✅ Purpose of the Document
The Supplier Code of Conduct (Code de Conduite Fournisseurs) defines the minimum standards of behaviour that your company expects from all its suppliers, sub-contractors, and business partners. Unlike the Responsible Purchasing Charter (which governs your own procurement practices), this document is addressed to your suppliers and sets out what they must comply with as a condition of doing business with you.
It directly supports your EcoVadis score across all four themes: Environment (ENV), Labour & Human Rights (LAB), Ethics (FB), and Sustainable Procurement (SUP). It is also one of the documents most frequently requested by EcoVadis assessors as proof that supplier requirements are formalised and contractually embedded.
🏗 Expected Structure & Key Elements
The list below outlines the core sections your Supplier Code of Conduct should include to ensure full auditability and alignment with EcoVadis criteria:
Introduction & Purpose: Explains what the Code is, who it applies to, and which international frameworks it references (UN Global Compact, ILO Core Conventions, UNGPs, OECD Guidelines)
Scope & Application: Defines which suppliers, tiers, and geographies are covered; cascade requirements to sub-contractors
Environmental Standards: 3.1 Energy & GHG · 3.2 Water Management · 3.3 Waste & Circular Economy ·3.4 Materials, Chemicals & REACH (sectorial) · 3.5 Customer/Consumer Health & Safety (sectorial) · 3.6 Animal Welfare (sectorial)
Labour & Human Rights: 4.1 Fair Labour Practices & Working Conditions · 4.2 Freedom of Association & Social Dialogue · 4.3 Child Labour, Forced Labour & Human Trafficking · 4.4 Non-Discrimination, Diversity & Inclusion ·4.5 Migrant Workers & Recruitment Fees (sectorial/conditional)
Business Ethics & Compliance: 5.1 Anti-Corruption & Bribery · 5.2 Anticompetitive Practices · 5.3 Information Security & Data Privacy
Sustainable Procurement & Supply Chain: 6.1 Integrating ESG into procurement · 6.2 Supplier Diversity & Inclusive Sourcing ·6.3 Conflict Minerals (sectorial) · 6.4 Palm Oil & Palm-Based Derivatives (sectorial)
Compliance & Enforcement: Audit rights, corrective action plan (CAP) process, whistleblowing channel, sanctions
Reporting & Metrics: 11-indicator table covering all themes - enabling Scope 3 and supply chain ESG consolidation
Versioning & Approval: Version history table, four-signatory block (CEO, CSO, CPO, CLO)
📚 Acceptance Criteria per Framework
For EcoVadis, the Code must:
Be a standalone, formally published document (not a clause buried in a contract)
Be explicitly addressed to suppliers (not to internal employees)
Cover at minimum: environmental requirements, labour & human rights, anti-corruption/ethics, and sustainable procurement expectations
Be signed or approved by senior management
Be dated within the last 8 years
Reference the company's right to audit supplier compliance
What makes the document strong "auditable evidence":-Formalisation - official document on company letterhead, with version number, effective date, and ownerCommunication to suppliers - proof it is shared with suppliers (e.g. onboarding checklist, countersigned acknowledgement form, portal upload confirmation)
Contractual embedding - reference to it in supplier contracts or purchase orders
Cascade requirement - explicit language requiring suppliers to pass requirements to their sub-contractors
Recency - issued or updated within the last 24 months
📌 Include on the document: company logo / letterhead · author function · effective date · version number · approval signatures
📎 Typical Attachments & Supporting Proofs
When uploading this Code to EcoVadis, also attach the following:
Signed supplier acknowledgement form - showing that key suppliers have received and accepted the Code
Supplier onboarding checklist - showing the Code is systematically shared at onboarding
Supplier evaluation results - evidence that compliance with the Code is assessed (connects to section 7)
Training records for procurement staff on the Code's requirements
Whistleblowing channel documentation - showing the confidential reporting mechanism exists and is accessible to supplier workers
Corrective action plan template - the CAP form referenced in section 7
Contract extract showing the Code is referenced as a contractual requirement
❌ Common Mistakes to Avoid
Confusing this document with the Responsible Purchasing Charter: the Charter is your internal policy; the Code is addressed to suppliers. Both are needed. EcoVadis assessors distinguish between the two.
No proof of communication: a Code of Conduct that lives in a drawer scores zero on EcoVadis. You must show it is communicated to suppliers - a countersigned acknowledgement page, a portal upload, or an onboarding checklist are all valid.
No audit right clause: EcoVadis specifically looks for the right to audit or verify supplier compliance. Section 7 of this template includes it - do not remove it.
Keeping sector-specific sections that don't apply to your supply chain. The template includes four sections marked ⚠ SECTOR-SPECIFIC. Review each carefully:
Section 3.4 - Materials, Chemicals & REACH: Only relevant if your suppliers handle chemical substances, mixtures, or articles subject to REACH (EC 1907/2006). This applies to manufacturers, chemical distributors, and producers of articles containing SVHCs.If you are a services company, SaaS, or your suppliers do not deal with chemical substances: remove this section entirely. Including it signals to the assessor that REACH is relevant to your business, which will trigger further evidence requests you cannot fulfil.
Section 3.5 - Customer & Consumer Health and Safety: Only relevant if your suppliers manufacture or distribute consumer products (food, cosmetics, toys, electronics, etc.).If your company is a B2B services provider or your supply chain does not involve consumer-facing products: remove this section. The associated EcoVadis questions (ENV3802, ENV3810, etc.) are only displayed for companies in relevant sectors.
Section 3.6 - Animal Welfare: Only relevant if your suppliers use animals in testing, production, or supply animal-derived materials (pharmaceuticals, cosmetics, food & beverage, textiles using leather/wool, etc.).If your supply chain has no animal welfare dimension: remove this section. EcoVadis question ENV3394 is sector-conditional and will not appear for most B2B or technology companies.
Section 4.5 - Migrant Workers & Recruitment Fees: Relevant where your supply chain involves geographies or sectors with significant migrant worker populations (manufacturing in Southeast Asia, Middle East construction, agricultural supply chains, etc.). If your Tier-1 suppliers are primarily based in Western Europe or North America and do not employ migrant workers at scale, this section may be simplified or removed. EcoVadis questions LAB1003 and LAB1007 are conditional.
Section 6.3 - Conflict Minerals: Only relevant if your suppliers manufacture products containing tin, tantalum, tungsten, or gold (3TG). This is primarily relevant for electronics, automotive, aerospace, and jewellery supply chains.If your products do not contain 3TG minerals: remove this section entirely. Including it when not applicable creates audit risk and confuses assessors - EcoVadis question SUP710 will be marked N/A for most service and consumer goods companies without 3TG in their products.
Section 6.4 - Palm Oil: Only relevant if your suppliers source palm oil or palm-based derivatives for use in food, cosmetics, cleaning products, or biofuels.If palm oil is not in your supply chain: remove this section. EcoVadis questions SUP2031 and SUP620 are sector-conditional.
Generic copy-paste: fill in all
[COMPANY NAME],[XX],[TARGET YEAR], and[DD Month YYYY]placeholders. A document with unfilled brackets signals a template, not a live policy.Addressing the wrong audience: the Code is written in the second person ("Suppliers shall…" / "Suppliers commit to…"). Do not convert it to first person - it must read as a set of requirements directed at suppliers, not as your own internal commitments.
🔄 How Often to Update
Updating frequency varies by framework and internal policy standards. Recommendations include:
EcoVadis: Every 8 years, or following a significant supply chain change
UN Global Compact: Annual (referenced in your Communication on Progress)
CSRD / CS3D: Annual - the CS3D requires due diligence obligations to be contractually embedded, which this Code supports
ISO 20400: Review whenever your sustainable procurement policy is updated Trigger an update when:
New legislation creates supplier obligations (e.g. EU Forced Labour Regulation, CS3D implementation)
You enter new geographies or supply chain sectors with different risk profiles
An audit finding or EcoVadis assessor feedback identifies a gap
A significant supply chain incident occurs (non-compliance, media exposure, audit failure)
Your Responsible Purchasing Charter is updated (the two documents must remain consistent)
🖋 Example of a Supplier Code of Conduct
See an example here.
This template is designed to serve as an inspiration and foundational guide for drafting your Supplier Code of Conduct. Its structure, themes, and commitments have been explicitly mapped to align with EcoVadis evaluation criteria.
However, this document must be thoroughly appropriated. A Code of Conduct is only credible if it reflects the actual risks in your supply chain and the commitments you can genuinely enforce. Before publishing, review each section against your supplier base and the geographies in which they operate.Sections requiring careful review before publishing:-Section 3.4 (Materials, Chemicals & REACH) - Remove entirely if your suppliers do not handle chemical substances subject to REACH. Keeping this section when it is not applicable signals to EcoVadis that REACH is relevant, triggering questions you cannot answer.
Section 3.5 (Customer/Consumer Health & Safety) - Remove if your supply chain does not involve consumer-facing products. The associated EcoVadis questions are conditional and sector-specific.
Section 3.6 (Animal Welfare) - Remove if your supply chain has no animal welfare dimension (no animal testing, no animal-derived materials). This is one of the most commonly included-but-irrelevant sections in generic templates.
Section 4.5 (Migrant Workers & Recruitment Fees) - Simplify or remove if your Tier-1 suppliers are based in low-risk geographies for migrant labour. Keep and strengthen if you source from Southeast Asia, the Middle East, or other regions with significant migrant worker populations.
Section 6.3 (Conflict Minerals) - Remove entirely if your products do not contain tin, tantalum, tungsten, or gold. Including this section for a SaaS company, a consulting firm, or a food & beverage brand that does not use 3TG minerals is a common mistake that undermines the document's credibility.
Section 6.4 (Palm Oil) - Remove entirely if palm oil is not in your supply chain. This section is specific to food, cosmetics, cleaning products, and biofuel supply chains.
Claiming requirements you do not enforce will not pass the evidence-gathering phase of the EcoVadis audit. Tailor each section to your actual supplier risk profile.
FAQs
Q1: Do we need both a Responsible Purchasing Charter and a Supplier Code of Conduct?
Yes, and EcoVadis assessors look for both. The Charter documents your own procurement commitments (internal policy). The Code documents what your suppliers must comply with (external-facing requirements). They are complementary and should cross-reference each other - the Charter should state that suppliers must sign the Code, and the Code should reference the Charter as the framework it implements.
Q2: Does the Code need to be signed by suppliers?
It does not need to be co-signed, but you need evidence that it was communicated to suppliers and accepted. Options include: a countersigned acknowledgement page, a supplier portal upload confirmation, a clause in the purchase order referencing the Code, or an onboarding checklist showing the Code was shared. At least one of these is strongly recommended for EcoVadis evidence.Q3: Can we use this Code in French only?
Yes. EcoVadis accepts documents in the language of the assessed entity. The French template (Template FR) is fully adapted, with references to loi Sapin II, devoir de vigilance, RGPD, and the CSE. If you supply to international suppliers, consider providing an English version as well.Q4: Our suppliers are all in France/Europe - do we still need sections on forced labour and migrant workers?
The forced labour section (4.3) is universally applicable and should always be kept - it covers ILO Conventions that apply globally, including in Europe. Section 4.5 (Migrant Workers & Recruitment Fees) can be simplified if your Tier-1 suppliers are exclusively in low-risk geographies, but should be retained for suppliers in sectors with known migrant labour risks (logistics, agriculture, cleaning services).Q5: How do we enforce the Code if a supplier refuses to comply?
Section 7 of the template sets out the escalation path: corrective action plan → suspension of new orders → termination. The key is to include the Code (or a reference to it) in your supplier contracts so it has legal force. Without contractual embedding, the Code is a best-efforts commitment rather than an enforceable obligation.