What is a supplier code of conduct?
A supplier code of conduct is a buyer's minimum operating rules for its providers. It normally covers labour and human rights, health and safety, environmental controls, business ethics, records, and your use of subcontractors. Check the code's effective date and the legal entity, site, product, or service named in your contract or onboarding request.
The March 2025 Google Supplier Code of Conduct requires suppliers under section 1.2 to cooperate with information requests or audits and maintain records, while section 6 requires a management system with risk assessment, training, monitoring, and corrective action.
Why does a supplier code of conduct matter to you?
A buyer may incorporate its code into a master agreement, purchase order, portal acceptance, or signed acknowledgement. Amazon's June 2024 Supply Chain Standards Manual says a commitment to its standards is included in all purchase or service agreements. After Amazon sends the Final CAP report, the supplier must complete and return its corrective action plan within 20 business days.
Accenture's 2025 Supplier Standards of Conduct section 1.2 asks suppliers to provide requested information on environmental commitments and progress and complete its Sustainability Assessment on time. A broad sustainability policy will not answer a request for a target, reporting period, calculation file, permit, training record, or corrective action.
How does a supplier code of conduct work?
- Confirm applicability: record the code version, contract reference, covered entity and sites, due date, and any clauses that must reach your own suppliers.
- Build a clause matrix: give every numbered requirement an owner, control, supporting document, reporting period, and status of met, gap, remediation, or not applicable.
- Test the records: match working-hours clauses to time and payroll records, environmental clauses to permits and waste records, and ethics clauses to training, declarations, and incident logs.
- Close gaps honestly: name the missing control, responsible person, action, and completion date instead of signing an unqualified compliance statement.
Keep the signed code, clause matrix, source records, submissions, audit findings, and corrective action plans together. That file lets you answer the next audit or annual update using the same clause numbers and document dates.
What mistakes should you avoid?
- Signing before checking whether the code covers subcontractors, labour agencies, or sub-tier material suppliers.
- Sending a policy as proof of performance when the clause asks for time records, permits, emissions data, training logs, or incident records.
- Reusing another buyer's response without checking the current version, reporting period, site boundary, and requested submission method.
- Claiming full compliance while an audit finding or corrective action remains open.
Is a supplier code of conduct mandatory?
Check the document that brought it to you. A code may be binding because your contract, purchase order, portal terms, or signed acknowledgement incorporates it. It does not replace applicable law, and some buyer requirements can be stricter than the legal minimum. Google section 1.1 separates code duties, applicable laws, and contract obligations.
Is a supplier code of conduct the same as a questionnaire?
No. The code states the rules; a supplier self-assessment questionnaire asks how you meet them and which records support your answer. Google section 1.2 permits information requests and audits, while Accenture section 1.2 names its Sustainability Assessment as a separate response step.
What should you send when a customer asks about its code?
Send the requested acknowledgement plus a clause-by-clause response for the named entity, sites, and period. Attach only the relevant policies, permits, certificates, training logs, performance data, audit reports, and corrective action records. Mark exclusions and open gaps clearly, and protect personal or commercially sensitive records before submission.