# Supplier Code of Conduct: [Organisation name]

> The minimum standards [Organisation name] expects from its suppliers
> on labour and human rights, health and safety, environment, business
> ethics and management systems, and how it will work with suppliers
> to meet them. Expectations draw on the UN Guiding Principles on
> Business and Human Rights (2011), the ILO Declaration on Fundamental
> Principles and Rights at Work (1998, amended 2022) and the OECD Due
> Diligence Guidance for Responsible Business Conduct (2018), with EU,
> UK and US laws given as dated examples. Replace every `[bracketed]`
> value. This is a documentation format, not legal advice: check the
> current official text and a qualified professional.

<!--
Guidance: How to use this template
- Purpose: a short, supplier-facing document that suppliers sign or
  accept in the contract, and that buyers use in onboarding,
  tendering and performance reviews.
- Write for the supplier: plain language, "you" for the supplier,
  "we" for the buyer. Keep it short enough to be read; put detailed
  procedures in your own due diligence documents.
- Decide the bracketed values first (working hours limit, notice for
  audits, reporting channel). Align them with your own employee Code
  of Business Conduct (`compliance/code-of-business-conduct`), so you
  do not ask suppliers for more than you do yourself.
- The code is a contract instrument: reference it in the terms of
  purchase and master agreements (`procurement/purchase-requisition-po`,
  `legal-lite/master-services-agreement-outline`).
- Related templates: Supplier Onboarding and Due Diligence
  (`procurement/supplier-onboarding-due-diligence`), Procurement Policy
  (`procurement/procurement-policy`), CSDDD Due Diligence Plan
  (`finance/csddd-due-diligence-plan`), Whistleblowing Policy
  (`compliance/whistleblowing-policy`), Sanctions Compliance Procedure
  (`compliance/sanctions-compliance-procedure`).
-->

## Document control

<!-- Guidance: The owner is usually procurement with sustainability and legal. Publish the version suppliers sign and keep earlier versions. -->

| Field | Value |
|---|---|
| Document ID | [SCOC-NNN] *Example:* SCOC-001 |
| Version | [1.0] |
| Owner | [@head-of-procurement] |
| Reviewers | [@head-of-sustainability], [@general-counsel], [@hr-director] |
| Approved by | [@ceo] |
| Effective date | YYYY-MM-DD |
| Next review | YYYY-MM-DD (every [2] years or on a change in law) |
| Languages | [Languages in which the code is published to suppliers] |
| Classification | Public |

### Revision history

| Version | Date | Author | Change summary |
|---|---|---|---|
| 0.1 | YYYY-MM-DD | [@name] | First draft |
| 1.0 | YYYY-MM-DD | [@name] | *Example:* Approved; recruitment fees and grievance access added |

## 1. Who this code applies to

<!-- Guidance: Say that suppliers must pass the expectations down their own supply chain, and that local law applies where it is stricter. Pitfall: a code that binds only the direct supplier, leaving the highest-risk tiers untouched. -->

This code applies to every company that supplies goods or services to
[Organisation name] and its subsidiaries, including its employees,
agents and subcontractors working on our business. We expect you to
communicate equivalent standards to your own suppliers and to check
that they are met in proportion to the risk.

Where national law and this code differ, follow the higher standard.
Where national law conflicts with this code, follow the law and tell us
how you respect the principles of this code as far as the law allows.

## 2. Labour and human rights

<!-- Guidance: Cover the five categories of the ILO Declaration and the practices that most often lead to forced labour, such as recruitment fees and retained documents. Questions: what working hours limit will you set, and will you ask for a living wage or a legal minimum? -->

We expect you to respect internationally recognised human rights, as
described in the UN Guiding Principles, and in particular:

| ID | Expectation |
|---|---|
| LAB-01 | **No forced labour.** No prison, bonded, indentured or trafficked labour. Workers keep their identity documents, are free to resign with reasonable notice and are not charged recruitment fees or related costs |
| LAB-02 | **No child labour.** No employment below the legal minimum age or the age of completing compulsory schooling, whichever is higher; young workers do no hazardous or night work |
| LAB-03 | **Freedom of association.** Workers may join or form trade unions and bargain collectively, or use lawful alternatives where the law restricts these rights, without retaliation |
| LAB-04 | **Non-discrimination.** No discrimination or harassment in hiring, pay, promotion, training or dismissal on grounds such as sex, race, religion, age, disability, sexual orientation, pregnancy or union membership |
| LAB-05 | **Safe and healthy workplace.** Risks are assessed and controlled, workers are trained and given protective equipment free of charge, and emergencies, accommodation and canteens meet safety standards |
| LAB-06 | **Wages and benefits.** At least the legal minimum wage and benefits, paid on time; we encourage wages that meet basic needs. No deductions as a disciplinary measure |
| LAB-07 | **Working hours.** Within legal limits and not more than [60] hours per week including voluntary overtime, with at least one day off in seven, except in genuine emergencies |
| LAB-08 | **Fair treatment and grievance.** Workers have a confidential way to raise concerns without retaliation, and concerns are answered |

LAB-01 to LAB-05 correspond to the five categories of the ILO
Declaration on Fundamental Principles and Rights at Work: freedom of
association and collective bargaining, elimination of forced labour,
abolition of child labour, elimination of discrimination, and a safe
and healthy working environment (added in 2022).

## 3. Environment

<!-- Guidance: Ask for what you will use: emissions data you need for your own Scope 3 inventory, and material declarations your products need. Pitfall: demanding certifications that small suppliers cannot afford, instead of evidence of practice. -->

| ID | Expectation |
|---|---|
| ENV-01 | Hold and comply with required environmental permits |
| ENV-02 | Measure and reduce greenhouse gas emissions; share Scope 1 and 2 data, and Scope 3 data where available, on request (see `finance/ghg-emissions-inventory`) |
| ENV-03 | Use energy, water and materials efficiently and reduce waste and packaging |
| ENV-04 | Prevent pollution of air, water and soil; manage hazardous substances safely |
| ENV-05 | Meet product substance restrictions that apply to what you supply to us, and provide declarations on request |
| ENV-06 | Avoid contributing to deforestation and biodiversity loss in sourcing raw materials |

## 4. Business ethics

<!-- Guidance: Mirror your anti-bribery, sanctions and data protection policies. Make clear that gifts to our staff during tenders are not acceptable. -->

| ID | Expectation |
|---|---|
| ETH-01 | No bribery or corruption in any form, including facilitation payments, to anyone, public or private |
| ETH-02 | No gifts or hospitality to our employees during a tender, and otherwise only within our published limits |
| ETH-03 | Disclose any conflict of interest, such as a family or financial link with one of our employees |
| ETH-04 | Compete fairly; no price fixing, bid rigging or market sharing |
| ETH-05 | Comply with sanctions and export control laws that apply to you and to us; tell us about any designation affecting you or your owners |
| ETH-06 | Protect our confidential information, intellectual property and personal data; report security incidents affecting us without undue delay |
| ETH-07 | Keep accurate books and records; no fraud or money laundering |
| ETH-08 | No retaliation against anyone who raises a concern in good faith |

## 5. Management systems and due diligence

<!-- Guidance: Ask suppliers to manage these issues, not just to promise. Scale expectations to supplier size and risk. -->

We expect you, in proportion to your size and risk, to:

1. Adopt policies covering this code and assign responsibility to a
   senior person.
2. Identify and assess risks of harm to people and the environment in
   your operations and supply chain, and act on the most severe first,
   following the steps of the OECD Due Diligence Guidance (embed,
   identify, prevent and mitigate, track, communicate, remediate).
3. Train relevant workers and managers.
4. Keep records that show compliance, and share them with us on
   reasonable request.
5. Provide or take part in remediation where you have caused or
   contributed to harm.

## 6. Raising concerns

<!-- Guidance: Give an external channel that workers of suppliers can use in their language, and say how reports are protected. -->

Your workers, your suppliers and other affected people can raise
concerns about any breach of this code through [channel: web form,
phone line, email], available in [languages], anonymously where the
law allows. We protect reporters against retaliation in line with our
whistleblowing policy (`compliance/whistleblowing-policy`).

## 7. Monitoring, remediation and consequences

<!-- Guidance: Be explicit that the first response to a problem is improvement, and that ending the relationship is a last resort considered with its effect on workers. Pitfall: an immediate termination clause that makes suppliers hide problems. -->

- We may ask you to complete self-assessments, provide evidence, or
  accept audits by us or an independent party with [10] working days'
  notice, or without notice where we have credible reports of serious
  harm.
- Where we find a gap, we agree a corrective action plan with you,
  with dates, and follow it up in supplier performance reviews
  (`procurement/supplier-performance-review`).
- Where you will not or cannot improve, we may suspend new business
  and, as a last resort, end the relationship, after considering the
  effect on affected workers and communities.
- Serious breaches, such as forced or child labour, bribery or
  sanctions violations, must be reported to us immediately.

## 8. Legal context

<!-- Guidance: List laws as dated examples only; never promise the supplier that following the code makes them compliant with any law. Check the dates before each publication. -->

| Jurisdiction | Instrument | Status checked 2026-10-30 |
|---|---|---|
| International | UN Guiding Principles on Business and Human Rights | Endorsed 2011 |
| International | ILO Declaration on Fundamental Principles and Rights at Work | 1998, amended 2022 |
| International | OECD Due Diligence Guidance for Responsible Business Conduct | 2018 |
| EU | Corporate Sustainability Due Diligence Directive (EU) 2024/1760, as amended by Directives (EU) 2025/794 and 2026/470 (Omnibus I) | Scope narrowed to EU companies with more than 5,000 employees and more than EUR 1.5 billion net worldwide turnover, and non-EU companies with more than EUR 1.5 billion net turnover in the EU (check the consolidated text); transposition by 2028-07-26, application from 2029-07-26 |
| EU | Regulation (EU) 2024/3015 prohibiting products made with forced labour | Applies from 2027-12-14 |
| UK | Modern Slavery Act 2015, section 54 (transparency in supply chains statement) | In force; applies to commercial organisations above the turnover threshold set in regulations |
| US | Uyghur Forced Labor Prevention Act (Public Law 117-78) | Rebuttable import presumption in effect since 2022-06-21, enforced by CBP |

## 9. Supplier acknowledgement

<!-- Guidance: Collect acceptance at onboarding and on each new version. -->

| Field | Value |
|---|---|
| Supplier legal name | [Name] |
| Signed by | [Name, role] |
| Date | YYYY-MM-DD |
| Code version accepted | [1.0] |
| Exceptions or local law conflicts declared | [None, or description] |

## References

<!-- Guidance: Keep official links here so suppliers can read the source frameworks. -->

| Reference | Official source |
|---|---|
| UN Guiding Principles on Business and Human Rights (2011) | https://www.ohchr.org/sites/default/files/documents/publications/guidingprinciplesbusinesshr_en.pdf |
| ILO Declaration on Fundamental Principles and Rights at Work (1998, amended 2022) | https://www.ilo.org/ilo-declaration-fundamental-principles-and-rights-work |
| OECD Due Diligence Guidance for Responsible Business Conduct (2018) | https://www.oecd.org/en/publications/oecd-due-diligence-guidance-for-responsible-business-conduct_15f5f4b3-en.html |
| European Commission, corporate sustainability due diligence | https://commission.europa.eu/business-economy-euro/doing-business-eu/sustainability-due-diligence-responsible-business/corporate-sustainability-due-diligence_en |
| UK Home Office, Transparency in supply chains: a practical guide | https://www.gov.uk/government/publications/transparency-in-supply-chains-a-practical-guide |
| US CBP, Uyghur Forced Labor Prevention Act | https://www.cbp.gov/trade/forced-labor/UFLPA |

## Standard and licence note

Based on the UN Guiding Principles on Business and Human Rights
(2011), the ILO Declaration on Fundamental Principles and Rights at
Work (as amended in 2022) and the OECD Due Diligence Guidance for
Responsible Business Conduct (2018), summarised in original words;
laws are cited as dated examples and must be checked in their current
official text. The text is original and is not legal advice. Template
licence: MIT.