Supply Chain Policy

Xtravirt is committed to conducting our business in a responsible, sustainable and ethical manner, and we expect the same level of commitment from our suppliers

Xtravirt is committed to conducting our business in a responsible, sustainable and ethical manner, meeting regulatory requirements in place wherever we operate. We expect the same level of commitment from its suppliers, who play a vital role in the delivery of our services and the achievement of our strategic goals.

This Supply Chain Policy sets out the minimum standards that Xtravirt requires from its suppliers and applies to all suppliers who provide goods or services to Xtravirt. This Policy supplements (and does not replace) any contract agreed between Xtravirt and the relevant supplier.

General Requirements

The Supplier shall comply with this Policy and ensure that its Representatives are aware of and comply with it.

The Supplier shall comply with all applicable Laws, including those related to issues addressed in this Policy. This includes compliance with all applicable competition Laws, including those relating to teaming and information sharing with competitors, price fixing and rigging bids.

If there is a conflict between any applicable Law, the provisions of a contract between Xtravirt and the Supplier, and the provisions of this Policy, the Supplier shall meet the most stringent standard.

Where a Supplier relies on further suppliers within a supply chain in order to provide the contracted services to Xtravirt, the Supplier shall ensure they meet the terms of this policy.

Payment and Invoicing

Only nominated individuals are authorised to commit Xtravirt to contractual terms and/or expenditure. Please contact the Xtravirt accounts team for confirmation of such individuals. Any Supplier acting on requests from Xtravirt who have not been properly authorised, or without a valid Purchase Order (PO) number, may not be paid for those goods or services, and therefore does so at its own risk.

The Supplier shall obtain a PO number prior to supplying any goods or services to Xtravirt.

The Supplier is responsible for submitting accurate and valid invoices, which quote the correct PO to Xtravirt be email to the Xtravirt accounts team. Statements and queries shall be sent to the email address provided on the order. Invoices shall not be backdated or password protected, and shall be addressed as detailed on the PO

The following terms shall apply in the absence of others agreed between the parties:

  1. All invoices for subcontracted Suppliers used for the delivery of services on public sector contracts will be paid in line within 30 days following the date of receipt of a valid, undisputed and properly due invoice. Any incorrectly submitted invoices may be returned to the Supplier for correction and resubmission.
  2. All invoices will be paid in line with agreed invoice and payment terms. If none are agreed, our default is 30 days following the date of receipt of a valid, undisputed and properly due invoice. Any incorrectly submitted invoices may be returned to the Supplier for correction and resubmission.
  3. Where Xtravirt disputes any portion of an invoice, Xtravirt will notify the Supplier in writing within 7 days of the invoice date, detailing the reasons for the dispute and specifying the exact amount being disputed. The Supplier will investigate the claim and work with Xtravirt in good faith to resolve the issue. Both parties agree to cooperate and provide all relevant supporting documentation. In such circumstances where the parties agree that payment is due (in total or part), Xtravirt shall make payment within the original 30-day terms, or within 3 days of the agreement where such date has passed

Ethical People Practices

Human Rights

The Supplier shall respect the human rights of their employees, other personnel and local communities, and comply with all relevant Law related to human rights.

Modern Slavery

Xtravirt is determined to identify and eradicate any modern slavery in its business and supply chain, and to ensuring transparency in our approach to this, consistent with our disclosure obligations under the Modern Slavery Act 2015 (MSA 15). Modern slavery in this document means any activity which involves the exploitation of a person or deprivation of their liberty by another, in order to exploit them for personal or commercial gain, such as slavery, servitude, forced and compulsory labour and human trafficking, and any similar or related activity prohibited by Law.

The Supplier shall take all reasonable steps to ensure that modern slavery is not taking place in its business or supply chain, including by (a) putting in place, maintaining and enforcing appropriate policies and procedures to identify risks and actual instances of modern slavery in its business and supply chain, (b) implementing appropriate due diligence, risk analysis and mitigation measures, (c) providing appropriate training to personnel, including on MSA 15.

The Supplier shall document the steps taken to tackle modern slavery (as described above. The Supplier shall promptly notify Xtravirt upon becoming aware of any actual or suspected instance of modern slavery.

The Supplier shall ensure that it, and all persons engaged by it or its supply chain to provide goods or services to Xtravirt in any part of the world, at all times comply with the provisions of the MSA 15, all Laws, made under or relating to it, and all equivalent Laws applicable across the world. The Supplier shall ensure that all relevant personnel do not engage in any activity, practice or conduct that would constitute an offence under the MSA 15 if carried out in the UK, and comply with any other policy relating to modern slavery reasonably required by Xtravirt

Labour practices

Xtravirt is committed to a policy of equal opportunity and inclusiveness in our employment and working practices and expects its Suppliers to be committed to the same principles. The Supplier shall not discriminate against any job applicant, employee or other individual, or treat them less fairly, because of gender identity, marital status, race (including nationality or ethnic origin), disability, health condition, religion, age, sexual orientation, union membership, political affiliation, being a member of a protected class under international human rights law or any other conditions not justified in Law or relevant to the performance of the job. The Supplier shall have policies in place to promote diversity and inclusion within their own organisations and supply chain, including workplace standards such as the UK Government’s Disability Confident scheme (as may be updated or replaced from time to time) or equivalent.

The Supplier shall ensure that, within its own organisations and throughout its supply chain:

  1. Child labour is not used and relevant Law relating to minimum working age legislation is strictly complied with;
  2. Forced labour, in any form, is not used and workers are not required to lodge papers or deposits on starting work;
  3. Physical abuse, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation or inhumane practice are prohibited and do not take place, whether as part of a disciplinary process or otherwise;
  4. All terms and conditions of employment are made clear to the workforce in a manner which is easily understood;
  5. Employee wages comply with relevant minimum wage Laws, and minimum wages or the prevailing industry wage (whichever is higher) are paid to workers as a minimum;
  6. Employees are provided with all benefits under Law and no non-statutory deductions are made from wages;
  7. The employment terms of young workers adhere to International Labour Organisation Standards, the OECD Guidelines for Multinational Enterprises and Law;
  8. Laws relating to working time and the maximum hours of work permitted to be undertaken by any employee in any period of time are complied with, with any overtime being on a voluntary basis and at manageable levels;
  9. All employees, local or migrant, have the right and ability to leave employment when they choose;
  10. Obligations under Law arising from regular employment are not avoided through the use of labour-only contracting, sub-contracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, or through the excessive use of fixed-term contracts of employment;
  11. Clear, fair and uniformly applied disciplinary practices and grievance procedures are implemented;
  12. The rights of workers to form or join trade unions, which are free to meet without hindrance and to bargain collectively, are recognised, and an open attitude towards the activities of trade unions is adopted;
  13. Where it is not practicable for unions to operate, other means of association, such as Works Councils, are recognised; and
  14. All necessary training is provided to workers, including that required under Law and industry specific training (both mandatory and best practice).

Harassment

Xtravirt does not tolerate any form of harassment in the workplace, including sexual harassment. The Supplier shall take appropriate measures to prevent harassment, including sexual harassment, occurring in any workplace (whether its own or Xtravirt’s), while providing goods or services to Xtravirt.

Health and Safety

Xtravirt recognise our duty of care to foster practices that support operational excellence while ensuring compliance with relevant health and safety Law, industry standards and best practices.

It is the Supplier’s responsibility to ensure that all Representatives are suitably trained and competent to perform their tasks safely.

The health and safety responsibilities of both the Supplier and Xtravirt must be clearly defined.

The Supplier shall implement a formal hazard management process to effectively minimise health and safety risk.

The Supplier is responsible for promoting health and safety standards, maintaining a healthy working environment to ensure the well-being of all individuals impacted by Xtravirt’s operations, and complying with health and safety Laws wherever it operates.

Environmental Responsibility

The Supplier shall comply with all relevant Law relating to the environment and operate its business in an environmentally responsible way.

The Supplier shall take a proactive approach to working with Xtravirt in reducing our environmental impact. In the case of key suppliers to Xtravirt, this will involve working with Xtravirt and its third-party sustainability ratings provider, to evaluate sustainability performance to help identify opportunities for improvement and benchmark sustainability within our supply chain. It will also involve working with Xtravirt and its third-party carbon emissions monitoring provider to participate in carbon emissions assessment and monitoring and collaborating to explore mechanisms to reduce our and our suppliers’ carbon footprint.

The Supplier shall ensure that:

  1. It monitors and takes action to reduce its and its supply chain’s carbon emissions, ideally by implementing formal carbon reduction or net zero or similar targets;
  2. It adopts and uses practices and systems that minimise the use of resources e.g. water efficiency, energy efficiency;
  3. It and its suppliers use environmentally friendly working practices, tools and equipment, consumables and replacement parts, wherever possible;
  4. The goods it sells or manufactures (including the inputs and components incorporated into those goods) comply with all applicable environmental Laws;
  5. Where practicable, all consumables originate from a sustainable or recycled source;
  6. There are facilities or arrangements in place, either directly or through its suppliers, to ensure Xtravirt can return used packaging for recycling or reuse or environmentally friendly disposal; and
  7. Any hazardous or toxic waste that is produced is properly identified and disposed of by licensed and competent bodies via authorised and/or licensed means.


The Supplier shall have a written environmental / sustainability policy appropriate to the size and nature of its operation which addresses preventing, mitigating and controlling serious environmental and health impacts from its operations.

The Supplier shall carry out annual reviews and audits of its environmental performance and the environmental performance of its suppliers and keep a record of all findings and any remedial action or improvements in processes or procedures that are made to reduce any negative environmental impact.

The Supplier shall have an effective internal environmental management program, with adequately trained staff, which addresses environmental impact control, collation and communication of data on key environmental indicators, the continuous improvement of environmental performance, and the reduction of pollution, emissions and waste.

If the Supplier is not currently accredited, Xtravirt recommends the Supplier works towards ISO 14001 accreditation.

Financial Crime

Xtravirt is committed to providing the highest standards of care and service to our clients. As such, we take compliance with Law extremely seriously and expect our suppliers to do so too.

Anti bribery and corruption, AML and tax evasion

Supplier shall ensure that no benefit which would amount to a bribe under Law, is given or accepted on behalf of Xtravirt, and shall put in place, maintain and enforce an appropriate policy and procedures to prohibit Supplier personnel from:

  1. The offering, giving, soliciting or receiving of a bribe at any time (including the making of facilitation payments or the bribery of public officials) whether for the benefit of Supplier, Xtravirt, the worker, or a member of the worker’s family, friends, associates or acquaintances;
  2. The use of a gift or hospitality to induce a fraud or other wrongdoing to secure a personal or business benefit (and Supplier shall keep proper and accurate records of all payments or other benefits made or received and expenses incurred in connection with its contract with Xtravirt);
  3. The use of sponsorship or advertising agreements to exercise undue influence; and
  4. Unapproved or unauthorised charitable donations or political donations of any kind.

Supplier shall put in place, maintain and enforce an appropriate anti-money laundering and counter terrorist financing policy and procedures which:

  1. Verify the legitimate origin of goods and services within their supply chain; and
  2. Verify the identity and the legitimate nature of the businesses with which Supplier contracts.

Supplier shall maintain a tax strategy that demonstrates a willingness to pay the right amount of tax, in the right place at the right time. Supplier shall put in place, maintain and enforce an appropriate policy and procedures aimed at preventing tax evasion and the criminal facilitation of tax evasion, which:

  1. Regularly assess the opportunity, motive and means within their business for the criminal facilitation of tax evasion;
  2. Implement reasonable preventative measures by developing procedures that are appropriate to mitigate the identified risks; and
  3. Effectively communicate the expectations of management, being that compliance with such policy and procedures is mandatory and that the business takes a zero-tolerance approach to any breach.

Prevention of fraud

Supplier shall ensure that it and its Associates shall not, by any act or omission, commit, cause, facilitate or contribute to the commission by any person, including Xtravirt, of a Fraud Offence or Failure to Prevent Offence, in each case in connection with the performance of services for Xtravirt.

Supplier shall not, and shall ensure that its Associates shall not, solicit or engage with or take steps to solicit or engage with any Associate of Xtravirt to commit, cause, facilitate or contribute to the commission of a Fraud Offence in connection with its contract with or the performance of services for Xtravirt.

Supplier shall ensure that it and all relevant Supplier Associates have in place such Prevention Procedures as it is reasonable in all the circumstances to expect Supplier and Supplier Associates to have in place to prevent any breach of these provisions.

Trade Sanctions

Supplier and Xtravirt shall comply with Law pertaining to international trade sanctions and shall notify the other promptly on becoming aware of any activity or suspected activity, connected to the business relationship between Xtravirt and Supplier, which contravenes any such economic, trade and/or territorial restrictions.

Financial Crime Monitoring and Prevention

Supplier shall encourage workers to promptly report to an appropriate senior manager if they know or suspect that any business activity contravenes Supplier’s Financial Crime policies and shall implement disciplinary action for any worker failing to comply with such procedures. Supplier shall ensure that workers do not suffer any adverse consequences for making a report under the Financial Crime policies or refusing to participate in Financial Crime.

Supplier shall ensure that all Supplier Associates involved in the performance of services for Xtravirt, in connection with its contract with Xtravirt have been vetted and that due diligence and monitoring has been and is undertaken on a continuing basis in respect of them to an appropriate standard in the relevant circumstances.

Supplier shall ensure that all Supplier Associates involved in the performance of services for or its contract with Xtravirt are subject to and at all times comply with obligations which are equivalent to Supplier’s obligations under these Financial Crime provisions. Supplier shall be liable to Xtravirt for any act or omission by any Supplier Associate in breach of any such obligation as if this was an act or omission of Supplier itself.

Supplier warrants and represents that it has not, and to the best of its knowledge, information and belief, no Supplier Associate:

  1. Has been investigated in connection with, or charged with having committed, caused, facilitated, or contributed to the commission of any Financial Crime;
  2. Has received any court orders, warrants, or oral or written notices from a government prosecuting authority concerning any actual or alleged violation by it of any Financial Crime; or
  3. Has received any report (including from Supplier’s external auditors, any Supplier Associates or any other person) or discovered any evidence suggesting that Supplier or any Supplier Associate has committed, caused, facilitated or contributed to the commission of any Financial Crime.


Without affecting any right or remedy available to Xtravirt, a breach by Supplier of these Financial Crime provisions shall be deemed a material breach of its contract with Xtravirt.

Gj Sig 12

Gavin Jolliffe
CEO
Xtravirt