Ethical & Sustainable Procurement

1. Introduction

As a global provider of IT staffing solutions, Montreal Associates (Systems) Limited and its subsidiaries (‘Montreal Associates’, ‘MA Group ‘, ’we’, ‘us’, and ‘our’) recognise the need to do business with integrity and in a sustainable manner.

We connect curious people who believe in technology with the mission to build a sustainable, responsible, and smarter future.

This Policy commits the MA Group, and every individual involved in purchasing and supply management processes, to use their best endeavours to ensure that our purchasing and contracting activities are legal, accountable, auditable, sustainable, and economically effective.

Adherence to this Policy is both an individual and a corporate responsibility. Wilful breach of this Policy, or unauthorised departure from the procedures derived from this Policy, may constitute a disciplinary offence.

The main guiding principles under this Policy are:

I. Respect for the Rule of Law

II. Integrity

III. Accountability

IV. Transparency & Record Keeping

V. Sustainability & Environment Protection

2. Scope of the Policy

This document applies to all persons working for Montreal Associates or on our behalf in any situation where they are involved in a purchasing process or in a procedure requiring validation or authorization of payments, including employees at all levels, directors, officers, consultants, hereinafter the “Stakeholders”.

Responsibility to purchase is granted by one of the MA Group’s Directors.

 3. Purchasing Ethics

The MA Group commits to incorporate social, environmental, and ethical considerations into its purchasing decisions.

In doing so, we endeavour to make a positive contribution to the environment and society. To this effect, it is our objective as a company to only work with suppliers and contractors who subscribe to and operate on similar principles.

As far as regards the Stakeholders, we expect them to observe our Business Ethics Code, including to comply with the following:

3.1 Timely Disclosure of any Potential Conflict of Interest

Any personal interest, which may impinge or might reasonably be deemed by others to impinge upon impartiality in any matter relevant to purchasing duties, should be declared timely to a MA Group Director for approval before conducting the business.

Sometimes, former employees may be potential suppliers. It is important that they do not receive or expect to receive special consideration. If their “inside knowledge” appears to give them an unfair competitive advantage, it may be desirable to take steps to ensure fair competition among all suppliers.

3.2 Confidentiality of Information

The confidentiality of information received in the course of duty should be respected and specific details of suppliers’ offers must not be divulged to competitors. The information acquired should never be used for personal gain.

3.3 Fair Competition

Any arrangement which might, in the short or long term, restrict, distort, or prevent, the effective operation of fair competition, should be avoided.

For more details, see our Competition Law Policy.

 3.4 Gifts & Hospitality

All Stakeholders should only engage in purchasing activities in accordance with MA Group’s Integrity & Anti-Corruption Policy.

As a reminder, gifts other than items of very small intrinsic value should not be accepted.

Items for personal use should be declined. The frequency and scale of hospitality should not be significantly greater than the company would be likely to provide in return.

If a situation arises where it is not easy to decide what is and is not acceptable in terms of gifts and hospitality, the offer should be declined, or advice sought from the Legal & Compliance Department.

3.5 Personal Purchases

No personal purchases shall be made in the name of the company and company resources shall not be used in any way for the purpose of making personal purchases.

 4. Incorporation of Sustainability in Procurement & Main Commitments

The MA Group commits to carry out its purchasing activities in a sustainable manner and to incorporate environmentally responsible factors in its purchasing decisions, as well as to increase the environmental awareness both internally, as well as within its supply chain.

Our main Commitments in this area include the following:

• Ensure that purchasing decisions are done in compliance of the principles of integrity and ethics, equal opportunities and free competition, transparency and traceability, and with independency and objectivity,
• Promote equality, diversity, inclusion, and non-discrimination among our suppliers, ensuring that our supply chain acts respectful of fair remuneration and working conditions, prioritizing workers’ safety, and well-being,
• Promote a culture of open communication and dialogue with our suppliers, while making sure that human and labour rights are fully respected throughout the supply chain, and that practices such as forced labour, child labour or human trafficking are strictly prohibited,
• Advance a culture of respect for the environment and promoting climate actions by engaging with suppliers capable of demonstrating that their practices are intended to lead to a responsible and efficient use of resources, including to a reduced consumption of energy, water, fuels, raw materials, etc,
• Prioritize measures taken for the preservation of the natural environment, and suppliers that carry out their activity with minimum impact on the environment and that promote the preservation of biodiversity,
• Encourage the purchase of goods and services sourced locally and contribute meaningfully to the development of the local economy, and
• Train and sensitise both internal purchasers and third-party suppliers on ethical and sustainable practices and encourage them to transfer the same requirements in their own supply chain.

For more details on the aspects that we expect our suppliers to comply with, please see our Supplier Code of Conduct, in particular the chapters dedicated to:

1. Compliance with applicable laws,
2. Ethics and integrity,
3. IPR, data privacy and security,
4. Inclusion and diversity,
5. Employment, working conditions, and human rights,
6. Wellbeing, health, and safety,
7. Environmental protection.

 5 . Sustainable Initiatives by MA Group

In our day-to-day operations, we strive to engage with suppliers that are focused on improving their performance in terms of sustainability; and we also try to adopt purchasing decisions designed to improve our own sustainability management.

Among the measures that the MA Group has already implemented and those envisaged to be put in place, we note as follows:

• Ensure that our team involved in procurement operations understands the importance of sustainable procurement, and is also able to determine key sustainability issues in the selection of suppliers,
• Communicate with suppliers to let them know about our sustainability agenda,
• Contribute to a circular economy by promoting a reduce-reuse-recycle policy,
• Buying responsibly, only goods & services truly necessary and giving priority to more sustainable alternatives,
• Where practicable, favour products with a lower environmental impact, and avoid to the maximum extent substances harmful for the environment,
• Consider digital alternatives where possible, and implement a no-print policy throughout our operations,
• Consider goods and services which can be manufactured, used, and disposed of in an environmentally responsible way,
• Reduce the purchase of goods associated with overconsumption and the generation of waste, and where not possible, ensure that disposal of waste is done in a manner which allows achieving our sustainability objectives,
• Engage with suppliers which offer ancillary services, such as disposal of hazardous substances (such as toner cartridges) in a controlled and safe manner; for non-hazardous substances, disposal is made in compliance with the principles of sustainability,
• Give preference, where items are of a similar cost, to those that are manufactured with a high recycled content,
• Consider the energy usage/cost of operating equipment prior to purchase,
• Avoid the use of products having detrimental and damaging effects on the environment where a less damaging alternative is available.

6. Purchasing Procedure

Purchases of goods and services can be made either by using petty cash (the maximum spend is to be communicated from time to time by the Finance Manager) or company credit cards.

The delegation or instruction to purchase shall be granted in written by a Director, and the conclusion of any purchase contract, supply arrangement, and placement of any order engaging the MA Group above the threshold communicated by the Directors shall be validated expressly, in written form, by one of the Directors.

The relevant Stakeholders shall agree and abide by the limits and limitations applicable to the relevant credit card and will not disclose the business credit card details to any other person nor use the card for personal use.

All relevant purchases shall be accompanied by an invoice, receipt, delivery notes and any other documentation required according to the applicable legislation. 

7. Reporting of Concerns

MA expects Stakeholders to speak up promptly about any conduct or circumstances they believe may constitute a violation of this Ethical & Sustainable Procurement Policy.

Stakeholders shall promptly notify the Legal & Compliance Department of MA, at legal@montrealassociates.com, regarding any known or suspected illegal or improper behaviour relating to dealings with or on behalf of MA, including behaviour by MA's employees or agents.

8. Acknowledgment. Managing Violations

MA expects Stakeholders to commit to compliance with this Policy and to be fully accountable in case of any breach.

8.1 Acknowledgement & Trainings

Each Stakeholder is required to sign a statement (essentially in the form enclosed under Schedule 1 herein) which confirms that such person:

• Has received a copy of this Policy,
• Has read and understands the Policy, and
• Has agreed to comply with the Policy.

All MA employees involved in procurement processes are required to attend a compliance training as part of the induction process, and afterwards regular training is provided to all staff members to refresh information or raise awareness on specific risks. Attendance to such trainings and awareness campaigns is mandatory.

 8.2 Managing Lack of Compliance

Failure to abide by the standards of this Policy may trigger discipline measures.

Persistent and repeated non-compliance, depending on the gravity of the circumstances, shall have consequences ranging from a warning to termination of employment/contract, as well as any other legal or administrative actions that may be deemed appropriate.

9. Responsibilities

The board of directors has overall responsibility for ensuring this Policy complies with our legal obligations, and that all those under our control comply with it.

MA’s COO shall have the authority to approve any revisions.

The Legal & Compliance Department has primary and day-to-day responsibility for monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective.