What does the Code require?
Minimum expectations of suppliers and their subcontractors while under Commonwealth contract: ethical behaviour, corporate governance, business practices, and health, safety, and employee welfare. It does not supersede legislation or other obligations; it sits alongside them as a contractual layer. Mandated through the CPRs, with an Accountable Authority able to exempt a contract in part or full on a documented basis, but assume inclusion unless the pack says otherwise.
The Code places a positive duty on suppliers to prevent and discourage breaches, not merely to avoid committing them. Where the Commonwealth asks, tenderers and suppliers must demonstrate appropriate policies, frameworks, or similar covering ethics, governance, and accountability. Due diligence scales with the procurement’s scale, scope, and risk.
What evidence should you hold?
- Ethics and integrity policies. Written, current, and actually used: gifts, conflicts, whistleblowing.
- Governance framework. Who is accountable for compliance, and what happens when it fails.
- Work health and safety systems. Policies plus records, covering employees and subcontractors.
- Supply-chain visibility. What your subcontractors sign up to, and how you check, which is where modern slavery requirements enter the same conversation.
- Breach response. Notification and remediation process, because the Code’s misconduct provisions assume you have one.
Recheck the current Finance guidance before relying on any summary here; CPR changes taking effect from 17 November 2025 may move the surrounding references, and the Code’s implementation guidance is updated without fanfare.
What does this mean for the bid/no-bid call?
If the policies above do not exist in your firm today, a Commonwealth tender is a review, not a bid; writing them during the response window produces documents no one follows, which is worse than none. If they exist, the response work is demonstration, not invention. The scope of the CPRs themselves is on Commonwealth Procurement Rules.