Anti-Slavery and Human Trafficking Policy

Modern slavery is a crime and a violation of fundamental human rights. All types of modern slavery have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We are committed to acting ethically and with integrity in all our business dealings and relationships and to ensure modern slavery is not taking place anywhere in our own business.

We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our business relationships, consistent with our disclosure obligations under the Modern Slavery Act 2015.

Our subcontractors, suppliers and other business partners are made aware that we expect them to adhere to these high standards.

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, 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 we may amend it at any time.

Responsibility for the policy

The management of the company has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all of our people comply with it.

Compliance with the policy

You must ensure that you read, understand and comply with this policy.

The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Employees are required to notify the Company as soon as possible if it is believed or suspected that a conflict with this policy has occurred or may occur in the future.

We encourage openness, will support anyone who raises genuine concerns in good faith, even if they turn out to be mistaken and will ensure no one suffers any detrimental treatment as a result of reporting in good faith their knowledge, or suspicion, that modern slavery is taking place in any part of our business or in any of our supply chains.

Communication and awareness of this policy

Our zero-tolerance approach to modern slavery is communicated, where appropriate, to all significant suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

Breaches of this policy

Any employee who breaches this policy could face disciplinary action, which could result in dismissal for misconduct or gross misconduct.

We reserve our right to terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.

Anti-corruption and bribery policy

A bribe is an inducement or reward offered, promised or provided in order to improperly gain any commercial, contractual, regulatory or personal advantage, which may constitute an offence under the Bribery Act 2010, namely:

• giving or offering a bribe;

• receiving or requesting a bribe; or

• bribing a foreign public official.

The Company may also be liable under the Act if it fails to prevent bribery by an associated person for the Company’s benefit.

This policy does not prohibit normal and appropriate gifts and hospitality (given and received) to or from third parties in the normal course of business. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The financial limit will be £50 per event unless approved by a Director.

We conduct business in an honest and ethical manner and will uphold all laws relevant to countering bribery and corruption.

Responsibility for the policy

The management of the company has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all our people comply with it.

Compliance with the policy

You must ensure that you 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 us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.

Employees are required to notify the Company as soon as possible if it is believed or suspected that a conflict with this policy has occurred, or may occur in the future, or if they are offered a bribe, are asked to make one, suspect that this may happen in the future, or believe that they are a victim of another form of unlawful activity.

We encourage openness, will support anyone who raises genuine concerns in good faith, even if they turn out to be mistaken and will ensure no one suffers any detrimental treatment as a result of reporting in good faith their knowledge, or suspicion, that bribery is taking place in any part of our business or in any of our supply chains.

Record keeping

We keep appropriate financial records and have appropriate internal controls in place which evidence the business reason for gifts, hospitality and payments made and received.

Communication and awareness of this policy

The Company takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships, wherever it operates, and implementing and enforcing effective systems to counter bribery.

Our zero-tolerance approach to bribery and corruption will, where appropriate, be communicated to clients, suppliers, contractors and business partners.

Breaches of this policy

Any employee who breaches this policy may face disciplinary action, which could result in dismissal for gross misconduct.

We reserve our right to terminate our contractual relationship with other individuals and organisations working on our behalf if they breach this policy.

Equality and diversity policy

It is unlawful to discriminate directly or indirectly in recruitment or employment because of age, disability, sex, gender reassignment, pregnancy, maternity, race (which includes colour, nationality and ethnic or national origins), sexual orientation, religion or belief, or because someone is married or in a civil partnership. These are known as "protected characteristics”. (Equality Act 2010)

Discrimination after employment may also be unlawful, e.g. refusing to give a reference for a reason related to one of the protected characteristics.

Employees should not discriminate against or harass a member of the public in the provision of services. It is unlawful to fail to make reasonable adjustments to overcome barriers to using services caused by disability. The duty to make reasonable adjustments includes the removal, adaptation or alteration of physical features, if the physical features make it impossible or unreasonably difficult for disabled people to make use of services. In addition, service providers have an obligation to think ahead and address any barriers that may impede disabled people from accessing a service.

We are committed to promoting equality and diversity, providing equal opportunities in employment and to avoiding unlawful discrimination in employment and against customers.

The Company will avoid unlawful discrimination in all aspects of employment including recruitment, promotion, opportunities for training, pay and benefits, discipline and selection for redundancy.

Responsibility for the policy

The management of the company has overall responsibility for ensuring this policy complies with our legal obligations, and that all our people comply with it.

Every employee is required to assist the Company to meet its commitment to provide equal opportunities in employment and avoid unlawful discrimination.

Employees can be held personally liable as well as, or instead of, the Company for any act of unlawful discrimination.

Compliance with the policy

You must ensure that you read, understand and comply with this policy.

Person and job specifications will be limited to those requirements that are necessary for the effective performance of the job. Candidates for employment or promotion will be assessed objectively against the requirements for the job, taking account of any reasonable adjustments that may be required for candidates with a disability.

The Company will consider any possible indirectly discriminatory effect of its standard working practices, including the number of hours to be worked, the times at which these are to be worked and the place at which work is to be done, when considering requests for variations to these standard working practices and will refuse such requests only if the Company considers it has good reasons, unrelated to any protected characteristic, for doing so. The Company will comply with its obligations in relation to statutory requests for contract variations. The Company will also make reasonable adjustments to its standard working practices to overcome barriers caused by disability.

The Company will monitor the ethnic, gender and age composition of the existing workforce and of applicants for jobs (including promotion), and the number of people with disabilities within these groups and will consider and take any appropriate action to address any problems that may be identified as a result of the monitoring process.

The Company will not discriminate unlawfully against customers using or seeking to use facilities or services provided by the Company.

Grievances

If you consider that you may have been unlawfully discriminated against, you may use the Company’s grievance procedure to make a complaint.

The Company will take any complaint seriously and will seek to resolve any grievance that it upholds. You will not be penalised for raising a grievance, even if your grievance is not upheld, unless your complaint is both untrue and made in bad faith.

Use of the Company’s grievance procedure does not affect your right to make a complaint to an employment tribunal. Complaints to an employment tribunal must normally be made within three months beginning with the act of discrimination complained of.

Communication and awareness of this policy

The Company will communicate this policy to all employees. In addition, the Company will provide training in equality and diversity to managers and others likely to be involved in recruitment or other decision making where equal opportunities issues are likely to arise.

Breaches of this policy

Acts of discrimination, harassment, bullying or victimisation against employees or customers are disciplinary offences which could lead to dismissal without notice for gross misconduct.

Health & Safety Policy

It is a legal requirement to comply with the Health and Safety at Work etc Act 1974, (and regulations made under it).

We are committed to

• maintaining a safe and healthy work place and environment for all employees, and

• ensuring the health, safety and welfare of all employees, including the prevention of injury and ill health

both in the course of their duties and in any Company activities.

We also have a duty to ensure the health and safety of any person who may be affected by our activities; this will extend to contractors, customers, visitors and members of the Public.

Our policy is to

• Provide adequate control of the health and safety risks arising from our work activities

• Consult with our employees on matters affecting their health and safety

• Provide and maintain safe plant and equipment

• Ensure safe handling and use of substances

• Provide information instruction and supervision for employees

• Ensure all employees are competent to do their tasks, and to give them adequate training

• Prevent accidents and cases of work-related ill health

• Maintain safe and healthy working conditions

• Review and revise this policy as necessary at regular intervals.

Compliance with the policy

You must ensure that you read, understand and comply with this policy.

It is the duty of all employees when at work to:

• Comply with the Company's Health and Safety Policy and Procedures.

• Take reasonable care to ensure the health and safety of yourselves and other persons who may be affected by your acts or omissions at work.

• Co-operate with your Employer on safety matters.

• Identify potentially unsafe acts or conditions and notify management.

• Work in a safe manner in accordance with safety instructions.

• Make others aware of situations you believe to be unsafe and that you think others may not be aware of and report hazards to your line manager.

• Use the proper equipment for the job in the way that it was intended to be used and, where necessary, use the protective equipment provided.

• Never perform a task that you believe is unsafe.

• Never intentionally or recklessly interfere with or misuse anything provided in the interests of health, safety or welfare.

• Communicate and coordinate all aspects of health and safety with other employers (or their staff) who share or work in our premises, to ensure that they are aware of any risks to themselves and other people posed by our activities and that we are aware of any risks to our staff from their activities.

• Ensure compliance with current fire legislation and provide the necessary resources to minimise the risk of a fire occurring and effective measures to respond to a fire if it were to occur.

• Participate in any prescribed occupational health surveillance programme.

Communication and awareness of this policy

This Policy shall be brought to the attention of all employees and made available to all interested parties.

Working at different locations

It is the duty of all employees when working at third party offices to ensure they have received, read and understand the Health & Safety policy of the third-party offices.

Breaches of this policy

If an employee fails to reasonably carry out their Health & Safety roles and responsibilities, the Company will take this very seriously and, following a thorough investigation into the circumstances, any breach could result in disciplinary action being taken. The disciplinary sanctions are up to & including termination.

Environmental & Sustainability Policy

Our key impacts on the environment arise from waste generation, energy use including travel, and resource consumption. We are seeking to minimize these impacts through continual improvement in our environmental performance.

We are committed to minimizing our impact on the environment – to protect the planet; ensure resources are available for future generations; and create a better quality of life for all living beings. We recognize that the way in which we operate has an impact on the environment and are committed to integrating sustainability best practice into our decision-making and business activities.

In seeking to improve our environmental performance, we will focus on the following areas in particular:

Waste management

We will manage waste generated by our business as efficiently as possible, and will seek to reduce, reuse and recycle waste wherever possible.

Reduction of greenhouse gases

We will promote the use of travel options or alternatives to travel that minimise our impact on the environment.

Stakeholder engagement

We will encourage and promote environmental awareness amongst our staff through information, instruction and training.

Customers

We will share our sustainability policy and objectives with our clients and, where appropriate, encourage our clients to adopt environmental and sustainability strategies.

Communication

We will communicate our sustainability policy internally and externally.

Law and regulation

We will comply with all laws and regulation relating to the environment.

Responsibility

The Directors are responsible for deciding the Company’s sustainability policy, objectives and targets and for ensuring that the necessary organisation and resources exist to facilitate their achievement. It is also the responsibility of all employees to implement this policy in practice and live up to its commitments.

Review

We will review periodically, and, if necessary, revise, our environmental policy to ensure that it continues to meet the highest best practice standards.