Reasonable Sourcing Policy

NuColour Ltd

1. Policy Statement

At NuColour Ltd, we are committed to ethical, responsible, and sustainable sourcing practices. We recognise the importance of sourcing materials, equipment, and services from suppliers that uphold high standards in environmental responsibility, fair labour practices, and human rights.

Our reasonable sourcing policy ensures that all procurement activities align with legal, social, and environmental obligations, while maintaining high-quality standards in our commercial spray painting, protective coatings, and refurbishment services.

This policy applies to all employees, subcontractors, and suppliers involved in the procurement of goods and services for NuColour Ltd.

2. Legal & Regulatory Compliance

NuColour Ltd ensures full compliance with the following legislation and industry standards:

✔ The Modern Slavery Act 2015 – Ensuring no forced, bonded, or child labour is used in our supply chain.
✔ The Bribery Act 2010 – Ensuring procurement decisions are free from bribery, corruption, and undue influence.
✔ The Equality Act 2010 – Promoting diversity and non-discrimination in supplier selection.
✔ The Environmental Protection Act 1990 – Ensuring responsible sourcing of eco-friendly materials.
✔ The Waste (England and Wales) Regulations 2011 – Supporting suppliers that prioritise sustainable waste management.

All suppliers and contractors must comply with these legal standards and adhere to our responsible sourcing requirements.

3. Ethical Sourcing Standards

NuColour Ltd expects all suppliers and subcontractors to:

✔ Respect Human Rights & Fair Labour Practices

• No use of forced, bonded, or child labour.
• Compliance with legal minimum wage requirements.
• Providing a safe and fair working environment for employees.

✔ Ensure Ethical Supply Chains

• No engagement in human trafficking, discrimination, or exploitation.
• Commitment to diversity and inclusion in employment practices.

✔ Promote Environmental Sustainability

• Prioritising the use of low-VOC paints, sustainable coatings, and recyclable materials.
• Reducing carbon footprint and environmental impact.
• Minimising waste production and promoting circular economy principles.

✔ Maintain Transparency & Accountability

• Disclosing sources of raw materials and labour practices upon request.
• Engaging in regular audits and supplier assessments to verify compliance.

4. Supplier Selection & Procurement Guidelines

4.1. Due Diligence & Risk Assessment

NuColour Ltd will:

✔ Conduct due diligence checks on all new suppliers.
✔ Assess ethical, legal, and sustainability risks before entering supply agreements.
✔ Require suppliers to demonstrate compliance with UK laws and industry best practices.

4.2. Preferred Suppliers & Sustainable Procurement

NuColour Ltd prioritises:

✔ Suppliers with recognised sustainability accreditations (ISO 14001, FSC, etc.).
✔ Local suppliers to minimise transport-related carbon emissions.
✔ Eco-friendly materials that align with low-VOC and non-toxic coating solutions.

4.3. Continuous Monitoring & Improvement

✔ Conduct regular reviews of supplier performance to ensure ongoing compliance.
✔ Engage in open communication with suppliers about sustainability and ethical practices.
✔ Require corrective action plans for suppliers failing to meet ethical sourcing standards.

5. Responsibilities

5.1. Employer Responsibilities (NuColour Ltd)

✔ Maintain a transparent and responsible supply chain.
✔ Conduct regular supplier audits and risk assessments.
✔ Provide training for procurement staff on ethical sourcing.

5.2. Supplier Responsibilities

✔ Comply with all relevant UK laws and industry standards.
✔ Provide evidence of responsible sourcing and ethical business practices.
✔ Engage in fair employment and environmental sustainability initiatives.

6. Reporting & Whistleblowing

NuColour Ltd encourages employees, suppliers, and stakeholders to report any concerns regarding unethical sourcing, modern slavery, or supply chain malpractice.

Email: sales@londonsprayers.co.uk
Phone: 03301 333 420
Address: 86-90 Paul St, London, EC2A 4NE

All reports will be handled confidentially, and appropriate action will be taken.

7. Monitoring & Review

This policy will be reviewed annually or whenever necessary to reflect changes in legislation, industry standards, or business operations.

Last Reviewed: 16.03.2025
Next Review Date: 16.03.2026

NuColour Ltd remains committed to ethical sourcing, sustainable procurement, and compliance with all UK laws.