About Us - Based on the Sussex/Surrey border near Gatwick Airport and established for over 30 years we are the South’s premier Waste Management and recycling Specialist. Our services cover all aspects of waste management including advice on how to reduce waste, re- use waste, recycle and recover waste products. We focus on reducing our customers reliance on Landfill, this approach has led us to achieve average recycling/recovery rates of over 90%. This is possible due to the processes in place at our Waste Recycling Centre in West Sussex . The services we offer are available to all; corporate clients, business users, householders and local builders. With services ranging from site clearances and mini skip hire through to large roll on roll off containers no job is too big or too small. Our dedicated team of professionals are qualified to provide advice on all aspects of waste management. Our staff are friendly and approachable, so if you have a question about waste please give us a call and we will be happy to help. Hazardous Waste: Our specialist Hazardous Waste Team are qualified to advise on all aspects of hazardous waste disposal . We can list, pack, prepare for transportation, transport, process, treat and dispose of all types of hazardous waste in accordance with current legislative requirements. Trade Waste: Cox Skips provides a commercial waste collection service for businesses in the South East. This can be from as little as one bag a week to the supply of large Euro bin containers for a more regular collection. We supply the bins, the collection and the paperwork. THE RECYCLING PARTNERSHIP Ltd provides a commercial recycling collection service for businesses in the South East. Services include collection of Glass, drinks cans, office paper, cardboard, plastic bottles and food tins. Prices start from just £3.00 per week. For further information please contact our Enquiries Team on 01342 715456 or visit http://recyclingpartnership.co.uk Recycling We are committed to sustainable development and aim to recycle at least 90% of the waste we handle. We process as much waste as possible using our own fully licensed Waste Recycling Centre. This facility allows us to separate recyclables and process in the most efficient way. With our Site Clearance Service Cox will provide the wheels, the manpower and the required documentation to safely collect and dispose of all waste items large and small. We will collect mixed general waste as well as Hazardous wastes such as TV’s, monitors, fridges, and Cement Bonded Asbestos. House clearance? Warehouse clearance? Site clearance? We take care of everything including separating recyclable waste, arranging extra staff for larger sites, providing the appropriate collection vehicles and locking up at the end of the job. Site Clearance: Our professional approach allows us to provide the highest standard of service with a rapid response to all enquiries. Since the introduction of new legislation in 2008 plasterboard and gypsum based products can no longer be sent to landfill and must be recycled. Cox Skips have the solution to your plasterboard and other gypsum based products recycling needs. We provide a separate collection of all plasterboard products. All plasterboard waste is broken down and recycled back into plasterboard products providing a “closed loop” solution for all of our customers. For further information contact us on 01342 715978. We can assist with planning the process for on site segregation to ensure that 100% of the plasterboard waste produced is recycled. Our specialist team can be contacted for further advice. Waste transfer and Recycling facility Summer opening times: Monday to Friday: 07:15 – 16:30 (last tip 16:30) | Saturday: 07.15 – 11:00 (last tip 11:00) | Sunday: Closed
Certificate of Registration
Cox Management Services Limited Inc. Cox Skips Limited and The Recycling Partnership Limited Cox House, Burleigh Oaks Farm, Turners Hill, West Sussex, RH10 4PZ
have been assessed and approved to:
Integrated Management System
Incorporating
ISO 9001:2015, ISO 14001:2015, ISO 45001:2018
The approved management system applies to the following scope:
Specialists in waste management services, including skip hire, waste collection, recycling, and hazardous waste disposal serving clients across various sectors and operations.
9 th December 2024
Original Approval:
9 th December 2024
Current Certificate:
9 th December 2025
Certificate Expiry:
Certificate Number:
CAP1412IMS
Signed: Certification Officer
This certificate remains valid while the holder maintains their administration systems in accordance with the standards and guidelines stated above, which will be audited annually by QAS International. The holder is entitled to display the above registration mark for the duration of this certificate, which should be returned to QAS International upon reasonable request
Tel: 020 31989788 - info@qas-international.com - https://www.qas-international.com Issuing Office: QAS International, 20 Grosvenor Place, London, England, SW1X 7HN
Redcliff Court Redcliff Road Hessle Hull HU13 0EY
Tel 01482 579800
To Whom It May Concern
Date: 10th January 2025 Our Ref: 90693607
Dear Sir/Madam
Re: Cox Management Services Ltd & Cox Skips Limited & The Recycling Partnership Limited
Aon UK Limited hereby confirms that our clients hold the following policy / policies:
Employers Liability Insurer: Policy number: Period of cover: Limit of indemnity: Public Liability Insurer: Policy number: Period of cover: Limit of indemnity: Products Liability Insurer: Policy number: Period of cover: Limit of indemnity:
Aspen Insurance UK Ltd B190324MS174C0069 11/08/2024 to 31/12/2025
£20,000,000 any one occurrence
Aspen Insurance UK Ltd B190324MS174C0069 11/08/2024 to 31/12/2025
£10,000,000 any one occurrence
Aspen Insurance UK Ltd B190324MS174C0069 11/08/2024 to 31/12/2025
£10,000,000 any one occurrence and in the aggregate
Professional Indemnity Insurer:
HCC International Insurance Company Plc T/as Tokio Marine HCC
Policy number: Period of cover: Limit of indemnity:
PI24A625480
01/01/2025 to 31/12/2025
£2,000,000 any one occurrence and in the aggregate
All policies are subject to the terms, conditions and exceptions of the policies themselves. The information provided is based on the insurance arrangements at the time of writing. Alterations may be made during the period of cover. We have no obligation to advise you of any changes which may be made to the policies or advise you of their cancellation or termination.
Please do not hesitate to contact us if you have any queries.
Yours sincerely,
Michelle Parkinson I Client Service Manager T: 01652 681330 E: michelle.parkinson@aon.co.uk
Aon UK Limited Registered office | The Aon Centre | The Leadenhall Building | 122 Leadenhall Street | London | EC3V 4AN
Registered in England & Wales No. 210725 | VAT Registration No. 480 8401 48 Aon UK Limited is authorised and regulated by the Financial Conduct Authority
Cox Management Services Ltd
Membership No.: CHAS-0009383 General
has demonstrated compliance with the CHAS standards in line with SSIP Core Criteria and UK H&S Legislation.
MEMBERSHIP VALID UNTIL CERTIFICATE VALID UNTIL CERTIFICATE DATE OF ISSUE DATE OF INSPECTION CERTIFICATE NUMBER
23/09/2025 20/11/2025 20/11/2024 20/11/2024
FD4B2E07-6B2D-40FF-986E-7F7C47F2C11B
Classification: PUBLIC
The information on this certificate is correct at the time of issue. To confirm the validity of a contractor, please visit veriforceone.com Full validation of this certificate should be made via the SSIP Portal www.ssipportal.org.uk
Certificate of Registration under the Waste (England and Wales) Regulations 2011 Regulation authority Name
National Customer Contact Centre 99 Parkway Avenue Sheffield S9 4WF
Address
Telephone number
03708 506506
The Environment Agency certify that the following information is entered in the register which they maintain under regulation 28 of the Waste (England and Wales) Regulations 2011.
Carriers details Name of registered carrier
THE RECYCLING PARTNERSHIP LIMITED
Registered as
An upper tier waste carrier, broker and dealer
Registration number
CBDU219429
Burleigh Oaks Farm East Street Turners Hill RH10 4PZ
Address of place of business
Telephone number 01342711950 Date of registration 15 January 2024 Expiry date of registration (unless revoked) 24 February 2027 This certificate was created on 15 January 2024. These details are correct at the time of certificate generation. This copy has been issued under Regulation 6 of Waste (England and Wales) Amendment Act 2014 by the Environment Agency. This is copy number 1 of the certificate. Making changes to your registration Your registration will last 3 years and will need to be renewed after this period. If any of your details change, you must notify us within 28 days of the change.
Document Reference: IM 01 Quality Policy
The quality of the service and work provided by Cox Management Services Limited, Cox Skips Limited and The Recycling Partnership Limited (The Cox Group) to its customers is the concern of each member of the organisation. The target is to provide a level of service and work that meets and exceeds our customers’ needs and expectations. The Cox Group operates an integrated ISO Management system, to include ISO 9001, ISO 14001, and ISO 45001 for waste management services for commercial, municipal and construction industry customers. We promote Quality in our business by: • Operating within an integrated management system that meets the requirements of ISO 9001:2015 and seek to prevent process loss such as adverse impacts on products and services and to identify risk and opportunities. • Ensuring customer needs and expectations are determined and fulfilled with the aim of achieving high customer satisfaction. • Monitoring, auditing, and evaluating the performance of the integrated management system and processed to satisfaction of interested parties. • Providing ongoing training and development of our people to underpin an initiative-taking approach to continuous improvement. • Adopting a forward-looking view on future business decisions that may affect quality and/or customer service. • Commitment to communicate the policy to all staff, customers, and other interested parties. • Complying with all applicable statutory laws and regulations. • Reviewing the context of the organisation and developing objectives and targets. • Ensuring adequate resources are available to achieve targets and that employees are suitably skilled to develop and provide a high-quality service and work in accordance with best practice. The Cox Group is responsible for establishing this Policy and for monitoring and reviewing the quality performance. The responsibility for the management and delivery of quality lies with all Directors and Managers.
Managing Director
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
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Document Reference: IM 02 Health and Safety Policy
Cox Management Services Limited is the holding company for subsidiary trading companies inclusive of Cox Skips Limited and The Recycling Partnership Limited generally referred to within this policy as the Cox Group. The Cox Group, inclusive of its subsidiary companies, recognise and are committed to the detail within the disclosure of the policy. The Cox Group (the ‘Company’) recognises the importance of health and safety and is committed to the Health and Safety of all its employees and other persons who may be affected by the Company’s activities. The Company operates a Health and Safety Management System and has ISO 45001: 2018 Health and Safety Management Accreditation , along with ISO 14001 and ISO 9001 accreditations, for waste management services for commercial, municipal and construction industry customers. The Managing Director is responsible to the board for the effective implementation and continuance of the Health and Safety Management System by the Management Team. The Senior Health, Safety and Transport Manager is responsible for, but not limited to: • Reporting and record keeping of records under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR). • Investigating near misses / incidents / accidents. • Carrying out new employee inductions. • Ensuring production and review of all risk assessments is completed and actions arising out of those assessments are implemented where necessary. The Management Team is committed to: • Providing strong Health and Safety leadership throughout the Company. • Striving for continual improvement in the management of Health and Safety. • Developing and maintaining the Health and Safety Management system. • Operating the business responsibly and complying with all applicable statutory laws, regulations, legislation and approved codes of practice relating to health and safety management. • Ensuring all reasonable and practical steps are taken to safeguard the health, safety and welfare of all employees and other persons who may visit the site. • Provisioning safe plant, machinery, equipment and systems of work. • Providing clear and adequate information, instructions and training to all employees and other persons who may work on site , to ensure competence to carry out their work in a responsible and safe manner.
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
Rev 11
01/11/2024
Approved: AK/AB
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PAS99: 2012 Issue 1
Document Reference: IM 02 Health and Safety Policy
• Carrying out visitor and subcontractors health and safety inductions, and provision of appropriate training and personal protective equipment where necessary. • Maintaining good relations with all regulatory bodies. The Management Team has a continuing commitment to: • Controlling noise emissions from operations. • Communicating throughout the Company the importance of meeting Health and Safety requirements. • Reviewing and communicating the Health and Safety Policy and its objectives to employees and interested parties, through Management meetings, employee meetings, employee noticeboards, training and Company websites. • Ensuring health and safety performance is constantly monitored, with effective implementation of improvements where required. • Reviewing the effectiveness of any improvements taken. • Ensuring availability of resources. The Company have taken the following actions to ensure compliance with Health and Safety: • All relevant and necessary signage for the protection and safety of employees and any other persons entering the site are displayed clearly and constantly reviewed. • Escape routes are well signed and kept clear at all times and monitored on a daily basis via the Site Daily Log. • Evacuation plans and procedures are tested at least annually and updated as necessary. • Facilities, such as toilets, washing facilities and drinking water are always provided. The Company ensures that these facilities are safe to use through a system of routine inspection and cleaning and will take appropriate action where necessary. • Implementation of systematic inspections and testing of equipment and machinery is completed ensuring any necessary action if carried out promptly and efficiently. Employees, visitors and other persons entering the site have a duty to cooperate in the implementation through: • Working and conducting themselves in a manner that promotes their own safety and the safety of others. • Following and obeying procedures and practices of the Company, which have been designed and implemented to ensure safe and healthy working conditions. • Reporting of any health and safety concerns, observations, accidents and near misses. This Health and Safety Policy statement is made available to all employees. Minutes of meetings , or extracts thereof, are provided to individual employees in accordance with
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
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Document Reference: IM 02 Health and Safety Policy
their role and responsibilities as a means of communicating the effectiveness of the Health and Safety Management System.
Managing Director
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
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Document Reference: IM 03 Environmental Policy
Cox Management Services Limited is the holding company for subsidiary trading companies inclusive of Cox Skips Limited and The Recycling Partnership Limited generally referred to within this policy as the Cox Group. The Cox Group, inclusive of its subsidiary companies, recognise and are committed to the detail within the disclosure of the policy. The Cox Group recognises the importance of environmental protection and is committed to reducing the impact of its activities on the environment and assisting our customers by encouraging them to use sustainable resources. The Company operates a Environmental Management System and has ISO 14001: 2015 Environmental Management Accreditation, along with ISO 45001 and ISO 9001 accreditations, for waste management services for commercial, municipal and construction industry customers. The Directors are responsible to the board for the effective implementation and continuance of the Environmental Management System by the Management Team. The Management Team is committed to: • Developing and maintaining the Environmental Management system. • Operating the business responsibly and complying with all applicable statutory laws, regulations, legislation and approved codes of practice relating to environmental waste management. • Adopting a forward-looking view on future business decisions that may affect environmental protection. • Maintaining good relations with all regulatory bodies. The Management Team has a continuing commitment to: • Reducing consumption of natural resources. • Controlling noise emissions from operations. • Reducing and/or limit the production of pollutants to water, land and air from operations. • Communicating throughout the Company the importance of meeting environmental requirements. • Reviewing and communicating the Environmental Policy and its objectives to employees and interested parties, through Management meetings, employee meetings, employee noticeboards, training and Company websites. • Assessing its environmental performance against the nature and scales of aspects, impacts and targets set within the scope of the Environmental Management system.
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
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Document Reference: IM 03 Environmental Policy
• Ensuring quality performance is constantly monitored, with effective implementation of improvements where required. • Ensuring daily / weekly and monthly site inspections are carried out to ensure the reduction / prevention of significant impacts on the environment and to record any environmental incidents, emergencies and complaints. • Reviewing the effectiveness of any improvements taken. • Ensuring availability of resources. • Ensuring that any suppliers the Company engage with apply environmental protection measures that are appropriate to the activity for which they are being engaged, and to check and review where necessary.
The Company provides environmental training to all employees.
This Environmental Policy statement is made available to all employees. Minutes of meetings , or extracts thereof, are provided to individual employees in accordance with their role and responsibilities as a means of communicating the effectiveness of the Environmental Management System.
Managing Director
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
Rev 11 01/11/2024 PAS99: 2012 Issue 1
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Document Reference: IM 04 Anti Bribery and Corruption Policy
Cox Management Services Limited is the holding company for subsidiary trading companies inclusive of Cox Skips Limited and The Recycling Partnership Limited generally referred to within this policy as the Cox Group. The Cox Group, inclusive of its subsidiary companies, recognise and are committed to the detail within the disclosure of the policy. This anti-bribery and corruption policy exists to set out the responsibilities of The Company and those who work for us with regards to observing and upholding our zero-tolerance position on bribery and corruption. It also exists to act as a source of information and guidance for those working for The Company. It will help them to recognise and deal with bribery and corruption issues, and to understand their responsibilities. The Cox Group is committed to conducting business in an ethical and honest manner and is committed to implementing and enforcing systems that ensure bribery is prevented. The Company has zero-tolerance for bribery and corrupt activities. The Company is committed to acting professionally, fairly and with integrity in all business dealings and relationships. The Cox Group will uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. The Company is bound by the laws of the UK, including the Bribery Act 2010. The Cox Group recognises that bribery and corruption are punishable on conviction on indictment, to imprisonment for a term, not exceeding 10 years, or to a fine, or to both. If The Company is discovered to have taken part in corrupt activities, they may be subjected to an unlimited fine, be excluded from tendering for public contracts and face serious damage to their reputation. The Cox Group commit to preventing bribery and corruption in their business and take their legal responsibilities seriously. This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK). The policy also applies to Officers, Trustees, Board, and/or Committee members at any level. In the context of this policy, third-party refers to any individual or organisation The Company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors,
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
Rev 12 01/11/2024 PAS99: 2012 Issue 1
Approved: AK
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Document Reference: IM 04 Anti Bribery and Corruption Policy
business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties. Any arrangements The Company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery and corruption. Definition of bribery Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision. A bribe refers to any inducement, reward, or object/item of value offered to another individual to gain commercial, contractual, regulatory, or personal advantage. Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law. Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from The Company’s Finance Manager. Gifts and hospitality The Cox Group accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements: a. It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits. b. It is not made with the suggestion that a return favour is expected. c. It is in compliance with local law. d. It is given in the name of the company, not in an individual’s name. e. It does not include cash or a cash equivalent (e.g. a voucher or gift certificate). f. It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion). g. It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift. h. It is given/received openly, not secretly.
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
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Document Reference: IM 04 Anti Bribery and Corruption Policy
i. It is not selectively given to a key, influential person, clearly with the intention of directly influencing them. j. It is not above a certain excessive value, as pre-determined by the company’s Finance Manager (usually in excess of £100). k. It is not offered to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s Finance Manager. Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is declared to the Finance Manager, who will assess the circumstances. The Company recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each. As good practice, gifts given and received should always be disclosed to the Finance Manager. Gifts from suppliers should always be disclosed. The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the Finance Manager should be sought. Facilitation Payments and Kickbacks The Cox Group does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action. The Cox Group does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage. The Cox Group recognises that, despite our strict policy on facilitation payments and kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may put their family’s personal security at risk. Under these circumstances, the following steps must be taken: a. Keep any amount to the minimum. b. Ask for a receipt, detailing the amount and reason for the payment. c. Create a record concerning the payment. d. Report this incident to your line manager.
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
Rev 12 01/11/2024 PAS99: 2012 Issue 1
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Document Reference: IM 04 Anti Bribery and Corruption Policy
Political Contributions The Cox Group will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. The Company recognise this may be perceived as an attempt to gain an improper business advantage. Charitable Contributions The Cox Group accepts (and indeed encourages) the act of donating to charities – whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes. Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery. The Cox Group will ensure that all charitable donations made are legal and ethical under local laws and practices, and that donations are not offered/made without the approval of the Finance manager. Competition Law The Cox Group are committed to ensuring that as a company and as individuals we comply with various legal rules around the world which are designed to ensure that market competition, nationally and internationally, is not restricted, prevented or distorted. Employee Responsibilities As an employee of The Cox Group, employees must ensure that they read, understand, and comply with the information contained within this policy, and with any training or other anti- bribery and corruption information they are given. All employees and those under The Company’s control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy. If any employee has reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, they must notify the Finance Manager. If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. The disciplinary procedure will be carried out as per The Employee Handbook. The Cox Group has the right to terminate a contractual relationship with an employee if they breach this anti-bribery policy.
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
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Document Reference: IM 04 Anti Bribery and Corruption Policy
If anyone suspects that there is an instance of bribery or corrupt activities occurring in relation to The Cox Group, they are encouraged to raise their concerns at as early a stage as possible. If they are uncertain about whether a certain action or behaviour can be considered bribery or corruption, they should speak to their line manager, the Finance Manager or Directors. What to do if you are a victim of bribery or corruption The Finance Manager must be informed as soon as possible if an employee is offered a bribe by anyone, if an employee is asked to make one, if any employee suspects that they may be bribed or asked to make a bribe in the near future, or if the employee has reason to believe that they are a victim of another corrupt activity. Protection If an employee refuses to accept or offer a bribe or they report a concern relating to potential act(s) of bribery or corruption, The Cox Group understands that they may feel worried about potential repercussions. The Cox Group will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken. The Cox Group will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption. Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised. If an employee has reason to believe they have been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, they should inform their line manager or the Finance Manager immediately. Training and communication The Cox Group will provide training on this policy as part of the induction process for all new employees. The Cox Group Anti Bribery and Corruption Policy and zero tolerance attitude will be made available to all suppliers, contractors, business partners and any third party upon request and via the relevant web sites. The Cox Group will provide relevant anti-bribery and corruption training to employees where The Company feels their knowledge of how to comply with the Bribery Act needs to be enhanced.
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
Rev 12 01/11/2024 PAS99: 2012 Issue 1
Approved: AK
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Document Reference: IM 04 Anti Bribery and Corruption Policy
Record keeping The Cox Group will keep detailed and accurate financial records and will have appropriate internal controls in place to act as evidence for all payments made. The Company will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given and understand that gifts and acts of hospitality are subject to managerial review. Monitoring and reviewing The Cox Group’s Finance Manager is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness. Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice. Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the Finance manager. This policy does not form part of an employee’s contract of employment and The Cox Group may amend it at any time so to improve its effectiveness at combatting bribery and corruption.
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
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Document Reference: IM 06 Data Protection Policy
Policy information
Cox Management Services Limited Cox Skips Limited The Recycling Partnership Limited
Organisation
The Data Controller is responsible for all branches of the Company.
Scope of policy
07 October 2021
Policy operational date
Kathryn Wakeling
Policy prepared by
Date approved by Board/ Management Committee
It is important that the policy should be approved by a Board if you have one Annually 01/11/2025 (Audited through ISO internal audits)
Policy review date
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
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Document Reference: IM 06 Data Protection Policy
Introduction
The Cox Group are committed to ensuring that your privacy is protected by: • complying with the law • complying with the Data Protection Act 2018 • complying with GDPR requirements and legislation • following good practice • protecting customers, staff and other individuals • protecting the organisation • Name • Contact information including email address • Demographic information including address and postcode • Legally required data relating to employees • Payment information • Identification documentation • Data required to comply with legal and legislative requirements • Other information relevant to business requirements The Cox Group are committed to : • comply with both the law and good practice • comply with the Data Protection Act 2018 • comply with GDPR • respect individuals’ rights • be open and honest with individuals whose data is held • provide training and support for staff who handle personal data, so that they can act confidently and consistently • Providing up to date IT data security, including but not limited to, firewalls, virus scanning, encrypted information, secure password policy • Voluntary reporting of any data breaches to the ICO
Purpose of policy
Types of data
Policy statement
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
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Document Reference: IM 06 Data Protection Policy
The main risks within the Company are: • information about data getting into the wrong hands, through poor security or inappropriate disclosure of information • individuals being harmed through data being inaccurate or insufficient
Key risks
Responsibilities Company Directors / Senior Management
Our Company Director and Senior Management have overall responsibility for ensuring that the organisation complies with its legal obligations. Our Data Protection Officer responsibilities include: • Briefing the Company Director and Senior Management on Data Protection responsibilities • Reviewing Data Protection and related policies • Advising other staff on tricky Data Protection issues • Ensuring that Data Protection induction and training takes place • Notification to the ICO • Handling subject access requests • Approving unusual or controversial disclosures of personal data • Approving contracts with Data Processors • IT Data Security in conjunction with IT Company All staff are required to read, understand and accept any policies and procedures that relate to the personal data they may handle in the course of their work. Employees that breach the Data Protection Policy will be subject to disciplinary action, up to and including termination of employment. Employees may also be held personally liable for violating this policy.
Data Protection Officer
Employees & Volunteers
Enforcement
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
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Document Reference: IM 06 Data Protection Policy
Security
To ensure secure, compliant and manageable Data Security and Business Continuity. The Company has undertaken an analysis of the risks presented by their processing and has used this to assess the appropriate level of security needed. The Company has put in place the following security measures: • An Information Security Policy including steps to make sure the policy is implemented • Additional policies and procedures where required. • Regular internal audits of policies and procedures • Data encryption where it is appropriate to do so • Appropriate onsite and off site encrypted back up process to ensure The Company can restore access to personal data in the event of any incidents • Regular testing and reviews of measures to ensure they remain effective, and to act on the results of those tests where they highlight areas for improvement • All computers are password protected, using a higher security password across the Company • A Business Continuity plan • IT virus scanning is scheduled on a daily basis, and updates and Firewalls are installed and are controlled by our IT company • Regular systems and server monitoring is active, with any issues or failures immediately reported to designated IT Company • Secure Virtual Private Networks (VPN) for any off site employees
Scope
Setting security levels
Security measures
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
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Document Reference: IM 06 Data Protection Policy
• Appropriate onsite and off site encrypted back up process to ensure The Company can restore access to personal data in the event of any incidents • Business Continuity Plan (QMF 601)
Business continuity
Data recording and storage
Data accuracy is confirmed either verbally, or via written media. Discarding of old data is checked on an annual basis. Certain legal and legislative obligations require The Company to hold data for specific periods. Customer information is stored securely on operational systems. Payment information is stored and encrypted through Sage. Employee information is stored securely using an external website. A full list of retention periods is updated and reviewed at least annually by the Data Protection Officer. The destruction of data is checked and carried out on an annual basis, using the retention periods list as reference, which is updated annually.
Accuracy
Updating
Storage
Retention periods
Archiving
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
Rev 6 01/11/2024 PAS99: 2012 Issue 1
Approved: AK
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Document Reference: IM 06 Data Protection Policy
Right of Access
The Data Protection Officer is responsible for ensuring that right of access requests are handled within one month. Right of access requests must be in writing and addressed to the Data Protection Officer. Employees are made aware of their responsibility to pass on anything which might be a subject access request to the Data Protection Officer or Deputy without delay. Where the person managing the access procedure does not know the individual personally , an identity check will be carried out as far as is reasonably practicable before handing over any information. Information will be provided free of charge, however should a request be manifestly unfounded, excessive, or particularly repetitive a reasonable fee will be charged, which is based on the administrative cost of providing the information. If the request is made electronically, The Company will provide the information in a commonly used electronic format.
Responsibility
Procedure for making request
Provision for verifying identity
Charging
Procedure for granting access
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
Rev 6 01/11/2024 PAS99: 2012 Issue 1
Approved: AK
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Document Reference: IM 06 Data Protection Policy
Transparency
The Company is committed to ensuring that Data Subjects are aware that their data is being processed, by providing transparent and honest information.
Commitment
Data subjects are informed by: • The Employee Handbook • Privacy Policy • Information Security Policy • The Company’s websites • Contracts • Terms and Conditions
Procedure
Senior Management, Departmental Heads, and The Data Protection Officer are responsible for ensuring the platforms are accessible.
Responsibility
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
Rev 6 01/11/2024 PAS99: 2012 Issue 1
Approved: AK
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Document Reference: IM 06 Data Protection Policy
Lawful Basis
• The individual has given clear consent for The Company to process their personal data for a specific purpose • The processing is necessary for a contract we have with the individual • The processing is necessary for us to comply with the law • The processing is necessary for us to perform a task in the public interest • The processing is necessary for our legitimate interests and/or the legitimate interests of a third party The opportunity to opt out of their data being used in particular ways can be exercised by contacting the Data Protection Officer via email or post. The Recycling Partnership Ltd: dpo@trpltd.com Cox Skips Ltd: dpo@coxskips.co.uk Cox Management Services Ltd: dpo@coxskips.co.uk The Company acknowledges that once given, consent can be withdrawn, however not respectively. There will be occasions where the organisation must retain data for a certain length of time for legal or compliance requirements, even though consent for withdrawal has been requested.
Underlying principles
Opting out
Withdrawing consent
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
Rev 6 01/11/2024 PAS99: 2012 Issue 1
Approved: AK
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Document Reference: IM 06 Data Protection Policy
Employee training & Acceptance of responsibilities
All employees who have access to any kind of personal data will have their responsibilities outlined during their induction procedures. Opportunities to raise Data Protection issues are available through employee E learning, employee departmental meetings, Senior Management meetings, internal audits. Acceptance of the employees’ responsibilities to Data Protection will be gained through their induction, and an annual review of the policy, which will be read through the E Learning process, which is recorded and added to the employee training file. The policy will be reviewed at least annually by the Data Protection Officer who is also the internal ISO auditor. The internal audit of the policy will be carried out by open surveillance of the procedures by the auditor, noting all observations and actions which will be reported to Senior Management and actioned where appropriate. The policy review will be carried out in accordance with our Internal ISO audits.
Induction
Continuing training
Procedure for staff signifying acceptance of policy
Policy review
Responsibility
Procedure
Timing
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
Rev 6 01/11/2024 PAS99: 2012 Issue 1
Approved: AK
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Document Reference: IM 10 Modern Slavery Policy
Cox Management Services Limited is the holding company for subsidiary trading companies inclusive of Cox Skips Limited and The Recycling Partnership Limited generally referred to within this policy as the Cox Group. The Cox Group, inclusive of its subsidiary companies, recognise and are committed to the detail within the disclosure of the policy. Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another to exploit them for personal or commercial gain. The Cox Group has a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or in any of our supply chains. The Cox Group are committed to ensuring there is transparency in the business and in the approach to tackling modern slavery throughout the supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. The Cox Group expect the same high standard from their contractors, suppliers and other business partners. This policy applies to all persons working for the Cox Group or on their behalf in any capacity, including but not limited to; employees at all levels, directors, officers, agency workers, agents, contractors, external consultants, third-party representatives and business partners. This policy does not form part of any employee’s contract of employment and The Cox Group may amend it at any time. Responsibility The Cox Group has overall responsibility for ensuring this policy complies with legal and ethical obligations, and that all those under the control of The Cox Group comply with it. The Cox Group has primary and day to day responsibility for implementing this policy, monitoring its use and effectiveness through internal audits, dealing with any queries about it, and auditing internal control systems and procedures at least annually in accordance with the ISO Management systems to ensure they are effective in countering modern slavery.
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
Rev 11 01/11/2024 PAS99: 2012 Issue 1
Approved: AK
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Document Reference: IM 10 Modern Slavery Policy
Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains. Compliance The Cox Group ensures that all employees read, understand and comply with this policy. The prevention, detection and reporting of modern slavery in any part of the Cox Group or supply chains is the responsibility of all those working for the Cox Group or under their control. Any employees, business partner, contractor or supplier must avoid any activity that might lead to or suggest a breach of this policy. They must notify a Line Manager or Company Director as soon as possible if they believe or suspect that a conflict with this policy has occurred or may occur in the future. All associated persons are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of the Cox Group business or supply chains of any supplier tier at the earliest possible stage. A suspected breach of this policy must be notified to the Line Manager or Company Director and reported in accordance with our Whistleblowing Policy (QSOP 119) as soon as possible. The Cox Group aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. The Cox Group are committed to ensuring that no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of the business or in any of their supply chains. Detrimental treatment includes dismissal, disciplinary actions, threats or other unfavourable treatment connected with raising a concern. Any employee who believes that they may have suffered such treatment should inform their Line Manager immediately or alternatively follow the Grievance Procedure in accordance with Employee Handbook. Communication Training on this policy and on the risk the business faces from modern slavery in its supply chain, forms part of the annual training for all individuals who work for The Cox Group and updates are provided using established methods of communication, including but not limited to, HR Program, staff noticeboard and E Learning.
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
Rev 11 01/11/2024 PAS99: 2012 Issue 1
Approved: AK
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Document Reference: IM 10 Modern Slavery Policy
Breaches If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. The disciplinary procedure will be carried out as per The Employee Handbook. The Cox Group has the right to terminate a contractual relationship with an employee if they breach this policy. The Cox Group hold the right to terminate a business relationship with other individuals and organisations that work on their behalf this policy is breached.
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
Rev 11 01/11/2024 PAS99: 2012 Issue 1
Approved: AK
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Document Reference: IM 11 Equality and Diversity Policy
Cox Management Services Limited is the holding company for subsidiary trading companies inclusive of Cox Skips Limited and The Recycling Partnership Limited generally referred to within this policy as the Cox Group. The Cox Group, inclusive of its subsidiary companies, recognise and are committed to the detail within the disclosure of the policy. The Cox Group are committed to promoting equality and diversity and promoting a culture that actively values difference and recognises that people from different backgrounds and experience can bring valuable insights to the workplace. Through recruiting, developing, training and retaining people, and complying to the Equality Act 2010 The Cox Group promotes a culture of respect and dignity and actively challenges discrimination should it ever arise. Every employee is entitled to a working environment that promotes dignity, equality and respect for everyone, and The Cox Group will not tolerate any acts of unlawful or unfair discrimination committed against an employee, contractor, job applicant or visitor because of a protected characteristic: • Sex • Gender reassignment • Marriage and civil partnership • Pregnancy and maternity • Race (including ethnic origin, colour, nationality and national origin) • Disability • Sexual orientation • Religion and/or belief • Age Any employee, contractor, job applicant or visitor who feels they may have suffered discrimination because of any of the above protected characteristics, should consider the appropriateness and feasibility of attempted informal resolution by discussion in the first instance with their Line Manager or another colleague in a relevant position of seniority. They may alternatively decide to raise the matter through the Company’s Grievance Policy. Allegations regarding potential breaches of this policy will be treated in confidence and investigated in accordance with the appropriate procedure. False allegations of a breach of this policy which are found to have been made in bad faith will be dealt with under the Company’s Disciplinary Procedure.
The policy will be reviewed at least annually through ISO audits to assess its effectiveness.
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
Rev 12 01/11/2024 PAS99: 2012 Issue 1
Approved: AK
1
Document Reference: IM 15 Right to Work Policy
Cox Management Services Limited is the holding company for subsidiary trading companies inclusive of Cox Skips Limited and The Recycling Partnership Limited generally referred to within this policy as the Cox Group. The Cox Group, inclusive of its subsidiary companies, recognise and are committed to the detail within the disclosure of the policy. The Company is legally obliged to comply with the requirements set by the UK Border Agency, to ensure that new and current staff are eligible to work in the UK and to adhere to any restrictions on their employment. The Company has controls in place to ensure compliance with Sections 15 to 25 of the Immigration, Asylum and Nationality Act 2006, which are applicable to all potential and current employees. The Cox Group assures that all agency, self-employed and subcontracted personnel are eligible to work in the UK. Penalties for employing illegal workers are as follows: If found guilty of employing someone who you knew or had reasonable cause to believe did not have the right to work in the UK, you can be subject to a five year prison sentence and an unlimited fine. If you employ someone who does not have the right to work in the UK and the correct checks were not undertaken or completed properly, you may face a civil penalty for each illegal worker. This policy outlines the requirements for obtaining proof of eligibility to work in the UK for potential and current employees. If you are unsure of the procedure you should contact a Senior Manager. Checking employee eligibility to work The Company is required to comply with the following, in ensuring that employees have the right to work in the UK: • Immigration Act 1971 • Asylum and Immigration Act 1996 • Immigration, Asylum and Nationality Act 2006 • Immigration Act 2016 The Cox Group identifies any foreign workers and their nationalities by viewing and checking their passport and/or settlement status card or other documentation compliant with the Home Office guidance - Comprehensive Guidance of Employers on Preventing Illegal Working – (full and up to date information can be found at gov.uk or here . _Copies of the documentation are uploaded to the HR system for audit purposes and are only viewable by the employee, line manager and
Cox Management Services Ltd ISO 9001 / ISO 14001 / ISO 45001
Rev 10 01/11/2024 PAS99: 2012 Issue 1
Approved: AK
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