Supplier Code of Conduct

The Consumers’ Association and Which? Limited (“Which?”) are committed to acting ethically in business dealings and expects suppliers to do the same. We value transparency, trust, respect, and open communication. This Supplier Code of Conduct (“Code”) explains our expectations and provides guidance for meeting these shared values.

In this article

Compliance with the code

Which? asks all suppliers to sign up to the Code and encourages the same standards to be applied across your supply chain. In committing to the Code, you agree that you will comply with it, have appropriate systems in place to ensure continuous compliance, and you will demonstrate your compliance by self-certifying to Which? on an annual basis.

Legal and regulatory compliance practices

We expect all our suppliers to commit to operating in compliance with applicable laws and regulations, including but not limited to those addressed by this Code. If there is a conflict between any applicable laws, regulations, the provisions of an agreement with Which?, or the provisions of this Code, you shall meet the most stringent standard.

Trade: Comply with all international and local rules, regulations, ordinances, and controls on technology transfers (physical and electronic), exports, re-exports, and imports.

Antitrust: Conduct business in full compliance with antitrust and fair competition laws that govern the jurisdictions in which they conduct business.

Boycotts: Not participate in international boycotts that are not sanctioned by the United Kingdom government or applicable laws.

Anti-Corruption, Bribery, and Kickbacks: Conduct business in full compliance with the anti-corruption and anti-money laundering laws that govern the jurisdictions in which you conduct business. You must not tolerate, permit, or engage in any form of corruption, extortion, or bribery.

Governance: You should be able to demonstrate compliance with the UK Corporate Governance Code or the comparably appropriate code applicable to your primary jurisdictions.

Privacy and Data Protection: If you handle any form of personal data – especially customer personal data – you should implement best practices for cyber security and data protection to ensure the safety and confidentiality of all data is maintained.

Business practices and ethics

People and Accessibility: You should strive to accommodate all users and customers, paying particular attention to the more vulnerable and/or disadvantaged ones. We also expect you to create products and services that are accessible (usable, reachable, and obtainable) to people of all abilities, including those with vision, hearing, mobility, and cognitive conditions.

Business Records and Accounting: You must keep accurate and honest books and records of all business dealings with Us, including reasonable documentation to demonstrate compliance with this Code. These records must be in accordance with applicable standard accounting practices.

Transparent Communication: We expect you to be honest, direct, and truthful in discussions, including those with regulatory agency representatives and government officials.

Conflicts of Interest: You must avoid conflicts of interest or the appearance of them. Suppliers should not deal directly with any Which? Trustee, Board member, or employee, or the spouse, domestic partner, other family member, or relative of such Trustee, Board member, or employee who holds a financial interest in the supplier. In situations where this cannot reasonably be avoided, any potential conflict must be declared.

Commitment to ESG (Environmental, Social, and Governance): In line with our own commitments, you should be conscious of, and track and report on, their impact on the world around them. We will ask you to provide these reports to us at regular intervals to enable us to meet and report on our own targets.

Human rights and fair labour practices 

We are a Real Living Wage employer and a Disability Confident employer. We focus on being representative of the UK consumers we serve and strive to ensure our hiring practices are unbiased. We participate in various schemes designed to provide alternative career paths and are open to new and creative work opportunities. We value our diversity at all levels and are committed to improving this further. We expect the same of you.

In addition to ensuring compliance with all applicable employment laws, you must respect every individual’s rights, personal dignity, and privacy. We expect you to:

  • Respect workers’ right to freely associate and bargain and engage in fair hiring practices. 
  • Follow all laws and regulations regarding child labour.
  • Respect anti-modern slavery laws and never use any forced or involuntary labour.
  • Compensate workers sufficiently to meet their basic needs by paying the living wage.
  • Ensure that working hours, including overtime, do not exceed applicable legal limits.
  • Provide a safe, healthy, and sanitary working environment and comply with UK health and safety laws and other relevant laws where it operates, including protecting employees from harassment and discrimination.

Protecting the environment

We are committed to protecting and respecting our environment. At a minimum, we expect you to follow all applicable environmental laws, regulations, and standards, including goals to reduce environmental impact from operations.

We focus on sustainability practices and promote recycling and reductions in waste and single use plastics. We are accredited as carbon neutral; it is our goal to reduce our carbon emissions in line with United Nations sustainability targets and are therefore committed to reporting on our carbon emissions, including those generated by you on our behalf. We ask and expect the same of you.

Reporting concerns and questionable behavior

We count on our suppliers to help our business succeed and to uphold our values and our high ethical standards. To meet this expectation, we are committed to creating an environment where you feel comfortable raising concerns and getting help.

If you believe that someone – whether an employee of Which? or a supplier – is not meeting the standards in this Code, please report your concerns via email to: procurement@which.co.uk, sharing as much detail as possible. We will promptly and professionally investigate all reported matters and respond appropriately. We will make every effort to safeguard your confidentiality and, if applicable, your anonymity.