Supplier Code of Conduct

At Howdens we promote a culture and working environment where our people treat each other with respect, courtesy and fairness, promoting equal opportunity for all, and we expect our Suppliers to do the same.  In particular, and in accordance with the United Nations Global Compact Initiative, Suppliers are required to uphold:

• the freedom of association and the effective recognition of the right to collective bargaining;

• the elimination of all forms of forced and compulsory labour;

• the abolition of child labour; and

• the elimination of discrimination in respect of employment and occupation.

Human Rights

Howdens takes a zero-tolerance approach to any infraction of human rights. Suppliers must comply with all internationally recognised human rights understood, at a minimum, as those expressed in the International Bill of Human Rights and the principles concerning fundamental rights set out in the International Labour Organisation's Declaration on Fundamental Principles and Rights at Work from time to time in force. Businesses should support and respect the protection of internationally proclaimed human rights within the scope of their influence, and at all times they must not be complicit in human rights abuses.

Equal Opportunities

We are an equal opportunities employer and our Suppliers must 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.

Health and Safety

We believe that all employees have a right to work in a safe and healthy environment and we intend to carry out our business without putting employees, or others, health or physical wellbeing at risk. Suppliers must equally provide a safe and healthy workplace for all its employees and conduct business in an ethical way.

As a minimum Suppliers are required to:

• Establish appropriate organisational structures and procedures for the effective management of health, safety and environmental risks;

• Ensure that all workers are sufficiently aware of these risks and appropriately trained on the implementation of health and safety control measures;

• Ensure workers have access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided. Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers; and

• Working hours must comply with national laws and collective agreements.

Modern Slavery

Howdens is committed to preventing acts of modern slavery and human trafficking from occurring within our business and supply chain, and we expect our suppliers to comply with the same high standards.  

Suppliers are required to:

• Comply with all applicable modern slavery and anti-trafficking laws;

• Not, under any circumstances, engage in any activity involving modern slavery or anti-trafficking of any kind when acting for or on behalf of Howdens, to include any activities within the supply chain by any sub contractor, distributor, supplier and/or agents; and 

• Be transparent and co-operative in the provision of relevant information where Howdens is conducting appropriate and proportionate due diligence on their business structure and operations.

A copy of our modern slavery statement can be found at Modern Slavery Statement | Howden Joinery Group Plc (https://www.howdenjoinerygroupplc.com/governance/modern-slavery-statement).

Anti-bribery and corruption

Howdens takes a zero-tolerance approach to bribery, corruption and any other form of illegal or unethical conduct. Suppliers are required to:

• Comply with all applicable anti-bribery and corruption laws;

• Ensure that they do not, under any circumstances, engage in any activity involving bribery or corruption of any kind when acting for or on behalf of Howdens.  For the avoidance of doubt, bribery includes “facilitation payments”, which commonly arise in the form of payments made to officials to obtain or speed up routine services which the officials are required to provide; and

• Be transparent and co-operative in the provision of relevant information where Howdens is conducting appropriate and proportionate due diligence on their business structure and operations.

Anti-tax evasion and anti-money laundering

We will not tolerate any involvement with, or facilitation of, tax evasion or money laundering within Howdens’ business activities, or within the business activities of those who perform services for or on behalf of the Howdens Group. Suppliers are required to:

• Comply with all applicable anti-tax evasion and anti-money laundering laws;

• Ensure that they do not request cash payments in respect of goods/services provided to Howdens and ensure that, at all times, they make accurate and honest representations to Howdens during the course of relevant accounting and/or on-boarding processes; for example, when completing purchase orders and submitting invoices to Howdens for payment; and

• Be transparent and co-operative in the provision of relevant information where Howdens is conducting appropriate and proportionate due diligence on their ownership structure and financial/payment processes.

Competition

It is Howdens’ policy to compete vigorously but fairly. Suppliers must comply with all applicable competition and antitrust laws and must not engage in any form of anti-competitive practices or behaviour in relation to their work with Howdens, such as:

• price-fixing – i.e. entering into agreements or understandings with competitors to fix selling prices or restrict sales;  

• market-sharing – i.e. agreeing with competitors to share or allocate markets, customers or products, e.g. by agreeing to focus on different geographic areas, sale channels or product types; 

• sharing pricing or commercially sensitive information – i.e. informing competitors of yours / Howdens’ pricing intentions, or of other confidential information.  The mere exchange of information can be illegal, as can simply listening without speaking up; and/or

• bid-rigging – i.e. secretly colluding with competitors in responding to customer tenders, rather than submitting transparent or independent bids.