Supplier Code of Conduct
Date of Creation: 27/03/2024
Date of Last Modification: 31/07/2024
Introduction
Owkin is the first end-to-end TechBio company on a mission to understand complex biology and ensure every patient gets the right treatment. We identify precision therapeutics, de-risk and accelerate clinical trials and develop diagnostics using AI trained on world-class patient data through privacy-enhancing federated technologies.
On this journey, collaboration is key. We are committed to developing lasting and meaningful relationships with our suppliers, aligned with our mission. Our Supplier Code of Conduct outlines the business standards we expect our providers to follow in order to preserve our patients, the environment, employees and collaborators.
This Code of Conduct does not prevent Owkin and its suppliers from setting more detailed and demanding requirements, whether contractually or through their internal governance documents. We require our suppliers to explicitly acknowledge and adhere to the principles of this Code of Conduct. Additionally, they must ensure that their own suppliers uphold these principles throughout their respective supply chains.
Business Ethics, Compliance & Integrity
Anti-corruption & anti-bribery
All forms of corruption, bribery, extortion, and embezzlement are strictly prohibited.Suppliers must comply with all applicable anti-corruption and anti-bribery laws and regulations and implement adequate systems to prevent corruption and comply with all applicable laws, rules, and regulations.
Suppliers are strictly prohibited from offering, giving, soliciting, or accepting bribes or other improper payments, whether directly or indirectly, to influence business decisions or gain an unfair advantage.
Gifts & favors
Suppliers should prohibit the provision or receipt of any payments or gifts. Suppliers shall not provide or accept any financial or other advantage which can take the form of money, gifts, loans, fees, hospitality, services, discounts, charitable contributions, the award of a contract or any other benefit that could create, or appear to create, a conflict of interest or undue influence.
Fair competition
Suppliers shall not abuse a market position that may potentially be considered dominant or engage in any other anti-competitive practices. Suppliers shall conduct their business in compliance with relevant fair competition, fair business practices, and applicable antitrust laws.
Conflict of interests
Suppliers must identify and avoid situations where personal interests, relationships, or activities could conflict, or appear to conflict, with their obligations to Owkin. This includes, but is not limited to, ownership, financial interests or business relationships with Owkin competitors, suppliers, or customers.
Any potential or actual conflict of interest must be promptly disclosed to Owkin before engaging in any business relationship. Suppliers must implement appropriate safeguards to prevent conflicts of interest from arising, establishing internal protocols and controls to manage potential overlaps and ensure impartiality in decision-making. These measures include, but are not limited to, ensuring strict separation of information and employees involved in business relationships with Owkin and any competitors or third party working on similar projects or topics.
Human rights & labor
Freely chosen employment
Every employee must be working on their own free will, without being under threat of punishment. Suppliers shall not use forced, bonded, enslaved, indentured or involuntary prison labor, or engage in human trafficking.
Child labor and young workers
Suppliers must not practice or support any forms of child labor. They shall not employ persons under the age of 16 (or under the legal school-leaving age). Any work assigned to individuals under the age of 18 must be safe, not detrimental to their well-being, and in compliance with the country’s legal minimum working age or the age required to complete mandatory education.
Non discrimination and fair treatment
Suppliers shall ensure a workplace where all employees are treated fairly and without discrimination or harassment. This includes, but is not limited to, protection against discrimination based on gender, race, skin color, age, sex, gender identity or expression, sexual orientation, genetic information, religion, ethnicity, language, physical or mental disability, political affiliation, marital status, or any other status protected by applicable law.
Wages, benefits & working hours
Suppliers shall pay workers fairly and in accordance with applicable wage laws, including minimum wages, overtime hours and mandated benefits. Overtime must be voluntary and comply with national and international standards. Suppliers shall communicate clearly and promptly with workers about the basis of their compensation, any required overtime, and the wages to be paid for such overtime.
Diversity, equity & inclusion
Suppliers shall provide a working environment that recognizes and promotes diversity, equity, and inclusion. Suppliers shall foster this culture through appropriate strategies, training, and incentives. It also implies ensuring that employees can report concerns or potentially unlawful practices at the workplace without fear of retaliation. Owkin encourages Suppliers to have an active diversity program in place.
Freedom of association
Suppliers shall respect workers' rights, as established by local laws, to freely associate, join or choose not to join labor unions, and join workers' councils. Workers shall be able to communicate openly with management regarding working conditions without risk of intimidation, reprisal, or harassment.
Health & Safety
Worker health and safety protection
Suppliers are responsible for safeguarding the health and safety of workers, subcontractors, and visitors by preventing workplace accidents and occupational diseases. They must identify, evaluate, and mitigate risks associated with physical hazards, as well as chemical and biological exposures. Facilities must be maintained to ensure a safe working environment, with full compliance with local occupational health and safety regulations. Suppliers must provide appropriate personal protective equipment and protect workers from excessive exposure to ergonomic risks, chemicals, pharmaceutical substances, and biological agents. Effective technical protective measures must be implemented, along with safety information on hazardous materials to educate and safeguard employees. Worker well-being must also be considered when addressing workplace hazards.
Animal welfare
Animals shall be treated respectfully, with pain and stress minimised. Animal testing should be performed after consideration to replace animals, reduce the numbers of animals used or refine procedures to minimise distress. Alternatives should be used wherever scientifically valid and acceptable to regulators.
Environment
Compliance with applicable environmental laws
Suppliers shall comply with all applicable environmental laws and hold the necessary licenses and permits, keeping them up to date and respecting their operational and reporting requirements.
Environmentally responsible practices
Suppliers should minimize their impact on the environment by conserving natural resources, avoiding hazardous materials, and promoting recycling and reuse. Suppliers shall endeavor to reduce and prevent sources of emissions from their activities. They shall also comply with chemical regulations, and ensure the long-term traceability of critical raw materials.
Waste, wastewater and emission
Suppliers must establish systems to effectively manage waste, air emissions, and wastewater discharges, ensuring they are properly treated before being released into the environment to minimize negative impacts. Releases to air, water, and soil must be adequately measured, managed, and tracked to ensure compliance and traceability. Additionally, suppliers must handle environmentally hazardous substances with care to prevent accidental spills and mitigate potential environmental harm.
Sustainable procurement
Sustainable material sourcing & traceability
Suppliers should implement sustainable sourcing practices and do their best to ensure the traceability of their materials. This includes verifying that raw materials are obtained responsibly and ethically, focusing on minimizing environmental impact and supporting fair labor practices throughout the supply chain.
Green logistics and transport
Suppliers should encourage the use of environmentally-friendly transport methods and optimize logistics to reduce carbon emissions. This includes prioritizing fuel-efficient vehicles, reducing waste, and optimizing delivery routes to lower the carbon footprint.
Responsible business
Suppliers must act in good faith, ensuring ethical, transparent, and fair business practices. They should promote equal opportunities through inclusive procurement and uphold integrity in all operations.
Quality
Quality assurance and regulatory compliance
Owkin expects its suppliers to uphold and demonstrate the highest standards of quality reasonably expected from professionals in their field. Suppliers are selected based on their ability to meet or exceed these standards consistently, ensuring the delivery of reliable and high-quality products and services. Suppliers are also expected to immediately address all issues that could potentially affect the quality of Owkin’s goods and services and answer any interrogations promptly.
Audits
Suppliers should conduct regular internal audits to identify and correct non-conformities, risks or quality issues ensuring compliance with all relevant standards and regulations. Additionally, suppliers are required to conduct regular audits of their subcontractors to ensure they meet the same standards. Suppliers must also allow Owkin to perform audits of their facilities, processes, and documentation as necessary to verify compliance with this Code and contractual obligations.
Quality Management System (QMS)
Suppliers concerned shall develop, implement, and maintain a robust quality management system aligned with recognized standards (e.g., ISO 9001, ISO 13485 or equivalent). Suppliers must immediately report any quality issues identified in delivered products or services. This system should ensure the continuous improvement of processes and products.
Information protection
Data privacy
Suppliers must protect personal data in compliance with all applicable data protection laws and regulations. This includes ensuring the lawful collection, processing, and storage of personal data, as well as respecting the privacy rights of individuals.
Intellectual property and confidentiality
As business partners, Suppliers shall respect Owkin’s intellectual property rights and protect Owkin’s confidential information with the highest standards of care, treating it with the same level of protection they apply to their own confidential information. This includes safeguarding Owkin’s IP, information, trade secrets and any data or documents shared during the course of their business relationship to prevent unauthorized access, use, or disclosure.
Suppliers must also ensure that their activities do not infringe upon the intellectual property rights of third parties. They are required to conduct appropriate due diligence and implement measures to avoid unauthorized use of third-party materials, technologies, or information.
Security
Suppliers are required to implement robust security measures to protect information including personal data, confidential information, client data and intellectual property. This system must:
- Align with recognized industry standards (e.g., ISO/IEC 27001 or equivalent) to ensure robust security practices.
- Include measures to prevent unauthorized access, misuse, or disclosure of information.
- Be regularly reviewed and updated to address emerging threats and vulnerabilities.
- Ensure that any subcontractors or third parties handling data on behalf of the supplier adhere to equivalent security standards.
- Ensure prompt notification to Owkin in the event of a data breach or security incident, suppliers with a detailed action plan to mitigate risks and resolve the issue.
Management systems
Legal Requirements
Suppliers shall identify and comply with all applicable local, national, and international laws. They must ensure that all necessary permits, certificates, and licenses are kept up to date.
Risk Management and Continuous Improvement
Suppliers should have mechanisms in place to identify, monitor and manage risks in all areas of their activities. They must commit to continuous improvement by setting performance targets, implementing plans, and taking corrective action on issues identified by assessments or audits.
Reporting and Documentation
Suppliers shall encourage employees to report concerns or illegal activities without fear of reprisal and ensure follow-up on these concerns to take corrective action. They must maintain documentation demonstrating compliance with applicable standards and laws.