Purpose

This Supplier Code of Conduct outlines the expectations and principles of International Workplace Group plc (‘IWG’) for all suppliers, subcontractors, vendors, and business partners. The policy aims to ensure that our supply chain operates in an ethical manner, protects the environment, respects human rights, and acts in accordance with relevant regulations.

Scope

This Code of Conduct applies to all suppliers of IWG, including their employees, subcontractors and business partners involved in delivering goods and services to IWG.

Definitions

Conflict of Interest: when personal relationships or interests cause bias in decision-making in a professional environment.

Due Diligence: a structured process through which enterprises identify, assess, prevent, mitigate, and account for how they address potential adverse impacts related to human rights, labour, the environment, and other areas within their operations, supply chains and business relationships. It's a risk-based approach, meaning the level of due diligence is proportionate to the severity and likelihood of potential harm.

Policy Statement

At a minimum, suppliers must comply with all applicable environmental and social laws, regulations, and standards within the countries in which they operate and in which they carry out activities for IWG. We expect our suppliers to also adhere to international standards regarding human rights, workplace safety, workers' compensation and fair treatment. It is our expectation that suppliers will conduct business in an honest and ethical manner.

Protecting our planet’s environment

We’re committed to:

• Working with suppliers on ways to understand the environmental impact of our services and products
• Encouraging the continual evaluation of environmental best practices.

Environmental impact

Suppliers must recognise the importance of addressing environmental sustainability in their business and continuously work to minimise the environmental impact of their operations as much as possible.

Environmental Policy

We seek to ensure that best practice in environmental principles, statements and metrics are incorporated in our business policies. We pay particular attention to ethical and sustainable sourcing, environmental performance and our relationships with our suppliers and customers.

Our positive selection of suppliers will, where practicable, include a review of the suppliers' objectives and actions in relation to best practices, via our detailed Supplier Sustainability Questionnaire. We expect our larger suppliers to meet a robust set of sustainability criteria, and we encourage and assist the adoption of best practice amongst all suppliers.

Suppliers should refer to our Environmental Policy, and No Deforestation Policy to ensure their practices are in accordance with its requirements.

Conduct business lawfully and with integrity

Bribery and Corruption

IWG has zero-tolerance for any form of bribery, corruption, extortion, fraud, theft, or embezzlement. All of IWG’s suppliers must comply with all applicable anti-bribery laws and maintain accurate records that correctly reflect their transactions and contain no false or misleading information.

Suppliers should not give, offer to give, request from, or agree to accept money or anything of value from anyone, directly or indirectly through another party, to gain an improper advantage related to IWG.

Conflicts of Interest

IWG expects suppliers to disclose any and all conflicts of interest in any business dealings. Suppliers must avoid all conflicts of interest that may adversely influence business relationships.

Any ownership or beneficial interest in a supplier (including a supplier’s subcontractors or agents), business by a government official, representative of a political party, or an IWG employee must be declared to IWG prior to entering into any business relationship with us.

Confidential and Competitor Information

IWG expects suppliers to obtain and use all market intelligence legitimately and in compliance with all applicable laws and regulations.

Suppliers must not attempt to divulge to IWG any non-public material information about its competitors obtained illegally or unethically. Likewise, IWG’s confidential information or its affiliates must not be shared with any third party including the media unless expressly permitted by IWG in writing.

Gifts and Entertainment

IWG strongly discourages gift giving, however, we appreciate that in limited instances, gift-giving (of nominal value) may be customary in some countries and cultures to maintain business relations. Gift-giving should occur sparingly and always be legitimate and aligned with IWG’s Statement of Commitment.

In no instances shall suppliers accept from or offer to IWG employees any cash or cash equivalent gifts. Any gifts, entertainment, or hospitality must always be of nominal value and, regardless of amount, never received or offered during contract negotiation, bidding, tender, or award. All employees are provided with training on gifts and hospitality and all employees and Board members must disclose all gifts on the IWG Gift Register.

Sanctions

Suppliers must comply with applicable embargoes and trade sanctions, including the restrictions maintained by the EU, UN, US, and the UK (or all other applicable laws). These laws prohibit dealings with restricted countries, governments, businesses, and individuals.

Financial Records, Money Laundering, and Insider Trading

All business and commercial dealings are transparently performed and must be accurately recorded in the supplier’s records. Suppliers must not falsify records or misrepresent conditions or practices. There must be no actual or attempted participation in financial crime, tax evasion, facilitation of tax evasion, and money laundering and suppliers shall take steps to prevent financial transactions from being used by others to launder money or evade or facilitate the evasion of taxes.

No confidential information in the suppliers possession regarding IWG or its affiliates is used to either engage in or support insider trading.

Anti-Facilitation of Tax Evasion

IWG has a zero-tolerance policy towards tax evasion or facilitation of tax evasion. We are fully committed to complying with all legislation, regulation, and applicable guidelines designed to prevent tax evasion and the facilitation of tax evasion wherever we, our clients, our suppliers, and our business partners operate. At all times, business is to be conducted in a manner such that the opportunity for, and incidence of, tax evasion is prevented.

Safeguarding Information and Property

IWG’s confidential information, know-how, and intellectual property must be respected and safeguarded. Any and all personal information about individuals, such as IWG’s clients, consumers or employees, must be handled with full respect for the protection of their privacy and for all relevant privacy laws and regulations. All information provided by IWG that is not in the public domain is deemed confidential and it is only used for its intended and designated purpose.

IWG expects suppliers not to misuse or misappropriate IWG’s physical assets and proprietary information. All such information and data must be kept confidential and protected from any unauthorized access, destruction, use, modification, and disclosure, through appropriate organisational and technical controls. Suppliers must respect the intellectual property rights of all third parties.

Reporting Concerns and Non-retaliation

All employees (whether directly or indirectly employed) are provided with means by which to raise their concerns about any of these requirements. (Insert link here)

Processes are in place to ensure that employees who raise concerns and speak up in good faith are protected from retaliation.

Workplace Respect

IWG expects suppliers to establish a safe, respectful, and inclusive workplace for their employees. All employees are treated with respect and dignity. No employee should be subject to any threats, bullying, or unlawful harassment of any type, including emotional, physical, or sexual harassment. IWG expects suppliers not to discriminate against any person or group of people in its hiring and employment practices, codes of conduct, programs, services, compensation, advancement, discipline, termination, or retirement or in any other aspect of its operations or activities on the basis of that person or group of people's personal characteristics or attributes.

Any form of disrespect and abuse towards IWG’s employees is not tolerated.

Inclusive Practices

IWG expects suppliers to create a work environment where all individuals have equal opportunities and are treated with dignity and respect. IWG encourages suppliers to seek to create an equally diverse and global workforce, and to expect their employees to embrace norms that support an inclusive culture, workplace, and community.

A safe and healthy workplace for everyone

Suppliers are expected to conduct their activities in a manner that respects human rights, in line with international frameworks such as the UN Guiding Principles on Business and Human Rights, the International Labor Organization (ILO) Core Conventions, the International Covenants on Economic, Social, and Cultural Rights and the International Covenant on Civil and Political Rights, to the extent applicable to their operations.

A healthy and safe workplace

Work is conducted on a voluntary basis

Under no circumstances should a supplier use forced labour, whether in the form of compulsory or trafficked labour, bonded labour, indentured labour, or other forms. Mental and physical coercion, slavery, and human trafficking are prohibited.

Wages and working hours are reasonable

All employees are paid fair wages which meet or exceed the legal minimum standards or appropriate prevailing industry standards, whichever is higher. Other than legally mandated deductions, all other deductions from wages must be made only with the express and written consent of the employees concerned and in compliance with applicable laws and international human rights standards.

Working hours for all employees are reasonable, and employees are not required to work more than the regular and overtime hours allowed by the law of the country where the employees are employed. All overtime work by employees is on a voluntary basis and compensated in line with relevant regulations.

All employees’ health and safety are protected at work

IWG expects all suppliers to provide their employees with a healthy and safe workplace, as per local health and safety laws and regulations, to prevent accidents and injury arising out of, linked with, or occurring in the course of work or as a result of the supplier/employer’s operations.

Work is conducted on the basis of freely agreed and documented terms of employment.

All employees, whether permanent, fixed term, or casual, are provided with employment documents that are freely agreed to and respect employees’ legal and contractual rights.

All employees are of an appropriate age

Under no circumstances should a supplier employ individuals under the local legal minimum age for work or mandatory schooling. If young individuals are employed by a supplier, the supplier must ensure those employee’s are not subjected to work that is mentally, physically, socially, or morally dangerous or harmful or interferes with their schooling by depriving them of the opportunity to attend school.

All employees are free to exercise their right to form and/or join trade unions and to bargain collectively.

The rights of employees to freedom of association and collective bargaining are recognised and respected. Employees are not intimidated or harassed in the exercise of their right to join or refrain from joining any organisation.

Suppliers are expected to align their practices with our Fair Treatment Policy and the Modern Slavery Act, taking reasonable steps to prevent any form of slavery or human trafficking within their operations and supply chains.

Respect and support local communities

IWG believe every company has a responsibility to the local communities on which they have an impact and from which they profit. We are committed to working with suppliers who understand the issues facing the communities in which they operate, and encourage conduct of business in a way that builds social capital and achieves a positive impact.

Community Involvement

IWG encourages suppliers to bolster the well-being of the local community through their business. Suppliers must operate with respect for local communities and indigenous people and their rights and title to property and land.

IWG encourages suppliers to understand and observe the cultural and economic context in which they are working, to operate safely and responsibly, to be mindful of the wellbeing of communities and to foster positive social and economic relationships with local communities.

Social Value

IWG recognise the mutual influence between supply chains and communities and encourage our supplier to take opportunities to integrate sustainability initiatives into their supply chain - through creating value for communities and providing a more integrated and holistic consideration of supply chain-community interaction

Suppliers should refer to our Fair Treatment Policy and Just Transition Commitment to ensure their performance is in accordance with its requirements.

Procedures

We will adhere to the OECD Guidelines for Multinational Enterprises to ensure that ethical, environmental and social risks are identified and managed effectively.

Suppliers are encouraged to implement internal processes and controls to ensure their business operations comply with this policy.

Roles and Responsibilities

• Suppliers must understand and adhere to this policy throughout their operations and supply chain.
• IWG Procurement and Supply Chain Teams must communicate the policy to suppliers, undertake due diligence and follow up on identified and reported violations.
• Employees and stakeholders can report concerns or suspected violations through established grievance or whistleblower channels.

IWG operates a broad sustainability program with accountabilities across the organisation. This program includes delivery of our environmental targets and ultimately enhanced outcomes for customers, employees and investors.

IWG’s independent Board of Directors, regularly reviews and assesses performance and ensures alignment with its corporate strategy. The Board sets targets and frameworks to comply with, for the business, based on the business department and jurisdiction.

Compliance

To support the compliance with this policy, IWG will:

• Communicate expectations transparently and provide guidance to suppliers where required
• Provide mechanisms and channels for reporting grievances
• Monitor and audit supplier performance frequently
• Collaborate with suppliers to address non-compliance and drive continuous improvement

In case of adverse impacts, suppliers are expected to promptly address any issues by implementing appropriate corrective and remedial actions. Failure to comply may lead to suspension or termination of the business relationship.

References

The following international standards and policies have informed the development of this Code:

• UN Guiding Principles on Business and Human Rights
• International Labour Organization (ILO) Core Conventions
• OECD Guidelines for Multinational Enterprises
• International Covenant on Economic, Social and Cultural Rights of 1966
• International Covenant on Civil and Political Rights of 1966

Policies

1. Environmental Policy
2. International Workplace Group Water Policy
3. No Deforestation Policy
4. Just Transition Policy
5. Fair Treatment Policy
6. Modern Slavery Act Statement
7. Statement of Commitment
8. Global Grievance Policy
9. Global Right to Speak Policy

Revision

This policy is reviewed annually and updated in line with evolving best practice, and regulatory requirements.