Supplier Code of Conduct

Last updated: 31st August 2023 

About this Code

The Sustainability Group is committed to ensuring that the principles, standards, and values we uphold as part of our own operations are also upheld by our suppliers. These principles of corporate integrity, responsible sourcing and the safety and well-being of workers are reflected in this code, which sets out the minimum standards we expect of the suppliers that we work with. 

Compliance with Laws and Regulations

We expect our suppliers to abide by all applicable laws and regulations in any jurisdictions in which they operate.

Human Rights

We expect our suppliers to comply with all applicable human rights and employment laws, including the principles recognised in the International Bill of Human Rights. 

Diversity, Inclusion and Non-Discrimination

The Sustainability Group is committed to creating a diverse and inclusive working culture and environment where people feel valued and respected. We expect our suppliers to share this ethos. 

This means striving to employ diverse teams reflective of the societies in which suppliers operate and ensuring equitable and inclusive access to opportunities and resources for all, including those who might be otherwise excluded or marginalised as a result of socio-economic circumstances, gender, race, colour, disability, neurodiversity, age, nationality, union affliction, or religion.

Suppliers should also assess and address any potential negative impact their activities may have in their local communities, providing employees and managers with direct responsibility for supply chain management and with training on the mitigation of labour abuses and discrimination. 

Inclusive Procurement 

Inclusive procurement is a process that supports the use of a range of businesses, including those that are owned and led by minority or historically marginalised groups such as women, ethnically diverse and LGBTQ+ individuals, or those with disabilities, as well as small businesses local to our operations.  

At The Sustainability Group, we are proud to put inclusion at the heart of our procurement processes by ensuring that we make every effort to support a broad range of businesses, suppliers and contractors from different backgrounds. 

To this end, we will:

  • Actively seek out suppliers from diverse backgrounds, including women-owned, minority-owned, and small businesses.

  • Provide fair and equal opportunities to all suppliers, regardless of their size or location.

  • Require all suppliers to comply with our anti-discrimination and anti-harassment policies.

  • Monitor our supply chain for any signs of discrimination or harassment, and take steps to address any issues that arise.

We believe that inclusive procurement is essential to building a more sustainable and equitable future. We are committed to working with our suppliers to create a supply chain that is open, fair and inclusive for all.

Labour Rights

We expect our suppliers to respect the rights of their workforce and to comply with all relevant labour laws and legislation. In the absence of such legislation, compliance with relevant International Labour (ILO) conventions is expected to ensure that:

  • No forced or child labour exists anywhere in the supply chain.

  • Freedom of association and the right to collective bargaining are respected.

  • Working conditions are safe and sanitary.

  • Fair pay, working hours and rest periods are provided.

  • No harassment, harsh or inhumane treatment is allowed.

Forced or Child Labour

Suppliers, wherever located, must work towards ensuring no slavery, forced or child labour or human trafficking exists in their business or at any stage of their own supply chain. All employment must be on a voluntary basis. All workers should be free to terminate their employment at any time with reasonable notice.  

Freedom of Association

Suppliers must ensure that their employees have the right to form labour unions without prior permission in order to safeguard and develop their economic and social rights. Where the right to freedom of association is restricted under law, there must be an equivalent means of independent representation for workers.

Working Conditions

Suppliers must ensure that they provide a safe, humane and sanitary working environment for their employees, meeting the requirements set out in the ILO Occupational Health and Safety Guidelines. Suppliers must also ensure that appropriate training is given to employees in safety practices and procedures, including fire protection. 

Working Hours and Wages

Suppliers should comply with local laws relevant to living minimum wages, standard working hours and employee benefits. Where these do not exist, suppliers should pay above the minimum living wage and benefits as defined by the ILO or similar initiatives. Suppliers should ensure fair remuneration for both men and women for work of equal value in accordance with local applicable laws, directives and regulations. 

Harassment and Harsh Treatment

Suppliers must ensure they provide a workplace for their employees that is free of harassment, including sexual harassment, exploitation and sexual abuse, threats, verbal abuse, and harsh or inhumane treatment.

Suppliers should also make sure they have a formal whistle-blowing policy in place that ensures protection for employees raising concerns about any historical, present or future incidents or wrongdoing, in compliance with local laws, directives and regulations. 

Anti-Corruption and Bribery 

Suppliers should perform all business dealings with integrity and transparency, complying with applicable anti-bribery, anti-lobbying, anti-money laundering and anti-corruption laws, regulations and codes, including, but not limited to, compliance with the UK Bribery Act 2010.

Suppliers should also ensure:

  • That accurate business records are securely retained for the period required by law.

  • Compliance with laws and directives providing for the protection, transfer, access and storage of personal information. This includes, but is not limited to, compliance with the General Data Protection Regulation (GDPR), the Data Protection Act 2018, and equivalent applicable legislation in other jurisdictions..

Conflicts of Interest

A conflict of interest arises when a person’s private interest interferes in any way with the interests of The Sustainability Group. To prevent or manage potential conflicts of interest, we expect our suppliers to continually recognise and avoid situations that can create an actual or potential conflict of interest when working with or on behalf of The Sustainability Group or our clients. 

Suppliers must disclose any actual conflict of interest or any interest, relationship or activity that could give rise to a conflict of interest, or the appearance of a conflict of interest, via our Conflict of Interest Register. 

Environment and Climate

The Sustainability Group is committed to reducing emissions within its own operations and expects its suppliers to make the same commitment by, at a minimum, monitoring, recording and reducing the emissions within their direct control (i.e., scopes 1 and 2 emissions). 

We expect our suppliers to adhere to all environmental legislation, regulations and all local laws in order to facilitate the protection of the environment and to have processes committed to reducing the environmental impact of their designs, operations, manufacturing processes and waste streams.

Suppliers should, wherever possible, support a precautionary approach to environmental matters and emissions, undertake initiatives to promote greater environmental responsibility and encourage the use of environmentally friendly technologies. 

Review and Audit

This code will be reviewed annually.

Date of next review: September 2024