Business Partner Code

Business Partner Code – Draft March 2023

 

Business Partner Code scope

For ESPERANTE Development’s suppliers, contract manufacturers, partners, distributors, agents, consultants and other business partners.

 

  1. Introduction

1.1. ESPERANTE Development values and expectations

ESPERANTE Development is a global company with strong values. We believe it is essential that all our business partners operate in accordance with and contribute to the same or similar high ethical standards and integrity as we do.

The ESPERANTE Development Business Partner Code sets out our expectations to you, our business partners. It takes into account the UN Global Compact’s ten fundamental principles within the areas of human rights, labour rights, the environment and anti-corruption. ESPERANTE Development is committed to implement the principles as part of our core operations.

As an ESPERANTE Development business partner, you are expected to work towards implementing the standards laid out in the ESPERANTE Development Business Partner Code within your own business, if you have not already done so, and should require the same from your own business partners.

1.2. Scope and compliance

This Business Partner Code is applicable to all of our business partners, irrespective of the country and territory they operate in. If local laws, regulations or standards are stricter than the principles and requirements set out here, we expect you to adhere to the stricter requirements.

1.3. Legal compliance

In addition to adherence to the principles set out in this ESPERANTE Development Business Partner Code, we expect you to respect and comply with all applicable laws and regulations, and prevailing industry standards. In the event that there is a conflict between such applicable laws, regulations and standards and the principles set out here, we require you to inform us so that we can work together to decide on an appropriate joint approach to the issue.

The principles of the ESPERANTE Development Business Partner Code

  1. Labour Rights

2.1. Equal opportunities

ESPERANTE Development believes that diversity and inclusion are key to its global success. We expect our business partners to provide an inclusive work environment, where everyone (regardless of age, gender, gender identity, sexual orientation, colour, race, disability, religion, belief, nationality, social status or any other status recognised by international law) is treated with respect. You are also expected to work towards eliminating any form of discrimination and harassment in the workplace.

2.2. Rights at work

ESPERANTE Development respects employees’ rights at work. Our business partners are required to respect their employees’ right to freedom of association and must recognise their right to be a member of a union or other collective bargaining group. Employees must be compensated with fair pay for their work, as well as benefit from reasonable work breaks and paid holidays in accordance with local law.

2.3. Child labour and Young workers

ESPERANTE Development never employs child labour, either directly or through subcontractors or other business partners. You must therefore ensure that you do not use child labour, either at your own sites or at your suppliers’ sites. Unless stricter national laws apply, the minimum age for employees is 15 years. In rare cases, and if national law permits, children under the age of 15 years are allowed to carry out light work that does not interfere with the children’s schooling. Young workers under the age of 18 are not allowed to work during night and should not work with dangerous goods or hazardous substances.

2.4. Forced labour

ESPERANTE Development expects that its business partners do not engage in human trafficking and allow their employees freedom of movement during their employment and that personal documentation such as passports and/or payment of compensation are not retained or withheld to prevent such freedom of movement, thereby giving rise to forced or involuntary labour.

 

  1. Health, Safety and Environment

 

3.1. Health and safety

At ESPERANTE Development, health and safety in our workplaces is a priority and we expect nothing less from our business partners. You must follow applicable safety rules and regulations, provide a safe and healthy work environment, and strive to promote an accident-free workplace.

If you handle or use dangerous goods, you must ensure that all risks associated with the handling or use of dangerous goods and hazardous substances are safely controlled and managed. In particular, safe work procedures specific to the handling of dangerous goods and hazardous substances must be implemented and guidelines and emergency plans must be available in the workplace; appropriate training and protective equipment must be provided to employees who may be exposed to dangerous goods and hazardous substances.

3.3. The environment

At ESPERANTE Development, we care about the environment and support the protection of the environment through meaningful action. As an ESPERANTE Development business partner, you should always comply with applicable environmental legislation and strive to minimise your environmental impact. This includes identifying those areas that have the most significant environmental impact and continuously looking for improvements in those areas (e.g. waste reduction, minimisation of energy consumption, recycling).

3.4 Animal Welfare

ESPERANTE Development believes that animals shall be treated respectfully, with pain and stress minimised. We expect that our business partners comply with applicable local laws and regulations relating to such. Whenever you undertake trials which involve animals or breed and supply animals for use in studies, you are expected to treat animals humanely with greatest consideration given to their health and welfare and consistent with meeting the scientific objectives. In studies, you should consider whether animals can be replaced, the number of animals reduced, or procedures refined to minimise distress.

  1. Anti-Bribery and Fair Competition

 

4.1. Bribery and corruption

ESPERANTE Development is committed to honest and fair business dealings, free from bribery, corruption, extortion or fraud. As an ESPERANTE Development business partner, you are required to conduct business in a fair, transparent and legal manner and not engage in bribery in any form. This includes giving, requesting or receiving bribes, as well as engaging in improper payments or corrupt practices. Courtesies extended to ESPERANTE Development Employees or their close relatives must be reasonable in scope, value and frequency, and must reflect ordinary local business customs. Cash or equivalents, such as gift cards, can never be offered to ESPERANTE Development Employees.

4.2. Political donations, charitable contributions and sponsorships

At ESPERANTE Development, we avoid supporting any political organisations, and we never use charitable or commercial sponsorships to improperly influence decision-makers. Similarly, we expect that our business partners will not provide any political support, make charitable donations or offer sponsorships with a view to gaining an unfair advantage or a view to influence decision-making in connection with any transaction with ESPERANTE Development.

4.3. Conflicts of interest

At ESPERANTE Development, business is conducted in an objective manner. We expect mutual transparency in the business decisions and transactions with one another to prevent the possibility of conflicts of interest arising. This means being transparent about the involvement of any Employee (or a close relative of such) which is directly involved or has a substantial economic interest in the other party’s business.

4.5. Fair competition

ESPERANTE Development is committed to the principle of fair, open and unrestricted competition, and we conduct our business in a fair and legal way. Our business partners are required to comply with all applicable competition and antitrust laws and must not engage in anticompetitive practices, such as price-fixing and sharing, market sharing, output limitation, bid-rigging, etc.

4.6. Books and record keeping

It is essential for ESPERANTE Development to maintain accurate and complete books and accounting records. As our business partner, you must also comply with all relevant laws and regulations, and reporting and accounting guidelines in respect of your business at all times.

4.7. International sanctions and export control

ESPERANTE Development complies with applicable international sanctions and export control restrictions – including relevant applicable sanctions imposed or introduced from time to time by either the USA, UK or EU – and adopts appropriate measures to implement such compliance in practice. Our business partners must also observe and adhere to the relevant applicable international sanctions and export control.

4.8. Anti-money laundering

ESPERANTE Development does not engage in or accept any involvement with money laundering. As our business partner, you must have proper internal control systems in place to monitor your business for any indications of money laundering activities and thereby minimise the risk of being involved in such practices.

 

  1. Data Privacy and Information Protection

 

5.1. Company assets, intellectual property and confidential information

ESPERANTE Development strives to safeguard company assets, intellectual property rights and confidential information, all of which are of immense value to our company and our business partners. Similarly, we expect you to exercise due care and attention and not to disclose any confidential ESPERANTE Development information to unauthorised third parties. We further expect you to protect ESPERANTE Development company assets and comply with all relevant laws regarding intellectual property rights. As an ESPERANTE Development business partner, you should never knowingly infringe the intellectual property of ESPERANTE Development or others.

5.2 Data Privacy

ESPERANTE Development complies with applicable data privacy legislation. Similarly, we expect our Business Partners to establish and maintain adequate personal data and information security protection for the information that you, and any third parties acting on your behalf, processes. We further expect you to operate in a manner that is consistent with applicable data protection/privacy laws and aligned with industry standards for the protection and security of all information, including personal information.

 

  1. Supply Chain

 

6.1 Distribution

ESPERANTE Development undertakes distribution in accordance with Good Distribution Practices (GDP). We expect our distributors to ensure that any form of tampering, contamination, damage etc. is immediately reported to ESPERANTE Development.

6.2 Security in the Supply Chain

To guarantee security in the supply chain, ESPERANTE Development has introduced measures to protect goods and services against unauthorized access during production, storage and handling and processing. Similarly, we expect our suppliers to have in place adequate for their activity’s security measures.

 

  1. Transparency and collaboration

 

7.1. How will adherence to this code affect your relationship with ESPERANTE Development?

The ESPERANTE Development Business Partner Code is applicable and mandatory to all of our business partners. Our choice to work with you as a business partner is not only based on the quality, price and professionalism of your services or products; it is also based on your respect for our commitment to conduct business in an ethical, environmental and socially responsible manner in accordance with the ESPERANTE Development Business Partner Code.

We expect our business partners to have adequate management systems to facilitate continual improvement and compliance with these standards by allocating appropriate resources, identifying and complying with applicable laws, regulations, standards, and employing mechanisms to demonstrate conformance and determine and manage risk in the areas addressed by the ESPERANTE Development Business Partner Code.

7.2. Assessment and audit

We may request that certain business partners work with us openly and transparently to assess whether they are in compliance with the ESPERANTE Development Business Partner Code. In such cases, any such assessment may consist of an initial collection of code related information by ESPERANTE Development, collected through dialogue with you. After this, you may be required to provide further information through a more detailed self-assessment questionnaire. In certain circumstances, we may request to perform an on-site audit and, if required, work with you to introduce an improvement programme based on the audit findings.

7.3. Possible actions post-audit or on discovery of non-compliance

In the event that ESPERANTE Development becomes aware – either through an audit or otherwise – of serious or multiple failures to comply with the ESPERANTE Development Business Partner Code by a business partner, we expect the business partner to engage in a constructive dialogue around how to develop and implement an appropriate corrective action plan. In the event of continued repeated or serious breaches of the code, we may terminate our relationship with the business partner, or exclude them from undertaking further business with ESPERANTE Development until we are satisfied that sufficient progress has been made to remedy the breaches.

7.4. Legal documentation

ESPERANTE Development may require that business partners agree to the addition of reasonable legally binding clauses in the contractual documents between them to ensure the business partner follows the principles, and procedures where relevant, set out in the ESPERANTE Development Business Partner Code.

7.5. Questions and suggestions

If you have any questions or suggestions about any aspect of the ESPERANTE Development Business Partner Code, please get in touch with your ESPERANTE Development contact or contact the ESPERANTE Development CEO.