Code of conduct for suppliers

In order to ensure equality and fairness through the supply chain, the BFI requires its suppliers to adhere to the following code of conduct, which is based on the Ethical Purchasing Policy developed by Oxfam and incorporates International Labour Organisation conventions.

Labour standards

Employment is freely chosen

Workers are not required to lodge ‘deposits’ or their identity papers with their employer and are free to leave their employer after reasonable notice.

Freedom of association and the right to collective bargaining are respected

Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively. The employer adopts an open attitude towards the legitimate activities of trade unions. Workers representatives are not discriminated against and have access to carry out their respective functions in the workplace. Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.

Working conditions are safe and hygienic

A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment. Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers. Access to clean toilet facilities and potable water and, if appropriate, sanitary facilities for food storage shall be provided. Accommodation, where provided, shall be clean, safe and meet the basic needs of the workers. The company observing the standards shall assign responsibility for health and safety to a senior management representative.

Child labour shall not be used

There shall be no new recruitment of child labour. Companies shall develop or participate in and contribute to policies and programmes which provide for the transition of any child found to be performing child labour to enable her/him to attend and remain in quality education until no longer a child. Children and young people under 18 years of age shall not be employed at night or in hazardous conditions.

Living wages are paid

Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmarks, whichever is higher. In any event wages should always be high enough to meet basic needs and to provide some discretionary income. All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time they are paid. Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the express and informed permission of the worker concerned. All disciplinary measures shall be recorded.

Working hours are not excessive

Working hours comply with national laws and benchmark industry standards, whichever affords greater protection. Overtime shall be voluntary, shall not be demanded on a regular basis and shall always be compensated at a premium rate.

No discrimination is practised

There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.

Regular employment is provided

To every extent possible work performed must be on the basis of a recognised employment relationship established through national law and practice. Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, sub-contracting or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment.

No harsh or inhumane treatment is allowed

Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.

No slavery, servitude, forced or compulsory labour, or human trafficking is taking place

As part of the Modern Slavery Act 2015, commercial organisations with a UK presence and a global turnover of £36m or above will be required to publish an annual statement of the steps it has taken for each financial year that ends on or after 31 March 2016. For these purposes, turnover means the amount derived from the provision of goods and services falling within the ordinary activities of the organisation or its subsidiaries, after deduction of i) trade discounts, ii) VAT and iii) any other taxes. The statement must disclose what steps the organisation has taken to ensure that slavery and human trafficking is not taking place in any of its supply chains or in any part of its business.

Regardless of turnover or location, the BFI will expect its suppliers to publish an annual statement which, dependent on each suppliers own individual circumstances, covers all or part of the below and / or any other areas deemed relevant to that particular supplier:

  • A brief description of the supplier’s business model and supply chain relationships;
  • Policies relating to modern slavery, including due diligence and auditing processes implemented;
  • Its due diligence processes in relation to slavery and human trafficking in its business and supply chains; 
  • Training available and provided to those in (i) supply chain management and (ii) the rest of the supplier’s organisation;
  • The principal risks related to slavery and human trafficking including how the supplier evaluates and manages those risks in their organisation and their supply chain; and
  • Relevant key performance indicators (key performance indicators are measures that will assist the reader of a slavery and human trafficking statement to assess the effectiveness of the activities described in the statement).

If the supplier has a global turnover of £36m or above, the annual statement should have been approved internally and published in accordance with the Modern Slavery Act 2015 requirements.

Environmental standards

Suppliers should as a minimum comply with all statutory and other legal requirements relating to the environmental impacts of their business. Detailed performance standards are a matter for suppliers, but should address at least the following:

Waste management

Waste is minimised and items recycled whenever this is practicable. Effective controls of waste in respect of ground, air and water pollution are adopted. In the case of hazardous materials, emergency response plans are in place.

Packaging and paper

Undue and unnecessary use of materials is avoided and recycled materials used whenever appropriate.


Processes and activities are monitored and modified as necessary to ensure the conservation of scarce resources, including water, flora and fauna and productive land in certain situations.

Energy use

All production and delivery processes, including the use of heating, ventilation, lighting, IT systems and transportation are based on the need to maximise efficient energy use and to minimise harmful emissions.