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Responsible Procurement Policy

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1. Policy

This Responsible Procurement Policy underpins all purchases of goods and services made by or on behalf of HWLE.

HWLE is committed to minimising adverse social and environmental impacts within our supply chain. We partner with suppliers who embed sustainable and ethical practices in their organisations and who promote these practices within their own supply chains.

2. Our commitment

In situations where HWLE is acquiring goods and services from third parties, we seek to engage suppliers that share our approach to diversity and sustainability.

Our policy is to:

  • conduct due diligence on suppliers before they are selected to work with us, so that we can ensure they meet our expectations around sustainability and ethical practices;
  • prevent any adverse impacts on human rights in our procurement activities, and actively address any such issues should they arise;
  • ensure that all of our procurement activities are consistent with applicable laws;
  • review and assess suppliers on a regular basis to ensure they do not present a risk of modern slavery, and if any concerns arise, address that risk including by terminating the relationship with the supplier, as appropriate;
  • treat suppliers fairly and objectively at all times;
  • ensure that major supply contracts are reviewed in line with our purchase strategy and that appropriate suppliers have an equal opportunity to win our business;
  • pay suppliers in accordance with the agreed terms and deal with any exceptions in a timely manner;
  • select suppliers without considerations of the gender of their employees or their ethnic origin;
  • select suppliers without consideration of the number of their employees or their location, unless this would create unacceptable risk to HWLE or its clients or staff;
  • engage with suppliers to identify ways in which we can improve our own environmental and social practices;
  • share information with suppliers so that they can better understand our approach to responsible procurement, and they can embed similar values in their own organisation;
  • fully comply with applicable local regulations relating to diversity and inclusion;
  • ensure that suppliers understand our approach to diversity and inclusion, sustainability and social impact, and seek to engage with suppliers who are culturally aligned with our firm;
  • work with our suppliers to support improvements in their social and ethnical practices; and
  • continuously improve our knowledge of socially and environmentally responsible supply chain management practices.

3. Supplier Requirements

We expect our suppliers to meet with following requirements:

  • comply with all laws and regulations applicable in the jurisdiction where the goods or services are procured and/or delivered;
  • maintain effective policies and procedures to manage their environmental impact;
  • implement and maintain policies and frameworks to appropriately communicate and integrate their risk mitigation strategies and compliance programs within the organisation;
  • respect fundamental human rights including worker representation;
  • manage their risk, governance and compliance appropriately, with senior management responsibility and accountability for legal compliance;
  • have a positive impact on the communities in which they operate;
  • maintain and evidence responsible health and safety practices;
  • be committed to a comprehensive policy of equal opportunities in employment;
  • adopt ethical business practices with respect to the business behaviour of individuals and the organisation as a whole;
  • manage their carbon footprint;
  • to the extent applicable, treat HWLE’s clients fairly at all times;
  • comply with HWLE’s confidentiality requirements at all times;
  • have management systems and practices in place to ensure the prevention of:
    • money laundering;
    • insider trading;
    • conflicts of interest;
    • fraud, bribery and corruption and other improper payments or gifts, and
    • unauthorised access to personal and business information; and
  • maintain a sustainable procurement policy.

Where it is found that a supplier’s conduct is not in accordance with the above principles, we will seek to engage with that supplier and encourage improvement in their environmental, social and ethical performance.

If agreed improvements are not achieved by the supplier within an agreed timetable, or if the matter is of such a serious nature it warrants immediate action, we may terminate the relationship with the supplier, or take such other steps as we deem appropriate in the circumstances.

4. Review Date

This Policy was last reviewed in May 2025.