Supplier Code of Conduct
Alley Pond Trading Corporation · Version 1.0 · September 2026 · Reviewed annually
Introduction
Alley Pond Trading Corporation supplies raw Gum Acacia (Gum Arabic), Baobab and Hibiscus ingredients to processors and manufacturers worldwide. Our customers hold us to standards of integrity, human rights and environmental care, and we hold the same standards throughout the chain that supplies us.
This Code applies to every supplier, collector, agent, contractor, transporter, processor and service provider who supplies goods or services to Alley Pond, and to their own suppliers and subcontractors in turn (together, “Suppliers”). It applies in full regardless of the size of the business or the volume supplied.
The Code is grounded in the UN Guiding Principles on Business and Human Rights, the core conventions of the International Labour Organization, and the applicable laws of every country in which our Suppliers operate. Where this Code and local law differ, the higher standard applies. Where they conflict outright, comply with local law and tell us, so we can find a lawful way to meet the intent.
We do not expect perfection at signature. We expect honesty, and we expect improvement. A Supplier who tells us about a problem is a better partner than one who conceals it, and will be treated accordingly.
1. Business integrity
1.1 Bribery and improper payments
Suppliers shall not offer, promise, give, request or accept any bribe, kickback, facilitation payment or other improper advantage, to or from anyone, whether a public official or a private party, whether directly or through an intermediary.
This includes informal payments demanded for the movement of goods. Suppliers shall not pay any charge for the passage, release, loading, escort or clearance of material other than a payment that is (a) required by law, (b) charged at the official rate, and (c) supported by an official receipt.
For the movement of gum from producing areas to port, the only payments recognised as legitimate under this Code are:
- Zakat
- Forestry taxes
- Business profit tax deposits
each of which is mandatory by law for the official trade of gum acacia — together with any other charge that meets all three conditions above and is documented as such.
These payments are verified in transit and again at Port Sudan before the consignment enters customs clearance, which applies a further layer of official verification. The trail is therefore checked by the authorities themselves rather than resting on the Supplier’s own account of it, and the receipts should reconcile at every stage.
Any demand for a payment outside those bounds must be refused and reported to Alley Pond. We would rather lose a consignment than pay for it improperly, and no Supplier will be penalised by us for a delay caused by refusing such a demand.
1.2 Sanctions, smuggling and illicit trade
Suppliers shall comply with all applicable trade-control and sanctions laws. Material supplied to Alley Pond must be lawfully harvested, lawfully purchased, lawfully transported and lawfully exported, with the documentation to show it. Suppliers shall not deal in material of unknown, undocumented or misrepresented origin, and shall not commingle such material with material intended for Alley Pond.
1.3 Fair dealing, records and confidentiality
Suppliers shall compete fairly, keep accurate and unfalsified books and records, disclose any conflict of interest affecting their dealings with us, and protect confidential information, personal data and intellectual property entrusted to them.
2. Human rights and labour
2.1 Child labour
No person under the age of 15, or under the legal minimum working age in the country of operation, whichever is higher, shall be employed. No person under 18 shall perform hazardous work, night work, or work that interferes with their education.
The smallholder reality. Much of the gum belt is harvested by family units, and children may be present or may help alongside their families. This Code does not treat that as child labour in itself. It does require that any such work is light, non-hazardous, supervised by a parent or guardian, does not interfere with schooling, and takes place outside school hours. Work that is hazardous, that displaces education, or that is performed for a third party rather than the family is prohibited without exception.
Suppliers employing workers directly shall keep a record of date of birth for every worker, and shall be able to produce it.
2.2 Forced labour
No forced, bonded, indentured, trafficked or involuntary labour of any kind. No worker shall be required to lodge deposits or identity documents as a condition of employment; passports, identity documents, work permits and travel documents shall never be confiscated or withheld. Workers shall be free to leave their employment on reasonable notice.
2.3 Wages, hours and terms
Wages shall meet or exceed the legal minimum. Working hours and rest periods shall comply with law. Deductions shall be lawful and explained. Where formal contracts are customary and lawful, they shall be used; where they are not customary, terms shall nonetheless be communicated clearly and honestly.
2.4 Freedom of association
Workers may associate freely, form or join organisations of their choosing, and bargain collectively where the law permits, without intimidation or reprisal.
2.5 Health, safety and dignity
Suppliers shall provide a safe working environment, access to clean sanitation and potable drinking water, appropriate protection for the task, and basic safety instruction. Workplaces shall be free of harassment, violence, intimidation and discrimination on any ground including sex, age, ethnicity, religion, disability or origin.
3. Environment and the resource
3.1 Legal compliance and basic practice
Suppliers shall comply with applicable environmental law, dispose of waste responsibly, and avoid uncontrolled burning of waste or vegetation.
3.2 Stewardship of the acacia resource
Gum acacia is harvested from living trees, and the way a tree is tapped determines whether it yields for decades or dies within a few seasons. Suppliers shall use tapping practices that do not compromise tree health, shall not fell or damage productive acacia stands for fuel, charcoal or clearance, and shall support the natural regeneration of the belt.
The resource is the business. A Supplier who exhausts it has ended their own trade as well as ours.
4. Traceability and chain of custody
This section is the operational core of the Code, and compliance with it is a condition of supply.
For every consignment supplied to Alley Pond, the Supplier shall be able to state and evidence:
- The harvesting area the material came from
- The collection market or point of purchase, and the date
- The identity of the party from whom it was purchased
- The location and dates of cleaning, sorting, grading and packing
- The route and dates of movement to port, and the means of transport
- That no payment was made outside the bounds of section 1.1, with the supporting receipts for those that were
- That no illegal activity occurred at any point in the chain described above
Material of unknown or undocumented origin shall never be supplied to Alley Pond, and shall never be commingled with material intended for us. Records supporting the above shall be retained for not less than five years and made available to Alley Pond on request.
5. Raising a concern
Any person — a Supplier, an employee of a Supplier, a worker, a collector, or any affected party — may report a suspected breach of this Code to Alley Pond at:
speakup@alleypondglobal.com
Reports may be made confidentially. Reports may be made anonymously, though we can investigate more effectively when we can ask questions. We investigate every report we receive.
No retaliation. Alley Pond will not penalise, and requires that no Supplier penalise, any person for raising a concern in good faith or for refusing an improper payment. Retaliation is itself a breach of this Code.
Suppliers are encouraged to operate their own reporting route for their workers. Concerns may always be escalated to us.
6. Monitoring, improvement and consequences
Alley Pond may ask Suppliers to complete self-assessment questionnaires, to provide supporting documentation, to receive a site visit, or to accommodate an audit by us or by a third party we appoint. Our customers may make equivalent requests of us, and we will pass them on.
Where a shortfall is found, our first response is a corrective action plan with an agreed timeframe. We would rather raise a Supplier’s standard than replace them, and we will invest reasonable effort in doing so.
Where a Supplier declines to engage, conceals information, retaliates against a person who raises a concern, or where a breach is severe and cannot be remediated, Alley Pond will end the relationship.
7. Acknowledgment
By signing below, the Supplier confirms that they have read and understood this Code, that they will comply with it, that they will communicate it to their own employees, suppliers and subcontractors, and that they will inform Alley Pond promptly of any breach or suspected breach.
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