Ethical Procurement and Conduct Policy

Our Corporate Commitment

We carry out our business honestly, ethically and with respect for the rights and interests of our employees, sub-contractors, and suppliers.

We seek to develop relationships with supplier companies consistent with these basic principles, and specifically with respect to human rights and conditions and standards of employment as documented in our AVA Energy Statement on Human Rights and Labour Standards.

Statement on Ethical Procurement

Conducting our business in an ethical and sustainable way is of primary importance to our company. This Business Integrity Policy, and the supplier management provisions which apply to all purchases of goods and services, sets out how we will conduct business with our suppliers and describes the expectations we have of our suppliers regarding the way they conduct their business.

Our aim is to ensure that the way business is conducted throughout the whole of our supply chain conforms to our own standards.

We strive to maintain the highest standards of ethical conduct and corporate responsibility worldwide and seek to influence our suppliers to operate to similarly high standards as ourselves.

We require our employees engaged in purchasing activity to act in accordance with the following code.

We will:

Treat our suppliers fairly and objectively at all times.

Ensure that appropriate suppliers have an equal opportunity to win our business.

Pay suppliers in accordance with the agreed terms and deal with any exceptions in a timely manner.

Encourage responsible business practice.

Select suppliers without consideration of the gender of their employees or their ethnic or religious origin in accordance with our Equal Opportunities policy.

Continuously improve our knowledge of socially and environmentally responsible supply chain management practices.

We expect our suppliers to:

Maintain effective policies and procedures to manage their environmental impact.

Respect fundamental human rights including worker representation.

Have a positive impact on the communities in which they operate.

Maintain a safe working environment and responsible health & safety practices.

Be committed to a comprehensive policy of equal opportunities in employment.

Adopt ethical business practices with respect to the business behaviour of individuals and the organisation as a whole.

Comply with all applicable local, national, regional and international laws,

Respect the intellectual property rights of others.

We will:

Carry out ethical conduct due diligence, including a risk assessment and screening before entering into a binding commitment with any new or existing counterparty or before AVA Energy undertakes business in a country for the first time

Regularly review our ethical purchasing practice to determine areas for improvement.

Identify suppliers who can comply with our ethical purchasing policy and use them wherever possible.

Train our staff in our policy to make sure they have a full understanding of our corporate requirements with regards to supplier dealings and the principles and operation of the policy.

Principles Underlying this Policy


We are committed to free and fair competition and we will compete robustly but honestly, complying with all relevant competition laws.


Offering, paying, soliciting or accepting bribes or any form of inappropriate payment including “kick-backs” or “facilitation payments” is strictly prohibited.

Gifts and Hospitality

Giving and receiving modest gifts and hospitality may foster goodwill in a range of business relationships without any intention to prejudice or influence current or future business dealings.

Any such gifts or hospitality must, however, be reasonable, appropriate, limited in value and frequency and in keeping with appropriate business “custom and practice” and in accordance with all applicable laws.

Gifts and hospitality designed to induce or reward improper conduct or where they might compromise – or be perceived to compromise – the recipient’s judgment or integrity are not permitted.

Charitable Donations

As part of its Corporate Social Responsibility and Community Involvement activities, AVA Energy may support local, national or international charities or provide sponsorship, for example, to sporting or cultural events. Any such sponsorship must be transparent and properly documented.

We will only provide donations to organisations that serve a legitimate public purpose and are themselves subject to high standards of transparency and accountability.

Political Donations

We do not make donations to political parties.

Confidentiality and Accuracy of Information

The confidentiality of information received in the course of business will be respected and never used for personal gain.

False information will not be given in the course of commercial negotiations.

Review and Update

This policy will be reviewed annually and updated where appropriate in accordance with prevailing legislation.


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