Supplier code of conduct
Statement

Shoosmiths supplier code of conduct

1. Introduction

Operating with integrity governs our approach and therefore our aspiration to be recognised by our stakeholders as an organisation which is a responsible corporate citizen in all our relationships. We expect our suppliers to share these commitments and to conduct their business in a responsible, ethical and sustainable manner.

This Code of Conduct sets out the minimum standards that all suppliers are expected to meet, alongside good practice expectations intended to support continuous improvement over time. Suppliers are expected to comply with the minimum requirements and, where appropriate, work towards the good practices outlined in this Supplier Code of Conduct.

By working collaboratively with our suppliers, we aim to drive positive environmental and social outcomes across our supply chain.

Scope & Applicability: This Supplier Code of Conduct applies to all suppliers, contractors, consultants, and other third parties providing goods or services to Shoosmiths. Suppliers are expected to use reasonable efforts to cascade and promote these requirements throughout their own supply chains.

Date: March 2026
Signed: Nicola Ward

2. Laws and regulations

Suppliers will comply with all applicable local and national laws, rules, regulations and requirements in the provision of products and services manufactured and provided to Shoosmiths. This includes compliance with the International Labour Organization (ILO) Core Conventions and applicable environmental legislation. It is the supplier’s responsibility to maintain and enforce these standards within its own supply chain.

3. Human rights and labour

Minimum Requirements and Good Practice

TOPIC
MINIMUM REQUIREMENTS
GOOD PRACTICE
CHILD LABOUR PREVENTION

Suppliers shall ensure that no underage labour has been used in the production or distribution of goods and services to Shoosmiths.

A child is any person under the minimum employment age according to the laws of the country where the product (or parts of) or services are sourced from, or in the absence of law under the minimum age for completed mandatory education.

Suppliers should implement age verification processes for all workers.

Suppliers should take appropriate steps to monitor and verify compliance

FORCED LABOUR & MODERN SLAVERY

Suppliers will not use or tolerate in their supply chain any form of slavery, servitude, indentured, bonded, involuntary prison, military or compulsory labour or any form of human trafficking.

All work must be conducted without threat of any penalty or sanctions.

No employee government issued identification, passports or work permits will be retained by the supplier as a condition of employment.

Workers’ rights to leave the workplace after their shift or to terminate their employment after reasonable notice and receive owed salary must be recognised by the supplier. This applies to local or migrant employees.

Suppliers must promptly report to Shoosmiths any incidents of slavery or human trafficking found in its business or supply chain.

Suppliers should assess the risk of modern slavery within their operations and supply chain and, where required, publish an annual statement.

Suppliers should provide regular training to relevant staff on modern slavery and forced labour prevention, including legal requirements, identifying risks, and clear procedures for reporting concerns.

Suppliers should promote responsible practices within their supply chain and, where feasible, take steps to understand and address risks beyond tier 1 suppliers.

WORKING HOURS & REST
Suppliers must ensure working hours comply with national laws and standards and should not expect workers to work (including overtime) in excess of hours set out in relevant working time legislation or other national legal limits unless an opt out has been chosen by the employee with appropriate supporting written evidence.

Suppliers should implement systems to monitor working hours and rest breaks.

Suppliers should seek to offer flexible and fair working arrangements, where feasible.

FAIR PAY & BENEFITS
Wages and benefits must meet legal minimums and industry standards without unauthorised deductions.

Suppliers are encouraged to work towards Living Wage accreditation and to promote fair pay practices within their supply chain.

Suppliers should adopt prompt payment practices, particularly when working with SMEs and social enterprises.

FREEDOM OF ASSOCIATION & COLLECTIVE BARGAINING

Suppliers shall respect the rights of workers to associate or not to associate with any group, as permitted by and in accordance with all applicable local and national laws and freedom of association and collective bargaining.

Suppliers shall not interfere with or discriminate against workers choosing to belong to them.

Where the right to freedom of association and collective bargaining is restricted under national law, suppliers will facilitate, not hinder, alternative means of independent and free association and bargaining.

Suppliers should support alternative means of worker representation and engagement, such as worker committees or forums, where trade unions are restricted.
EQUALITY, DIVERSITY & INCLUSION

Suppliers are expected to promote an inclusive and diverse working environment, supporting equal opportunities for all workers.

All employees must be treated fairly and not discriminated against in any form of employment.

Suppliers must not discriminate against any employee based on age, gender, sexual orientation, race, ethnicity, colour, disability, religion, political affiliation, union membership, national origin, marital or pregnancy status during any recruitment or employment activities.

Suppliers must commit to a workforce free of any harassment or threat of harassment. Any forms or threats of harassment, physical, mental, sexual or verbal, must be prohibited and not tolerated.

Suppliers should maintain and, where appropriate, publish an Equality, Diversity and Inclusion (EDI) policy.

Suppliers should provide regular diversity and inclusion training and monitor progress through appropriate metrics or reviews.

HEALTHY AND SAFE WORKING CONDITIONS

Suppliers must provide safe and clean conditions for workers at sites of working and residential facilities.

Clear procedures must be in place to ensure regulated occupational health, safety and wellbeing standards are adhered to.

Suppliers must comply with the Shoosmiths Health and Safety policy.

Suppliers should conduct regular risk assessments and provide appropriate health and safety training to workers to support safe working conditions.
GRIEVANCE MECHANISMS & FAIR DISCIPLINE

Suppliers must provide a grievance mechanism for workers and their organisations to enable workers to anonymously raise workplace concerns.

The mechanism must be transparent, set out clearly how grievances will be assessed and feedback provided. Workers and their representatives must be informed clearly how the scheme operates and its scope and that it is equally accessible to all workers.

Disciplinary procedures shall be clearly documented, communicated and easily accessible to all workers.

All disciplinary matters shall be recorded including evidence that the worker knew and understood what they were accused of and given the right to trade union or other appropriate representation at disciplinary meetings which may lead to significant disciplinary penalties or dismissal.

Suppliers should align grievance mechanisms with the UN Guiding Principles on Business and Human Rights, ensuring they are effective, accessible and transparent.

Suppliers should implement anonymous reporting channels, such as hotlines or digital platforms, to enable concerns to be raised safely and confidentially.

Suppliers should track and monitor grievance resolution, including timelines and outcomes, to support continuous improvement.

4. Environment

Minimum Requirements and Good Practice

4.1 Climate

TOPIC
MINIMUM REQUIREMENTS
GOOD PRACTICE
ENVIRONMENTAL MANAGEMENT

Suppliers must comply with all applicable environmental laws and regulations.

Suppliers must comply with the Shoosmiths Environment policy.

Suppliers must have an environmental policy or be able to demonstrate an appropriate approach (e.g. documented processes or procedures) to ensure that environmental impacts associated with their goods and services are understood, measured and managed.

Suppliers are encouraged to publish sustainability information and, where appropriate, align reporting with recognised standards such as GRI.

Suppliers should establish clear accountability for environmental and/or sustainability management, with defined roles and responsibilities at an appropriate level within the organisation.

CLIMATE ACTION & EMISSIONS

Suppliers must cooperate with reasonable requests to support Shoosmiths' 2040 net zero ambition, including the provision of relevant climate data where requested.

Suppliers are expected to have, or be working towards, measuring and reporting their Scope 1 and Scope 2 emissions in line with the GHG Protocol.

Suppliers classified by Shoosmiths as high risk for climate impact and with annual spend exceeding £50,000 should be able to provide relevant climate data on an annual basis.

Suppliers should work towards accounting for material Scope 3 emissions.

Suppliers should aim to set science-based emissions reduction targets aligned with recognised methodologies such as the Science Based Targets initiative (SBTi).

Suppliers should seek independent or third-party assurance of greenhouse gas emissions data, where appropriate.

Suppliers should aim to provide product carbon footprints (PCFs) or life cycle assessments (LCAs), where relevant.

Suppliers should aim to engage Tier 1 suppliers on decarbonisation through data collection, training, or contractual requirements.

ENERGY & RENEWABLE TRANSITION
Where not already in place, suppliers should work towards setting time-bound energy efficiency targets and increasing the use of lower-carbon or renewable energy sources, where feasible.

4.2 Nature & biodiversity

TOPIC
MINIMUM REQUIREMENTS
GOOD PRACTICE
BIODIVERSITY & HABITAT PROTECTION
Suppliers must comply with all applicable biodiversity and deforestation related laws (e.g., EU Deforestation Regulation).

Suppliers should identify and understand any material biodiversity impacts associated with their goods and services, assess and monitor related risks within their operations

and supply chain, and implement appropriate measures to mitigate negative impacts on nature, where relevant.

Suppliers are encouraged to identify opportunities to contribute positively to biodiversity, for example through nature-positive commitments or habitat improvements where appropriate.

WATER STEWARDSHIP & POLLUTION

Suppliers must comply with all applicable regulations relating to air emissions and wastewater.

Suppliers must manage water use responsibly and prevent pollution and contamination, particularly where water is used in operations.

Suppliers should assess water-related risks where water use is significant, and, where appropriate, set targets and implement measures to manage water use, air emissions, and prevent pollution.
RESOURCE EFFICIENCY & CONSERVATION
Suppliers must use energy, materials and resources efficiently, minimising consumption and avoiding unnecessary resource use where feasible.

Suppliers should identify areas of high resource use and, where appropriate, set targets to reduce energy and material consumption.

Suppliers should transition products and services to lower-impact alternatives, such as recycled materials or low-impact service models, where feasible.

4.3 Waste & circularity

TOPIC
MINIMUM REQUIREMENTS
GOOD PRACTICE
CIRCULAR ECONOMY & WASTE MANAGEMENT

Suppliers must comply with all waste-related regulations and ensure appropriate segregation and disposal.

Suppliers must

implement robust waste management practices and minimise waste at source.

Suppliers should take steps to reduce packaging and material waste, where applicable.

Suppliers should identify opportunities to reduce waste and increase reuse or recycling within their operations and supply chain.

Suppliers should set targets to reduce waste generation and divert waste from landfill.

Suppliers should implement or participate in circularity programmes (e.g. reuse schemes, refill models, remanufacturing), where appropriate.

Suppliers should design products and services to support reuse, repair, or recycling, and offer take-back schemes where relevant.

CHEMICAL & HAZARDOUS MATERIALS MANAGEMENT

Where hazardous substances are used or handled, suppliers must ensure they are identified, labelled, stored and managed safely.

Suppliers must comply with all applicable chemical and hazardous waste regulations, including REACH.

Suppliers should seek to minimise the use of hazardous substances and, where possible, transition to safer or lower-impact alternatives.

5. Inclusivity & community

Minimum Requirements and Good Practice

TOPIC
MINIMUM REQUIREMENTS
GOOD PRACTICE
INCLUSIVE SOURCING
Suppliers are expected to conduct their sourcing and business practices in a fair and transparent manner, supporting equal opportunity.
Suppliers are encouraged, where appropriate, to consider opportunities to engage SMEs, social enterprises, and diverse-owned businesses (e.g. women, ethnic minority, disability, or LGBTQ+ owned) within their supply chains.
SUPPLIER DIVERSITY & REPORTING
Suppliers must be able to disclose, upon request, their diversity, equity and inclusion (DEI) practices. This may include policies, procedures and initiatives that support equal opportunities and non-discrimination, as well as any relevant diversity data collected.

Suppliers should have a DEI policy and be able to provide this upon request.

Suppliers should track and report spend with diverse suppliers (e.g. as a percentage of total spend), where relevant.

Suppliers should aim to publish annual diversity performance data.

COMMUNITY IMPACT
Suppliers are expected to take reasonable steps to identify, prevent and mitigate adverse impacts on local communities and vulnerable groups arising from their operations.

Suppliers should conduct community impact assessments for major projects, where relevant.

Suppliers are encouraged to support local employment, skills development or community initiatives, where appropriate.

LOCAL SOURCING

Suppliers should seek to source locally where feasible, in order to

reduce environmental impact and support local economies.

DISABILITY INCLUSION
Suppliers must comply with all applicable disability inclusion laws.
Suppliers should promote disability inclusion within their operations and, where relevant, in the delivery of goods and services to Shoosmiths.

6. Business Integrity

Suppliers shall not engage in any form of bribery or corruption or undertake any action that contravenes the Shoosmiths Anti-Bribery and Corruption policy.

7. Compliance with the Code

Suppliers must be able to demonstrate compliance with the Shoosmiths Supplier Code of Conduct. This includes documented evidence and the right of Shoosmiths or a designated firm to conduct audits. Audits include facility inspections, review of supplier records business practices and conducting employee interviews.

8. Reporting Concerns

Suppliers are invited to report any area of concern to Shoosmiths.

An external whistleblowing helpline, Safecall, is available.

Any concerns can be reported via the telephone number or via the website:

Phone: 0800 915 1571

Web: www.safecall.co.uk/report

The minimum standards set out in this Supplier Code of Conduct apply to all suppliers and represent Shoosmiths’ expectations in relation to responsible business conduct. Certain standards within the Supplier Code of Conduct are reflected in Shoosmiths’ ESG Clauses and, where incorporated into contractual agreements, are legally binding.