Group Procurement Policy

Transcription

1 Our commitment to good business Enhancing customer experiences and business partnerships 4 Version 1 July 2014

2 Our Business Principles 1 Demonstrating integrity in corporate conduct 2 Ensuring openness and transparency 3 Respecting human rights 4 Enhancing customer experiences and business partnerships 5 Valuing our people 6 Focusing on health, safety and security 7 Protecting the environment 8 Investing in communities Our commitment to good business Your commitment Introduction Responsibilities Engaging with suppliers Actions / 16

3 Our commitment to good business Business Principles and Group Policies Our purpose is helping people today and securing energy for tomorrow. Our Business Principles and Group Policies are the foundation for how we operate to achieve this purpose. More than a tick box for compliance, how we conduct business defines us in the eyes of our people, our customers and our wider stakeholders. We are committed to ethical and responsible practice, as one business, with one set of Business Principles and Group Policies. Together, our eight Business Principles, which set out the operating standards we expect, and our Group Policies, which support these Business Principles, are our commitment to good business. The standards our people expect of themselves and one another are very high, and reflect the nature of our business, and our place within it. Our Business Principles and Group Policies are here to help us make the right decisions and provide guidance when needed. Your commitment We remain a principled business as a direct result of every single employee conducting themselves with integrity. Every decision you make impacts those around you. You also need to know that you can rely on responsible and ethical decisions made by others. You, along with everyone else involved in Centrica s business and operations, have a personal responsibility to adhere to these principles and policies and to conduct business legally, responsibly and ethically. You must be confident about those decisions. Adhering to these principles and policies will give you that confidence. Your commitment regarding this policy In doing so, you will uphold our Business Principle of Enhancing customer experiences and business partnerships. You have a responsibility, wherever you work in the world, for operating our activities responsibly and with integrity, treating customers, partners and suppliers fairly and professionally. 03 / 16

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5 Introduction Each year we spend billions of pounds purchasing goods and services that help our business activities run smoothly, ensuring that we deliver on our commitments and add value to the organisation. It is important that we conduct our procurement in line with the Business Principle of Enhancing customer experiences and business partnerships. Wherever you work in the world, you are responsible for operating our activities responsibly and with integrity, and treating customers, partners and suppliers fairly and professionally. When you engage with other people in the course of your role, you will manage the health, safety, social, environmental and ethical impact of your activities in the relevant market. Scope This policy applies to you as an employee, and also to consultants, contractors and third parties involved in procurement on behalf of Centrica. You should also view the policy documents and guidance listed on page 15, particularly Procurement standards. 05 / 16

6 Purpose The policy explains your responsibilities during the course of your involvement in procurement activities, enabling you to observe and uphold our Business Principles. Policy Complying with this policy will enable you to maintain proper standards of fairness and integrity in business relationships with your colleagues and all suppliers. This policy should be viewed in conjunction with the Group Anti-Bribery and Corruption Policy. If you make a request for improper payment, or we see that you might be making corrupt payments or intend, or plan, to violate Anti-Bribery Laws, we will report you to the relevant authorities in addition to any internal disciplinary action. 06 / 16

7 Responsibilities As an employee you are responsible for undertaking the procurement process and enhancing customer experiences and business partnerships. You should always deliver excellent service and ensure you understand customer needs, resolve queries satisfactorily, demonstrate fairness and integrity, comply with relevant laws and regulations, keep customer information confidential and secure, and be responsible for procurement best practice. To do this, you will: engage with your business unit Procurement team as early as possible when a requirement is identified only authorise or sign contracts and purchase orders up to the approval limit assigned in the Delegation of Authority relevant to the purchase not delegate your payment authority to anyone with a lower limit than you not combine financial authorities, i.e. you and another manager with an approval limit of 500,000 cannot combine your limits to approve an order of 1,000,000 not divide purchase orders, e.g. you will not split a known commitment for 100,000 into three smaller purchase orders to avoid referral to a higher level of approver. 07 / 16

8 Responsibilities Procurement teams As part of Procurement you will develop and implement the sourcing approach, working collaboratively with the business in line with operating standards and our principles. You will develop category plans for key areas of expenditure and designated categories and market-test third-party solutions, and understand business requirements regularly in line with the business needs. Category planning should be approached as follows: 1 key understanding of the business need both today and in the future 2 understanding of external market dynamics and potential providers 3 development of strategy to meet business needs. You will collaborate with the business to identify and manage suppliers who are to come under the supplier relationship management process, and help manage the contractual aspects of the business relationship. Where it has been agreed that a tender process will not be used, you will develop and implement the procurement strategy. You must ensure that all electronic copies of submitted contractual documents are retained on the contracts database, and assess our commitments and obligations in our third-party contracts against clear criteria. You will approve categories of spend on approval of issue of each purchasing card. When any purchase is likely to: have a total lifetime cost above 250,000 have a potential requirement that could be business critical or involves TUPE involve the use of Personal Data, as defined under the Data Protection Act, irrespective of value. You must involve Procurement at the start. You should follow the relevant defined business unit strategic sourcing and contract methods for any purchase, using our purchasing systems. The Procurement teams in your business unit will be able to assist you with this. 08 / 16

9 Responsibilities Purchasing on behalf of Centrica You must follow purchasing best practice for your business unit whenever possible and not approve expenditure through any purchasing channel where it may be considered a personal interest exists. You should manage all spend over 1,000 through the purchase order process unless otherwise agreed with Procurement and only request the purchase of goods and services using the one-off payment request process with agreement from Accounts Payable. 09 / 16

10 Responsibilities Use of purchasing cards You can only use a purchasing card to buy goods and services on behalf of the company below a maximum single transaction value, as agreed when issue was approved. The monthly cumulative limit will be agreed then too. You must not use a purchasing card for goods and services where separate ordering arrangements with preferred suppliers exist, such as stationery, travel or IT, or if that supplier already exists on Centrica s purchasing system. Purchasing cards must not be used for paying any contractors or third parties providing services on customer job-related activities, because there are taxation implications. 10 / 16

11 Engaging with suppliers You will treat our suppliers, as well as other business partners such as contractors and venture partners, with fairness, and encourage them to respect our Business Principles. However, you should negotiate effectively to gain competitive benefits, improved quality and service, security of supply and regulatory compliance on purchases, and not discriminate when selecting suppliers. Sourcing decisions should be decided on consistent criteria across all suppliers. Always place our business with the best value supplier; making total acquisition cost along with the ability to meet our legal, regulatory and HSE requirements the main considerations. You should purchase goods and services on behalf of Centrica from preferred suppliers and involve Procurement in their selection when the goods or services have a total value of more than 250,000 or are considered to be business critical, irrespective of value. Appoint preferred suppliers when it is beneficial and where a preferred supplier list exists, and ensure Procurement approves new suppliers before you commit any spend on them. You should only request a new supplier when a current preferred supplier is unwilling or unable to meet the requirement. You must make sure a non-disclosure agreement (NDA) is signed before exchanging any confidential information and disclose any potential conflicts of interest to Procurement and your line manager before sourcing or market testing occurs. You will also: use a competitive process with at least three suppliers for commitments with an anticipated lifetime cost above 100,000. You must agree any deviation from this with your lead Procurement contact in the corresponding business unit in advance develop evaluation criteria to support the supplier selection process before supplier proposals are received and agree this with Procurement make all suppliers aware they are bound by Centrica s approved Terms and Conditions of Purchase manage the daily supplier relationship unless agreed otherwise with Procurement ensure suppliers agree to meet Centrica s guidelines on Corporate Responsibility etc. and other relevant regulations ensure purchase order approval before spend is committed to suppliers. 11 / 16

12 Engaging with suppliers Supply chain risk It is important that Centrica sets high ethical standards when dealing with suppliers, particularly where they operate in high-risk industries or high-risk countries. High-risk and strategic suppliers should be formally assessed before formalising a contractual arrangement, based on: financial stability anti-bribery and corruption compliance corporate responsibility HSE. Where appropriate, a site audit to the supplier may be required to ensure compliance with Centrica standards. The Supply Chain Risk Manager will provide guidance and standards to identify the relevant risk criteria under which suppliers should be assessed. 12 / 16

13 Engaging with suppliers Making contractual commitments Use Group contracts where they exist, and when they are appropriate, and follow contract management best practice for your business unit. You should transact all business on Centrica s approved Terms and Conditions of Purchase and contract precedents, unless agreed with Procurement and Legal. This is to protect Centrica s interests and minimise our exposure to risk from unnecessary or unauthorised commitments. Before you enter any commitment, whatever the value, on the basis of the supplier s Terms and Conditions, you must seek Procurement s approval. You must also forward the original executed version of all contracts to Procurement to file. Minimise the use of letters of intent and only use them once the business unit s senior Procurement and Legal contacts have approved them. You must not allow contractors to sign any contracts or authorise purchase orders. 13 / 16

14 Actions what happens next If you have any concerns about a supplier, or that this policy is not being followed, speak to your relevant Procurement contact or Head of Procurement, either in your business unit or at Group level. Alternatively, call the Speak Up helpline. Training and communications As a manager or employee you may receive relevant training on how to put this policy in place within the scope of your role or place of business. Monitoring and reporting We monitor supplier corporate responsibility risk, financial risk and bribery and corruption risk. This is reported to the Centrica Risk Committee. Internal controls and audit Centrica maintains and retains accurate records, which properly and fairly document all relevant transactions and activities. All aspects of the business are subject to regular audits of internal control systems on a risk-based approach and provide assurance that applicable systems and controls are effective in meeting our procurement needs. 14 / 16

15 Actions what happens next Related policies and documents Group Anti-Bribery and Corruption Policy Group Anti-Fraud Policy Group Delegation of Authority and Decision Making Policy Group Environment Policy Group Gifts and Hospitality Policy Group Handling of Confidential and Price Sensitive Information Policy Group Information Security Policy Group Responsible Procurement and Supplier Management Policy Centrica Business Principles Centrica Group UK Business expenses policy and guide Centrica Procurement Principles Centrica UK Group Data Protection Policy Contract Management Best Practice Guidelines Contract Management Guidelines Procurement and Corporate Responsibility Policy for Suppliers The Rough Undertakings and Code of Conduct 15 / 16

16 Version 1 July 2014 David Wylie David.Wylie@centrica.com 16 / 16