FP NEWSPAPERS INC. SUPPLIER CODE OF CONDUCT
APPLICATION
This Supplier Code of Conduct applies to FP Newspapers Inc., FP Canadian Newspapers Limited Partnership (collectively, “FP”).
It applies equally to all suppliers, directors, officers and employees of every entity within FP. Suppliers are responsible for knowing and adhering to the contents of this policy and applying its principles in its supply of goods and services to our day-to-day activities.
All suppliers are required to undergo a detailed risk analysis prior to our entering into a supply contract with them.
PRINCIPLES OF SUPPLIER CONDUCT
The company is committed to sourcing responsibly and considers all activities in its supply chains that lead to human rights abuses as unacceptable. We require that our suppliers accept the performance standards contained in our Supplier Code of Conduct (the “Supplier Code”), with the expectation that the supplier will comply with the requirements of the Supplier Code through its own operations and within its supply chains.
Our Procurement Policy requires that all supplier contracts include the Supplier Code. The Supplier Code seeks to ensure suppliers respect our requirements and laws related to ethics, labour and human rights, the responsible sourcing of minerals, health and safety, data privacy and security, and the environment. This includes competition and anti-trust laws, and laws prohibiting corrupt practices. The Supplier Code helps reduce risks to our operations in the areas of business continuity and financial stability.
The Supplier Code includes the requirement that suppliers not use forced or child labour, provide working hours and wages that meet local statutory requirements, that their workplace be free of sexual harassment and abuse, corporal punishment and unlawful discrimination and that they respect and uphold workers’ rights to freely join labour unions.
Under the Supplier Code, we may conduct onsite reviews of selected supplier facilities that provide us with products or services. Onsite reviews may include examination of relevant supplier records, policies and work practices, as well as an inspection of supplier facilities for compliance with the Supplier Code.
CONFIDENTIALITY AND PRIVACY
Many Suppliers have FP business related information which can be either financial or competitive information. This information is both sensitive and confidential, and in some cases, subject to protection by privacy law. Release of such information is potentially harmful to FP, its employees, and customers. In some cases, it is illegal. Suppliers must use extreme care and discretion when dealing with confidential or sensitive information. Such information must not be shared or released to anyone outside of FP who is not authorized or legally entitled to receive it and must not be used or disclosed for any reason except for adherence to statutory law.
GIFTS, BENEFITS AND ANTI-BRIBARY
Receiving and giving gifts and benefits in a business context is a sensitive area that requires the exercise of good judgment and common sense. Suppliers who wish to do business with FP should not provide gifts or benefits to FP employees, directors, or officers, if such gifts might be perceived as a bribe or appear to influence business decisions. The same principle applies to giving gifts or benefits on behalf of FP and to gifts given to, or received by, employees’ family members and spouses.
Generally, gifts or other benefits may be given and accepted by employees if they:
- are consistent with local business practice and custom,
- are not excessive in value,
- do not violate applicable laws and ethical standards, and
- are able to withstand public scrutiny.
It is prohibited to receive or give a gift in cash or cash equivalent.
COMPLIANCE WITH THIS POLICY
It is critical to FP’s success that we conduct ourselves ethically and legally in every aspect of our business activities. Every supplier is required to comply with this Supplier Code.
In the case of an observed non-compliance with the Supplier Code, we require that the supplier take all reasonable measures to diligently correct the non-compliance. A supplier’s failure to meet this requirement can result in FP taking appropriate further action, including the cancellation of our supply contract with them.
Adopted by resolution of the Board of Directors effective April 17, 2024.