Last updated: 30 December 2025

London Paint Works Ltd (trading as London Machine Works) (“LMW”, “we”, “us”) is committed to conducting business ethically, lawfully, and responsibly. This Supplier Code of Conduct (“Code”) sets out the minimum standards we expect from our suppliers, contractors, consultants, agents, distributors, and other third parties that provide goods or services to LMW (collectively, “Suppliers”).

This Code applies to all Suppliers and, where relevant, their employees, agency workers, subcontractors, and sub-suppliers involved in delivering products or services to LMW.

1) Compliance with laws and standards

Suppliers must comply with all applicable laws, regulations, and industry standards in the jurisdictions in which they operate, including (where applicable) UK regulations and customer flow-down requirements.

Where this Code sets a higher standard than local law, Suppliers are expected to meet the higher standard unless prohibited by law.

2) Ethical business conduct and integrity

Suppliers must conduct business with integrity and in a manner that maintains trust and transparency.

Anti-bribery and corruption

• Suppliers must not offer, promise, give, request, or accept bribes or improper advantages of any kind.
• Gifts and hospitality must be modest, reasonable, infrequent, and never intended to influence decision-making.
• Facilitation payments are prohibited.

Fair competition

• Suppliers must comply with competition and anti-trust laws.
• Suppliers must not engage in price-fixing, bid-rigging, market allocation, or sharing competitively sensitive information unlawfully.

Conflicts of interest

• Suppliers must avoid conflicts of interest and disclose any actual or potential conflicts that could influence their work for LMW.

3) Human rights, modern slavery, and labour standards

Suppliers must respect internationally recognised human rights and uphold fair labour practices, including:

• No forced, bonded, or involuntary labour, and no human trafficking or modern slavery.
• No child labour. Workers must meet the applicable legal minimum age requirements.
• Fair wages and working hours in line with applicable law, including statutory minimum wage and working time rules.
• Freedom of association and the right to collective bargaining, consistent with local law.
• No harassment, abuse, or discrimination. Employment decisions must be based on ability, qualifications, and performance.

Suppliers must have controls to identify and address modern slavery risks within their own operations and supply chains.

4) Health, safety, and wellbeing

Suppliers must provide a safe and healthy working environment and manage risks appropriately. As a minimum, Suppliers must:

• Maintain appropriate health and safety policies, procedures, training, and risk assessments.
• Provide suitable PPE, safe equipment, and safe systems of work.
• Report and investigate incidents and near misses, implementing corrective actions to prevent recurrence.
• Ensure that any work performed on LMW sites (or customer sites under LMW responsibility) follows site rules, permits, RAMS, and applicable legal duties.

5) Environmental responsibility

Suppliers must operate with regard to environmental protection and sustainability. As a minimum, Suppliers must:

• Comply with all applicable environmental laws and permits.
• Implement good practices to reduce environmental impacts (e.g., energy use, waste, emissions, noise, and water use).
• Handle chemicals and hazardous materials safely and lawfully, including correct labelling, storage, and disposal.
• Aim to reduce waste through reuse and recycling where feasible.
• Provide environmental information reasonably requested by LMW (e.g., material declarations, product compliance statements, or carbon-related information) where relevant.

6) Quality, product safety, and compliance

Suppliers must provide goods and services that meet agreed specifications and quality requirements.

Suppliers must:

• Maintain effective quality controls and inspection/testing where appropriate.
• Use competent personnel and suitable equipment to meet specification.
• Notify LMW promptly of any nonconformance, suspected counterfeit risk, or deviation from agreed requirements.
• Maintain traceability where relevant (e.g., batch/lot numbers, certificates, material test reports).
• Where applicable, support product compliance requirements (e.g., UKCA/CE-related documentation, material conformity, certificates of conformity, declarations, and test evidence).

Counterfeit prevention
Suppliers must have reasonable measures to prevent the introduction of counterfeit parts/materials into the supply chain, including purchasing from reputable sources and maintaining records.

7) Information security and data protection

Where Suppliers access, process, store, or transmit LMW information (including customer information), they must:

• Protect information against unauthorised access, loss, damage, or disclosure using appropriate technical and organisational measures.
• Use information only for the agreed business purpose.
• Comply with applicable data protection laws (including the UK GDPR and Data Protection Act 2018 where relevant).
• Notify LMW promptly if they become aware of a security incident or suspected breach involving LMW data.

8) Confidentiality and intellectual property

Suppliers must:

• Keep LMW confidential information secure and confidential.
• Respect LMW and third-party intellectual property rights.
• Not disclose confidential information without authorisation, except where legally required.

9) Responsible sourcing and supply chain management

Suppliers are expected to promote responsible business practices throughout their supply chains, including:

• Flowing down relevant requirements of this Code to subcontractors and sub-suppliers involved in LMW work.
• Using due diligence proportionate to risk (e.g., for labour practices, ethics, and compliance).
• Maintaining records that demonstrate compliance where appropriate.

10) Reporting concerns and cooperation

Suppliers must promptly report to LMW any:

• suspected or actual breach of this Code,
• material legal or regulatory non-compliance,
• significant health and safety incident relating to LMW work,
• confirmed or suspected modern slavery/human trafficking risk in connection with LMW supply.

Suppliers are expected to cooperate with reasonable requests from LMW to investigate concerns, complete corrective actions, or provide supporting evidence.

11) Monitoring, audits, and corrective actions

LMW may assess Supplier compliance with this Code through reasonable measures such as self-assessments, document reviews, or (where proportionate) site visits/audits. Where issues are identified, Suppliers must implement corrective actions within agreed timescales.

12) Consequences of non-compliance

Failure to comply with this Code may result in actions including (as appropriate):

• corrective action requirements,
• suspension of work or deliveries,
• removal from approved supplier lists,
• termination of contracts and/or reporting to relevant authorities where required.

13) Contact

If you have questions about this Code or need to raise a concern, contact:

London Machine Works
Email: info@londonmachineworks.com