Enstar is committed to maintaining a high ethical standard in all its business activities. Our aims are to:
Enstar works with all its vendors to support adoption and maintenance of appropriate standards and strategies to enable Enstar to meet these shared aims. 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 the United States, the United Kingdom, the European Union, Bermuda 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 security incident (meaning any attempted, suspected, or actual unauthorised access, use, modification, or disclosure, unauthorised, unlawful, or accidental loss, misuse, destruction, acquisition of, or damage to Enstar data or any other unauthorised access to Enstar data and/or Enstar systems) involving Enstar data. Vendors shall not retain or use Enstar data for purposes other than for which the information was collected.
Vendors (including authorised vendor personnel) may process Enstar data solely in accordance with Enstar’s written instructions and only for the purpose of providing the services to Enstar. 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 organisational security measures; security incident notification obligations; data subject rights; and data privacy audits.
Vendors, in accordance with good industry standards, shall maintain appropriate technology and logical security controls to protect Enstar’s data, maintain sound Business Continuity practices, operational resiliency measures and disaster recovery controls, in compliance 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 business has on the environment and of the need to minimise energy usage, travel, and the production of non-recyclable waste. Enstar reports its Green House Gas (GHG) emissions annually, including those relating to its supply chain. Enstar endeavours to minimise its environmental impact, through adopting initiatives such as:
Enstar expects its vendors to develop and implement environmentally sustainable 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 aware 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.
July 2024
