Procurement Policy

Policy date: October 2026
Review frequency: Annually, or sooner where required by changes in legislation, funding conditions or organisational circumstances.

1. Introduction

Rights & Equality Sandwell (RES) is committed to ensuring that all procurement and purchasing activities are conducted fairly, transparently, responsibly and in accordance with applicable legislation and funding requirements.

As an organisation dedicated to promoting equality, challenging discrimination, supporting individuals and strengthening communities, RES recognises its responsibility to use financial resources effectively and ethically.

This policy establishes the principles and procedures governing the purchase of goods, services, equipment, consultancy, professional support and externally commissioned activities.

Our procurement approach reflects our organisational values of equality, inclusion, accountability, integrity and respect for the communities we serve.

2. Purpose of This Policy

The purpose of this policy is to ensure that RES:

Achieves value for money when purchasing goods and services.
Maintains transparency and accountability in financial decision-making.
Provides fair and equitable opportunities for suitable suppliers.
Prevents fraud, bribery, corruption and conflicts of interest.
Complies with applicable legislation, contractual obligations and funding conditions.
Promotes equality, diversity, accessibility and responsible business practices.
Protects confidential information and personal data.
Maintains appropriate records for financial monitoring, auditing and reporting.
Ensures that suppliers working with children, vulnerable individuals or sensitive information meet relevant safeguarding and security requirements.

3. Scope of the Policy

This policy applies to all RES directors, employees, project workers, volunteers and other individuals authorised to purchase goods or services on behalf of the organisation.

It covers procurement funded through core organisational resources, grants, public funding, commissioned services and other funding arrangements.

Purchasing activities may include:

Office equipment, stationery and operational supplies.
Information technology, software, website services and digital systems.
Training, consultancy and professional services.
Community engagement and outreach activities.
Workshop facilitators, educators and specialist practitioners.
Research, surveys, evaluations and consultation services.
Translation, interpretation and accessibility services.
Venue hire, events and community activities.
Marketing, printing, communications and promotional materials.
Specialist casework, advocacy and project delivery support.

All purchases must be necessary, proportionate, appropriately authorised and consistent with RES's organisational objectives.

4. Procurement Principles

RES follows the principles below when making purchasing decisions.

4.1 Value for Money

Procurement decisions must consider the overall value offered by a supplier, rather than price alone.

Relevant considerations include quality, reliability, suitability, accessibility, experience, delivery timescales, environmental impact and long-term costs.

The lowest-priced supplier will not automatically be selected where another supplier demonstrates better overall value or is more appropriate for the intended service.

4.2 Fairness and Transparency

Suppliers must be treated fairly and objectively.

Procurement decisions must be based on appropriate selection criteria, supported by relevant documentation and free from improper personal or financial influence.

4.3 Equality, Diversity and Inclusion

RES is committed to ensuring that procurement practices support the principles of the Equality Act 2010.

Where relevant, supplier assessments will consider accessibility, inclusive service delivery, cultural awareness and the ability to meet the needs of diverse communities.

RES encourages opportunities for small businesses, voluntary organisations, social enterprises and community-based providers, while maintaining fair competition and appropriate value-for-money standards.

4.4 Accountability

Individuals involved in procurement must act responsibly, remain within their delegated authority and maintain appropriate records.

Purchases must not be divided into smaller transactions to avoid approval requirements or competitive purchasing procedures.

4.5 Ethical and Sustainable Procurement

RES encourages responsible purchasing practices that consider environmental sustainability, fair working conditions, ethical supply chains and positive community impact.

5. Procurement Procedures

RES will adopt a proportionate procurement process based on the value, complexity and risk associated with each purchase.

5.1 Identifying the Requirement

Before purchasing goods or services, the responsible staff member or project lead must establish:

What goods or services are required.
Why the purchase is necessary.
The expected cost and available budget.
Whether the expenditure is permitted under relevant funding agreements.
Whether suitable existing resources or contracts are available.
Any accessibility, safeguarding, information security or other requirements.

5.2 Obtaining Quotations

Appropriate quotations or market comparisons must be obtained in accordance with RES's authorised internal financial procedures and any applicable funder requirements.

Higher-value or more complex purchases will normally require greater competition and more detailed assessment.

Where competitive quotations are not reasonably available, the reasons must be documented and an appropriate exception authorised before a commitment is made.

5.3 Supplier Evaluation

Suppliers will be evaluated against criteria relevant to the proposed purchase, which may include:

Cost and overall value for money.
Relevant qualifications, experience and competence.
Quality and suitability of goods or services.
Ability to meet project requirements and deadlines.
Financial and operational reliability.
Equality, diversity and accessibility considerations.
Safeguarding arrangements, where applicable.
Data protection and confidentiality arrangements.
Insurance, health and safety, and other relevant compliance requirements.

Supplier selection decisions must be documented and supported by an appropriate explanation.

5.4 Approval and Authorisation

Purchases and contractual commitments must be approved by individuals with the appropriate delegated authority.

Significant expenditure, exceptional purchasing decisions and transactions involving potential conflicts of interest must be escalated for appropriate independent or Board-level consideration.

No individual may approve expenditure for their own personal benefit.

Staff and representatives must not enter into financial commitments exceeding their authorised responsibilities.

5.5 Orders and Contracts

Appropriate written documentation must be maintained for purchases and supplier arrangements.

Depending on the nature of the purchase, this may include quotations, purchase orders, written agreements or formal contracts.

Contracts should clearly identify the services or goods to be supplied, delivery arrangements, costs, payment terms, responsibilities and any relevant confidentiality, safeguarding or data protection requirements.

6. Grant-Funded and Publicly Funded Procurement

RES recognises that grant-funded and publicly funded projects may be subject to additional procurement requirements.

Before committing expenditure, RES will review the relevant funding agreement and ensure that purchasing decisions comply with applicable conditions.

These may include:

Specific quotation or tendering requirements.
Restrictions on eligible expenditure.
Requirements for prior approval from funders.
Evidence of competitive supplier selection.
Rules relating to subcontracting and partnership delivery.
Financial monitoring and reporting obligations.
Requirements to retain supporting records.

Where a funder's conditions impose stricter requirements than RES's internal procedures, those conditions must be followed.

RES will also assess whether any procurement is subject to the Procurement Act 2023, Procurement Regulations 2024 or other applicable public procurement requirements. Such obligations will be followed where legally applicable.

Funding allocated to a particular project must only be used for authorised project purposes and must be supported by appropriate financial documentation.

7. Conflicts of Interest and Anti-Bribery

RES is committed to maintaining integrity and preventing improper influence in procurement activities.

Anyone participating in purchasing decisions must declare any actual, potential or perceived conflict of interest.

This includes situations involving:

Family members or close personal relationships.
Financial interests in a potential supplier.
Business relationships with individuals or organisations seeking contracts.
Personal benefits arising from procurement decisions.

Conflicts must be recorded and appropriately managed.

Individuals with relevant conflicts must not improperly influence supplier selection, contract awards or expenditure approvals.

RES maintains a zero-tolerance approach to bribery, fraud, corruption, kickbacks and improper inducements.

Procurement activities must comply with the Bribery Act 2010 and other applicable financial and criminal legislation.

Suspected misconduct must be reported through the organisation's appropriate management, governance or whistleblowing arrangements.

8. Safeguarding and Supplier Responsibilities

RES delivers and supports activities involving individuals and communities who may experience discrimination, disadvantage, vulnerability or additional support needs.

Where suppliers, consultants or external practitioners are engaged to work directly with children or adults at risk, appropriate safeguarding checks and measures must be completed before activities begin.

Depending on the nature of the service, these may include:

Verification of qualifications and relevant experience.
Review of safeguarding arrangements and procedures.
Appropriate references and risk assessments.
Disclosure and Barring Service (DBS) checks where the role is legally eligible.
Clear procedures for reporting safeguarding concerns.
Suitable supervision and professional boundaries.

Suppliers must comply with applicable safeguarding legislation and RES's relevant safeguarding procedures.

Safeguarding requirements must not be compromised solely to reduce procurement costs.

9. Data Protection and Confidentiality

RES recognises the importance of protecting personal information, particularly where services involve casework, discrimination concerns, hate incidents, advocacy or sensitive personal circumstances.

All procurement activities must comply with applicable UK data protection legislation, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018 and relevant subsequent amendments.

Where suppliers handle personal information on behalf of RES, appropriate arrangements must be established to ensure that information is processed lawfully, securely and only for authorised purposes.

These may include:

Confidentiality agreements and contractual safeguards.
Data processing agreements where legally required.
Appropriate technical and organisational security measures.
Restrictions on access to confidential records.
Secure storage, transmission and disposal of information.
Assessment of risks associated with digital systems and external service providers.

Suppliers must not access, disclose or use confidential service-user information beyond what is necessary and authorised for their contracted work.

Further information is available in RES's Data Protection Policy.

10. Partnership Working and External Service Providers

RES works collaboratively with voluntary organisations, community groups, public-sector bodies, educational providers and specialist organisations to deliver services and projects.

Where RES commissions an external organisation or individual to deliver work, responsibilities must be clearly established before services begin.

Relevant arrangements should identify:

The intended activities and outcomes.
Delivery responsibilities and timescales.
Agreed costs and payment conditions.
Safeguarding and confidentiality obligations.
Monitoring, reporting and evaluation requirements.
Responsibilities for maintaining records and demonstrating project outcomes.

Partnership arrangements funded through grants must comply with the applicable funding agreement, including any restrictions on subcontracting or transfer of funds.

RES is committed to maintaining constructive, accountable relationships with partner organisations while protecting the interests of beneficiaries and funders.

11. Financial Management and Payment Controls

All procurement expenditure must be accurately recorded and supported by appropriate financial documentation.

Before payment is authorised, RES will undertake proportionate checks to confirm that:

The purchase was appropriately authorised.
The goods or services were supplied as agreed.
The invoice is accurate and corresponds to the agreed purchase.
Relevant funding conditions have been satisfied.
Payment details have been appropriately verified.
The expenditure is allocated to the correct budget or project.

Appropriate separation of purchasing, approval and payment duties will be maintained wherever practicable.

Where organisational capacity makes full separation impractical, additional independent review or oversight must be implemented.

Financial records must be maintained securely and made available for authorised audit, monitoring and reporting purposes.

12. Emergency and Exceptional Procurement

RES recognises that exceptional circumstances may require urgent procurement to protect individuals, organisational operations or essential service delivery.

Where standard purchasing procedures cannot reasonably be followed, the circumstances and justification must be documented.

Exceptional purchases must be proportionate, properly authorised and subject to appropriate subsequent review.

Urgency does not remove the obligation to comply with applicable legal requirements or funding conditions.

13. Monitoring, Record Keeping and Audit

RES will maintain appropriate procurement records to support transparency, accountability and effective financial management.

Records may include:

Purchase requests and approvals.
Supplier quotations and comparisons.
Evaluation and selection decisions.
Contracts and written agreements.
Supplier compliance and risk assessments.
Invoices, receipts and payment records.
Funding approvals and related correspondence.
Records of conflicts of interest or exceptional decisions.

Records will be securely stored, with access restricted where appropriate, and retained in accordance with applicable legal, contractual, funding and data protection requirements.

Procurement activity will be subject to appropriate management and governance oversight.

Any identified concerns, irregularities or breaches of this policy must be reviewed and addressed.

14. Responsibilities

The RES Board of Directors is responsible for oversight of the organisation's financial governance and procurement arrangements.

Day-to-day responsibilities may be delegated to appropriately authorised staff or representatives, subject to established financial controls.

All individuals involved in procurement are expected to:

Understand and follow this policy.
Act in the best interests of RES and its beneficiaries.
Use resources responsibly.
Declare relevant conflicts of interest.
Protect confidential information.
Maintain accurate records.
Report suspected financial or procurement irregularities.

15. Policy Review

This policy will be reviewed at least annually and sooner where necessary to reflect changes in legislation, organisational activities, governance arrangements or funding obligations.

Updates will be considered through RES's appropriate governance and approval processes.

Rights & Equality Sandwell is committed to maintaining procurement practices that demonstrate integrity, fairness, accountability and responsible stewardship of the resources entrusted to the organisation.

Rights & Equality Sandwell (RES)
ASRA Smethwick, Fenton Street, Smethwick, West Midlands, B66 1HR
Website: www.rightsandequalitysandwell.co.uk