Policies

Cogent Staffing commits to conducting 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 whilst implementing and enforcing effective systems to counter bribery.

Coverage

This Policy applies to all permanent and temporary employees of the Company. It also applies to any individual or corporate entity associated with the Company or who performs functions in relation to, or for and on behalf of, the Company. All employees and associated persons are expected to adhere to the principles set out in this Policy.

Responsibility

Responsibility to ensure the policy commitments are upheld, including training, updates and auditing lies with Cogent Staffing.

The responsibility for investigation of any suspicions, concerns or complaints raised in relation to bribery and corruption would be Cogent Staffing.

Policy commitments

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 whilst implementing and enforcing effective systems to counter bribery.

This Policy sets out the Company’s position on any form of bribery and corruption and provides guidelines aimed at:

• Ensuring compliance with anti-bribery laws, rules and regulations in any country within which the Company may carry out its business or in relation to which its business may be connected.
• Enabling employees and persons associated with the Company to understand the risks associated with bribery and to encourage them to be vigilant and effectively recognise, prevent and report any wrongdoing, whether by themselves or others.
• Providing suitable and secure reporting and communication channels and ensuring that any information that is reported is properly and effectively dealt with.
• Creating and maintaining a rigorous and effective framework for dealing with any suspected instances of bribery or corruption.
  Legal obligations

The legislation on which this Policy is based is UK legislation and it applies to the Company’s conduct in all the countries that it operates. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

Under the Bribery Act 2010, it is an offence in the UK.

You can be held personally liable for any such offence.

It is also an offence in the UK for an employee or an associated person to bribe another person in the course of doing business intending either to obtain or retain business or to obtain or retain an advantage in the conduct of business, for the Company. The Company can be liable for this offence where it has failed to prevent such bribery by associated persons. As well as an unlimited fine, it could suffer substantial reputational damage.

Policy statement

All employees and associated persons are required to:

• Comply with any anti-bribery and anti-corruption legislation that applies in any jurisdiction in any part of the world in which they might be expected to conduct business;
• Act honestly, responsibly and with integrity;
  Safeguard and uphold the Company’s core values by operating in an ethical, professional and lawful manner at all times.

Bribery of any kind is strictly prohibited. Under no circumstances should any provision be made, money set aside or accounts created for the purposes of facilitating the payment or receipt of a bribe.

The Company recognises that industry practices may vary from country to country or from culture to culture. What is considered unacceptable in one place may be normal or usual practice in another. Nevertheless, a strict adherence to the guidelines set out in this Policy is expected of all employees and associated persons at all times. If in doubt as to what might amount to bribery or what might constitute a breach of this Policy, refer the matter to your line manager or to the HR Department.

The giving of business gifts to clients, customers, contractors and suppliers is not prohibited provided the following requirements are met:

• The gift 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;
• It complies with local laws;
• It is given in the Company’s name, not in the giver’s personal name;
• It does not include cash or a cash equivalent (such as gift vouchers);
• It is of an appropriate and reasonable type and value and given at an appropriate time
• It is given openly, not secretly;
• It is approved in advance by a director of the receiving Company.

In summary, it is not acceptable 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, or to accept a payment, gift or hospitality from a third party that you know or suspect is offered or provided with the expectation that it will obtain a business advantage for them.

Any payment or gift to a public official or other person to secure or accelerate the prompt or proper performance of a routine government procedure or process, otherwise known as a “facilitation payment”, is also strictly prohibited. Facilitation payments are not commonly paid in the UK but they are common in some other jurisdictions.

Any recruitment fees charged to workers to secure employment, whether directly for the company or for one of its suppliers or sub-contractors, are also strictly prohibited. Payments to facilitate employment are not paid in Cogent Staffing and are not tolerated by the company anywhere in its supply chain. There is clear evidence of links between recruitment fees and slavery and forced labour.

Responsibilities and reporting procedure

All employees and associated persons should ensure compliance with this Policy and seek to prevent detect and report any suspected bribery or corruption.

Immediately disclose to the Company any knowledge or suspicion you may have that you, or any other employee or associated person, has plans to offer, promise or give a bribe or to request, agree to receive or accept a bribe in connection with the business of the Company. For the avoidance of doubt, this includes reporting your own wrongdoing. The duty to prevent, detect and report any incident of bribery and any potential risks rests not only with the directors of the Company but equally to all employees and associated persons.

The Company encourages all employees and associated persons to be vigilant and to report any unlawful conduct, suspicions or concerns promptly to the HR department. Confidentiality will be maintained during any subsequent investigation to the extent that this is practical and appropriate in the circumstances. The Company is committed to taking appropriate action against bribery and corruption. This could include either reporting the matter to an appropriate external government department, regulatory agency or the police and/or taking internal disciplinary action against relevant employees and/or terminating contracts with associated persons. The Company will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. It is also committed to ensuring nobody 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 corruption offence has taken place or may take place in the future.

Record keeping

All accounts, receipts, invoices and other documents and records relating to dealings with third parties must be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off the record” to facilitate or conceal improper payments.

Sanctions

A breach of any of the provisions of this Policy will constitute a disciplinary offence and will be dealt with in accordance with the Company’s disciplinary procedure. Depending on the gravity of the offence, it may be treated as gross misconduct and could render the employee liable to summary dismissal.

As far as associated persons are concerned, a breach of this Policy could lead to the suspension or termination of any relevant contract, sub-contract or other agreement.

Monitoring compliance

The Company’s compliance team has lead responsibility for ensuring compliance with this Policy and will review its contents on a regular basis. They will be responsible for monitoring its effectiveness and will provide regular reports in this regard to the directors of the Company who have overall responsibility for ensuring this Policy complies with the Company’s legal and ethical obligations.

Training

The Company will provide training to all employees to help them understand their duties and responsibilities under this Policy. The Company’s zero-tolerance approach to bribery will also be communicated to all business partners at the outset of the business relationship with them and as appropriate thereafter.

Our Corporate Social Responsibility (CSR) company policy outlines our efforts to be socially responsible, supporting the (local) communities in which we operate, and providing employees with opportunities for charitable work.

Our company’s social responsibility falls under two categories: compliance and proactiveness. Compliance refers to our company’s commitment to legality and willingness to observe community values. Proactiveness is every initiative to promote human rights, help communities and protect our natural environment.

Compliance

Legality

Our 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

Business ethics

We’ll always conduct business with integrity and respect to human rights. We’ll promote:

• Safety and fair dealing
• Respect
• Anti-bribery and anti-corruption practices

Protecting the environment

Our company recognises the need to protect the natural environment. Keeping our environment clean and unpolluted is a benefit to all. We’ll always follow best practices when disposing garbage and using chemical substances. Stewardship will also play an important role.

Protecting people

We’ll ensure that we:

• Don’t risk the health and safety of our employees and community.
• Support diversity and inclusion.

Human rights

Our company is dedicated to protecting human rights. We are a committed equal opportunity employer and will abide by all fair labour practices. We’ll ensure that our activities do not directly or indirectly violate human rights in any country (e.g. forced labour).

Proactiveness

Donations and aid

Our company may preserve a budget to make monetary donations. These donations will aim to:

Advance the arts, education and community events and alleviate those in need.

Volunteering

Our company will encourage its employees to volunteer. They can volunteer through programs organised internally or externally. Our company may sponsor volunteering events from other organisations.

Preserving the environment

Apart from legal obligations, our company will proactively protect the environment. Examples of relevant activities include:

• Recycling
• Conserving energy
• Organising reforestation excursions
• Using environmentally-friendly technologies
• Supporting the community
• Our company may initiate and support community investment and educational programs. 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.

Learning

We will actively invest in R&D. We will be open to suggestions and listen carefully to ideas. Our company will try to continuously improve the way it operates.

The Company maintains a commitment to monitor best practice and operate continuous improvement in our CSR policy.

All our team have the opportunity to involve themselves in their charitable passions.

Team members are regularly released from work in order to support their chosen charitable activities including bereavement counselling and school governor meetings.

Our CSR is ingrained throughout our organisation.

Purpose

The purpose of this Policy is to ensure that necessary records and documents of The Company are adequately protected and maintained and to ensure that records that are no longer needed by The Company or are of no value are discarded at the proper time. This Policy is also for the purpose of aiding employees of The Company in understanding their obligations in retaining electronic documents – including e-mail, Web files, text files, sound and video files, PDF documents, and all Microsoft Office or other formatted files.

Policy

This Policy represents The Company’s policy regarding the retention and disposal of records and the retention and disposal of electronic documents.

Administration

Attached as Appendix A is a Record Retention Schedule that is approved as the initial maintenance, retention and disposal schedule for physical records of The Company and the retention and disposal of electronic documents. We will make modifications to the Record Retention Schedule from time to time to ensure that it follows National legislation and includes the appropriate document and record categories for The Company; monitor legislation affecting record retention; annually review the record retention and disposal program; and monitor compliance with this Policy.

In addition, any retained information can only be used for the purpose for which it is stored. This is compliant with the Data Protection Act 1998 and the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679)

Suspension of Record Disposal In Event of Legal Proceedings or Claims

There are certain occasions when information needs to be preserved beyond any limits set out in the Policy. The Policy must be SUSPENDED relating to a specific customer or document and the information retained beyond the period specified in The Company’s Data Retention Schedule in the following circumstances:

Legal proceedings or a regulatory or similar investigation or obligation to produce information are known to be likely, threatened or actual.

A crime is suspected or detected.

Information is relevant to a company in liquidation or receivership, where a debt is due to The Company.

Information is considered by the owning unit to be of potential historical importance and this has been confirmed by the Administrator.

In the case of possible or actual legal proceedings, investigations or crimes occurring, the type of information that needs to be retained relates to any that will help or harm The Company or the other side’s case or liability or amount involved.

If there is any doubt over whether legal proceedings, an investigation or a crime could occur, or what information is relevant or material in these circumstances, the Administrator should be contacted and legal advice sought.

The Administrator shall take such steps as is necessary to promptly inform all staff of any suspension in the further disposal of documents.

Security of personal information

The Company will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.

The Company will store all personal information on our secure (password- and firewall-protected) servers.

The Client should acknowledge that the transmission of information over the internet is inherently insecure, and that The Company cannot guarantee the security of data sent over the internet.

The Client will be responsible for keeping their Username and Password used for accessing The Company’s website confidential; The Company will not ask for password other than when needed to log in to our website.

Amendments

The Company may update this policy from time to time by publishing a new version.

This page should be checked occasionally to ensure that the policy remains relevant.

Applicability

This Policy applies to all physical records generated during The Company’s operation, including both original documents and reproductions. It also applies to the electronic documents described above.

This Policy was approved by the Board of Directors of The Company on 5th January 2018.

APPENDIX A RECORD RETENTION SCHEDULE

The Record Retention Schedule is organised as follows:

SECTION TOPIC

1. Accounting and Finance
2. Contracts
3. Corporate Records
4. Correspondence and Internal Memoranda
5. Personal Information
6. Electronic Records
7. Grant Records
8. Insurance Records
9. Legal
10. Miscellaneous
11. Personnel Records
12. Tax Records

1. ACCOUNTING AND FINANCE

Record Type and then Retention Period

Annual Audit Reports and Financial Statements: Permanent

• Annual Audit Records, including work papers and other documents that relate to the audit:  7 years after completion of audit
• Annual Plans and Budgets: 7 years
• Bank Statements and Cancelled Cheques: 7 years
• Employee Expense Reports: 7 years
• Interim Financial Statements: 7 years

2. CONTRACTS

Record Type and then Retention Period

Contracts and Related Correspondence (including any proposal that resulted in the contract and all other supportive documentation):  7 years after expiration or termination

3. CORPORATE RECORDS

Record Type and then Retention Period

• Corporate Records (minutes, signed minutes of the Board and all committees, record of incorporation, articles of incorporation, annual corporate reports): Permanent
• Licenses and Permits: Permanent

4. CORRESPONDENCE AND INTERNAL MEMORANDA

General Principle: Most correspondence and internal memoranda should be retained for the same period as the document to which they pertain or support. For instance, a letter pertaining to a particular contract would be retained as long as the contract (7 years after expiration). It is recommended that records that support a particular project be kept with the project and take on the retention time of that particular project file.

Correspondence or memoranda that do not pertain to documents having a prescribed retention period should generally be discarded sooner. These may be divided into two general categories:

1. Those pertaining to routine matters and having no significant, lasting consequences should be discarded within five years. Some examples include:

• Routine letters and notes that require no acknowledgment or follow up, such as notes of appreciation, congratulations, letters of transmittal, and plans for meetings.
• Form letters that require no follow up.
• Letters of general inquiry and replies that complete a cycle of correspondence.
• Letters or complaints requesting specific action that have no further value after changes are made or action taken (such as name or address change).
• Other letters of inconsequential subject matter or that definitely close correspondence to which no further reference will be necessary.
• Chronological correspondence files.
• Please note that copies of interoffice correspondence and documents where a copy will be in the originating department file should be read and destroyed, unless that information provides reference to or direction to other documents and must be kept for project traceability.

        2. Those pertaining to non-routine matters or having significant lasting consequences should generally be retained permanently. 

5. Retaining personal information

1. This Section sets out the data retention policies and procedure of The Company, which are designed to help ensure compliance with legal obligations in relation to the retention and deletion of personal information
2. Personal information that is processed by The Company for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

Without prejudice to point 2 (above) The Company will usually delete personal data falling within the categories set out below at the date/time set out below:

Record Type and then Retention Period

• Information about a computer and about visits to and use of this website (including an IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths: 2 years
• Information provided when registering with our website (including email address): 2 years
• Information provided when completing a profile on our website (including a name, gender, date of birth, interests and hobbies, educational details): 2 years
• Information provided for subscribing to email notifications and/or newsletters (including a name and email address): Indefinitely or until the client chooses to ‘unsubscribe’
• Information provided when using the services on the website, or that is generated during the use of those services (including the timing, frequency and pattern of service use): Indefinitely
• Information relating to any subscriptions made (including name, address, telephone number, email address and sector sought): 2 years or until consent is withdrawn
• Information posted to our website for publication on the internet: 5 years after post
• Information contained in or relating to any communications sent through the website (including the communication content and meta data associated with the communication): 2 years following contact
• Any other personal information chosen to be sent:    2 years following contact
• •  

Notwithstanding the other provisions of this Section, The Company will retain documents (including electronic documents) containing personal data:

(a) to the extent that The Company is required to do so by law;
(b) if The Company believes that the documents may be relevant to any ongoing or prospective legal proceedings;
(c) and to establish, exercise or defend The Company’s legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
(d) if explicit consent is given by the data subject. Consent is requested at least every 2 years from candidates seeking contract roles and at least every 12 months for candidates seeking permanent employment.

Each day The Company will run a database backup copy of all electronic data contained on The Company data centre, except for the one financial package. All other databases are in the cloud, connected to a Tier 3 data centre. This backup will include all information relating to current users, as well as any information that remains due to any reason contained in this policy.

6. ELECTRONIC DOCUMENTS

1. Electronic Mail: Not all email needs to be retained, depending on the subject matter.

• All e-mail—from internal or external sources – is to be deleted after 12 months.
• Staff will strive to keep all but an insignificant minority of their e-mail related to business issues.
• The Company will archive e-mail for 90 days after the staff has deleted it, after which time the e-mail will be permanently deleted.
• Staff will take care not to send confidential/proprietary information held by The Company to outside sources
• Any e-mail staff deems vital to the performance of their job should be copied to the relevant client or candidate record in E Recruit Adapt. (The Company CRM system).

        2. Electronic Documents: including Office 365 and PDF files, retention also depends on the subject matter.

The Company does not automatically delete electronic files beyond the dates specified in this Policy. It is the responsibility of all staff to adhere to the guidelines specified in this policy.

In certain case’s a document will be maintained in both paper and electronic form. In such cases the official document will be the electronic document.

7. INSURANCE RECORDS

Record Type and then Retention Period

• Certificates Issued to The Company: Permanent
• Claims Files (including correspondence, medical records, etc.): Permanent
• Insurance Policies (including expired policies): Permanent
• •  

8. LEGAL FILES AND PAPERS

Record Type and then Retention Period

• Legal Memoranda and Opinions (including all subject matter files): 7 years after close of matter
• Litigation Files: 1 year after expiration of appeals or time for filing appeals
• Court Orders: Permanent
• •  

9. MISCELLANEOUS

Record Type and then Retention Period

• Material of Historical Value (including pictures, publications): Permanent
• Policy and Procedures Manuals – Original: Current version with revision history
• Annual Reports: Permanent
• •  

10. PERSONNEL RECORDS

Record Type and then Retention Period

• Employee Personnel Records (including individual attendance records, application forms, job or status change records, performance evaluations, termination papers, withholding information, garnishments, test results, training and qualification records): 6 years after separation
• Employment Contracts – Individual: 6 years after separation
• Employment Records Correspondence with Employment Agencies and Advertisements for Job Openings: 3 years from date of hiring decision
• •  

11. TAX RECORDS

General Principle: The Company must keep books of account or records as are sufficient to establish amount of gross income, deductions, credits, or other matters required to be shown in any such return.

These documents and records shall be kept for as long as the contents thereof may become material in the administration of state, and local income, franchise, and property tax laws.

Record Type and then Retention Period

• Tax-Exemption Documents and Related Correspondence: Permanent
• Tax Bills, Receipts, Statements: 7 years
• Tax Returns: Permanent
• Sales/Use Tax Records: 7 years
• Annual Information Returns: Permanent
• •  

Policy Statement

Cogent Staffing recognises that our commercial activities have the potential to impact on our suppliers and our locality. As a socially responsible small business our suppliers, local community and customers have a right to expect:

1. All workers involved in the delivery of services provided by Cogent Staffing are treated with full consideration to their basic human rights.
2. Cogent Staffing acts in an ethical manner above and beyond basic legal requirements.
3. Cogent Staffing is committed to implementing the principles of the Ethical Trading Initiative Base Code.

Code of Practice

This Code of Practice applies to:

1. Staff directly employed by Cogent Staffing on temporary or permanent contracts.
2. Staff employed or provided by contractors or employment agencies to work on Cogent Staffing premises or to undertake work for or on behalf of Cogent Staffing.

Employment Is Freely Chosen

1. No forced, bonded or involuntary labour shall be used.
2. Staff are not required to lodge deposits or identity papers with us.
3. Staff are free to leave Cogent Staffing after reasonable notice.

Working Conditions Are Safe and Hygienic

1. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.
2. Staff receive health & safety information.
3. Staff have access to toilet facilities and drinking water.
4. The workforce has a published Health & Safety Policy.

Child Labour Shall Not Be Used

1. There shall be no recruitment of child labour.
2. Children or persons under 16 are not employed at any time, day or night.
3. Young persons under 18 shall not be employed at night or in hazardous conditions. Living Wages Are Paid

Staff pay rates are equal to or above the national legal minimum standards

1. Staff are given information about their employment conditions in respect to wages
2. No deductions are made from wages as a disciplinary measure, and pay slips detailing lawful deductions are provided for each pay period.
3. Staff are given clearly understandable written terms and conditions of employment that details the employment relationship and the respective obligations of the employee and employer.

Working Hours Are Not Excessive

1. Staff are not forced to work in excess of 48 hours per week, a voluntary opt-out agreement is available for those wishing to work in excess of 48 hours per week.

No Discrimination Is Practised

1. There is no discrimination in pay, hiring, compensation, access to training, promotion, and termination of employment or retirement on the grounds of race, nationality, religion, age, disability, marital status, sexual orientation, union membership or political affiliation.
2. Opportunities for personal and career development are equally available to all employees. No Harsh Or Inhumane Treatment Is Allowed
3. Physical, verbal and sexual threats, abuse, harassment or intimidation is expressly prohibited and grounds for summary dismissal, if proved.

The Company embraces diversity and aims to promote the benefits of diversity in all of our business activities. We seek to develop a business culture that reflects that belief. We will expand the media in which we recruit to in order to ensure that we have a diverse employee and candidate base. We will also strive to ensure that our clients meet their own diversity targets.

The Company is committed to diversity and will promote diversity for all employees, workers and applicants. We will continuously review all aspects of recruitment to avoid unlawful discrimination. The Company will treat everyone equally and will not discriminate on the grounds of an individual’s “protected characteristic” under the Equality Act 2010 (the Act) which are age, disability, gender re-assignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation. We will not discriminate on the grounds of an individual’s membership or non-membership of a Trade Union. All staff have an obligation to respect and comply with this policy.

The Company is committed to providing training for its entire staff in equal opportunities and diversity.

The Company will avoid stipulating unnecessary requirements which will exclude a higher proportion of a particular group of people and will not prescribe discriminatory requirements for a role.

The Company will not discriminate unlawfully when deciding which candidate/temporary worker is submitted for a vacancy or assignment, or in any terms of employment or terms of engagement for temporary workers. The Company will ensure that each candidate is assessed in accordance with the candidate’s merits, qualifications and ability to perform the relevant duties for the role.

Discrimnation

Under the Act unlawful discrimination occurs in the following circumstances:

Direct discrimination
Direct discrimination occurs when an individual is treated less favourably because of a protected characteristic. Treating someone less favourably means treating them badly in comparison to others that do not have that protected characteristic.

It is unlawful for a recruitment consultancy to discriminate against a person on the grounds of a protected characteristic:

• in the terms on which the recruitment consultancy offers to provide any of its services;
• by refusing or deliberately omitting to provide any of its services;
• in the way it provides any of its services.

Direct discrimination can take place even if the individual does not have the protected characteristic but is treated less favourably because it is assumed he or she has the protected characteristic or is associated with someone that has the protected characteristic.

Direct discrimination would also occur if a recruitment consultancy accepted and acted upon instructions from an employer which states that certain persons are unacceptable due to a protected characteristic, unless an exception applies. The Act contains provisions that permit specifying a requirement that an individual must have a particular protected characteristic in order to undertake a job. These provisions are referred to as occupational requirements.

Where there is an occupational requirement then the client must show that applying the requirement is a proportionate means of achieving a legitimate aim, i.e. the employer must be able to objectively justify applying the requirement. An occupational requirement does not allow an employer to employ someone on less favourable terms or to subject a person to any other detriment.

Neither does an occupational requirement provide an excuse against harassment or victimisation of someone who does not have the occupational requirement.

Indirect discrimination
Indirect discrimination occurs when a provision, criterion or practice (PCP) is applied but this results in people who share a protected characteristic being placed at a disadvantage in comparison to those who do not have the protected characteristic. If the PCP can be objectively justified it will not amount to discrimination.

Indirect discrimination would also occur if a recruitment consultant accepted and acted upon an indirectly discriminatory instruction from an employer.

If the vacancy requires characteristics which amount to an occupational requirement or the instruction is discriminatory but there is an objective justification, The Company will not proceed with the vacancy unless the client provides written confirmation of the occupational requirement, exception or justification.

The Company will use best endeavours to comply with the Act and will not accept instructions from clients that will result in unlawful discrimination.

Harassment
Under the Act, harassment is defined as unwanted conduct that relates to a protected characteristic which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual. This includes unwanted conduct of a sexual nature.

The Company is committed to providing a work environment free from unlawful harassment.

The Company will ensure that the consultants do not harass any individual.

Examples of prohibited harassment are:

1. verbal or written conduct containing derogatory jokes or comments;
2. slurs or unwanted sexual advances;
3. visual conduct such as derogatory or sexually orientated posters;
4. photographs, cartoons, drawings or gestures which some may find offensive;
5. physical conduct such as assault, unwanted touching, or any interference because of sex, race or any other protected characteristic basis;
6. threats and demands to submit to sexual requests as a condition of continued employment or to avoid some other loss, and offers of employment benefits in return for sexual favours;
7. retaliation for having reported or threatened to report harassment.

If an individual believes that they have been unlawfully harassed, they should make an immediate report to The Company followed by a written complaint as soon as possible after the incident. The details of the complaint should include:

• Details of the incident
• Name(s) of the individual(s) involved
• Name(s) of any witness(es)

The Company will undertake a thorough investigation of the allegations. If it is concluded that harassment has occurred, remedial action will be taken.

All employees and workers will be expected to comply with The Company’s policy on harassment in the workplace. Any breach of such a policy will lead to the appropriate disciplinary action.
Any individual who The Company finds to be responsible for harassment will be subject to the disciplinary procedure and the sanction may include termination.

Victimisation
Under the Act victimisation occurs when an individual is treated unfavourably because he/she has done a ‘protected act’ which is bringing a claim for unlawful discrimination or raising a grievance about discrimination or giving evidence in respect of a complaint about discrimination.

The Company will ensure that the consultants do not victimise any individual.

Disable persons

Discrimination occurs when a person is treated unfavourably as a result of their disability.

In direct discrimination occurs where a provision, criterion or practice is applied by or on behalf of an employer, or any physical feature of the employer’s premises, places a disabled person at a substantial disadvantage in comparison with persons who are not disabled.

In recruitment and selection there may be a requirement to make reasonable adjustments. For example, it might be necessary to have different application procedures for partially sighted or blind applicants that enable them to use Braille. With testing and assessment methods and procedures, tests can only be justified if they are directly related to the skills and competencies required for the job. Even then, it might be appropriate to have different levels of acceptable test results, depending on the disability. For example, an applicant with a learning disability might need more time to complete a test, or not be expected to reach the same standard as other non-disabled applicants.

Reasonable adjustments in recruiting could include:

• modifying testing and assessment procedures;
• meeting the candidate at alternative premises which are more easily accessible;
• having flexibility in the timing of interviews;
• modifying application procedures and application forms;
• providing a reader or interpreter.

Wherever possible The Company will make reasonable adjustments to hallways, passages and doors in order to provide and improve means of access for disabled employees and workers. However, this may not always be feasible, due to circumstances creating such difficulties as to render such adjustments as being beyond what is reasonable in all the circumstances.

The Company will not discriminate against a disabled person:

• in the arrangements i.e. application form, interview or arrangements for selection for determining whom a job should be offered; or
• in the terms on which employment or engagement of temporary workers is offered; or
• by refusing to offer, or deliberately not offering the disabled person a job for reasons connected with their disability; or
• in the opportunities afforded to the person for receiving any benefit, or by refusing to afford, or deliberately not affording him or her any such opportunity; or
• by subjecting the individual to any other detriment (detriment will include refusal of training or transfer, demotion, reduction of wage, or harassment).

The Company will make career opportunities available to all people with disabilities and every practical effort will be made to provide for the needs of staff, candidates and clients.

Age discrimination

Under the Act, it is unlawful to directly or indirectly discriminate against or to harass or victimise a person because of age.  Age discrimination does not just provide protection for people who are older or younger. People of all ages are protected.

A reference to age is a reference to a person’s age group. People who share the protected characteristic of age are people who are in the same age group.

Age group can have various references:

• Under 21s
• People in their 40s
• Adults

The Company will not discriminate directly or indirectly, harass or victimise any person on the grounds of their age. We will encourage clients not to include any age criteria in job specifications and every attempt will be made to encourage clients to recruit on the basis of competence and skills and not age.

The Company is committed to recruiting and retaining employees whose skills, experience, and attitude are suitable for the requirements of the various positions regardless of age. No age requirements will be stated in any job advertisements on behalf of the company.

If The Company requests age as part of its recruitment process such information will not be used as selection, training or promotion criteria or in any detrimental way and is only for compilation of personal data, which the company holds on all employees and workers and as part of its equal opportunities monitoring process. In addition if under age 22 to adhere to Conduct of Employment Agencies and Employment Business Regulations 2003 and other relevant legislation applicable to children or young candidates.

Where a client requests age or date of birth, this will have to be under an occupational requirement or with an objective justification which should be confirmed in writing.

Part-time workers

This policy also covers the treatment of those employees and workers who work on a part-time basis, The Company recognises that it is an essential part of this policy that part time employees are treated on the same terms, with no detriment, as full time employees (albeit on a pro rata basis) in matters such as rates of pay, holiday entitlement, maternity leave, parental and domestic incident leave and access to our pension scheme. The Company also recognises that part time employees must be treated the same as full time employees in relation to training and redundancy situations.

Gender reassignment policy

The Company recognises that any employee or worker may wish to change their gender during the course of their employment with the Company.

The Company will support any employee or worker through the reassignment.

The Company will make every effort to try to protect an employee or worker who has undergone, is undergoing or intends to undergo gender reassignment, from discrimination or harassment within the workplace.

Where an employee is engaged in work where the gender change imposes genuine problems The Company will make every effort to reassign the employee or worker to an alternative role in the Company, if so desired by the employee.

Any employee or worker suffering discrimination on the grounds of gender reassignment should have recourse to the Company’s grievance procedure.

Recruitment of ex-offenders

Where The Company has registered with the Disclosure and Barring Service (DBS) and has the authority to apply for criminal records checks on individual because they are working with children or vulnerable adults or both, we will comply with the DBS’s Code of Practice which includes having a policy on the recruitment of ex-offenders.

Complaints and monitoring procedures

The Company has in place procedures for monitoring compliance with this policy and for dealing with complaints of discrimination. These will be made available immediately upon request. Any discrimination complaint will be investigated fully.

It is an important duty of The Company, in the conduct of its business operations, to ensure a safe and healthy working environment for all its employees. The organisation accepts the fact that this implies a corresponding duty of ensuring that necessary organisation, equipment, and instruction is provided to fulfil this obligation. An effective health and safety policy requires the full collaboration and co-operation of all employees; everybody is asked to read this policy and accept their own personal responsibility for health and safety at work. The objectives of this policy are fundamental to our business and the Company Directors are responsible for ensuring that the requirements of this policy are achieved.

The Company is committed to operating the business in accordance with the Health and Safety at Work Act 1974 and all applicable regulations made under the Act, as far as reasonably practicable.

• Risk assessments are to be completed by the brand manager/director to assess the office environment to ensure our workplaces are safe for our workers. Completed risk assessments are sent to the Group’s head office for central collation and record keeping.
• Provide and maintain facilities, equipment, and systems of work that are safe and without risks to health.
• Provide such information, instruction supervision as is necessary to ensure the health and safety at work of employees and visitors.
• Maintain any place of work under the Company’s control in a condition that is safe and without risks to health and to provide and maintain means of access to and egress from it that are safe and without such risks.
• Provide and maintain a working environment for employees that is safe and without risks to health and is adequate as regards facilities and arrangements for their welfare at work.
• Encourage staff to set exacting standards of health and safety by personal example and to instill an attitude of mind which accepts good health and safety practice as normal.
• Monitor the effectiveness of health and safety provisions within The
• Keep the Health & Safety Policy under regular review and to duly publish any

Management and staff have responsibility for implementing the specific arrangements made under this policy throughout the Company. All employees are expected to familiarise themselves with its provisions and fulfill their defined responsibilities, a copy of all related policies will be held in the HR department and will be made available to all employees.

This policy will be audited for its effectiveness on a regular basis.

Health & Safety Statement from the CEO

The Company regards the management of health and safety as an integral part of its business and as a management priority. It is our policy that all activities and work will be conducted in a safe manner, and we will ensure the health, safety and welfare of our employees and others who may be affected by our activities.

Proper management of health and safety issues is seen as an integral part of the efficient management of the Company’s activities, and critical to developing the professional culture of the Company and establishing and maintaining a solid reputation with all our customers.

The Company is committed to ensure the health, safety & wellbeing of all staff in line with government guidance and legislation.

Organisation

Ultimate responsibility for Health & Safety rests with The Company and its team of directors. The HR Director has specific responsibility for overseeing the implementation of Health & Safety policy and for advising and updating the Board of The Company and CEO on developments and performance.

All employees, contractors and sub-contractors are required to cooperate with the Company and their colleagues in implementing the policy and shall ensure that their own work is without risks to themselves and others as far as reasonably practicable. And to be proactive on health and safety issues as part of the continued development of the health and safety culture of the organisation

Directors

The Company’s directors have responsibility for implementation of the Health & Safety Principles and Policy in their areas of responsibility. They must show leadership by ensuring the organisation, management and conduct of operations is in line with The Company standards and ensuring this is supported by adequate resource allocation to implement this policy across the business.

All employees have the responsibility to co-operate with the directors and management to achieve a healthy and safe workplace and to take reasonable care of themselves and others.

Whenever an employee notices a health or safety problem which they are not able to put right, they must straightaway inform a member of the Health & Safety Committee.

Managers 

Managers have responsibility for the health, safety and wellbeing of those working within their area of operation and those who may be affected by the activities. They must ensure that adequate systems are in place to ensure delivery of policy and standards and meet local statutory requirements.

Those tasked with the supervision of staff, at whatever level, are required to give careful attention to the health and safety of those under their supervision and to ensure that appropriate precautions are taken.

To fulfil its function, the degree of supervision must have reasonable regard to the level of training, experience and expertise of employees being supervised.

The responsibilities of manager(s) within the company shall be:

• To read and understand the company’s safety policy and to ensure that its provisions are being effectively conducted.
• To bring the provisions of this policy, as far as they affect the personnel, to the attention of the employees under the control of managers/supervisors.
• To inspect machinery, equipment and structures regularly and to ensure that any defects discovered are remedied forthwith.
• To prevent access by the workforce or other persons to any defective equipment or structures until the faults have been rectified.
• To ensure that employees are adequately instructed in the safe operation of equipment and machinery.
• To ensure that any areas of the site to which the public or visitors may have access, are maintained to ensure their safety.
• To arrange for all necessary insurances, certificates , appropriate to the site’s

size and function.

• To arrange via the responsible person for the reporting of all incidents to the insurers where appropriate.
• To arrange the appropriate fire-certificates for each site, the proper maintenance of firefighting equipment, regular fire drills and adequate access to fire-fighting
• Ensure that adequate first-aid facilities are available and adequately
• To ensure that all accidents are reported in accordance with the provision of this
• Ensure that no unnecessary risks are taken by the employees in pursuance of their duties and to ensure a site disciplinary procedure is in place for
• Set a personal
• To give advice upon this policy when requested by either the directors or

Individuals

Individual employees have a duty to conduct their work in a safe manner to prevent injury and ill health either to themselves or to others who may be affected by their acts or omissions at work.

Individuals are required to comply with the Company’s Health and Safety Policy as it relates

to their work activities, and to any action to be taken in case of an emergency.

Amendments

Any amendments will be notified by revision of this document.

Policy Statement

This policy is approved by the Bluestones Investment Group Limited Board and is reviewed annually.

The policy applies to Bluestones Investment Group Limited and its subsidiary companies (except subsidiary companies that have published a separate modern slavery related policy on their website).

References to the Group relate to Bluestones Investment Group Limited and its subsidiary companies.  References to ‘we’, ‘us’ ‘our’ etc are intended to relate to each company within the Group to which this policy applies. 

This policy applies to all persons working with us or on our behalf in any capacity, including employees at all levels, directors, officers, consultants, agency workers, contractors and suppliers.

This policy does not form part of any employee’s contract of employment, and we may amend it at any time.

Responsibilities

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

The Managing Director of each company within the Group has overall responsibility for ensuring that their company and those working for or on behalf of their company complies with this policy. 

If you suspect a breach you must notify your manager, Board Sponsor or the Bluestones Group Head of Legal as soon as possible.  Concerns about any issue or suspicions of modern slavery in our business or supply chains should be raised at the earliest possible stage. Concerns may also be reported in accordance with our Whistleblowing Policy.

We 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. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should promptly inform the HR Department (HR@bluestonesgroup.co.uk). You may also raise concerns in accordance with our Grievance Policy.

Commitments

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.

We are committed to conducting our business dealings and relationships in a way that safeguards against modern slavery and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains. 

The systems and controls used in relevant business dealings and relationships include due diligence processes, due diligence questionnaires, compliance audits, the use of specific contractual provisions with third parties relating to compliance with this policy and the Modern Slavery Act 2015 and regular monitoring. The appropriate systems and controls will be determined in line with our commitment in 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 and on our behalf.  Individuals and companies must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.

We have a zero-tolerance approach to modern slavery in our organisation and supply chains. 

We expect the same high standards from all of our contractors, suppliers and other business partners and we expect that our suppliers will hold their own suppliers to the same high standards.

We are committed to providing awareness information and training around modern slavery to all individuals who work for us.

Breaches of this Policy

Alleged breaches of this policy will be taken seriously, and we commit to investigating such matters at an appropriate level of seniority in an effective and expeditious manner.

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

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

Introduction

The foundation of the Bluestones Group’s ‘No Child Labour Policy’ is based on the Company’s commitment to find practical, meaningful and culturally appropriate responses to support the elimination of such labour practices. It has been formulated in consideration with the acts. It, therefore, endorses the need for appropriate initiatives to progressively eliminate these abuses.

Policy

Bluestones Group and its subsidiary companies do not employ any person below the age of eighteen years at the workplace and prohibits the use of child labour and forced or compulsory labour in all of its businesses and operations. No employee is made to work against his/her will or work as bonded/forced labour, or subject to corporal punishment or coercion of any type related to work.

Implementation

This policy is publicly available throughout the Company and clearly communicated to all employees in a manner in which it can be understood through induction programmes, Intranets and policy manuals. The implementation of the policy is the responsibility of the Group’s human resources department, who do not permit minors to enter the workforce. There is zero tolerance policy towards its breach. Employment contracts and other records, documenting all relevant details of the employees, including age, are maintained by the Company and/or its subsidiaries and are open to verification by any authorised personnel or relevant statutory body.

Monitoring & Audit

Periodic assessment is conducted. The human resources department undertakes random checks of records annually.

Cogent Staffing commit to developing and adopting a proactive approach to tackling hidden labour exploitation.

Hidden labour exploitation is an abuse of job applicants or workers by third party individuals or gangs other than the employer or labour provider including rogue individuals working within these businesses but without the knowledge of management. It includes forced labour and human trafficking for labour exploitation; payment for work-finding services and work-related exploitation such as the forced use of accommodation. It is understood that it is often well hidden by the perpetrators with victims if they perceive of themselves as such, reluctant to come forward.

Scope

This ‘Preventing Hidden Labour Exploitation Policy’ applies to all Cogent Staffing sites.

Responsibility

Cogent Staffing and its sites will take responsibility for ensuring this policy is held in each site process. However HR will have overall responsibility for the policy and ensuring it is updated and upheld throughout the business. The company’s Managing Director and Branch Managers should take responsibility to ensure the policy is followed. Consultants must also implement it into their approach. Training will be developed and implemented by HR for all staff. This policy will be reviewed annually or more often as and when necessary.

Policy Commitments

We shall:

1. Designate appropriate managers to attend “Tackling Hidden Labour Exploitation” training and to have responsibility for developing and operating company procedures relevant to this issue.
2. Accept that job finding fees are a business cost, and will not allow these to be paid by job applicants. We will not use any individual or organisation to source and supply workers without confirming that workers are not being charged a work finding fee.
3. Ensure that all staff responsible for directly recruiting workers are aware of issues around third-party labour exploitation and signs to look for and have signed appropriate Compliance Principles.
4. Ensure that labour sourcing, recruitment and worker placement processes are under the control of trusted and competent staff members.
5. Adopt a proactive approach to reporting suspicions of hidden worker exploitation to the Gangmasters Labour Abuse Authority and police if Modern Slavery is suspected.
6. Provide information on tackling “Hidden Labour Exploitation” to our workforce through workplace posters, Intranets, induction, etc.
7. Encourage workers to report cases of hidden third party labour exploitation, provide the means to do so and investigate and act on reports appropriately.
8. Positively encourage and support employees and agency workers to report such exploitation which may be occurring within their communities and inform the best ways how to do report any case.
9. Require labour providers and other organisations in the labour supply chain to adopt policies and procedures consistent with the above.

Policy Implementation

• Cogent Staffing is working towards ensuring all staff receive comprehensive Stronger Together training as part of the Employee Induction/Onboarding process within their first month of employment.
• Training records will be held on the Employee’s Sage HR account, within ‘Onboarding Documents’.
• Once Stronger Together training has been rolled out across the business, there will be two key representatives in the company at all times who are qualified ‘Stronger Together Train the Trainers’ and have attended ALP training within the last two years.

Use of this website is governed by this website policy and you agree to be bound by them each time you access the website.

The material on this website is provided purely for your information and you should seek further guidance and make independent inquiries before relying on it. The Company may make alterations to the website at any time. You will be deemed to accept such alterations when you next use the website following any such alteration.

Any employment placement will be subject to The Company’s current standard employment terms and conditions.

The information on this website is updated from time to time. Whilst The Company has made every effort to ensure the accuracy and completeness of information on this website, The Company makes no representations or warranties whatsoever, express or implied, as to the quality, accuracy or completeness of such information.

The Company may without notice modify, suspend or discontinue the website or any part of it at any time without any liability to you or any third party.

To the full extent permitted by law, The Company accepts no liability in contract, tort or otherwise (including liability for negligence), for loss or damage of any kind including without limitation, direct or indirect loss or damage, loss of business, revenue or profits, corruption or destruction of data, or any other consequential loss or damage arising out of your use or inability to use the website (or other site linked to the website) or in connection with any computer virus or system failure and The Company excludes any such liability even if The Company is expressly advised of the possibility of such damage or loss.

You will indemnify The Company against all costs, losses, expenses or other liabilities incurred by The Company arising from the use of the website by you.

Lawful Use

You will use the website for lawful purposes only.

Links

You should note that The Company provides links to websites maintained by others. The Company accepts no responsibility or liability for the accuracy or legality of any content contained in such websites. The fact that you may use one of these links to access other websites is not an endorsement by The Company of any content contained in those websites. Neither you nor any third party may link another site to The Company’s website without The Company’s prior written consent.

Copyright

Unless otherwise stated, the copyright and similar rights in this website and in all the material contained on this website belong to The Company. You are only permitted to copy or print extracts of the material for your own personal use. You may not use any of this material for commercial or public purposes.

Without The Company’s written permission, you may not (whether directly or indirectly including through the use of any programme) create a database in an electronic or other form by downloading and storing all or any part of the pages from this website. Without the permission of The Company, no part of this website may be reproduced, transmitted to or stored on any other website, disseminated in any electronic or non-electronic form, or included in any public or private electronic retrieval system.

Changes to these Terms and Conditions

The Company may add to or change this policy from time to time. You are deemed to have accepted changed or additional policy statements when you access the website following any such change or addition.

The Accuracy of your Registration Information

You are responsible for ensuring that any information you provide to The Company, including your CV, is accurate, complete and your own. If The Company has any reason to believe that any information you have supplied is false, inaccurate or not your own, we may remove your ability to log-in to the site and may prohibit you from using this site. The Company is entitled, forthwith and without notice, to remove from the website any such information found to be false, inaccurate, incomplete or not your own.

Your Username and Password

You are responsible for all use of this site made using your username and password, whether or not such use is made by you or by someone else using your username and password. You are responsible for protecting and securing your username and password from unauthorised use. Your username and password must not be disclosed to another person. If you believe there has been a breach of security of your username or password, such as theft or your username or password becoming known to someone else or unauthorised use, you must notify The Company.

Information that you post on the website

The Company reserves the right, at your cost, at any time to remove any material from the site which it believes to be salacious, defamatory or offensive or which The Company believes may be in breach of a third party’s rights, such as a third party’s intellectual property or confidentiality rights. You agree to indemnify The Company on a full and continuing basis against any loss or damage suffered or costs (including legal costs) incurred by The Company in defending any action brought against The Company as a result of any information you have posted on the website.

Governing Law and Applicable Legislation

This website policy is governed by English law and you agree that the English courts shall have exclusive jurisdiction to determine any matter or dispute arising out of or in connection with use of this website and this policy.

It is not intended that a third party should have the right to enforce any provision of this policy pursuant to the Contracts (Rights of Third Parties) Act 1999 and furthermore The Company may, and without the consent of a third party to whom the right of enforcement of any of the terms has been expressly provided vary and amend this policy.

Use of this website may not be allowed in countries outside the United Kingdom where such use may be contrary to local law or regulation. If you access information on this website it is your sole responsibility to ensure compliance with any applicable laws or regulations in any other country. Any use of this website outside the United Kingdom is your responsibility and we accept no liability whatsoever in connection with such use.

The Company has the right at any time to terminate or suspend access to, or use of, the website where The Company reasonably believes you have infringed this policy.

We are committed to conducting our business with honesty and integrity, and we expect all workers to maintain high standards. However, all organisations face the risk of things going wrong from time to time, or of unknowingly harbouring illegal or unethical conduct. A culture of openness and accountability is essential in order to prevent such situations from occurring or to address them when they do occur.

The aims of this policy are: (a) To encourage workers to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected. (b) To provide workers with guidance as to how to raise those concerns. (c) To reassure workers that they should be able to raise genuine concerns in good faith without fear of reprisals, even if they turn out to be mistaken.

This policy takes account of the Whistleblowing Arrangements Code of Practice issued by the British Standards Institute and Public Concern at Work.

What is whistleblowing?

Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work. This may include: (a) criminal activity; (b) miscarriages of justice; (c) danger to health and safety; (d) damage to the environment; (e) failure to comply with any legal or professional obligation or regulatory requirements; (f) financial fraud or mismanagement; (g) negligence; (h) conduct likely to damage our reputation; (i) unauthorised disclosure of confidential information; (j) the deliberate concealment of any of the above matters.

A whistleblower is a person who raises a genuine concern in good faith relating to any of the above. If you have any genuine concerns related to suspected wrongdoing or danger affecting any of our activities (a whistleblowing concern) you should report it under this policy.

This policy should not be used for complaints relating to your own personal circumstances, such as the way you have been treated at work. In those cases, you should use the Grievance Procedure or Anti-harassment and Bullying Policy as appropriate.

If you are uncertain whether something is within the scope of this policy you should seek advice from the Whistleblowing Officers whose contact details are at the end of this policy.

Raising a whistleblowing concern

We hope that in many cases you will be able to raise any concerns with your manager. You may tell them in person or put the matter in writing if you prefer. They may be able to agree on a way of resolving your concern quickly and effectively. In some cases, they may refer the matter to a Whistleblowing Officer.
We will arrange a meeting with you as soon as possible to discuss your concern. Under this Procedure, you have the statutory right to be accompanied at formal meetings, but not informal meetings or investigatory meetings.

We will take down a written summary of your concern and provide you with a copy after the meeting. We will also aim to give you an indication of how we propose to deal with the matter.

Confidentiality

We hope that workers will feel able to voice whistleblowing concerns openly under this policy. However, if you want to raise your concern confidentially, we will make every effort to keep your identity secret. If it is necessary for anyone investigating your concern to know your identity, we will discuss this with you.

We do not encourage workers to make disclosures anonymously. A proper investigation may be more difficult or impossible if we cannot obtain further information from you. It is also more difficult to establish whether any allegations are credible and have been made in good faith. Whistle-blowers who are concerned about possible reprisals if their identity is revealed should come forward to their manager or a Whistleblowing Officer and appropriate measures can then be taken to preserve confidentiality.

External disclosures

The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases, you should not find it necessary to alert anyone externally.

The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. It will very rarely if ever be appropriate to alert the media. We strongly encourage you to seek advice before reporting a concern to anyone external. The independent whistleblowing charity, Public Concern at Work, operates a confidential helpline. They also have a list of prescribed regulators for reporting certain types of concern. Their contact details are at the end of this policy.

Whistleblowing concerns usually relate to the conduct of our workers, but they may sometimes relate to the actions of a third party, such as a customer, supplier or service provider. The law allows you to raise a concern in good faith with a third party, where you reasonably believe it relates mainly to their actions or something that is legally their responsibility. However, we encourage you to report such concerns internally first. You should contact your manager.

Investigation and outcome

Once you have raised a concern, we will carry out an initial assessment to determine the scope of any investigation. We will inform you of the outcome of our assessment. You may be required to attend additional meetings in order to provide further information.

In some cases, we may appoint an investigator or team of investigators including staff with relevant experience of investigations or specialist knowledge of the subject matter. The investigator(s) may make recommendations for change to enable us to minimise the risk of future wrongdoing.

We will aim to keep you informed of the progress of the investigation and its likely timescale. However, sometimes the need for confidentiality may prevent us from giving you specific details of the investigation or any disciplinary action taken as a result. You should treat any information about the investigation as confidential.

If we conclude that a whistleblower has made false allegations maliciously, in bad faith or with a view to personal gain, the whistleblower will be subject to disciplinary action.

While we cannot always guarantee the outcome you are seeking, we will try to deal with your concern fairly and in an appropriate way. By using this policy you can help us to achieve this.

Protection and support for whistleblowers

It is understandable that whistleblowers are sometimes worried about possible repercussions. We aim to encourage openness and will support workers who raise genuine concerns in good faith under this policy, even if they turn out to be mistaken.

Workers must not suffer any detrimental treatment as a result of raising a concern in good faith. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform HR immediately. If the matter is not remedied you should raise it formally using our Grievance Procedure.

Workers must not threaten or retaliate against whistleblowers in any way. Anyone involved in such conduct will be subject to disciplinary action.

Responsibility for the success of this policy

The HR Manager has day-to-day operational responsibility for this policy and must ensure that all managers and other staff who may deal with concerns or investigations under this policy receive regular and appropriate training.

All workers are responsible for the success of this policy and should ensure that they use it to disclose any suspected danger or wrongdoing.

Workers 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 HR Manager.

Whistleblowing Officers:

Tasmin Withey (HR Manager) Email: Tasmin.withey@bluestonesgroup.co.uk
Justine Dawson (Head of Legal) Email: Justine.dawson@bluestonesgroup.co.uk

Public Concern at Work confidential helpline – 020 7404 6609