Business Partner Code of Conduct

PURPOSE AND SCOPE OF APPLICATION

COBALT (the “Law Firm”) complies with applicable environmental, social and corporate governance laws while conducting its business. The Law Firm expects ethical, responsible and legally compliant business activities, including in relation to the environment and society, also from its clients, suppliers and subcontractors (the “Business Partners”).

The Code of Conduct (the “Code”) is an important part of, and establishes the basis of the Law Firm’s strategy for a sustainable supply chain and the ambition to collaborate with our Business Partners in the promotion of lawful, professional and fair business practices that integrate the respect for labour rights, human rights, environment and business ethics.

LEGAL COMPLIANCE

Business Partners are expected to ensure they conduct business in compliance with the applicable laws and regulations of the jurisdictions in which they operate.

Upon Business Partner’s failure to comply with the Code, the Law Firm may reconsider continuing the business relationship with the Business Partner.

The Law Firm specifically expects its Business Partners and encourages them to address the following issues:

HUMAN RIGHTS AND LABOUR RIGHTS

To support and respect fundamental human rights as set down in the United Nations’ Universal Declaration of Human Rights and to recognise a responsibility to observe these rights when conducting business.
To follow international principles of UN Global Compact, UN Guiding Principles on Business and Human Rights, OECD Guidelines for Multinational Companies, and International Labour Organization when conducting business.

CHILD AND FORCED LABOUR

Not to use, or benefit from, forced labour, or employ, or benefit from the employment of, any person below the legal minimum age for working.

WORKING CONDITIONS

To ensure that normal working hours and overtime working hours are within the limits permitted by applicable laws and regulations or agreed to in relevant collective agreements.
To pay employees a wage as defined by national laws or any applicable collective agreement.

HEALTH AND SAFETY

To provide all employees with a safe and healthy working environment to prevent accidents, in accordance with applicable laws and industry standards.
To offer employees access to adequate health and safety training.
To have health and safety policies in place, including standards designed to reduce work-related injury and illness, and promote the general health of employees.
To record, report to relevant authorities and investigate all significant health and safety incidents.

NON-DISCRIMINATION

To promote equal opportunities for, and equal treatment of, employees irrespective of ethnicity, nationality, religion, sex, age, sexual preferences or other distinguishing characteristics.
To refuse to tolerate any unacceptable treatment of employees, such as violence or harassment of any kind, or discrimination in the work environment.

ANTI-CORRUPTION AND BRIBERY

To comply with applicable anti-corruption laws and regulations.
Not to tolerate bribery, extortion or other forms of corruption.

DATA PRIVACY AND INFORMATION SECURITY

To protect Law Firm’s client and personal information in accordance with their contractual obligations to the Law Firm and follow applicable laws and best practices.

ENVIRONMENT

To comply with all relevant environmental requirements applicable to the Business Partner’s activities, products and services.

CORRECTIVE ACTION

In case of any deficiencies identified with respect to compliance with applicable laws and regulations, to promptly take corrective action to address identified deficiencies.

TRANSPARENCY AND MONITORING COMPLIANCE

Upon request of the Law Firm, to provide information on the Business Partner’s compliance with the Code.