At Reed Smith, our goal is always to be “Doing The Right Thing.”

All Reed Smith suppliers (and their employees, agents, and contractors) are, therefore, required to conduct themselves in accordance with both the spirit and the letter of this Code of Conduct and all other Reed Smith policies provided to them and to maintain the highest standards of ethics and integrity. Suppliers contracting with Reed Smith are likewise expected to promote the principles of this Code of Conduct in their own supply chains. While Reed Smith recognizes that there are different legal and cultural environments in which our suppliers operate around the globe, this Code of Conduct outlines the basic requirements that suppliers, and their employees, agents, and subcontractors should adhere to in order to do business with Reed Smith. We refer to such parties as “You” in this Code of Conduct.

Doing the Right Thing

Our goal is that You will conduct your activities for or on behalf of Reed Smith in a manner consistent with our Core Values –

Integrity | Excellence | Teamwork and Respect | Innovation | Impact

and with this Code of Conduct. You are expected to acknowledge this Code of Conduct as a prerequisite to every Reed Smith contract for the supply of goods and services, confirming that your business is subject to the principles contained in this Code of Conduct. You must be able to demonstrate adherence to the Code of Conduct at our request. 

Reed Smith Code of Conduct

Business Practices and Compliance

We expect You to have policies and procedures in place to ensure the prevention of unethical business practices and to achieve compliance with all applicable laws, rules, and regulations. In particular -

Financial Crime: Reed Smith will not tolerate conduct that is criminal or in breach of applicable regulations of any kind. You must ensure that You are not engaged, directly or indirectly, in money laundering, fraud, tax evasion (including the facilitation of tax evasion by another person), bribery, corruption, and other improper payments, benefits, or gifts. You must not participate in bribes or kickbacks of any kind, whether in dealings with public officials or individuals in the private sector.

Antitrust: You must conduct your business in full compliance with antitrust and fair competition laws that govern the jurisdictions in which You conduct business. 

Data Privacy and Confidentiality: You must respect privacy and protect personal data and confidential information. You must not publicize your relationship with Reed Smith without our consent.

Business Records: You must honestly and accurately record and report all business information and must create, retain, and dispose of business records in full compliance with all applicable legal and regulatory requirements and our instructions.

Intellectual Property: You must respect and protect the intellectual property rights of Reed Smith and all parties including by only using, and providing to Reed Smith, software, hardware, and content in accordance with their associated licenses or terms of use.

Employment Practices and Human Rights

Reed Smith expects You to share our commitment to human rights, respect and equal opportunity in the workplace. You must conduct your employment practices in full compliance with all applicable laws and regulations, and where there are no laws or regulations which protect workers in accordance with the principles set out below, You will work collaboratively with Reed Smith to meet at least the following standards - 

• Give employees the freedom to choose employment. You must not use any form of forced, bonded or involuntary labor. Workers must not be required to lodge identity papers and You must take steps to ensure your workers have not been required to pay as a condition of being provided work by You. You must act in compliance with our Modern Slavery Policy;
• Have recognized employment relationships with employees. You must not seek to avoid providing employees with their legal or contractual rights including rights to join Unions as permitted by applicable laws;
• Implement working hours, wages, and benefits which provide a fair living wage for reasonable hours;
• Under no circumstances abuse or intimidate employees and always have appropriate procedures in place to prevent the occurrence of any such abuse or intimidation;
• Support the elimination of child labor by ensuring child labor is not used in your operations and employ only workers who meet or exceed the applicable minimum legal working age in the relevant country.
• Provide employees with a safe, reasonably accessible including to disabled persons, and hygienic workplace that has adequate fire and life safety systems and equipment, is free of harmful pollution, toxic materials and waste and have in place measures to prevent accidents and injury at work.

Non-discrimination and Fair Treatment

You must ensure that your employees are treated with respect and dignity, and You must not discriminate on the basis of race, religion, ethnicity, disability, age, sexual orientation, political affiliation, union membership, gender, or marital status. You must protect your employees from harassment in the workplace including sexual, physical, and psychological.

Environment

Reed Smith takes its responsibility for protecting the environment seriously and is committed to reducing its own environmental impact. As a minimum, You must be compliant with local environmental laws and regulations, including those relating to waste disposal, pollution, discharges and air emissions. Where necessary, You will hold all required environmental licences and permits. Reed Smith seeks to work with suppliers that demonstrate evidence of their commitment to environmental protection and best practice going well beyond the minimum standards set by environmental legislation and regulation. We expect You to conserve natural resources, to avoid the use of hazardous materials and to promote activities that include the concepts of reuse and recycling.

Reporting Concerns

Actual, or suspected, material violations by You, or any other party, of this Code of Conduct should be reported to Reed Smith’s Chief Legal Officer. If you are a supplier to Reed Smith and suspect that a Reed Smith person or any other person or entity acting on behalf of Reed Smith has engaged in illegal or otherwise improper conduct you should report the matter to Reed Smith’s Chief Legal Officer.