Principles of conduct in supplier relations

The NLB’s suppliers are the key partners in providing quality services and products. The Code sets out the fundamental principles, values, and rules of desired conduct in business, which must also be understood and respected by the NLB Group’s suppliers to ensure ethical, responsible, and compliant business operations. Suppliers must ensure that these rules are observed by their representatives, employees, subcontractors, and their own suppliers with whom they collaborate in providing goods and services to the NLB Group. We expect everyone to act in accordance with standards that are at least equivalent to those provided for in this Code. 

Suppliers are also expected to observe and act in accordance with:

• the United Nations (UN) Guiding Principles on Business and Human Rights,
• the International Labour Organization (ILO) Declaration on Fundamental Principles and Rights at Work,
• the Organization for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises, which include workers in the value chain.

• They conduct their business professionally and in accordance with the highest ethical standards, which includes honesty, integrity, and taking responsibility for their actions.
• They act in accordance with the legislation and the rules of profession, the ethical principles and good business practices.
• They actively prevent and eliminate the risks of misconduct and unethical conduct. Respect the copyrights and intellectual property of third parties (authors, performers, etc.) and use them in accordance with their intended purpose or the owner’s consent and use only appropriately licensed tools in their work.
• It is desirable for suppliers to have their own Code of Ethics.

• Respecting human rights and fundamental freedoms of all individuals, ensuring equal opportunities for all employees in a fair and transparent manner, regardless of gender, age, race, skin colour, nationality, ethnic background, sexual orientation, religion, or other personal traits, and by promoting a positive and safe work environment.
• They prohibit any form of discrimination, harassment, or exploitation; involuntary or forced labour; modern slavery; human trafficking; unequal or unfair treatment of employees; and any form of violence, harassment, bullying, or victimization of individuals in the workplace.
• They do not employ individuals under the age of 15 (or 14, if required by the laws of the country where the work is performed) and fully comply with the applicable national laws and operate in accordance with the standards of the ILO Declaration.
• They strive to pay a minimum wage that enables a decent standard of living and ensures acceptable living conditions when providing housing for employees (in accordance with the international standards).
• They respect the rights of minorities and indigenous communities, including rights to land, forests, and water resources.
• They ensure that employees are provided with at least minimum standard working conditions.

• Comply with environmental regulations and strive to continuously reduce negative impacts on the environment.
• Promote sustainable practices and use environmentally friendly materials to the best of their ability.
• Comply with applicable laws and international standards in the field of environmental protection.
• Have procedures in place for the safe and sustainable management of waste, air emissions, energy and water consumption, and their reduction.

Suppliers must handle confidential information and data in accordance with the applicable regulations and the highest international standards of due diligence in information and data management. They must protect the NLB Group’s confidential information and data and use them solely for the purpose for which they were obtained. They must also protect confidential data and information, including personal data, and take all necessary measures to prevent their misuse, theft, fraud, or unauthorised access or disclosure.

Disclosure of confidential information and data to third parties without the express written consent of the NLB is prohibited. 

Suppliers must identify, disclose, and avoid situations that could give rise to a conflict of interest.

In the event of a potential or actual conflict of interest, suppliers must immediately notify the NLB.

All business activities must be conducted fairly and transparently.

Suppliers must comply with the applicable anti-corruption legislation, reject any form of bribery, extortion, and other forms of corruption intended to influence the business decisions of the other party.

We expect suppliers to have appropriate measures in place to prevent such practices.

Suppliers provide jobs and an environment that is safe, friendly, and healthy. They promote mutual respect and a healthy lifestyle among employees and provide services that meet the requirements of applicable quality, health, and safety standards.

They proactively manage occupational health and safety risks to ensure an incident-free environment that prevents occupational injuries and illnesses.

Occupational health and safety at work requirements, as defined in this chapter of the Code, are an integral part of the suppliers’ contractual obligations. Failure to comply with these requirements is considered a breach of contract and may lead to termination of the business relationship.

All applicable national and international tax regulations must be complied with.

Suppliers shall, to the best of their ability:

• identify, detect, and address any suspicion of money laundering or terrorist financing,
• develop procedures and measures to respect sanctions and embargoes that prevent persons or organisations to conduct business with certain countries, groups of persons, companies, organisations and individuals, including those connected with terrorist activities, drug smuggling, nuclear weapon development and similar. (https://www.transparency.org/en/our-priorities/extractive-industries; https://www.transparency.org/en/cpi/2021/index/nzl) 

To make the right decisions, the suppliers must follow these steps:

1. Is it legal?
   • Is it in compliance with the NLB policies?
2. Does it reflect the fundamental principles, values and rules of conduct in the NLB?
3. Can it negatively influence the stakeholders of the NLB?
4. Would they feel good if this action were publicly exposed?
5. Could it negatively influence your company or the NLB if everybody did it?

Suppliers must maintain open and honest communication with the NLB and cooperate in all necessary inspections and audits. In the event of questions or concerns regarding this Code, they may contact the appointed contact person at the NLB.

NLB suppliers are required to provide the NLB with all requested information regarding environmental, social and governance factors, or explain why certain information cannot be provided.

The NLB reserves the right to regularly monitor and verify the suppliers’ compliance with this Code. This may include:

• supplier self-assessments,
• internal or external audits,
• visits to the suppliers’ locations,
• requests for additional documentation or clarifications.

In the event of identified non-compliance, the NLB will require the supplier to prepare and implement a plan of corrective measures within a reasonable timeframe.

If a supplier fails to remedy the non-compliances or in the case of serious violations, the NLB reserves the right to terminate the cooperation and pursue other legal remedies.

Suppliers undertake to actively cooperate in all monitoring procedures and to provide accurate, complete and timely information. Suppliers are required to immediately report any violations of this Code.

Suppliers and their employees are required to notify the NLB Group of any potential violations of this Code or other unethical conduct; the NLB Group will handle all reports with the highest level of confidentiality and without retaliation against the whistleblowers.

In the event of suspected misconduct within the NLB Group, suppliers have the following (including anonymous) channels available for reporting it:

• electronically via the Whistler web application
• ordinary mail: NLB d.d. Ljubljana, Trg republike 2, 1520 Ljubljana, for SPKI – do not open!