Surface Matter Supplier Code of Conduct

Surface Matter is committed reducing environmental impact, defend and promote human rights and to fight corruption, discrimination and all forms of forced labour. It’s essential to us that our Suppliers do the same. Surface Matter is constantly working to reduce our environmental impact by optimising resource management, reducing emissions, reducing consumption of energy and water and treating waste as a valuable resource. The Surface Matter team follow a Code of Conduct that mirrors the Supplier Code of Conduct, to make sure we’re aware of our joint sustainable commitments and expectations. We expect our Suppliers to always act in goodwill and in a way that doesn’t negatively affect the brand. This Supplier Code of Conduct applies to all suppliers who provide products and/or services to Surface Matter. Suppliers should stay updated on changes to our Supplier Code of Conduct which can be found on

Legal Compliance

Compliance with laws and regulations is a requirement for doing business with Surface Matter. This Supplier Code of Conduct, which contains rules for Surface Matter’s business conduct, in some cases goes further and must be applied entirely throughout any work with Surface Matter. All Suppliers must comply with the laws and agreements that apply to their operations and employment in the countries where they’re based and their employees must know and follow the laws that govern their individual tasks.

Human Rights

Fundamental human rights

The respect of human rights and where possible the promotion of these rights, should be integrated in all business activities and operations. All employees shall be treated fairly, with dignity and respect.

Equal Rights and Non-Discrimination

The Supplier should not discriminate, but promote equal opportunity, in hiring and employment practices. The Supplier should not accept and actively mitigate any form of harassment, violence or verbal abuse of its employees. Surface Matter Suppliers are expected to support diversity and equal opportunity in their workplaces.

Workplace Rights

Forced Labour

The Supplier should not use, or in any other way benefit, from forced or bonded labour. No one should be subject to working under threat of any penalty.

Child labour

Use or support of any child labour, or other child exploitation, is not tolerated in any form.

Salary and Benefits

All Suppliers should make sure their employees are paid a salary which should at least meet national or industry minimum standards, and preferably a living wage.

Health & Safety

Surface Matter prioritises our team’s safety. The Supplier should provide its team with a safe, hygienic and healthy workplace, factoring in physical and mental health. The Supplier should make sure appropriate health and safety information is given to its employees, suppliers and contractors and any relevant training and protective equipment is provided.


Environmental Management System

Suppliers should use a proactive approach to reduce environmental impacts. Suppliers should be able to demonstrate environmental management or document an environmental program or system. The Supplier should also have an activity program to reduce environmental impact in the production and transport chain, including but not limited to:

  • reduced consumption of materials
  • reduced discharge of hazardous substances and minimised use of products harmful to humans and wildlife
  • reduced greenhouse gas emissions
  • reduced waste
  • reduced energy and water consumption
  • a focus on recycling

Compliance with Environmental Legislation

All Surface Matter Suppliers shall operate in full compliance with relevant environmental legislation and requirements. Relevant environmental aspects shall be identified and appropriate actions taken to address these should be identified including resource consumption, emissions, chemicals and waste reduction.

Bribery and Corruption

All Suppliers shall act with integrity and without actions involving bribery and/or corruption. The Supplier should make sure its employees and third parties do not offer, promise, give or accept any advantage, directly or indirectly, nor accept improper payments to obtain new business or secure any other improper advantage.

Conflicts of interest

The Supplier should avoid situations where there is conflict of interest, such as participating in activities where personal or other inappropriate relationships could influence business decisions.

Monitoring and Compliance

Suppliers should make sure they work with Surface Matter’s Supplier Code of Conduct throughout the value chain. Any non-compliance must be reported to Surface Matter, which can be communicated by email , in phone or in person and through Surface Matter’s whistleblowing policy, found on

Surface Matter may ask suppliers for confirmation or proof of performance to this code.

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.