Supplier Code of Conduct

1. Purpose

This Code sets out the standards the Group expects of its suppliers, contractors and service providers and of their own supply chains. Compliance is a condition of doing business with the Group. Where this Code is not referenced in a contract, the terms of that contract apply.

Procurement is a collaboration, not only a transaction: the Group selects suppliers transparently and expects them to manage their own supply chains responsibly.

Brand. A supplier may not disclose that it supplies the Group without the Group’s prior written consent. The Group does not endorse or recommend any supplier’s brand, product or service.

2. Standards

• Law and ethics — comply with all applicable laws; act with integrity.
• Anti-bribery — no bribes, facilitation payments or improper advantages (Bribery Act 2010).
• Sanctions and financial crime — no dealings with persons subject to UK, EU, UN, US or Swiss sanctions; cooperate with the Group’s screening.
• Human rights and labour — no forced, bonded or child labour, no human trafficking (Modern Slavery Act 2015); fair wages and working hours; freedom from discrimination and harassment.
• Data protection and security — process personal data only on the Group’s instructions and under a written agreement (Art. 28 GDPR); protect information to an appropriate standard; report incidents without delay.
• Confidentiality and intellectual property — protect the Group’s confidential information and respect its rights.
• Conflicts of interest — disclose any relationship that could create a conflict.
• Environment — reduce environmental impact where practicable; make no unsupported environmental claims.

3. Verification

The Group may request information, carry out due diligence and require corrective action. Serious or repeated breaches may lead to termination.

4. Raising concerns

Suppliers and their workers may report concerns through the confidential disclosure channel, anonymously if they wish.