TRUELINE EXPANDED PRODUCTS LIMITED
EMPLOYEE HANDBOOK
January 2022
TABLE OF CONTENTS
1. introduction................................................................................................................................. 1 2. Using the Staff Handbook .......................................................................................................... 1 3. Responsibility for the Staff Handbook ........................................................................................ 1 4. Personal data ............................................................................................................................. 2 5. Emergency contact details ......................................................................................................... 2 Schedule 1 - Dress code......................................................................................................................... 3 Schedule 2 - Expenses policy ................................................................................................................. 5 Schedule 3 - Equal opportunities policy .................................................................................................. 7 Schedule 4 - Anti-harassment and bullying policy ................................................................................ 11 Schedule 5 - Anti-corruption and bribery policy .................................................................................... 16 Schedule 6 - Anti-facilitation of tax evasion policy ................................................................................ 22 Schedule 7 - Sickness absence policy.................................................................................................. 27 Schedule 8 - Capability procedure ........................................................................................................ 34 Schedule 9 - Disciplinary rules.............................................................................................................. 40 Schedule 10 - Disciplinary procedure ................................................................................................... 43 Schedule 11 - Grievance procedure ..................................................................................................... 48 Schedule 12 - Whistleblowing policy..................................................................................................... 51 Schedule 13 - Holidays policy ............................................................................................................... 55 Schedule 14 - Time off for antenatal appointments policy.................................................................... 58 Schedule 15 - Time off for adoption appointments policy..................................................................... 60 Schedule 16 - Maternity policy .............................................................................................................. 62 Schedule 17 - Paternity policy............................................................................................................... 68 Schedule 18 - Adoption policy............................................................................................................... 72 Schedule 19 - Shared parental leave (birth) policy ............................................................................... 78 Schedule 20 - Shared parental leave (adoption) policy ........................................................................ 84 Schedule 21 - Parental leave policy...................................................................................................... 90 Schedule 22 - Time off for dependants policy....................................................................................... 94 Schedule 23 - Compassionate leave policy .......................................................................................... 96 Schedule 24 - Parental bereavement leave policy ............................................................................... 97 Schedule 25 - Flexible working policy ................................................................................................... 99 Schedule 26 - Homeworking policy..................................................................................................... 104 Schedule 27 - Time off for training policy............................................................................................ 108 Schedule 28 - Time off for public duties policy ................................................................................... 113 Schedule 29 - Adverse weather and travel disruption policy .............................................................. 115 Schedule 30 - Health and safety policy............................................................................................... 117 Schedule 31 - No-smoking policy ....................................................................................................... 120 Schedule 32 - Menopause policy ........................................................................................................ 121 Schedule 33 - Stress and mental wellbeing at work policy................................................................. 123 Schedule 34 - Substance misuse policy ............................................................................................. 128 Schedule 35 - Relationships at work policy ........................................................................................ 132 Schedule 36 - CCTV policy ................................................................................................................. 135 Schedule 37 - Privacy notice for employees, workers and contractors .............................................. 140 Schedule 38 - IT and communications systems policy ....................................................................... 149 Schedule 39 - Social media policy ...................................................................................................... 154 Schedule 40 - Repayment of training costs ........................................................................................ 157
1
1.
INTRODUCTION
1.1
We are one of the leading manufacturers and suppliers of fabricated products for the building and construction industry. For over 27 years we have been delivering our high-quality products all over the UK. With huge manufacturing facilities, powder coating, CAD design, large storage facilities we pride ourselves on being able to provide and assure clients a fast quality service. We are an equal opportunities employer and do not discriminate on the grounds of gender, sexual orientation, marital or civil partner status, pregnancy or maternity, gender reassignment, race, colour, nationality, ethnic or national origin, religion or belief, disability or age.
1.2
2.
USING THE STAFF HANDBOOK
2.1
This Staff Handbook sets out the main policies and procedures that you will need to be aware of while working for us. You should familiarise yourself with it and comply with it at all times. Any questions you may have with regard to its contents or what you have to do to comply with it should be referred to Management. The policies and procedures set out in this handbook apply to all staff unless otherwise indicated. They therefore apply to managers, officers, directors, employees, consultants, contractors, trainees, homeworkers, part-time and fixed- term employees, casual and agency staff and volunteers (collectively referred to as staff in this handbook). They do not form part of the terms of your contract with us, which are provided to you separately. Your contract sets out your job title, hours and place of work, probationary period, salary, holidays and holiday pay, sickness absence reporting procedure and sick pay, your entitlement to and obligation to give notice to terminate your contract and the duties of confidentiality and restrictions that continue to apply after the termination of your contract.
2.2
3.
RESPONSIBILITY FOR THE STAFF HANDBOOK
3.1
Our board of directors (the board) has overall responsibility for the operation of this Staff Handbook and for ensuring that its policies and procedures comply with our legal obligations. The board has delegated day-to-day responsibility for the operation of our policies and procedures to identified managers.
3.2
The Staff Handbook will be reviewed annually by the board to ensure that its provisions continue to meet our legal obligations and reflect best practice.
3.3
All managers have a specific responsibility to operate in accordance with the provisions set out in this Staff Handbook, to ensure that all staff understand the standards of behaviour expected of them and to take action when behaviour falls below those requirements. Managers will be given training in order that they may do so. Those working at a management level have a specific responsibility to set an appropriate standard of behaviour, to lead by example and to ensure that those they manage adhere to the policies and procedures and promote our aims and objectives with regard to equal opportunities. Everyone should ensure that they take the time to read and understand the content of this handbook and act in accordance with its aims and objectives. All staff must ensure that they are familiar with and comply with and support its policies and procedures. Questions about the content or application of the handbook should be directed to management. In addition, staff are invited to submit any comments or proposals with regard to the handbook or any of its content to management.
3.4
3.5
3.6
1
4.
PERSONAL DATA
Whenever we process personal data about you in connection with our policies, we will process it in accordance with our Data Protection Policy. We will only process your personal data if we have a lawful basis for doing so. We will notify you of the purpose or purposes for which we use it. Please see the Privacy Notice in this Staff Handbook for further information.
5.
EMERGENCY CONTACT DETAILS
5.1
The Business Support Officer is responsible for maintaining up-to-date details of your home address and the emergency contact telephone numbers of the person or persons you would like us to contact in the event of an emergency, for example if you have an accident. This information will be requested you start work and you should advise us of any changes straight away. This information is held in confidence and will only be used when needed.
2
SCHEDULE 1- DRESS CODE
1.
ABOUT THIS POLICY
1.1
We encourage everyone to maintain an appropriate standard of dress and personal appearance at work. The purpose of our dress code is to establish basic guidelines on appropriate clothing and appearance at our workplace, so that we:
(a) promote a positive and professional image;
(b) respect the needs of men and women from all cultures and religions;
(c) make any adjustments that may be needed because of disability;
(d) take account of health and safety requirements; and
(e) help staff and managers decide what clothing it is appropriate to wear to work.
1.2
Managers are responsible for ensuring that this dress code is observed and that a common sense approach is taken to any issues that may arise. Any enquiries regarding the operation of our dress code (including whether an article of clothing is suitable to wear to work) should be made to your line manager.
1.3
Failure to comply with the dress code may result in action under our Disciplinary Procedure.
1.4
We will review our dress code periodically to ensure that it reflects appropriate standards and continues to meet our needs.
1.5
This policy does not form part of any employee's contract of employment and we may amend it at any time.
2.
APPEARANCE
2.1
While working for us you represent us with clients and the public. Your appearance contributes to our reputation and the development of our business.
2.2
It is important that you appear clean and smart at all times when at work, particularly when you may be in contact with clients, other business contacts or the general public. Different departments may have specific clothing requirements, for example, because their work is customer-facing or raises particular health and safety concerns. It is important that you dress in a manner appropriate to your working environment and the type of work you do. Employees in certain roles may be required to wear company branded clothing provided by us, which should be kept clean and neat. If you are provided with an overall you should wear this at all times whilst on Company business.
2.3
2.4
2.5
All employees should wear business casual attire. If you are issued with PPE you must wear this at all times.
2.6
You should not wear casual, gym or beach wear to work. This includes track suits, sweat-shirts, combat trousers, jogging bottoms, or leggings. Clothing should not be dirty, frayed or torn. Tops should not carry wording or pictures that might be offensive or cause damage to our reputation. It is inappropriate to wear cut-off shorts, crop tops, see-through material or clothing that exposes areas of the body normally covered at work.
2.7
You may wear casual wear to work on a dress down Friday.
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2.8
Footwear must be safe and clean and take account of health and safety considerations. Stilettos, and flip-flops are not acceptable.
2.9
Where we provide safety clothing and equipment, including protective footwear, it should be worn or used as appropriate and directed.
2.10
You should not wear clothing or jewellery that could present a health and safety risk.
3.
RELIGIOUS AND CULTURAL DRESS
3.1
You may wear appropriate religious and cultural dress (including clerical collars, head scarves, skullcaps and turbans) unless it creates a health and safety risk to you or any other person or otherwise breaches this policy.
3.2
Where necessary your line manager can give further information and guidance on cultural and religious dress in the workplace.
3.3
Priority is at all times given to health and safety requirements. Where necessary, advice will be taken from the Health and Safety Manager.
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SCHEDULE 2 - EXPENSES POLICY
1.
ABOUT THIS POLICY
1.1
This policy deals with claims for reimbursement of expenses, including travel, accommodation and hospitality.
1.2
This policy covers all employees, officers, consultants, contractors, volunteers, interns casual workers and agency workers.
1.3
This policy does not form part of any employee's contract of employment, and we may amend it at any time.
2.
PERSONNEL RESPONSIBLE FOR THIS POLICY
2.1
Our board of directors (the board) has overall responsibility for the effective operation of this policy but has delegated day-to-day responsibility for overseeing its implementation to the General Manager. All managers have a specific responsibility to operate within the boundaries of this policy, to ensure that all staff understand the procedure they are required to follow and to take action when behaviour falls below its requirements.
2.2
3.
REIMBURSEMENT OF EXPENSES
3.1
We will reimburse expenses properly incurred in accordance with this policy. Any attempt to claim expenses fraudulently or in breach of this policy may result in disciplinary action.
3.2
Expenses will only be reimbursed if they are:
(a) submitted to the Accounts Department on the appropriate claim form;
(b) submitted within 28 days of being incurred;
(c) supported by relevant documents (for example, VAT receipts, tickets, and credit or debit card slips); and
(d) authorised in advance where required.
3.3
Claims for authorised expenses submitted in accordance with this policy will be paid directly into your bank/building society account via payroll.
3.4
Any questions about the reimbursement of expenses should be put to your line manager before you incur the relevant costs.
4.
TRAVEL EXPENSES
4.1
We will reimburse the reasonable cost of necessary travel in connection with our business. The most economic means of travel should be chosen if practicable and you should use existing travelcards or season tickets wherever possible. The following are not treated as travel in connection with our business:
(a) travel between your home and usual place of work;
(b) travel which is mainly for your own purposes; and
(c) travel which, while undertaken on our behalf, is similar or equivalent to travel between your home and your usual place of work.
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4.2
Trains . We will reimburse the cost of standard class travel on submission of a receipt with an expenses claim form.
4.3
Taxis . We do not expect you to take a taxi when there is public transport available, unless it is cost effective due to a significant saving of journey time or the number of staff travelling together. A receipt should be obtained for submission with an expenses claim form. Car . Where it is cost effective for you to use your car for business travel, and you have been authorised to do so, you can claim a mileage allowance on proof of mileage. Details of the current mileage rates can be obtained from the Accounts Department. You can also claim for any necessary parking costs which must be supported by a receipt or the display ticket.
4.4
4.5
Air travel . If you are required to travel by plane in the course of your duties you should discuss travel arrangements with a Director in advance.
4.6
We will not reimburse penalty fares or fines for parking or driving offences, other than at our discretion in exceptional circumstances.
5.
ACCOMMODATION AND OTHER OVERNIGHT EXPENSES
5.1
If you are required to stay away overnight in the course of your duties you should discuss accommodation arrangements with Accounts Department in advance.
5.2
We will reimburse your reasonable out-of-pocket expenses for overnight stays provided they are supported by receipts as follows:
(a) up to £80 for each night spent away from home for incidental expenses.
6.
ENTERTAINING CLIENTS
6.1
You may entertain actual or prospective clients only where your proposal and an appropriate budget has been agreed in writing in advance with your line manager. Receipts must be submitted in full with your expenses claim.
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SCHEDULE 3- EQUAL OPPORTUNITIES POLICY
1.
EQUAL OPPORTUNITIES STATEMENT
1.1
Trueline Expanded Products Limited committed to promoting equal opportunities in employment. You and any job applicants will receive equal treatment regardless of age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation ( Protected Characteristics ).
2.
ABOUT THIS POLICY
2.1
This policy sets out our approach to equal opportunities and the avoidance of discrimination at work. It applies to all aspects of employment with us, including recruitment, pay and conditions, training, appraisals, promotion, conduct at work, disciplinary and grievance procedures, and termination of employment.
2.2
This policy covers all employees, officers, consultants, contractors, casual workers and agency workers.
2.3
This policy does not form part of any employee's contract of employment and we may amend it at any time.
3.
WHO IS RESPONSIBLE FOR THIS POLICY?
3.1
Our board of directors (the board) has overall responsibility for the effective operation of this policy and for ensuring compliance with discrimination law. Day-to- day operational responsibility for this policy including regular review of this policy, has been delegated to the General Manager. All managers must set an appropriate standard of behaviour, lead by example and ensure that those they manage adhere to the policy and promote our aims and objectives with regard to equal opportunities. Managers will be given appropriate training on equal opportunities awareness and equal opportunities recruitment and selection best practice. The General Manager has overall responsibility for equal opportunities training.
3.2
3.3
If you are involved in management or recruitment, or if you have any questions about the content or application of this policy, you should contact Luke Wellings.
3.4
This policy is reviewed annually by the board. Recommendations for change should be reported to the board.
3.5
Staff are invited to comment on this policy and suggest ways in which it might be improved by contacting Luke Wellings.
4.
DISCRIMINATION
4.1
You must not unlawfully discriminate against or harass other people including current and former employees, job applicants, clients, customers, suppliers and visitors. This applies in the workplace, outside the workplace (when dealing with customers, suppliers or other work-related contacts or when wearing company branded clothing), and on work-related trips or events including social events.
4.2
The following forms of discrimination are prohibited under this policy and are unlawful:
(a) Direct discrimination: treating someone less favourably because of a Protected Characteristic. For example, rejecting a job applicant because of their religious views or because they might be gay.
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(b) Indirect discrimination: a provision, criterion or practice that applies to everyone but adversely affects people with a particular Protected Characteristic more than others, and is not justified. For example, requiring a job to be done full-time rather than part-time would adversely affect women because they generally have greater childcare commitments than men. Such a requirement would be discriminatory unless it can be justified. (c) Harassment: this includes sexual harassment and other unwanted conduct related to a Protected Characteristic, which has the purpose or effect of violating someone's dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. Harassment is dealt with further in our Anti- harassment and Bullying Policy.
(d) Victimisation: retaliation against someone who has complained or has supported someone else's complaint about discrimination or harassment.
(e) Disability discrimination: this includes direct and indirect discrimination, any unjustified less favourable treatment because of the effects of a disability, and failure to make reasonable adjustments to alleviate disadvantages caused by a disability.
5.
RECRUITMENT AND SELECTION
5.1
Recruitment, promotion, and other selection exercises such as redundancy selection will be conducted on the basis of merit, against objective criteria that avoid discrimination. Shortlisting should be done by more than one person. Our recruitment procedures should be reviewed regularly to ensure that individuals are treated on the basis of their relevant merits and abilities. Vacancies should generally be advertised to a diverse section of the labour market. Advertisements should avoid stereotyping or using wording that may discourage particular groups from applying. They should include a short policy statement on equal opportunities and a copy of this policy will be made available on request. We take steps to ensure that our vacancies are advertised to a diverse labour market and, where relevant, to particular groups that have been identified as disadvantaged or underrepresented in our organisation. Where appropriate, we may approve the use of lawful exemptions to recruit someone with a particular Protected Characteristic, for example, where the job can only be done by a woman. The advertisement should specify the exemption that applies. Job applicants should not be asked questions which might suggest an intention to discriminate on grounds of a Protected Characteristic. For example, applicants should not be asked whether they are pregnant or planning to have children. Job applicants should not be asked about health or disability before a job offer is made. There are limited exceptions which should only be used with the approval of a director. For example:
5.2
5.3
5.4
5.5
(a) Questions necessary to establish if an applicant can perform an intrinsic part of the job (subject to any reasonable adjustments).
(b) Questions to establish if an applicant is fit to attend an assessment or any reasonable adjustments that may be needed at interview or assessment.
(c)
Positive action to recruit disabled persons.
(d) Equal opportunities monitoring (which will not form part of the selection or decision-making process).
Where necessary, job offers can be made conditional on a satisfactory medical check.
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5.6
We are required by law to ensure that all employees are entitled to work in the UK. Assumptions about immigration status should not be made based on appearance or apparent nationality. All prospective employees, regardless of nationality, must be able to produce original documents (such as a passport) before employment starts, to satisfy current immigration legislation. The list of acceptable documents is available from the Business Support Officer or UK Visas and Immigration. To ensure that this policy is operating effectively, and to identify groups that may be underrepresented or disadvantaged in our organisation, we monitor applicants' ethnic group, gender, disability, sexual orientation, religion and age as part of the recruitment procedure. Provision of this information is voluntary and it will not adversely affect an individual's chances of recruitment or any other decision related to their employment. The information is removed from applications before shortlisting, and kept in an anonymised format solely for the purposes stated in this policy. Analysing this data helps us take appropriate steps to avoid discrimination and improve equality and diversity.
5.7
6.
TRAINING AND PROMOTION AND CONDITIONS OF SERVICE
6.1
Training needs will be identified through regular appraisals. You will be given appropriate access to training to enable you to progress within the organisation and all promotion decisions will be made on the basis of merit. Our conditions of service, benefits and facilities are reviewed regularly to ensure that they are available to all of you who should have access to them and that there are no unlawful obstacles to accessing them.
6.2
7.
TERMINATION OF EMPLOYMENT
7.1
We will ensure that redundancy criteria and procedures are fair and objective and are not directly or indirectly discriminatory.
7.2
We will also ensure that disciplinary procedures and penalties are applied without discrimination, whether they result in disciplinary warnings, dismissal or other disciplinary action.
8.
DISABILITIES
8.1
If you are disabled or become disabled, we encourage you to tell us about your condition so that we can support you as appropriate.
8.2
If you experience difficulties at work because of your disability, you may wish to contact your line manager to discuss any reasonable adjustments that would help overcome or minimise the difficulty. Your line manager may wish to consult with you and your medical adviser about possible adjustments. We will consider the matter carefully and try to accommodate your needs within reason. If we consider a particular adjustment would not be reasonable we will explain our reasons and try to find an alternative solution where possible. We will monitor the physical features of our premises to consider whether they might place anyone with a disability at a substantial disadvantage. Where necessary, we will take reasonable steps to improve access.
8.3
9.
PART-TIME AND FIXED-TERM WORK
9.1
Part-time and fixed-term staff should be treated the same as comparable full-time or permanent staff and enjoy no less favourable terms and conditions (on a pro-rata basis where appropriate), unless different treatment is justified.
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10.
BREACHES OF THIS POLICY
10.1
We take a strict approach to breaches of this policy, which will be dealt with in accordance with our Disciplinary Procedure. Serious cases of deliberate discrimination may amount to gross misconduct resulting in dismissal. If you believe that you have suffered discrimination you can raise the matter through our Grievance Procedure or through our Anti-harassment and Bullying Policy as appropriate. Complaints will be treated in confidence and investigated as appropriate. There must be no victimisation or retaliation against staff who complain about discrimination. However, making a false allegation deliberately and in bad faith will be treated as misconduct and dealt with under our Disciplinary Procedure.
10.2
10.3
11.
RELATED POLICIES
11.1
This policy is supported by the following other policies and procedures:
(a) Anti-Harassment and Bullying Policy.
(b) Grievance Procedure.
(c)
Disciplinary Procedure.
(d) Flexible Working Procedure.
(e) Maternity, Paternity, Adoption and Shared Parental Leave Policies.
(f)
Parental Leave Policy.
(g) Time Off for Dependants Policy.
(h) Dress Code.
(i)
Homeworking Policy.
(j)
Career Break Policy.
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SCHEDULE 4- ANTI-HARASSMENT AND BULLYING POLICY
1.
ABOUT THIS POLICY
1.1
Trueline Expanded Products Limited is committed to providing a working environment free from harassment and bullying and ensuring all staff are treated, and treat others, with dignity and respect. This policy covers harassment or bullying which occurs at work and out of the workplace, such as on business trips or at work-related events or social functions. It covers bullying and harassment by staff (which may include consultants, contractors and agency workers) and also by third parties such as customers, suppliers or visitors to our premises.
1.2
1.3
This policy covers all employees, officers, consultants, contractors, volunteers, interns, casual workers and agency workers.
1.4
This policy does not form part of any employee's contract of employment and we may amend it at any time.
2.
WHO IS RESPONSIBLE FOR THIS POLICY?
2.1
Our board of directors (the board) has overall responsibility for the effective operation of this policy but has delegated day-to-day responsibility for overseeing its implementation to the General Manager. All managers have a specific responsibility to operate within the boundaries of this policy, ensure that all staff understand the standards of behaviour expected of them and to take action when behaviour falls below its requirements.
2.2
2.3
Staff should disclose any instances of harassment or bullying of which they become aware to the General Manager.
2.4
Questions about this policy and requests for training or information on dealing with bullying or harassment should be directed to the General Manager .
2.5
This policy is reviewed annually by the board. Recommendations for any amendments are reported to Luke Wellings.
2.6
Luke Wellings has responsibility for ensuring that any person who may be involved with investigations or administrative tasks carried out under this policy receive regular and appropriate training to assist them with these duties.
2.7
Staff are invited to comment on this policy and suggest ways in which it might be improved by contacting Luke Wellings
3.
WHAT IS HARASSMENT?
3.1
Harassment is any unwanted physical, verbal or non-verbal conduct that has the purpose or effect of violating a person's dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. A single incident can amount to harassment.
3.2
It also includes treating someone less favourably because they have submitted or refused to submit to such behaviour in the past.
3.3
Unlawful harassment may involve conduct of a sexual nature (sexual harassment), or it may be related to age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation. Harassment is unacceptable even if it does not fall within any of these categories.
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3.4
Harassment may include, for example:
(a) unwanted physical conduct or "horseplay", including touching, pinching, pushing and grabbing;
(b) continued suggestions for social activity after it has been made clear that such suggestions are unwelcome;
(c) sending or displaying material that is pornographic or that some people may find offensive (including emails, text messages, video clips and images sent by mobile phone or posted on the internet);
(d) unwelcome sexual advances or suggestive behaviour (which the harasser may perceive as harmless);
(e) racist, sexist, homophobic or ageist jokes, or derogatory or stereotypical remarks about a particular ethnic or religious group or gender;
(f)
outing or threatening to out someone as gay or lesbian;
(g) offensive emails, text messages or social media content; or
(h) mocking, mimicking or belittling a person's disability.
3.5
A person may be harassed even if they were not the intended "target". For example, a person may be harassed by racist jokes about a different ethnic group if the jokes create an offensive environment.
4.
WHAT IS BULLYING?
4.1
Bullying is offensive, intimidating, malicious or insulting behaviour involving the misuse of power that can make a person feel vulnerable, upset, humiliated, undermined or threatened. Power does not always mean being in a position of authority, but can include both personal strength and the power to coerce through fear or intimidation.
4.2
Bullying can take the form of physical, verbal and non-verbal conduct. Bullying may include, by way of example:
(a) physical or psychological threats;
(b) overbearing and intimidating levels of supervision;
(c) inappropriate derogatory remarks about someone's performance;
4.3
Legitimate, reasonable and constructive criticism of a worker's performance or behaviour, or reasonable instructions given to workers in the course of their employment, will not amount to bullying on their own.
5.
IF YOU ARE BEING HARASSED OR BULLIED: INFORMAL STEPS
5.1
If you are being harassed or bullied, consider whether you feel able to raise the problem informally with the person responsible. You should explain clearly to them that their behaviour is not welcome or makes you uncomfortable. If this is too difficult or embarrassing, you should speak to your line manager who can provide confidential advice and assistance in resolving the issue formally or informally. If you are not certain whether an incident or series of incidents amounts to bullying or harassment, you should initially contact your line manager informally for confidential advice.
5.2
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5.3
If informal steps are not appropriate, or have been unsuccessful, you should follow the formal procedure set out below and/or refer to our Grievance Procedure.
6.
RAISING A FORMAL COMPLAINT
6.1
If you wish to make a formal complaint about bullying or harassment, you should submit it in writing to the General Manager, whose role is to achieve a solution wherever possible and to respect the confidentiality of all concerned. If the matter concerns that person, you should refer it to Luke Wellings. Your written complaint should set out full details of the conduct in question, including the name of the harasser or bully, the nature of the harassment or bullying, the date(s) and time(s) at which it occurred, the names of any witnesses and any action that has been taken so far to attempt to stop it from occurring. As a general principle, the decision whether to progress a complaint is up to you. However, we have a duty to protect all staff and may pursue the matter independently if, in all the circumstances, we consider it appropriate to do so.
6.2
6.3
7.
FORMAL INVESTIGATIONS
7.1
We will investigate complaints in a timely and confidential manner. Individuals not involved in the complaint or the investigation should not be told about it. The investigation will be conducted by someone with appropriate experience and no prior involvement in the complaint. The investigation should be thorough, impartial and objective, and carried out with sensitivity and due respect for the rights of all parties concerned. We will arrange a meeting with you, usually within one week of receiving your complaint, so that you can give your account of events. You have the right to be accompanied by a colleague or a trade union representative of your choice, who must respect the confidentiality of the investigation. You will be given a provisional timetable for the investigation. The investigator will arrange further meetings with you as appropriate throughout the investigation. Where your complaint is about an employee, we may consider suspending them on full pay or making other temporary changes to working arrangements pending the outcome of the investigation, if circumstances require. The investigator will also meet with the alleged harasser or bully who may also be accompanied by a colleague or trade union representative of their choice to hear their account of events. They have a right to be told the details of the allegations against them, so that they can respond. Where your complaint is about someone other than an employee, such as a customer, supplier or visitor, we will consider what action may be appropriate to protect you and anyone involved pending the outcome of the investigation, bearing in mind the reasonable needs of the business and the rights of that person. Where appropriate, we will attempt to discuss the matter with the third party. We will also seriously consider any request that you make for changes to your own working arrangements during the investigation. For example you may ask for changes to your duties or working hours so as to avoid or minimise contact with the alleged harasser or bully.
7.2
7.3
7.4
7.5
7.6
It may be necessary to interview witnesses to any of the incidents mentioned in your complaint. If so, the importance of confidentiality will be emphasised to them.
7.7
At the end of the investigation, the investigator will submit a report to a senior manager nominated to consider the complaint. The senior manager will arrange a meeting with you, usually within a week of receiving the report, in order to discuss the outcome and what action, if any, should be taken. You have the right to bring a
13
colleague or a trade union representative to the meeting. A copy of the report and the senior manager’s findings will be given to you and to the alleged harasser.
8.
ACTION FOLLOWING THE INVESTIGATION
8.1
If the Senior Manager considers that harassment or bullying has occurred, prompt action will be taken to address it.
8.2
Where the harasser or bully is an employee the matter will be dealt with as a case of possible misconduct or gross misconduct under our Disciplinary Procedure. If the harasser or bully is a third party such as a customer or other visitor, we will consider what action would be appropriate to deal with the problem. Whether or not your complaint is upheld, we will consider how best to manage any ongoing working relationship between you and the person concerned. Whether or not your complaint is upheld, we will consider how best to manage the ongoing working relationship between you and the person concerned. It may be appropriate to arrange some form of mediation and/or counselling, or to change the duties, working location or reporting lines of one or both parties. Any staff member who deliberately provides false information or otherwise acts in bad faith as part of an investigation may be subject to action under our Disciplinary Procedure.
8.3
8.4
9.
APPEALS
9.1
If you are not satisfied with the outcome you may appeal in writing to Luke Wellings stating your full grounds of appeal, within one week of the date on which the decision was sent or given to you. We will hold an appeal meeting, normally within one week of receiving your written appeal. This will be dealt with impartially by a more senior manager who has not previously been involved in the case (although they may ask anyone previously involved to be present). You may bring a colleague or trade union representative to the meeting.
9.2
9.3
We will confirm our final decision in writing, usually within one week of the appeal hearing. This is the end of the procedure and there is no further appeal.
10.
PROTECTION AND SUPPORT FOR THOSE INVOLVED
10.1
Staff who make complaints or who participate in good faith in any investigation must not suffer any form of retaliation or victimisation as a result. Anyone found to have retaliated against or victimised someone in this way will be subject to disciplinary action under our Disciplinary Procedure. If you believe you have suffered any such treatment you should inform your line manager. If the matter is not remedied you should raise it formally using our Grievance Procedure or this procedure if appropriate.
10.2
10.3
We offer access to confidential counselling, which is available on request for anyone affected by, or accused of, bullying or harassment. The details are set out below.
11.
CONFIDENTIALITY AND RECORD-KEEPING
11.1
Confidentiality is an important part of the procedures provided under this policy. Details of the investigation and the names of the person making the complaint and the person accused must only be disclosed on a "need to know" basis. Breach of confidentiality may give rise to disciplinary action under our Disciplinary Procedure.
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11.2
Information about a complaint by or about an employee may be placed on the employee's personnel file, along with a record of the outcome and of any notes or other documents compiled during the process.
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SCHEDULE 5 - ANTI-CORRUPTION AND BRIBERY POLICY
1.
POLICY STATEMENT
1.1
It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery and corruption. We will uphold all laws relevant to countering bribery and corruption in all the jurisdictions in which we operate. However, we remain bound by UK laws, including the Bribery Act 2010, in respect of our conduct both at home and abroad.
1.2
2.
ABOUT THIS POLICY
2.1
The purpose of this policy is to:
(a) set out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption; and
(b) provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues.
2.2
It is a criminal offence to offer, promise, give, request, or accept a bribe. Individuals found guilty can be punished by up to ten years' imprisonment and/or a fine. As an employer if we fail to prevent bribery we can face an unlimited fine, exclusion from tendering for public contracts, and damage to our reputation. We therefore take our legal responsibilities very seriously. In this policy, third party means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
2.3
2.4
This policy does not form part of any employee's contract of employment and we may amend it at any time.
3.
WHO MUST COMPLY WITH THIS POLICY?
3.1
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners, sponsors, or any other person associated with us, wherever located.
4.
WHO IS RESPONSIBLE FOR THE POLICY?
4.1
The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it. The compliance manager has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering bribery and corruption. 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.
4.2
4.3
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4.4
You are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the compliance manager.
5.
WHAT ARE BRIBERY AND CORRUPTION?
5.1
Bribery is offering, promising, giving or accepting any financial or other advantage, to induce the recipient or any other person to act improperly in the performance of their functions, or to reward them for acting improperly, or where the recipient would act improperly by accepting the advantage.
5.2
An advantage includes money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or anything else of value.
5.3
A person acts improperly where they act illegally, unethically, or contrary to an expectation of good faith or impartiality, or where they abuse a position of trust. The improper acts may be in relation to any business or professional activities, public functions, acts in the course of employment, or other activities by or on behalf of any organisation of any kind.
5.4
Corruption is the abuse of entrusted power or position for private gain.
Examples:
Offering a bribe: You offer a potential client tickets to a major sporting event, but only if they agree to do business with us.
This would be an offence as you are making the offer to gain a commercial and contractual advantage. We may also be found to have committed an offence because the offer has been made to obtain business for us. It may also be an offence for the potential client to accept your offer.
Receiving a bribe: A supplier gives your nephew a job, but makes it clear that in return they expect you to use your influence in our organisation to ensure we continue to do business with them.
It is an offence for a supplier to make such an offer. It would be an offence for you to accept the offer as you would be doing so to gain a personal advantage.
Bribing a foreign official: You arrange for the business to pay an additional "facilitation" payment to a foreign official to speed up an administrative process, such as clearing our goods through customs. The offence of bribing a foreign public official is committed as soon as the offer is made. This is because it is made to gain a business advantage for us. We may also be found to have committed an offence.
6.
WHAT YOU MUST NOT DO
6.1
It is not acceptable for you (or someone on your behalf) to:
(a) give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given;
(b) give or accept a gift or hospitality during any commercial negotiations or tender process, if this could be perceived as intended or likely to influence the outcome;
(c) accept a payment, gift or hospitality from a third party that you know or suspect is offered with the expectation that it we will provide a business advantage for them or anyone else in return;
(d) accept hospitality from a third party that is unduly lavish or extravagant under the circumstances.
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(e) offer or accept a gift to or from government officials or representatives, or politicians or political parties;
(f) threaten or retaliate against another individual who has refused to commit a bribery offence or who has raised concerns under this policy; or
(g) engage in any other activity that might lead to a breach of this policy.
7.
FACILITATION PAYMENTS AND KICKBACKS
7.1
We do not make, and will not accept, facilitation payments or "kickbacks" of any kind.
7.2
Facilitation payments , also known as "back-handers" or "grease payments", are typically small, unofficial payments made to secure or expedite a routine or necessary action (for example by a government official). They are not common in the UK, but are common in some other jurisdictions in which we operate.
7.3
Kickbacks are typically payments made in return for a business favour or advantage.
7.4
You must avoid any activity that might lead to a facilitation payment or kickback being made or accepted by us or on our behalf, or that might suggest that such a payment will be made or accepted. If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with the compliance manager.
8.
GIFTS, HOSPITALITY AND EXPENSES
8.1
This policy allows reasonable and appropriate hospitality or entertainment given to or received from third parties, for the purposes of:
(a) establishing or maintaining good business relationships;
(b) improving or maintaining our image or reputation; or
(c) marketing or presenting our products and/or services effectively.
8.2
You are prohibited from accepting a gift from or giving a gift to a third party is allowed if the following requirements are met:
(a) it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
(b) it is given in our name, not in your name;
(c) it does not include cash or a cash equivalent (such as gift certificates or vouchers);
(d) it is appropriate in the circumstances, taking account of the reason for the gift, its timing and value. For example, in the UK it is customary for small gifts to be given at Christmas;
(e) it is given openly, not secretly; and
(f)
it complies with any applicable local law.
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