Our supply chain is multi-tiered and varied, and includes subcontractors, suppliers, vendors, consultants, and joint venture partners. Throughout our history, our goal has been to partner with businesses that embrace our core values and exemplify a genuine dedication to ethical and honest dealing.
Prequalification and due diligence
We subject prospective suppliers to rigorous prequalification and due diligence during onboarding and on existing suppliers at regular intervals. This process helps us select business partners that follow workplace standards and business practices consistent with our own. We implement a multi-tiered, risk-based approach, which increases our visibility and reduces regulatory, safety, financial, and legal risk.
As part of our process, suppliers must complete our prequalification package, which includes our prequalification questionnaire, terms and conditions, and health and safety responsibilities. Suppliers are asked specifically about the steps they’ve taken to ensure compliance with the MSA and whether they are aware of instances or concerns of modern slavery and human trafficking in their business or supply chain.
We also partner with various third-party professionals to maximize data assessment, including a vendor to provide regulatory background checks based on both structured and unstructured data. Weighing various factors and using known information (including our independent research and historical knowledge, the supplier’s prequalification submissions, and the background check), we identify suppliers that may need further review and risk controls before we proceed with engaging them. Suppliers renew their prequalification submissions at regular intervals, and we continue to screen for any red flags.
Adherence to our policies
As a condition of doing business with us, our suppliers must agree to comply with our Supplier Code of Conduct and Ethics (“Supplier Code”), which sets forth the minimum standards of conduct expected of our business partners. The Supplier Code applies to all third parties that provide goods or services to our organization, as well as to their owners, officers, directors, employees, contractors, agents, and others working on their behalf. Suppliers are responsible for providing their own subcontractors with the Supplier Code and ensuring that they follow it.
Our Supplier Code expressly prohibits child labor and all forms of modern slavery and human trafficking. Suppliers are required to comply with our MSA Policy as well as with the letter and spirit of all applicable laws, including those governing child labor, involuntary labor, and fair wages and hours. Suppliers are to immediately notify us if they suspect any instance of modern slavery in their own business or supply chain.
Our Supplier Code also sets out our expectation that suppliers:
- Not retaliate against anyone who in good faith reports potential misconduct and have a formalized system for employees to report concerns without fear of retaliation
- Cooperate in audits, investigations, and reviews
- Maintain a discrimination- and harassment-free workplace and respect the dignity of all workers
- Respect the rights of workers to bargain collectively, freely organize, and join associations of their own choosing (or refrain from doing so), as permitted by law
- Provide a safe and healthy work environment
- Have effective controls to ensure that applicable law and policies are followed; and
- Minimize any adverse impact to the environment and human health
Our Suppliers must report potential violations of the Supplier Code and are provided multiple avenues for doing so, both within and outside of our organization. Our Supplier Code may be found at stobuildinggroup.com/compliance/supplier-codeGo to https://stobuildinggroup.com/compliance/supplier-code/.
Additionally, we include specific contractual commitments in our supplier contracts that no form of modern slavery is used anywhere in the supplier’s business or supply chain. Our suppliers agree to comply with all applicable laws and regulations, and we have the right to terminate contracts with suppliers that breach our terms and conditions.