Supplier Code of Conduct

Overall Objective

We wish to work with Suppliers (meaning all suppliers, contractors, consultants, agents and their staff) who demonstrate the same values and ethics as us. This Code of Conduct outlines the business behaviours we expect from our Suppliers. 

Suppliers must comply with all aspects of this Code of Conduct, notify us of any suspected breaches of it and to speak out when our staff or other Suppliers are not upholding the values embedded in it.

One Estuary

When becoming a Supplier for Estuary, you become part of the team providing services and support to our customers. The One Estuary value means, being positive, ready to help, setting high standards of delivery and taking pride in everything they do on our behalf.

Treating Employees and Customers With Respect

We value inclusiveness and we are committed to embedding equality and diversity at the heart of our work. We aim to  be an inclusive organisation, where individual differences are respected, where staff, our customers, as well as their families and carers, are treated with dignity and on the basis of their merits, abilities and needs, and where everyone has a fair opportunity to fulfil their potential without suffering discrimination or disadvantage.

We abide by the Equality Act 2010 and firmly oppose all forms of unlawful discrimination, harassment and victimisation. We expect our Suppliers to support us to achieve our aims by providing the same commitment to both the delivery of services to us and to the treatment of their own employees.

Vulnerable Service Users and Safeguarding

Some contracts deliver services to customers with particular needs such as physical or mental disabilities, medical conditions or other factors that place them in a vulnerable position. Suppliers should ensure that these customers are treated at all times with courtesy and that their dignity, safety, security and well-being is treated as a priority.

Safeguarding is everyone’s responsibility including our Suppliers. We take our Safeguarding responsibilities very seriously. As a responsible housing provider, we have an important role in to play in keeping people safe and we are committed to Safeguarding adults and children who use or are connected to our services and to protecting them from abuse or neglect.

Please see the Safeguarding section of this website for details of how to report Safeguarding concerns.

Human Right and 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 they use, also comply. This includes complying with the provisions of the Modern Slavery Act 2015.


As part of Estuary’s due diligence, we may ask Suppliers to complete a questionnaire on Modern Slavery. If a Supplier is requested to do so, this must be completed in full and submitted within 14 days after receipt by the Supplier. Any violations of the Modern Slavery Act 2015 (or any further legislation enacted relating to it or any amendments to it) may lead to termination of a Supplier's contract.

Management of Risk

We try to ensure that risk is placed with the party best able to manage it. This means requiring our prime contractors not to flow risk inappropriately to subcontractors, and not to advise us when a risk is in fact better managed by us.

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

End-to-End Delivery

Some of the services that we require are complex, and no single Supplier will have complete contractual responsibility for every element of what is needed to deliver to our customers.

We expect Suppliers to be aware of how they contribute to that overall delivery, and to work with us and other Suppliers to ensure that their product or service delivers a high quality service. When a contract is coming to an end, we also expect Suppliers to behave in accordance with required standards and be forthcoming with information and assistance in its transition to a new Supplier or contract exit.

Value

As a Public Body for the purposes of the Procurement Act, we are expected to obtain value for money from all expenditure and to be able to, where relevant, demonstrate longer-term value. This means that contracts should be priced to offer sustainable value throughout their life, including when changes are needed.

Whilst we accept our Suppliers make a profit margin in return for the risk they are accepting, Suppliers must not to exploit an incumbent or monopoly position, an urgent situation or control of capability or information to impose opportunistic pricing. We expect Suppliers to work in good faith to resolve any disputes promptly and fairly during the life of a contract through good relationship management. 

Reputation

We want to work with Suppliers who are proud of their reputation for fair dealing and quality delivery. We also want working with us to be seen as reputation enhancing for the Supplier.

We expect Suppliers to be protective of our reputation, and ensure that neither they, nor any of their partners or subcontractors, bring us into disrepute by engaging in any act or omission which is reasonably likely to diminish the high standards that our customers and the public places in us.

Cyber Security and Data Protection

It is essential that Suppliers safeguard the integrity and security of their systems and comply with the government standards and guidance. We will vet potential Suppliers, where relevant, on their data protection policies to ensure they meet ISO 27001 standards and expect Suppliers to sign a Data Sharing Agreement. 

Suppliers must inform us if they become aware of any cyber security incident or other incident that affects or has the potential to affect our data or our customers’ data.

Sustainable Procurement and Social Value

We expect our Suppliers to assist us in the understanding and reduction of supply chain impacts on our environment, the risks related to the security of raw material supply and share innovation that will minimise the environmental impact of any goods, services or works provided, working towards Net Zero.

We expect Suppliers to be open and transparent in assisting us in reporting publicly on product or service utilisation and any environmental impacts.

From time to time our Suppliers may be approached to assist us in the delivery of Social Value projects for the enhancement of environmental, economic and social benefit of our customer’s and the local community.

Confidentiality

Suppliers must comply with the provisions in their contracts and any legal requirements to protect sensitive information.

Our Suppliers 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.

Ethical Behaviour

We expect the highest standards of business ethics from Suppliers. 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.

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.

Fraud, Corruption and Bribery

Suppliers must 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 operate a zero tolerance policy towards bribery of our board members, employees, contractors, agents and other associated persons. 

Suppliers should immediately notify us where fraudulent practice is suspected or uncovered and disclose any interests that might impact their decision making or the advice that they give to us.

Conflicts of Interest

Suppliers are expected to declare any existing relationships they may have with our staff or Board Members to avoid conflicts of interest. Non-disclosure of a conflict of interest by a Supplier may lead to termination of their contract with Estuary. Conflicts of interest can be notified to procurement@estuary.co.uk.

Treatment of Subcontractors

We expect our Suppliers to deal fairly with the subcontractors in their supply chain, observing the principles of the Prompt Payment Code. We expect Suppliers to avoid flowing unreasonable levels of risk to subcontractors who cannot reasonably be expected to manage or carry these risks.

We expect Suppliers not to create barriers to the use of small and medium-sized enterprises who are qualified to provide goods or services where this increases value for money or quality of supply to us.

IR35

Where relevant, Suppliers must assist us in matters of IR35 when this is found or suspected in the delivery of the Supplier’s goods, services or works. This includes, but is not limited to, the timely communication of IR35 findings to us.