Procurement Policy

Sept 2021


Policy Objectives

This policy sets out the requirements and standards for the procurement of all solutions with the objective of ensuring a cost effective, efficient, sustainable and legally compliant processes to procurement that provides value for money for EBG LTD customers.

This Procurement Policy exists for a number of discrete but often interconnected purposes. These objectives are expanded below, and are reflected in the detailed procedures that follow. 

The Policy commits EBG LTD, and every individual involved in Procurement and Contract Management processes on behalf of EBG LTD, to use their best endeavours to ensure that our Procurement and contracting activities are: 

– legal; 

– accountable and auditable; 

– ethically, environmentally and socially responsible; 

– economically effective; 

– appropriate to be able to exploit relevant technological, commercial and organisational developments as they arise; 

– capable of identifying, minimising and managing risks that may threaten the supply chain or the wider organisation; 

– open to continuous improvement and development, in particular by the training, development and support of staff.

– will only engage suppliers and contractors who subscribe to and operate on similar principles.

Policy Objectives

This procurement policy can be broken down into eight main purposes:

– to provide value for money for EBG LTD customers through best practice and ethical procurement consistent with EBG LTD values; 

– to comply with UK legislative and statutory requirements as detailed below 

– to provide an auditable framework for EBG LTD procurement activities that complies with relevant public sector transparency requirements. 

– To deliver innovation and best practice in procurement 

– To identify and deliver social value outcomes through best practice social value procurement 

– to help ensure risks related to our relationship with third party suppliers are managed, including to protect EBG LTD staff and partners from allegation of fraud, bribery and wrongdoing; 

– to support the delivery of the EBG LTD Business Strategy, Objectives and Procurement Strategy/Vision;

– to ensure positive, robust and outcome focused relationships with existing and new suppliers

Organisational Context

This Policy supports the wider Policies, Procedures and Mission Statement of the Education Buying Group Ltd and is to be read in conjunction with the company constitution. This Policy is intended to be followed in accordance with the vision and values of the Education Buying Group Ltd.

Every procurement undertaken or contract entered into on behalf of EBG LTD and its Customers shall comply with this Policy.


This Procurement Policy, and all associated sub-policies, procedures, processes and standards are applicable and mandatory to all staff engaged by EBG LTD engaged in procurement (either internal or external) regardless of value and risk.

Staff are defined as employees, volunteers, workers (e.g., agency workers, casual workers, freelance workers, contractors), work experience students, interns, self-employed persons, and anyone carrying out duties on behalf of EBG LTD or who is perceived as representing EBG LTD.

This Policy applies to the following circumstances:

– All procurements undertaken on behalf of the EBG LTD for the establishment of national procurement solutions for EBG LTD customers where EBG LTD is acting as a Centralised Purchasing Body as defined in Regulation 37 of the Public Contracts Regulations 2015.

– Procurements undertaken by EBG LTD on behalf of any individual EBG LTD customers/clients

– Consultancy Services provided by EBG LTD, unless a client’s procurement policy takes precedence.

For the avoidance of doubt this Policy covers all scenarios where a procurement must follow the requirements and principles of the Public Contracts Regulations 2015.

Directors of Education Buying Group Ltd will be responsible for ensuring staff working on behalf of EBG LTD comply with this policy.

The Director of Procurement will investigate any incidences of non-compliance and will provide advice on the delivery and subsequent amendments of this policy.

Policy Statement of Principles

EBG LTD will ensure all procurement is consistent with the following Statements of Principles:

Compliance with Legislation

All procurements will be conducted in accordance with the following legal requirements:

– All applicable UK laws and regulations; specifically, the Public Contracts Regulations 2015 and subsequent amendments.

– Where relevant/applicable Procurement Policy Notices.

– All applicable European Union laws, directives and regulations (including those governing Public Procurement, where relevant).

– The relevant laws, regulations and so on of other territories in which organisations operate, to which we supply, or from which we source.

– International laws, treaties and agreements to which the UK government is party (including, for example, any United Nations-approved trade sanctions).

Procurement Best Practice

Procurements will be delivered in accordance with industry best practice, providing the following outcomes:

– All procurement undertaken on behalf of EBG LTD and other Public Sector organisations will be conducted in accordance with latest best practice taking into account latest procurement innovation and technological advancements where applicable.

– Procurement will be undertaken with due care, attention and skill, using category management intelligence to design appropriate and best outcome solutions.

– Staff engaged in undertaking procurement on behalf of EBG LTD will follow all relevant procedures, processes and template documents.

– Procurements will be undertaken in the most efficient and cost-effective manner possible. 

– Procurements will be designed so as to allow continuous improvement and development.


Procurement processes and activities will be performed with the appropriate level of accountability and transparency, ensuring: 

– A transparent and fair tender, supplier selection and award process is conducted.

– That openness, fairness and integrity of the competition are taken into account in the sourcing process and associated activities 

– Responsibility is taken for procurement decisions and reported in accordance with EBG LTD’s reporting, accountability and governance procedures.

Treatment of Bidders and Suppliers

Bidders and Suppliers will be treated in accordance with the values that underpin EBG Ltd, accordingly all suppliers will be treated in the following manner:

– All suppliers and prospective suppliers are treated fairly and equitably, with respect and in accordance with EBG LTD values.

– Procurements will, where possible, be simple, straightforward and without ambiguity.

– Bidders will be treated fairly and equitably in accordance with the principles of the Public Contracts Regulations 2015.

– Suppliers will be held accountable for the delivery of goods and services in accordance with pre-agreed specifications and contract terms and where standards are not upheld seek to address it immediately.

– Suppliers will be managed in accordance with EBG LTD Contract and Supplier Management Procedures.

– We will work with suppliers in a spirit of good faith, openness and work jointly to deliver continuous improvement and value.

Ethical Procurement

Procurement will be conducted in accordance with best practice ethical requirements. Staff employed in the delivery of procurement solutions on behalf of EBG LTD and it’s Customers must conduct themselves with high regard to ethical standards, including:

– Compliance with the CIPS ethical code of conduct

– There is no collusion or anti-competitive behaviour 

– Does not distort competition to result in fraudulent benefits

– Does not accept gifts, hospitality, or inducements aimed at distorting the outcome of a procurement or inducing preferential treatment of a bidder or supplier

Furthermore it will be the responsibility of staff engaged in delivering procurement solutions on behalf of EBG LTD and it’s Customers to ensure that suppliers are:

– Not involved in illegal activities (therefore complying with international policies) 

– Have not participated in any collusive, corrupt, or fraudulent behaviour, either alone or together with other tenderers, or use bribery to their advantage 

– Ensure suppliers working conditions comply with international labour standards as issued by the International Labour Organization 

– do not employ children and do not engage in any practices inconsistent with the rights set out in the Convention on the Rights of the Child. 

– are not engaged, nor their supply chain is engaged, in Modern Slavery activities

Risk mitigation

Procurement recognises the essential need to identify, assess, mitigate and monitor supply risks in driving effectiveness. In order to manage supply risks, Procurement ensures that: 

– All procurement processes and activities are performed in compliance with the applicable laws and regulations.

– For critical items/services (e.g. value or criticality for the missions) appraisal checks are performed, including but not limited to financial sustainability, supplier reference, and/or operational capacity.

– The risk of fraud is minimised by putting in place the required validation steps and segregation of duties in the procurement process .

– Procurement processes and activities comply with the applicable internal control framework. 

– Procurement drives the process to identify, assess and mitigate procurement-related supply risks to limit negative impacts on EBG LTD’s reputation.

Public Services (Social Value) Act 2012 (SVA)

Social Value legislation requires public authorities to consider the social, economic and/or environmental impact of each procurement decision. This is primarily achieved at the pre-procurement stage and subsequently ‘designed’ into the procurement solution. The intention of the Act is to ensure that any business that can provide social value as a consequence of securing contracted work is able to identify, measure and report on such impact, thereby increasing the effectiveness of procurement decisions.

EBG LTD has a duty to its Public Sector customers and clients to embed the SVA in each procurement exercise in order to provide opportunities for the delivery of social value outcomes. Social value outcomes specified or part of award criteria must be relevant to the subject matter of the contract and proportionate to the value, risk and scope of the procurement.

The Act, which became law in March 2012 and came into force in January 2013, covers public service contracts (including primarily service contracts with a works or goods element where the service element is greater in value), but not goods contracts. Notwithstanding where applicable EBG Ltd will incorporate social value good practice into Goods procurements.

All tender documents published on behalf of EBG LTD and our Customers will include either clear specification requirements relating to Social Value or evaluation criteria as to how suppliers intend to support social value outcomes through the delivery of the contract. 

Further detail on the Social Values Act 2012 can be found at the following address:

Legislative Context

All employees/agents involved in procurement on behalf of the EBG LTD and/or it’s clients/customers must comply with the requirements of all relevant and applicable legislation. This includes, but is not limited to, general duties imposed on the EBG LTD as a public body/authority:

Sale of Goods Act 1979 as amended by the Sale and Supply of Goods Act 1994    

Modern Slavery Act

General Data Protection Regulation 2016

Data Protection Act 2018

Transfer of Undertakings (Protection of Employment) Regulations 2006 (TUPE)

Waste Electrical and Electronic Equipment (WEEE) Regulations 2006

Bribery Act 2010

The Public Services (Social Value) Act 2012 13

Equality Act 2010

Criminal Finance Act 2017

FOI Act 2000