12th January 2022


Suppliers and Business Intermediaries


26 Delegates


We wanted to understand if our supply chain could comply with the proposed Code, the areas they would struggle with, and the support they would require to become compliant.

Specifically, we wanted to hear Stakeholder views on the clarity of aims and the compliance requirements, what they would need to do in order to comply, the impacts of compliance on their business and support we could provide and their levels of acceptance and support for our proposed code.

Key comments & our responses


Considered the objectives of the code to be clear and understandable. Attendees were unanimously supportive of us introducing the code.

Keeping the Code accessible

You told us that some of the language in the Code document may be off-putting to smaller businesses who don’t have in-house specialists or dedicated resources to ensure compliance, you also stated it may be useful to have a main point of contact at NGN to answer any questions around the requirements of the Code.


In order to keep the Code accessible to all, we will review the Code documentation to remove any jargon and explain any technical terminology to make the document more accessible. We will also provide a compliance guidance document to explain how to effectively demonstrate compliance and what good looks like. Contact details for any concerns, questions or queries will be added to the Code documentation to ensure that any questions not addressed by the guide document we produced can be directed to a specialist member of the procurement team.

Code content

You thought it was surprising to see no reference to minimising the use of hazardous substances in the Code.

Following this comment, we fully agreed, and we have since added this commitment to the Code documentation.

Code content

The expectation for a Modern Slavery Policy for suppliers whose annual turnover is <£36m was raised as a concern and potentially a barrier for small and medium sized enterprises (SMEs) as this is not a statutory requirement for them.

We recognise the importance of ensuring that this code doesn’t become a blocker for SMEs to work with us but also feel it is important to have a good standard of behaviour and expectations from our supply chain. We will review the wording of this expectation in the Code and direct suppliers to freely available online resources for guidance and support to help them meet the requirements.

Becoming compliant

Over half of attendees (58%) stated they felt there were already compliant with the Code criteria, with the remainder believing they would need up to six months to become compliant, however they were typically unsure of the level of investment they would need to make to achieve this.

We were pleased with the levels of support received by our stakeholders and will look to implement the Code in late Spring 2022.

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