Code for Suppliers

As a provider of infrastructure services for international financial centers and a large client base, we are aware of the systemic importance of SIX, of which BME is a part, and therefore assume a great responsibility. The proper functioning of the services we offer is therefore of paramount importance.

SIX is determined to ensure the highest standards in the conduct of its business activities and expects each employee to comply with the relevant laws and to act ethically in all matters. SIX imposes the same requirements on its suppliers. In its Code of Conduct, SIX defines the fundamental standards for the ethical and professional conduct of its employees. This code sets out the corresponding requirements for SIX suppliers and their subcontractors.

All suppliers and their subcontractors are bound by the Code for Suppliers and must conduct their business in accordance with it. This means that SIX suppliers must ensure the integration, implementation and communication of the Code for Suppliers within their organizations as well as with their subcontractors. The Code for Suppliers serves as a basic guideline to which reference is made in contracts as well as in the General Terms and Conditions between SIX and its suppliers. It includes codes of conduct on human rights, labor rights, environmental standards and anti-corruption principles.

For more information, please contact: 

BME Procurement: procurement@grupobme.es

Reporting of potential misconduct 

Suppliers that have a relationship with BME or any of its group companies may use BME’s Internal Information System to report any potential misconduct or inappropriate behavior. 

Suppliers can report these issues, also anonymously, through BME’s Integrity Line platform: EQS Integrity Line

For more information on BME’s Internal Information System and other means of communication, follow this link. 

Legal and Compliance

Of course, all suppliers must comply with all laws, regulations, policies and local conditions applicable in all countries in which they operate, produce or conduct business.

Fair Competition

Suppliers must not resort to bribery, price fixing or other forms of corruption or anti-competitive behavior to obtain or retain business. In addition, suppliers are prohibited from demanding bribes from SIX if SIX wishes to do business with them. All such suppliers will be immediately excluded from supplying SIX.

Anti-competitive Behavior

Laws that protect and promote fair competition, particularly antitrust laws, must be complied with. Suppliers must abide by the prohibition of collusion between competitors and other measures that impede the free market.

Conflicts of Interest

Suppliers must disclose all potential conflicts of interest, in particular those that arise unintentionally due to business or personal relationships with SIX customers, other suppliers, competitors or SIX employees.

Protection of Trade Secrets

Suppliers are obliged to protect confidential information related to SIX that has come to their knowledge in the course of a business relationship and to treat it as a trade secret. Suppliers must not trade or solicit others to trade in securities on the basis of confidential information received from SIX.

Data Protection 

SIX expects its suppliers to maintain a high standard of data protection and security. The suppliers are therefore obliged, among other things, to process and protect SIX personal data in accordance with applicable law; in particular, SIX personal data may only be processed in accordance with the contractual agreements and directives of SIX and may not be disclosed to third parties without written consent.

Trademark and Copyright Protection

Suppliers must respect the protection of patents, copyright and trademark rights. They must have the permission of the authorized party or else refrain from their use.

International Standards

Suppliers must comply with the following internationally recognized labor and human rights standards:

• International Bill of Human Rights
• United Nations Guiding Principles on Business and Human Rights (UNGPs)
• OECD Guidelines for Multinational Enterprises
• Labor Standards and Principles of the International Labor Organization (ILO)

 

Respectful Work Environment

Suppliers shall promote a work environment free from abuse, persecution, sexual abuse, physical violence, discrimination, intimidation and workplace harassment.

Health and Safety

Suppliers must ensure a safe working environment to prevent accidents and injuries in the workplace.

Free Choice of Work

Suppliers may not allow any forced or involuntary labor to be performed. Employees must be free to terminate employment with reasonable notice.

Prevention of Child Labor

Suppliers shall not employ children below the minimum age established by the International Labor Organization.

Prohibition of Discrimination

Suppliers must commit to equal opportunity in personnel decisions. No one may be discriminated against on grounds of racial or ethnic origin, gender, nationality, age, sexual orientation or religion.

Health and Safety

Suppliers must ensure a safe working environment to prevent accidents and injuries in the workplace. The same applies to housing that the supplier makes available to employees.

Freedom of Association and Right to Collective Bargaining

Suppliers must respect their employees’ right to freedom of association and collective bargaining. The right of employees to be elected to a trade union must be respected.

Salaries and Benefits

Suppliers shall provide wages and supplementary benefits that comply with all applicable standards and local practices. Any form of illegal labor is prohibited.

Working Time and Rest Periods

Suppliers shall ensure that their employees’ working hours do not exceed the local legal maximum limits for standard working hours and overtime. Statutory rest periods must be observed.

Suppliers are required to comply with all applicable national and international legal obligations and all existing industry standards or guidelines relating to environmental protection; however, as an absolute minimum standard (i.e., where mandatory standards do not exist or they are of lesser scope), suppliers must comply with the following principles:

Reduction of Resources Used and Emissions

Suppliers shall use raw materials and natural resources responsibly and take all reasonable measures to minimize energy and fuel consumption and associated emissions. Suppliers are obliged to provide SIX with relevant information and to actively support SIX in achieving its own reduction targets as part of the company’s net-zero emissions strategy.

Substances Hazardous to the Environment and to Health

Wherever possible, suppliers shall refrain from using chemicals or other substances that pose a risk to the environment or health if released. If this is not possible, the use of such substances must be clearly identified and safe and environmentally sound handling, storage, use, recycling and disposal must be ensured.

Continuous Optimization

Suppliers shall have adequate internal processes for the systematic planning, training, implementation, monitoring and evaluation of the company’s environmental performance (environmental aspects) with the aim of continuously reducing the environmental impact of their operations. Suppliers shall take all reasonable steps to implement new advanced environmental technologies that lead to measurable improvements in their own environmental impact (e.g., climate change and biodiversity).

Compliance With Legal Requirements and Industry Standards

Suppliers must continuously monitor their compliance with laws, regulations and common industry standards.

Risk Assessment and Management

Suppliers shall have an appropriate risk management system to identify and manage the risks associated with the supplier’s activities in all areas defined in the Code for Suppliers.

Communication and Training

Suppliers shall have appropriate communication tools and training programs to ensure that their employees achieve the highest possible level of knowledge, awareness and skills to meet the objectives and principles set out in this Code for Suppliers.

Documentation

Suppliers must be able to demonstrate at any time through documentation that they comply with all applicable laws and the objectives and principles set out in the Code for Suppliers.

SIX Audit Right

SIX has the right to request information on compliance with this Code for Suppliers at any time or to conduct on-site audits. On-site audits must be announced by SIX at least ten days in advance, be conducted during office hours and no more than once a year. If there are concrete indications that the supplier does not comply with this Code for Suppliers, SIX may also conduct more than one audit per year.

Incident reporting

Suppliers are required to report to SIX all incidents, misconduct or other circumstances that constitute an imminent or actual violation of this Code for Suppliers or applicable laws or regulations in these areas.

Incident Remediation and Right of Termination

Suppliers shall promptly remedy any violation of the Code for Suppliers. In the event of intentional or grossly negligent violation of the Code for Suppliers, SIX shall have the right to terminate all contracts with the supplier in accordance with the contractual provisions on termination for good cause.

Subsuppliers

Suppliers are obliged to ensure that their subsuppliers also comply with the objectives and principles defined in this Code for Suppliers. In particular, contracts with subsuppliers must be drafted accordingly and a right of audit must be agreed.