Exclusion checks for Chinese subcontractors
Identify the factory's role, obtain intended subcontractor details and check the debarment list. Assess relevant exclusion grounds and continuing risks, then allow supplier representations and any required replacement opportunity. Evidence gathering in China can be supported by Cambridge China Bridge.
Identify the factory's role in the bid
For procurements using the Cabinet Office exclusions framework, an associated person is an entity relied on to meet participation conditions, excluding a guarantor. A Chinese factory may therefore be an associated person even further down the supply chain. Ask the bidder which condition depends on the factory and what evidence demonstrates that reliance.
Keep associated persons distinct from connected persons: relevant influence or control can bring connected persons into the assessment. Record the bidder, factory, ownership links and contract tasks separately. Use the factory identity guide for the underlying identity checks.
Obtain the intended subcontractor information
The authority must request details of intended subcontractors at every tier and check them against the debarment list. This concerns subcontracted contract performance, rather than every existing commercial supplier. Ask for legal names, Chinese names, addresses, roles and links between entities; keep unresolved name matches open.
Unknown subcontractors should be identified as unknown, with details supplied once confirmed and at least by final tenders. The authority may investigate exclusions beyond the list check for selected subcontractor categories or identified risks. Ask the bidder to explain whether the proposed factory will perform part of this contract or merely supply through an existing arrangement.
Match concerns to exclusion grounds
Consider mandatory and discretionary grounds and whether the circumstances are continuing or likely to recur. An excluded supplier must be excluded; an excludable supplier may be excluded. Relevant overseas conduct can fall within the UK exclusions framework. Discretionary grounds include labour or environmental misconduct and poor performance; check the precise ground rather than treating an allegation as a conclusion.
Create a record linking each concern to the entity, event, source document and proposed ground. Ask for the underlying decision where available, an accurate translation and any explanation of disputed facts. The supplier verification guide supports evidence gathering; a factory audit should not be presented as an exclusion clearance.
Hear representations and test remedial action
Before deciding exclusion status, the authority must give the supplier a reasonable opportunity to make representations and provide evidence that the circumstances have ended or are unlikely to recur. Evidence requests must be proportionate. Ask the bidder to answer the specific concern, identify disputed facts and explain corrective action with supporting records.
Where the concern relates to another relevant entity or person, remedial evidence should address them as well as the bidder's measures. Ask what changed, who implemented it and how it can be verified. Keep completed action separate from promises, and record what remains unverified.
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Handle replacement and retain the decision record
Where exclusion arises through an associated person or intended subcontractor, the bidder must have an opportunity to replace them before exclusion. Check a replacement subcontractor against the debarment list, repeat relevant exclusion checks and confirm participation conditions remain satisfied. The same replacement entitlement does not apply to connected persons.
Record the evidence reviewed, representations, replacement assessment and reasons for the decision. Use the second supplier qualification guide for manufacturing capability checks after a replacement is proposed. Cambridge China Bridge can support identity and site evidence gathering through its own staff in China; the public buyer retains the exclusion decision.
Frequently asked questions
Is every Chinese factory an associated person?
The test is reliance on that entity to meet participation conditions, excluding a guarantor. A factory performing contract work may instead be another intended subcontractor.
Must we check subcontractors below the main supplier?
Yes. Request intended subcontractor details across all tiers and check the debarment list. Further exclusion investigation can target selected categories or identified supply-chain risks.
Does absence from the debarment list settle exclusions?
No. Assess applicable grounds for the bidder and associated persons, including relevant connected persons. Further investigation of other subcontractors may also be appropriate.
Can the bidder replace a factory before exclusion?
It must have that opportunity where exclusion arises through an associated person or intended subcontractor. Check the replacement and confirm the bidder still meets participation conditions.