Supplier Code of Conduct
0.0 Introduction to the Supplier Code of Conduct
Reel is committed to upholding the highest standards of environmental protection, ethical conduct and integrity in its operations and collaborations with suppliers and partners.
Reel’s Code of Conduct and Supplier Code of Conduct outline the principles and expectations that Reel requires all its employees, suppliers, and partners to adhere to. By following these Codes of Conduct, we can collectively accelerate the renewable energy transition, while taking responsibility for the impact of our operations.
The Supplier Code of Conduct outlines the essential requirements on environmental, social, and ethical practices of Reel's suppliers and is an integral component of all supplier agreements. Reel strives to foster and uphold constructive relationships with its suppliers through open communication and high-quality documentation, working together towards shared sustainability objectives.
In the Supplier of Code of Conduct, ‘where feasible’ is used to denote those actions that may be difficult or impossible to fully implement due to economic, logistical, or political constraints. This does not mean that the specified conduct is optional - rather, the supplier shall seek to implement the conduct to its fullest possible implementation, while working to remove the barriers to its feasibility. The supplier must aim to progressively improve their systems and processes to avoid and address adverse impacts.
1.0 Environment
In regards to the environment, the supplier must comply with all applicable laws, regulations, and industry standards.
In addition, the supplier must comply with the following:
1.1 Climate and Environmental Responsibility
- The supplier must proactively protect the environment from harm by promoting sustainable practices and adequate mitigation measures across its operations.
- The supplier must comply with all relevant environmental laws and regulations, strive for energy efficiency, minimise waste generation, and promote the conservation of resources.
- The supplier must effectively identify and manage the safe handling, movement, storage, and disposal of chemicals and other substances that pose a threat to the environment, including providing workers with appropriate training on the safe-handling and safe disposal of hazardous substances.
- Where feasible, the supplier shall minimise its impact on biodiversity, optimise resource consumption and promote circular economy principles.
- Where feasible, the supplier shall prioritise low-carbon technologies throughout its value chain and demonstrate a policy commitment with clear targets to achieving real and measurable emission reductions.
1.2 Reporting of Environmental Impact
- The supplier must have an environmental management system to record the environmental impacts and performance of its operations relevant for the type and size of the supplier’s operation.
1.3 Assessment and Requirements to Energy Projects
- The supplier must truthfully answer Reel’s Biodiversity Survey and provide documentation to support their answers if requested. This measures the extent of mitigation measures each energy project has in place.
- The supplier must abide by Reel’s minimum project requirements, which will follow the latest best practices on environmental sustainability for renewable energy projects.
1.4 Responsible Site Selection and Nature Stewardship
- The supplier must prioritise site selection that does not negatively impact sensitive habitats, cultural heritage, and communities, while maximising the use of brownfield sites and areas with lower ecological value.
- Where feasible, the supplier shall preserve and restore nature and biodiversity across its operations.
1.5 Stakeholder Engagement
- Where feasible, the supplier shall engage with local communities, indigenous peoples, and other stakeholders to ensure their meaningful participation in the decision-making process, consider their concerns and strive for mutually beneficial outcomes.
- The supplier shall respect the rights, culture, and interests of local communities and seek to maximise positive social impacts.
2.0 Labour and Human Rights
In regards to labour and human rights, the supplier must comply with all applicable laws, regulations, and industry standards. This includes but is not limited to labor laws, data protection laws, international standards established by the International Labour Organization, the OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights
In addition, the supplier must comply with the following:
2.1 Anti-Discrimination
- The supplier must treat all employees, customers, partners, and stakeholders with respect, fairness and dignity, regardless of race, ethnicity, gender, age, religion, disability, or any other protected characteristic.
- The supplier must foster an inclusive and diverse work environment where everyone feels valued and respected. Discrimination, harassment, or any form of unfair treatment must not be tolerated.
2.2 Working Conditions
- The supplier must provide a safe and healthy work environment for all employees.
- The supplier must adhere to applicable health and safety regulations and take necessary precautions to prevent accidents or injuries.
- The supplier must promptly report potential hazards or incidents to relevant authority.
- During site visits, the supplier must educate Reel employees on potential hazards, precautions and regulations.
2.3 Data Privacy and Security
- The supplier must protect the privacy and confidentiality of customer, partner and employee data.
- The supplier must adhere to data protection laws and regulations.
- The supplier must implement robust security measures to safeguard data against unauthorised access or misuse and comply with legislation regarding data protection and privacy including, but not limited to, GDPR.
2.4 Freedom of Association
- The supplier must uphold its employees’ freedom to organise themselves and negotiate collective wage agreements. In cases where independent labour unions face discouragement or constraints, the supplier must facilitate the ability of workers to congregate independently and deliberate upon matters related to their work.
2.5 Forced Labour
- Where feasible, the supplier will purchase modules from vertically integrated suppliers of photovoltaic modules and provide signed declarations from their sub-suppliers stating that no forced labour was used in the production of the solar technologies.
2.6 Child labour and Young Workers
- The supplier must not be associated with exploitative forms of child labour. The supplier must engage workers whose age is the greater of: (i) 16, (ii) the age of completion of compulsory education, or (iii) the minimum age to work in the country where work is performed. Furthermore, workers under the age of 18 must not perform hazardous work. When employing young workers, suppliers must act in accordance with the International Labour Organization’s standards.
3.0 Business Ethics & Integrity
In regards to business ethics and integrity, the supplier must conduct all business with integrity, fairness, and transparency, and with the highest ethical standards.
In addition, the supplier must comply with the following:
3.1 Protection of Intellectual Property
- The supplier shall protect and use any confidential information and intellectual property shared during collaborations only for the intended purposes.
3.2 Complaint Mechanism and Whistleblower Protections
- The supplier shall encourage employees and stakeholders to report any corruption behaviour of the supplier’s employees or management.
- The supplier must comply with relevant whistleblower regulations including, but not limited to the EU Whistleblower Directive if employing more than 50 employees within the European Union.
- The supplier shall have mechanisms for whistleblowers to submit their grievances anonymously, protect whistleblower confidentiality and prohibit retaliation against those that report workplace grievances.
3.3 Anti-Corruption and Bribery
- The supplier must not engage in any form of bribery, corruption, fraud, money laundering, tax evasion, conflicts of interest or unethical behaviour amongst its employees and value chain.
- The supplier must report any suspected or observed instances of bribery or corruption promptly.
3.4 Fair Competition
- The supplier must comply with all applicable competition laws and regulations.
4.0 Compliance and Consequences
Adherence to this Supplier Code of Conduct is mandatory for all suppliers of Reel. Reel encourages all employees, suppliers, and partners to report any concerns, violations, or potential breaches of this Supplier Code of Conduct.
Where non-compliance with this Code of Conduct occurs, Reel will initiate a dialogue with the supplier to clarify the circumstances and the scope of the non-compliance. The supplier and Reel will jointly develop a corrective action plan to ensure compliance with the Code of Conduct.
If by intention or repeated negligence, the supplier fails to comply with the requirements laid out by the Supplier Code of Conduct, Reel reserves the right to carry out appropriate disciplinary action, including termination of business relationships.
5.0 Conclusion
Reel is committed to conducting its business in a responsible and ethical manner. By following the Supplier Code of Conduct and its Code of Conduct, Reel can maintain the trust of our stakeholders, foster a positive work environment, and contribute to a sustainable future.
