Supplier Code Of Conduct
October 2022
1. The Code
When we refer to “Mako”, “we“, “us”, or “our” we mean Mako Europe Ltd with its registered offices at 1 Snowden Street, London EC2A 2DQ and its affiliated entities that are either controlling, controlled by or under common control with Mako Europe Ltd. “Supplier” or “you” means a third party organisation or individual providing a product or service to Mako or any of our clients either directly or indirectly.
In conducting our business we rely on effective and adaptable technology as a tool for generating returns and deploy advanced trading applications to connect to global markets. Our suppliers provide a large part of the technology we use, as well as general services ranging from the delivery of stationery and IT hardware to data usage and consulting services.
The overall objective of this Supplier Code of Conduct (“Code”) is to achieve mutually beneficial,trusting and open relationships with our suppliers and business partners. We expect Suppliers to acknowledge this Code as a prerequisite to supplying any goods and/or services to Mako, to comply with all aspects of it and to be able to demonstrate compliance. This includes documented evidence and the right of Mako or a designated firm to conducts audits.
2. Our values
We are committed to minimising the social, environmental and ethical impacts of our supply chain and seek to ensure that we and our suppliers act in a responsible manner.
We have identified the following corporate values, which underpin this Code: aspiration, communication, integrity, pro-activity, innovation and distinctiveness. We expect our Suppliers to align with and demonstrate our core values when acting on our behalf.
3. Respectful treatment and professional behaviour
We ask our suppliers to treat people in our workplace and their own with respect at all times and to comply with all applicable local and national laws, rules, regulations and requirements in the provision of products and/or services to us. Suppliers are responsible for maintaining and enforcing these standards within their own supply chains.
4. Diversity and inclusion
We value diversity as a foundation of innovation and are committed to create a workplace of equality and opportunity. As such we seek to attract, retain and motivate people from many backgrounds and perspectives.
Any form of discrimination, harassment or victimisation in the workplace is unacceptable to us and we expect our Suppliers to provide the same commitment with respect to their own employees and supply chains.
5. Human rights and society
We support human rights and fair working conditions for persons working in our workplaces and in our supply chain. Suppliers must ensure that working conditions, hours, wages and benefits comply with applicable national and local laws.
We have, and expect from our Suppliers, zero tolerance for any form of human trafficking or child, forced or compulsory labour. Compliance with all applicable human rights (including the Modern Slavery Act 2015) and employment laws by our Suppliers in the jurisdictions they work in is paramount to us and we expect our Suppliers to have robust means of ensuring that the subcontractors in their supply chain also comply.
6. Environmental management
We are committed to protecting the environment and to understanding and reducing our business’s and supply chain’s impact on the environment. As such we expect our Suppliers to conduct their operations and businesses in an environmentally responsible manner and in accordance with applicable environmental laws and regulations. We expect our Suppliers to encourage the use of environmentally friendly technologies and practices throughout their own business and their supply chains.
7. Health and safety
We care for our people and strive to develop a work environment that promotes health, safety and wellbeing. As our Supplier, you will have appropriate measures in place to ensure the health and safety of your workforce and the wider public, including our people.
8. Data protection
We respect everyone’s right to the protection of his or her personal data and the rights to his/her integrity in connection with processing of personal data. We expect from our Suppliers that they ensure that all uses of personal data, including but not limited to the collection, registration, comparison, storage and deletion or a combination of these, takes place in accordance with applicable laws and regulations and that you have systems in place that guarantee secure and appropriate processing of data.
9. Cyber security
We expect you to implement reasonable measures for minimising exposure to physical and cyber security threats including but not limited to terrorism, crime, viruses and hacking.
10. Anti-bribery
We are dedicated to conducting business with a high level of integrity and do not tolerate any form of bribery or corruption. We require that Suppliers adhere to anti-corruption laws,including but not limited to the Bribery Act 2010, and anti-money laundering regulations.
We expect Suppliers to have robust processes in place to ensure that subcontractors in their supply chain also comply with these laws. We do not tolerate any form of corrupt practices including extortion and fraud that we become aware of and we expect our Suppliers to be vigilant and proactively look for fraud and the risk of fraud in their businesses.
11. How to contact us
Please contact us promptly at suppliers@mako.com if you become aware of any breach or suspected breach of this Code.
