Supplier Code of Conduct | Ingenious Partners

This Supplier Code of Conduct sets out the standards we expect of everyone who supplies goods or services to Ingenious Partners. Version 1.1, 1 September 2026. Owner: Tracy Clarke, Director.

1. Purpose

This Supplier Code of Conduct sets out the standards Ingenious Partners Ltd expects of every supplier, manufacturer, distributor or other business partner (“supplier”) that supplies goods or services to us or on our behalf. It brings together, in one document, the standards already set out in our own Modern Slavery Policy, Environmental Management System, Equality, Diversity and Inclusion Policy, and Code of Conduct. We ask key suppliers to read, confirm and sign this Code when they are onboarded, and at least once every 12 months after that.

2. Our Own Checks Before and During a Supplier Relationship

Before we onboard a new key supplier, and periodically for existing key suppliers, we check the supplier’s name against the UK Sanctions List published by the UK Government, and against any equivalent list relevant to a country the supplier or its goods pass through. We do not knowingly onboard or continue to use a supplier who is subject to UK sanctions, or who we have credible reason to believe is affiliated with a sanctioned entity.

We ask suppliers to confirm, as part of this Code, that they have not been convicted of, or are not currently under investigation for, bribery, corruption or a related offence, and that any goods they supply to us are not subject to export control legislation (such as ITAR, UK Military or Dual-Use, or EU Military or Dual-Use lists) that would prevent us from lawfully supplying them to our customers, or, where they are, that the supplier has told us so. Where a supplier cannot confirm this, or where our own checks raise a concern, we record this and take it into account, alongside price and quality, when deciding whether to use or continue using that supplier, as set out in Section 11.

3. Labour Standards and Human Rights

Every supplier must meet the core labour standards of the International Labour Organization (ILO), as set out in the ILO Declaration on Fundamental Principles and Rights at Work and its fundamental Conventions. These cover freedom of association and the right to collective bargaining (Conventions 87 and 98), the elimination of forced or compulsory labour (Conventions 29 and 105), the effective abolition of child labour (Conventions 138 and 182), the elimination of discrimination in employment and occupation (Conventions 100 and 111), and a safe and healthy working environment (Conventions 155 and 187). These standards are also reflected in our Modern Slavery Policy.

In particular, work must be freely chosen, with no forced, bonded, prison or trafficked labour, and workers must be free to leave their employment on reasonable notice and to move freely in and out of the workplace. Suppliers must not hold workers’ identity documents or charge workers recruitment fees. Child labour must not be used. Workers must be paid on time, at no less than the legal minimum wage or the applicable industry standard, and working hours must comply with local law, with overtime voluntary and paid correctly. Workers must be treated with respect, free from harassment, threats or discrimination. Workers must be free to join or form trade unions and to bargain collectively, and where this right is restricted by law, suppliers must allow other means for workers to associate freely and raise concerns without fear of reprisal.

We ask suppliers to be open with us about who makes our goods and where, to tell us promptly of any subcontractor or change in place of manufacture, and to provide, where we ask for it, evidence such as a modern slavery statement, an independent factory audit (for example under amfori BSCI, Sedex or WRAP), or a signed declaration.

Suppliers must apply the standards in this Code to their own suppliers and sub-contractors involved in making goods for us, and must not sub-contract the manufacture of our goods without telling us first.

4. Health, Safety and Product Quality

Suppliers must provide a safe working environment for their own workers, and must supply goods that meet the applicable product safety standards and marking (such as CE or UKCA marking for personal protective equipment and electrical goods). Suppliers must provide us with a declaration of conformity, test certification or safety data sheet, as relevant, for the products they supply to us, and must tell us promptly of any safety concern, non-conformance, or change to the specification, materials, place of manufacture or certification of a product, in line with our Health and Safety Policy.

5. Environmental Responsibility

We ask suppliers to manage the environmental impact of their own operations responsibly, and, where they can, to hold an environmental policy or certification such as ISO 14001. Where a supplier’s product is a chemical or hazardous substance, the supplier must provide a safety data sheet and confirm compliance with REACH or an equivalent scheme. Where a supplier’s product may contain PFAS, conflict minerals (tin, tantalum, tungsten or gold) or other Critical Raw Materials, we ask the supplier to confirm this, in line with our Environmental Management System and our CSR and ESG Policy.

6. Equity, Diversity and Inclusion

We ask suppliers to treat their own workers fairly and without discrimination, and, where they can, to provide evidence of their own written approach to equity, diversity and inclusion, in line with our Equality, Diversity and Inclusion Policy.

7. Business Ethics

Suppliers must not offer, give, ask for or accept a bribe or other improper payment or advantage in connection with our business relationship, must compete fairly, and must not facilitate tax evasion. Suppliers must keep confidential any information we share with them and use it only for the purpose it was given, and must comply with data protection law where they process personal data on our behalf.

8. Raising a Concern

Any supplier, or anyone working for a supplier, can raise a concern about a breach of this Code, or about modern slavery, bribery, safety or any other matter covered by it, directly with Ingenious Partners Ltd, by writing to the Director or by email to whistleblowing@ingeniouspartners.co.uk. Reports can be made anonymously, and we will not tolerate any detriment against anyone who raises a genuine concern in good faith.

9. Monitoring Compliance

We keep an approved supplier list recording each supplier’s acceptance of this Code, the ethical audit or other labour standards evidence they have provided, and its expiry date. Before approving a garment manufacturer, we ask for evidence of an independent ethical audit, such as amfori BSCI, Sedex SMETA or WRAP, together with the location of the factories used, and we ask for updated evidence when it expires. We also check the Modern Slavery Statement of any supplier required to publish one.

Each key supplier is reviewed at least once every 12 months against this Code, their audit results, any open corrective actions, and their delivery and quality performance. We may, on reasonable notice, visit a supplier’s premises or arrange an independent audit, and we may share relevant evidence with our customers on request.

10. Responding to Labour Rights Concerns

Where a concern about labour rights is identified in our supply chain, whether through an audit, a supplier, a worker, a customer or the media, we follow these steps:

Record and assess: the concern is logged by the Director on the day it is raised and its severity assessed. Any risk to a worker’s safety, or any indication of forced or child labour, is treated as critical.
Investigate: we contact the supplier within two working days, ask for evidence and, where appropriate, an independent audit or the support of a specialist third party.
Remediate: the supplier must agree a corrective action plan with clear actions and deadlines, which we monitor until it is closed. We put the wellbeing of affected workers first, so we work with the supplier to put things right rather than withdrawing and leaving workers worse off.
Escalate: where a supplier refuses to co-operate, or a critical issue cannot be resolved, we suspend orders and move the product to an alternative approved supplier, and we report the matter to the relevant authorities where the law requires.
Inform our customers: we notify any customer whose goods may be affected immediately on becoming aware of a concern, or having reason to believe there may be one, co-operate fully with the customer’s own due diligence, and keep them informed until the concern is resolved.

11. Compliance and Review

We ask key suppliers to confirm their acceptance of this Code when they are onboarded, and to reconfirm it at least once every 12 months, alongside our other supplier due diligence. Where a supplier does not meet the standards in this Code, we raise it with them, ask for a corrective action plan with a reasonable timescale, and take this into account, alongside price and quality, when deciding whether to continue sourcing from that supplier, as set out in our Modern Slavery Policy. We may end a relationship where a concern is serious or is not resolved.

This Code is reviewed by the Director at least once every 12 months, and is provided to suppliers alongside our Modern Slavery Policy, Environmental Management System and Equality, Diversity and Inclusion Policy on request.