Working with suppliers

We are committed to the fair treatment of the businesses who supply goods and services to HSBC – and expect them to operate responsibly, in line with our values. Read more about the principles we apply and our supplier code of conduct.

HSBC is fully committed to the effective management and control of our supply chain and how we conduct business with our third party suppliers – whether we are meeting our legal and commercial obligations responsibly in our supplier dealings, as well as treating our suppliers fairly in our behaviours and actions.

The following five principles set out HSBC’s commitments to how our employees should act when managing supplier relationships, aligning to our values that define who we are as an organisation and what makes us distinctive. These principles are shared with all new sourcing engagements through surveys and our performance against these principles is assessed regularly through direct feedback from the supplier relationships that we manage, to ensure we deliver on this commitment.

Supplier Management Conduct Principles

  1. HSBC will treat suppliers in a fair and consistent way
  2. HSBC will communicate to suppliers in a knowledgeable, clear and transparent way
  3. HSBC will always behave in a professional way when dealing with our suppliers
  4. HSBC will listen and act quickly on incidents of poor conduct by HSBC employees when interacting with suppliers
  5. HSBC will hold our supply chain to the same high standards that it demonstrates

In addition to the above principles HSBC also asks our employees to act in line with internal Group conduct, value and behaviour standards.

We also expect businesses who supply goods and services to HSBC to operate responsibly and our supplier code sets out the standards we require.

Supplier Due Diligence

As part of the HSBC sourcing process, all potential suppliers will be subject to due diligence and in order to comply with data protection laws we are required to notify our intentions regarding the use of your data. The Data Privacy Notice further down this page sets out how we will use the information you provide, or which we collect, in connection with any sourcing activity and any subsequent agreement(s) with us.

Ethical and Environmental Code of Conduct for Suppliers of Goods and Services

HSBC is one of the largest banking and financial services organisations in the world. HSBC has a responsibility to ensure its supply chain operates responsibly and improves the lives of workers, their communities and the environment. HSBC is committed to making a positive contribution to human rights. We are guided by the International Bill of Human Rights, the UN Universal Declaration of Human Rights and the principles set out in the International Labour Organization’s Declaration on Fundamental Principles and Rights at Work. HSBC is a signatory or has publicly expressed support for to the UN Global Compact, the OECD Guidelines for Multinational Enterprises, the Global Sullivan Principles, the UN Principles for Responsible Investment and the UN Principles for Sustainable Insurance.

HSBC will periodically review this Code and make revisions when needed, which we will expect suppliers to adopt.

Scope

All HSBC suppliers must comply with the HSBC Ethical and Environmental Code of Conduct for Suppliers of Goods and Services. This includes suppliers that are:

  • Providing services to or on behalf of HSBC
  • Third parties sub-contracted by a supplier

Policy

HSBC has developed this Code for all suppliers and any third parties sub-contracted by suppliers. It is applicable to all suppliers appointed by any HSBC Function, Business or individual working on behalf of HSBC. Any supplier that has any commercial dealings with HSBC, and any of their subcontractors, must state compliance with this Code.

At all times, our goal is to work collaboratively with our supply chain partners on sustainability. In those cases where a supplier or one of its subcontractors is found to not be in compliance with this Code, HSBC will work with the supplier on an improvement plan. If the supplier continues to be not in compliance with this Code, HSBC will take steps to review the terms of the contract, including reduction in the order and exiting of the relationship.

This Code of Conduct is made up of four sections. Sections 1 and 2 outline standards for Economic, Environmental and Social, respectively. Sections 3 and 4 outline the requirements of having a reasonable governance and management structure to ensure compliance with this Code.

Requirements

Economic

Economic sustainability focuses upon bringing economic benefit to the workers, investors and communities in which a company operates. From an ethical perspective, commercial transactions should be economically beneficial to all parties involved and relationships should be based on the principle of fair and honest dealings, whilst promoting fair and sustainable development:

  1. Suppliers must embed basic business principles in a Code of Business Standards or a similar policy, including such items as adherence to local laws and regulations
  2. Suppliers must ensure that policies are in place to stop fraud, money laundering, bribery and corruption and refrain from offering gifts and entertainment to HSBC employees
  3. All suppliers must comply with national and international sanctions policy and legislation
  4. Suppliers must have reasonable and lawful payment policies with their own suppliers and subcontractors
  5. Suppliers must consider the principles of the Circular Economy, Whole Life Costing and Life Cycle Analysis in design, manufacture and recycling/disposal

Environmental

Recognising that sustainable businesses should acknowledge the planet’s finite resources, HSBC expects its suppliers to support sound environmental management principles and reduce their impact on the environment within which they operate. In addition, HSBC’s suppliers are expected to support the development of sustainable technologies:

  1. Suppliers must have a written environmental/sustainability policy appropriate to the size and nature of the supplier’s operations that, where applicable, addresses preventing, mitigating and controlling serious environmental and health impacts from operations including raw material usage, greenhouse gas emissions, water, waste, air quality and biodiversity
  2. Suppliers must have an effective internal environmental management programme/system with adequately trained staff responsible for managing the organisations environmental performance and communicate data on key environmental indicators internally and externally
  3. Suppliers must abide by all legislation and regulations related to the protection of the environment and the handling of dangerous and hazardous materials
  4. Suppliers must keep dangerous and/or hazardous materials to a minimum and keep records for all hazardous materials that are necessary
  5. Suppliers must ensure that every manufacturing facility complies with environmental laws, including all laws related to waste disposal, air emissions, discharges, toxic substances and hazardous waste disposal
  6. Suppliers must validate that all input materials and components were obtained from permissible harvests consistent with international treaties and protocols in addition to local laws and regulations

Social

The UN Guiding Principles on Business and Human Rights, state that all private enterprises hold an equal responsibility to respect human rights. HSBC is committed to improving human rights. HSBC expects suppliers to respect the human rights of their employees and to comply with all relevant legislation, regulations and directives in the countries and communities in which they operate:


Labour

  1. Suppliers must prohibit the use of all types of slavery and forced and bonded labour and give workers, whether local or migrant, the right and the ability to leave employment when they choose
  2. Suppliers must ensure that child and underage labour is not used and that the employment of young workers adheres to International Labour Organization standards, the OECD Guidelines for Multinational Enterprises and local regulations
  3. Suppliers must ensure that wages meet legally mandated minimums and industry standards without unauthorised deductions
  4. Suppliers must ensure that working hours are in accordance with local regulation and industry practice and voluntary overtime is at manageable levels
  5. Suppliers must not discriminate against any group on religious, social, gender identity, sexual orientation or ethnic grounds or any protected classes covered under international human rights standards and such other ground as may be recognized under national law
  6. Suppliers must not hinder the right of workers to legally organise and join associations such as labour unions
  7. Suppliers must provide clear and uniformly applied disciplinary practices and grievance procedures that include provisions prohibiting mental, physical or verbal abuse

Health and safety

  1. Suppliers must provide a safe work environment, abiding by local laws and regulations;
  2. Suppliers must ensure health and safety is effectively managed, so that health and safety risks, issues, incidents and non-compliance are identified and addressed in order to provide adequate facilities to ensure the health and well-being of its workforce

Ethics

  1. Suppliers must support fair-trade and ethical sourcing practices relevant to the commodity or service provided
  2. Suppliers must respect the human rights of the people and communities in which they operate and should strive to improve the lives of the people and communities in which they operate
  3. Suppliers must not engage in or support trafficking in human beings
  4. Suppliers must provide evidence that they have implemented due diligence procedures to manage ethical issues within their supply chain, including all labour-related processes to ensure they comply with laws on slavery and human trafficking
  5. In addition to the requirements of the UK Equality Act 2010, HSBC’s general principles are that suppliers and their supply chain, contractors and service providers must ensure that they have robust procedures to ensure that they provide disability accessible products, services and opportunities. Suppliers should:

  • commit to removing employment barriers for disabled people
  • provide products and services that are accessible to disabled people
  • review their products and services with the involvement of disabled people
  • promote their commitment to disability issues externally

Management System

Suppliers with whom HSBC has regular and recurring dealings should have good management and governance processes in place to ensure compliance with this Code. Furthermore, suppliers must make reasonable efforts to monitor their supply chain, ensuring their suppliers are aware of, and compliant with, the aims of the Code. Suppliers must ensure that their systems and procedures are sufficient to mitigate any potential negative impact on HSBC’s brand and reputation.

HSBC reserves the right to randomly review the supplier’s policies, procedures or any other document related to adherence to this Code. In some cases, HSBC may require an on-line or on-site audit of a supplier’s adherence to this Code.

HSBC is working with Sedex to ensure that the principles set out within this Code are applied and require all suppliers, when requested, to register with Sedex and complete the supplier appraisal questionnaire. If suppliers are assessed as medium or high risks, HSBC may audit the supplier using third party auditors and the Sedex Members Ethical Trade Audit (SMETA) methodology.

Compliance

HSBC requires suppliers to sign this code, thereby acknowledging the requirements contained within. HSBC requires suppliers to agree to adhere to these requirements and to be able to demonstrate to HSBC how these requirements are being met.

HSBC operates a policy of transparency with suppliers and will work collectively with suppliers ensure adherence to the Code and develop improvement programmes if required.

Collection, processing and sharing of your information

This privacy notice explains how we (‘we’ or ‘us’ is the HSBC Group of companies) will use the information you provide, or which we collect, in connection with any sourcing activity and any subsequent agreement(s) with us. Failure by you to supply such information may result in us being unable to enter into a commercial relationship and/or agreement(s) with you.

By participating in any sourcing activities or entering in to any agreements with us, you agree that we may use your information in accordance with this notice. The data user in relation to your information is the HSBC Group Member who may enter into a services agreement with you.

The information that we collect from you may include information relating to an employee, director or any other person who exercises control over an entity (“Controlling Person”) who enters into a services agreement with us. For a trust, a Controlling Person may include a settlor, a trustee, a protector, beneficiaries and classes of beneficiaries. We may also collect information relating to individuals connected with a director, an entity or a Controlling Person, such as any guarantor, a director or officer of a company, partners or members of a partnership, or beneficial owner, trustee, settlor or protector of a trust, account holder of a designated account, payee of a designated payment, your representative, agent or nominee, or any other persons or entities with whom you have a relationship that is relevant to your relationship with the HSBC Group (“Connected Person”). Prior to providing information to us relating to a Controlling Person, a Connected Person or any other person, you shall ensure that they have consented to us processing their information as set out in this notice.

We may collect, use and share the information you provide to us, subject to local data privacy laws, for reasons connected to our business and relationship with you, including to:

  1. approve, manage, administer or effect the services agreement between us
  2. meet the compliance obligations of the HSBC Group
  3. conduct financial crime (which includes money laundering, terrorist financing, bribery, corruption, tax evasion, fraud, evasion of economic or trade sanctions, and any act or attempt to circumvent or violate any law relating to these matters) risk management activity (which will include making further enquiries as to the status of a person or entity, whether they are subject to a sanctions regime, or confirming their identity and status)
  4. if applicable, collect any amounts due and outstanding from you
  5. conduct credit checks and obtaining or providing credit references (where you are a potential tenant of the HSBC Group)
  6. enforce or defend our rights
  7. verify your identity.

In carrying out these purposes we may transfer and disclose your (or any Controlling Party (’s) or Connected Person (’s)) information to:

  1. any member of the HSBC Group
  2. any sub-contractors, agents, advisers or service providers of the HSBC Group (including their employees, directors and officers)
  3. any regulatory authorities of the HSBC Group
  4. credit reference agencies and other companies for use in credit decisions, fraud prevention and to pursue debtors
  5. any third party in connection with a transfer, disposal, merger or acquisition of business by us or any member of the HSBC Group wherever located, including in jurisdictions which do not have data protection laws providing the same level of protection as the jurisdiction in which you are based. Your information will be protected by appropriate security and technical measures to keep your information secure. Such information may be transferred to a place outside the country of your residence.

Accessing your information

In certain jurisdictions, data privacy laws may allow you to make a written request for a copy of the personal data we hold about you and to ask us to rectify, erase or block any inaccurate data. You should make a request to your usual HSBC contact who will be able to direct your query. Depending on your jurisdiction there may be a small fee charged for providing this information to you.

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