Supplier Code of Conduct and Sustainability Policy

MSI are committed to the highest standards of integrity and responsible business practices. MSI provides its services to third party companies (Customers) that have legal and regulatory obligations to procure services from responsible and sustainable suppliers. All suppliers, agents, consultants and contingent or temporary workers (collectively, Suppliers) doing business with MSI agree to deliver their services in a manner consistent with MSI’s commitments to its own high standards and those standards expected by MSI’s Customers in respect of labour, environmental impact and social contributions of its suppliers. Accordingly, each Supplier must ensure compliance with this Code of Conduct which sets out the minimum standards for social responsibility and sustainability. Nothing herein is intended to conflict with any independent Supplier agreement between a Supplier and MSI. In the event of any such conflict, the relevant provision of the independent Supplier agreement shall prevail.

This Code of Conduct has been drafted in accordance to international norms such as the Governing Principles for Companies and the UN Universal Declaration of Human Rights, the International Labour Organization conventions, OECD (The Organisation for Economic Co-operation and Development) guidelines, and ISO (International Standards Organization) criteria.

General Principles

MSI is committed to acting with rigor, objectivity, transparency, and professionalism in its relationships with Suppliers, and specifically with:
  • ensuring compliance with MSI’s commitments towards Suppliers.
  • using mechanisms that promote reasonable transparency in the management of purchases, especially in negotiations with Suppliers and in the decision-making process for the awarding of the purchases.
  • ensuring equal opportunity to all Suppliers involved in a specific procurement process, basing the selection of suppliers, the awarding of purchases and other decisions on objective criteria.
  • encouraging a culture of Sustainable Business among our Suppliers.
  • working with Suppliers in order to ensure compliance of the minimum standards for sustainable business (contained in this document) and supporting continuous improvement
  • evaluating compliance to the minimum standards for sustainable business demanded through independent supervision and/or verification. This verification may be carried out through information provided by the Supplier itself and/or through on-site audits. MSI expects its Suppliers to provide adequate timely responses to its requests for information, and to provide reasonable access to all pertinent information, facilities, and workers in order for verification to be carried out.

Any company or organization that wishes to be considered as an MSI Supplier must comply with this Code of Conduct and transfer at all times the demand for compliance with the minimum standards for sustainable business to its permitted subcontractors. Any breach of this Code of Conduct by a Supplier will be considered a breach of contract, and MSI may, at its option elect to terminate its contract with a Supplier and claim any and all damages which MSI may sustain as a result of the breach and/or termination of the contract. In the alternative, MSI may demand the Supplier to undertake immediate corrective measures in order to comply with this Code of Conduct, in which case, the evaluation of the corrective measures and whether they are adequate, both in impact, form and timeframe, will be determined in the discretion of MSI.

Minimum Standards for a Sustainable Business

  • 1- Ethical Criteria
    • 1.1- Compliance with Laws, Rules, and Regulations: All Suppliers must comply with all applicable laws, rules and government regulations applicable to it and to the MSI entity where they provide services.
    • 1.2- Anti-Corruption: MSI respects and strictly adheres to legislation in force, professional ethics and internal regulations, and never allows for any form of corruption, extortion or bribery. Suppliers must not engage in bribes, kickbacks or other corrupt practices and must comply with all ethical standards and applicable law where their assignment takes place. Suppliers must actively and consistently fight against any form of punishable or unethical influence with respect to decisions related to MSI or other companies or entities. Suppliers will take immediate action against corruption within their own company. Supplier must ensure and have checking processes to ensure that its personnel refrain from making or offering, directly or indirectly, any payment in cash or in kind or in any other form, to any person or legal entity acting for the benefit of any authority or public or private entity, with the aim of obtaining or maintaining any sort of benefit.
    • 1.3- Conflicts of interest: Suppliers must not engage in any activities that could present a conflict of interest relating to MSI. Suppliers must disclose all situations where, in the course of their assignment, they may be engaged to provide services to MSI employees who are members of the Supplier’s family, friends or others with whom they have a close personal or business relationship.

  • 2- Social Criteria
    • 2.1- Labour and Workplace Behaviour: The work done by the employees of the Supplier must be based on a recognized labour relationship established in accordance to all applicable legislation. The obligations of the Supplier with respect to its employees regarding labour or social security norms must be fully complied with. Abuse of service provision contracts or the recurring use of subcontracts, to avoid legal obligations will not be allowed. Workers must be provided with a written employment agreement in their native language. Employees shall not be required to pay employers’ or agents’ recruitment fees or other related fees for their employment. If any such fees are found to have been paid by workers, such fees shall be immediately repaid to the employee.

      The Supplier workday hours should adhere to national legislation and the industry norms of reference, the criteria that offer the highest levels of protection for the employee will prevail. Workers will not be demanded on a regular basis to work more than 48 hours per week, and they will be provided with a minimum of one day off for every average period of 7 days. Overtime required by the Supplier shall be voluntary and must not be requested on a regular basis, and will always be compensated with a special rate. In accordance to what is established in Convention 1 of the ILO, these dispositions are aimed at functions other than those of supervision and/or management.

      Suppliers engaged to provide services to MSI must not engage in misconduct or inappropriate behavior, including any form of discrimination, harassment, bullying or violence.

  • 3- Health and safety: Suppliers engaged to provide services on MSI premises are expected to contribute to a safe workplace and must comply with all safety standards in force at the premises of their assignment and report any unsafe working conditions or practices.

  • 4- Gifts and hospitality: Suppliers may not provide or receive business gifts or hospitality (this includes meals, services, presents, entertainment, or anything similar of any value), unless it is of a lawful and limited nature in the ordinary course of performing their assignment and prior written approval is received from the Supplier’s MSI’s engagement contact. This includes gifts and hospitality given to or received from MSI employees, clients, business partners or suppliers.

  • 5- Confidentiality: Suppliers must adhere to specific confidentiality terms agreed as part of their assignment. If a separate confidentiality agreement does not exist, Suppliers must presume that all information available to them from MSI is confidential and may not be disclosed externally. This includes non-public information relating to MSI’s business, internal working processes, pricing information, strategies, tools, IT systems, employees, clients, suppliers and business partners. Suppliers must also respect any confidentiality restrictions imposed on MSI by third parties when this relates to their assignment.

  • 6- Privacy: Suppliers must may not use, disclose or retain any personally identifiable information relating to MSI’s employees, clients, business partners or suppliers, unless strictly required in the performance of the contracting assignment.

  • 7 -Intellectual property: Suppliers must ensure that they respect the intellectual property rights of MSI and third parties and may not use any intellectual property such as software, photos, video, documents, drawings, or designs which are unlicensed or do not have MSI’s permission for use in relation to their assignment. Suppliers may further not appropriate, corrupt, destroy, misuse, or transfer any intellectual property materials belonging to MSI or its clients, suppliers and business partners.

  • 8- Company resources: To the extent that Suppliers are required to utilize MSI assets, resources, data or equipment, including the company’s computers, telephones and information technology systems (collectively, Assets), such use must be solely for MSI business purposes and must be consistent with the Supplier’s independent Supplier agreement and this Code of Conduct. Suppliers may not harm, compromise or destroy any Assets, use Assets in violation of the law, or offer Assets to third parties for any purpose. For reasons of safety, supervision and security, MSI may, in accordance with applicable law, access and inspect the Supplier’s use of all Assets, at any time and without notice.

  • 9- Press and media: Suppliers are not permitted to speak to the press or media (including via social media) on behalf of MSI.

  • 10- Reporting Violations: Suppliers are expected to report any conduct that they believe in good faith to be inconsistent with this Code of Conduct or with any law, rule or regulation. Reports can be made to their MSI engagement contact or to Giorgi Bakradze.