SCC’s Supplier Code of Conduct

About this Code:

At SCC we enable people to do business by planning, supplying, integrating and managing their IT. We value the way we do business, acting with integrity and in line with our social responsibility in a sustainable way. Corporate integrity, responsible sourcing and the safety and wellbeing of workers in the countries where we do business are of paramount importance to SCC. We are committed to conducting our business in compliance with all applicable laws and have developed this Supplier Code of Conduct (this “Code”) to support this commitment.  We believe this ensures we will deliver long-term social, environmental and economic benefits for the businesses and communities in which we operate.

While SCC appreciates that its suppliers and contractors (each referred to as “suppliers”) may all operate in a variety of different legal, geographical, and cultural environments, we do still expect all suppliers to comply with the minimum standards in this Code and hope that our suppliers will also strive to exceed these expected standards. We expect these standards to be implemented throughout our suppliers’ businesses and within their own supply chains.

The standards expected of SCC’s suppliers in this Code are in addition to any applicable statutory or regulatory obligations and any contractual obligations of a supplier under any contract between a supplier and SCC. References to statutory and regulatory compliance applies to all countries within which our suppliers operate.

This Code includes the following expectations:

Business Integrity:

SCC is committed to the highest standards of business integrity. We expect our suppliers to adopt the same high standards and we do expect that our suppliers will not tolerate any practice that is inconsistent with the principles of honesty, integrity and fairness, anywhere they do business. Any potential conflicts of interest with SCC employees or our customers or end customers should be disclosed to SCC. SCC also expects suppliers to abide by competition laws and compete fairly. SCC strives to partner with suppliers that are proud of their reputation for fair dealing and quality delivery. SCC expects suppliers to be protective of SCC’s reputation just as much as their own. No SCC supplier should bring SCC or its employees, customers or other suppliers into disrepute by engaging in any act or omission which is likely to diminish the reputation of SCC or our employees, customers and other suppliers.

Legal Compliance:

SCC expects all of its suppliers to comply with all applicable international, national and regional laws, statutes and regulations from time to time in force. This includes, but is not limited to, laws, statutes and regulations relating to human rights, employment, health and safety, environment, information security, data protection and anti-bribery and corruption.  If there is a conflict between any applicable laws or regulations, the provisions of any contract between SCC and a supplier and the provisions of this Code, SCC expects its suppliers to meet the most stringent standard.

Human Rights and Fair Treatment:

SCC expects all of its suppliers to conduct their activities in a manner that respects human rights. This means complying with the fundamental rights granted to workers under applicable local laws, including in the United Kingdom the Modern Slavery Act 2015. This also includes taking due account of applicable local laws and providing appropriate protection in the following areas:

1. Discrimination

SCC is an equal opportunities employer. SCC expects that its suppliers will not discriminate in hiring, compensation, training, advancement or promotion, termination, retirement or any employment practice based on race, caste, colour, national origin, gender, gender identity, sexual orientation, religion, age, marital or pregnancy status, disability, union membership or political affiliation or any other characteristic other than the worker’s ability to perform the job subject to any accommodations required or permitted by law.  SCC expects that its suppliers will also ensure a safe, respectful working environment for all of its workers which is free from all forms of discrimination, abuse and harassment.

2. Wages and working time

SCC expects that its suppliers will ensure that its workers are engaged in compliance with all applicable laws and mandatory industry standards concerning working hours and wages. SCC also expects its suppliers to pay their workers on time and in accordance with applicable legal requirements.

3. Freedom of association and collective bargaining

SCC expects that its suppliers will observe all applicable laws regarding collective bargaining and ensure all workers are free to form or join a workers’ council or other employee trade union body and to engage in collective bargaining.

4. Child labour

SCC expects that its suppliers will comply with all applicable child labour laws and under no circumstances employ workers under the age of 15 or under the minimum age for work as specified by applicable law. SCC requires its suppliers to have in place appropriate processes to verify the age of new employees in order to ensure compliance with applicable child labour laws and the International Labour Organisation’s Convention concerning Minimum Age for Admission to Employment.

5. Voluntary labour

SCC expects that its suppliers will employ all workers on a voluntarily basis and no workers should be subject to any form of forced, involuntary or debt-bonded labour.

6. Safeguarding vulnerable groups

SCC expects that its suppliers will make sure that vulnerable groups are treated with courtesy and that their dignity, safety, security and well-being is treated as a priority concern at all times. SCC also expects its suppliers to ensure safe surroundings and working practices. SCC suppliers should protect against any kind of threat to vulnerable groups, which includes children, young persons or adults at risk.

7. Modern Slavery

SCC expects its suppliers to:

  • comply with all applicable anti-slavery and human trafficking laws, statutes, regulations from time to time in force including but not limited to the Modern Slavery Act 2015;
  • not engage in any activity, practice or conduct that would constitute an offence under sections 1, 2 or 4, of the Modern Slavery Act 2015 where such activity, practice or conduct is or were carried out in the UK;
  • take appropriate steps to ensure that they do not cause SCC to breach Modern Slavery legislation;
  • include in contracts with its own suppliers and contractors suitable provisions which are at least as comprehensive as those set out in the Modern Slavery section of this Code;
  • notify SCC as soon as it becomes aware of any actual or suspected slavery or human trafficking in a supply chain which has a connection with its arrangements with SCC; andnotify SCC as soon as it becomes aware of any actual or suspected slavery or human trafficking in a supply chain which has a connection with its arrangements with SCC; and
  • maintain a complete set of records to trace the supply chain of any goods and/or services provided in connection with its agreements with SCC.

Health and Safety and environmental responsibility:

SCC expects its suppliers’ operations, facilities and procedures to protect and promote worker health and safety and provide their workers with a safe and healthy working environment. SCC suppliers must comply with all applicable laws in relation to health and safety and environmental protection.

SCC suppliers must identify hazardous materials, chemicals and substances, and ensure their safe handling, movement, storage, recycling, reuse and disposal. SCC suppliers must comply with any applicable material restrictions and product safety requirements set by applicable laws and regulations, as well as ensuring workers are aware of, and work in accordance with, all appropriate safety practices.

Information Security and Data Protection

SCC suppliers must protect all information and data received from SCC or its customers and their customers in the course of doing business with SCC and in accordance with industry recognised good security practices, legislation, regulation and any applicable contractual obligations. Such information and data must be kept confidential at all times and not used for any purposes other than the business purpose for which it was provided or made available.

All such information and data must be protected from any unauthorised access, destruction, use, modification and disclosure, through appropriate organisational and technical measures and controls.

If any of our suppliers process any personal data on behalf of SCC, SCC’s customers or their end customers,  SCC  expects its suppliers to comply with all applicable data protection and privacy legislation and implement appropriate technical and organisational security measures in accordance with good industry practice regarding any such processing of personal data.

Wherever suppliers are aware of a security and/or data privacy incident or breach that affects or has the potential to affect SCC or its customers or their customers, they must inform SCC immediately.

Anti-bribery and Anti-corruption Measures:

In addition to all applicable statutory and contractual obligations on SCC’s suppliers, including but not limited to in the United Kingdom the Bribery Act 2010, this Code also expressly prohibits any and all forms of bribery, corruption, extortion or embezzlement. SCC’s suppliers are expected to ensure that they have adequate procedures in place to prevent bribery in all commercial dealings undertaken by them. SCC adopts a zero tolerance approach to bribery and corruption and SCC requires its suppliers to also adopt the same zero tolerance approach when conducting business with SCC.

Any supplier must not accept, offer, promise, pay, permit or authorise: (a) bribes, facilitation payments, kickbacks or illegal political contributions; (b) money, goods, services, entertainment, employment, contracts or other things of value, in order to obtain or retain improper advantage; or (c) any other unlawful or improper payments or benefits.

SCC expects that any actual or suspected incident of corruption, including; bribery, facilitation, fraud, money laundering or theft, which affects SCC or its customers or end customers will be reported to SCC with appropriate details of the circumstances, impact, action taken or to be taken and timescale. Under no circumstances should any invitations or gifts be given to SCC or its customers or end customers in order to gain any form of undue influence or advantage. In addition, no order for goods, services or otherwise should be accepted from SCC where the order is conditional on the supplier conferring a payment or other benefit to either an SCC employee or to that SCC employee’s direction.

Suppliers must also not do, or omit to do, anything which may cause SCC or its workers to be in breach of its own anti-bribery and corruption policies.

It is imperative that SCC suppliers implement appropriate governance and controls in order to detect and prevent fraud, misrepresentation or money laundering. SCC expects its suppliers to not make false or misleading statements or submit false claims in conducting business.

Anti-facilitation of tax evasion:

Tax evasion is the act of intentionally underpaying tax. This is a criminal offence and can be committed at an individual or corporate level. It is also an offence to facilitate another party’s actions in evading tax. 

SCC has a zero-tolerance approach to the facilitation of tax evasion whether under UK law or under the law of any foreign country.  We comply with all applicable laws relevant to countering tax evasion, including the Criminal Finances Act 2017. 

Suppliers must:

  • have a zero tolerance approach to tax evasion in any form;
  • comply with the Criminal Finances Act 2017;
  • have appropriate and reasonable prevention of facilitation of tax evasion procedures and policies in place;
  • not engage in any form of tax evasion or facilitation of tax evasion (whether UK or foreign) and must not aid, abet, counsel or procure the commission of a tax evasion offence by another person;
  • notify SCC immediately if they become aware that they are not in compliance with anti-tax evasion or anti-facilitation of tax evasion legislation; and
  • use all reasonable efforts to secure from organisations and persons within its own supply chain commitments equivalent to those imposed on the supplier in this anti-facilitation of tax evasion section.

Corporate Social Responsibility:

Corporate social responsibility (CSR) is extremely important to SCC and SCC therefore expects its suppliers to be good corporate citizens. SCC’s suppliers should uphold the same values and strive, where possible, to support significant CSR policy areas, such as sustainability, life cycle assessments, carbon foot printing (where applicable), diversity and inclusion, prompt payment, support of the Armed Forces Covenant, apprenticeships and skills development.

Supply Chain Compliance

We expect our suppliers to regularly monitor their own supply chain’s compliance with the standards set out in this Code and to immediately notify SCC of any issues or concerns that may arise.

Self-monitoring and reporting breaches:

SCC expects its suppliers to monitor their own compliance with this Code and report any breaches  (actual or suspected) of this Code as soon as possible to SCC.  

SCC expects all suppliers to have appropriate systems and procedures in place to ensure continuous compliance with this Code and to demonstrate such compliance.

No Supplier must retaliate or take disciplinary action against any worker that has, in good faith, reported any breaches of this Code or questionable behaviour, or who has sought advice regarding this Code.


SCC may monitor its suppliers’ compliance with this Code through routine and ad hoc supplier reviews and questionnaires as well as requests for information regarding such compliance and site inspections.

If a supplier has breached this Code, SCC will require that such supplier takes corrective action and provides appropriate supporting evidence to demonstrate rectification. SCC also reserves the right to immediately suspend or terminate any business relationship with such supplier.

Updates to this Code:

SCC may modify this Code from time to time on giving reasonable notice to its suppliers (writing includes email).

Scroll to Top