Responsible Procurement & Supplier Code

1. Purpose and intent

Sets expectations for fair sourcing, supplier integrity, labour standards, safety, environment and confidentiality. This policy is intended to provide a consistent reference for decisions, conduct and controls. It should be read alongside applicable laws, contractual obligations and relevant internal procedures. Where requirements differ, the applicable legal requirement and formally approved internal control take precedence.

2. Scope and application

Applies to personnel involved in sourcing, evaluation, negotiation, contracting, purchase approval and supplier oversight, and communicates expectations to relevant suppliers and partners.

Business partners are expected to observe equivalent standards where these are relevant to the services they provide or the activities they undertake on the organisation’s behalf. Application should be proportionate to role, activity, risk and applicable legal requirements.

3. Core principles

• Fair competition: provide a fair and consistent process where practicable.
• Integrity: prohibit bribery, kickbacks, undisclosed conflicts and bid manipulation.
• Value and suitability: assess quality, capability, service, risk and total value.
• Responsible conduct: expect lawful labour, safety and environmental practices.
• Confidentiality: protect supplier and organisational information.

4. Minimum standards and controls

The following controls describe the expected minimum approach. Specific procedures, approval limits, forms and technical controls may be established separately and updated through controlled internal documents.

• Document requirements, evaluation criteria and approvals for material procurements.
• Conduct proportionate due diligence based on supplier risk and criticality.
• Use written contracts with clear scope, deliverables, pricing, responsibilities and controls.
• Verify delivery and invoice accuracy before payment.
• Monitor critical suppliers and address material non-performance or misconduct.
• Disclose conflicts and gifts in accordance with relevant policies.

5. Roles and accountability

Requesting departments define needs; procurement or authorised personnel manage sourcing; approvers act within delegated limits; contract owners monitor delivery and supplier performance.

Any person who is uncertain about the application of this policy should seek guidance before taking action. No individual may override a legal obligation or approved control without appropriate authority and documented justification.

6. Reporting and escalation

Concerns, suspected breaches, control weaknesses and incidents should be raised promptly through the relevant management or designated reporting channel. Urgent threats to health, safety, the environment or the security of information must be escalated immediately. Reports should be handled fairly, sensitively and in accordance with applicable privacy and records requirements.

7. Monitoring, assurance and review

Supplier performance, risk assessments, exceptions, complaints, incidents and corrective actions should be documented and reviewed. High-risk suppliers may require enhanced review.

Where improvement actions are identified, they should be assigned to an accountable owner, given a proportionate target date and monitored to closure. Material changes in law, risk, organisational context or operating arrangements should trigger an earlier review.

8. Non-compliance

Failure to follow applicable requirements may result in corrective action, additional training, restricted authority, disciplinary measures, contractual remedies or referral to relevant authorities, depending on the circumstances and applicable law. Any response should be proportionate and follow fair process.

9. Related policies and standards

Anti-Bribery; Conflicts of Interest; Human Rights; QHSE; Records Management.

Additional policy requirements

The following provisions expand the practical expectations set out in this policy. They should be applied in conjunction with applicable law, approved internal procedures, contractual obligations and the circumstances of each activity.

Planning and competition

Procurement should begin with a defined need, proportionate specification, budget confirmation and approval. Competition should be encouraged where practicable. Exceptions to competition should be justified, authorised and recorded.

Supplier due diligence

Supplier assessment should be proportionate to value, criticality and risk. Relevant checks may include legal identity, ownership, capability, financial resilience, licensing, insurance, sanctions, conflicts, safety performance, data protection and human-rights or environmental risks.

Evaluation and award

Evaluation criteria should be established before bids are assessed and applied consistently. Decisions should consider total cost, quality, delivery, lifecycle performance, risk and compliance rather than price alone. Evaluators must disclose conflicts and maintain confidentiality.

Contract management

Contracts should define scope, deliverables, service levels, pricing, change control, records, confidentiality, data handling, audit rights where appropriate, incident notification and exit arrangements. Variations must be approved before implementation except where urgent action is necessary to protect people or assets.

Supplier performance

Critical suppliers should be monitored against agreed requirements. Material non-performance should be documented, discussed and addressed through corrective plans or contractual remedies. Repeated or serious failures may result in suspension or termination.

Ethical conduct

Personnel must not solicit or accept improper benefits from suppliers. Supplier information must be protected and used only for legitimate procurement purposes. Undisclosed arrangements, bid manipulation and collusion are prohibited.

10. Document governance

This web page is a public policy statement. The controlled internal version, where formally approved, is maintained through the organisation’s document-control process. Approval status, document owner, effective date, review cycle and revision history must be confirmed in the controlled document register before this text is represented as a formally issued internal policy.