Code of Conduct

1. About this Code

Eyesupply Limited (“Eyesupply”, “we”) is a UK distributor of medical devices, personal protective equipment (PPE) and related consumables to the NHS and independent healthcare providers. We do not manufacture, sterilise, relabel or repackage products.

This Code sets out how we meet UK law and NHS supplier requirements, including the NHS England Supplier Code of Conduct. It is short and proportionate because we are a micro-entity, but it applies in full.

2. Our commitments

• We act with integrity and use public money responsibly.
• We put patient safety first.
• We treat NHS staff, patients, suppliers and each other with dignity and respect.
• We comply with all UK laws, regulations and NHS requirements that apply to us, and we expect our suppliers to do the same.

3. Legal and NHS framework

The main requirements we follow are:

• UK law: Bribery Act 2010; Medical Devices Regulations 2002 (UK MDR); Personal Protective Equipment Regulation 2016/425 as it applies in Great Britain; Modern Slavery Act 2015; Procurement Act 2023; Competition Act 1998; Equality Act 2010; Health and Safety at Work etc. Act 1974; National Minimum Wage Act 1998; Working Time Regulations 1998; UK GDPR and Data Protection Act 2018; Criminal Finances Act 2017; Public Interest Disclosure Act 1998.
• NHS requirements: NHS England Supplier Code of Conduct and the terms of any NHS contract or framework we hold.

4. Anti-bribery and corruption

• We never offer, pay, request or accept bribes, facilitation payments or any improper advantage, directly or through anyone else.
• We never offer money, gifts or hospitality to influence a customer’s decision or gain a commercial advantage.
• We do not offer gifts to customer staff, other than low-value branded promotional items.
• Any hospitality is modest, linked to a genuine business or educational purpose, and never offered while a procurement is live.

5. Working with customer staff and conflicts of interest

• We respect organisations’ conflicts of interest policies and expect staff to declare anything they receive from us as their policies require.
• Any payment to a healthcare professional (for example for consultancy or training) is for a genuine, documented service at fair market value.
• Product samples are provided only for evaluation, in reasonable quantities, and are recorded.
• We declare any actual or possible conflict of interest and manage it appropriately.
• We never use any position to unfairly disadvantage other suppliers or reduce future competition.

6. Product quality and patient safety

• We supply only products lawfully placed on the Great Britain market: UKCA marked, or CE marked where the MHRA still recognises CE marking. Medical devices must be registered with the MHRA and have a valid Declaration of Conformity.
• We keep conformity documents for every product we supply.
• We store, handle and transport products as the manufacturer specifies, and we keep batch or lot traceability.
• We inform partners as appropriate should incidents arise. We support recalls without delay.
• We maintain a quality management system proportionate to our business, and we hold ISO 9001.
• Product claims are accurate, supported by evidence and consistent with the manufacturer’s Instructions for Use.

7. Fair competition and honest tendering

• We compete fairly and never agree prices, divide markets or share proposal information with competitors.
• Our tender responses and declarations are honest, accurate and complete.
• We are open about our costs and performance when required.
• We tell relevant partners about any supply-chain risk, such as possible shortages or the loss of a key supplier, as soon as we become aware of it.

8. Confidentiality, data and cyber security

• We protect confidential information in line with UK GDPR and our contracts, and we only use it for the purpose it was provided.
• We keep our systems secure and follow UK government and NCSC cyber security guidance, including Cyber Essentials where a contract requires it.

9. People, labour standards and modern slavery

In our own business, we:

• comply with UK employment law, including the National Minimum Wage, working time limits, written terms and paid holiday;
• do not discriminate on the basis of any protected characteristic under the Equality Act 2010, and do not tolerate harassment or bullying;
• provide a safe and healthy workplace.

In our supply chain, we require our suppliers to:

• comply with all employment and human rights laws where they operate;
• ensure there is no slavery, forced, bonded or child labour or human trafficking in their business or supply chain;
• pay at least the legal minimum wage and respect legal working hours;
• provide safe working conditions and not discriminate;
• comply with anti-bribery and environmental laws.

We check suppliers in proportion to risk, as set out in our Modern Slavery Policy. We pay particular attention where the risk of forced labour is higher. If a serious problem is not fixed, we stop using that supplier.

10. Financial integrity

• Our accounts, invoices and records are accurate and complete.
• We do not evade tax or help anyone else to evade tax.
• We do not take part in fraud or money laundering, and we do not trade with persons or countries subject to UK sanctions.

11. Environment and net zero

• We comply with UK environmental law and reduce our energy use, packaging and waste where practical.

12. Raising concerns

Anyone can raise a concern about a possible breach of this Code, or about any wrongdoing, without fear of retaliation.

• Internally: speak to or email the Director, Donald Sinclair.
• Externally (for example if the concern involves the Director): Protect, the whistleblowing charity (protect-advice.org.uk); the MHRA; the ICO; HMRC; or the Modern Slavery & Exploitation Helpline.

13. Breaches

A breach of this Code may lead to disciplinary action, including dismissal, or the end of a supplier relationship. We report breaches of the law to the relevant authority, and we tell customers where their contract requires it.

14. Monitoring and review

• Everyone working for Eyesupply reads and signs this Code when they join and reviews it every year.
• We share this Code with suppliers and customers via publishing it on our website.
• The Director reviews this Code every year, or sooner should UK law or customer requirements change.