Revising the code of practice on ethical employment in supply chains

The Welsh Government’s Code of Practice on Ethical Employment in Supply Chains sets out twelve commitments concerning ethical employment and risks of unethical and illegal labour practices

First published in 2017, the Code of Practice addresses issues such as modern slavery and human rights abuses, blacklisting, false self‑employment, unfair use of umbrella schemes and zero‑hours contracts, and payment of the Real Living Wage. 

The Welsh Government expects all public sector organisations, businesses and third sector organisations in receipt of public sector funding to sign up to the Code of Practice. Other organisations operating in Wales from any sector are encouraged to adopt the Code.

We are now consulting on a revised version of the Code of Practice to reflect changes in the labour market and ethical procurement practices since 2017. The aim is to ensure the Code remains robust, relevant and aligned with current expectations of ethical employment practices. Your views will help shape an updated Code that continues to support fair treatment for workers and responsible procurement across Wales.

We will:

Develop and implement a policy on tackling modern slavery and unethical employment

• Produce and implement a written policy (or policies) to address modern slavery and unethical employment and recruitment in our own organisation and our supply chains. Such policies should be endorsed at a senior level and cover international workers where applicable.

Provide training on modern slavery and unethical employment

• Train relevant staff and, where feasible, encourage suppliers to understand modern slavery, unethical employment and our organisation’s policies.

Identify risks of modern slavery and unethical employment

• Produce and regularly update a risk assessment of key products and services that may involve modern slavery and unethical employment practices in our organisation and supply chains.

Address risks of modern slavery and unethical employment

• Respond to our risk assessments by acting to reduce and mitigate risks. Remediate harms linked to our organisation and our supply chains. 

Record our actions to reduce modern slavery and unethical employment

• Record our key actions, findings, progress and outcomes, within our organisation and our supply chains, and make this a regular topic of contract management and review meetings. 

Publish annual statements about our work on modern slavery and unethical employment

• Produce and publish an annual statement explaining what we have done and what we plan to do to tackle modern slavery and unethical employment in our organisation and our supply chains. The statement will list the named senior individual(s) with responsibility for addressing these issues.

Pay at least the Real Living Wage

• Pay at least the Real Living Wage to all direct employees. Consider becoming an accredited Real Living Wage employer and encourage UK suppliers to pay at least the Real Living Wage.
• When buying goods and services overseas, give focus to suppliers who pay at least a regional living wage for their geographical area or use certifications focused on fair pay, such as Fair Trade certification.

Provide access to trade unions 

• Make sure trade unions can access the workplace and that workers can join and participate in trade unions without fear of discrimination. Ensure workers are protected from adverse treatment and blacklisting when raising grievances, making formal complaints or whistleblowing. Ensure these rights are clearly stated in employment contracts.
• Place a focus on suppliers, in the UK and globally, who can show a positive and cooperative approach to working with trade unions. In countries where trade unions are prevented from freely operating, consider suppliers that support alternative democratic or cooperative structures while recognising these are not equivalent to trade union engagement.

Protect workers’ rights and job security

• Meet all legal duties to our workers and make sure they know their rights. Prevent unfair treatment in relation to pay, terms and conditions and avoid unfair use of umbrella schemes and zero hours contracts, or false self-employment.  
• Ensure any changes to pay, terms or conditions are agreed through proper negotiation with the workforce and avoiding unacceptable practices such as fire and rehire.
• Support job security of suppliers’ workers by paying invoices promptly, within 30 days, and ensure that undue cost and time pressures are not applied that may lead to the unethical treatment of workers. 

Promote equality, diversity and inclusion

• Embed equal opportunities in our recruitment, workforce and treatment of others, and eliminate unlawful discrimination, harassment, and victimisation.
• Place a focus on suppliers who actively promote equality, diversity and inclusion and encourage suppliers to keep improving practice in these areas.
• Act to prevent all forms of discrimination and harassment (including sexual harassment) and respond effectively when this arises.

Keep workers and workplaces safe

• Ensure that our organisation has effective health and safety measures, and these are communicated and regularly reviewed in consultation with workers and trade union representatives.
• Require suppliers to comply with all relevant health and safety regulations. Place a focus on suppliers who can provide clear evidence of effective health and safety management. This includes robust risk assessments, workforce involvement in health and safety measures, and transparent incident reporting and recording. 

Consider the impact of technology on workers

• In consultation with the workforce, identify and manage risks associated with the use of technology, including AI and people-management technology, in our organisation and supply chains.

Question 1

Do you agree the revised Code of Practice should include a commitment to develop and implement a policy on tackling modern slavery and unethical employment as set out in the draft document?

Question 2

Do you agree the revised Code of Practice should include a commitment to provide training on modern slavery and unethical employment as set out in the draft document?

Question 3

Do you agree the revised Code of Practice should include a commitment to identify risks of modern slavery and unethical employment as set out in the draft document?

Question 4 

Do you agree the revised Code of Practice should include a commitment to address risks of modern slavery and unethical employment as set out in the draft document?

Question 5

Do you agree the revised Code of Practice should include a commitment to record actions to reduce modern slavery and unethical employment as set out in the draft document?

Question 6

Do you agree the revised Code of Practice should include a commitment to publish annual statements about work addressing modern slavery and unethical employment as set out in the draft document?

Question 7

Do you agree the revised Code of Practice should include a commitment to pay at least the Real Living Wage as set out in the draft document? 

Question 8

Do you agree the revised Code of Practice should include a commitment to provide access to trade unions as set out in the draft document?

Question 9

Do you agree the revised Code of Practice should include a commitment to protect workers’ rights and job security as set out in the draft document?

Question 10 

Do you agree the revised Code of Practice should include a commitment to promote equality, diversity and inclusion as set out in the draft document?

Question 11

Do you agree the revised Code of Practice should include a commitment to keep workers and workplaces safe as set out in the draft document?

Question 12

Do you agree the revised Code of Practice should include a commitment to consider the impact of technology on workers as set out in the draft document?

Question 13 

Overall, do you agree the Welsh Government should update the Code of Practice in line with this draft revised version?

Question 14

Is there anything missing, unclear or insufficiently addressed in the draft revised Code of Practice?

Submit your comments by 14 January 2027, in any of the following ways.

• Complete our online form
• Download, complete our response form and email fairwork@gov.wales 
• Download, complete our response form and post it to:

Employability and Fair Work Division
Welsh Government
Cathays Park
Cardiff
CF10 3NQ

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Welsh Ministers have statutory powers they will rely on to process this personal data which will enable them to make informed decisions about how they exercise their public functions. The lawful basis for processing information in this data collection exercise is our public task; that is, exercising our official authority to undertake the core role and functions of the Welsh Government. (Art 6(1)(e)) 

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In order to show that the consultation was carried out properly, the Welsh Government intends to publish a summary of the responses to this document. We may also publish responses in full. We publish responses anonymously and your name and contact details will not be included. If you would like your name or other details published alongside your response, please let us know when you submit your response, and we will include them.

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Data Protection Officer:

Welsh Government
Cathays Park
Cardiff
CF10 3NQ
e-mail: dataprotectionofficer@gov.wales

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Wycliffe House
Water Lane
Wilmslow
Cheshire SK9 5AF
Tel: 0303 123 1113

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Large print, Braille and alternative language versions of this document are available on request.

For further information:

Employability and Fair Work Division
Welsh Government
Cathays Park
Cardiff
CF10 3NQ

Email: fairwork@gov.wales 

This document is also available in Welsh.

Number: WG54084