SUPPLIER CODE OF CONDUCT
The Shangri-La group of companies including Shangri-La Asia Limited, Shangri-La International Hotel Management Limited, their respective subsidiaries, affiliates and controlled entities, as well as hotels and properties operated by the Group (collectively, “Group”), are committed to the core values that define the Group’s reputation and brand: integrity, fairness, respect, ethical business conduct and excellence in service.
We require our suppliers, their employees, subsidiaries, affiliates and sub-contractors (collectively, “Suppliers”) to uphold the Group’s core values and adhere to ethically, socially and environmentally responsible practices when doing business with the Group. These requirements are set out in more detail in this code of conduct (“Code”).
As a minimum, Suppliers are required to comply with the Code. Failure to comply with any provision of the Code could result in termination of the business and/or contractual relationship with the Group. The Group prefers to do business with Suppliers whose operations and business practices exceed the requirements of the Code.
1. Compliance with Laws and Regulations
Suppliers shall comply with all applicable laws, rules and regulations, including (but not limited to) those relating to labour, health and safety, anti-trust and competition, anti-bribery and corruption, privacy and data protection and the environment, of the place in which they operate or conduct business.
Suppliers shall notify the Group immediately of any violation of applicable laws, rules and regulations that may affect their ability to supply products or services to the Group in accordance with the Code.
2. Product Quality and Safety
Suppliers shall supply products and services that are safe, fit for purpose, of merchantable quality and comply with all applicable laws, rules and regulations.
3. Business Integrity and Ethics
Suppliers shall deal honestly, fairly and ethically in every aspect of their business, including sourcing, operations and relationships with clients, employees, suppliers and business partners.
Suppliers must not resort to anti-competitive, deceptive, discriminatory, dishonest, unlawful or unethical business practices, such as price fixing, bid-rigging, market sharing and output restriction.
4. Labour Standards and Practices
Suppliers shall comply with all applicable laws, rules and regulations pertaining to working hours, wages, benefits, minimum age, working conditions, occupational health and safety, and industrial relations.
Suppliers shall implement fair, humane and non-discriminatory employment practices, treat their employees fairly, with dignity and respect, and respect diversity and inclusion. Suppliers shall ensure that no threats of violence, physical punishment, or other forms of physical, sexual, psychological or verbal harassment or abuse are used as a method of discipline or control of their employees. Suppliers shall not use any form of forced labour, including coerced, bonded, indentured or child labour. Any form of slavery and/or human trafficking, or any contribution thereto, is strictly prohibited.
Suppliers shall provide a safe and healthy work environment to their employees and take measures to prevent workplace hazards and accidents.
Where employee housing is provided, we expect our Suppliers to meet or exceed the standards for health and safety as those that apply in the workplace.
Suppliers shall provide employees with avenues to raise issues of concern in confidence, without fear of reprisal or negative repercussion.
Where the right to freedom of association and collective bargaining is not restricted under law, Suppliers shall respect the rights of their employees to join or form trade unions and to bargain collectively.
Suppliers shall comply with all applicable environmental codes, laws, rules and regulations in the place where they operate and ensure that they obtain and maintain all necessary environmental permits and registrations to conduct their business.
Suppliers shall adopt appropriate environmentally friendly practices to minimise negative environmental impacts of their operations, products and services through measures such as proper waste management, pollution control and recycling, while continually advancing the sustainability of the products and services provided to the Group.
6. Community Engagement
Suppliers are encouraged to engage with, promote and contribute to the communities in which they operate to help foster social and economic development and sustainability.
Any and all forms of corruption and bribery are strictly prohibited. Suppliers must comply with all applicable anti-corruption laws, rules and regulations of the country where their businesses are being conducted.
Suppliers shall not, directly or indirectly, offer, solicit, pay or accept any form of unlawful advantages such as (but not limited to) bribes, kickbacks, secret commissions, reward, favours, cash, gifts, loans, employment, facilitation payments or any other thing of value (“Advantages”) to secure improper business advantages.
Suppliers doing business with the Group must not offer, solicit, pay or accept any form of Advantages to or from the Group’s employee or representative on account of the Supplier’s business dealings with the Group. Likewise, Suppliers must not offer any employee or representative of the Group excessive business entertainment that could be seen to compromise their objectivity in making decisions, that creates the appearance of impropriety, or that violates the law.
A Supplier must not offer or transfer any form of Advantages, directly or indirectly, to any public official, body or agency in order to secure any improper business advantage for or on behalf of the Group.
The Group is required to comply with various anti-corruption laws and regulations, including without limitation Hong Kong’s Prevention of Bribery Ordinance (Cap. 201). Suppliers doing business with the Group must be familiar and comply with the requirements of these laws and regulations.
8. Accurate Books and Records
Suppliers shall maintain proper, accurate and complete books and records in accordance with applicable laws, rules, regulations and recognised accounting standards and practices.
Suppliers shall promptly and in good faith, provide accurate information reasonably required to enable the Group to comply with its legal, regulatory and reporting obligations to governmental authorities, financial and stock exchange regulators. The intentional creation of false, misleading and deceptive books, records or documents is strictly prohibited.
All information provided by the Group or otherwise obtained by Suppliers in their course of dealings with the Group (“Group Information”), including without limitation those pertaining to the Group’s businesses, operations and policies, shall be treated as confidential, sensitive and proprietary information. Suppliers shall only use the Group Information for legitimate business purposes, in accordance with non-disclosure agreement(s), local laws, rules and regulations. Unless specifically authorised by the Group or otherwise required under law, Suppliers shall not disclose or communicate any Group Information to unauthorised third parties, the public and/or the media.
10. Data Protection
The Group is required to comply with various data privacy laws and regulations, including without limitation Hong Kong’s Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”). In the event that a Supplier receives, becomes privy to or is given access to the personal data of the Group’s guest(s), customer(s) and/or employee(s) (“Personal Data”), we expect our Suppliers to collect, use, handle, process, store, disclose and transfer such Personal Data in compliance with the Group’s policies, the PDPO and all data protection and privacy laws and regulations of all applicable jurisdictions. Suppliers shall not use or disclose any such Personal Data, or engage and/or authorise any third-party service providers to process any such Personal Data, without the prior written consent from the Group.
Suppliers shall promptly notify us in the event of any unauthorised disclosure, leakage or use of Personal Data (“Data Incident”) and work with us in good faith to mitigate the impact of any Data Incident on us, our guest(s), customers and employees and in compliance with the applicable data protection and privacy laws and regulations.
11. Intellectual Property Rights
Suppliers shall recognise and respect the Group’s intellectual property rights in its trademarks, copyright, design and patents. Suppliers shall not engage in any activities that may infringe upon any of the Group’s intellectual property rights or tarnish the Group’s reputation.
12. Implementation of the Code
Suppliers shall take appropriate steps to ensure that the principles of this Code are communicated to, adopted and applied by their employees and throughout their own supply chains (including their suppliers, sub-contractors and business partners who are involved in the provision of products and services to the Group), where applicable. The Group reserves the right, upon provision of reasonable notice to Suppliers, to conduct compliance audit with Suppliers on the Code. Suppliers shall promptly and in good faith, provide relevant information to demonstrate compliance with the Code. If necessary, Suppliers shall facilitate site visits by us and/or our auditor(s) to assess compliance with the Code.
Suppliers shall report any violations or suspected violations of applicable laws, regulations and the Code to the Group. To report a violation confidentially, please click on the following link: http://www.shangri-la.com/corporate/about-us/supplier-code-of-conduct/violation-reporting/
The Code may be updated from time to time. Suppliers should refer to the Group’s website at: https://www.shangri-la.com/group/supplier-code-of-conduct for the most up-to-date version of the Code.