A large customer has asked for your supplier code of conduct. It is now a standard item in supply chain due diligence, particularly for suppliers to retail, apparel, electronics, and other consumer-facing sectors.
The document is straightforward to produce. Before you start, establish what the customer is checking: that the code exists, that it covers labor, health and safety, environment, and ethics, that it is signed, and that it reflects what you actually do.
| First question | Short answer |
|---|---|
| What is it? | A signed statement of the minimum labor, safety, environmental, and ethical standards you commit to, and expect of your own suppliers. |
| How long? | Two to four pages. Customers check for the commitments and the signature, not the word count. |
| Do I need a lawyer? | Not for a basic code. Plain language, signed by the Managing Director or CEO. |
| Is there a template? | Yes. A Word document with eight sections and highlighted placeholders, below. |
| What if the customer's own code is stricter? | You will usually be asked to accept theirs as well. Align your wording with the strictest customer you have. |
Why customers ask for it
Large companies are under pressure from investors, regulators, and consumers to show that their supply chains meet ethical standards. Increasingly the pressure is legal: Germany's supply chain act (LkSG) and the EU's due diligence directive (CSDDD) require large companies to check their suppliers' labor and environmental practice. They cannot audit every supplier, so they ask each supplier for its own code of conduct — a written commitment to minimum standards.
Providing one says: these are the standards we hold ourselves to, and we expect our own suppliers to meet them. It is a statement of practice and a contractual commitment to the customer.
What a code covers
1. Labor and human rights
How you treat workers.
- No child labor. Nobody below the legal minimum working age (typically 15–16, depending on local law). Legally employed young workers get appropriate protection.
- No forced or compulsory labor. All work is voluntary. Workers can leave with reasonable notice. No retained identity documents, no deposits.
- Wages and hours. At least the legal minimum wage (or a living wage if you commit to one). Working hours within legal limits. Overtime voluntary and paid at the premium rate.
- Freedom of association. Workers may join trade unions or worker committees and bargain collectively.
- Non-discrimination. No discrimination on race, gender, religion, age, disability, sexual orientation, or other protected characteristics. Hiring, pay, and promotion on ability.
- Dignity. No harassment, abuse, or corporal punishment. A grievance route without retaliation.
These commitments follow the International Labour Organization core conventions and the UN Universal Declaration of Human Rights. Reference them to show alignment with international norms.
2. Health and safety
- Safe conditions. Workplace risks assessed and controlled; personal protective equipment provided; equipment maintained.
- Emergency preparedness. Fire safety, emergency exits, evacuation procedures, first aid.
- Training. Health and safety training appropriate to each role.
- Incident handling. Accidents reported, investigated, and followed by corrective action.
For most suppliers this section states compliance with applicable health and safety legislation and a commitment to continuous improvement.
3. Environment
- Compliance. Applicable environmental law, including permits for emissions, waste, and discharges.
- Pollution prevention. Air, water, and soil.
- Waste. Responsible handling, recycling maximized, hazardous waste through licensed carriers.
- Resource efficiency. Reduction of energy and water consumption.
- Climate. Measuring greenhouse gas emissions and working to reduce them. Increasingly expected.
The code does not need targets; those belong in the environmental policy. It is a statement of principle and direction. If it commits to measuring greenhouse gas emissions, have a figure: the free carbon calculator produces a first estimate from energy and fuel bills.
4. Business ethics and governance
- Anti-bribery and anti-corruption. No bribes, kickbacks, or improper payments, including to public officials.
- Conflicts of interest. Declared; decisions made objectively.
- Accurate records. No falsified documents or certifications.
- Intellectual property. Respected; no counterfeit or unauthorized materials.
- Whistleblowing. Concerns reported without retaliation.
- Data protection. Customer and employee data handled responsibly; GDPR where it applies.
- Fair competition. Compliance with competition law.
5. Supply chain responsibility
Most codes extend the standards to the supplier's own suppliers: "We expect our suppliers to uphold the standards in this code. We communicate these expectations and consider ESG factors in procurement decisions." This shows the customer that responsibility cascades.
Referencing international standards
Most codes reference established frameworks:
- ILO core conventions — freedom of association, collective bargaining, forced labor, child labor, discrimination
- UN Universal Declaration of Human Rights
- UN Global Compact — ten principles on human rights, labor, environment, and anti-corruption
- OECD Guidelines for Multinational Enterprises — responsible business conduct
You do not need certification or audit against them. Stating that the code is "informed by" or "aligned with" ILO conventions or UNGC principles is sufficient.
The template
The template is a Word document with the eight sections below written in full. Placeholders are highlighted in yellow. Fill them in, delete what does not apply, remove the highlighting, sign, save as PDF.
Supplier Code of Conduct template (.docx)
Eight sections, 40 clauses, highlighted placeholders, signature block, and a one-page how-to-use note. Free, no email required.
What is in it:
- Purpose and scope — commitment statement; which frameworks the code is informed by (ILO fundamental conventions, UN Universal Declaration, UN Global Compact, OECD Guidelines)
- Labor and human rights — child labor, forced labor, wages and hours, freedom of association, non-discrimination, dignity, grievance channel
- Health and safety — legal compliance, hazard control and PPE, emergency provision, training, incident investigation, worker accommodation
- Environment — permits and compliance, pollution prevention and hazardous waste, tracking energy, water and waste, GHG measurement, responsible sourcing
- Business ethics — anti-bribery, gifts and hospitality, conflicts of interest, accurate records, competition law, intellectual property, data protection, export control and sanctions
- Our supply chain — cascading the standards to your own suppliers
- Reporting concerns — the channel, anonymity, no retaliation
- Implementation and review — communication, training, audit access, review cycle; signature block
Two adjustments most suppliers make. If a clause describes something that does not exist in your business (no shift work, no worker housing), delete it rather than leaving a commitment about nothing. If a customer's own supplier code goes further than yours — many retail and electronics codes do, on working hours or grievance mechanisms — you will usually be asked to accept theirs in addition, so align your wording with the strictest customer you have.
Finishing it in a day
Morning. Open the downloaded template and read your largest customer's own supplier code alongside it. Large companies publish theirs under "Sustainability" or "Responsible Sourcing". Note any clause where theirs is stricter.
Late morning. Fill in the brackets. Delete clauses that describe something you do not do or cannot verify. Keep it to two to four pages. Do not include commitments you cannot meet; an auditor will ask for evidence.
Midday. Check the opening: company name, effective date, and the leadership statement in section 1.
Afternoon. Confirm the framework references (ILO, UNGC, OECD) and the compliance-monitoring statement in section 8.
Late afternoon. Senior management reviews and signs. The signature of the Managing Director or CEO is what customers look for.
End of day. Save as PDF. Publish it on your website if you have a sustainability or about page. File it where it can be attached to a questionnaire.
After it exists
Communicate it. Employees, especially managers and procurement staff. Include it in the handbook or induction.
Provide it to customers. When a questionnaire asks for a supplier code of conduct, attach it.
Pass it to your suppliers. Share it with key suppliers; consider code-of-conduct clauses in supplier contracts.
Review it annually. Expectations move. Update the code each year.
Follow it. The code has value only if it reflects practice. If it commits to fair wages, pay them. If it commits to waste reduction, track waste.
Storing and managing it
You will attach the code repeatedly: customer questionnaires, RFPs, audits, supplier communications. ESG Passport keeps the signed PDF with your other evidence and attaches it wherever a questionnaire asks for a code of conduct, so every customer receives the same version. If you would rather not start from the template, its guided policy builder assembles a first draft from questions about your own practices.
Final note
A supplier code of conduct is a practical document. It tells customers you understand supply chain responsibility and commit to basic ethical and environmental standards. A small or mid-sized supplier does not need twenty pages from a law firm. It needs a clear, honest, two-to-four-page statement that it follows. Fill in the template, cut what does not apply, get it signed, publish it. Refine it as practice matures.
Official References
- ILO Declaration on Fundamental Principles and Rights at Work
- UN Global Compact — the Ten Principles
- OECD responsible business conduct guidance
- ISO 14001 environmental management