Last updated: May 2026

1. Introduction

1.1 Policy Statement

Founded in 1949 and informed by the personal histories of our founders, Thames & Hudson (“T&H”) is proud to uphold high standards in acting fairly and ethically wherever and however we do business. These standards are built on our company values, the values of our employees and our collective commitment to acting with integrity throughout our organisation.

This Supplier Code of Conduct (the “Code”) outlines the minimum standards we expect from our suppliers and their subcontractors in conducting business and providing goods and services to T&H.

1.2 Scope of the Code

Our business comprises trade book and gift publishing and distribution services. We produce printed and electronic trade books and printed gift products and provide publishing and distribution services globally. Our registered office is in the UK, with over two hundred staff employed globally. We have subsidiary companies in France, Hong Kong, Singapore, and Australia as well as a sister company, Thames & Hudson Inc. in the US.

For the purposes of this Code, a Supplier includes, amongst others, all suppliers of goods or services, printers, repro houses, licensors, vendors, publishing partners, sub-contractors, agents, and sales representatives.

By working with a T&H entity, suppliers acknowledge their commitment to upholding this Code.

1.3 Compliance with the Code

T&H reserves the right to assess and monitor suppliers for compliance with this Code. Non-compliance may result in corrective action, termination of contracts, or other appropriate measures.

2. Operating with Integrity

2.1 Compliance with Laws and Regulations

Suppliers must comply with all applicable local, national, and international laws, administrative provisions, and regulations. This includes, but is not limited to, legislation relating to labour, health and safety, environmental protection, anti-bribery, and anti-corruption.

National and international laws regulate the import, export and domestic trade of goods and services, and capital movements and payments. Our Suppliers must have adequate procedures in place to ensure that transactions with third parties do not contravene economic embargoes or regulations of trade, import and export control or regulations for the combating of terrorism financing.

2.2 Anti-Corruption, Bribery and Fraud

Suppliers must conduct business ethically, free of corruption, bribery, and fraudulent practices. We take a zero-tolerance approach to bribery, corruption, and fraud, and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate. Trust and honesty are cornerstones of the T&H culture; therefore, we reserve the right to enquire or investigate any Supplier if any form of corruption is suspected.

2.3 Financial Integrity

Suppliers must conduct their business, store documents, and perform financial reporting with integrity. Accurate and honest records must be maintained, and any requested documentation should be shared with transparency.

All payments and transactions must follow all applicable laws and established accounting policies. Suppliers shall have appropriate procedures in place to detect and report money laundering.

T&H reserves the right to undertake credit checks and/or request references from third parties to ensure its Suppliers meet its financial integrity requirements.

2.4 Fair Competition

Suppliers must comply with all applicable anti-trust and competition laws. As ethical organisations, Suppliers shall be committed to behaving openly and fairly when competing for customers' business.

Suppliers will not engage in or tolerate any anti-competitive behaviour, including entering into restrictive agreements with competitors, suppliers, distributors, retailers, or customers. This includes, but is not limited to, price-fixing agreements with competitors; any form of market division or allocation agreement; bid-rigging; or the unlawful sharing of competitively sensitive information with competitors.


2.5 Protection of Intellectual Property

Suppliers shall respect and protect any type of intellectual property. Intellectual property covers any works of intellectual creation, including but not limited to, literary works, photographs, sound recordings, designs, databases, trademarks, and patents.

Intellectual property infringements include, but are not limited to, the publication, distribution or display of copyright or trademark material without permission or licence, and the creation and distribution of unauthorised copies of intellectual property, both in physical and digital form.

2.6 Data Privacy and Protection

Suppliers have a legal responsibility to safeguard the privacy of their clients, employees, and other parties, and must comply with all applicable laws and rules when personal data are collected, processed, transferred, or stored.

2.7 Information Security

Suppliers must only use information provided to them by T&H to fulfil their contractual obligations and shall protect it from internal and external misuse by implementing appropriate security measures. Failure to implement such measures can have significantly damaging consequences, such as cyber-attack, data loss, intellectual property infringement or identify theft.

Suppliers shall not use any information provided by T&H for any personal purpose, or a purpose which may be improper, unethical, or illegal.

Prior to T&H granting access to its systems or data, Suppliers are required to respond satisfactorily to an information security questionnaire. T&H reserves the right to deny Suppliers access to its systems where T&H is not satisfied that appropriate security measures have been implemented.

2.8 Subcontracting

Subcontracting is the use of an outside organization to do work that Suppliers are unable to do themselves. There may be several reasons for subcontracting, including a lack of expertise, a temporary shortage of resources or capacity, or a lack of appropriate equipment.

Prior to subcontracting, Suppliers must undertake preliminary due diligence to ensure the welfare of all subcontractor workers will be safeguarded, and that the provisions of this Code will be upheld. Once approval to subcontract has been approved by T&H, Suppliers must enter into a written agreement with their subcontractors, and monitor and record their compliance to the same standards as set out in this Code

Upon request, Suppliers must share all relevant subcontractor information, including audit reports, with T&H.

2.9 Land & Indigenous Peoples’ Rights

Suppliers must comply with the following principles:

• Conform to relevant international, national, and local standards of land tenure when working in communities.
• Undertake a due diligence process to understand the established rights to land and property in the communities where the Supplier works.
  
• Adhere to the practice of Free and Prior informed consent (“FPIC”) for land rights.

2.10 Conflicts of Interest

For the purposes of the Code, a potential conflict of interest occurs when the outside interests of an employee of a Supplier interfere with T&H’s interests or the employee's work-related duties. For example, a conflict of interest may occur when a Supplier’s employee is able to influence a decision that may result in a personal gain for the employee or the employee's family member because of business dealings with T&H.

Suppliers who are affected by a potential or actual conflict of interest in their activities in relation to T&H are obliged to disclose and resolve these as promptly as possible.

2.11 Confidentiality and Business Information

T&H confidential information includes any information or data that is sensitive or confidential within the organisation and intended solely for business use by those with a legitimate need to know. Unauthorised disclosure of such information could cause significant harm, including legal or financial liability, and damage to the reputation of T&H and its Suppliers.

T&H is committed to preserving the confidentiality and integrity of all its business information assets to preserve its competitiveness, cash-flow, profitability, and compliance with its legal, regulatory, and contractual obligations, as well as to protect its commercial reputation.

Suppliers must ensure that confidential information and data are stored securely, made accessible to authorised individuals only, and is only used for agreed business purposes. Any unauthorised disclosure of confidential information relating to T&H or its Suppliers to third parties, such as the media or competitors, shall constitute a breach of this Code.

3. Maintaining a Fair Workplace

3.1 Prohibition of Forced and Child Labour

Suppliers must not use any form of forced, bonded or involuntary labour. This prohibition applies to all work or service which is demanded from any person under the threat of any penalty and for which the individual has not offered themself voluntarily, modern forms of slavery and trafficking for labour.

Suppliers are also prohibited from using any form of child labour. Child labour is defined in accordance with the International Labour Organization (ILO) Conventions 138 and 182, and national laws. All workers must have reached the age of fifteen or have reached the minimum legal working age under national law, whichever age is the higher.

3.2 Health and Safety

T&H provides and maintains a healthy and safe working environment for all its employees and for others who visit its places of work. T&H does all that is reasonable and practicable to prevent personal injury and to comply with the duties laid upon the company as an employer under relevant legislation.

Suppliers are expected to provide a safe and healthy working environment for their employees. This includes:

• Identifying and mitigating workplace hazards.
  
• Providing proper training and safety equipment.
  
• Ensuring emergency preparedness.

3.3 Anti-Discrimination and Harassment

T&H’s employees have a responsibility to always treat others with dignity, respect, and courtesy. All employees are expected to exhibit conduct that reflects these behaviours, as well as attend training to enhance knowledge and awareness.

T&H does not tolerate discrimination because of age, colour, disability, ethnicity, family or marital status, gender, gender identity or expression, nationality, physical and mental ability, race, religion, sex, sexual orientation, socio-economic status, or any other characteristic that makes all of us unique.

Suppliers must conduct their business in a respectful and dignified manner, in an environment which treats its employees with dignity, free from harassment, bullying, discrimination, physical and verbal abuse, threats or intimidation of any description.

3.4 Fair Working Conditions

Suppliers must pay workers timely and in compliance with applicable wage laws, including minimum wages, overtime, and legally mandated benefits as well as complying with legal limits on working hours and provide workers with adequate rest periods.

4. Environmental Responsibilities

4.1 Initiatives

We have signed the Publishing Declares Pledge. This includes commitments to setting measurable targets to limit global warming to 1.5 °C, while also protecting nature and biodiversity, strengthening sustainable industry partnerships, educating employees on climate issues, and using our platform to advocate for environmental action.

We have conducted a carbon footprint of the business using the leading international standard, the Green House Gas Protocol. This has enabled us to identify the most problematic areas and establish a benchmark for reductions.

4.2 Paper

Paper is the single largest source of emissions arising from our activities (because of the energy needed to convert pulp into paper). We are working with our suppliers to move from high to low-carbon papers.

Additionally, we are aware of the harm that occurs because of uncontrolled deforestation. Therefore, we have been requiring our suppliers to use paper from mills that have been certified by the Forestry Stewardship Council (FSC) and the Programme for the Endorsement of Forest Certification (PEFC).

4.3 Printing

We are committed to working only with print suppliers who can demonstrate a commitment to preserving the environment. We require ISO 14001 accreditation as a minimum. ISO 14001 is a standard that requires effective Environmental Management Systems to be in place. These ensure effective management of waste, careful use of energy and recycling processes in line with governments standards.

We are aiming to further reduce emissions and waste by increasing use of economical page size formats.

4.4 Shipping & Distribution

We are a global publisher so transporting our books to customers inevitably has an environmental impact. We are minimising this by shipping rather than air freighting books. 91% of our shipping is with companies that have certified schemes to reduce emissions in line with science-based targets.

We are also aiming to consolidate as many shipments as possible, which has a positive impact on milage and emissions.

4.5 Emissions

In early 2025 we moved into a new office building, which is highly energy efficient. We use air source heat pumps for our heating and we use renewable electricity. This has resulted in our office-related emissions decreasing by around 80%.

We have the recycling facilities in place to ensure we comply with the workplace recycling regulations that came into effect on 31st March 2025.

Business travel is the most significant source of employee-related emissions, so we have introduced sustainable travel principles that prioritise rail transport and virtual meetings.

We have quantified the emissions generated by employees commuting. These are less than 1% of the total. Our new office is in central London, so almost all employees commute using public transport.

5. Implementation

5.1 Observation of the Code

Suppliers shall ensure that the minimum standards set out in this Code are complied with in all their business dealings with T&H.

5.2 Supply Chain Compliance

Suppliers shall implement and maintain effective systems to ensure that the provisions of this Code are adhered to by their own subcontractors/suppliers engaged in activities for T&H, and to monitor and document such compliance to T&H’s satisfaction.

5.3 Violations of the Code

If T&H considers that a Supplier is not in compliance with the Code, the Supplier must take all such appropriate remedial actions as requested by T&H to address any areas of concern, including supporting any investigation conducted by T&H or its appointed representative(s).

Failure to remedy any area of concern within a reasonable timeframe may result in T&H taking further appropriate action, including contract termination.

6. Reporting Violations

Should Suppliers have any queries regarding any part of the Code, please contact your T&H business contact.

Any suspected violation of the Code should be reported to T&H’s Legal & Business Affairs team:

dept.legal-business-affairs@thameshudson.co.uk

Postal address:

Thames & Hudson Limited
6-24 Britannia Street
London, WC1X 9JD, United Kingdom