Surface Matter Ethical labour policy

Code of Conduct

We love working with great people and we have high standards of the people we work with and how we work together – as a team and with our wider community. Our standards – a code of behaviour rooted in our values – help guide us to the right choice and shapes how we work day-to-day.

Surface Matter is committed reducing environmental impact, defend and promote human rights and to fight corruption, discrimination and all forms of forced labour. Our team follows a Code of conduct that mirrors our Supplier Code of Conduct, to make sure we’re aware of our joint sustainable commitments and expectations. We expect our team to always act in goodwill and in a way that doesn’t negatively affect the brand, our stakeholders or our community.

Legal laws and regulations

Compliance with laws and regulations are essential for working with Surface Matter, and all team members must comply with local laws and regulations.

Human rights

Respect for human rights, and promoting these rights is integrated in all of our operations. All employees shall be treated fairly, with dignity and respect.

Equality, diversity and inclusion

Our team promote equal opportunities and we will not accept any form of discrimination, harassment, violence or verbal abuse of our team, customers or suppliers. We support diversity, inclusion and equity in our workplace and our community.

Fair labour

Surface Matter will never use or benefit from any form of forced or bonded labour. No one in our team should be subject to working under threat of any penalty. The use or support of any child labour or exploitation is not tolerated in any form. We are a living wage employer and provide a number of benefits that exceed national or industry minimum standards.

Health and Safety

Surface Matter prioritises our team’s safety, and operate safe, hygienic and healthy workplaces, that support physical and mental wellbeing. We conduct risk assessments and health and safety information is given to our team, contractors, clients and consultants including relevant training and protective equipment.

Environmental management

We proactively work to track and reduce our environmental impact and comply with relevant environmental legislation and requirements. 

Bribery, fraud and corruption

Our team should act with integrity and without actions involving bribery, fraud or corruption. We will not offer, promise, give or accept any advantage, directly or indirectly, or accept improper payments to obtain new business or secure any other improper advantage.

Conflicts of interest

We avoid situations where there could be a conflict of interest between Surface Matter and our suppliers, consultants or clients, like where personal or inappropriate relationships could influence a business decision.

Compliance and monitoring

Our code of conduct applies to our whole team, regardless of level, experience or role. Any noncompliance or concerns with your own or another team member’s conduct should be managed under our Grievance and Disciplinary procedure, or whistleblower policy as needed.

Ethical labour policy

In accordance with Section 54, Part 6 of the Modern Slavery Act 2015 Surface Matter has taken steps to make sure slavery or slavery-like practices, forced labour and human trafficking are not taking place in our supply chains or any part of our business.

Slavery and Human Trafficking

Surface Matter is committed to preventing slavery and human trafficking in our supply agreements or across wider global supply chains and we have a zero tolerance approach towards slavery and human trafficking. We expect our suppliers and contractors to comply with the Modern Slavery Act 2015. Our team is expected to report any concerns about slavery or human trafficking. Any concerns raised will be investigated and acted on. We also adopt the principles of the Ethical Trading Initiative Base Code of labour– Statement on Slavery and Human Trafficking 2018, including:

  • Employment is freely chosen
  • Freedom of association and the right to collective bargaining are respected
  • Working conditions are safe and hygienic
  • Child labour is not used
  • Minimum wages are paid
  • Working hours are not excessive
  • No discrimination is practiced or tolerated
  • Regular employment is provided
  • No harsh or inhumane treatment is allowed

Due diligence for ethical labour practices

  • Sourcing the materials we work with
  • Reporting

Surface Matter takes all allegations of slavery and human trafficking seriously. Disclosing information about malpractice/wrongdoing occurring within the business is encouraged. Any allegations of slavery and human trafficking can be raised in line with our Whistleblowing Policy.

As part of our initiative to identify and mitigate risk we:

  • Build long-standing relationships with local suppliers and make our expectations of behaviour clear.
  • Make it our business to know our customers to make sure we work with appropriate businesses.
  • Expect national and international supply chains to have suitable anti-slavery and human trafficking policies and processes. We expect each entity to adopt ‘one-up’ due diligence at minimum on the next link in the chain, as it is not practical for us or other participants in the chain to have a direct relationship with parts of the supply chain.

We have in place systems to encourage the reporting of concerns and the protection of whistleblowers.


To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we provide briefings to our employees. Under our Supplier Code of Conduct we also request our business partners provide regular and relevant training to their staff and suppliers and providers.