Púca Third Party Code of Conduct
This statement was last updated: 10th March 2025
At Púca Technologies Ltd (T/A Púca), doing the right thing is at the heart of who we are. We believe in ethics, professionalism, and integrity. This commitment extends to our people, the environment, and the communities in which we live and operate.
Our employees are expected to uphold an unwavering dedication to ethics, integrity, and full compliance with laws, regulations, and professional standards, adhering strictly to Púca’s Code of Conduct. We also require our clients and third parties, including subcontractors, consultants, and suppliers, to align with these same ethical principles.
To this end, our Third Party Code of Conduct (TPCOC) aims to advocate for high legal, ethical, environmental, and human standards, whilst providing clear guidance and requirements for third parties. These responsible business practices and principles are intended to be observed by third parties throughout their contractual relationship with Púca.
Applicability
The TPCOC applies to all third parties engaging with Púca Technologies. A third party is defined as any individual or organisation that: (i) provides goods or services to Púca; (ii) provides goods or services to Púca’s clients under contract; or (iii) engages in a strategic alliance or partnership with Púca.
Monitoring
Púca Technologies expects all third parties to actively monitor their own and their employees’ adherence to the TPCOC. Púca may also conduct periodic compliance assessments to ensure continued adherence.
Principles Overview
Third parties are required to fully comply with this TPCOC and all applicable laws and regulations. Where contractual terms are stricter than this TPCOC, the more stringent obligations apply. Third parties should implement policies and procedures to ensure compliance with the standards set in the TPCOC and encourage the same within their own supply chains.
Significant deviations or violations of the TPCOC must be reported immediately. Anonymous reporting options are available to safeguard those who report without fear of retaliation.
Human Rights
- Humane Treatment: Third parties must treat all workers with respect and dignity, avoiding any demeaning practices.
- Harassment: An inclusive, harassment-free environment must be upheld, prohibiting any form of harassment or retaliation.
- Human Trafficking: Third parties must not engage in or support human trafficking, modern slavery, or any form of forced or involuntary labour.
Labour Standards
- Forced Labour: Use of forced or involuntary labour is prohibited, including any coercive practices or withholding of worker documentation.
- Child Labour: Workers must not be under the minimum legal age, and work involving individuals under 18 must comply with laws ensuring safety and educational needs.
- Non-Discrimination: A culture of equal opportunity must be promoted, avoiding discrimination based on protected characteristics such as gender, race, or age.
- Wages and Working Conditions: Compliance with minimum wage laws and workplace safety standards is essential.
- Freedom of Association: Third parties must respect workers’ rights to freely communicate concerns and form associations without fear of retaliation.
Health and Safety
Work environments must be secure, healthy, and drug-free, meeting legal standards and promoting accident prevention.
Grievance Procedures
Effective, anonymous grievance channels must be available for employees to raise workplace concerns without retaliation.
Environmental Responsibility
- Resource Conservation: Third parties should endeavour to improve resource efficiency and minimise waste, adopting environmentally sustainable practices.
- Emissions Reduction: Efforts should be made to limit greenhouse gas emissions, including tracking and setting reduction targets.
Supplier Diversity
Púca encourages diversity and equality in procurement, expecting third parties to support minority-owned, women-owned, and other diverse businesses within their supply chains.
Integrity, Ethics, and Anti-Corruption
- Business Integrity: Third parties must maintain fair business practices and uphold ethical standards.
- Anti-Corruption: Strict adherence to anti-corruption laws, including applicable Bribery Acts, is required, and bribery in any form is prohibited.
- Fair Competition: Practices that manipulate markets, collude, or disrupt fair competition are forbidden.
- Gifts and Hospitality: Any gifts or inducements must not create perceptions of bias or improper influence.
Violations of the TPCOC may result in audits, corrective actions, removal from supplier lists, or contract termination.
Contact Us
If you have any questions or concerns about this Code of Conduct, please contact us by email addressed to dataprotection@puca.com.