FIRST Supplier
Code of Conduct

1. Ethical Business Practices

• • A. Compliance with Law: Supplier’s business activities must comply with all applicable laws and regulations in the countries and jurisdictions in which they operate.
  • B. Business Integrity: Suppliers must maintain the highest standards of integrity in all interactions. Suppliers must not engage in any and all forms of bribery, corruption, extortion, embezzlement, fraud and forced labor. Suppliers will not violate the Foreign Corrupt Practices Act (FCPA), the UK Bribery Act 2010, any international anti-corruption conventions, and applicable anti-corruption laws and regulations of the countries in which they operate.
  • C. Conflict of Interest: Suppliers must disclose to FIRST any information regarding potential conflicts of interest in business relations relating to your activities as a FIRST supplier, including disclosure of any financial interest an employee may hold in your business.  Suppliers will avoid any conflict of interest when interacting with FIRST employees.
  • D. Books and Records: Suppliers must maintain up to date books and records to demonstrate compliance with this code and applicable governmental and industry regulations.
  • E. Intellectual Property: Suppliers must respect the intellectual property rights of others and take appropriate steps to safeguard and maintain confidential and proprietary information or trade secrets
  • F. Gifts & Entertainment: If Suppliers and business partners extend any business courtesies to our employees, they will do so infrequently and the courtesies must be of no more than moderate value.

2. Human Rights

1. • A. Voluntary Labor: FIRST promotes a no tolerance standard when it comes to the use of forced, compulsory, or child labor. Suppliers must employ all workers on a voluntary basis free from any threat of violence, threats of criminal penalty, and restrictions on freedom of movement. All work will be voluntary, and workers should be free to leave work or terminate employment upon reasonable notice. Suppliers may not retain or confiscate the personal papers of any worker including their passports. FIRST also prohibits the payment of recruitment, processing or placement fees by workers to employers.
   • B. Inhumane Treatment: Suppliers must not subject or threaten workers to any inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers; nor is there to be the threat of any such treatment. Supplier shall clearly define and communicate disciplinary policies and procedures in support of these requirements to its workers.
   • C. Child Labor: Suppliers must ensure that Workers below the legal minimum working age for where the work is performed are not hired, either directly or indirectly.
   • D. Modern Slavery Statement – Our most recent statement on Modern Slavery can be found HERE.

3. Workplace Health and Safety; Environmental Compliance

• • A. Safe Environment: Suppliers must provide their workers with a safe and healthy working environment that complies with applicable safety and health laws, regulations, policies and procedures. Supplier shall put in place procedures and systems to prevent, manage, track and report occupational injury and illness. Suppliers should have standards that prevents work done under the influence of any substance whether legal or illegal, that would impair judgement or compromise workplace safety.
  • B. Safety Training: Suppliers will eliminate or minimize physical hazards where possible and will provide workers with appropriate personal protective equipment. Suppliers will ensure that all workers are sufficiently aware of these risks and appropriately trained on the implementation of control measures.
  • C. Environmental Regulation Compliance: FIRST requires its suppliers to comply with all applicable legal environmental requirements and regulations in the countries and jurisdictions in which they operate. Suppliers shall make sure that it obtains, keeps current, and follows the reporting guidelines of all the required environmental permits and registrations to be at any time legally compliant.

4. Workplace Culture

• • A. Discrimination & Harassment: Suppliers must treat all workers with respect and dignity. No worker is to be subject to any physical, sexual, psychological, verbal harassment, abuse or other form of intimidation. There must be no discrimination in employment, including hiring, compensation, advancement, discipline, termination or retirement. Discrimination based on national origin, ethnicity, religion, age, disability, gender, marital status, sexual orientation, union membership, political affiliation, health, veteran status, disability, pregnancy or any characteristic protected by state or local law will not be tolerated. In particular, attention should be paid to the rights of workers most vulnerable to discrimination.
  • B. Diversity: Suppliers are expected to provide and foster a diverse and inclusive workplace. FIRST expects its suppliers to demonstrate a diverse workforce composition actively embracing workforce age, gender, race, national or ethnic origin, religion, language, political beliefs, sexual orientation and physical ability. FIRST encourages suppliers to promote supply chain inclusion throughout their own supply chains and may request information related to supply chain diversity from Supplier.
  • C. Freedom of Association: Suppliers shall respect the rights of workers to associate or not to associate with any group, as permitted by and in accordance with all applicable laws and regulations.
  • D. Grievance Mechanism; Whistleblower Policy: Suppliers shall provide all workers with transparent, fair, accessible and confidential procedures that are designed to result in unbiased and fair resolution of conflicts which may arise as part of their working relationship. Supplier will ensure a whistleblower policy is in place whereby workers will be protected from retaliation for submitting such complaints.
  • E. FIRST Whistleblower Service
    FIRST has partnered with an anonymous reporting service called WhistleB. This service will provide a secure and confidential platform for our employees, suppliers, and partners to report any concerns or violations to alert us about malpractice and serious risks affecting people, our organization, society, and the environment.
    WhistleB is encrypted, password-protected, and all messages are processed confidentially. We allow no retaliation against a person or business that sends a whistleblower message in good faith. By offering a confidential channel for reporting, we aim to encourage an open and safe environment where our teams and partners feel empowered to speak up.
    To submit a message, click here https://report.whistleb.com/en-GB/firstglobalmanagementserviceslimited

5. Data

1. • A. Suppliers will handle and process data only for the purposes for which it was collected or otherwise made available. Suppliers shall demonstrate appropriate industry standard and best practices data security controls to ensure that all information is protected and secure from damage and unauthorized use. Additional documentation may be required based upon the type of data.

FIRST expects Suppliers to establish effective grievance mechanisms to receive and respond to concerns relating to the topics discussed in this Supplier Code.

Subsidiaries Covered

• FIRST Protocol Group Limited
• Clive Agency (US)
• Clive Agency Limited (UK)
• Clive Agency (Ireland)
• FIRST Protocol Inc (US)
• FIRST PTE Limited (Singapore)
• FIRST Agency Limited (HK)
• FIRST Protocol Event Management Limited (UK)
• FIRST Agency Solutions Inc (US)
• FIRST Agency Solutions Limited (UK)
• FIRST Agency Solutions PTE Ltd
• FIRST Servicios De Eventos Ltda (Brazil)
• First Agency Solutions PTY Limited (Australia)
• FIRST Events Agency Ltd (Ireland) (Euro Zone Parent Company)
  • FIRST Events Agency Ltd (France Branch)
  • FIRST Events Agency Ltd (Belgium Branch)
  • First Events Agency Limited, Dublin, Zweigniederlassung Zürich (Switzerland Branch)
• First Agency Holdings Limited (UK)
• First Agency Solutions Holdings Limited (UK)
• FIRST Global Management Services Ltd (UK)
• FIRST Global Management Services Inc. (US)

If you have any questions or wish to report a concern, you may reach out to FIRST’s compliance team at compliance@firstagency.com.