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Responsible Procurement Policy

At Kaplan, we are working hard to build a brighter future together. We are guided by our values (Act with Integrity, Grow Knowledge, Empower and Support, Create Opportunity, Drive Results Together) and we intend to create success for our learners, our customers, our people and for our organisation in a positive and sustainable way. To achieve this, we believe we need to apply these principles throughout our supply chain. 

Contents

  1. Purpose and Scope
  2. Principles for operating this policy
  3. Our business conduct
  4. Our procurement decisions
  5. Supplier code of conduct
  6. Policy review and contacts
  7. Appendix A: Questionnaire

1. Purpose and Scope

This policy applies to all businesses within the Kaplan Professional UK group (KPUK) and their suppliers. It sets out our commitment to have a positive impact through our business activities, on our environment, and in our community.

2. Principles for operating this policy

To operate this Responsible Procurement Policy, Kaplan will:

  • Ensure that all relevant employees are aware of this Responsible Procurement Policy.
  • Base our selection of products, services and suppliers on objective and transparent criteria that include the consideration of ethical, environmental, and community performance.
  • Ensure that the Procurement Manager is responsible for establishing the acceptance and compliance by key suppliers with the Supplier Code of Conduct.
  • Protect the confidentiality of information entrusted to us.
  • Work collaboratively with suppliers to improve ethical, environmental, and community standards with the aim of realising continuous improvement in all these areas for both our suppliers and ourselves.
  • Recognise the supplier’s own standard where they are working to ethical, environmental, and community standards similar to those stipulated in this policy.
  • Not require suppliers to realise ethical, environmental, and community standards more onerous than our own.
  • Ensure that supplier’s staff working on our premises are treated with the same respect for diversity and workplace safety as our own staff.
  • Seek to exert commercial influence where we are confident that improvements can be made in ethical, environmental, and community performance of suppliers.
  • Where it is found that a supplier’s conduct does not meet the standards set out in this policy, seek to engage with that supplier and encourage continuous improvement in their environmental, social and ethical performance.
  • Cease trading with suppliers showing persistent disregard for important elements of ethical, environmental, and community performance.
  • Use a risk based approach to ensure we focus on those areas where the risk is greatest and maximum impact can be achieved.
  • Act as an advocate for responsible supply chain practices.

3. Our business conduct

We act with integrity, and we’re proud to be conducting business the right way as set out in our Corporate Responsibility Policy.

  1. Graham Holdings Company, Kaplan’s parent company, operates a group Code of Business Conduct which sets out strong principles guiding the way we do business and the way we treat each other, our customers, suppliers and partners. We seek to conduct our operations in accordance with the highest standards of business ethics and compliance with all applicable laws.
  2. Kaplan operates an Anti-bribery and Corruption Policy which sets out our commitment to the highest standards of ethical conduct and integrity in our business activities in the UK and overseas. This policy outlines our position on preventing and prohibiting bribery, in accordance with the Bribery Act 2010. It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and to implementing and enforcing effective systems to counter bribery.
  3. Out of respect for the cash flow of our suppliers, it is our policy to pay them within 30 days of receipt of a correct invoice.

4. Our procurement decisions

  1. We are committed to making our procurement decisions on the basis of product, service, price and this Responsible Procurement Policy.
  2. Organisations with whom we spend or expect to spend more than £5,000 per year will be asked to provide information which demonstrates their compliance with this policy.

5. Supplier code of conduct

Kaplan is committed to minimising the ethical, environmental and community impacts of its supply chain by incorporating these considerations into purchasing decisions and working in partnership with suppliers to conduct our business in a responsible manner.

  • Health, safety and hygiene

    All workers should expect to work in an environment that is both safe and healthy. Adequate steps should be taken to prevent accidents occurring in the normal course of work. Workers should receive suitable health and safety training and have access to clean toilet facilities and clean drinking water as required.

  • Ethics and compliance

    1. Kaplan has clear ethical standards and arrangements to promote and encourage compliance: similar standards are expected of our suppliers.
    2. Organisations should be able to demonstrate the existence of processes and procedures to implement appropriate codes of conduct.
    3. Organisations should ensure that management systems and practices are in place to ensure the prevention of money laundering, insider trading, conflicts of interest, fraud, bribery, corruption and other improper payments or gifts, and unauthorised access to personal and business information.

  • Labour practices

    It is understood that organisations must comply with national and other applicable laws and regulations. Those provisions or the provisions below, whichever give the greatest protection to workers, should be applied.
    1. Child Labour: Organisations should ensure the effective long-term elimination of child labour, in a manner consistent with the interests of the children concerned. Children or young persons under 18 shall not be employed at night or in hazardous conditions.
    2. Forced Labour: There should be no forced, bonded or involuntary labour and no workers are required to lodge “deposits” or identity papers with their employers and should be able to leave after giving reasonable notice.
    3. Discipline: Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation is not acceptable. Disciplinary and grievance procedures shall be clearly documented and communicated to all employees. All disciplinary measures of a serious nature shall be recorded.
    4. Working Hours: Working hours should not be excessive and shall comply with relevant national laws.
    5. Remuneration: Wages and benefits afforded to workers should meet national standards. Kaplan intends to become accredited as a Living Wage Foundation employer, so suppliers’ UK workers who work regularly for Kaplan (for 2 or more hours a week, for 8 or more consecutive weeks a year) should be paid at least the rates published annually by the Living Wage Foundation. Workers should be provided with clear written information on their pay and conditions. Excessive deductions on wages should not be permitted as a disciplinary measure.
    6. Employment terms: All workers should be provided with written contracts which must detail the terms and conditions of their employment. Contracts should be clearly understandable to each worker. Work performed should be on the basis of recognised employment law and practice.

  • Equality, diversity and inclusion

    Organisations will seek to eliminate discrimination in access to employment, training and working conditions, on grounds of race, colour, sex, age, religion, political opinion, national extraction, sexual orientation, disability or social origin and promote equality of opportunity and treatment.

  • Environment

    Organisations should be able to demonstrate environmental policies and commitments sufficient to ensure continuous improvement in environmental performance, which may include:

    1. Documented policies regarding environmental management.
    2. The ability to monitor and review environmental performance.
    3. The awareness of potential environmental risks inherent in their production, service or sourcing activities.
    4. The implementation of mechanisms and processes in place to mitigate or minimise potential environmental risks.
    5. The degree to which products and services have been designed with environmental considerations in mind.

      6. Suppliers should seek to:

    6. Minimise the use of energy, water and raw materials where practical.
    7. Maximise the use of recyclable and renewable materials including energy where possible.
    8. Make practical efforts to minimise waste and dispose of it in a safe, efficient, and environmentally responsible manner.
    9. Avoid contamination of the local environment and ensure that emissions, air, noise and odour pollution is, as a minimum, within nationally defined limits.

  • Community

    Organisations are encouraged to support the communities in which they operate through appropriate community initiatives.

6. Policy review and contacts

  • If you have any questions about this policy, your line manager or the Procurement Manager can help.
  • Our policies are reviewed and (if required) updated at least every two years in line with legal obligations, business objectives, and operational needs.
  • We will notify staff of some key changes, but it is not practical to notify of every change that occurs so it is everyone’s responsibility to keep themselves up to date with the current versions of policies as made available via our employee intranet.
  • Active suppliers will be sent the latest version of this policy at least every two years.

7. Appendix A: Questionnaire

All suppliers will be required to sign up to the Supplier Code of Conduct, and Suppliers with whom we anticipate spending more than £5,000 in one year will also be asked to answer the questions below, and supply the indicated documents.

The aim of these questions is to:

  • Encourage suppliers to pause and consider their practices in relation to individual elements of the Supplier Code of Conduct
  • Request, where possible, some evidence that their practices are in line with individual elements of the Supplier Code of Conduct

  • Health, safety and hygiene

    1. Does your organisation operate a Health and Safety Policy (or similar)? If yes, please supply a copy.
    2. Is there anything else you wish to say or supply to demonstrate your commitment to providing a safe and healthy working environment?

  • Ethics and compliance

    1. Does your organisation operate a Code of Business Conduct (or similar) which sets out your commitment and expectations in relation to ethical business practices? If yes, please supply a copy.
    2. Do employees receive training on your Code of Business Conduct (or similar). If yes, how often is that training repeated?
    3. Does your organisation operate an Anti-bribery and Corruption Policy (or similar)? If yes, please supply a copy.
    4. Does your organisation have controls in place to prevent bribery and corruption? If yes, please describe.
    5. Do employees receive training on your Anti-bribery and Corruption Policy (or similar)? If yes, how often is that training repeated?
    6. Does your organisation have a modern slavery statement in place? If yes, please supply a copy.

  • Labour practices

    1. Does your organisation pay all workers rates which comply with all relevant national standards (e.g. in the UK this would be the National Living Wage)?
    2. Can you confirm that each of your organisation's workers who work regularly for Kaplan (i.e. for 2 or more hours a week, for 8 or more consecutive weeks a year) will receive at least the rate of pay published annually by the LIving Wage Foundation (link to Living Wage Foundation website).
    3. Does your organisation have, or are you pursuing, Living Wage Foundation accreditation?

  • Equality, diversity and inclusion

    1. Does your organisation operate an Equality, Diversity and Inclusion Policy (or similar)? If yes, please provide a copy.
    2. Does your organisation publish a gender pay gap report? If yes, please provide a copy.
    3. What percentage of the following groups within your organisation are from BAME backgrounds:
      • leadership team
      • senior managers
      • managers
      • individual contributors
    4. What percentage of your organisation’s workforce identifies as having a disability?
    5. Is there anything else you wish to say or supply to demonstrate your commitment to equality, diversity and inclusion?

  • Environment

    1. Does your organisation operate an Environment Policy (or similar)? If yes, please provide a copy.
    2. Is there anything else you wish to say or supply to demonstrate your commitment to reducing your organisation’s impact upon the environment?

  • Community

    1. Does your organisation operate a Corporate Responsibility Policy (or similar)? If yes, please provide a copy.
    2. Does your organisation support your local communities through community initiatives? If yes, please specify.

  • General questions

    1. Does your organisation operate a Responsible Procurement Policy (or similar)? If yes, please provide a copy.
    2. Does your organisation operate a Supplier Code of Conduct (or similar)? If yes, please provide a copy.

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