Responsible Business Report 2023

Introduction

11

Our suppliers

on our clients’ behalf are also in compliance with anti-bribery and corruption legislation, and that they have effective policies and procedures in place that are at least of the same standard as our own. We provide comprehensive information on the ABC policy and the Bribery Act on our Intranet. Our Risk team is always on hand to help with employee questions. We deliver training on financial crime, anti-money laundering and sanctions to employees in the UK, Europe, Asia Pacific, South Africa, and the Middle East, and provide supplementary video recordings to employees. We have a structured approach to delivering additional periodic training across our global network. Our whistleblowing policy ensures that no-one suffers any detriment because of reporting any breaches or suspected breaches of our anti-bribery policy. We aim to encourage openness and we will support anyone who raises concerns.

have a database of our first-tier suppliers to maximise co-ordination and control. We have moved suppliers onto a form of contract that requires them to comply with all local, national and (where applicable) international laws and regulations. We hold regular service reviews with tier one suppliers. We perform vetting and due diligence on new suppliers via our new third-party risk management solution Prevalent. This solution is used to screen prospective suppliers on a range of issues, including anti-bribery and corruption, modern slavery, and sustainability. Anti-bribery and corruption Clyde & Co is committed to conducting business fairly, honestly, and openly. We take a zero-tolerance approach towards bribery and corruption, and we act professionally and with integrity in all our business activities and relationships worldwide. In compliance with our antibribery and corruption (“ABC”) policy, we must ensure that people acting on our, or

Clyde & Co has long-term relationships with many of the businesses it engages to run its premises, such as catering and cleaning providers. We have a dedicated procurement team that collaborates closely with these suppliers to make sure that we do not make demands of them that may lead them to violating laws. We have a Code of Ethics, to ensure that our supplier relationships are based on professional, ethical, and transparent behaviour. We have introduced this year a Sustainable Procurement Policy which recognises that our procurement of goods and services has the potential to impact the environment, society, and economy. We are committed to operating sustainable procurement practices that uphold our values and contribute to a more sustainable future. Most of our suppliers are based in the UK and supply standard goods or services. We

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