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Cloud Capital Advisors LLC Responsible Vendor Policy

Background

Cloud Capital Advisors LLC (the Company) is committed to conducting business in a legal, ethical, transparent and socially and environmentally responsible manner. Accordingly, we have made a commitment to work only with those whose standards are consistent with our own.

We ask our suppliers to comply with this Responsible Vendor Policy and to familiarise themselves with the guiding principles set out in our ESG Policy. Our Responsible Vendor Policy lays out the standards that we expect from our suppliers. These are in line with meeting international standards on basic human rights, addressing key environmental concerns and our commitments as a signatory to the UN Principles for Responsible Investment (UNPRI).

Our Commitment

These are our commitments to our suppliers:

  • We will be objective, impartial and transparent in our dealings with you.
  • We will provide information in a timely manner.
  • We shall seek continuous improvement in our supplier relationships, a collaborative working relationship will be encouraged.
  • We will maintain open lines of communication.
  • We will adhere to fair and transparent payment practices.

Your Commitment

We ask our suppliers to commit to the following:

  • To look to impose a policy of similar or higher standards on their own supply chains, including any sub-contractors they work with. The expectation is that each supplier in the supply chain will monitor their own compliance with a view that the Company will be able to meaningfully audit any tier in the chain if this is required.
  • Where possible, to set up a documented monitoring process to verify standards are met and continually reviewed to ensure compliance, with a process for corrective actions to be set up and followed through.
  • To make their workforce (including those not directly employed by the Supplier, i.e. agency staff, contractors and subcontractors) aware of the supplier’s own policy and provide them with appropriate training and skills to continually improve the supply chain.

Minimum Requirementss

We expect all suppliers to meet all requirements in this section.

People

  • Suppliers should comply with all applicable health and safety legislation.
  • The supplier should conduct employment practices in compliance with all applicable laws and regulations including, without limitation, all applicable human rights and labour laws and regulations. In accordance with the UN Global Compact, the UN Universal Declaration of Human Rights, the OECD Guidelines for Multinational Enterprises, the UN Guiding Principles on Business and Human Rights, the 1998 ILO Declaration on Fundamental Principles and Rights at Work and the Modern Slavery Act, we expect our partners to share in our respect for human rights.
  • Employees should be allowed freedom of association and the right to collective bargaining. Where national laws restrict freedom of association and collective bargaining, employers should facilitate alternative means of representation by staff.
  • Employees should be paid fairly. Total compensation packages should meet or exceed the legal minimum standards or appropriate prevailing industry standards. Working hours may not exceed the maximum amount permitted by applicable law.
  • All employees shall be treated equally with respect and dignity and should not be discriminated against.

Environment

  • Suppliers should comply with local and national environmental legislation at a minimum.
  • The Company is committed to conserving energy supplies and reducing consumption in order to reduce CO2 emissions, identifying water saving opportunities and reducing waste. Suppliers should monitor and, to the extent possible, reduce the environmental impacts of the services or products they provide.

Governance and Ethics

We have a strict set of financial crime policies in place, including fraud, bribery, anti-money laundering, terrorist financing, tax evasion and sanctions. We expect our suppliers to uphold high standards of integrity, transparency and governance. At a minimum we expect suppliers:

  • To comply with all applicable local laws and regulations.
  • Not to be associated with any group that supports acts of violence or terrorism.
  • Not to offer, promise, give or receive any bribe or kickback and/or other improper advantage to or from any person, customer, or supplier.
  • Not to make nor offer, directly or indirectly, any payment, gift or other advantage to a public official with the intention of influencing them and obtaining or retaining an advantage in the conduct of business.
  • To adhere to an anti-facilitation of tax evasion policy and not engage in any activity, practice or conduct which would cause an offence to be committed relating to the prevention of tax evasion and/or the facilitation of tax evasion.
  • Comply with all data protection laws including the protection of personal information.

Independently verified practices and standards

We value third party verified assessment and certification schemes, standards or equivalents which address the above issues. Cloud Capital is a signatory to the UN Principles for Responsible Investment (UNPRI) and a participant in the Global Real Estate Sustainability Benchmark (GRESB). We encourage our suppliers to aspire towards the recognised independent assessments, standards and best practices relevant to their business.

Monitoring and Review

The Company expects its suppliers to provide access to any information about compliance with this Policy reasonably requested by the Company or its representatives.

Should suppliers become aware of or suspect non-compliance with this Policy, it should be reported to the Company immediately. Concerns can be reported to any employee of the Company, or via the email address #ob#abgvprf#at#pyqpnc.pbz#ob#.

From time to time, the Company may request ESG related data from its suppliers for the purposes of its own ESG reporting.

This Policy shall be reviewed annually or as required to ensure its relevance and effectiveness.

Third Party Rights

The Responsible Vendor Policy does not confer, not shall it be deemed to confer, any rights on the part of third parties, including any third-party beneficiary rights. For example, no employees of any supplier shall have any rights against the Company by virtue of this Policy, nor shall any such employees have any rights to cause the Company to enforce any provisions of this Policy, the decision with respect to any such action being reserved by the Company in its sole discretion.

September 2022