1. Introduction
Plan A’s purpose is to support organisations in the transition to a more sustainable economy. Plan A achieves this by providing tools and knowledge to embed environmentally friendly practices in their operations, while gaining visibility around their environmental performance.
The purpose of our Company furthermore is to create a positive impact on society and the environment.
We aim to act as a role model at all times by sustainably balancing people, planet and profit.
We are committed to foster inclusive, collaborative and safe working conditions for all Plan A staff, regardless of gender, sexual orientation, ability, ethnicity, socioeconomic status, and religion (or lack there of).
We conduct our business with integrity, in a righteous and ethical manner, respecting all human rights and our environment, and in accordance with law.
We expect all our contracting partners, companies or individuals, such as suppliers, service providers, sub-contractors, independent contractors, consultants, commercial agents or commercial partners (here in after the “Business Partners”) to commit to the same shared values. This Code outlines our expectations for all Plan A Business Partners, as well as their compliance and reporting duties while conducting business with us.
2. Integrity and business ethics
Anti-bribery and anti-corruption
Plan A is devoted to fighting all forms of bribery and corruption, and as such, takes steps to ensure that it complies with applicable anti-bribery and anti-corruption laws in all jurisdictions within which Plan A is established or performs services. This means that Plan A takes a zero-tolerance policy towards bribery and corrupt conduct. All improper arrangements involving public officials, customers, suppliers or any other public or private third parties are therefore strictly forbidden.
Our Business Partners shall be equally committed to fight bribery and corruption and ensure that their directors, officers, employees and partners do not give or accept bribes or engage into any other related unethical behaviour.
As part of its due diligence processes with Business Partners, Plan A reserves the discretion to request the disclosure of personal or professional connections with public officials. At the earliest opportunity, Business Partners shall inform Plan A of any such connections that occur after the due diligence process or that were not disclosed during this process.
Business Partners must have internal controls to detect, prevent and respond to related unlawful activities, and keep accurate and up-to-date records thereof.
International sanctions and anti-money laundering, fight against fraud
Business Partners must comply with sanctions, export control, and anti-boycott laws and regulations and anti-money laundering laws and regulations applicable in their jurisdictions of business.
Business Partners shall aim to always act against fraud. Any invoices issued to Plan A by a Business Partner shall accurately represent in reasonable detail any fees and other financials related to any Plan A transaction. Any potential fraud that may have an impact on Plan A must be reported immediately.
Fair competition
Plan A is committed to the principles of lawful and free competition based on the merits of our services. We abide by all applicable antitrust and competition laws in all countries in which we operate and we expect our Business Partners to have a similar level of commitment to fair competition and compliance with applicable antitrust laws and regulations.
Conflicts of interest
Business Partners should take appropriate measures to avoid conflicts of interest, whether of a personal, or professional nature, that may prevent any party involved in a Plan A relation to act in the best interest of Plan A and/or its customers. While taking decisions related to Plan A business transactions, Business Partners shall not be influenced by personal or private interests. Personal relationships with a Plan A employee shall not be used to influence the employee’s business judgement. If an employee relationship represents actual or potential conflict of interest in a transaction, Business Partners must disclose this fact to their Plan A contact or ensure that the Plan A employee does so.
Data protection and security, confidentiality
Plan A collects, processes, uses and discloses personal information according to Plan A PrivacyPolicy available at https://plana.earth/privacy-policy.
Business Partners must comply with all applicable laws and regulations relating to personal data, notably the EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016. Business Partners shall further implement appropriate technical and organisational security measures (“TOM”s) to protect natural persons against unlawful processing of personal data and against loss, theft, accidental or fraudulent deletion, alteration or destruction, or damage, or unauthorised disclosure, use or access to personal data. Business Partners shall in particular act in accordance with Plan A Privacy Policy referenced above.
Where needed, Business Partners and Plan A will work on data protection impact assessment in regard to their relationship and implement an action plan to mitigate the risks identified therein. Plan A and Business Partners will execute all appropriate data processing agreements, whenever required. In the event of a potential or actual personal data breach, Business Partners shall inform Plan A contacts as soon as practicable, and in no event later than 72 hours after discovery, and take all reasonable steps, defined jointly with Plan A, to mitigate the consequences.
Moreover, all information received by Business Partners in the course of a business relation shall be treated as strictly confidential, any disclosure being subject to prior written authorisation as per executed terms, conditions and other relevant documentation. Business Partners shall take any appropriate steps to prevent disclosure or unauthorised use of Plan A confidential information made available to them. Business Partners shall ensure high standards in their business communications and handle such with due care and diligence.
Intellectual property rights
Business Partners shall respect all intellectual property rights (IPRs), including those of Plan A and any third party. Business Partners shall at all times respect all IP laws and regulations in any location they conduct their business and/or provide their services.
3. Sustainability, environmental protection, human rights
Protection environnementale
Business Partners shall observe and respect all applicable laws and regulations on the protection of our environment and take steps to ensure such protection, including the respect of land and national resources, the rights of individuals, animals and communities. Business Partners shall be engaged to preserve biodiversity, and further to reduce their environmental impact, and to act against climate change.
Human rights
Business Partners recognise and uphold human rights, as enshrined in the Universal Declaration onHuman Rights and the UN Guiding Principles on Business and Human Rights.
Business Partners shall prevent violations of human rights and remediate any that occur as a result of its relationship with Plan A.
More generally, Business Partners shall be committed to identifying, preventing and responding to any violation of human rights that occurs as part of their operations, and shall implement policies and processes to this end; including for the prevention and mitigation of child labour, forced labour, modern slavery, and human trafficking.
They shall operate in compliance with all applicable local laws relating to working hours and wages, including those related to minimum wages, overtime and benefits.
They shall ensure freedom of movement and freedom of association, and uphold the right of their employees to choose whether to form or join lawful trade unions and other organisations of their choice, in accordance with applicable laws.
4. Health and safety, non-discrimination, diversity and inclusion
Business Partners shall be committed to providing a safe and healthy workplace and to minimise the risk of accidents and injury and to reduce exposure to health and safety risks, for all its employees. They shall comply with applicable laws and regulations and take measures to ensure health and safety in the workplace, including policies and procedures and training programs.
Business Partners shall implement and apply non-discriminatory policies and encourage honest communication so that employees may openly voice their ideas and concerns.
Business Partners must prohibit all forms of discrimination and harassment against employees based on, but not limited to, personal characteristics such as race, ethnic background, religion or beliefs, gender, age, political opinion, national extraction, social origin, pregnancy and maternity, disability, and sexual orientation.
Business Partners’ recruitment, compensation and advancement for employees shall be exclusively based on qualifications, performance, skills and expertise, without regard to the above personal characteristics or any other status protected by applicable local laws.
Business Partners shall support and promote diversity and inclusion for all its employees.
5. Whistleblower policy, compliance and reporting
Plan A supports and encourages its people and Business Partners to speak out, anonymously or not, if they witness anything that happens within our business that they believe goes against the principles of this Code of Ethics, or is unlawful.
At Plan A, we support this via an internal alert line enabling employees to report issues. Business Partners are expected to have similar systems in place to enable grievance reporting by individuals. The objective of any whistleblower mechanism should be to seek to understand allegations, mitigate the consequences, and provide remediation, where appropriate. Business Partners shall ensure zero retaliation against individuals who lodge in good faith complaints or concerns. Issues should be dealt with in a timely manner and in compliance with applicable laws and regulations.
Business Partners are required to enforce compliance with the minimum standards set forth in this Code of Ethics. Plan A expects Business Partners to report their own and third-party violations of this Code of Ethics and encourages any individual to report any compliance violations, unlawful or unethical behaviours they have been a victim of or have witnessed during conducting business with Plan A.
Reporting of compliance violations to Plan A for external stakeholders may be done via email at [email protected]. Issues will be dealt with in a timely manner and the individual who raised the issue will be promptly notified on the next steps Plan A is taking, as appropriate.
The Business Partner undertakes to actively cooperate in case their employees are involved in a suspected compliance violation. If there is such reasonable suspicion and Business Partner does not sufficiently cooperate with Plan A to investigate it, Plan A may, at its own discretion, terminate the business relationship with Business Partner with immediate effect. Plan A reserves the right to take further legal steps in the event of a violation of this Code of Ethics.
Last updated: April 2024