Supplier Code of Conduct

Procurement Supplier Code of Conduct

Our aim is to deliver for our customers on a range of commitments, in delivering against our commitments we must ensure adherence to the highest standards of ethical and professional behaviour.

Our relationships with our suppliers are critical to successful performance.

This Supplier Code of Conduct sets out behaviours that we expect of suppliers who are delivering services on to and on behalf of GB Group. In selecting suppliers, GB Group performs checks that are in line with procurement regulations that guarantee fair access to opportunities for all suppliers and equal treatment during selection processes. In additional GB Group suppliers are subject to stringent Information Security and Data Compliance checks.

We expect our suppliers, in delivering services, information or goods to act in a manner that is compatible with GB Group values.

We expect our employees to treat suppliers with fairness and respect. Our expectation is that everybody comes to work every day determined to do a good job. In return we expect suppliers to treat our employees in the same way, and seek to build trusting and effective collaborative relationships that are focused on delivering for the public. 

This code is intended to be used by all GBG Group employees in their relationships with suppliers. As a statement of good practice it should be read both by current and aspiring suppliers and by any subcontractors in the supply chain.

We expect our suppliers to communicate this code of conduct to employees, any parent company, subsidiaries and subcontractors.

Our staff and service users have the right to respectful treatment. We will not tolerate discrimination, harassment or victimisation in the workplace, and we expect our suppliers to provide the same commitment, including to their own employees. The Equality Act 2010 protects against discrimination, harassment and victimisation.

Occupational Safety & Health

Suppliers must comply with all applicable safety and health laws and regulations, and identify, evaluate and control worker exposure to safety and health hazards, including chemical, biological, physical and ergonomic stressors, through proper design, engineering controls, maintenance, safe work procedures and ongoing health and safety guidance.

Suppliers will implement procedures to prevent, manage, track and report occupational injury and illness, including encouraging worker reporting, classifying and recording cases, providing medical treatment, investigating cases, implementing corrective actions and facilitating workers’ return to work.



Professional behaviour

We expect suppliers to be prepared to invest in their relationships with GB Group and establish trust with our staff and with other suppliers involved in delivery.

We also expect suppliers to be able to speak out when internal staff or other suppliers are not upholding the values of GB Group. We also expect suppliers to speak out, without fear of consequences, when a project or service is unlikely to succeed because of our behaviours or a lack of good governance. We expect the same behaviour when a contract is no longer fit for purpose, e.g. in its contractual stipulations or measures.


Human rights & employment law

Suppliers must comply with all applicable human rights and employment laws in the jurisdictions in which they work and have robust means of ensuring that the subcontractors in their supply chain also comply.

Suppliers will not use or permit any form of forced, bonded or indentured labour. All work must be voluntary, and all workers must be free to terminate their employment at any time.

Suppliers will not hold workers’ identity, immigration or work permit documents longer than reasonably necessary for administrative processing. As part of the hiring process, suppliers are expected to give each worker a written agreement describing the worker’s terms of employment in a language understood by the worker and, if internationally relocating, the written agreement will be provided before they leave their country of origin.

This includes complying with the provisions of the Modern Slavery Act 2015. a lack of good governance. We expect the same behaviour when a contract is no longer fit for purpose, e.g. in its contractual stipulations or measures.


Continuous improvement

We expect our suppliers to use recognised industry practices in the delivery of goods and services to, or on behalf of, GB Group.

We also expect suppliers to continuously improve these goods and services and bring worldclass innovation, ideas and expertise.


Information security

It is essential that suppliers safeguard the integrity and security of their systems and comply with the relevant GB Group Information Security standards and guidance including but not limited to the latest ISO27001 and ISO27002 ISO standards, OWASP (, Cloud Security Alliance (, etc.

Suppliers must inform GB Group without undue delay if they become aware of any information security incident that affects or has the potential to affect GB Group data. Refer to GB Group’s ‘ISMS-029 Third-Party Information Security Policy’ for additional information. Suppliers will respect intellectual property rights, and will conduct technology and knowhow transfers in a manner protecting intellectual property rights. 



Suppliers are expected to comply with the provisions in their contracts (including NDA) and any legal requirements to protect sensitive information.

Suppliers to GB Group may also be party to confidential information that is necessary for them to be effective partners. This information, even if it is not covered by contractual provisions, should be handled with the same care as information of similar sensitivity in the supplier’s own organisation.


Conflicts of interest

We expect suppliers to mitigate appropriately against any real or perceived conflict of interest. A supplier with a position of influence gained through a contract should not use that position to unfairly disadvantage any other supplier or reduce the potential for future competition, for example by creating a technical solution that locks in the supplier’s own goods or services.


Standards of behaviour, Ethical behaviour

We expect the highest standards of business ethics from suppliers and their agents in the supply of goods and services.

We expect suppliers to be explicit about the standards they demand of executives, employees, partners and subcontractors and to have the governance and audit processes to monitor and enforce these standards.


Counter fraud & corruption

We stipulate that suppliers adhere to anti-corruption laws, including but not limited to the Bribery Act 2010, and anti-money laundering regulations.

We expect suppliers to have robust processes to ensure that the subcontractors in their supply chain also comply with these laws. We have zero tolerance of any form of corrupt practices including extortion and fraud that we become aware of and we expect suppliers to be vigilant and proactively look for fraud, and the risk of fraud, in their business. Suppliers should immediately notify GB Group where fraudulent practice is suspected or uncovered and disclose any interests that might impact their decision making or the advice that they give to GB Group.


Corporate Social Responsibility

We expect our suppliers to be good corporate citizens.

By upholding the values of this code and supporting corporate social responsibility policy areas, such as diversity and inclusion, sustainability, prompt payment, small and medium sized enterprise engagement, apprenticeships and skills development.



We expect our suppliers will cooperate with any information requests or audits that we may initiate to confirm their fulfilment of these responsibilities.

Though we seek to work with suppliers to improve conditions, we may terminate our relationship with any supplier that fails to meet these responsibilities.


Management of risk

We look to our supplier to ensure risk is placed with the party best able to manage it.

All parties should also be prepared to share intelligence of supply chain risks, so that material commercial and operational risks can be mitigated.



The overall objective of this Supplier Code of Conduct is to drive improved performance by building trusting and open relationships with our supply base.

Suppliers who provide goods or services are expected to comply with all aspects of this code. Suppliers should be open and transparent with GB Group in relation to breaches or suspected breaches of this Supplier Code of Conduct and should promptly notify GB Group of any such breach.

If non-compliance with the requirements of this code is reported or alleged, the first step is for GB Group to discuss it with the respective supplier. If that does not result in a return to compliance, or in cases where the breach is sufficiently grave, GB Group will take appropriate steps in accordance with contractual obligation to bring the engagement to a close and thus preventing further harm.