Supplier Code of Conduct

Introduction

This Supplier Code of Conduct (our “Supplier Code”) aims to cover key areas and expected behaviours from our suppliers in order to ensure clear and strong partnerships within the supply chain of the Nicholls & Clarke Group (“N&C”). We encourage our suppliers to engage in constructive dialogue with us regarding our Supplier Code and doing business together. If any of the below expectations are not met, you must inform us immediately.

This Supplier Code applies to providers of goods and services – and their employees – in their work with N&C through a contractual agreement. The group that we collectively call “suppliers” includes suppliers, subcontractors, service providers, professional service providers, consultants, intermediaries and agents.

As an N&C supplier, you’ll be required to acknowledge the significance of social, environmental and ethical matters in your conduct, and to work towards improving your quality standards and performance in these areas. Therefore, we encourage and expect the adoption of responsible behaviour throughout your supply chain. You must be able to demonstrate full visibility and understanding of your supply chain.

As a minimum, we expect you to be able to demonstrate compliance with all UK, EU and international legislation that applies to your business operations from Modern Slavery, Anti-Bribery, Corporate Criminal Offences (“CCO”) and Health & Safety laws to product-specific regulations. It is your responsibility to make sure that all relevant staff within your organisation, and any sub-contractors or other third parties that work for us on your behalf, are aware of all the requirements. Customs or local practices never take precedence over legal requirements.

Anti-Corruption and Anti-Bribery

We are committed to conducting business with a high level of integrity, and we do not tolerate any form of bribery or corruption, including embezzlement, money laundering, kickbacks, extortion, fraud, nepotism (family) or cronyism (friends). We expect you to conduct business with integrity, and that you, likewise, do not tolerate any form of bribery or corruption. We expect CCO to have been reviewed and assessed in line with the HMRC guidance and that you have suitable prevention measures in place based on your risk assessment.

Fair Working Conditions

We support recognised global human rights and fair working conditions for persons working within N&C and in our supply chain. We require you to have zero tolerance for any form of human trafficking or child, forced or compulsory labour. A copy of our Modern Slavery Policy can be found on our website Nicholls & Clarke Ltd.

Health & Safety

We care for our people and the people affected by our workplaces, and we continuously strive to develop a work environment that promotes health, safety and well-being. We expect you have effective methods of monitoring the Health & Safety standards of both your employees and third party providers and for you to ensure that your employees and others in your supply chain are adequately trained and provided with the proper equipment to safely carry out their work.