Supplier code of conduct and minimum terms

Hill Dickinson recognises its responsibility to protect human rights. We expect our suppliers and partners to have policies and processes in place to meet responsibilities. You must adhere to the requirements of the Human Rights Act 1998 and the European Convention of Human rights.

We have a zero-tolerance approach to modern slavery. We expect you to prohibit the use of forced, bonded, indentured or any other form of compulsory labour and comply with the Modern Slavery Act 2015.

You must comply with all respective national laws and regulations regarding working hours, wages and benefits including;

• The Working Time Regulations 1998

• The National Minimum Wage Act 1998

• The Employment Rights Act 1996

• The Pensions Act 2008.

Hill Dickinson is committed to celebrating diversity and providing equality of opportunity and fair treatment for all Individuals must be treated with dignity and respect, promoting equal opportunities without discrimination throughout your daily practices.

We require all our partners, suppliers, and vendors to uphold the principles set out in the Equality Act 2010, as amended by the Equality Act 2010 (Amendment) Regulations 2023 (SI 2023/1425), which came into effect on 1 January 2024. This includes maintaining safe working practices, implementing supportive policies, and ensuring robust whistleblowing procedures and training programmes are in place.

We expect a demonstrable commitment to fostering a workplace culture rooted in fairness, equality, and respect for all individuals—regardless of age, gender, gender identity, professional background or status, ethnicity, disability, sexual orientation, marital or transgender status, nationality, religion, or belief.

We have built an environment free from physical, psychological verbal harassment, or abuse. A suite of effective and governed policies and procedures ensure we fulfil our commitments in this area and expect the same from our suppliers and partners.

We expect all suppliers and partners to fully comply with all applicable health and safety laws, regulations, and standards relevant to their operations. Suppliers must provide a safe, clean, and hygienic working environment for all workers, ensuring that risks to health and safety are identified, assessed, and effectively controlled.

Clear and documented procedures must be in place to uphold regulated occupational health, safety, and wellbeing standards. This includes the provision of appropriate training, access to necessary protective equipment, and mechanisms for reporting and addressing health and safety concerns without fear of retaliation.

You must ensure that you supply or provide goods and/ or services to the firm in a way which is not only lawful,

but open and transparent.

We cannot act where there is a conflict of interest and expect any parties working for or on behalf of Hill Dickinson to inform us as soon as a conflict is suspected or identified.

You must therefore anticipate and identify all relevant potential conflicts of interest and report immediately in writing to your usual contact at the firm and [email protected].

Suppliers must comply with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, ensuring that all personal data is processed lawfully, fairly, and securely. They are required to implement appropriate technical and organisational measures to protect data, limit processing to legitimate business purposes, ensure staff confidentiality and training, and promptly report any data breaches. Suppliers must also ensure that any third parties involved in processing data are contractually bound to equivalent standards and cooperate fully with audits or assessments to verify compliance.

We have a range of controls to prevent fraud and money laundering activities and we take the effectiveness of our training and procedures in this area extremely seriously working with regulatory bodies, our partners and suppliers closely.

We expect all suppliers and partners to maintain robust controls to prevent money laundering, terrorist financing, and other forms of financial crime. Suppliers must comply with all applicable anti-money laundering laws and regulations, including but not limited to:

• The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017, as amended;

• The Proceeds of Crime Act 2002;

• The Financial Services and Markets Act 2000, where applicable.

• The Economic Crime and Corporate Transparency Act 2023

Suppliers must not engage in, facilitate, or enable any activity that involves the concealment, disguise, conversion, or transfer of criminal property or terrorist funds.

Hill Dickinson maintains a zero-tolerance approach to bribery and corruption in any form. We are committed to conducting business with integrity and in full compliance with all applicable anti-bribery and corruption laws, including but not limited to the UK Bribery Act 2010. We expect our suppliers and partners to share this commitment and uphold the highest ethical standards in all business dealings.

Suppliers must not, directly or indirectly, offer, give, solicit, or accept any bribe, kickback, facilitation payment, or other improper advantage in connection with Hill Dickinson or any third party. This applies to interactions with both public officials and private sector individuals. Suppliers are required to implement and maintain effective anti-bribery policies, conduct regular risk assessments, and ensure that all employees and subcontractors receive appropriate training.

Suppliers must also conduct due diligence on third parties involved in delivering goods or services on our behalf and report any suspected or actual instances of bribery or corruption without delay.

Furthermore you must ensure prompt reporting and disclosure. Suppliers must not breach or contravene any sanctions regulations.

Hill Dickinson reserves the right to audit compliance and take appropriate action, including termination of the business relationship, in the event of a breach.

Hill Dickinson is fully committed to minimising the environmental footprint of its business operations and contributing to broader societal goals for sustainable development. We expect our suppliers and partners to demonstrate environmental sustainability commitments that are comparable to our own, and to actively work toward reducing their environmental impact across all areas of operation.

Suppliers must comply with all applicable environmental laws and regulations and are encouraged to go beyond compliance by adopting best practices in environmental stewardship. This includes implementing measures to measure and reduce all in scope greenhouse gas emissions, minimise waste, conserve energy and water, and prevent pollution. Suppliers should also consider the environmental impact of their supply chains and strive to source materials and services responsibly.

Business continuity or disaster recovery plans must be implemented to ensure the continuation of services to Hill Dickinson can be provided. This includes provisions for employee safety, security and limiting environmental impact (where applicable). Where partners and suppliers provide services that impact Hill Dickinsons ability to meet targets and obligations, we expect operational resilience and timely notification should an event take place.

Our suppliers and business partners must have adequate and relevant insurance including, but not limited to, public and product liability and professional indemnity insurance which is current for the duration of the contract. They must comply with any request to provide proof of insurance or other related information and keep the firm abreast of any material changes.