Supplier Code of Conduct

The vision of the Universal Group of companies (hereinafter “Universal”) is to create value in our chosen markets by empowering wellness and crafting a better, healthier future.

This Code applies to all suppliers of products and services to Universal (hereinafter “Business Partners”). Business Partners are required to adhere to the standards in this Code and comply with all relevant laws and regulations.

Universal is committed to do business with integrity and the highest standards of quality and ethics.  We aim to be fair and transparent in everything that we do and to instill a culture of trust for our internal and external stakeholders.  We will therefore only conduct business with individuals and businesses who share our vision and commitment  in this regard.  Our aim is to maintain a good and mutually beneficial business relationship with each of our Business Partners.

Business Integrity

Legal Compliance

Business Partners must comply with all applicable local, national and international laws and meet the requirements set by regulatory bodies.  This includes the Intellectual Property rights of the Parties.

Anti-Bribery and Corruption and Fraud Prevention

Universal has a zero tolerance for any form of corruption, including bribery, fraud, money laundering, extortion, facilitation payments etc.

 No Business Partners or associated person may directly or indirectly bribe a government official or any third party. Similarly, no Business Partners or associated person may receive anything of value in exchange for performing their duties disloyally or illegally. Any demand for, or offer of, a bribe must be rejected immediately and reported to the Universal Group, Legal, Risk and Compliance Department.

Gifts and Hospitality


All gifts and hospitality extended to Universal employees must be declared in terms of our policies which sets out acceptable thresholds while considering the local custom, position of the recipient and the circumstances. Charitable and political donations warrant extra scrutiny and must be pre-approved by the Group CEO or CFO.

Conflicts of Interest

All Business Partners are required to disclose any present or past relationship between themselves and Universal employees that would be construed as a conflict. The same applies to material relationships with our clients in the public sector.

Protected disclosures and whistleblowing

Universal has an independent tip-off line that can be used to report any allegations of fraud, corruption and unethical behaviour anonymously:

Toll free line: 080 111 4447


Global Human Trafficking: [email protected]


Our Ethics Policy incorporates the 10 United Nations Global Impact Principles and sets out the standards of integrity and professional behaviour that we subscribe to.

Record Keeping

Business Partners must ensure that financial books and business records are accurate and fairly reflect, in reasonable detail, all transactions and dispositions of assets.

Due diligence

Universal’s policies require that due diligence is performed on a risk based approach when new Business Partners are contracted.

Human Rights and working conditions

Human Rights

Businesses should support and respect the protection of internationally proclaimed human rights; and make sure that they are not complicit in human rights abuses.  All forms of discrimination and harassment must be strictly prohibited.



Businesses should uphold the freedom of association and the effective recognition of the right to collective bargaining. Suppliers and service providers must prohibit, and not benefit from any forms of forms of forced, compulsory labour or child labour.  Workers must never be required to relinquish identity papers, passports or work permits as a condition of employment or required to pay recruitment fees.  There must be a balance between work and leisure and overtime must be dealt with in terms of the relevant laws of the location where the business is conducted.

Health and Safety


Business Partners must ensure high standards of occupational health and safety throughout their organisation that are aimed to prevent all accidents, injuries and occupational illnesses within their operations. Health and safety practices must, at minimum, comply with national and local laws and international best practice. 

Due diligence

Universal’s policies require that due diligence is performed on a risk based approach when new Business Partners are contracted.

Privacy and Data Protection

Universal respects the privacy rights of our internal and external stakeholders and places a top priority on the protection of personal information.  We have a comprehensive information security management framework in place to ensure that we comply with all the applicable data protection laws and best practices.

Our Business Partners are required to do the same and to be able to demonstrate that they have reasonable and appropriate technical and organisational measures in place to prevent unauthorised access to personal and confidential information.


Business Partners must observe all applicable laws and regulations concerning the environment and contribute to environmental sustainability in their operations.

Compliance with the Code

Universal reserves the right to verify your compliance with the Code. As our trusted Business Partner you are required to distribute the code to your employees, subcontractors and suppliers.

In the event that we become aware of any actions or conditions that are in conflict with this Code, we reserve the right to demand corrective actions or measures, including terminating our business relationship.

Continuous Improvement

Business Partners are encouraged to continuously improve their ethical, social, environmental practices and operations to align with international standards and best practices.

Contact Us

Contact Number:  +27 (0)11 208 1000
Email Address:  [email protected]