SUMMARY OF GROUP PROCUREMENT POLICY
Aim of policy
All our purchasing activities aim to achieve the best possible value at the lowest possible cost, whilst adhering to the Group’s Policy on Standards of Business Conduct and in accordance with the Trinity Mirror standard terms and conditions. We aim work with our suppliers to make it easier for them to meet our requirements, and to encourage them to invest in improving their product, prices, quality and service.
Key policy statements
Value: Value includes not only the initial purchase price, but also recurring costs over the lifetime of the goods or services, such as financing, maintenance, energy and so on. Value also includes the quality and reliability of the goods or services and the timeliness and reliability of their delivery.
E-procurement: The Group should use e-procurement where possible.
Legality: Our activities must fully respect all applicable UK and European laws and regulations, including taxation law.
Corporate Responsibility: Whilst any supplier that can be of service to us should have a fair opportunity to secure our business, we will avoid using companies that exploit child or sweated labour, that disregard basic health and safety provision, that `pirate` the intellectual property of others, or that wilfully and avoidably damage the environment. Wherever possible, we should use our purchasing power to promote environmental sustainability in the supply chain. We are committed to ensuring that there is no slavery or human trafficking within our supply chains or in any part of our business. We expect our suppliers to adhere to the requirements of the Modern Slavery Act 2015, and we will undertake all reasonable and practical steps to ensure that these standards are implemented within our supply chain.
Code of Conduct for Purchasing: We insist on ethical standards from our suppliers, and in turn we must exhibit the highest ethical standards ourselves. Trinity Mirror prohibits the offering, giving, solicitation or acceptance of any bribe, whether cash or another form of inducement. Trinity Mirror prohibits the making of any payments for securing or accelerating routine processes and procedures (“Facilitation Payments”). The prevention, detection and reporting of bribery is the responsibility of all employees throughout Trinity Mirror plc and any instance of bribery or suspected bribery should be reported in accordance with the Group’s Whistle Blowing policy.
Contras and Bartering: This can be a complex area so please refer to the Policy before entering into such arrangements.
Anti-Competitive Behaviour: This is likely to be in breach of the Competition Act and could well be a criminal offence. Any suspicions should be reported (with any supporting evidence) to the Group Services Director, who sits within Central Services.
Conflicts of Interest: These can sometimes arise e.g. spouses or other relatives may be employed by the supplier company; personal friendships may grow up over time. Such potential conflicts should be reported to your line manager as soon as they are identified.
Whistleblowers: It is our policy to support, protect and, where possible, preserve the anonymity of any employees who report apparently questionable activity, even if their fears subsequently prove unfounded. See the Group’s Whistle Blowing policy.
Structure and Authority: This is clearly defined. Refer to the Policy for details and refer to the Group Services Director for general guidance, review and comment in all areas of procurement.
Authority Levels: These are clearly defined in the table of authorities and each individual has been notified in writing of their authority level. It is never permissible to split a contract in order to circumvent authority limits.
Ordering and Approval: The general rule is that written Purchase requests and orders should be raised for all transactions and the Trinity Mirror standard terms and conditions should be used in all circumstances. For exceptions, refer to the Policy.
Payments: Payments to suppliers will be made by our Shared Service Centre in conjunction with the Treasury department, and it is the Group’s policy to pay suppliers in accordance with our standard terms and conditions. For details and exceptions, refer to the Policy.
Foreign Currency and Overseas Suppliers: Purchases should be made in British Pounds where possible to ensure the Group is not exposed to foreign exchange risk. However, where the Group is likely to commit to a purchase in a foreign currency, limits apply and VAT considerations could be complex. Therefore Group Treasury & Tax advice could be required prior to any commitment being incurred. For details, refer to the Policy.
Approval of Suppliers: Orders should only be placed with approved suppliers who are included on the suppliers’ ledgers in our Shared Service Centre. Regarding suppliers who are not on the approved lists, refer to the Policy for details.
Contracts: All significant commercial contracts, addendums to contracts and letters of agreement should be reviewed by the Group Legal Department or Company Secretariat before they are agreed and signed, with as much time as possible given for their review. For further details, refer to the Policy.
Leases: All finance leases, such as those for photocopiers or vending machines, should be reviewed prior to renewal and agreed with the user department and the Group Treasurer. For further details refer to the policy.
Capital expenditure: there are clearly defined procedures covering submissions on standard capex approval forms, justifications, authorisations for different types of capex and approvals required for different levels of expenditure. For further details, refer to the Policy.
Intellectual Property and Commercial Information: The Group’s intellectual property, designs, patents, trademarks and know-how are valuable to us. This information must never be passed to a supplier, for whatever reason, without approval. Ownership rights of intellectual property must be considered where suppliers work on design and development on our behalf, or we are buying from a supplier something which we, or our customers, are likely to need to reproduce or copy at a later date. For further details, refer to the Policy.
Key information and reporting points
Good intelligence work is vital to effective purchasing. Therefore the following should be reported:
Failure by a supplier to meet our requirements, requests to vary the terms of a contract after it has been agreed, prices from a preferred supplier appearing to be less favourable than available elsewhere, issues regarding warranties, guarantees and service agreements and new sources of supply, products and services must be reported to your local Finance Director, or local or Group functional head and escalated as appropriate.
Any actual or potential unethical approach or inducement, evidence of restrictive practices or possible conflicts of interest or information on illegal or unacceptable practices by a supplier which could be to our discredit if we were known to be a customer must be escalated immediately to the Group Company Secretary.