Supplier Code of Conduct

Introduction

As signatories to the Good Business Charter (GBC), we are proud that we continue to be formally recognised as a responsible and caring business and employer. The GBC seeks to acknowledge and encourage responsible business practice. The charter covers a range of criteria such as prioritising employee wellbeing, fair tax compliance, care for the environment, and treatment of customers and suppliers. The goal is to raise awareness of those businesses that take action and introduce initiatives to benefit communities and colleagues, rather than just being profit driven. To qualify for the accreditation, firms must demonstrate commitment across 10 categories that include paying at least the real living wage, action on employee wellbeing, diversity and inclusion, sustainable practice and other Corporate Social Responsibility (CSR)

The West Brom requires its suppliers, sub-contractors, consultants and agents to at least strive to adopt the ten Components of the Charter, where appropriate, and ideally formally adopt the Charter. The ten Components are:

1. Real Living Wage - requires all employers to pay directly employed staff and regularly contracted staff the real living wage as set out by the Living Wage Foundation and for those with over 50 employees, commit to becoming an accredited Living Wage Employer within a mutually agreed time frame.
2. Fairer Hours and Contracts - requires a fair approach to zero hours contracts, including fair shift scheduling and cancellation policy, and proper consideration given to contracts with guaranteed hours.
3. Employee Well-Being - requires clear, fair and transparent policies that support and encourage employee well-being and ban unreasonable penalties for legitimate sickness.
4. Employee Representation - requires businesses to evidence how they monitor the diversity of their workforce and their commitment to close the gender, disability and ethnicity pay gaps.
5. Diversity and Inclusion - requires businesses to evidence how they monitor the diversity of their workforce and their commitment to close the gender, disability and ethnicity pay gaps.
6. Environmental Responsibility - requires businesses to commit to an environmental policy to demonstrate they are committed to reducing their environmental impact and continually improving their environmental performance.
7. Pay Fair Tax - requires businesses to commit to paying their taxes, not engage in tax avoidance and commit to be transparent in their relationship with HMRC.
8. Commitment to Customers - requires businesses to publish their commitment to their customers on their website. Businesses will be expected to gather and monitor customer feedback and report the results to their board.
9. Ethical Sourcing - requires businesses to commit to the standards set out in the Ethical Trading Initiative Base Code for sourcing through a process of continuous due diligence.
10. Prompt Payment to Suppliers - requires businesses to sign the government’s Prompt Payment Code.

Full details of the requirements of the GBC can be found here.

New and updated contracts will normally include specific reference to compliance with this Charter. Small local suppliers may be provided with some exemption relating to the documentation of procedural aspects of compliance but are expected to comply/work towards complying where appropriate.

Whistleblowing

Suppliers are actively encouraged to report inappropriate behaviour by the West Brom, its employees and its suppliers.

The West Brom will treat information seriously and, where possible, confidentially. Contractors or suppliers will suffer no consequences for bringing to the West Brom’s attention, in good faith, suspected malpractice..

The Whistleblowing Procedure for Suppliers may be accessed by clicking on this link.

Monitoring

It is an essential element of policy compliance that Suppliers monitor and ensure compliance with the ten key components of the GBC. The West Brom requires all its suppliers to complete an annual questionnaire demonstrating the supplier’s adoption of the ten components or describing the work underway to achieve compliance with the standards. The West Brom reserves the right to review the policies and documents submitted in response to this Code of Conduct. The West Brom may wish to undertake an on-site audit to validate Supplier statements and evidence offered of compliance. Requests will be made to the Supplier in advance.

Compliance

Suppliers that are fully compliant with this code will be preferred to non-compliant Suppliers. To be fully compliant Suppliers must supply documentation in support of their response.

In the event that a Supplier or a Suppliers’ subcontractor is, or becomes, non-compliant with the Code, the West Brom will work with the Supplier to achieve compliance within a reasonable period. If, however, the non-compliance is particularly grave or cannot be resolved in a reasonable period, the West Brom may review the terms of the contract, or terminate it.