Supplier Code of Conduct
What is OPG’s Supplier Code of Conduct (OPG-STD-0141)?
OPG’s Supplier Code of Conduct (Supplier Code) sets out the standard of business behaviour expected of OPG’s suppliers. We expect suppliers to act with honesty and integrity, be guided by our ethical values, and comply with both the spirit and intent of the Supplier Code.
The Supplier Code is comprised of three sections: Introduction, Values and Standards of Business Conduct. The Supplier Code also outlines OPG’s expectations regarding code compliance, reporting, declaration of conflicts of interest, and rules around gift giving and entertainment.
Where does the Supplier Code obtain its authority from?
The Supplier Code and Code of Business Conduct are OPG standards that take their authority from the Code of Business Conduct Policy.
The Code of Business Conduct Policy states OPG’s commitment to being an ethical company and outlines requirements and accountabilities. The Policy is reviewed annually and was approved by the OPG Board of Directors in March 2017.
Why have a Supplier Code?
Ethical business conduct by employees, suppliers, consultants, contractors, and business partners is a critical component of our operations. The aim of Supplier Code is to hold our suppliers to the same high standards that we expect of our employees, and to ensure that suppliers conducting business with OPG conduct their business in a manner that aligns with our values and corporate governance.
Who does OPG’s Supplier Code apply to?
The Supplier Code applies to OPG suppliers, including their owners, employees, agents, partners and sub-contractors who provide goods and/or services to OPG.
What is the difference between the Supplier Code and OPG’s Code of Business Conduct?
Safety, Integrity, Excellence, People & Citizenship: These are Ontario Power Generation’s ethical values, and are the fundamental truths about OPG that don’t change. They clarify what is important in our organization, guide our behaviour and decision-making, and point the way to business conduct that results in successful individuals and a successful company. OPG’s ethical values inform the standards of business behaviour that we expect of our employees and of our suppliers. The business conduct expected of suppliers is found in the Supplier Code and the business conduct expected of our employees is contained in the Code of Business Conduct.
When did the Supplier Code become effective?
In November 2015, the Supplier Code was approved by the OPG Board of Directors and it became effective Jan. 1, 2016. The Supplier Code was amended by the Board in March 2017 to provide further clarity to suppliers on the disclosure of conflicts of interest, approval requirements for disclosing sensitive information and procurement practices.
How often will the Supplier Code be reviewed?
The Supplier Code will be reviewed at a minimum every three years.
To become an OPG supplier does the supplier have to comply with the Supplier Code?
How is OPG informing suppliers about the Supplier Code?
Prior to Jan. 1, 2016, suppliers with active contracts were notified through an email communication from the Chief Supply Officer introducing the Supplier Code. The Supplier Code and related information are also available on this website.
New contracts issued after Dec. 31, 2015 will incorporate the obligation to comply with the Supplier Code as part of the contract Terms & Conditions.
What do ARIBA-enabled suppliers need to do?
ARIBA-enabled suppliers with existing contracts with OPG will be prompted by the system for acknowledgement of compliance with the Supplier Code.
What happens if a supplier fails to comply with the Supplier Code?
A failure to comply with the Supplier Code may result in suspension or termination, in whole or in part, of the supplier’s agreement(s) with OPG and may include removal of the supplier from OPG’s vendor list.
What is a conflict of interest and where can I obtain more information?
OPG’s Supplier Code states that suppliers must not try to gain improper advantage or improperly impact an OPG employee’s ability to make sound, impartial, and objective decisions on behalf of OPG. Suppliers must disclose in writing to the OPG contract owner and/or Chief Ethics Officer any situation that appears to conflict, or could potentially conflict, in any way, with the interests of OPG. This includes situations where an OPG employee has an interest in, or non-arm’s length relationship, to the supplier’s business.
It is mandatory for suppliers to declare to the manager of their OPG contract owner and the Chief Ethics Officer any actual, perceived or potential conflict of interest in writing. the Supplier’s Declaration of Conflict of Interest or Potential/Perceived Conflict of Interest form to make a declaration.
What are the rules regarding gifts and entertainment?
Suppliers must never offer, ask for, give or receive any gift, gratuity, entertainment, hospitality, or benefit that may compromise or appear to compromise an OPG employee’s ability to make business decisions in the best interest of OPG. If a supplier is unsure whether a gift or entertainment offer complies with the Supplier Code and/or the Code of Business Conduct, the supplier should consult with the intended recipient’s manager. OPG expects suppliers to maintain appropriate records of any gifts or entertainment offered or provided to OPG employees.
Do suppliers have to protect OPG sensitive information even after their contract has expired?
Suppliers must not disclose OPG sensitive information, except as required by law, to anyone outside OPG, without prior approval. Suppliers must not use OPG sensitive information for any improper purpose. This applies even after the supplier’s contract is complete.
Where can I obtain more information about the Supplier Code?
For current suppliers and potential suppliers:
For suppliers with existing OPG contracts contact your:
- OPG contract owner counterpart; or
- Supply Chain commercial contact (i.e., purchasing agent/buyer)
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Where can I report a violation or suspected violation of the Supplier Code or the Code of Business Conduct?
Suppliers who violate the Supplier Code or the Code of Business Conduct, or who are aware of conduct by others that violates or appears to violate the Supplier Code or the Code of Business Conduct must report it to the OPG Ethics Office (email@example.com).
Employees who violate the Code of Business Conduct or who are aware of conduct by others that violates or appears to violate the Supplier Code or the Code of Business Conduct must report it to:
- Their supervisor/manager; or
- Their HR Business Partner; or
- The OPG Ethics Office (firstname.lastname@example.org).
To report concerns related to financial accounting, auditing, suspected fraudulent activities, bribery or corruption, individuals including suppliers, employees, consultants, contractors and business partners may choose to make anonymous reports through EthicsPoint, Inc. The EthicsPoint reporting tool provides a secure third-party reporting system and can be reached by: