Costrick Vendor Code of Conduct

Version 1.0 / February 2026 / Business-to-Business Platform / English

Introduction

The Costrick Vendor Code of Conduct (“Code”) outlines Costrick Ltd’s expectations for how its current and prospective suppliers conduct business. Costrick Ltd, a company registered in Scotland (company number SC806470) at 6 Ristol Road, Glasgow, G13 1UY, operates a B2B platform (www.costrick.com) connecting convenience store retailers and wholesalers across the UK. All suppliers providing goods or services to Costrick, including wholesalers, distributors, and logistics providers, are required to understand and adhere to this Code. This includes aligning their policies, practices, and supply chains (including subcontractors) with these standards.

Suppliers must act with integrity, demonstrating a commitment to legal, ethical, safe, fair, and environmentally responsible business practices. Costrick seeks suppliers who comply with all applicable laws, promote inclusivity, and avoid discrimination in any form. This Code summarizes expectations for suppliers, their subcontractors, and their employees, ensuring alignment with our commitment to ethical sourcing and human rights, as detailed in our Modern Slavery Statement (www.costrick.com/modern-slavery-statement).

Suppliers must operate in compliance with all relevant laws, rules, and regulations in the jurisdictions where they operate. Where this Code sets higher standards than local laws, suppliers must adhere to these standards within the framework of applicable laws. Suppliers are expected to cooperate with regulators and communicate this Code throughout their organization and supply chain.

Ethical Business Practices

Costrick is committed to conducting business with the highest ethical standards and in compliance with all applicable laws. Suppliers are expected to share these principles, uphold these standards, and implement policies to ensure their employees understand and adhere to them.

Anti-Bribery and Anti-Corruption

Costrick has zero tolerance for bribery or corruption, as outlined in our Anti-Bribery Policy. Suppliers must comply with all applicable anti-bribery and anti-corruption laws, including the UK Bribery Act 2010. Suppliers, including their agents or subcontractors acting on Costrick’s behalf, must maintain policies and procedures to prevent bribery and corruption. Suppliers are prohibited from offering, providing, authorizing, soliciting, or receiving “anything of value” (e.g., cash, gifts, entertainment, or other benefits) to obtain or retain business, secure improper advantages, or influence improper performance. This includes “facilitation payments” to expedite routine governmental actions by public officials. Suppliers must ensure transparency in all transactions and avoid disguised corrupt payments.

Gifts, Travel, and Entertainment

Suppliers must not offer lavish or inappropriate gifts, fees, favors, travel, or entertainment intended to influence, or that may appear to influence, business decisions. Such actions may create improper obligations or expectations and are prohibited to maintain impartiality.

Conflicts of Interest

Suppliers must avoid conflicts of interest or the appearance thereof. A conflict exists when a supplier’s activities could affect, or appear to affect, objectivity in business dealings with Costrick. Suppliers must disclose any potential conflicts to costrickcloud@gmail.com immediately.

Confidentiality, Privacy, and Data Protection

Suppliers must protect confidential information and personal data accessed, received, or processed on behalf of Costrick. This includes adopting robust technical and organizational measures to comply with UK GDPR and the Data Protection Act 2018. Unauthorized use or disclosure of such information may have legal, reputational, and financial consequences. Suppliers must report any data breaches to costrickcloud@gmail.com promptly.

Grievance Mechanism

Suppliers must provide a transparent and accessible process for workers to raise workplace concerns without fear of retaliation. This mechanism should protect whistleblowers and align with our Ethics Hotline at www.costrick.ethicspoint.com, ensuring workers can report issues confidentially.

Responsible Sourcing of Minerals

Suppliers providing products containing minerals (e.g., tantalum, tin, tungsten, or gold) must ensure these are not sourced from conflict-affected or high-risk areas in ways that contribute to armed conflict, terrorist financing, or human rights violations. Sourcing must align with the OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas.

Anti-Tax Evasion

Suppliers must not engage in or facilitate unlawful tax evasion. They are expected to implement reasonable processes to prevent deliberate and fraudulent diversion of funds from tax authorities, ensuring compliance across their supply chain.

Labour and Human Rights

Costrick is committed to protecting human rights, as articulated in the UN Guiding Principles on Business and Human Rights, the Universal Declaration of Human Rights, and the International Labour Organization (ILO) Core Conventions. Suppliers must adopt similar policies applicable to all workers, including migrant and temporary workers, covering the following:

Wages and Benefits

Suppliers must provide wages and benefits meeting or exceeding local legal requirements, including minimum wage, overtime pay, and legally mandated benefits (e.g., paid leave, pension, health benefits). Suppliers are encouraged to pay a living wage where higher than the legal minimum. Payments must be regular, timely, and compliant with applicable contracts or collective agreements.

Working Hours

Suppliers must adhere to legal limits on working hours, overtime, and weekly working days. Workers must receive all legally entitled paid leave, including holidays, maternity/parental leave, and sick leave, with correct compensation.

Slavery, Forced Labour, and Human Trafficking

Costrick does not tolerate slavery, forced labour, or human trafficking, as stated in our Modern Slavery Statement. Suppliers must comply with the UK Modern Slavery Act 2015 and ensure no involuntary labour (e.g., prison labour, debt bondage) is used. Practices such as wage withholding, identity document retention, or movement restrictions are prohibited. Suppliers must eliminate worker-paid recruitment fees, provide contracts in workers’ native languages, and conduct due diligence to prevent human trafficking in their supply chains. Suspected victims should be referred to the UK’s National Referral Mechanism (NRM), as outlined at www.gov.uk/government/collections/modern-slavery.

Child Labour

Suppliers must not employ anyone under the legal minimum age for employment (typically 15, or higher if required by local law or education standards), per ILO Conventions 138 and 182 and the UN Convention on the Rights of the Child. For workers aged 13–18, employment must comply with local laws and avoid hazardous conditions. Suppliers must implement age verification and training to prevent child labour.

Freedom of Association and Collective Bargaining

Suppliers must respect workers’ rights to freedom of association and collective bargaining, complying with local laws and ensuring workers can engage without fear of retaliation.

Respect, Inclusion, and Non-Discrimination

Suppliers must treat workers with respect and dignity, maintaining a workplace free from discrimination, harassment, or abuse based on age, disability, ethnicity, gender, gender identity, nationality, race, sexual orientation, religion, or other protected characteristics. Equal opportunity and a harassment-free environment are mandatory.

Safe and Healthy Work Environment

Suppliers must provide a safe and healthy workplace, complying with all applicable health and safety laws and providing free personal protective equipment. Risks must be minimized, and accident prevention measures implemented.

Sanitation, Water, and Housing

Suppliers must ensure access to clean toilet facilities and potable water. If accommodation is provided, it must be clean, safe, and equipped with emergency exits, fire safety measures, hot water, adequate ventilation, and reasonable access privileges.

Support for Small and Diverse Suppliers

Costrick is committed to fostering competition and inclusivity in its supply chain. We encourage small businesses and those owned or led by underrepresented groups (e.g., women, BAME, LGBT, or disabled individuals) to join our platform. Suppliers are urged to provide similar opportunities to small and diverse businesses in their own supply chains, promoting fair access to opportunities.

Environmental Stewardship

Costrick is dedicated to environmental responsibility, as reflected in our Responsible Sourcing Policy. Suppliers are encouraged to adopt practices that minimize environmental impact, aligned with industry best practices.

Energy and Emissions

Suppliers should track and mitigate energy use and greenhouse gas (GHG) emissions (scopes 1, 2, and 3 where feasible). This includes adopting energy-efficient technologies and disclosing emissions data to Costrick upon request.

Water

Suppliers should conserve and reuse water, ensuring operations do not restrict access to safe water, sanitation, or hygiene for surrounding communities.

Waste

Suppliers must minimize waste, particularly hazardous waste, and ensure safe handling, storage, and disposal. Workers handling hazardous materials must be trained, and only permitted transporters should be used.

Material Restrictions and Handling

Suppliers must comply with laws restricting specific substances, ensuring safe handling, storage, and disposal of materials to prevent environmental harm.

Business Continuity and Emergency Preparedness

Suppliers must maintain business continuity plans to ensure service resilience during emergencies (e.g., natural disasters, pandemics, or system outages). These plans should minimize disruptions to Costrick’s operations and be shared upon request.

Management Systems and Governance

Suppliers are encouraged to implement management systems (e.g., ISO 9001, ISO 14001, or ISO 45001) to comply with this Code and continuously improve performance. This includes risk identification, mitigation, monitoring, and prompt incident reporting to costrickcloud@gmail.com. Suppliers must cooperate with Costrick’s audits and provide performance data when requested.

Reporting and Compliance

Suppliers must immediately report any inability to meet this Code’s requirements to costrickcloud@gmail.com. Violations must be remedied promptly, or Costrick may review or terminate the relationship. Suppliers can report concerns anonymously via our Ethics Hotline at www.costrick.ethicspoint.com or by calling 0800 123 4567 (UK) or +44 141 123 4567 (international). Retaliation against good-faith reporters is strictly prohibited.

Costrick retains the right to audit supplier compliance with this Code. This Code is subject to periodic updates, with the latest version available at www.costrick.com/vendor-code-of-conduct. It complements, but does not override, contractual obligations. In case of conflicts between this Code and supplier contracts, the contract prevails. Non-compliance may result in Costrick exercising its rights under contracts or local laws.

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