code of conduct

section 1. applicable to all.

 

what is our Code of Conduct and who is it for?

our Code of Conduct exhibits our minimum business commitments and is focused on our policies to ensure we act appropriately, in line with industry standards, law, regulation, stakeholder, supply, distribution and customer expectations. if circumstances beyond our control arise (for example climate events), we may temporarily use alternative sources where needed, any alternatives would still meet our food safety, legal and animal welfare standards.

it applies to the whole of our business, to us, and to all the supply and distribution, franchisees, contractors, consultants, service providers, and agents who support us.

while every policy area may not be relevant to everyone, we should all understand our commitments and comply with them as far as they affect us.

in the event an employee was found not to comply with any of the relevant parts of our code of conduct, the internal policies will apply. for any 3rd party suppliers or contractors, this will be subject to our contractual terms, and we shall always respond decisively to a breach.

 

human rights

we are committed to respecting international recognised human rights in line with the United Nations Guiding Principles on Business and Human Rights [https://www.un.org/en/about-us/universal-declaration-of-human-rights]

we do not tolerate or condone any abuse of human rights within the supply and distribution partners, franchisees, contractors, consultants, service providers, and agents who support our business.

anti bribery, corruption, and conflicts of interest

we are committed to the highest standards of ethics and honesty and operate a zero-tolerance approach to bribery and corruption.

the giving or receiving of bribes and any other form of corrupt payment, in any course of conduct involving itsu is unacceptable.

none of our business dealings will be inappropriately influenced by personal and/or considerations of personal relationships. we act with integrity in all our business relationships.

 

modern slavery

we require our supply and distribution, franchisees, contractors, consultants, service providers, and agents to publish an annual report setting out the steps taken to prevent modern slavery as per section 54 (Transparency in Supply Chains) of the Modern Slavery Act 2015. [https://www.legislation.gov.uk/ukpga/2015/30/contents]

 

supply chain and responsible sourcing

the following applies to all our supply and distribution, franchisees, contractors, consultants, service providers, and agents for all goods and/or services (also known as ‘all 3rd party spend’).

we are committed to responsible sourcing across our procurement and supply chains, ensuring that our partners are treated fairly and lawfully, and we insist our partners do the same.

we actively source products and services for our operations in an ethical, environmentally sustainable, and socially conscious way and we monitor these through audit compliance and our contractual terms.

we ensure our business practices, in our own business and across our partners businesses, have a positive impact, on people and the planet.

we work ethically with our partners to ensure their employees are provided with good working conditions. we agree standards and monitor these through frequent site visits that encourage continuous improvement.

we expect our partners to demonstrate that they are mitigating risk and maximising a transparent supply chain. if a significant risk is identified, we will work together to manage, monitor, and mitigate.

all of our partners will have to have a transparent and appropriate business continuity plan to ensure any business risks are mitigated.

 

section 2. applicable to all directly involved in food, beverage, and packaging.

 

food, beverage, and packaging requirements

as part of our commitment to worker welfare across our supply chain, we require all food, drink, packaging supply, and distribution partners to:

• be accredited to BRCGS Global Food Safety Standard (or an equivalent GFSI standard).
• be registered on SEDEX with a supplier membership.
  • be only approved as an itsu supplier once linked with itsu.
  • have renewed annual SEDEX membership.
  • have fully completed the SEDEX Self-Assessment Questionnaire (SAQ).
  • ensure their site is linked and the site, SEDEX SAQ, and audit information is visible to us:
    • itsu grocery - ZC415702304
    • itsu retail - ZC421226474
  • update and review the self-assessment questionnaire(s) at least once annually.

supplier and distribution partners who are rated ‘high risk’ by the SEDEX system must undertake a 2-pillar SMETA audit and share the report with us through the SEDEX platform, at a frequency agreed with us.

before commencing supply to us, ‘high risk’ supply partners must have undertaken a SMETA audit within the previous 12 months and have an appropriate action plan or have signed off any critical non-conformances.

all animal protein supplied to us must meet retained EU and/or UK legislation and adhere to the principles of the Farm Animal Welfare Council (FAWC) Five Freedoms for animal welfare:

• freedom from hunger and thirst
• freedom from discomfort
• freedom from pain, injury, or disease
• freedom to express normal behaviour
• freedom from fear and distress

all fresh red meat and poultry are humanely slaughtered and are appropriately gassed and/or pre-stunned prior to slaughtering.

antibiotics are only used as necessary and should not be in replacement of good animal husbandry. we do not permit the routine prophylactic use of antibiotics. prophylactic antibiotics treatment should only be considered under exceptional circumstances.

there is no genetic engineering or cloning of animals used in our products.

long-distance transportation of live animals across species is to be avoided. transportation should be kept to a minimum and not exceed 8 hours except in exceptional circumstances outside the hauliers or processors control.

 

beef

in addition to our food, beverage, and packaging requirements:

we will only use beef sourced from farms that are certified to a recognised farm assurance scheme such as Red Tractor, Bord Bia, RSPCA assured or QS.

we do not permit castration, de-horning or disbudding across our farms without prior anaesthesia and or analgesia, and all cattle are to be pre-stunned prior to slaughter to ensure the most humane method is followed.

we do not condone the use of electric goads to help move cattle across any of our farms or abattoirs. if required, it will only be used as a last resort and should not be used as a primary driving tool. It will be used as sparingly as possible.

 

chicken

in addition to our food, beverage, and packaging requirements:

all our fresh chicken is to be sourced to Red Tractor standards (or international equivalent) as a minimum.

as part of our commitment to improve welfare standards, we have signed up to the Better Chicken Commitment (BCC) with the aim of meeting all possible requirements by 2026.

Better Chicken Commitment requirement:

• comply with all UK and EU animal welfare laws and regulations, regardless of the country of production.
• implement a maximum stocking density of 30kg/m2 or less. Thinning is discouraged and if practiced must be limited to one thin per flock.
• adopt breeds that demonstrate higher welfare outcomes: either the following breeds, Hubbard Redbro (indoor only), JACY57, JA757, 787, 957, or 987, Rambler Ranger, Ranger Classic, and Ranger Gold, or others that meet the criteria of the RSPCA Broiler Breed Welfare Assessment Protocol.
• meet improved environmental standards including:
  • at least 50 lux of light, including natural light.
  • at least two metres of usable perch space, and two pecking substrates, per 1,000 birds.
  • on air quality, the maximum requirements of Annex 2.3 of the EU broiler directive, regardless of stocking density.
  • no cages or multi-tier systems.
  • adopt controlled atmospheric stunning using inert gas or multi-phase systems, or effective electrical stunning without live inversion.
  • demonstrate compliance with the above standards via third-party auditing and annual public reporting on progress towards this commitment

 

pork

in addition to our food, beverage, and packaging requirements:

to ensure the welfare of pigs in our supply chain, we will only use fresh pork sourced from farms that are certified to a recognised farm assurance scheme such as Red Tractor, RSPCA assured, QS or an equivalent international standard.

the routine tail docking, teeth clipping or teeth grinding of pigs is not permitted unless it is in the best interests of pig welfare. we do not permit castration, and we do not recommend the use of electric goads to help move pigs across any of our farms or abattoirs. if required, it will only be used as a last resort and should not be used as a primary driving tool. It will be used as sparingly as possible.

 

duck

in addition to our food, beverage, and packaging requirements:

from the end of 2026 we will only use duck sourced from farms that are certified to a recognised farm assurance scheme such as Red Tractor, QS, RSPCA assured or international equivalent.

no caged animals are permitted; ducks must have access to water facilities which allow the duck to cover their head and take water up by the bill to preen effectively.

none of the following is permitted: de-winging, pinioning, notching, severing tendons, or conducting any other operation that mutilates wings. When it is appropriate to prevent flying, the flight feathers of one wing should be clipped.

 

fish and seafood

to ensure the sustainability and welfare of fish, all suppliers of fish / seafood to us must complete an annual Fish and Seafood Traceability Exercise, providing details of the product country of origin, capture method, accreditation rating, and any relevant eco-labelling.

fish or seafood from aquaculture that we use are sourced to the following commitment: 

• all wild fish - to be MSC accredited where it is available www.msc.org
• all farmed fish - to be sourced from Global G.A.P www.globalgap.org and/or Aquaculture Stewardship Council (ASC) www.asc-aqua.org certified farms.

we are committed to working with our suppliers to help understand and support the adoption of best practice in pre-slaughter handling and stunning.

all farmed fish are to be pre-stunned, ensuring loss of consciousness prior to slaughter.

we do not allow routine prophylactic use of antibiotics in farmed fish. the use of antibiotics identified as critical for human health are specifically prohibited.

as well as farms and hatcheries being certified we also aim to have all the marine ingredients used in our fish feed certified to the International Fishmeal & Fish Oil Organisation (IFFO) standard, helping to ensure a responsible approach for the supply and production of these ingredients.

to uphold our high standards, we will not source any species that are:

• listed under the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES)
• listed on the International Union for Conservation of Nature (IUCN) red list of threatened species as ‘endangered’ and ‘critically endangered.’
• caught by illegal, unreported, and unregulated (IUU) fishing.
• rated 4 - 5 by the Marine Conservation Society (MCS) Good Fish Guide

fish or seafood from aquaculture used in our products should be sourced from farms meeting one of the following requirements:

• sourced from a farm that has been certified by a third-party standard recognised by the Global Sustainable Seafood Initiative (GSSI Recognised Certification), such as:
  • Best Aquaculture Practices (BAP)
  • Aquaculture Stewardship Council (ASC)
  • Global G.A.P
  • or, from an Aquaculture Improvement Project (AIP) listed on the AIP Directory.

 

prawns

in addition to our fish and seafood requirements, and to ensure the sustainability and welfare of prawns, all prawns used in our products will be sourced from ASC and / or BAP 2* accredited farms from 2026:

BAP, or Best Aquaculture Practices, refers to a certification program that ensures farmed seafood is produced safely, responsibly, and ethically www.bapcertification.org

 

crab

in addition to our fish and seafood requirements and to ensure the sustainability and welfare of crabs, all crab used in our products will be sourced from ASC accredited farms.

 

salmon

in addition to our fish and seafood requirements, we will only source from farms where annual harvested volume, from any freshwater and seawater farms, are certified according to sustainability standards recognised by the Global Seafood Sustainability Initiative (GSSI): ASC, GSA BAP and/or Global G.A.P.

GSSI has worked in close partnership with the Food and Agriculture Organisation (FAO) of the United Nations and its member states since its inception to operationalise and champion internationally agreed guidelines and instruments in the seafood sector. it is therefore a recognised body that has developed a global benchmark tool to provide a formal recognition of seafood certification schemes that have successfully completed a rigorous and transparent benchmark process, underpinned by the FAO Guidelines https://ourgssi.org

standards are evolving and changing over time; therefore, it is the important work of GSSI which benchmarks the different standards.

 

tuna

in addition to our fish and seafood requirements and to ensure the sustainability and welfare of tuna, all tuna used in our products will be sourced from MSC Fisheries Standard or equivalent accredited farms and supply partners. https://www.msc.org/standards-and-certification/fisheries-standard

we also share the mission of The Global Tuna Alliance (GTA):

the GTA was created as a sector-wide, multi-stakeholder initiative of partners to build a shared, global and non-competitive solution to sustainability issues in the global tuna supply chain https://www.globaltunaalliance.com/

‘global tuna fisheries and ecosystems are healthy and resilient as a result of responsible supply chains and best practice management’ and ‘to transform global tuna fisheries through the implementation of innovative and sustainable solutions that protect marine ecosystems and enhance the livelihoods of all stakeholders involved.’

 

coffee

all our coffee will be Fairtrade certified. Fairtrade’s three pillars focus on the economic, social, and environmental factors of coffee production. they aim to improve wages and do not allow for bonded or child labour, this supports:

• minimum pricing for Arabica and Robusta coffee producers
• protecting their workforce and the communities they work with
• supporting gender equity.
• 100% of the bag of coffee must be certified to use the accreditation.

 

cocoa

to ensure worker welfare and sustainable sourcing of cocoa, by 2026 all cocoa will be certified Fairtrade and will be sustainably sourced.

we will only purchase cocoa from areas which have not been converted to agricultural land from forest.

 

eggs

to ensure the welfare of laying hens, our fresh eggs are cage-free.

all our whole egg will be free-range and to be produced certified to British Lion Quality Standards or international equivalent by April 2026.

eggs contained as ingredients in our products to be cage-free by end of 2027.

 

milk

all our fresh milk meets the Red Tractor standards or international equivalent.

 

palm oil

we will avoid using palm oil where possible and in order to ensure our products do not lead to illegal deforestation, all palm oil will be sourced to certified RSPO standards.

generic product standards

By the end of 2026, we will remove from our products:

• MSG as an added ingredient.
• artificial sweeteners as an ingredient in food products.
• Southampton colours warning: E102, E104, E110, E122, E124, E129.

 

packaging

our aim is that all packaging is safe, legally compliant, 100% widely recyclable, frustration free and minimises waste.

as required under legislation, we will measure and report how much of each packaging substrate we use and pay a commensurate ‘producer responsibility’ (or recycling) levy.

our standards on packaging prefer sustainable fibre-based product, however we also recognise the need for plastic currently to maintain our product offering.

all new paper-based packaging will be sustainable sourced and backed by either a PEFC/FSC or similar international accreditation.

wherever possible, new fibre-based packaging must be recyclable and all new plastic packaging will be recyclable and made from recyclable material.

from 2026, all new packaging design to be recyclable, compostable, biodegradable, or reusable.

packaging partners for direct food contact packaging must be accredited to a GFSI recognised scheme such as BRCGS Packaging Materials www.brcgs.com/our-standards/packaging-materials and/or FSSC 22 000 www.fssc.com/fssc-22000/

a Document of Compliance and packaging specification for all packaging to be provided upon request.