Supplier Code of Conduct

1. comply with applicable law and contractual requirements;
2. work only within their competence, insurance and permissions;
3. protect workers, customers, the public and the environment;
4. prohibit bribery, fraud, forced labour, child labour and unlawful discrimination;
5. provide lawful pay, hours and working conditions;
6. maintain accurate records, certificates and invoices;
7. protect confidential and personal information;
8. disclose conflicts and material incidents;
9. use approved subcontractors only with permission;
10. cooperate with reasonable checks, audits and corrective action; and
11. avoid making unauthorised statements or using Black & White branding without written permission.

Suppliers provide suitable risk information, competent people, supervision and equipment. They stop and report unsafe or environmentally harmful work and comply with site, waste and emergency arrangements.

Information is used only for the authorised purpose, protected against loss or misuse and returned or deleted when required. Suspected data or security incidents are reported without undue delay.

Suppliers disclose who will perform the work and must not subcontract material obligations without approval. Credentials and experience must be represented accurately.

Suppliers must use freely chosen labour, prohibit recruitment fees charged to workers, retain no identity papers unlawfully, permit lawful freedom of movement, prevent child labour and provide lawful wages, working time, rest and employment documentation. They must not discriminate, harass, threaten, exploit or retaliate and must provide a safe route for concerns.

Work must be properly planned, supervised and delivered by competent people using suitable equipment and materials. Suppliers cooperate on risk assessment, permits, isolations, asbestos and hazardous-substance information, public protection, safeguarding, emergencies and incident reporting. Accidents, near misses, enforcement, significant defects and unsafe conditions connected with the work are reported promptly.

Suppliers prevent bribery, fraud, tax evasion facilitation, collusion, conflicts and improper gifts; comply with applicable sanctions and competition rules; and keep complete and accurate records. Confidential, customer and personal information is used only for the authorised purpose, protected appropriately and not passed to an unapproved subprocessor.

Environmental duties include preventing pollution, lawful waste handling, responsible materials and accurate environmental claims. Subcontractors may be used only as permitted and must receive equivalent relevant obligations. The supplier remains accountable for its chain and must provide reasonable evidence, cooperate with reviews and remedy identified failures.

A breach may result in investigation, corrective action, suspension, termination, recovery of loss or referral to an authority. Responses are proportionate to risk and seriousness.

Approved by David Swaddle, Founder, on 30 August 2026.