The Company is committed to promoting equal opportunities in employment. Employees 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).
This policy sets out the Company’s approach to equal opportunities and the avoidance of discrimination at work. It applies to all aspects of employment, including recruitment, pay and conditions, training, appraisals, promotion, conduct at work, disciplinary and grievance procedures, and termination of employment. In addition our Valuing Diversity and Dignity at Work policy can be found in our Employee Handbook.
Employees 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), and on work-related trips or events including social events.
The following forms of discrimination are prohibited under this policy and are unlawful:
• 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.
• 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.
• 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.
• Victimisation: retaliation against someone who has complained or has supported someone else’s complaint about discrimination or harassment.
• 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.
Recruitment and selection
Recruitment, promotion and other selection exercises such as redundancy selection will be conducted on the basis of merit, against objective criteria that avoid discrimination. Where practicable, shortlisting and/or selection decisions will be undertaken by more than one person.
Vacancies will generally be advertised to a diverse section of the labour market. Advertisements will avoid stereotyping or using wording that may discourage particular groups from applying.
Job applicants will 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 will not be asked about health or disability before a job offer is made, except in the very limited circumstances allowed by law: for example, to check that the applicant could perform an intrinsic part of the job (taking account of any reasonable adjustments), or to see if any adjustments might be needed at interview because of a disability. Where necessary, job offers can be made conditional on a satisfactory medical check.
If an employee is disabled, or becomes disabled, the Company encourages employee to let us know about their condition so that the Company can consider what reasonable adjustments or support may be appropriate.
Part-time and fixed-term work
Part-time and fixed-term employees will be treated the same as comparable full-time or permanent employees and enjoy no less favourable terms and conditions (on a pro-rata basis where appropriate), unless different treatment is justified.
Anti-Slavery and Human Trafficking 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 in order to exploit them for personal or commercial gain.
The Company has a zero-tolerance approach to modern slavery and any form of child labour in their business operations and is committed to acting ethically and with integrity in all business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere within the business or in any of its supply chains.
The Company is also committed to ensuring there is transparency in its own business and in its approach to tackling modern slavery throughout its supply chains, consistent with its disclosure obligations under the Modern Slavery Act 2015. The Company expects the same high standards from all of its contractors, suppliers and other business partners, and as part of its contracting processes, the Company includes specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and the Company expects that its suppliers will hold their own suppliers to the same high standards.
This policy applies to all persons working for the Company or on its 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.
This policy does not form part of any employee’s contract of employment and the Company may amend it at any time.
Responsibility for the policy
The board of directors has overall responsibility for ensuring this policy complies with the Company’s legal and ethical obligations, and that all those under its 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 modern slavery.
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 with the policy
The prevention, detection and reporting of modern slavery in any part of the Company’s business or supply chains is the responsibility of all those working for the Company or under its control. Employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.
Employees must notify their manager as soon as possible if they believe or suspect that a conflict with this policy has occurred, or may occur in the future.
Employees are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of the Company or supply chains of any supplier tier at the earliest possible stage.
If employees believe or suspect a breach of this policy has occurred or that it may occur they must notify their manager as soon as possible.
If employees are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, they must raise it with their manager.
The Company aims 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 Company is committed to ensuring 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 Company’s own business or in any of its supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If an employee believes that they have suffered any such treatment, they should inform the compliance manager immediately. If the matter is not remedied, the employee should raise it formally using the Grievance Procedure, which can be found in the Employee Handbook.
Communication and awareness of this policy
Training on this policy, and on the risk the Company faces from modern slavery in its supply chains, forms part of the induction process for all individuals who work for the Company, and regular training will be provided as necessary.
The Company’s zero-tolerance approach modern slavery in its business and supply chains must be communicated to all suppliers, contractors and business partners at the outset of its business relationship with them and reinforced as appropriate thereafter.
The Company may terminate its relationship with other individuals and organisations working on its behalf if they breach this policy.
Environment and Sustainability Policy
The aim of this policy is to set out the Company’s obligations and approach which will be taken in respect promoting sustainability whilst having a respect for the environment.
The Company is committed to promoting sustainability and reducing the impact on the environment of any activity carried out by the Company. In addition the Company will encourage its employees, clients and suppliers to adopt a similar approach.
• The Company wishes to comply with and exceed where possible relevant legislation and codes of practice.
• The Company will ensure all employees are aware of its environment and sustainability policy and practices and is committed to implementing them.
• The Company will minimise waste by evaluating its operations, taking action wherever possible to ensure its practices are as efficient as possible.
• The Company will actively recycle any packaging and waste materials encouraging employees and suppliers to do the same.
• The Company will take into consideration its suppliers’ environmental and sustainability practices when deciding who to include as a preferred supplier.
• The Company is committed to training employees to raise their awareness of environmental issues and enlist their support in improving the Company’s performance.
• The Company will take action to minimise the impact on sustainability of all office and transportation activities.
Corporate Social Responsibility
The Company’s Corporate Social Responsibility (CSR) policy refers to its responsibility toward the environment. The Company’s existence is not lonely. It is part of a bigger system of people, values, other organisations and nature.
This policy applies to the Company and its subsidiaries. It may also refer to suppliers and partners.
The Company wants to be a responsible business that meets the highest standards of ethics and professionalism.
The Company’s social responsibility falls under two categories: compliance and proactiveness. Compliance refers to the Company’s commitment to legality and willingness to observe community values. Proactiveness is every initiative to promote human rights, help communities and protect the natural environment.
The Company will:
• Respect the law
• Honour its internal policies
• Ensure that all its business operations are legitimate
• Keep every partnership and collaboration open and transparent
The Company will always conduct business in a legal way that upholds fair competition with integrity and respect to human rights and promote:
• Safety and fair dealing
• Respect toward the consumer
• Anti-bribery and anti-corruption practices
Protecting the environment
The Company recognises the need to protect the natural environment. Keeping the environment clean and unpolluted is a benefit to all. The Company will always follow best practices when disposing of waste and using chemical substances. Stewardship will also play an important role.
The Company will ensure that it:
• Doesn’t risk the health and safety of employees and the community.
• Avoids harming the lives of local and indigenous people.
• Supports diversity and inclusion.
The Company is dedicated to protecting human rights. It is a committed equal opportunity employer and will abide by all fair labour practices. The Company will ensure that its activities do not directly or indirectly violate human rights in any country (e.g. forced labour).
Donations and aid
The Company may preserve a budget to make monetary donations. These donations will aim to:
• Advance the arts, education and community events.
• Alleviate those in need.
The Company will encourage its employees to volunteer. They can volunteer through programs organised internally or externally. The Company may sponsor volunteering events from other organisations.
Preserving the environment
Apart from legal obligations, the Company will proactively protect the environment. Examples of relevant activities include:
• Conserving energy
• Organising reforestation excursions
• Using environmentally-friendly technologies
Supporting the community
The Company may initiate and support community investment and educational programmes. For example, it may begin partnerships with vendors for constructing public buildings. It can provide support to non-profit organisations or movements to promote cultural and economic development of global and local communities.
The Company will actively invest in research and development. The Company will be open to suggestions and listen carefully to ideas. The Company will try to continuously improve the way it operates.
The Company is committed to the United Nations Global Compact. The Company will readily act to promote its identity as a socially aware and responsible business. Management must communicate this policy on all levels. Managers are also responsible for resolving any CSR issues.
The Company will consistently provide services that meet or exceed the requirements and expectations of our clients whilst fulfilling our Company standards, values and ethos. The Company will strive to always improve on its quality through its checks and achievement of standards.
The Company will review its services and individual processes to ensure that these exceed the regulatory and client requirements.
Anti-Bribery and Corruption
The Company conducts its business in an honest and ethical manner. A zero-tolerance approach is taken to bribery and corruption and the Company is committed to acting professionally, fairly and with integrity in all business dealings and relationships wherever it operates and implementing and enforcing effective systems to counter bribery.
The Company expects its partners and business associates to adopt a similar policy and reserves the right not to do business with those that don’t.
The Company will uphold all laws relevant to countering bribery and corruption. The Company is bound by the laws of the UK, including the Bribery Act 2010, in respect of conduct both at home and, where applicable, abroad.
This policy sets out the Company’s responsibilities, and of those working for the Company, in observing and upholding the Company’s position on bribery and corruption. It also provides information and guidance to those working for the Company on how to recognise and deal with bribery and corruption issues.
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 the Company fails to prevent bribery it can face an unlimited fine and damage to its reputation. The Company therefore takes its legal responsibilities very seriously.
In this policy, third party means any individual or organisation an employee comes into contact with during the course of their work for the Company, 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.
Who must comply with this policy?
This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with the Company, or any of its subsidiaries or their employees, wherever located (collectively referred to as workers in this policy).
What are bribery and corruption?
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.
Corruption is the abuse of entrusted power or position for private gain.
An advantage includes money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or anything else of value.
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.
What is not acceptable?
It is not acceptable for employees (or someone on their behalf) to:
• 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;
• 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;
• accept a payment, gift or hospitality from a third party that an employee knows or suspects is offered with the expectation that it will obtain a business advantage for them or anyone else in return;
• accept hospitality from a third party that is unduly lavish or extravagant under the circumstances;
• threaten or retaliate against a work colleague who has refused to commit a bribery offence or who has raised concerns under this policy; or
• engage in any other activity that might lead to a breach of this policy.
Facilitation payments and kickbacks
The Company does not make, and will not accept, facilitation payments or “kickbacks” of any kind.
Facilitation payments, also known as ‘backhanders’ are typically small, unofficial payments made to secure or expedite a routine or necessary action. They are not common in the UK, but are common in some other jurisdictions.
Kickbacks are typically payments made in return for a business favour or advantage. All workers must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.
If employees are asked to make a payment on the Company’s behalf, they should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. Employees should always ask for a receipt which details the reason for the payment. If an employee has any suspicions, concerns or queries regarding a payment, they should raise these with their manager.
Gifts and hospitality
This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties for the purposes of establishing or maintaining good business relationships, improving or maintaining the Company’s image or reputation, or marketing or presenting products and/or services effectively.
No employee or any member of their immediate family should accept from a supplier, customer or other person doing business with the Company, payments of money under any circumstances, or special considerations, such as discounts or gifts of materials, equipment, services, facilities or anything else of value unless:
• They are, in each instance, of a very minor nature usually associated with accepted business practice.
• They do not improperly interfere with the employee’s independence of judgement or action in the performance of their employment.
In every circumstance where a gift is offered, the advice of the employee’s manager must be sought and a record maintained.
The Company does not make contributions to political parties.
The Company only makes charitable donations that are legal and ethical under local laws and practices.
The Company must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties.
Employees must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review.
Employees must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with the Company’s expenses policy and specifically record the reason for the expenditure.
All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off-book” to facilitate or conceal improper payments.
Employees must ensure that they read, understand and comply with this policy.
The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for the Company or under its control. All employees are required to avoid any activity that might lead to, or suggest, a breach of this policy.
Employees must notify their manager as soon as possible if they believe or suspect that a conflict with this policy has occurred, or may occur in the future. For example, if a client or potential client offers an employee something to gain a business advantage with the Company or indicates that a gift or payment is required to secure their business.
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. The Company reserves the right to terminate its contractual relationship with other individuals and/or third parties if they breach this policy.
How to raise a concern
Employees are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If an employee is unsure whether a particular act constitutes bribery or corruption, or if the employee has any other queries, these should be raised with the employee’s manager. Concerns should be reported by following the procedure set out in the Whistleblowing Policy in the Company handbook.
Employees who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. The Company aims 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 Company is committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If an employee believes that they have suffered any such treatment, they should inform their manager immediately. If the matter is not remedied the employee should raise it formally using the Grievance Procedure.
This policy does not form part of any employee’s contract of employment and it may be amended at any time.