Supplier Code of Conduct

1. Purpose and scope

Roam designs, installs, owns and operates electric vehicle charging infrastructure across the UK. Our purpose is to make the transition to electric transport straightforward for the people and organisations we serve. How we deliver that matters as much as what we deliver.

This Code sets out the standards we expect of every organisation that supplies goods, services or labour to Roam. It applies to all suppliers, subcontractors, agents and consultants.

Suppliers must apply equivalent standards throughout their own supply chains, and must communicate this Code to their employees, subcontractors, agency workers and temporary staff engaged in work for Roam.

Several of our clients operate their own supplier codes and responsible sourcing policies. Where we deliver work for those clients, we may need to pass their requirements through to you. We will tell you when that applies and give you the relevant documents. Those requirements then form part of the standards you must meet under this Code. You must accept them, and complete any client questionnaires, declarations or registrations we ask for, within the timeframes we give you.

This Code sets a minimum standard, not a maximum. Where the law and this Code address the same subject, apply whichever affords the greater protection to workers and the environment. This Code does not replace the terms of any contract between us; where a contractual obligation is more demanding, the contract applies.

2. Legal and ethical conduct

• Comply with all applicable laws, regulations and industry standards in the countries in which you operate.
• Do not offer, give, request or accept bribes, kickbacks or improper payments. We expect suppliers to have controls consistent with the Bribery Act 2010.
• Do not engage in money laundering, insider trading, fraud, or unauthorised access to personal or business information.
• Do not engage in any conduct that would constitute an offence, or cause Roam to commit an offence, under sections 45 or 46 of the Criminal Finances Act 2017. Maintain your own policies and procedures to prevent the facilitation of tax evasion, and include anti-tax evasion provisions no less onerous than these in your contracts with your own suppliers and subcontractors. Comply with applicable tax, competition, sanctions and export control law, and maintain accurate books and records.
• Declare any actual or potential conflict of interest involving Roam employees. Any gift or hospitality offered to or accepted from Roam must be modest, infrequent and recorded in your own gifts and hospitality register, which you must make available to us on request. Do not offer anything that could reasonably be seen to influence a business decision.
• Do not misrepresent your certifications, accreditations, insurances or capabilities to Roam.
• Tell us promptly about any serious breach of this Code, and about any investigation by a regulator or enforcement authority into your compliance, where it relates to work performed for Roam.

3. Human rights and labour standards

We expect suppliers to respect internationally recognised human rights, consistent with the UN Guiding Principles on Business and Human Rights and the core ILO conventions.

Modern slavery and forced labour

• No forced, bonded, indentured, trafficked or involuntary prison labour in any form. All work must be voluntary and free from threat.
• Do not charge workers recruitment fees, directly or indirectly, and do not require deposits.
• Do not retain workers’ identity or travel documents, or restrict their freedom of movement.
• Workers must be free to leave employment on reasonable notice and receive all earned wages, with those terms explained before employment begins and confirmed in their contract.
• Maintain controls consistent with the Modern Slavery Act 2015, and notify us promptly of any actual or suspected instance of modern slavery, forced labour or other breach of the labour standards in this Code, whether in your own business or your supply chain.

Child labour and young workers

Do not employ anyone under 15, or under the local compulsory school leaving age if that is higher. Where ILO conventions designate a minimum age of 14 for a particular country, that applies instead.

Maintain formal documentation verifying the age of every worker.

Workers under 18 must not work at night, work long hours, or perform hazardous work, including work involving exposure to chemicals, dust, or excessive heat, cold or noise.

Where local law and international standards conflict, apply the standard that offers greater protection.

Wages and working hours

• Pay at least the national legal minimum or the relevant industry benchmark, whichever is higher, and pay in full, on time and directly to the worker.
• Provide written, understandable information about pay and employment conditions before employment begins, in a language the worker understands, and provide a pay statement each pay period.
• Do not make deductions from wages as a disciplinary measure, or any deduction not provided for in law.
• Basic working hours must not exceed 48 per week, and workers must have at least one day off in every seven-day period.
• Overtime must be voluntary and properly paid. Workers may decline overtime without disciplinary or retaliatory consequence.
• Provide contractual annual leave in line with a clear policy communicated to workers.
• Roam is an accredited Real Living Wage employer and encourages suppliers to work towards the same standard.

Employment relationships

• Work must be performed under a recognised employment relationship established through national law and practice.
• Do not use labour-only contracting, subcontracting, home-working arrangements, apprenticeship schemes with no genuine intent to impart skills, or excessive fixed-term contracts to avoid obligations to workers.
• Migrant, agency, contract and part-time workers must receive equivalent rights, benefits and opportunities to directly employed workers performing similar work.
• Where you use agencies or subcontractors, their employment terms and labour standards must be formally understood and documented by you.
• Keep an up-to-date list of everyone working on site for Roam, including direct employees, agency workers and subcontracted personnel, and provide it to us on request.

Fair treatment, equality and inclusion

• Comply with the Equality Act 2010. Recruit, pay and promote on merit, and do not discriminate on the basis of any protected characteristic.
• Do not tolerate harassment, bullying, victimisation, physical or verbal abuse, sexual harassment or intimidation. Record any incident and act on it.
• Disciplinary action must be fair, proportionate, lawful and recorded.
• Respect freedom of association and the right to collective bargaining where lawful, and do not retaliate against workers exercising those rights.
• When delivering services to residents, tenants or members of the public, make reasonable adjustments to support people with disabilities or additional needs.
• Maintain a whistleblowing policy and grievance mechanism for your own workers, owned by a named senior member of staff.

4. Health, safety and wellbeing

Much of the work carried out on our behalf involves electrical installation and works in public and occupied premises. Safety is not negotiable.

• Maintain a documented health and safety management system proportionate to your activities, and comply with all applicable health and safety law.
• Assign responsibility for health and safety to a named, competent senior manager.
• Ensure everyone working on Roam sites is competent, appropriately qualified and holds current certification for the work they perform.
• Provide recorded health and safety training, repeated for new and reassigned workers and refreshed whenever working methods change.
• Carry out suitable risk assessments and method statements, and provide the correct plant, tools and personal protective equipment.
• Maintain a record of accidents and injuries with an action plan to address causes, and report all accidents, near misses and dangerous occurrences arising from work for Roam to us promptly.
• Where worker accommodation is provided, it must meet applicable health, sanitation, fire and structural safety requirements and afford reasonable privacy.
• Support the mental as well as physical wellbeing of your workforce.

5. Personnel vetting and safeguarding

Our engineers, surveyors and subcontractors work in and around occupied homes, including social housing and communal residential settings, and on school sites. Roam’s Safeguarding Policy applies to all work carried out on our behalf. Where you work in a residential or school setting we will provide it to you, and you must follow it.

• Operate a documented procedure for checking, validating and recording the identity and right to work of everyone you send to work on Roam contracts, including agency and subcontracted personnel, and take up employment references covering recent employment history. Keep the records centrally and be able to produce them on site.
• Hold a current Basic DBS check for every operative attending occupied homes, and an Enhanced DBS check for every operative attending a school site, or such other vetting standard as the site or Roam client requires. Retain the records and make them available to us on request.
• Ensure operatives working in residential or school settings complete safeguarding awareness training and follow the code of conduct for that setting set out in Roam’s Safeguarding Policy.
• Follow the site’s own access, sign-in and supervision requirements when working on a school site, including any requirement to be escorted or to work outside school hours.
• Report any safeguarding concern arising on a Roam project to Roam’s Designated Safeguard Lead the same working day. Where someone is in immediate danger, call the emergency services first.
• Report immediately any allegation or concern about the conduct of your own personnel towards a child or adult at risk. Do not investigate it yourself.
• Where a Roam client operates its own safeguarding procedure, follow it in addition to ours.

6. Environment and climate

Roam has emissions reduction targets validated by the Science Based Targets initiative. The majority of our footprint sits in our value chain, which means we cannot meet those targets without our suppliers. We therefore expect the following.

7. Data protection and information security

• Comply with the UK GDPR and the Data Protection Act 2018, and process any personal data shared by Roam only as instructed and for the purposes we have agreed.
• Do not share Roam personal data with subcontractors or any third party without our prior written permission.
• Do not transfer Roam or client personal data outside the UK without our prior written consent.
• Ensure your employees handling Roam data are trained in data protection and information security.
• Before anyone you engage has access to Roam or client data, complete right to work, employment history and Basic DBS checks, plus financial checks for anyone with access to financial information. Provide the results to us on request.
• Apply appropriate technical and organisational security controls. Roam holds ISO 27001 certification and expects suppliers handling our data or connecting to our systems to demonstrate equivalent control.
• Notify Roam immediately, and in any event within 24 hours, if you suspect or have reason to believe that a security incident or personal data breach has occurred affecting Roam data, systems, clients or customers. Provide further details as they become available and follow our instructions on managing the incident.
• Protect Roam confidential information and that of our clients, and return or securely destroy it on our request or when it is no longer required, and certify destruction on request.
• Do not make any public statement, post on social media, publish case studies or photographs, or otherwise disclose that you are working for a Roam client or use a client’s name or brand, without Roam’s prior written approval.

8. Responsible sourcing and product quality

• Know your own supply chain, and be able to tell us where the goods you supply to us are made.
• Operate a due diligence process to check that your own suppliers and subcontractors meet the standards in this Code, and share the results with us on request.
• Where we ask, register on SEDEX and link to Roam and, where relevant, to our client, and ask your own suppliers to do the same.
• Source minerals and materials responsibly, including conflict minerals, and be able to evidence due diligence on request.
• Supply goods that meet the relevant product safety, electrical and conformity standards for the UK market.
• Where you supply charge point hardware, software or back-office services, ensure they support Roam’s compliance with the Public Charge Point Regulations 2023.
• Provide accurate technical documentation, and notify us of any product defect, safety issue, recall or specification change affecting goods supplied to Roam within three working days of becoming aware of it, or immediately where there is a safety risk.
• Do not subcontract any part of the work without our prior written consent, keep us informed of every subcontractor involved, and satisfy yourself that any subcontractor is competent for the work.
• Where you carry out electrical installation work on Roam’s behalf, hold NICEIC or equivalent UKAS-accredited scheme, for example NAPIT, Approved Contractor status for the duration of the contract, and ensure any electrician you engage for that work holds it too. Carry out all installation work to BS 7671 and the IET Code of Practice for Electric Vehicle Charging Equipment Installation.
• Where electrical work is being claimed under an OZEV grant scheme, hold current OZEV-authorised installer status and maintain any registration Roam needs to make or support the claim.
• Meet agreed lead times and quality standards, and tell us early when you cannot.

9. Business continuity

• Maintain proportionate plans for disruption to your operations, including severe weather, cyber incidents, supply shortages and workforce absence.
• Tell us promptly about any event likely to affect your ability to supply Roam, and about the steps you are taking.
• Where you provide services critical to the operation of our charge points, your business continuity and disaster recovery arrangements must be consistent with Roam’s Risk and Resilience Policy. Share them with us on request, take part in testing where we ask, and notify us immediately of any disruption.

10. Social value and community benefit

Our clients increasingly ask us to demonstrate the wider benefit our contracts deliver, and we cannot do that alone. We encourage suppliers to support the communities where work takes place by:

• Recruiting and training locally, and offering apprenticeships, work experience and employment routes for people facing barriers to work.
• Paying fair wages and promoting equality in your own workforce.
• Giving small and medium-sized businesses and diverse suppliers a fair opportunity to compete for your work.
• Supporting education, environmental and community initiatives locally.
• Where a Roam contract carries specific social value commitments, we will tell you what is required and agree how it will be measured.

11. Raising concerns

Anyone working for a Roam supplier can raise a concern about conduct connected to Roam, in confidence and without fear of retaliation. Concerns can be raised with your usual Roam contact or by emailing esg@roamcharging.com.

We expect suppliers to provide their own workers with an equivalent route to raise concerns, and to protect anyone who does so in good faith from detriment.

12. Compliance, monitoring and consequences

• We ask suppliers to acknowledge this Code in writing. For new suppliers, acknowledgement forms part of our onboarding process.
• We may ask you to complete a supplier assessment, provide supporting evidence, or take part in an audit or site visit, on reasonable notice, or at short notice where there is suspected fraud, a security incident or a serious breach, with access to relevant premises, records and personnel. Where a Roam client requires visibility of our supply chain, this may extend to their auditors.
• We, our clients or their appointed auditors may carry out an ethical audit of your facilities, and of sites connected with your work for us, to the SMETA standard or equivalent. You must close any non-conformance within the timeframe set in the audit report. Where a follow-up audit is needed because of a non-conformance, you will bear its cost.
• Keep records relating to work for Roam for at least six years.
• Where you already hold certifications or operate to standards comparable to those in this Code, tell us. We will recognise them rather than duplicate the work.
• Tell us promptly if you become aware of a breach of this Code in connection with work performed for Roam.
• Where we identify a shortfall, our normal approach is to agree a corrective action plan with you and support you to close it.
• Persistent or serious breaches, or a refusal to engage, may lead to suspension or termination of our relationship in line with the relevant contract terms. Before ending a relationship we will consider the impact on your business and the people it employs.
• Where a breach places Roam in breach of a client contract, or involves modern slavery, child labour, bribery, a safeguarding concern or a serious safety failure, we may suspend or end the relationship immediately and may require the removal of any individual or subcontractor from a client’s sites.
• We may update this Code from time to time. The current version is published on our website, and continuing to supply Roam after an update constitutes acceptance of it.

13. What you can expect from us

This Code places obligations on our suppliers. We hold ourselves to the following in return.

• We will work to fair, transparent and mutually agreed terms, and will not use our position to impose unreasonable conditions.
• We will pay correctly submitted invoices in full and in accordance with agreed terms.
• We will give clear instructions, reasonable notice and accurate information.
• We will work with you where standards need to improve, rather than simply withdrawing.
• We will protect confidential information you entrust to us.
• We will keep our own requirements proportionate to the size of your business and the nature of what you supply.

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