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Supplier code of conduct: the document your suppliers have to be able to follow

A supplier code of conduct sets what you require of the people you buy from. What to include, how to make it enforceable, and why long codes get signed and ignored.

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A supplier code of conduct states the standards you expect from the companies you buy from — on labour, safety, the environment, bribery, and how they treat their own suppliers in turn. It is signed at onboarding, filed, and in most companies never referred to again. That is a shame, because it is the only document that gives you a contractual basis to ask questions later, and the difference between a code that works and one that does not is almost entirely about whether a small supplier could realistically comply with it.

What a supplier code of conduct should cover

  • Labour: no forced or child labour, freedom of association, working hours, and wages that meet at least the legal minimum where the work is done.
  • Health and safety: a safe workplace, training, and the right to refuse unsafe work.
  • Environment: permits held, waste handled lawfully, and any specific requirements your own customers pass down to you.
  • Business integrity: bribery, conflicts of interest, sanctions and competition law, aligned with your own anti bribery policy rather than contradicting it.
  • Confidentiality and data, where the supplier handles anything of yours.
  • Sub-tier expectations: that they pass equivalent requirements to their own suppliers, which is where most of the real risk sits.
  • How to raise a concern, including a route that does not go through the person they deal with.

Making it enforceable rather than decorative

  1. Reference it in the contract or purchase terms, so it is a term and not an attachment.
  2. Say what happens on breach — engagement and improvement first, termination as the end of a path, not the first step.
  3. Give yourself an audit right, and use it occasionally, or the right becomes theoretical.
  4. Ask for acknowledgement from someone with authority, dated, and record when it was signed and against which version.
  5. Re-issue on material change and require re-acknowledgement, because a code signed in 2019 against a text you have since rewritten proves very little.

Length is the enemy. A forty-page code sent to a twelve-person machining firm will be signed unread, and you will have bought a signature rather than a standard. Two to four pages that a small supplier can actually implement produces more compliance than a comprehensive document produces paper.

What separates a real code from a template

  • It is proportionate: what you ask of a sole trader differs from what you ask of a multinational, and saying so is not weakness.
  • It states what you will do, not only what they must — payment terms you will honour, notice you will give, and how you will handle a problem you cause.
  • It is available in the language of the people expected to follow it.
  • It is checked somewhere: the supplier audit is where the code stops being a claim.
  • Breaches are recorded and tracked, so the picture across suppliers exists rather than living in individual buyers’ memories.

Where the code and the acknowledgements live

Ettex Records holds the signed acknowledgements against each supplier record — who signed, when, which version — which is the question that arrives during a customer audit and the one that spreadsheets answer badly. The code itself belongs with your other published policies, and where your customers require it, alongside the modern slavery statement that draws on the same supply-chain work. The supplier onboarding file is where the acknowledgement should be collected in the first place. Ettex does not audit suppliers and does not assess compliance.

Frequently asked

Do small companies need one?

If your customers ask for evidence of supply-chain standards, you need one to pass it down, and increasingly they do. It can be short. What matters is that it exists, is referenced contractually, and is acknowledged.

What if a supplier refuses to sign?

Ask why before treating it as a red flag. Refusals often come from a specific clause that is impossible in their jurisdiction or unworkable at their size — which is useful information about your code, not only about them.

How is this different from our own code of conduct?

Your internal code binds your staff; this binds companies you have no authority over, which is why it works through contract and audit rather than through management. Copying the internal one across is the most common reason supplier codes read as unusable.

AS
Written by Alex S.

Part of the Ettex team — writing about product, engineering and the future of work.

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