Code of conduct

Key principles & scope of applicability

In this Code of Conduct the following words and terms shall have the meaning set opposite them:

“Employee” - means any employee of Evri;

“Evri” - means Hermes Parcelnet Limited or any trading subsidiary or branch office of the company;

“Service Provider” - means any self-employed individual that provides services on behalf of Evri including (without limitation) individuals who are final mile couriers, operate Evri ParcelShops and/or provide sub-depot operational services;

“Supplier” - means any organisation that provides labour resource, goods or services directly to Evri including (without limitation) any sub-contractors of Evri; and

“Supply Chain Parties” - means Evri’s tier one Suppliers and Service Providers and those parties’ direct suppliers and their onward supply chains.

Evri’s operations

Evri is committed to the sustainable development of its business in a way that reconciles economic success with the need to reduce negative environmental impact and ensure the social wellbeing of individuals that are employed or engaged directly by Evri.

Evri’s Code of Conduct therefore sets out Responsible Business Principles, based on ethics, morals and the law, which provide the framework for all it does and which it will apply within its own operations.

Evri’s supply chain

Evri’s Employees, Service Providers and Suppliers can expect Evri to comply with these Responsible Business Principles. In turn Supply Chain Parties must, as applicable, apply the Responsible Business Principles to their own conduct and operations and ensure that they are applied in their onward supply chains.

Access to this Code of Conduct

Evri will make this Code of Conduct accessible and will facilitate its communication as and when needed to all Employees, Service Providers and Suppliers and shall display it in appropriate locations. In turn Evri’s Service Providers and Suppliers will, as applicable, ensure that the Code of Conduct is communicated to and accessible to their employees and other Supply Chain Parties.

Reporting a breach

Employees, Service Providers and Suppliers must report breaches of these Responsible Business Principles to Evri as provided for in SECTION 7 (REPORTING A BREACH / MAKING A COMPLAINT) of this Code of Conduct including breaches which they become aware of in other Supply Chain Parties (and also, for the avoidance of doubt, breaches for which they are themselves responsible).

Responsible business principles

1.  COMPLIANCE WITH LAWS

  • All relevant laws and regulations in any applicable legal jurisdiction must be complied with at all times including, but not limited to, those relating to:
  • Employment of employees and engagement of workers.
  • the Environment and in particular, but not limited to, waste legislation and laws related to Streamlined Energy and Carbon Reporting (SECR).
  • Immigration rules and the right to work.
  • Tax (and in this respect please see Evri’s statement on its group tax strategy here).
  • Antitrust or anti-competitive practices – Evri and its Supply Chain Parties shall not tolerate breaches of applicable competition laws and regulations. Fair competition is beneficial to the raising of standards in products and services and benefits customers through lowering prices and promoting greater choice. Laws that counter anti-competitive practices therefore benefit businesses      and consumers.
  • Money laundering – Evri and its Supply Chain Parties shall not tolerate breaches of money laundering laws and regulations.
  • Bribery and corruption – Evri and its Supply Chain Parties will have zero tolerance of any form of bribery and corruption and there must be no inappropriate personal dependency, obligation or influence (or appearance of such). All business must be conducted with integrity and honesty and with the highest ethical standards. Any giving or receiving of a bribe or corrupt payment is unacceptable.
  • Fraud – Evri and its Supply Chain Parties must be vigilant towards and must not tolerate any form of fraudulent activity and shall investigate and take appropriate action whenever fraud is suspected (whatever its value).
  • Data privacy – Evri and its Supply Chain Parties will comply with all applicable data protection and privacy legislation (including but not limited to the General Data Protection Regulation 2016 and the Data Protection Act 2018). Appropriate measures shall be taken to keep personal data safe, secure and protected against unauthorised access and such data shall only be used in a fair, lawful and transparent manner.
  • Cyber security – Evri and its Supply Chain Parties must promote and enforce policies and practices that ensure the confidentiality, integrity, and availability of their information, data and systems.
  • Contract obligations and law – Evri and its Supply Chain Parties shall honour all contractual obligations and shall not abuse their bargaining position to impose unreasonable contract terms as they are not ethical and have the potential to increase the risk of a breach of these Responsible Business Principles.
  • Sanctions and export controls – through contractual terms of engagement and appropriate monitoring and due diligence (including with respect to monitoring the jurisdiction of origin and dispatch of imports), Evri and its Supply Chain Parties must comply with their legal obligations with respect to trade sanctions and export controls.

2. DISCRIMINATION, EQUALITY, DIVERSITY AND INCLUSION

All those individuals engaged in our business and by Supply Chain Parties (including employees, workers and customers as applicable):

  • must be treated with dignity, respect and inclusivity and benefit from a culture where they are able to develop and progress based on their competence and achievements;
  • should expect to be engaged in or served by organisations that strive to ensure that they reflect the diversity of the communities in which they are located;
  • must not be subjected to verbal, psychological, physical, sexual and/or bodily violence, duress or harassment;
  • must be treated in accordance with equality laws and regulations applying in the jurisdictions relevant to them and as a minimum must not suffer unlawful discrimination, for example:

– on the grounds of colour, nationality (including citizenship), national or ethnic origin, race, religion, sex, pregnancy, marital status, social class, age, sexual orientation, disability, political views, membership or non-membership of a trade union or any other characteristic protected in law;

– harassment;

– victimisation.

Evri’s equality and diversity policy can be found here. Our gender pay gap report can be found here. Evri and its Supply Chain Parties shall complete gender pay gap reporting where required by law. We expect our Supply Chain Parties to also work towards producing an ethnicity pay gap report.

3. HUMAN RIGHTS

Abuse of internationally respected human rights shall not be tolerated in Evri’s business and supply chains. In particular the following standards shall be adhered to:

  • International Labour Organization (ILO) standards;
  • applicable laws, regulations and protocols with respect to engaging labour above the legal minimum age and the protection of children and young workers (including ILO Conventions 138 and 182 and the UN Convention on the rights of the child).

For the avoidance of doubt Evri will not tolerate modern slavery or human trafficking in its business or supply chains. Forms of modern slavery may include, but are not limited to, working under threat or penalty, being forced to work very long hours without rest breaks, being forced and/or coerced to accept wages that are below the level set by applicable national laws, depending on the employer for housing, food and other necessities, withholding of passports and limitations on movements of workers. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery and human trafficking are crimes and a violation of fundamental human rights.

4. WORKING CONDITIONS AND PRACTICES

All those engaged in Evri’s business and by its Supply Chain Parties shall benefit from good working conditions that comply with the legal and regulatory requirements in the relevant jurisdiction including with respect to:

  • payment of wage rates that are both objectively fair and allow individuals to earn income that is at least equivalent to the hourly rates set out in the UK’s National Minimum Wage Regulations (or the equivalent rules in the jurisdiction where the individual works);
  • the provision of easily understandable and regular breakdowns of pay or charges (as the case may be);
  • length of working time;
  • provision of a safe and healthy working environment in which health and safety risks are properly assessed and addressed (including with respect to risks posed to employees, workers, suppliers, customers and members of the public);
  • the right to join or be members of trade unions; and
  • stability of employment / inappropriate lay-off practices.

Evri commits to work constructively with recognised Trade Unions and expects its Supply Chain Parties also to do so.

5. ENVIRONMENT

Evri and its Supply Chain Parties must comply with all environmental laws in relevant jurisdictions. Supply Chain Parties will report to Evri all breaches of environmental laws for which they are directly responsible and when they become aware of such breaches occurring in their onward supply chains.

Evri and its Supply Chain Parties must frequently and clearly communicate to stakeholders their respective strategies and commitments with respect to reducing the environmental impact of their business and shall set themselves targets and explain progress towards those targets. Evri expects its Supply Chain Parties to co- operate with Evri to achieve its strategy. Supply Chain Parties must also:

  • collect and provide to Evri all data necessary for Evri to monitor the emissions associated with and the environmental impacts of its operations and supply chains; and
  • implement their own strategies and targets to reduce their emissions and the environmental impacts of their business and onward supply chains, and collate and provide Evri on demand with all data necessary to evidence the implementation of their strategies and progress towards their targets.

6.  CONTRACT TERMINATION, SANCTIONS AND REMEDIAL MEASURES

Immediate steps shall be taken by Evri and any relevant Supply Chain Party:

  • to prevent any breach of the Responsible Business Principles set out in this Code of Conduct occurring again; and
  • where individuals have been impacted by such breach to take reasonable steps to ensure that the party directly responsible for the breach provides impacted individuals with remediation.

Where Evri or any relevant Supply Chain Party identifies a breach by a third party, immediate consideration shall be given as to whether it is reasonably practicable and appropriate to continue to work with that third party to ensure that the appropriate standards are reached and adhered to in the future. Where that is not reasonably practicable and appropriate then recourse may be made to contractual rights with respect, for example, to termination of the contractual relationship.

Evri will, and its Supply Chain Parties must, abide by the applicable termination notice periods in contracts and, where there is no contractual notice period, then reasonable notice of termination must always be given (save where the termination is because of un-remedied or irremediable material breach of contract, in which case termination of a contract should be in accordance with the applicable contract terms and law).

Sustainable procurement procedures shall be applied at all times to ensure that undue pressure and strain is not generated in the supply chain which could in turn lead directly or indirectly to other breaches of the Responsible Business Principles set out in this Code of Conduct.

7. REPORTING A BREACH / MAKING A COMPLAINT

Where individuals have a concern about a breach or potential breach of this Code of Conduct they may report their concerns on a confidential basis as set out below. Please also see our Public Interest disclosure policy here.

Supply Chain Parties should as far as reasonably practicable have their own comparable processes to ensure that breaches of this Code of Conduct in their own operations and onward supply chains can be reported to them on a confidential and, if necessary, anonymous basis.

Evri and its Supply Chain Parties shall as far as reasonable investigate any complaints about breach of this Code of Conduct in accordance with their established procedures. Supply Chain Parties shall co- operate with Evri in any such investigation at their own cost.

Individuals who report a concern are encouraged to provide their name and contact details so that the issues they raise can be investigated most effectively. If an individual does not provide their name and contact details, it may be more difficult for Evri to investigate the matter effectively and/or to provide a means of redress.

Evri and Supply Chain Parties shall not tolerate any retaliation against any person who in good faith reports a concern about a breach of this Code of Conduct.

Employees

Where any Employee is concerned about a breach or potential breach of this Code of Conduct, they may report their concerns on a confidential basis through the Evri Speak Up Hotline. Employees may call 0808 196 5781 (UK & NI) or use the following link: https://secure.ethicspoint.eu/domain/media/en/ gui/106836/index.html

This service is completely independent, anonymous and confidential and is available 24/7, 365 days a year. Translation services are readily and freely available.

Service providers

Where any Service Provider is concerned about a breach or potential breach of this Code of Conduct, they may report their concerns on a confidential basis as follows:

  • to a representative of the GMB union if they are a member of that trade union; or
  • to Evri’s Company Secretary by email to: company.secretary@Evri.com

For the avoidance of doubt, Service Providers are required to report their own breaches of this Code of Conduct to Evri by contacting the Company Secretary of Evri by email to: company.secretary@Evri.com

Suppliers

Where any Supplier is concerned about a breach or potential breach of this Code of Conduct, they may report their concerns on a confidential basis to the Company Secretary of Evri by email to: company.secretary@Evri.com

For the avoidance of doubt Suppliers are required to report their own breaches of this Code of Conduct in the same way to Evri’s Company Secretary.

Employees or workers of a Supplier or Service Provider

Where any employee or worker of a Supplier or Service Provider is concerned about a breach or potential breach of this Code of Conduct, they may report their concerns through the Evri Speak Up Hotline on 0808 196 5781 or using the following link: https://secure.ethicspoint.eu/domain/media/en/gui/106836/ index.html

This service is completely independent and confidential and is available 24/7, 365 days a year. Translation services are readily and freely available.

CONTACTS

Any questions regarding content of this Code of Conduct should be sent to the following email address: codeofconductenquiry@Evri.com

RESPONSIBLE FOR CONTENTS

Published by:

Hugo Martin, Company Secretary, 22 October 2021