Enstar is committed to maintaining a high ethical standard in all its business activities. Our aims are to:
Enstar expects all its vendors to adopt appropriate standards and strategies to enable Enstar to meet these shared aims and will work with all our vendor partners to maintain these high standards. A vendor’s own Code of Conduct may be acceptable (subject to Enstar review) if it sets equivalent standards.
All vendors shall undertake their business in accordance with any legal and regulatory requirements in each jurisdiction in which they operate. This shall include:
Vendors are prohibited from undertaking any business with parties that would breach sanctions imposed by OFAC, the United Kingdom, the European Union, or Australia.
Vendors shall not receive or make any payments, whether in cash, tangible assets, services, or other benefits-in-kind, to procure or obtain services at favourable rates or business advantages. Receipt or provision of any form of bribery or facilitation payment is strictly prohibited.
Vendors shall maintain adequate procedures to prevent and detect suspicious activities which may be involved in the laundering of money or terrorist financing. Vendors shall take appropriate steps to satisfy themselves of the identity of parties with which they undertake business.
Vendors shall take appropriate steps to protect data which they hold, whether on behalf of Enstar or their other clients, and promptly inform Enstar in the event of any data breach involving Enstar information. Vendors shall not retain or use information for purposes other than for which the information was collected.
Vendors are prohibited from selling any personal, confidential, or other information which they may have access to through their relationship with Enstar.
Vendors must only process personal data on behalf of Enstar by means of a written agreement that sets out how all appropriate privacy laws are followed, including, but not limited to, onward transfers; the appointment of sub-processors; rights and obligations to confidentiality, return, and destruction of personal data; technical and organizational security measures; breach notification obligations; data subject rights; and data privacy audits.
Vendors shall maintain appropriate technology and logical security controls to protect the Company’s data, maintain disaster recovery controls, and comply with applicable regulatory requirements.
Enstar advocates the fair treatment of all individuals, including staff and contractors, throughout its supply chain. Enstar requires all vendors:
Enstar is acutely aware of the impact firms may have on the environment and the need to minimise energy usage, travel, and production of non-recyclable waste. Enstar endeavours to adopt environmentally friendly procedures to support a healthy environment, such as:
Enstar encourages its vendors to similarly develop and implement environmentally friendly standards and procedures wherever possible.
Enstar is committed to supporting the communities it operates in, supporting staff in charitable giving initiatives, corporate/community workdays, education partnerships, and work experience opportunities. Enstar encourages its vendors to similarly build relationships with their local communities and contribute to the economic and social development of their localities.
Vendors should be cognizant of Enstar’s other corporate policies maintained on its website, www.enstargroup.com, including:
If you or any of your staff have a concern or complaint relating to any fraud, embezzlement, misconduct or wrongdoing, whether in the context of accounting, financial reporting, internal controls, auditing matters or otherwise, you may bring it to the attention of Enstar's Audit Committee by submitting a report online or by phone via our independently-operated whistleblowing hotline. Phone numbers for each jurisdiction in which we operate, as well as an online reporting tool, are available here. You need not disclose your identity in any communication.
Enstar expects vendors to communicate this Vendor Code of Conduct to all those involved in the relationship with Enstar including third party service providers. Enstar reserves the right to validate vendors’ compliance with this Vendor Code of Conduct through the risk-based use of auditors, questionnaires, or other means, to confirm the accuracy of assertions and responses provided by vendors.
Where vendors are unable to meet any of the requirements of this Vendor Code of Conduct, they are expected to communicate this to Enstar, including reasons why such provisions are unable to be met.
Enstar may terminate relationships where vendors’ behaviour does not meet the non-discriminatory, ethical, legal or regulatory requirements of this Code.
This Vendor Code of Conduct is supported by the Board of Enstar Group Limited and each of the boards of its subsidiary entities.
August 2023
