Supplier Code of Conduct
Effective Date: 01/04/26
Purpose
This Code defines the minimum ethical, legal, quality, social and environmental standards expected of organisations and individuals supplying goods or services to Exell Training Ltd. It supports safe training delivery, learner and client protection, responsible procurement and public-sector tender assurance.
2. Scope
The Code applies to suppliers, contractors, consultants, subcontractors and other third parties engaged by Exell Training Ltd. Suppliers are expected to take reasonable steps to apply equivalent standards within their own relevant supply chains.
Legal and Regulatory Compliance
Suppliers must comply with all applicable laws, regulatory requirements, professional standards, licences, registrations, insurance obligations and contractual requirements relevant to the goods or services supplied.
Ethical Business Contact
Act honestly and maintain accurate records, invoices, qualifications, attendance evidence and supporting documentation.
Do not engage in bribery, fraud, facilitation payments, kickbacks, extortion, collusion or other corrupt practices.
Disclose actual, potential or perceived conflicts of interest promptly.
Protect confidential information and do not use information obtained through Exell Training for improper advantage.
Labour, Human Rights and Modern Slavery
Prohibit forced labour, servitude, human trafficking, debt bondage and unlawful exploitation.
Provide lawful terms of work, pay and deductions and respect applicable working-time and young-worker protections.
Do not retain workers' identity documents or impose unlawful recruitment fees.
Provide a safe route for workers to raise concerns without retaliation.
Equality, Dignity and Inclusion
Suppliers must promote fair treatment and must not unlawfully discriminate, harass or victimise workers, learners, clients or other persons. Where a supplier is involved in learner-facing delivery, it must support reasonable and lawful accessibility arrangements relevant to its role.
Health, Safety and Safeguarding
Suppliers must provide safe systems of work, competent personnel, suitable equipment and appropriate risk controls. Any supplier whose personnel interact with learners must comply with Exell Training's safeguarding, health and safety and incident-reporting requirements applicable to the engagement.
Data Protection, Confidentiality and Information Security
Suppliers must comply with applicable UK data protection law, including the UK GDPR and Data Protection Act 2018, and must implement appropriate technical and organisational security measures. Suspected or actual personal data or security incidents affecting Exell Training must be reported without undue delay.
Where a supplier processes personal data on behalf of Exell Training, a written controller-processor agreement or equivalent binding terms meeting the requirements of Article 28 UK GDPR must be in place. The Supplier Code does not replace those contractual data-processing terms.
Environmental Responsibility
Use energy, water and materials efficiently and seek to minimise waste where reasonably practicable.
Support lower-carbon purchasing, transport and packaging choices where proportionate.
Provide environmental or carbon information reasonably requested by Exell Training for public-sector procurement or carbon reporting.
Subcontracting and Supply Chain
Suppliers must not use subcontracting to avoid the standards in this Code. Where subcontractors are used, the supplier remains responsible for managing their performance and for applying appropriate equivalent requirements.
Assurance, Incidents and Breach
Exell Training may request proportionate evidence of compliance and may investigate material concerns. Suppliers must notify Exell Training promptly of material breaches, investigations, sanctions, safeguarding concerns or other incidents that could affect delivery, learners, clients, data, reputation or legal compliance. Exell Training may require corrective action and may suspend or terminate a relationship for serious or unresolved breach, subject to contract and law.
Governance
The Director has overall accountability for responsible procurement. The General Manager is responsible for implementation, supplier communication, proportionate due diligence and escalation of material concerns. This Code will be reviewed at least annually.