforcement procedures shall be implemented to ensure compliance with anti-corruption laws.

Suppliers shall not offer our employees any gifts, payments, fees, services, discounts, valued privileges or other favours where these would, or might appear to, improperly influence them in performing their duties. Our employees can be offered common courtesies normally associated with accepted business practices, so long as these are offered openly and not in a form that could be construed as a bribe, payoff, or secret compensation.