1. Our Commitment
West Brom is committed to operating as a responsible business that delivers positive outcomes for customers, colleagues, communities and the environment. We require our suppliers to uphold equivalent standards, consistent with B Corp principles of accountability, transparency and stakeholder impact.
This Code sets out the minimum mandatory requirements for all suppliers, contractors and partners.
2. Scope
This Code applies to all suppliers and their supply chains. Suppliers should:
- Comply with this Code in full; or
- Demonstrate clear, timebound plans to achieve compliance
Suppliers should ensure these standards are communicated, implemented and enforced across subcontractors.
3. Ethical Business & Governance
Suppliers are asked to:
- Act with integrity, transparency and accountability
- Comply with all applicable laws and regulations
- Maintain effective controls to prevent bribery, corruption and fraud, in compliance with the Bribery Act 2010
- Not offer, give or accept bribes or improper incentives
- Ensure gifts and hospitality are proportionate and appropriate
- Pay all taxes properly due and not engage in artificial tax avoidance
4. Fair Work, Pay & Inclusion
Suppliers should:
- Pay at least the Real Living Wage to employees and regularly engaged workers, and work towards accreditation where applicable
- Provide fair working hours, reasonable notice of shifts and secure terms of employment, avoiding inappropriate use of zero-hours contracts
- Maintain policies that support employee wellbeing without punitive practices
- Promote equality, diversity and inclusion, including monitoring and addressing pay gaps where applicable
- Respect freedom of association and employee voice
5. Human Rights & Modern Slavery
Suppliers should:
- Prohibit all forms of modern slavery, forced labour and human trafficking
- Comply with the Modern Slavery Act 2015 where applicable
- Maintain due diligence processes to identify and mitigate risks
- Notify West Brom promptly of any actual or suspected breaches
6. Environmental Responsibility
Suppliers should:
- Maintain an environmental approach proportionate to their operations
- Reduce emissions, waste and resource consumption
- Continuously improve environmental performance
- Support the transition to a low‑carbon, sustainable economy
7. Responsible Supply Chains
Suppliers should:
- Apply ethical sourcing practices aligned to the ETI Base Code
- Conduct risk-based due diligence on labour, human rights and environmental issues
- Take timely corrective action where issues are identified
8. Customers, Communities & Fair Dealing
Suppliers should:
- Treat customers fairly and transparently
- Maintain processes to capture, monitor and act on customer feedback
- Consider the impact of their operations on communities and wider society
- Pay their own suppliers promptly, and where applicable comply with the Prompt Payment Code
9. Data Protection & Security
Suppliers should:
- Comply with UK GDPR and Data Protection Act 2018
- Protect personal and confidential data through appropriate controls
- Process data only on authorised instructions
- Report any data breaches immediately
10. Speak Up
Suppliers should:
- Encourage the reporting of concerns relating to unethical or unlawful behaviour
- Ensure individuals raising concerns are protected from retaliation
11. Monitoring, Assurance & Enforcement
Suppliers should:
- Provide periodic confirmation of compliance
- Supply evidence upon request
- Cooperate with audits and reviews
Where non-compliance is identified, suppliers should implement agreed remedial actions within defined timeframes.
West Brom reserves the right to apply contractual remedies or terminate relationships where issues are serious or unresolved.
12. Proportionality
A proportionate approach may be applied for smaller suppliers; however, all suppliers should meet the principles of this Code and be able to demonstrate ongoing improvement.
