Supplier Code of Conduct

1.  Introduction and scope2.  Legal compliance3.  Labour rights and working conditions4.  Modern slavery and human trafficking5.  Health and safety6.  Business integrity and anti-corruption7.  Data protection and information security8.  Environmental responsibility9.  Confidentiality and intellectual property10. Sub-supplier and supply chain management11. Quality and service standards12. Audit, monitoring, and assessment13. Non-compliance and enforcement14. Reporting concerns (whistleblowing)15. Acknowledgement and agreement16. Contact us

1. Introduction and scope

Gradio Safety LTD is committed to conducting business in an ethical, lawful, and socially responsible manner. We expect the same commitment from all organisations that supply goods or services to us — whether directly or indirectly.

This Supplier Code of Conduct applies to:

• Direct suppliers: Companies that provide goods or services directly to Gradio Safety LTD
• Subcontractors: Companies engaged by our suppliers to perform part of the work
• Sub-processors: Companies that process personal data on our behalf (as defined under UK GDPR Article 28)
• Business partners: Joint venture partners, agents, distributors, and any other organisation acting on our behalf
• Supply chain: All tiers of the supply chain — suppliers must cascade these requirements to their own suppliers

2. Legal compliance

Suppliers must comply with all applicable laws, regulations, and statutory requirements in every jurisdiction in which they operate. This includes, but is not limited to:

Where local laws and this Code differ, the higher standard applies. If local law sets a lower standard than this Code, the Code prevails. If local law sets a higher standard, local law prevails.

3. Labour rights and working conditions

Suppliers must uphold fundamental labour rights as set out in the ILO Declaration on Fundamental Principles and Rights at Work. Specifically:

3.1 Freely chosen employment

• No forced, bonded, or compulsory labour of any kind
• No human trafficking in any form
• Workers must not be required to surrender identity documents (passports, ID cards) to employers or recruiters
• No recruitment fees charged to workers — if fees have been paid, the supplier must reimburse them
• Workers must be free to leave employment after reasonable notice

3.2 No child labour

• No worker under the age of 15 (or the local legal minimum working age, whichever is higher)
• No worker under 18 in hazardous work or night shifts
• Suppliers must verify the age of all workers at the time of recruitment
• Suppliers must support remediation programmes for any child workers found in their operations

3.3 Fair wages and working hours

• All workers must be paid at least the legal minimum wage for their jurisdiction
• Overtime must be voluntary and paid at the legally required premium rate
• Working hours must not exceed 60 hours per week (including overtime), except in exceptional circumstances
• Workers must receive at least one day off per week
• Wages and benefits must be communicated clearly and in writing to all workers
• No unauthorised deductions from wages

3.4 Freedom of association

• Workers must be free to join or form trade unions and to bargain collectively
• Where trade unions are not legally permitted, suppliers must establish alternative mechanisms for worker representation
• No discrimination, retaliation, or harassment against workers for union activity

3.5 No discrimination

• No discrimination in hiring, pay, promotion, training, discipline, termination, or retirement on the basis of race, colour, age, gender, sexual orientation, gender identity, ethnicity, disability, pregnancy, religion, political affiliation, union membership, national origin, or marital status
• Suppliers must have a written equal opportunities policy
• Suppliers must provide a mechanism for workers to raise discrimination concerns

3.6 No harassment or abuse

• No physical, verbal, sexual, or psychological harassment, abuse, or threats
• No corporal punishment in any form
• Suppliers must have a written anti-harassment policy and a grievance mechanism

4. Modern slavery and human trafficking

Suppliers must take all reasonable steps to ensure that modern slavery and human trafficking are not taking place in any part of their business or supply chain. This includes:

• Conducting risk assessments of their operations and supply chain for modern slavery risks
• Implementing due diligence processes for all new suppliers and sub-suppliers
• Providing modern slavery awareness training to relevant staff
• Publishing a Modern Slavery Act statement if required by law (Section 54, MSA 2015)
• Reporting any suspected modern slavery to Gradio Safety LTD immediately
• Cooperating fully with any modern slavery audit or investigation we conduct

See our Modern Slavery Act Statement for our own commitment and the standards we apply.

5. Health and safety

Suppliers must provide a safe, clean, and healthy working environment for all workers, in compliance with all applicable health and safety laws. Specifically:

• Risk assessment: Conduct regular risk assessments of all workplaces and work activities
• Safe equipment: Provide and maintain safe, well-functioning equipment and machinery
• Training: Provide health and safety training to all workers, including induction training for new workers
• PPE: Provide appropriate personal protective equipment (PPE) at no cost to workers
• Emergency preparedness: Maintain emergency procedures, fire exits, first aid kits, and trained first aid responders
• Sanitation: Provide clean toilets, washing facilities, and potable drinking water
• Accommodation: Where worker accommodation is provided, it must be clean, safe, and meet minimum standards
• Incident reporting: Record and investigate all workplace accidents, injuries, and near-misses
• Mental health: Take reasonable steps to support worker mental health and wellbeing

6. Business integrity and anti-corruption

Suppliers must conduct their business with integrity and transparency. The following are strictly prohibited:

• Bribery: Offering, giving, requesting, or accepting anything of value to influence a business decision improperly
• Facilitation payments: Small payments made to expedite routine government actions
• Kickbacks: Offering or receiving a portion of a contract value as an inducement
• Gifts and hospitality: No gifts or hospitality that could influence or appear to influence business decisions. Any gifts must be modest, lawful, and properly recorded
• Conflicts of interest: Suppliers must disclose any actual or potential conflicts of interest involving Gradio Safety LTD employees
• Fraud: No fraud, embezzlement, theft, or falsification of records
• Money laundering: No involvement in money laundering or terrorist financing
• Sanctions evasion: No business with sanctioned individuals, entities, or countries

Suppliers must maintain accurate books, records, and financial statements that reflect all transactions truthfully. Records must be retained in accordance with applicable legal requirements and made available to Gradio Safety LTD on request.

7. Data protection and information security

Suppliers that process personal data on behalf of Gradio Safety LTD must do so in full compliance with UK GDPR, EU GDPR, the Data Protection Act 2018, and all other applicable data protection laws. Specifically:

• Data processing agreement: Sign a written Data Processing Agreement (DPA) with Gradio Safety LTD before processing any personal data
• Purpose limitation: Process personal data only for the purposes specified in the DPA — never for the supplier's own purposes
• Data minimisation: Process only the minimum personal data necessary for the agreed service
• Security measures: Implement appropriate technical and organisational security measures, including encryption, access controls, and regular security testing
• Sub-processing: Do not engage sub-processors without our prior written authorisation. Any approved sub-processor must be bound by equivalent data protection terms
• Breach notification: Notify Gradio Safety LTD of any personal data breach within 24 hours of becoming aware of it
• Data subject rights: Assist us in responding to data subject requests within the statutory timeframes
• International transfers: Do not transfer personal data outside the UK/EEA without appropriate safeguards (e.g., UK IDTA, EU SCCs)
• Data return and deletion: Return or securely delete all personal data at the end of the contract
• Audit: Maintain records of processing activities and make them available for audit on request

See our Privacy Policy for the standards we apply to personal data processing.

8. Environmental responsibility

Suppliers must comply with all applicable environmental laws and regulations and are encouraged to go beyond minimum compliance. Specifically:

• Legal compliance: Obtain and maintain all required environmental permits, licences, and registrations
• Emissions: Monitor and minimise greenhouse gas emissions where feasible
• Energy: Use energy efficiently and consider renewable energy sources where available
• Waste: Minimise waste generation, maximise recycling and reuse, and dispose of waste through licensed facilities
• Water: Use water efficiently and prevent contamination of water sources
• Hazardous materials: Handle, store, transport, and dispose of hazardous materials in accordance with all applicable laws
• Biodiversity: Avoid or minimise adverse impacts on biodiversity and ecosystems
• Reporting: Be prepared to report environmental metrics (carbon footprint, energy use, waste) on request

9. Confidentiality and intellectual property

Suppliers must protect all confidential information belonging to Gradio Safety LTD, our clients, and our employees. Specifically:

• NDA: Sign a non-disclosure agreement before receiving any confidential information
• Confidentiality scope: Confidential information includes business plans, financial data, client information, source code, architecture diagrams, security findings, and any other non-public information
• Access control: Limit access to confidential information to personnel who need it for the agreed service
• No use: Do not use confidential information for any purpose other than providing the agreed service
• No disclosure: Do not disclose confidential information to any third party without our prior written consent
• Return/destruction: Return or securely destroy all confidential information at the end of the contract
• IP ownership: All intellectual property created for Gradio Safety LTD under a contract belongs to Gradio Safety LTD unless otherwise agreed in writing
• No infringement: Do not use or provide any third-party intellectual property that infringes the rights of others

10. Sub-supplier and supply chain management

Suppliers must extend the principles of this Code throughout their own supply chain. Specifically:

• Cascade: Suppliers must communicate the requirements of this Code (or equivalent standards) to all sub-suppliers and subcontractors
• Contracts: Include equivalent compliance clauses in contracts with sub-suppliers
• Due diligence: Conduct due diligence on sub-suppliers before engaging them, particularly in high-risk sectors or countries
• Monitoring: Monitor sub-supplier compliance on a risk-based approach
• Transparency: Provide Gradio Safety LTD with a list of sub-suppliers and sub-processors on request
• Escalation: Report any sub-supplier non-compliance that could affect Gradio Safety LTD
• Remediation: Take responsibility for remediating non-compliance found in the supply chain

11. Quality and service standards

Suppliers must deliver goods and services that meet the quality, specification, and timeline requirements agreed with Gradio Safety LTD. Specifically:

• Specifications: Deliver goods and services that meet agreed specifications and quality standards
• Timeliness: Meet agreed delivery deadlines and service levels
• Defect management: Promptly replace or repair defective goods at no cost to Gradio Safety LTD
• Continuous improvement: Strive to improve quality and efficiency over time
• Certifications: Maintain relevant quality certifications (e.g., ISO 9001) where applicable
• Change notification: Notify Gradio Safety LTD in advance of any material changes to products, services, processes, or ownership

12. Audit, monitoring, and assessment

Gradio Safety LTD reserves the right to monitor and assess supplier compliance with this Code. Our audit rights include:

Suppliers must cooperate fully with audits and assessments, provide requested documentation within 10 business days, and allow reasonable access to facilities, records, and personnel. Audit results will be shared with the supplier, and a remediation plan may be required for any findings.

13. Non-compliance and enforcement

If a supplier is found to be non-compliant with this Code, Gradio Safety LTD will take appropriate action based on the severity of the non-compliance:

14. Reporting concerns (whistleblowing)

Suppliers, their workers, and any third party can report concerns about non-compliance with this Code. We encourage open communication and protect those who raise concerns in good faith.

• Internal reporting: Email info@gradiosafetyltd.com with "Confidential — Supplier Code Concern" in the subject line
• Anonymous reporting: You may report anonymously. All reports are investigated regardless of whether you identify yourself
• Non-retaliation: We do not tolerate retaliation against anyone who raises a concern in good faith. Retaliation is itself a breach of this Code
• Modern Slavery Helpline: 08000 121 700 — modernslaveryhelpline.org
• Police: In emergencies, call 999. For non-emergencies, call 101

15. Acknowledgement and agreement

By accepting a contract, purchase order, or any other commercial engagement with Gradio Safety LTD, the supplier confirms that:

• They have read and understood this Supplier Code of Conduct
• They comply with all requirements set out in this Code
• They will cascade these requirements to their own suppliers and sub-suppliers
• They will notify Gradio Safety LTD of any actual or potential non-compliance
• They consent to audits and assessments as described in Section 12
• They understand that non-compliance may result in termination of the business relationship

16. Contact us

For questions about this Supplier Code of Conduct, to request a copy, or to report a concern:

• Email: info@gradiosafetyltd.com
• Subject line: "Supplier Code of Conduct" or "Confidential — Supplier Code Concern"
• Company: Gradio Safety LTD, Company No. 17456330, 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ
• Related policies: Compliance Overview · Modern Slavery Act Statement · Privacy Policy · KYC & AML Policy

v2.0  2026-08-28  Full rewrite — 16 sections: legal compliance table, labour rights (ILO), modern slavery, health & safety, anti-corruption, data protection (GDPR), environmental, confidentiality/IP, sub-supplier management, quality standards, audit rights, enforcement matrix, whistleblowing, acknowledgementv1.0  2026-08-27  Initial Supplier Code of Conduct