Procurement Policy Guide 2026

1. Purpose

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This Procurement Policy Guide sets out the principles and expectations by which Smarta Energy Limited seeks to procure goods, services and works in a lawful, fair, proportionate and commercially responsible manner. Its objectives are to secure value for money, maintain appropriate governance, support ethical and sustainable supply chains, manage risk, and promote timely and fair payment practices.

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2. Scope 

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This policy applies to procurement and supplier engagement undertaken by or on behalf of Smarta Energy, including the selection, appointment, contracting, management and review of suppliers, contractors, consultants and other third-party providers. It applies across the procurement lifecycle, from identification of need and market engagement through to contract award, performance management, renewal and exit.

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3. Core Procurement Principles 

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Smarta Energy expects procurement activity to be conducted in accordance with the following principles:

(a) Value for money: seeking an appropriate balance of quality, service, cost, resilience, sustainability and risk.

(b) Fairness and equal treatment: treating suppliers consistently and without improper bias.

(c) Transparency: maintaining appropriate clarity in specifications, evaluation criteria, decision-making and records.

(d) Proportionality: applying processes and controls appropriate to the value, complexity and risk of the requirement.

(e) Competition: using competitive processes where appropriate to encourage best value and reduce the risk of favouritism or waste.

(f) Integrity: avoiding bribery, corruption, undisclosed conflicts of interest and other improper conduct.

(g) Accountability and record-keeping: ensuring that decisions, approvals and contractual commitments are appropriately documented.

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4. Governance and responsibilities 

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Overall responsibility for procurement governance rests with Smarta Energy’s management and, where appropriate, its board or delegated authority structure. Individuals involved in procurement are expected to act within their authority, follow internal approval requirements, maintain adequate records and escalate material legal, financial, operational or ethical issues. Those involved in specifying, evaluating, approving or managing suppliers should, so far as relevant to their role:

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(a) define requirements clearly and objectively;

(b) apply proportionate due diligence and assessment criteria;

(c) identify and manage conflicts of interest;

(d) seek advice where specialist legal, compliance, data-protection or technical issues arise; and

(e) monitor performance and compliance during the life of the contract.

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5. Supplier selection and due diligence 

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Suppliers should be selected on the basis of objective and proportionate criteria relevant to the requirement. Depending on the nature and level of risk involved, assessment may include consideration of:

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(a) technical capability and service quality;

(b) financial standing and resilience;

(c) pricing and overall value for money;

(d) contractual and insurance position;

(e) information security and data-protection capability where relevant;

(f) health and safety competence where relevant;

(g) modern slavery, labour standards and ethical business conduct;

(h) sustainability and social value credentials; and

(i) past performance, references or market reputation.

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Due diligence should be commensurate with the category, value, duration and criticality of the proposed arrangement.

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6. Ethical Procurement 

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Smarta Energy expects suppliers and those acting on its behalf to comply with applicable law and to uphold appropriate standards of ethical conduct. This includes, where relevant: 

(a) Anti-bribery and corruption: zero tolerance of bribery and corruption, consistent with the Bribery Act 2010 and its adequate-procedures principles of proportionality, top-level commitment, risk assessment, due diligence, communication and monitoring. 
(b) Modern slavery: commitment to preventing forced labour, trafficking and exploitation in operations and supply chains. 
(c) Labour standards: lawful wages, working hours, freedom from unlawful discrimination, and respect for workers’ rights. 
(d) Equality, diversity and inclusion: compliance with equality obligations and fair treatment of workers and counterparties. 
(e) Health and safety: safe systems of work and compliance with relevant health and safety requirements. 
(f) Lawful conduct: compliance with sanctions, competition, tax, privacy, employment and other applicable laws. 

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7. Sustainable procurement and social value 

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Where appropriate to the requirement, Smarta Energy seeks to take account of environmental sustainability and wider social value in procurement decisions. This may include consideration of resource efficiency, waste reduction, carbon impact, responsible sourcing, circular-economy practices, community impact, skills development, fair employment and support for diverse and smaller suppliers.

Sustainability and social value considerations should be applied in a proportionate manner and balanced with legal, technical, commercial and operational requirements.

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8. Prompt payment and fair payment practices 

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Smarta Energy recognises the importance of responsible payment practices in supporting healthy supply chains and fair dealing. It therefore seeks to process valid and undisputed invoices promptly in accordance with agreed terms and to resolve payment queries efficiently. In the private sector, the Fair Payment Code is a voluntary code administered through the Small Business Commissioner framework. Smarta Energy supports the objectives of fair and prompt payment and may choose to align its practices with that framework where appropriate.

Where Smarta Energy is engaged in, or contributing to, public procurement or public-contract supply chains, it will seek to comply with any applicable statutory or contractual prompt-payment requirements. This may include 30-day payment terms and relevant supply-chain flow-down obligations where the Procurement Act 2023 or associated contractual requirements apply.

Where reporting obligations regarding payment practices and performance apply to Smarta Energy by law or by tender requirement, the company should ensure those obligations are properly met. 

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9. Contracting and contract management 

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Procurement outcomes should be appropriately documented. Contracts should clearly define scope, price or charging basis, service levels or deliverables, term, termination rights, confidentiality, data protection, intellectual property, liability allocation, compliance obligations and any relevant ethical, sustainability or audit provisions.

During the life of a contract, Smarta Energy should monitor supplier performance proportionately, including service quality, responsiveness, legal compliance, risk indicators, invoicing accuracy and adherence to contractual commitments.

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10. Risk Management and escalation 

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Procurement-related risks should be identified and managed throughout the procurement lifecycle. Relevant risks may include financial failure, operational dependency, security incidents, data breaches, service interruption, non-compliance, unethical conduct, modern slavery concerns, bribery risk, poor payment practices and reputational damage.

Material issues should be escalated through appropriate internal channels. Depending on the issue, escalation may involve management review, legal or compliance input, enhanced due diligence, corrective action planning, contractual remedies, suspension of onboarding, or termination.

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11. Records, audit trail and conflicts of interest 

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Those involved in procurement must keep sufficient records to demonstrate the rationale for key decisions, approvals, evaluations, due-diligence steps and contract variations. Actual, potential or perceived conflicts of interest must be declared and managed promptly. No individual should be involved in a procurement decision where their impartiality is compromised.

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12. Training and awareness 

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Smarta Energy should ensure that individuals involved in procurement and supplier management receive proportionate guidance and awareness on applicable procurement controls, ethical standards, modern slavery risks, anti-bribery requirements, information security and payment practices. Training should reflect the nature of the role and the level of procurement activity undertaken.

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13. Non-Compliance 

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Smarta Energy should ensure that individuals involved in procurement and supplier management receive proportionate guidance and awareness on applicable procurement controls, ethical standards,
modern slavery risks, anti-bribery requirements, information security and payment practices. Training should reflect the nature of the role and the level of procurement activity undertaken. 

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14. Review of this policy 

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This policy should be reviewed at least annually, and sooner if required to reflect material changes in law, regulation, guidance, organisational structure, procurement activity or risk profile.

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15. Contact

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Questions relating to this policy may be directed to:

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Smarta Energy Limited

Building 3, Workwell Office, Selby Road, Leeds, West Yorkshire, England, LS15 4LG

Email: enquiries@smartaenergy.com

Telephone: 0330 0947 110

Approved by K Dixon – Managing Director