Supplier Code of Conduct

We are committed to conducting our business ethically, responsibly, fairly and lawfully and to ensuring that the Suppliers that we work with do the same. Therefore, we have developed this Supplier Code of Conduct (the “Code”) which sets out the minimum standards that we expect our Suppliers to meet. This Code is not exhaustive and is not intended to replace our Suppliers own principles or codes. However, by conducting business with us, our Suppliers undertake to adopt behaviours and practices that are consistent with this Code.

We have a zero tolerance approach to fraud, bribery, corruption, modern slavery and dishonesty. Should we find that our Suppliers are failing to adhere to the minimum standards set out in the Code, we may seek to terminate our relationship with them.


Working in a spirit of co-operation

  • Suppliers should communicate with us and their regulators in a timely, open and honest manner.

Adherence to laws & regulations

  • Suppliers should comply with all laws and regulations that apply to their business.
  • Where the minimum standards set out in this Code differ from local law and regulation, Suppliers should respect these minimum standards within the context of their local legal obligations.

Confidential Information & Personal Data

  • Suppliers must respect The SR Group’s confidential information and only use it for the purpose it is disclosed to the Supplier.
  • Suppliers should have appropriate systems in place to protect personal data which should include staff training and robust IT controls.

Anti-Bribery, Corruption, Gifts & Hospitality

  • Suppliers should adhere to all laws and regulations relating to anti-corruption including the Bribery Act 2010 (UK) and the Foreign Corrupt Practices Act 1977 (US) and should have adequate procedures in place to prevent any of its own suppliers or other associated persons committing offences under this legislation.
  • Suppliers must prohibit extortion, bribery, facilitation payments and other improper inducements.
  • Suppliers must not offer gifts or hospitality to any SR Group personnel either with the intention of (or where it could be considered that there is an intention to) improperly influence decision making.

Anti-Competitive practices

  • Suppliers should not engage in anti-competitive practices. For example, enter into agreements that limit or share control of markets or fix market prices or conditions.
  • Conflicts of Interest
  • Suppliers must avoid conflicts of interest and declare any relationship between their personnel and The SR Group employees that creates or may appear to create a conflict of interest.

Compliance with Tax Obligations

  • Suppliers must comply with all tax obligations and not participate in tax evasion or facilitate the evasion of tax by others. Suppliers should ensure that all who act for or on their behalf also comply with such obligations.

Sustainability & Environmental Protection

  • Suppliers should act in accordance with all applicable environmental laws, regulations and standards and should be able to demonstrate evidence of their commitment to sustainability and the environment.


Discrimination & Harassment

  • Suppliers’ workplaces should be free from bullying, harassment, abuse and inappropriate behaviour.
  • Suppliers should treat their employees, clients and third parties equally and with fairness and respect irrespective of their gender, gender identity, sexual orientation, race, colour, ethnic or national origin, social origin or status, employment status, age, beliefs, disability, political convictions, pregnancy, marital status or any other protected class or characteristics under applicable law.

Compliant Working Hours & Wages

  • Suppliers should pay fair wages which are at least the minimum legal wage.
  • Suppliers should ensure that working hours are not excessive and comply with local laws.
  • Suppliers should ensure that all work (including overtime) is undertaken voluntarily.

Freedom of Association, Avoidance of Child Labour & Modern Slavery

  • Suppliers should respect their employees’ rights to exercise freedom of association.
  • Suppliers must ensure that all employees satisfy the minimum age requirements set by local laws.
  • Supplier must not engage in or support the use of child, forced or obligatory labour or human trafficking and must otherwise comply with the Modern Slavery Act 2015 and all other child labour laws.

Complaints mechanism

  • Suppliers should have formal complaints and whistleblowing mechanisms in place which allow employees to raise concerns or grievances without intimidation or fear of retaliation.

Health and Safety

  • Suppliers must comply with the requirements of all applicable health and safety laws and regulations and manage any health and safety risk.

Due Diligence, Monitoring & Consequences of Breach of this Code

  • Suppliers must co-operate with The SR Group’s due diligence requests and share any reasonably requested documentation.
  • Suppliers should monitor and document their own compliance and inform srgsuppliercontracts@thesrgroup.com if they are non-compliant with any of the basic standards set out in this Code.
  • The SR Group reserves the right to audit the Suppliers’ policies and procedures and may require Suppliers to conduct an annual self-certification against this Code.
  • The SR Group reserves the right to take such action as we, in our sole discretion, deem appropriate should any Supplier not meet the standards set out in this Code which may include termination of our agreement with the Supplier.

If you have any queries about this Code please contact srgsuppliercontracts@thesrgroup.com.

This Code is effective from 1 July 2021 and applies to all Suppliers who work with any of The SR Group companies (details of these legal entities can be found at the end of our Privacy Policy). We reserve the right to change the Code to reflect any changes in laws or standards and any amendments that we make shall be binding on our Suppliers. Our Suppliers are encouraged to check our website regularly for the most recent version of the Code which shall apply to them.