Supplier Code of Conduct
Sustainable & Responsible Supplier Code of Conduct
VERSION: 1
Released: 30/10/2024
To be reviewed before: 30/10/2026
1. Introduction
CLS want our suppliers to share our commitment to sustainability and responsible business and go beyond legislative compliance, aligned with our Sustainability Strategy, Net Zero Carbon Pathway and Social Value Framework. This Code of Conduct sets out our principles and expectations of environmental, social and ethical governance performance for our suppliers. It is designed to:
- provide a basis for honest and reasonable two-way communications, making sure we work effectively together,
- help our suppliers to operate ethically and responsibly, and
- drive improved performance.
Sustainability and responsible business issues and expectations are set out under the themes of:
- Ethical working and payment practices
- Employment standards, pay, human rights, diversity and inclusion
- Modern slavery and child labour
- Health and safety
- Environmental standards
- Community and social impact
Where possible, we integrate established standards and best practice in sustainable supply chain management (e.g. BS 8903 and the Ethical Trading Initiative Base Code) to improve our performance and that of our suppliers.
This Code of Conduct is reviewed biennially to ensure that it remains effective and relevant.
2. Working with the Code of Conduct
This Code of Conduct is designed to influence the most significant and regular areas of our total spend. To ensure we are focusing in the right areas of our supply chain we have:
- set an initial minimum annual spend threshold of £100,000, and
- committed to a supply chain risk review (aligned to the sustainability and responsibility issues set out above) to identify and prioritise the areas of highest risk.
The supply chain risk review will be carried out biennially to identify the most relevant areas in our supply chain. A questionnaire, covering the issues referenced in the sections above, is then issued to highlighted suppliers. Their responses enable us to monitor any areas identified as higher risk and, where appropriate, seek further clarification and evidence to confirm adherence to this Code of Conduct. We will report our findings where it is appropriate to do so.
All major suppliers (i.e. > £100K annual contract value) are expected to read, acknowledge and comply with this Code of Conduct along with the other key aspects of our Procurement Policy. The fundamental principles apply universally, but key issues, standards and emphasis will vary depending on the type and scale of the goods or services provided. Smaller suppliers, below the threshold, will still be provided with this code of conduct and expected to identify and address any significant risks.
3. Breaches and monitoring
Where there is a breach or potential breach of relevant legislation (e.g. suspected human trafficking, health and safety, environmental, tax evasion or bribery), related to services or goods supplied to CLS, we should be notified as soon as the supplier becomes aware. We encourage suppliers to raise any concern with us via their primary CLS contact.
Furthermore, we have systems in place to monitor our supply chain for incidents of corruption, bribery or unfair, anti-competitive actions and where any such practices are identified decisive action will be taken. Alternatively, we have a formal whistleblowing policy.
4. Ethical working and payment practices
CLS aims to develop relationships with our suppliers based on mutual trust and in good faith. We expect all suppliers, directly and indirectly, working on our behalf must act in a responsible manner. We are signatories of the Prompt Payment Code and committed to fair payment.
| Minimum standards | Zero tolerance for any form of corruption, bribery anti-competitive behaviour/ actions or dishonesty, including any form of tax evasion or the facilitation of fraudulent tax evasion in our supply chain. |
| Supplier Expectations | Operate an ethical business policy which sets out how they govern their business and supply chains. |
| Ensure robust data protection and IT procedures for their business, clients and supply chains. | |
| Have the correct financial procedures in place to record all transactions in accordance with accepted accounting principles. | |
| Ensure appropriate policies, processes and procedures are in place to ensure the prevention, detection and reporting of bribery and tax evasion in their business and supply chains | |
| Unless otherwise stated we aim to pay our suppliers within 30 days or otherwise will do so in accordance with specified contract conditions. Suppliers to adopt similar payment practices throughout their supply chains to ensure fair and prompt payment. | |
| Where materials are used, source them ethically, transparently and certified to an industry standard, where appropriate |
5. Employment standards, pay, human rights, diversity and inclusion
CLS recognises the United Nations Universal Declaration of Human Rights and the core conventions of the International Labour Organization and encourages its suppliers to do the same. We are an inclusive and respectful employer that welcomes diversity and promotes equality, tolerance and teamwork and expect the same from our suppliers.
| Minimum standards
|
Comply with the relevant employee-based legislation including the Equality Act 2010 in the UK or local equivalent |
| Supplier Expectations | Fair pay practices which ensure compliance with, where applicable, Living Wage and London Living Wage including pay for overtime hours and provision of legally mandated benefits |
| Fair working time practices including monitoring employees’ working hours to meet local legal working time requirements and international working time standards | |
| No use of exclusive zero hours contracts and minimise the use of agency staff at our properties | |
| Respect the rights of employees with regards to collective bargaining, the rights of freedom of association and to communicate openly with management regarding working condition without fear of harassment, intimidation, penalty, interference, or reprisal | |
| Have appropriately documented grievance procedures which are clearly communicated and made fully available to employees. | |
| Have appropriate and robust equality and diversity policies to ensure the active promotion of employment diversity and ensure all policies are communicated to employees and training provided | |
| Have procedures in place to safeguard against bullying, harassment, and discrimination based on Protected Characteristics to protect employees ensuring that they can work safely, |
6. Modern slavery and child labour
CLS has zero tolerance towards modern slavery and child labour and expects our suppliers to uphold our high values and not use any type of involuntary or forced labour, including indentured, bonded, slave, human trafficked labour or child labour.
| Minimum standards | Comply with the relevant legislation, more specifically the Modern Slavery Act 2015 and any local equivalent |
| No use of child labour, either directly or indirectly, with the minimum age for workers no less than defined by the ILO Minimum Age Convention and in compliance with local laws | |
| Supplier Expectations | If not obliged by law to comply with the Modern Slavery Act 2015, have in place a policy that reflects the principles of the Modern Slavery Act 2015 and discourages illegal, forced or child labour. |
| Provide training for employees on Modern Slavery | |
| Have provisions in place that endeavour to ensure any supply chain participants also adhere to the Modern Slavery Act 2015 | |
| Employees must not have government-issued identification, passports or work permits of employee retained as a condition of employment and must be free to terminate their employment in accordance with established local laws and rules | |
| On request, provide reasonable access to consultants employed by CLS Holdings to undertake spot checks of policies and procedures | |
| Where legitimate work for young workers is provided (e.g. apprenticeships and internships), comply with all local legal requirements including work hours, wages and safe working conditions |
7. Health and safety
Suppliers must be committed to creating safe working conditions and a healthy environment for all their employees and subcontractors.
| Minimum standards | A Health and Safety policy statement and management system appropriate to the nature and scale of their business and services and reviewed annually (where there are 5 or more employees) |
| Ensure compliance with all relevant health and safety legislation and with minimum standards and/or codes of practice specific to their industry | |
| In our buildings and on our sites, comply with CLS Holdings health and safety standards and procedures and work with us to continually improve health and safety standards. Compliance checks will be made by our team | |
| Supplier Expectations | Provide employees with appropriate workplace health and safety information and training, including written health and safety information and warnings, in their primary language |
| Avoid using materials that are documented to be harmful to health either during their manufacture, use or disposal | |
| Identify, evaluate, control and reduce employee exposure to physically demanding tasks or environments, including manual material handling, heavy lifting, prolonged standing, highly repetitive or forceful assembly tasks, loud noise and poor light | |
| Ensure adequate occupational health services to ensure the health and wellbeing of their employees, bearing in mind the nature and size of their business. Including support for good mental health and managing impacts of work on stress and anxiety | |
| Ensure subcontractors have appropriate health and safety standards and are competent to carry out the proposed work (i.e. adequate skills, experience, knowledge, training, and resource) | |
| For main contractors at major construction and refurbishment sites register under the Considerate Constructors Scheme | |
| Where relevant, membership should be maintained to at least one Safety Schemes in Procurement (SSIP) |
8. Environmental Standards
CLS is committed to working with suppliers who maintain high environmental standards, minimise their impact on the environment as well as sharing our commitment to decarbonisation. We expect suppliers to support us in achieving the environmental objectives from our Sustainability Strategy, including our Net Zero Carbon Pathway.
| Minimum standards | Robust environmental management policies and procedures in place appropriate to the nature and scale of their business including compliance with environmental legislation as a minimum, along with any standards and codes that may be specific to their industry |
| On our development and major refurbishment projects main contractors are required to have a certified environmental management system (EMS) in place accredited to ISO14001 or EMAS (Eco-Management and Audit Scheme) | |
| report any known environmental non-compliances to us to enable prompt action. This may include issues relating to nuisances such as noise, dust and odour; spillages, fly-tipping and uncontrolled emissions to air (e.g. refrigerant leaks) | |
| Supplier Expectations | Have a strategy / plan for decarbonisation in place including measures such as: utilising certified renewable energy, implementing electric/alternative vehicles for deliveries,
facilitating employees use of sustainable transport (public transport, bicycle etc). |
| Suppliers should consider applying the principles of the circular economy through careful design, selection of materials and construction / manufacturing techniques including reducing single-use plastics | |
| Review their own supply chains to ensure products and services they source are from ethically responsible suppliers with similar controls in place. Particularly where procuring products for use in our buildings, consider sustainability credentials (e.g. responsible sourcing, environmental product declarations, A.I.S.E., Eco-label) | |
| Track their carbon emissions and other relevant environmental KPIs (e.g. waste) and set appropriate reduction targets. Including providing data associated with the provision of goods and services to us, so that we can more accurately understand and monitor our scope 3 carbon emissions and indirect waste impacts | |
| On our development and major refurbishment projects work to our Design and Construction Guidelines, to achieve relevant targets particularly in connection with the reduction of carbon, energy and waste. |
9. Community and social impact
CLS wants to create a lasting positive social impact where we operate, working closely with our local communities and we expect suppliers to proactively support us in the successful delivery of identified key outcomes of our Social Value Framework.
| Supplier Expectations | Engage with local community stakeholders, including our neighbours and occupiers, where appropriate and with our prior approval, to develop relationships and minimise disruption in particular on our developments and refurbishments |
| Offer full and fair opportunity for local suppliers to actively participate in their/our supply chains. | |
| Offer local employment and apprenticeship opportunities and working with educational establishments to help address skills shortages | |
| Support local community causes and charitable initiatives |
