Supplier Code of Conduct

1. Policy Author
This document was created by Ben Dawson, Commercial & Transformation Director. For questions, suggestions or improvements to this document please contact

2. Introduction & Purpose
HCML aims to work with suppliers who align with our values and support our goals. We expect our suppliers to adhere to all relevant legislation, deliver evidence-based clinical services, and to act responsibly, fairly, ethically and safely at all times. These principles form an integral part of our sourcing activities and decisions. Our Supplier Code of Conduct sets out the behaviours and high standards we expect from our suppliers and their sub-contractors.

3. Legal & Regulatory Standards
HCML requires our suppliers to comply with all laws and regulations applicable to its business and seek commitments from their own supply chain to also meet this requirement.

4. Human Rights
HCML is committed to upholding all laws relating to the protection of human rights including but not limited to the UN Universal Declaration of Human Rights. In line with our Modern Slavery policy, we are committed to preventing slavery and human trafficking from taking place in our supply chain.

We expect our suppliers and their subcontractors to:

  • Prohibit human trafficking and child or forced labour including modern slavery
  • Comply with all applicable wage and working regulations
  • Embrace diversity, fairness and inclusion in their workforce/workplace
  • Support freedom of association in line with local regulations
  • Act ethically and with integrity and require their employees to do the same
  • Have robust policies in place that require their employees to adhere to relevant regulations and treat their own employees fairly and ethically
  • Have the ability to demonstrate robust procedures (appropriate for the size of their organisation) are in place to be confident that child labour, slavery or human trafficking is excluded from their supply chain.

5. Ethical Sourcing and Behaviour
HCML expects all our suppliers to conduct business with integrity and incorporate the ethical and responsible behaviour and sourcing of goods into their processes and governance whilst complying with all relevant legislation. Suppliers will be expected to have appropriate policies (relative to the size of their organisation) in place to demonstrate robust governance.

6. Bribery & Corruption
HCML expects our suppliers to operate with integrity, comply with the Bribery Act 2010, and have appropriate policies in place to prevent fraud, bribery and corruption, money laundering, tax evasion and any other improper payments, or inducements within its business and seek to only work with suppliers that demonstrate similar commitments. Suppliers must not directly or indirectly offer improper payments or inducements to HCML employees that may give rise to actual, potential, or perceived conflicts of interest or engage in any other unethical behaviour.

7. Diversity & Inclusion
HCML expects our suppliers to abide by all relevant equality legislation and not discriminate based on age, sex or sexual orientation, gender identity, disability, origin, race, colour, religion or belief in any employment or hiring practices.

8. Health & Safety
HCML expects suppliers to provide a safe and healthy working environment for their employees which meets the requirements of all applicable occupational health and safety regulations and abide by all local laws and regulations including the Health and Safety at Work Act 1974.

Suppliers should ensure their employees receive the appropriate safety instruction and training to keep them safe and well in the workplace and have business management practices in place to address:

  • Health and Safety Policy administration
  • Hazard identification, risk assessments and relevant procedures
  • Fire safety and emergency evacuation procedures
  • First aid and accident reporting procedures
  • Ergonomics
  • Clean and safe working conditions

9. Environment
HCML recognises the role we play in protecting the environment and minimising our environmental impact. We expect suppliers to work together with their supply chains to appropriately minimise the environmental impact of their operations and ensure business practices meet all applicable environmental laws and regulations. We require our suppliers to comply with all applicable environmental legislation and regulations.

10. Confidential Information
HCML expects any information received by a supplier from HCML to be held securely with appropriate technical and organisational security in place to safeguard that information to ensure there is no disclosure of the data to any other party without our permission.

11. Clinical Suppliers – Standards, Registration and Evidence
Where HCML’s supplier provides clinical treatments and/or services, the supplier shall use reasonable care, skill and diligence in providing and administering such services in accordance with evidence based practice using appropriately experienced, qualified, registered and trained professional staff.