U.K. Associate Handbook
Hedgehog
Execution
Vision, Mission, Core Values
Policy Deployment
Strategy
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The Justrite Way: Hedgehog Concept
The Justrite Way: Core Values
Passion: Exceptional Customer Experience
BHAG: $200M EBITDA
Best In Industry: Leveraging the Channel (Distribution, Direct, Government)
Economic Driver: Profit per Customer
ABCs
• Honest • Humble • Hungry
ABCs
• Mutual Respect
• Always do the right thing: Company, Customer & Community
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2
Personal Growth
Relationship Growth
Results Matter
Process Discipline
ABCs
ABCs
• Practical Risk Taker • Acknowledges Failure • Doesn’t Repeat
Mistakes
• Celebrates Success
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3
• Openly Challenge • Data Driven • Eliminate Waste
Attributes, Behaviors, Competencies (ABCs)
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The Justrite Way: Strategic Focus
Shareholders
The Just rite Way
Associates
Core Growth
Technical Leadership FM Global, EN, NFPA, OSHA
Selective Acquisitions/ Partnerships
Pro-active Service Customer Intimacy
Margin Expansion/ Free Cash Flow
Product Velocity Voice-of-Customer
New Products
Operational Excellence S, Q, D, C, P
Customers
Supp liers
Representatives
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The Justrite Way: Promise, Mission, & Vision
Our Promise
Keeping people, property and the planet safe is our first and greatest responsibility.
Our Vision
To be the most trusted EHS partner to distributors and customers worldwide.
Our Mission
Our mission is to protect people, property and the planet by:
compliance environment
industrial safety portfolio
• Pioneering the evolving EHS • Continuously improving our • Identifying customers’ • Guiding customers in creating
workplace vulnerabilities
safe work environments
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The Justrite Way: Continuous Improvement
Customer Focus
Safety, Quality, Delivery, Cost
Just In Time
Involvement
Built-in-Quality
• Takt Time
• Mutual Respect
• One-Piece Flow
• Go to Gemba
• Quick Changeover
• Empowerment
• Pull not Push
• Cross Training
• Kanban
• VSM
• Kaizen for Breakthrough
• Supplier Involvement
Stability
• Human & Machine Balance
• Repeatable processes
• Five Why’s
• Poks-Yoke
• Problem Solving
Visual Control | 6S | Standard Work | OEE
Leadership
Urgency | Accountability | Results
Plan, Do, Check, Act
Plan
Act
Do
Check
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TABLE OF CONTENTS
3.2.2 Public/Nominated Holidays … … … … … … … … … . . 28
- Joining Our Organization… … … … … … … … … … … … . . 15
3.3 Sickness Absence … … … … … … … … … … … … … … 28
1.1 Right to Work in the UK … … … … … … … … … … … … . 15
1.2 Probationary Period … … … … … … … … … … … … … . 15
1.3 Responsibilities and Duties … … … … … … … … … … … . 15
1.4 Hours of Work … … … … … … … … … … … … … … … 16
1.5 Pay … … … … … … … … … … … … … … … … … … . 17
1.6 Training and Development … … … … … … … … … … … . 17
3.3.1 Notification … … … … … … … … … … … … … … . 29
3.3.2 Payment During Sickness Absence … … … … … … … . . 30
3.3.3 Statutory Sick Pay … … … … … … … … … … … … . 30
3.3.4 Discretionary Company Sick Pay … … … … … … … … . 30
3.3.5 Persistent Short-term Absence … … … … … … … … . . 31
3.3.6 Long-term Absence … … … … … … … … … … … … 33
3.3.7 Records … … … … … … … … … … … … … … … . . 34
- What We Expect of You … … … … … … … … … … … … … 18
3.4 Time-off for Other Reasons … … … … … … … … … … … 34
2.1 Timekeeping … … … … … … … … … … … … … … … . . 18
3.4.1 Medical, Dental and Optical Appointments … … … … … . 34
2.2 Standards of Dress/Uniform … … … … … … … … … … … 18
3.4.2 Jury Service … … … … … … … … … … … … … … . 34
2.3 Personal Property … … … … … … … … … … … … … … 19
3.4.3 Public Duties … … … … … … … … … … … … … … 35
2.4 Telephones & Other Electronic Devices … … … … … … … . . 19
2.5 Company Property … … … … … … … … … … … … … . . 20
2.6 Smoking … … … … … … … … … … … … … … … … . . 20
2.7 Alcohol/Drugs … … … … … … … … … … … … … … … 21
2.8 Secondary Employment … … … … … … … … … … … … 22
2.9 Confidential Company Information … … … … … … … … … 22
2.10 Conflict of Interest … … … … … … … … … … … … … . 23
2.11 Company Vehicles … … … … … … … … … … … … … . . 23
- Important Policies and Procedures … … … … … … … … . . 26
3.4.4 Bereavement/Compassionate Leave … … … … … … … . 35
3.4.5 Time-off to Care for Dependants … … … … … … … … 35
3.5 Flexible Working … … … … … … … … … … … … … … . 36
3.6 Family Leave … … … … … … … … … … … … … … … . 37
3.6.1 Maternity Leave … … … … … … … … … … … … … 37
3.6.2 Ante-natal Care … … … … … … … … … … … … … 38
3.6.3 Statutory Maternity Pay … … … … … … … … … … . . 39
3.6.4 Paternity Leave and Pay … … … … … … … … … … . . 39
3.6.5 Shared Parental Leave … … … … … … … … … … … . 40
3.6.6 Adoption Leave … … … … … … … … … … … … … 40
3.1 Health and Safety … … … … … … … … … … … … … … 26
3.6.7 Parental Leave … … … … … … … … … … … … … . . 41
3.2 Holidays … … … … … … … … … … … … … … … … . . 27
3.7 Equal Opportunities … … … … … … … … … … … … … . 41
3.2.1 Company Shutdown Periods … … … … … … … … … . . 28
3.8 Bullying and Harassment … … … … … … … … … … … . . 42
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3.9 Bribery … … … … … … … … … … … … … … … … … 44
3.10 Search (Contractual) … … … … … … … … … … … … … 45
3.11 Use of IT, Internet, Email and Social Media … … … … … … . . 45
3.12 Data Protection Policy … … … … … … … … … … … … . 50
3.13 Disciplinary Procedure … … … … … … … … … … … … . 59
3.14 Performance Management Procedure … … … … … … … … 64
3.15 Grievance Procedure … … … … … … … … … … … … … 64
3.16 Public Interest Disclosures (“Whistle-Blowing”) … … … … … . 68
Keeping people, property and the planet safe is our first and greatest responsibility.
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1. Joining Our Organization
1.1 Right to Work in the UK
In line with current immigration legislation, the Company has a legal
obligation to check that every employee has the right to work in
the UK. You will therefore be required to show us your passport or
other acceptable original documentation for this purpose, prior to the
commencement of your employment. We will need to take copies for our
records, as required by the legislation.
Further checks (annually) will be required if you only have a limited right
to work in the UK.
1.2 Probationary Period
We have employed you because we believe that you will be a valuable
member of our team. However, you will initially be employed on a
probationary period, as detailed in your Contract of Employment. During
this period, we will give you as much support as we can to help you to
adapt to your new role and be successful. However, if your performance
doesn’t meet our standards, or if you do not appear to be suited to the
role for any reason, we will regrettably have to consider ending your
employment.
We hope that you will progress within our organisation, and we
encourage career development. Any subsequent internal promotions or
transfers may also be offered subject to you satisfactorily completing a
probationary period in the new position.
1.3 Responsibilities and Duties
When you join us, we will give you a job description outlining your specific
responsibilities and duties. We expect all our employees to work together
and to be flexible in undertaking other duties outside their roles as may
be required.
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1.4 Hours of Work
1.5 Pay
Your normal hours of work are stated in your Contract of Employment.
Your rate of pay and date/frequency of payment are detailed in your
We may, at times, need to change your hours, however, to meet the
Contract of Employment, and will be subject to deductions for tax and
organisation’s requirements, either on a temporary or permanent basis.
national insurance, which will be shown on your pay statement. Payments
You will be given as much notice as possible of any such changes.
will be made by automatic bank transfer, and we will require you to
provide us with your bank account number and sort code during induction.
Some flexibility is required, particularly when travelling to and from
location over the course of the weekend and in these circumstances
where travel time is less than a 24 hour period no time off in lieu will be
provided.
Where you are required to work a full weekend you may be provided with
1 day time off in lieu with the discretion and approval of your Manager.
If you undertake work in relation to our Exhibitions which require
weekend working, no time off in lieu will be provided unless this has
been approved in advance by your Manager. Where provided this is a
discretionary provision on a case by case basis.
In line with the Working Time Regulations 1998, you will not usually be
asked to work more than 48 hours per week. If you choose to work more
than an average of 48 hours per week, you will need to sign an agreement
to this effect.
In the unlikely event that we are unable to operate for reasons beyond
our control, or if there is a downturn in work which means that we do not
have sufficient work to keep everybody fully employed, your hours of
work may be temporarily reduced and your pay reduced commensurately
(“short time”) or you may be temporarily sent home without pay (“lay-
off”). In these circumstances, you may qualify to receive Statutory
Guarantee Pay for up to 5 days in any continuous 3-month period.
1.6 Training and Development
The Company is committed to training and developing all its employees
to enable them to achieve their maximum potential. However, it also
considers it appropriate to base training and development opportunities
on the requirements of the business. Therefore, decisions about
investment in staff training and development will always be made having
regard to the needs of the business as well as the employee’s individual
needs.
The Company regularly reviews its level of investment in staff training
and development to ensure not only those adequate resources are being
provided but also that training and development activity is delivering a
benefit to both the employee and the business.
Regular performance and development reviews will be undertaken by
your line manager as and when appropriate. Where the Company agrees
to provide a financial investment towards your training and development,
you may be required to complete a Training Agreement in relation to the
financial support provided.
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2. What We Expect of You
2.3 Personal Property
2.1 Timekeeping
We expect you to arrive for work in good time, and be ready to commence
work at your start time.
Your line manager will inform you if there are any specific requirements in
relation to recording your working time e.g. usage of an electronic clocking
in system.
Should you arrive at work more than fifteen minutes late, you should
report to your line manager before commencing your duties and explain
your reasons for late arrival. Where you are more than 10 minutes late
(morning or afternoon), you will be considered as having started work at
the commencement of the next quarter and your pay will be calculated
accordingly.
We would discourage you from bringing any valuable personal items
onto the premises. If this cannot be avoided, you should endeavour to
ensure that any personal property/equipment is not left on the premises
overnight. The Company does not accept any responsibility or liability for
loss, accident or damage to personal property (including vehicles) whilst
on our premises, or whilst working off-site.
A locker may be provided for some areas of the business for you to
securely store any personal items whilst working.
2.4 Telephones & Other Electronic Devices
Company Telephones:
You may make or receive a reasonable number of personal calls at work
providing permission is first obtained from your immediate manager.
Anybody found to be abusing this privilege may have the facility
If you are repeatedly late, without good reason, you may face disciplinary
withdrawn and/or disciplinary action may be taken.
measures.
2.2 Standards of Dress/Uniform
Some roles may require a Company uniform and you will be advised of
this requirement where necessary.
For some roles, you may be required to wear protective clothing.
If you are not required to wear a uniform, we would like you to adopt a
smart business style of dress.
You must be ready to start work appropriately dressed for your role. If you
are not, you may be sent home to change and we will reserve the right not
to pay you for the period you are not at work.
We carry out monitoring of employees’ use of Company telephones
for security reasons and to deter/detect unauthorised use. You should,
therefore, be aware that the telephone calls that you make or receive may
be monitored by the Company.
Personal Mobile Phones:
Whilst at work you should ensure that any personal mobile phone or other
personal IT device in your possession is switched off and stored in your
personal locker (if this facility is available to you), unless you have prior
authorisation to the contrary from your immediate manager.
Headsets/Headphones:
To safeguard employees and visitors on site, the Company does not permit
the use of personal headsets or headphones in the workplace during
working hours.
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This applies to all employees and visitors and to all working environments,
permitted in designated areas, outside the building, away from doorways,
whether workshop, warehouse or office based.
and during break periods only. This restriction applies equally to electronic
cigarettes (“e-cigarettes”) or any other tobacco related products.
Mobile Phones & Driving:
You are not permitted to use a hand-held mobile telephone while driving
any vehicle on Company business. Calls may only be made or answered
while the vehicle is stationary and the engine switched off (the only
exception to this rule is the use of a hand-held phone for a genuine
emergency call to the emergency services if it would be unsafe or
impracticable for the driver to stop driving).
If it is necessary to use mobile telephones while driving, calls should only
be made or taken using a hands-free device.
Any failure to comply with any or all of the above may lead to disciplinary
action up to and including dismissal.
2.5 Company Property
2.7 Alcohol/Drugs
You are not permitted to bring alcohol or drugs (other than prescribed or
over-the-counter medication) onto our premises.
You must not attend work under the influence of, or suffering the after-
effects of, alcohol consumption or the use of drugs. You must be fit
and able to perform your duties safely and efficiently and comply, if
appropriate, with road traffic, health and safety regulations etc. at all
times. If we feel that your performance is being affected in any way
due to alcohol consumption or drug use, or if we can smell alcohol on
your breath, you will be sent home pending the implementation of the
Disciplinary Procedure. Arriving for work while under the influence of, or
suffering the after-effects of, alcohol consumption or drug use will be
deemed to be gross misconduct, which could result in the termination of
You are responsible for the safekeeping of any equipment, tools, stock,
your employment.
computer hardware/software, or any other property issued to you during
your work. Adequate care must be taken to prevent loss, damage, or theft.
These rules apply equally to times when you are working on other
However, should any loss or damage occur, it is your responsibility to
premises, including client premises, on behalf of the Company.
promptly notify your immediate manager.
You are not permitted to remove any Company property/equipment from
as part of off-site training or corporate events, you may consume a
our premises for private use without first receiving written authorisation
moderate amount of alcohol when not undertaking work duties, if it does
to do so from your immediate manager. When permission is obtained, it
not affect your ability to conduct yourself in a professional manner at all
is provided conditional upon you obtaining and following all health and
times. If the Company believes that your consumption of alcohol has led
If you are attending a work social event, or are engaging in social activities
safety instructions.
2.6 Smoking
Smoking is strictly prohibited on Company premises at all times and
without exception. This includes company vehicles. Smoking is only
you to behave in an unprofessional manner, or in any way which reflects
negatively on the organisation, you will be subject to disciplinary action
which could result in the termination of your employment.
We will report to the Police, or other appropriate agencies, any
circumstances connected with drug use that, if left unreported, would
place the Company in breach of any statutory obligation and/or public
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duty. We will take disciplinary action against any employee who fails
external authority, without the express written consent of a Company
to report any person using drugs or alcohol on our premises or in
Director.
dealing/trafficking in drugs whilst on our premises, or whilst otherwise
undertaking duties on behalf of the Company.
Confidential information is identified as all information, which:
For reasons of health and safety and possibly your own protection, you
• Relates particularly to Company business or that of other persons or
are required to notify your immediate manager of any prescribed or over-
bodies with whom the Company has dealings;
the-counter medication that you take if your work performance could
• Is or has been acquired by you during your employment, or has
be adversely affected in any way. In certain circumstances, it may be
otherwise been acquired by you in confidence;
necessary for us to arrange for a risk assessment to be undertaken before
• Is not in the public domain; or
allowing you to continue with your duties.
• Is marked confidential.
The Company reserves the right to request you to provide blood, urine or
You are required to exercise reasonable care to keep safe all documents or
other like specimens for analysis as and when it deems necessary.
other material containing confidential information and shall at the time
2.8 Secondary Employment
of termination of your employment with us, or at any other time upon
demand, return to us any such material in your possession.
You must only undertake other employment whilst working for us, either
2.10 Conflict of Interest
paid or unpaid, with the consent of your Manager. When permission is
granted, it is given on the condition that any secondary employment does
If you have a personal involvement with any suppliers, contractors,
not interfere with, or have an adverse effect on your responsibilities to our
customers etc. or believe that you may be involved in a conflict of interest
organisation.
A statutory maximum 48-hour limit on your weekly working hours applies
to ALL work that you do, including any secondary employment that you
may have, unless you sign an opt-out (referred to above under “hours”).
If you have secondary employment, you should notify your immediate
manager of any changes in circumstances that would affect your total
hours worked in any week.
2.9 Confidential Company Information
situation you must inform your line manager immediately to discuss your
situation and to raise any queries you may have about your circumstances.
2.11 Company Vehicles
Where required the Company may provide certain employees with the use
of a vehicle to undertake the proper performance of his/her duties. When
doing so all employees must adhere to the following:
• To take good care of the vehicle and keep it clean and tidy;
• To comply with the requirements of the Employer’s Vehicle Policy from
You should not under any circumstances, whether during or after your
time to time;
employment, release confidential information to any other Company or
third-party including members of the public, other employees, or any
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• To comply with the terms of any insurance policy relating to the vehicle;
• Not to use any such vehicle for any purpose other than the proper
performance of his/her duties, except where prior permission has been
granted by a Company Director;
• Company vehicles are not be used for private use or any personal
journeys;
• Private vehicles are not to be used for any business mileage/journeys
except where prior permission has been granted by your Manager;
• To drive the vehicle with all due care and attention and to the best of
his/her ability at all times;
• To maintain a valid current driving licence at all times during his/
her employment and to produce it to the Employer for inspection on
request;
• No modifications, accessories or any electrical items should be used in
any Company vehicle unless the express permission has been granted by
a Company Director and any necessary PAT testing has been undertaken.
Where an employee fails to comply with any of these requirements he/
If, during the course of employment, the employee is convicted of any
driving office and/or other motoring incident, he/she must immediately
notify his/her manager, particularly in the following instances:
she will be liable to disciplinary action (up to and including dismissal), and
in particular, that he/she may be dismissed if he/she becomes unable to
discharge his/her duties as a result of losing his/her driving licence.
Records
• He/she is prosecuted or to be prosecuted for or convicted of any road
The Company installs vehicle trackers in all Company vehicles and will
traffic offence;
• A parking ticket is received for any alleged or actual parking violation in
the course of his/her employment or relating to a Company vehicle;
• While driving in the course of his/her employment he/she is involved
in any motoring accident or incident potentially giving rise to a claim
retain information regarding location and time of travel. It has a legal basis
for doing so in respect of its legitimate interests in ensuring the security
of Company property, in line with insurance requirements, safeguarding
mobile workers and recording time and attendance where required.
(whether by the employee or a third party) or which is otherwise
This data will be treated confidentially, and will only be shared with
required to be notified to the insurers by the Employer under the terms
relevant managers who are involved with the employee, or in any
of any insurance policy held by it;
• His/her driving licence is endorsed; or
• He/she is disqualified from holding a driving licence.
disciplinary or appeals processes which may arise in connection with the
Company’s procedures, with members of the HR department, and in some
cases, external HR & Legal Advisors. Further details, including details of
your rights with regard to your personal information, are contained in the
Data Protection Policy (featured elsewhere in this handbook) and the Data
Privacy Notice which has been issued to you separately.
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3. Important Policies and Procedures
3.2 Holidays
3.1 Health and Safety
The Company is committed to providing a healthy and safe working
environment. Everybody is responsible for promoting good practices
and we need all employees’ co-operation to ensure high standards are
maintained.
The Health & Safety Policy is displayed on the noticeboard. Please ensure
this is reviewed and read in full. If any further information is required, this
should be directed to your immediate manager.
If any unsafe practices or situation is witnessed this should be reported to
your immediate manager straight away.
Employees also need to:
• Take reasonable care of your own and your colleagues’ Health and
Safety and that of customers and visitors;
• Co-operate with the Company in any steps it takes to meet its legal
duties;
• Observe all safety precautions and regulations appropriate to any site
you may visit other than the site you are normally employed at;
• Not misuse or interfere with anything provided in the interests of
Health and Safety;
• Strictly observe relevant notices throughout the site, works and/or
offices regarding ‘No Smoking’, ‘Fire Precautions’ and ‘Safety’.
Accidents
The Company is obliged to keep records showing details of accidents to
employees, customers, visitors, suppliers or contractors.
Any accident or near miss, however small, must be reported to your
immediate manager, particularly where personal injury and damage is
concerned. A report of all accidents involving personal injury will be recorded.
The holiday year runs from 1st January to 31st December and your annual
holiday entitlement is stated on your Contract of Employment. Your
entitlement for the holiday year in which you join the Company will be
determined by the number of complete qualifying weeks between your
date of commencement and the end of that year.
To book any holidays, you will need to complete a Holiday Request Form,
which then needs to be approved by your immediate manager before you
make any firm holiday arrangements. Holidays are usually approved on a
first-come, first-served basis.
You should give at least 4 weeks’ notice of your intention to take holidays
of 1 week or longer and 1 weeks’ notice for single days. Normally a
maximum of 2 working weeks can be taken consecutively.
If you take holiday leave without the prior approval of your Manager,
or after any request has been refused, the period of absence shall be
considered as unauthorised and does not count towards your ‘qualifying
weeks’ for the purposes of calculating your holiday entitlement. This
may also apply if you call in reporting sick for a period of leave which has
previously been refused. This will be considered to be serious misconduct
and will result in disciplinary action which could result in the termination
of your employment.
If you are ill on a day on which you would otherwise have been on holiday,
and you wish your absence to be treated as sick leave and not holiday,
you will need to follow the sickness absence reporting procedure outlined
further in this handbook.
A maximum of two days’ holidays can be carried over from one holiday
year to the next with the permission of your Manager. Payment will not
be made for unused holiday entitlement other than at the end of your
employment.
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3.2.1 Company Shutdown Periods
3.3.1 Notification
It is usual practice for us to close down for certain holidays, although a
If you are unable to attend work because of sickness or injury, you must
small number of employees may be required to work during such periods.
arrange for telephone notification to be made to your line manager, or,
We will notify you of all shut down dates and you need to save sufficient
in the event of non-availability, the next level of management, before
leave from your annual entitlement for leave to be taken on these dates.
or within the first hour of your normal starting time on the first day of
We may restrict the taking of holidays in busy periods, e.g. Christmas.
absence.
3.2.2 Public/Nominated Holidays
We usually close on the following public holidays:
• New Year’s Day
• Good Friday
• Easter Monday
• May Day
• Spring Bank Holiday
• Summer Bank Holiday
• Christmas Day
• Boxing Day
You, or the person telephoning on your behalf, should advise the expected
length of absence and the reason for absence. Text messages or emails are
not an acceptable means of notification.
If your absence lasts for longer than one day, but is not covered by a
medical certificate, you must notify your manager as outlined above on
each day of your absence, unless otherwise advised. If you fail to make
contact, your absence will be treated as unauthorised, and you will not be
paid for the period of non-attendance.
For all absences of less than 7 days you will be required to complete a Self-
Certification Form in the presence of your line manager on your return to
work.
However, we may require you to work on any of these days, and if so,
If your absence lasts for more than 7 continuous days, you must obtain
you will be given the opportunity to take your holiday at a different
a Medical Certificate (Statement of Fitness for Work or ‘Fit Note’) from
time or paid an enhanced rate for any work carried out on those days, as
your Doctor stating how long you are going to be unfit for work. The note
stipulated in your Contract of Employment.
should be sent to the Group HR Manager.
3.3 Sickness Absence
The Company has certain notification and certification requirements which
must be followed if you are absent from work. Unauthorised absence may
lead to disciplinary action which could result in the termination of your
employment.
Private medical certificates are not acceptable for sick pay purposes.
It should be noted that a Medical Certificate, whilst persuasive, might not
be considered as absolute evidence of incapacity for work, particularly
where there is evidence to the contrary. Disputes may be pursued by
individuals through the Grievance Procedure, or by the Company through
the Disciplinary Procedure.
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3.3.2 Payment During Sickness Absence
SSP), up to an amount not exceeding the amount of the compensation or
damages paid by the third party.
3.3.3 Statutory Sick Pay
You may receive Statutory Sick Pay (SSP) if you are absent from work due
Failure to follow our absence notification procedure on the first day of
to sickness for 4 or more consecutive days, subject to you meeting the
absence, subsequent re-notification procedures if you cannot return on
qualification criteria.
the expected day, or failure to supply the necessary certification, will lead
to any sickness payments due to you being withheld for the day(s) which
SSP is not paid for the first 3 qualifying days of absence, and thereafter is
are not covered by notification/certification. Unless specified otherwise
paid for a maximum of 28 weeks.
on the Medical Certificate, your first notification lasts for seven days from
the date on which it was given – notification given on a Monday should
SSP is paid through the normal payroll and is subject to tax and NI
therefore be renewed the following Monday if you are unable to return
deductions.
within the specified period.
3.3.4 Discretionary Company Sick Pay
Please help us, and your fellow employees, by ensuring that you follow
The Company operates a discretionary Company Sick Pay Scheme. To
the above procedures in the event that you cannot work.
become eligible for payment through the Company Sick Pay Scheme,
you must have completed your probationary period, be unable to attend
If you are absent without acceptable reasons, without notification and/
work due to personal sickness or injury and comply with the Absence
or correct certification or documentation (regardless of the period of
Notification Procedure. The date you commenced your current period of
absence), or if you persistently fail to follow this procedure, disciplinary
employment shall be the date from which the qualifying period begins. If
action will be taken which could result in the termination of your
you have worked for the Company before, service in any previous period
employment.
of employment is discounted for the purpose of meeting the entry criteria.
Payment during one instance of sickness absence does not suggest that
For our organisation to be effective, we rely on the attendance of our
payment will be made for a further absence and any payments are
employees. If you have an unacceptable amount of short term sickness
calculated by reference to an aggregate absence in any rolling 365 day
absence, you may be subject to disciplinary action, regardless of the fact
period.
that there may be genuine reasons for your absence.
3.3.5 Persistent Short-term Absence
We are not obliged to make any payments for sickness/injury over and
To fairly measure and monitor absence, the Company utilises a method
above SSP. Where we choose to do so, payments will be made on a totally
called the ‘Bradford Factor’.
discretionary basis and SSP will be offset. Please refer to your Contract of
Employment for further details.
The ‘Bradford Factor’ is a simple formula which measures the impact of
unplanned absences, such as, sickness, doctors’ appointments, emergency
Where the circumstances of your incapacity are such that you receive,
leave etc.
or are awarded any sum by way of compensation or damages in respect
of the incapacity from a third party, then you will be required to re-pay
any payments we have made to you because of the absence (including
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The ‘Bradford Factor’ is calculated as follows:
S2 x D = B
process or delay a stage of the process, depending on the circumstances of
S = the total number of separate absences taken in the period under
the case.
review i.e. 3 months
The aims of a formal hearing in respect of an employee’s Bradford Factor
D = the total number of days of absence of that individual
score are to:
B = the Bradford Factor Score
For example, if an individual has been off ill 3 times and has taken a total
• Set out the required attendance standards that the Company believes
of 10 days absence, the Bradford Factor score will be 90.
the employee may have failed to meet, and present any relevant
evidence;
Regular monitoring of absence levels is carried out. Once an employee’s
• Allow the employee to ask questions, respond to and present evidence
score has reached a certain threshold, the business may consider taking
and make representations;
action to address the issue. This may take the form of informal discussions
• Establish the likely causes of poor attendance including any reasons why
in the early stages of the procedure but will progress to formal hearings to
any measures taken so far have not led to the required improvement;
consider disciplinary warnings if concerns regarding attendance continue.
• Establish whether there is any likelihood of a significant improvement in
As a guide the Company have agreed stages at which possible action,
whether formal or informal, will be taken. These trigger points are as
For further information regarding formal hearings, including the right to be
follows:
accompanied, please refer to the Disciplinary Procedure.
attendance being made within a reasonable period of time.
Bradford Factor Score-Trigger Threshold
Possible Action
3.3.6 Long-term Absence
51 Points
201 Points
401 Points
601 Points
Informal Warning
First Written Warning
Final Warning
Dismissal
If it becomes apparent that you may be off work for a prolonged period of
time or if you are absent due to illness or injury for more than 4 weeks we
may:
• Request access to your medical records from your GP; and/or
The Company reserves the right to depart from this procedure at any
time, however, should this be necessary to take account of individual
• Obtain a medical report from an independent medical adviser.
circumstances, e.g., a score lower than those identified above may also
trigger a particular formal warning under this procedure where the
You should make contact with your manager on a regular basis to keep
circumstances merit it (such as if an employee has a history of absence,
him/her informed of your situation, and you should attend any meetings
or where the absences show a pattern, such as around weekends and/or
which we may arrange to discuss your absence. If you cannot attend
bank holidays).
meetings at work, we will endeavour to meet with you at your home or an
alternative location may be agreed.
For the avoidance of doubt, the Company reserves the right to take action
with regard to any level of absence, to skip a particular stage of the
You may request a period of holiday during any period of long term
absence. To do so, you should use the Holiday procedure set out above.
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3.3.7 Records
3.4.3 Public Duties
The Company will retain information regarding absence and timekeeping.
Should you contemplate putting yourself forward for membership of
It has a legal basis for doing so in respect of its legal obligations
any designated authorities for voluntary public duties (such as Justice of
or legitimate interests, specifically, payment of Statutory and/or
the Peace, Territorial Army Volunteer Reserve etc.) you must obtain prior
discretionary Company Sick Pay. This data will be treated confidentially,
permission before doing so. Permission will not be unreasonably withheld,
and will only be shared with relevant managers who are involved with
providing that the time involved performing such duties is compatible
your employment, or in any disciplinary or appeals processes which may
with the job requirements of the Company.
arise in connection with the absence procedure, with members of the HR
department, and in some cases, external HR & Legal Advisors. Further
3.4.4 Bereavement/Compassionate Leave
details, including details of your rights with regard to your personal
We appreciate there may be unexpected events in your life that cannot
information, are contained in the Data Protection Policy (featured
be planned for, such as the death of a close relative (spouse, partner, child,
elsewhere in this handbook) and the Data Privacy Notice which has been
brother, sister or parent). The need of each individual may vary greatly and
issued to you separately.
3.4 Time-off for Other Reasons
3.4.1 Medical, Dental and Optical Appointments
You should make appointments with a doctor, dentist or optician outside
working hours. Where this is not possible, you should obtain prior
permission from your immediate manager and try to make appointments
at the beginning or end of the working day. If your appointment is during
working hours, you will be asked to obtain an appointment card to
confirm the time and date of your appointment. Your manager will inform
you if the time taken will be provided as unpaid leave or you will be
required to work additional hours to cover the time taken.
3.4.2 Jury Service
If you are required to attend court as a juror, you should notify your
manager as soon as you receive notification and you will be allowed the
requested time off unpaid. A Loss of Earnings Allowance should be claimed
from the court, together with any travelling and out of pocket expenses.
the setting of fixed rules for time off in the event of a family bereavement
is therefore difficult. However, in such cases you will typically be provided
with 3 days paid leave following the death of a close relative (indicated
above) or 1 days’ paid leave for any other relative.
Compassionate leave may also be granted for reasons other than
bereavement.
You should contact your immediate manager in line with the absence
reporting procedure, who will deal with each situation on an individual
basis.
3.4.5 Time-off to Care for Dependants
You have a statutory right to take a reasonable amount of unpaid time
off work in order to arrange for the care of a dependant in certain
circumstances.
A dependant is your wife, husband, partner or civil partner, child, parent
or someone who lives in the same household as you (but who is not your
employee, tenant, lodger or boarder) or any person who reasonably relies
on you for assistance.
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Requested changes can be to hours or days of work, or location of work.
You should make any such request in writing to your immediate manager,
and include:
• Details of your proposal, explaining what impact you think it will have
on the business and how this may be dealt with;
• A start date for the proposed change, allowing the Company 12-14 weeks
for consideration and implementation.
Each request will be considered on its own merits, whilst at the same time
considering the needs of the business. If we approve your application, the
variation in contractual terms will be permanent, unless otherwise stated,
and there will be no automatic right for you to revert to your previous
work pattern.
If we believe that the request would negatively impact the organisation,
and such impact cannot be reasonably overcome, we may refuse it, or
suggest an alternative arrangement. However, we will arrange a meeting
with you to discuss further before making a final decision. If we then
choose not to grant the request, we will advise you in writing of our
reasons, and you will have the right to appeal the decision.
Circumstances may include when a dependant:
• Becomes ill or dies;
• Has an accident;
• Has the arrangements for their care unexpectedly disrupted (including
unexpected school closures).
Only one request for flexible working arrangements can be made within a
If you require time off to deal with such a situation, you should contact
your immediate manager to explain the nature of the emergency and to
confirm the expected duration of your absence. What is “reasonable” will
depend upon the particular circumstances, but most absences for this
purpose would not be expected to be more than one or two days.
12 month period.
3.6 Family Leave
3.6.1 Maternity Leave
All pregnant employees are eligible for up to 52 weeks leave. This is made
up of 26 weeks Ordinary Maternity Leave (OML) and 26 weeks Additional
3.5 Flexible Working
Maternity Leave (AML).
All employees with at least 26 weeks continuous service with the
You must notify the organisation if you are pregnant at the earliest
Company have the statutory right to make a request to work flexibly.
opportunity, as we may need to conduct an assessment of any risks to you
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or your unborn child associated with your role, and take any necessary
mother’s spouse, civil partner, or partner in an enduring relationship.
action required.
There is no qualifying period, but there will be a requirement for the
In order to take maternity leave you must notify us of the date you intend
individual requesting the time off to confirm their relationship with the
to start your leave no later than the 15th week before the expected week
mother and provide details about appointments.
of childbirth (EWC), and provide a certificate from your doctor or midwife
(usually the MATB1 form) confirming the EWC. The earliest date you
3.6.3 Statutory Maternity Pay
can start your leave is 11 weeks before the EWC. If you are absent with
You will be eligible to receive Statutory Maternity Pay if you:
a pregnancy-related illness within 4 weeks of your EWC, your maternity
leave will be automatically triggered. If you wish to postpone or bring
• Have 26 weeks continuous service as at the 15th week before the EWC;
forward the date you intend to start your leave, you should advise us not
• Have average weekly earnings which are at or above the lower
less than 28 days before the original intended start date (if postponing) or
earnings limit for National Insurance contributions.
the new intended start date (if bringing forward).
SMP lasts for a maximum of 39 weeks and is paid at two rates as follows:
During maternity leave you will be entitled to the terms and conditions of
your employment, except those in relation to pay. You will also be bound
• 90% of your normal earnings for the first 6 weeks.
by the terms and conditions of your employment except those in relation
• The prescribed rate for 33 weeks (or 90% of your earnings if that is
to undertaking work.
lower). This rate changes each year. Details can be found on the HMRC
website, or can be provided on request.
You will be required to take any outstanding holidays prior to commencing
maternity leave. You will continue to accrue holidays during the period of
If you are not entitled to SMP, you may be entitled to Maternity
leave.
Allowance, which is paid at the prescribed rate for up to 39 weeks.
The Company will notify you of the date on which you are expected to
3.6.4 Paternity Leave and Pay
return to work. If you wish to return earlier, you are required to give the
If you are an expectant father, or if your partner is pregnant and you
Company at least 8 weeks’ notice of your earlier intended date of return.
expect to have responsibility for the child’s upbringing, you may, if you
3.6.2 Ante-natal Care
All pregnant employees are entitled to reasonable time off with pay for
have sufficient service and have provided the appropriate notification,
have the right to statutory paternity leave and pay.
the purpose of receiving antenatal care. Except for the first appointment,
Paternity leave can be taken as either one or two weeks leave in the 8
you are required to show the Company, if requested, an appointment card
weeks following the birth of the child.
or other documents showing that an appointment has been made.
Paternity Pay
The partner of a pregnant woman will be entitled to take unpaid time
If you have one complete years’ service at the 15th week prior to the
off work to attend up to 2 antenatal appointments with her, capped at
expected week of childbirth, the Company will provide you with paternity
6.5 hours per appointment. A ‘partner’ could be the baby’s father, or the
pay at the rate of 90% of your basic weekly salary. Alternatively, statutory
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paternity pay will be payable provided that your earnings are at least at
3.6.7 Parental Leave
the lower earnings limit for national insurance contributions. It is paid at
If you are the parent of, or have parental responsibility for, a child under
the prescribed rate set by the government annually, or 90% of your normal
the age of 18, and you have at least one year of complete service with
weekly earnings if this is less. Details of the current prescribed rate are
the Company, you will be entitled to take up to 18 weeks of unpaid leave
available on request, or can be found on the HMRC website.
for each child in order to look after them or make arrangements for their
3.6.5 Shared Parental Leave
welfare. You must inform the Company at least 21 days prior to your
intended start date. Leave must normally be taken in blocks of complete
Shared Parental Leave is designed to give parents more flexibility in how
weeks, except where the child is disabled when leave can be taken in odd
to share the care of their child in the first year following birth or adoption.
days, with the maximum amount of leave you can take in one year being
Parents will be able to share up to 50 weeks of leave, and can decide to
4 weeks.
be off work at the same time and/or take it in turns to have periods of
leave to look after the child. Further details can be obtained from your line
manager.
3.6.6 Adoption Leave
If you are adopting a child, you will be eligible for up to 52 weeks
Statutory Adoption Leave provided that you:
• You have notified the agency that you agree to the child being placed
with you on the EPD;
• Your spouse or partner will not be taking adoption leave with their
employer (although they may be taking paternity leave.
3.7 Equal Opportunities
We are committed to providing equality of opportunity and treatment in
all aspects of employment for every member of staff and for potential
new recruits.
It is unlawful to discriminate 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”.
You must give us at least 28 days’ notice of the date you intend to start
leave.
We will do everything reasonable to ensure that no person receives less
favourable treatment because of a protected characteristic.
You can begin leave at any date from the 14th day before the EPD, or on
the placement date itself, but not later.
Statutory Adoption Pay
Statutory Adoption Pay is payable for up to 39 weeks, but stops if your
placement ends or you return to work sooner. It is subject to you having
earnings which are at least at the lower earnings limit for national
insurance contributions, and is payable at the prescribed rate set by the
government annually, or 90% of your normal weekly earnings if this is less.
Details of the current prescribed rate are available on request, or can be
found on the HMRC website.
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Whilst the overall responsibility for this policy rests with the Group HR
Manager you must ensure that you treat all colleagues and job applicants
fairly, impartially and without discrimination.
The principles set out above apply in the workplace and outside the
workplace in a work related context such as business trips, customer or
supplier events or work related social events.
If you have any grievance relating to Equal Opportunity issues, you should
raise this through the Grievance Procedure.
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3.8 Bullying and Harassment
can occur because someone is associated with another person, for
example where someone cares for a disabled person or is friends with a
We will not condone any form of bullying or harassment against any
transsexual.
of our employees or workers. There is no legal definition of workplace
bullying, but it is generally regarded as negative behaviour targeted at an
individual or particular group of individuals, which occurs repeatedly or
persistently over time.
Whilst not an exhaustive list, forms of harassment include:
• Physical contact
• ‘Jokes’ or ‘banter’
Examples of unacceptable behaviour that could amount to bullying
• Offensive language, racial slurs
include:
• Abuse or misuse of power
• Spreading malicious rumours
• Ridiculing or setting someone up to fail
• Unfair treatment
• Deliberate exclusion without good reason
• Overbearing or intimidating supervision
Legitimate, reasonable and constructive criticism of performance or
behaviour, or reasonable instructions given will not amount to bullying.
Harassment is defined as any kind of conduct or behaviour including
physical, verbal or non-verbal conduct, which is considered to be
unwelcome, unwanted, unreasonable or offensive to the recipient
• Offensive screen savers, posters, emblems, symbols
• Isolation or exclusion
All employees are required to read this and ensure that they understand
what types of behaviour are unacceptable. You must always consider
whether your words or conduct may be considered offensive. If you have
any queries, please speak to your Manager.
The informal and formal procedure to follow is set out under the
Grievance section earlier in this handbook.
You will not be subject to any detriment for bringing a complaint of
bullying/harassment. However, if the investigation concludes that your
complaint is both untrue and that you have brought it with malicious
intent, you may be subject to disciplinary action up to and including the
particularly in relation to a protected characteristic (see above under
termination of your employment.
“Equal Opportunities”) and has the purpose of violating a person’s dignity
or creating an environment that is intimidating, hostile, degrading,
humiliating or offensive.
Where we have reason to believe that bullying or harassment is occurring,
we will take appropriate action under the Disciplinary Procedure, which
may result in disciplinary action up to and including dismissal of the
Conduct normally becomes harassment if it continues even though it has
person or people responsible.
been made clear that it is offensive or unwanted. The behaviour doesn’t
have to be directed at you. If you witness another person being harassed
Records
you should follow the procedure below.
Harassment may relate to any of the protected characteristics. However
it can also occur based on the perception of another person, for example
where it is believed a person is gay or disabled. In addition harassment
The Company will retain information regarding issues dealt with under
the Bullying and Harassment Procedure. It has a legal basis for doing so
in respect of its legitimate interests in following a fair procedure. This
data will be treated confidentially, and will only be shared with relevant
managers who are involved with your employment, or in any disciplinary
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or appeals processes which may arise in connection with the bullying &
Where the Company gives anything other than low value/token gifts,
harassment Procedure, with members of the HR department, and in some
these must be authorised by the Company Secretary and records must be
cases, external HR & Legal Advisors. Further details, including details of
kept.
your rights with regard to your personal information, are contained in the
Data Protection Policy (featured elsewhere in this handbook) and the Data
Privacy Notice which has been issued to you separately.
3.10 Search (Contractual)
3.9 Bribery
Where we have reasonable grounds for suspecting that you may have
committed a criminal offence or any serious breach of contract and/or of
our rules, we reserve the right to request at any time that you submit to
The Company is committed to the highest standards of ethical conduct
a search of your person (outer wear only) while on Company premises.
and integrity in its business activities. This policy outlines the Company’s
We also reserve the right to search any property you hold on Company
position on preventing and prohibiting bribery, in accordance with the
premises i.e. any locker, desk, personal belongings etc., or any vehicle used
Bribery Act 2010.
by you, at any time.
Any breach of this policy is likely to constitute a serious disciplinary
All searches will be conducted with your consent, in private and in
matter and could result in summary dismissal. It may cause serious
the presence of a work colleague chosen by you and a member of
damage to the reputation and standing of the Company and the Company
management. Any personal search will be conducted by a person of the
may also face criminal liability for unlawful actions taken by its employees
same sex.
or associated persons under the Bribery Act 2010. In addition, it could
amount to a criminal matter for the individual concerned.
If you unreasonably refuse to submit to a search, the police may be called
and you may be asked to remain on site pending their arrival.
A bribe is a financial advantage or other reward that is offered to,
promised to, given to, or received by an individual or company to induce
A search does not constitute any accusation on our behalf, but any refusal
or influence that individual or company to perform its public or corporate
to give consent may, in appropriate circumstances, be treated as a breach
functions or duties in an improper manner.
of contract, an act of misconduct and render you liable to disciplinary
Except for gifts of low value and which are mere tokens (such as
promotional pens, calendars and stationery), you are not permitted
to accept excessive hospitality from a client or supplier. This includes
action up to and including dismissal.
3.11 Use of IT, Internet, Email and Social Media
entertainment, the cost of recreation, holidays etc. Any offer of hospitality
Information Technology plays a crucial part in the operation and
must be discussed with and approved by the Company Secretary.
development of our business. As such it is essential that you are aware of,
and understand, Company rules relating to computer operations, including
Where refusal of an offer of a gift, or hospitality, might cause
E-Mail and Internet use.
embarrassment or difficulty, you should refer the matter to the Company
Secretary without delay.
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These rules apply not only to the use of Company technology at work but
also when using outside of work, e.g. when accessing our system remotely,
using a Company laptop or tablet when travelling, and when using
smartphones or other similar devices.
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Computer Operations – Summary
You must not:
confidentiality is protected (e.g. checking the correct email address,
protecting documents with a password, etc.)
• Divulge any confidential passwords.
We will not permit the use of E-mail messages that constitute bullying or
• Install any programme onto Company equipment, without first receiving
harassment, that are obscene or abusive, inconsistent with the Company’s
authority to do so from a Company Director.
Equal Opportunities/Bullying and Harassment statement.
• Copy or download any Company programmes, files or data of any kind
or remove these from the premises (this includes saving files or data to
You must not use a Company email address or the Company email system
online storage systems, e.g. Dropbox, Onedrive etc.) .
to send trivial messages, or copy or forward unnecessary messages e.g.
• Load any disk, pen drive or memory stick brought in from outside
chain mail, junk mail, cartoons, jokes or gossip.
without the authority of a Company Director.
• Install any programme without first screening for viruses.
• Remove any hardware/software off site without permission.
Passwords and Security
You must use passwords on all IT equipment and must keep any password
• Use any computer until you have received appropriate authorisation and
allocated confidential.
Company training.
• Access information you are not entitled to receive i.e. you must only
You must change your password regularly.
access that which is necessary in order for your own work functions to
be efficiently carried out and for which authorisation has been received.
You must not use another person’s username/password to access Company
• Use the Company systems for commercial purposes other than the
systems without authorisation.
business of the company
General Rules Regarding Communication and Email
This policy statement should be read in conjunction with equality,
harassment and bullying, monitoring and data protection policies.
• You must only access the Company’s email if you have been told by your
Manager that you may do so.
• You must not send messages from another person’s email address unless
authorised to do so.
• You must use the Company email address for sending and receiving
work-related emails and you must not use your own personal email
accounts for the purpose of the Company business.
If you are sending any e-mails of a confidential nature, it is essential
that you ensure that you do so only with the permission of the intended
recipient, and that you take all necessary precautions to ensure that
You must log out of your system or lock your computer when leaving your
desk for any extended period of time.
Contact Lists
Contact details of customers, clients or suppliers which have either been
made available to you or compiled by you during the course of your
employment, must be stored securely and kept confidential. Any lists of
contacts compiled by you during the course of your employment remain
the property of the Company. Such lists must not be copied or removed
during or after employment.
System and Data Security
Be vigilant when using the Company’s email system, viruses are often sent
by email and can cause significant damage to the Company’s IT systems.
No personal computer, mobile, tablet or USB storage device is allowed
to be connected to the Company’s system or network without prior
permission from a Company Director.
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The Internet
do so for work purposes. In your use of social media, even if it is outside
If you are authorised to use the Internet, you should do so only for
of your working hours and not using our systems, you must comply with
business purposes, unless you have the express permission of your
your contract of employment as well as all the Company policies, and in
Manager on specific occasions to access it for personal use. If you do have
particular you must not:
permission to access the Internet for personal purposes, you must not
access any content of an illegal or obscene nature. Any such action is likely
• Post anything related to your colleagues or the Company’s clients,
to result in summary dismissal.
competitors, business partners or suppliers without their written
permission;
Using your Company email to subscribe to news groups, mailing lists and
• Post disparaging statements about the Company, your colleagues,
social networking websites are permitted only when the subscription is in
clients, competitors, prospective clients, suppliers or other affiliates;
relation to a work-related purpose.
• Make communications that might be construed in a way that could
The Company may block or restrict access to any website at its discretion.
• Post comments about sensitive business-related topics, such as the
damage the Company’s reputation, even indirectly;
Social Media
Company’s performance;
• Do anything which might disclose confidential business information;
Social media means any internet based applications which allow users to
• Use the Company’s logos, brand names, slogans or other trademarks,
interact, such as social networking, blogs, wikis, social bookmarking, etc.
without the prior written consent of [POSITION];
Examples include Facebook, LinkedIn, YouTube, Instagram, Twitter, Flickr,
• Post anything that your colleagues, or our clients, competitors, suppliers
Slide share and Pinterest.
or other affiliates might find offensive, including discriminatory
comments, insults or obscenity, even if these are unrelated to your work.
We do not want to regulate how you use social media in a private capacity
providing your use has no bearing on the Company. This guidance is to
General Rules
ensure that you understand the rules and ensure that you use the various
• You must not use your work email address to sign up for personal use of
platforms responsibly.
social media sites;
When you create or exchange content using social media, you are making
a public statement. As such your content will not be private and can be
forwarded without your consent. If sensitive or confidential information
(or offensive/defamatory) has been disclosed, it cannot be recovered and
this may result in liability both for the company and you.
Bear in mind that even if you are using social media in a personal capacity,
other users who are/may be aware of your association with the company
and the content could damage the company’s reputation.
You should not use the Company’s systems to access social media or other
such platforms unless you have the express permission of your manager to
• You should have no expectation of privacy or confidentiality in anything
you create or share;
• You should not identify yourself as working for the company (without
approval from your Manager);
• You should regularly review your privacy settings;
• You should regularly review the content and delete anything that could
reflect negatively on you or on the Company.
Posting any of the above material, whether inside or outside of work, on
a personal account with privacy settings, and on personal devices, may
result in disciplinary action being taken, up to and including dismissal.
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The Company obtains, stores and uses personal information (also
referred to as data) about job applicants, current and former employees,
temporary and agency workers, contractors, interns, and apprentices for
a number of specific lawful purposes, as set out in the Company’s data
protection notices relating to recruitment and employment.
This policy sets out how we comply with our data protection obligations
and seek to protect personal information relating to our staff. Its
purpose is also to ensure that staff understand and comply with the rules
governing the collection, use and deletion of personal information to
which they may have access in the course of their work.
The Company’s Data Protection Officer is the Head of IT EMEA and is
responsible for informing and advising the Company and its staff on its
data protection obligations, and for monitoring compliance with those
obligations and with the Company’s policies. Any questions or comments
about this policy, or any requests for further information, should be
directed to the Head of IT EMEA. Any questions or comments about this
policy, or any requests for further information, should be directed to them.
Staff should refer to the Company’s Data Protection Privacy Notice for
Employees, and where appropriate, to its other relevant policies including
IT, email, Social Media etc.
This policy does not form part of any contract of employment (or contract
for services if relevant) and can be amended by the Company at any time.
It is intended that this policy is fully compliant with the 2018 Act and
the GDPR. If any conflict arises between those laws and this policy, the
Company intends to comply with the 2018 Act and the GDPR.
Data Protection Principles
To comply with the Data Protection Principles set out in the 2018 Act the
Company will ensure that all personal information it processes is:
• Processed fairly, lawfully and in a transparent manner;
If you feel that you have been harassed or bullied because of material
posted or uploaded by a colleague you should inform your Manager and
refer to the Bullying and Harassment or Grievance procedure.
Monitoring
We may monitor any E-mail and Internet use to ensure compliance with
our policies. You may be required to remove content created or shared by
you which the Company deems to be in breach of this policy.
3.12 Data Protection Policy
Introduction
The Company takes the security and privacy of personal data seriously.
We need to gather and use personal information or ‘data’ as part of our
business, and to manage our relationship with our staff. We intend to
comply with our legal obligations under the Data Protection Act 2018 (the
‘2018 Act’) and the EU General Data Protection Regulation (‘GDPR’) in
respect of data privacy and security.
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• Collected and processed only for specified, explicit and legitimate
How we define processing
purposes;
‘Processing’ means any operation which is performed on personal data
• Adequate, relevant and limited to what is necessary for the purposes for
such as:
which it is processed;
• Accurate and kept up to date. We will take reasonable steps to ensure
• Collection, recording, organisation, structuring or storage;
that any inaccurate data is deleted or rectified without delay;
• Not kept for longer than is necessary for the purposes for which it is
• Adaption or alteration;
• Retrieval, consultation or use;
processed; and
• Disclosure by transmission, dissemination or otherwise making available;
• Subject to appropriate technical and organisational measures to ensure
that it is kept securely and protected against unauthorised or unlawful
processing, and against accidental loss, destruction or damage.
• Alignment or combination; and
• Restriction, destruction or erasure.
How we define personal data
and any automated processing.
This includes processing personal data which forms part of a filing system
‘Personal data’ means information which relates to a living person who
can be identified from that data (a ‘data subject’) on its own, or when
taken together with other information which is likely to come into the
Company’s possession. It includes any expression of opinion about the
Basis for processing personal data
person and an indication of the intentions of us or others, in respect of
In relation to any data processing activity, there must be a legal basis for
that person. It does not include anonymised data.
the processing consisting of one or more of the following:
This policy applies to all personal data whether it is stored electronically,
(A) That the data subject has provided consent for the processing
on paper or on other materials.
(B) That the processing is necessary for the performance of a contract to
which the data subject is party or in order to take steps at the request
Personal data might be provided to the Company by the employee or
of the data subject prior to entering into the contract
applicant, or someone else (such as a former employer, an employee’s
(C) That the processing is necessary for compliance with a legal obligation
doctor, or a credit reference agency), or it could be created by the
to which the Company is subject
Company. It could be provided or created during the recruitment process
(D) That the processing is necessary for the protection of vital interests of
or during the course of the contract of employment (or services) or after
the data subject or another natural person
its termination. It could be created by a manager or other colleagues.
(E) That the processing is necessary for the performance of a task carried
out in the public interest or exercise of official authority
‘Special categories of personal data’ or ‘sensitive data’ means personal
(F) That the processing is necessary for the purposes of the legitimate
data about an individual’s race or ethnic origin, political opinions, religious
interests of the Company or a third party, and where those interests
or philosophical beliefs, trade union membership, genetic or biometric
are not overridden by the interests or fundamental rights and
data, health, or sex life and sexual orientation.
freedoms of the data subject
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We will only process personal data where we have a legal basis for doing
has been shared and in accordance with our instructions.
so (see above), and, in the case of Special Category Data (see above),
where one of the following special conditions applies:
We send some personal data outside the European Economic Area. When
doing so all data is sent as a protected, encrypted file.
• Where it is necessary for carrying out obligations or exercising specific
rights in the field of employment law;
How should you process personal data for the Company?
• Where it is necessary to protect the vital interests of a person where the
Everyone who works for, or on behalf of, the Company has some
subject is physically or legally incapable of giving consent;
responsibility for ensuring data is collected, stored and handled
• Where the data has been made public by the subject;
appropriately, in line with this policy.
• Where processing is necessary for the establishment, exercise or defence
of legal claims; and
The Company’s Data Protection Officer is responsible for reviewing
• Where processing is necessary for the purposes of occupational medicine
this policy and updating the Company Directors on the data protection
or for the assessment of the working capacity of the subject.
In particular, we may use information in relation to:
responsibilities and any risks in relation to the processing of data. You
should direct any questions in relation to this policy or data protection to
this person.
• You should only access personal data covered by this policy if you need
• Race, ethnic origin, religion, sexual orientation or gender to monitor
it for the work you do for, or on behalf of the Company and only if you
equal opportunities;
are authorised to do so. You should only use the data for the specified
• Sickness absence, health and medical conditions to monitor absence,
lawful purpose for which it was obtained.
assess fitness for work, to pay benefits, and to comply with our legal
• You should keep personal data secure and not share it with unauthorised
obligations under employment law, including to make reasonable
people.
adjustments and to look after our employees’ health and safety; and
• You should regularly review and update personal data which you have
to deal with for work. This includes telling us if your own contact details
We do not take automated decisions about individuals using their
change.
personal data or use profiling.
Sharing personal data
• You should not make unnecessary copies of personal data and should
keep and dispose of any copies securely.
• You should use strong passwords, where applicable, and under no
We may share personal data with group companies or our contractors and
circumstances should you disclose these to others.
agents to carry out our obligations under a contract of employment or
• You should lock your computer screens when not at your desk.
for our legitimate interests. Such third parties include payroll providers,
• Wherever possible, personal data should be encrypted before being
legal advisors, pension provider, healthcare providers and other benefit
transferred electronically to authorised external contacts. You can speak
providers.
to the IT department for more information on how to do this.
• Consider anonymising personal data or using separate keys/codes so
We require those companies to keep such personal data confidential and
that the data subject cannot be identified.
secure and to protect it in accordance with the law and our policies. They
• Do not save personal data to your own personal computers or any other
are only permitted to process the data for the lawful purpose for which it
personal device.
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• Personal data should never be transferred outside the European
How to deal with data breaches
Economic Area except in compliance with the law and with the
A data breach may take many different forms, for example:
authorisation of the Data Protection Officer.
• You should lock all drawers and filing cabinets which contain any
• Loss or theft of data or equipment on which personal data is stored;
personal data. Under no circumstances should you leave documents
• Unauthorised access to, or use of, personal data either by a member of
which include personal data in any place where they can be read by a
staff or third party;
person who does not have the authority to see the data. This includes
• Loss of data resulting from an equipment or systems failure;
your desk, in boxes, or in unlocked drawers or cabinets.
• Human error, such as accidental deletion or alteration of data;
• You should not take personal data away from the Company’s premises
• Unforeseen circumstances, such as fire or flood;
without authorisation from your line manager or the Data Protection
• Deliberate attacks on IT systems, such as hacking, viruses or phishing
Officer. Where you do have authority to take data from the office, you
scams.
should avoid taking it in paper form, which is more difficult to secure,
unless absolutely necessary. You should ensure that you take every
Should a breach of personal data occur (whether in respect of you or
reasonable precaution to ensure that personal data taken out of the
someone else) then the Company must keep evidence of that breach.
office is kept safe, including: Protecting electronic data with a strong
If the breach is likely to result in a risk to the rights and freedoms of
password, encrypting any memory stick or other portable storage
individuals then we will notify the Information Commissioner’s Office
device, not leaving laptops or bags in your vehicle, ensuring that no
without undue delay and, where possible, within 72 hours of becoming
other people, including members of your family, have access to such
aware of the breach.
information where it is taken home, avoiding taking such data on public
transport unless absolutely necessary, in which case you should take the
If the breach is likely to result in a high risk to an individual’s rights and
utmost care to ensure that such information is with your person at all
freedoms, then we will notify the affected individual.
times.
• Personal data should be shredded or disposed of securely (i.e.,
confidential waste facilities) when you have finished with it.
You should ask for help from the Data Protection Officer if you are unsure
about data protection or if you notice any areas of data protection or
security you think the Company can improve upon.
Any deliberate or negligent breach of this policy by you may result
in disciplinary action being taken against you in accordance with our
disciplinary procedure.
It is a criminal offence to conceal or destroy personal data which is part of
a subject access request (see below). This conduct would also amount to
gross misconduct under our disciplinary procedure, which could result in
your dismissal.
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If you are aware of a data breach you must contact the Data Protection
Officer immediately and keep any evidence you have in relation to the
breach.
Subject access requests
Data subjects can make a ‘subject access request’ (‘SAR’) to see the
personal data the Company holds about them. This request must be made
in writing. If you receive such a request you should forward it immediately
to the Data Protection Officer who will coordinate a response.
If you would like to make a SAR in relation to your own personal data
you should make this in writing to the Data Protection Officer. The
Company must respond within one month unless the request is complex
or numerous, in which case the period can be extended by a further two
months.
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There is no fee for making a SAR. However, if your request is manifestly
3.13 Disciplinary Procedure
unfounded or excessive the Company may charge a reasonable
administrative fee or refuse to respond to your request.
Data subject rights
An individual has the right to access information about what personal
data the Company processes about them. You have the right to access
The Company sets standards of conduct and work performance, which are
necessary for it to operate effectively in the interests of all its employees
and customers.
The purpose of these guidelines is to help and encourage you to achieve
your own personal data by way of a subject access request (see above).
and maintain standards and to provide a fair and consistent method of
You can request that inaccuracies in your personal data be corrected. To do
dealing with alleged failures. In instances of poor performance (where it is
so you should contact your line manager in the first instance, or the Data
a case of ”can’t do” as opposed to “won’t do”), the underlying reason will
Protection Officer where you are not satisfied with the response.
be capability (poor performance).
• You have the right to request that we erase your personal data where
Informal Warnings
we are not entitled under the law to process it, or it is no longer
necessary to process it for the purpose for which it was collected.
In minor cases of misconduct an employee will usually be given an
informal warning from their immediate manager in the first instance,
• While you are requesting that your personal data is corrected or erased
without the need to implement the formal disciplinary procedure. A file
or are contesting the lawfulness of our processing, you can apply for its
note of the warning may be kept in the employee’s file
use to be restricted while the application is made.
• You have the right to object to data processing where we are relying
Investigation
on a legitimate interest to do so and you think that your rights and
In most instances of alleged misconduct which could lead to formal
interests outweigh our own and you wish us to stop.
disciplinary action, an investigation will be undertaken to establish the
• You have the right to object if we process your personal data for the
facts. Circumstances where this may not be required include where the
purposes of direct marketing.
employee has openly admitted to the alleged misconduct, or where there
• You have the right to receive a copy of your personal data and to
is irrefutable evidence of the alleged misconduct.
transfer your personal data to another data controller. We will not
charge for this and will, in most cases, aim to do this within one month.
Suspension
• With some exceptions, you have the right not to be subjected to
The employee may be suspended with pay while the matter is
automated decision-making.
investigated. During any period of suspension, employees shall be
prohibited from attending the workplace other than for the purpose of
In most situations the Company will not rely on your consent as a lawful
attending meetings/hearings concerning the matter, nor shall they contact
ground to process your data. If it does request your consent to the
any other employees, suppliers or customers, without Company consent,
processing of your personal data for a specific purpose, you have the right
unless such contact is in respect of arranging for a work colleague or trade
not to consent or to withdraw your consent later.
union representative to accompany you to a disciplinary hearing.
To exercise any of your rights, as outlined above, you should contact your
Disciplinary Hearings
line manager in the first instance, and if not satisfied with the response,
Where the Company feels that there is a disciplinary allegation to be
you should contact the Data Protection Officer.
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answered, the employee will be required to attend a disciplinary hearing,
behaviour or conduct, or further unrelated misconduct occurs, this will
and will be notified in writing of the reason(s) for holding the hearing, and
usually result in Dismissal.
the date, time and location. Where practicable, at least 24 hours’ notice of
the hearing will be given.
The Company reserves the right, however, to implement the procedure at
any stage, or to skip stages of the procedure, if the situation so warrants,
At the disciplinary hearing the employee will be given the opportunity to
and in this respect a final warning may be given as the first stage of the
state his/her case.
procedure.
Employees have the right to be accompanied to a disciplinary hearing by a
Period of Warnings
work colleague or an authorised person as defined by current employment
The written notification of a warning will set out the period after which
legislation. The accompanying person can address the hearing to present
the warning will be disregarded for disciplinary purposes. In most
the employee’s case, ask questions, respond to any views expressed and
circumstances, the period for formal warnings will be 12 months, provided
sum up, but they cannot answer questions on the employee’s behalf.
that there has been satisfactory improvement in behaviour or conduct,
Employees should notify the Company of the name of any person who is
and no unrelated misconduct during that period. The Company may, at
to act as their representative as soon as practically possible in advance of
its discretion, issue warnings for longer periods where it deems this to be
any formal disciplinary hearing.
justified in the circumstances. It may also re-issue or extend the period
of a warning, as an alternative to escalating disciplinary action where
We may, on occasion, devolve responsibility for disciplinary and grievance
insufficient improvement has been made.
investigations and/or hearings to external consultants. Where we do
so, the consultant will adhere to the relevant Company policies and
Gross Misconduct
procedures.
Where an employee is deemed to have committed an act of gross
misconduct, they will usually be summarily dismissed (i.e. dismissed
We may, on occasion, make audio recordings of meetings or hearings.
without notice of pay in lieu of notice) without any warnings being issued.
Similarly, you are forbidden from making such recordings without prior
Examples of gross misconduct include:
written consent from the meeting/hearing chair and Group HR Manager. If
you are found to be covertly recording or to have made a covert recording,
(1) Theft from the Company, customers, or employees. Theft includes
you may be subject to disciplinary action up to and including dismissal.
misappropriation of property, and/or materials, unauthorised taking
The employee will be notified of the disciplinary decision in writing as
services for personal gain without prior management permission;
of Company-owned products, or using Company labour, facilities or
soon as possible.
Disciplinary Warnings
(2) Dishonesty or fraud, including the falsification of records;
(3) Conduct that brings/risks bringing the Company into disrepute;
(4) Serious negligence by the employee in the performance of his/her
A first instance of misconduct will usually lead to a First Written Warning.
duties;
If, during the period of a First Written Warning, there is insufficient
(5) Failure to carry out a lawful and reasonable management instruction;
improvement in behaviour or conduct, or further unrelated misconduct
(6) Serious breach of work procedures or rules including quality and health
occurs, this will usually lead to a Final Written Warning. If, during the
and safety, or repeated failure to follow procedures or rules in the case
period of a Final Written Warning, there is insufficient improvement in
of less serious breaches;
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(7) Breach of statutory regulations;
Appeals
(8) Any serious breach of internal security rules and requirements including
Employees may appeal against any formal disciplinary warning within 5
any breach of confidentiality;
days of being notified. In the first instance, if an employee wishes to lodge
(9) Competing with the employer in their business, or taking actions to do
an appeal he/she should notify the next level of management/a Company
so;
Director accordingly. The written request should contain a brief outline of
(10) Consuming or being under the influence of alcohol or drugs (except
the grounds for appeal. The manager/Director will arrange for an appeal
prescribed or over-the-counter medication) whilst on Company
hearing to take place. The employee will be notified of the date and time
premises, or during working time off-site; bringing alcohol or drugs
of the hearing and the name of the person who will hear the appeal.
onto Company premises;
The employee has the right to be represented at the appeal hearing as
(11) Bullying, harassment, threats of violence, abusive behaviour, fighting,
outlined above under “Disciplinary Hearings”.
intimidation;
(12) A criminal conviction which in the Company’s opinion renders the
The person hearing the appeal may take the following specific action:
employee unsuitable to continue in his duties;
(13) Undertaking private work on the premises and/or in working hours
without express permission;
(14) Unauthorised access to computer systems and codes. Unauthorised
copying/removal of computer programs, records, data etc.; introducing
a virus into the computer system or network; accessing pornographic,
• Overturn the original decision;
• Uphold the original decision;
• Reduce the penalty imposed; or.
• Increase the penalty imposed.
sexually explicit or illegal media;
The decision of the person hearing the appeal will be final.
(15) Any disclosure under the Public Interest Disclosure Act, which is made
maliciously or which is made without sufficient belief in its validity;
Pending the outcome of an appeal process, the original disciplinary
(16) Any covert recording of meetings or discussions, whether formal (e.g.
decision will stand.
disciplinary or grievance), or informal (e.g. staff, departmental or one
to one) meetings.
This list is not exhaustive.
Alternative sanctions to dismissal (Contractual)
In circumstances where dismissal would be the usual outcome, the
Company reserves the contractual right to impose a lesser sanction, which
could be used alone or in conjunction with a formal warning. Such lesser
sanctions could include one or more of the following:
• Demotion
• Transfer to a different department or job
• Suspension without pay for a defined period
• Non-payment of a bonus or salary increment
Records
The Company will retain information regarding the disciplinary procedure.
It has a legal basis for doing so in respect of its legal obligations or
legitimate interests, specifically, in following a fair disciplinary procedure.
This data will be treated confidentially, and will only be shared with
relevant managers who are involved with your employment, or in any
appeals processes which may arise in connection with the disciplinary
procedure, with members of the HR department, and in some cases,
external HR & Legal Advisors. Further details, including details of your
rights with regard to your personal information, are contained in the Data
Protection Policy (featured elsewhere in this handbook) and the Data
Privacy Notice which has been issued to you separately.
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3.14 Performance Management Procedure
The grievance procedure may not be used to pursue matters relating
to disciplinary decisions. Should an employee be dissatisfied with any
The Company acknowledges that it is more likely to achieve its wider
disciplinary sanction taken, he/she should follow the appeal process as
business objectives by ensuring that all employees have the necessary
contained in the Disciplinary Procedure.
skills and knowledge to perform to the highest level. As such, support and
training will be provided as appropriate in this regard. However, where
Informal steps
support and training are either unsuccessful or not applicable to the
performance issues at hand, an appropriate performance management
process will be followed. That process will reflect the Company’s
disciplinary procedure in terms of the stages involved (i.e. informal
discussion followed by formal meetings as necessary) and action taken
(first written warning, final written warning followed by termination
as necessary). However, where performance issues stem from attitude,
negligence or deliberate wrongdoing, the disciplinary procedure will apply.
The performance management process will apply to all employees
except those still within their probationary period. However, there
may be circumstances in which it will be appropriate for the Company
to bypass or shorten some stages of the procedure depending on the
circumstances or nature of the employee’s role and/or the type and extent
of the performance issue and/or the effect on the business and/or other
employees.
You will have the right of appeal in respect of any formal action taken
under the performance management process.
Where an employee has a complaint or issue, he/she should endeavour
to deal with it informally first, through his/her Manager, or if this is not
appropriate, with the next level of manager or Group HR Manager.
Managers will discuss the concerns, investigate as necessary (ensuring
discretion as appropriate) and attempt to address the concerns fairly and
promptly.
Mediation
At any stage in this procedure, the employee or Manager may suggest
that the concerns be referred for mediation. Mediation is likely to be most
appropriate where the concerns involve relationships with colleagues or
Managers. However, there may be circumstances in which alternative non-
adversarial discussions may be undertaken with the aim of promoting a
speedy resolution.
Mediation is voluntary and will take place only if all parties agree. It is,
however, hoped that all parties will recognise the benefits of seeking to
resolve issues via mediation and will be amenable to and cooperate with
this approach.
Formal steps
3.15 Grievance Procedure
Where the employee has not been able to resolve the matter(s) informally
and/or he/she wishes to formalise the complaint, this should be set out
The purpose of a grievance procedure is to provide employees with a
in writing, and submitted to the supervisor/manager or the next level
framework within which grievances may be resolved to help ensure that
of manager as appropriate. It is the employee’s responsibility to ensure
areas of dissatisfaction are identified, and responded to in a clear, orderly
that any issues, concerns, complaints (“grievances”) are raised without
and fair manner. The procedure itself cannot guarantee the resolution of
undue delay. This first stage requiring the employee to put the concerns in
a particular grievance, as this is dependent upon all concerned parties
writing forms the basis of the subsequent hearing and any investigations,
adopting reasonable attitudes to the problem(s) raised.
so it is important that the nature of the grievance is set out clearly.
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If the grievance is about the Manager, the employee should submit the
Right to be accompanied
written grievance to the next level of Management.
The employee will have the right to be accompanied at any formal
meetings (i.e. grievance hearing and any appeal hearing) by a work
Usually within 5 days of receiving the written grievance the employee will
colleague or an authorised person as defined by current employment
be notified of a time/date of a hearing to discuss the points raised. The
legislation. To exercise this right, the employee must make a reasonable
employee should make every endeavour to attend the hearing.
request. What is reasonable will depend on the circumstances of each
In certain circumstances, e.g. due to logistical and/or geographical issues,
meeting and to ask questions, but will not be allowed to answer questions
individual case. An authorised person will be allowed to address the
meetings/hearings may be held via telephone or video-link.
on the employee’s behalf. Management may at their discretion, arrange
for another person to be present at any grievance hearing. The employee
The Company may, on occasion, devolve responsibility for disciplinary and
and any accompanying person should make every effort to attend the
grievance investigations and/or hearings to external consultants. Where
this is necessary, the consultant will adhere to the relevant Company
policies and procedures.
hearing.
Records
On occasion the Company may make audio recordings of meetings
or hearings. Similarly, you are forbidden from making such recordings
without prior written consent from the hearing officer and/or Group
HR Manager. If you are found to be covertly recording or to have made
a covert recording, you may be subject to disciplinary action up to and
including dismissal.
After listening to the grievance, undertaking any further investigation as
necessary and fully considering all the facts, the Manager will notify the
employee in writing of the outcome, giving him/her the opportunity to
appeal against the decision or lack of decision.
Outcome
The employee will be advised of the decision regarding the grievance in
writing. Where the grievance has not been upheld, the employee will have
the right of appeal.
Right of Appeal
The employee will need to submit the grounds of his/her appeal in writing
to the person indicated on the outcome letter within five working days of
being notified. An appeal hearing will then be held. The decision at appeal
is final.
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The Company will retain information regarding issues dealt with under the
Grievance Procedure. It has a legal basis for doing so in respect of its legal
obligations or legitimate interests, specifically, ensuring that the Company
follows a fair grievance procedure. This data will be treated confidentially,
and will only be shared with relevant managers who are involved with
your employment, or in any disciplinary or appeals processes which may
arise in connection with the Grievance Procedure, with members of the
HR department, and in some cases, external HR & Legal Advisors. Further
details, including details of your rights with regard to your personal
information, are contained in the Data Protection Policy (featured
elsewhere in this handbook) and the Data Privacy Notice which has been
issued to you separately.
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3.16 Public Interest Disclosures (“Whistle-Blowing”)
Finally…
The Public Interest Disclosure Act 1998 makes provision about the kinds
have any queries or concerns with any aspect of the Handbook, please
of disclosures which may be protected, the circumstances in which such
direct these to your immediate manager as soon as possible.
We hope that you have found this Employee Handbook useful. If you
disclosures are protected and the persons who may be protected. These
are called “qualifying disclosures”. A qualifying disclosure is one made in
the public interest by a worker who has a reasonable belief that one of
the following sets of circumstances exists:
As we stated at the beginning of this Handbook, Justrite has been a strong
performer in our industry for more than a century, and we believe our
associates have and continue to be the key to our success. We hope you
will find your work to be both challenging and rewarding. We are glad you
• A criminal offence has been committed, is being committed or is likely to
have joined our team!
be committed. Examples of such are fraud, bribery or corruption.
• A person has failed, is failing or is likely to fail, to comply with any legal
obligation to which he is subject.
• A miscarriage of justice has occurred, is occurring or is likely to occur.
• The health and safety of any individual has been, is being, or is likely to
be endangered.
• The environment has been, is being or is likely to be damaged.
• Information tending to show any matter falling within any one of the
preceding paragraphs has been, is being, or is likely to be deliberately
concealed.
If an employee wishes to raise or discuss any issues that might fall into
the above categories, he/she should contact a Company Director who will
treat the matter in confidence.
You should be aware that this policy will apply where the employee
reasonably believes that the information disclosed and any allegation
contained in it, is substantially true. If any disclosure concerns information
which the employee does not substantially believe to be true, or if the
disclosure is made maliciously, then such a disclosure will constitute a
disciplinary offence and may constitute Gross Misconduct for which
summary dismissal is the sanction.
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We encourage you to carefully read this Handbook, as
well as our Global Code of Conduct and refer to them both
often for guidance. JSG’s outstanding reputation rests on
how each of us conducts ourselves and how we conduct
ourselves collectively as an organization.
For questions about our Associate Handbook, please
contact:
JSG Human Resources
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