Code of Business Conduct

Supply chain companies must:

  • Comply with all local and country environmental, health and safety laws and regulations
  • Manage their operations to minimize negative impact to the environment and community
  •  Provide a safe and healthy work environment for their employees, including training, work procedures and personal protective equipment
  • Comply with all applicable workplace health and safety laws
  •  Establish and maintain a management system or program that encourages continual improvement in environmental, health and safety performance.


Ethics and legal requirements

Cambridge conducts its business ethically and in accordance with the law and expects supply chain companies to conduct their business in the same way.

Supply chain companies must:

  • Disclose in advance any relationship with a Cambridge employee or person working with Cambridge that might represent a conflict of interest
  • Comply with all applicable laws regarding fair competition and antitrust
  • Keep accurate records of all matters related to their business with Cambridge and provide copies of relevant records on request
  • Protect Cambridge confidential information and act to prevent its misuse, theft, fraud or improper disclosure.

Supply chain companies must not:

  • Develop any relationship with an Cambridge employee or those working for Cambridge, whether financial or otherwise, which might conflict, or appear to conflict, with the employee’s obligation to act in the best interest of Cambridge
  • Engage in any form of bribery or offer any incentive to any Cambridge employee or Cambridge employee’s family or friends in order to obtain or retain Cambridge business.


We expect all of our employees and those working for us to comply with the law and act ethically in all matters – consistently demonstrating integrity. We have the same expectations of our supply chain. Our goal is that by working together, we can build a sustainable business relationship for both parties and help Cambridge achieve its vision. 

Gifts and hospitality

Cambridge has a gifts and hospitality policy which requires all employees and those working for Cambridge to seek approval for and register all gifts and hospitality both offered and accepted above a nominal value. Supply chain companies are discouraged from offering gifts and hospitality above a nominal value and must avoid anything involving the offer of cash or cash equivalents or travel that is frequent in nature or expensive.


Human rights and human resources

Cambridge is a signatory to the United Nations Global Compact and adheres to these principles. We expect Cambridge’s supply chain to respect the human rights of their employees and contractors and treat them fairly, in accordance with all applicable laws.


Supply chain companies must:

  • Comply with all applicable child labor laws
  • Set working hours, wages and overtime pay in compliance with all applicable laws. Workers should be paid at least the minimum legal wage or a wage that meets local industry standards, whichever is greater
  • Comply with all applicable laws on harassment and abuse of employees
  • Employ workers on the basis of their ability to do the job, not on the basis of their personal characteristics or beliefs (including race, color, gender, nationality, religion, age, disability, maternity or marital status)
  • Allow freedom of association. Workers must be free to join associations of their own choosing and have the freedom of collective bargaining where the local law confers such rights.


Supply chain companies must not:

  • Use any forced or child labor
  • Subject their employees to psychological, verbal, sexual, or physical harassment or any other form of abuse.



Cambridge reserves the right to assess and monitor suppliers’ compliance with this

Supply Chain Code. Any non-compliant suppliers are expected to implement corrective actions or they will not be considered for future business.


Supply chain companies must:

  • Comply with all applicable laws in the provision of products or services to Cambridge
  • Implement systems and controls to provide compliance with applicable laws and the principles set out in this Supply Chain Code, including policies, training, monitoring and auditing mechanisms
  • Apply these or similar principles to the supply chain they work with in providing goods and services to Cambridge.


Implementation – December 2013


Review and Updating

This policy will be reviewed and updated on a semi – annual basis by an executive of Cambridge. The Cambridge Executive Committee will receive an annual report on this policy and the company’s performance.