Bribery & Corruption

ACS has a zero tolerance approach to bribery and regards anti-bribery as one of its highest priorities in its business dealings.

ACS requires its Suppliers to implement a zero-tolerance approach to bribery. Suppliers must ensure that their employees, agents, subcontractors and others working on their behalf worldwide prohibit the offering, promising, giving, requesting, accepting or receiving of any bribe, in whatever form.

ACS expects its Suppliers to adhere to local laws and not engage in any form of corrupt practices, including but not limited to extortion, fraud or bribery.

ACS mandates that its Suppliers will uphold all laws relevant to countering bribery in all the jurisdictions in which they operate. ACS expects its Suppliers to strictly adhere to the Bribery Act 2010 and the US Foreign Corrupt Practices Act 1977 as the most prominent acts in respect of conduct both in the UK and throughout the world, as well as ensuring compliance with all applicable local and national legislation.

Gifts and Entertainment

ACS expects its Suppliers to refrain from providing entertainment and gifts to gain improper advantage with customers or to facilitate approvals from government officials. ‘Facilitation payments’ to government officials, usually defined as small payments or gifts given in order to facilitate or expedite routine governmental action, are bribes. Suppliers must not offer, provide or offer to provide such payments or gifts.

Entertainment and gifts cannot be offered, provided or accepted by Suppliers unless consistent with customary business practices and they (a) are of a nominal value, (b) are not made in cash, (c) do not consist of travel or lodging, (d) are not susceptible of being construed as a bribe or kickback and (e) and are not in violation of any applicable laws. Any gift that could create an obligation to the donor or recipient, or influence the business relationship with the donor or recipient, should not be offered, provided or accepted. These principles apply to ACS Supplier transactions worldwide, even where the practice is considered ‘a way of doing business.’ Suppliers’ employees should not accept gifts or entertainment that may reasonably be deemed to affect their judgment or actions in the performance of their duties.

Information Security/Confidentiality

One of ACS’s key assets is its confidential information. All parties who work with ACS who have received or have access to confidential information are obligated to keep this information confidential. Confidential information may include business, marketing and service plans, financial information, engineering and manufacturing ideas, designs, databases, customer lists, pricing strategies, marketing materials, personnel data, customer or other individual data (e.g. names, addresses, telephone numbers), and similar information provided to ACS by its customers, Suppliers and partners. This information may be protected by patent, trademark, copyright and trade secret laws.

Data Protection

ACS expects and requires all Suppliers, Supplier subcontractors and third parties to comply with the ACS data protection and privacy policy available on the ACS website at which ACS reserves the right to amend from time to time. In order to comply with applicable data protection legislation, ACS requires all Suppliers to carefully review and comply with the data processing obligations set out at

Tax compliance

ACS expects its Suppliers to pay their taxes in accordance with all applicable laws and will not tolerate the facilitation of tax evasion. ACS requires its Suppliers to implement measures to prevent tax evasion and to ensure that their employees, agents, subcontractors and others working on their behalf worldwide do not engage in tax evasion or the facilitation of it.

Compliance with laws and sanctions

ACS expects all Suppliers to comply with all applicable laws and requirements (both the letter and the spirit of the law), including without limitation trade embargoes or sanctions on any organisations with whom the Supplier engages.


ACS is committed to free enterprise and fair competition. ACS business must be conducted solely on the basis of merit and open competition. ACS will hire Suppliers, agents or other intermediaries only by careful and fair assessment. ACS employees are legally bound to make business decisions in the best interests of ACS independently of any understanding or agreement with another Supplier. Suppliers shall not duly try to restrict competition or entice ACS employees to not act in ACS’s best interests.


ACS’s commitment to quality is core to its business. In order to achieve the highest quality standards Suppliers are expected to adhere to the high standards ACS expects and work constantly to improve structures and processes for the benefit of ACS’s customers.

Conflicts of Interest

ACS expects its Suppliers to be free from influences that conflict with ACS’s best interests, or that might interfere with the performance of their duties as Suppliers. Suppliers should have undivided loyalties in connection with their supply of services. Improper influences, or ‘Conflicts of Interests’, are prohibited.

Even the appearance of a conflict of interest can be damaging to ACS even where none actually exists, and therefore should be avoided wherever possible.


ACS is committed to openness in our dealings with customers, employees, Suppliers, business partners and other organisations and institutions.

Suppliers shall accurately record information regarding its business activities, labour, health and safety and environment and shall disclose such information without misrepresentation to all appropriate parties (if requested).

Legal Compliance

ACS’s success depends on each employee, agent, Supplier, subcontractor and any other party working on its behalf worldwide. Suppliers must understand the national and international governmental requirements. ACS will not tolerate disregard for any of these laws, and Suppliers are thus encouraged to seek guidance if certain activities seem suspicious.

Antitrust and Competition Law Compliance

Suppliers must strictly comply with all applicable anti-trust laws, trade practice laws and any other laws, rules and regulations dealing for example with monopolies, unfair competition, restraints on trade and competition, and relationships with competitors and customers. Suppliers will not enter into agreements with competitors or act in any way which may unfairly impact competition, including but not limited to, price fixing or market allocations.

Health and Safety

Occupational Health, Safety and Hazard Prevention

Suppliers shall comply with applicable occupational health and safety regulations and provide a work environment that is safe and conducive to good health, in order to preserve the health of employees and prevent accidents, injuries and work-related illnesses.

ACS expects that the occupational health and safety of employees is a priority for its Suppliers throughout all significant aspects of its activities and that Suppliers implement health and safety management and training.

Workplace Environment

ACS provides safe and healthy workplaces to its employees. ACS expects that its Suppliers strive to implement the same standards of occupational health and safety.

Business Continuity, Emergency Preparedness and Response

ACS has a business continuity plan in place to avoid any disruption in service to its clients in the event of a significant issue to premises or infrastructure. Suppliers shall be similarly prepared for any disruptions of its business (e.g., natural disasters, terrorism, software viruses, illness, pandemic, infectious diseases).

This preparedness includes disaster plans to protect both employees as well as the environment as far as possible from the effects of possible disasters that arise within the domain of operations.

Health and Safety Communication

Suppliers are expected to provide workers with appropriate workplace health and safety training and clearly communicate health and safety information in a language understood by the worker.

Labour and Human Rights

Compensation and Working Hours

Suppliers shall ensure that all workers receive at least the legally required minimum wages and benefits. Working hours must comply with national laws and if employees are required to work longer than the national average, then an opt-out scheme shall be offered that shall not affect an employee’s statutory employment rights. Suppliers shall offer vacation time, leave periods, and time off for legally recognised holidays.

Freedom of Association and Collective Bargaining

Suppliers shall freely allow employees to associate with others, form, and join organisations of their choice, and bargain collectively, without interference, discrimination, reprisal, or harassment. Suppliers are expected to ensure that in the absence of formal representation, workers have a mechanism to report grievances and that facilitates open communication between management and employees.

Human Rights

ACS requires Suppliers to uphold all internationally recognised human rights wherever their operations are located. Suppliers must adhere to all relevant government guidelines designed to ensure that products are not incorporated into weapons or other equipment used for the purposes of terrorism or abuse of human rights.

Antidiscrimination & Equal Opportunities

ACS does not discriminate or tolerate discrimination with respect to gender, race, religion, age, disability, sexual orientation, national origin or any other characteristic protected under relevant, applicable law.

Suppliers are expected to adhere to the same standards and not discriminate regarding hiring, compensation, access to training, promotion, termination or retirement on the basis of race, religion, disability, age, sexual orientation, gender or any other protected characteristic and Suppliers are expected to use their best endeavours to adhere to all local, jurisdictional and legal requirements to ensure equality. Suppliers are expected to offer equal employment opportunities and compensation without any discrimination.

Forced Labour

ACS requires that no forced, bonded, or involuntary prison labour may be used by any of its Suppliers or their subcontractors. Workers must not be required to lodge deposits or identity papers or travel documents as a condition of work and must be free to leave their employer upon reasonable notice.

Suppliers are expected to ensure that workers are issued contracts which clearly convey conditions of employment in a language understood by the workers. Suppliers must ensure that recruitment agencies used are compliant with the provisions of ACS’s Supplier Code of Ethics and applicable laws.

Young Workers Protection

Where the local law makes provision for young workers, ACS never uses underage labour. Suppliers are expected to adhere to these standards and only employ workers that are older than the applicable legal minimum age. The young workers must not perform work that exposes them to undue physical risks or requires them to work nights or overtime.

Student Workers Protection

As part of its corporate and social responsibility work, ACS develops partnerships with a select group of educational establishments who ask it to provide work experience or internships for their students. In these cases, ACS ensures that the educational establishment is reputable and shares its values in respect of complying with the law and treating its people fairly and with respect.

Suppliers are expected to adhere to these standards and where legitimate work placement or apprenticeship is provided, Suppliers shall ensure proper management of student workers and compliance with the local laws.

Child Labour

ACS regards the use of child labour as unacceptable and will not work with Suppliers who are discovered to use child labour in any of their facilities, or who is discovered to not have efficient systems in place to ensure that child labour cannot occur within their organisation or their supply chain.

Suppliers must adhere to the provisions of the relevant International Labour Organisations standards.

ACS reserves the right to cancel a relationship with Suppliers or other partners if it is discovered that child labour, or contravention of child labour laws, has been committed.

Slavery and Human Trafficking

ACS recognises its social responsibility as part of the community in all regions in which it operates. ACS specifically mandates compliance with applicable human rights legislation such as the Modern Slavery Act 2015 and rejects any form of slavery and human trafficking and would never knowingly conduct business with contractors or employees engaged in such practices. ACS expects its Suppliers to adhere to the same standards. Suppliers shall not traffic persons or use any form of slave labour and shall ensure that all subcontractors adhere to same strict standards.

Harassment and Abuse

Suppliers must ensure that any form of psychological, physical, sexual or verbal abuse, intimidation, promises in exchange for sexual favours, threat or harassment is not tolerated.


ACS is committed to reducing its environmental impact and expects its Suppliers to maximise their efforts in this regard. ACS expects that Suppliers comply with all applicable environmental laws, regulations and standards as well as implement an effective system to identify and eliminate potential hazards to the environment.

Suppliers must ensure that, as far as reasonably practicable, any detrimental effects from their activities, products and services upon the environment are minimised.

Non - Hazardous Waste Management

ACS expects its Suppliers to reduce or eliminate where possible waste of all types, including water and energy at the source or by practices such as materials substitution, conservation, recycling and re-using materials

Hazardous Waste Management

ACS expects its Suppliers to ensure that chemicals and other materials posing a hazard if released to the environment are identified and managed to ensure their safe handling, movement, storage, recycling or reuse and disposal.

Climate Protection

ACS expects its Suppliers to strive to support ACS’s climate protection goals through the products and services they deliver (e.g. by providing relevant data on carbon footprint and climate protection). ACS also expects its Suppliers to take climate protection appropriately into account in their own operations, for example by setting climate protection goals for themselves and achieving them.

Violations of the Code of Ethics

The provisions of this Code are essential for the business relationship between ACS and its Suppliers. Therefore, if Suppliers do not comply with this Code, ACS reserves the right to terminate the business relationship with these Suppliers subject to applicable laws.

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