GLOBE GROUP - Site Operatives Induction & Health Surveillance

Title Page

Site conducted
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Employee name
Date of Induction
Inducted by
Location
Trade
Your Address
Your Contact Number
Date of Birth
Sex
Nationality
Emergency contact name & number
Relationship
Medical condition(s)

Personal Details

Hand arm Vibration Questionnaire

Date of previous HAVS screening (if completed)
Have you been using hand held vibrating tools, machines, or hand fed processes in your job, (IF NO, OR MORE THAN 2 YEARS SINCE LAST EXPOSURE - NO NEED TO ANSWER FURTHER IN THIS SECTION.
Do you have any numbness or tingling of the fingers lasting more than 20 minutes after using vibrating equipment?
Do you have any numbness or tingling of the fingers at any other time?
Do you wake at night with pain, numbness, or tingling in your hands or wrists?
Have any of your fingers gone white with cold exposure? (Whiteness means a clear discolouration of the fingers with a sharp edge, usually followed by a red flush).
Have you noticed any change in your response to your tolerance of working outdoors in the cold?
Are you experience any other problems in your hands or arms?
Do you have difficulty picking up very small objects, eg screws or buttons or opening tight jars?
Has anything changed about your health since the last assessment?
I certify that all the answers given are true to the best of my knowledge and belief.

Medical Questionnaire

Do you have any injuries or orthopedic problems (back, knees, shoulders, etc)?
Do you suffer from impaired vision (long or short sighted)?
Do you have any difficulty in hearing in normal conditions?
Do you have any known cardiovascular problems (abnormal ECG, previous heart attack, etc)?
Do you suffer from any respiratory illness (COPD, etc) or have problems with breathing when completing work activities?
Do you suffer with any skin issues (dermatitis)?
Have you ever been advised by a doctor, physician or specialist not to perform any type of exercise/activity?
Do you have any other medical condition, injury, or anything else we should be aware of?

To be completed by operative

I am able to communicate in English and understand health and safety signs or indicators
I have been briefed by my supervisor on the risk assessments and method statements regarding my work, and I understand and will comply with the required safe systems of work
I will not put myself or others at risk of harm as a result of my acts.
I am aware that I need to report ALL accidents, incidents, and near misses to the Site Management team
I understand, and will abide by the Site Rules (Including signing in and out on a daily basis)
I have been advised of the location of the welfare facilities and the fire assembly point
I am over the age of 18 and have no medical conditions which will affect my or others safety whilst working
Note 1: If under 18 – a separate risk assessment is needed
Note 2: Medical conditions

Sign Off

Inductee Name and Signature

Manual Handling

Nearly all tasks involve manual handling. This can mean lifting and carrying, pushing or pulling a range of objects. Some manual handling injuries may develop over a period of time rather than being the result of a single accident. Other injuries from manual handling include bruises, cuts, hernias, wrenched shoulders and crushed limbs.
Back injuries, are a major concern for manual handling operations and can be caused by bad handling techniques. If a load is lifted with the back in the wrong position, the lower back will take a lot of pressure. It is not designed to take this strain and may be damaged as a result.
It is not just lifting that causes strain. Over reaching and twisting when moving objects can also lead to injury.
Before lifting assess the weight of a load. Can manual handling of the object be avoided, and lifting machinery or aids be used instead? If not, do you need help in moving the load? If more than one person will be involved, you must work as a team with one person supervising the lift.
Assess the need for protective clothing. Should you be wearing gloves to protect your hands, or steel capped boots on your feet, or any other protective clothing?
Stop and think- PLAN THE LIFT. Where is the load to be placed? Use appropriate handling aids if possible. Do you need help with the load? Remove obstructions such as discarded wrapping materials. For a long lift, such as floor to shoulder height, consider resting the load mid-way on a table or bench to change grip.
Position the feet
Feet apart, giving a balanced and stable base for lifting (tight clothing and unsuitable footwear make this difficult). Leading leg as far forward as is comfortable and if possible, pointing in the direction you intend to go.
Adopt a good posture
When lifting from a low level, bend your knees. But do not kneel or overflex the knees. Keep the back upright, maintaining its natural curve (tucking in the chin helps). Lean forward a little over the load if necessary to get a good grip. Keep the shoulders level and facing in the same direction as the hips.
Get a firm grip
Try to keep the arms within the boundary formed by the legs. The best position and type of grip depends on the circumstances and individual preference; but must be secure. A hook grip is less tiring than keeping the fingers straight. If you need to vary the grip as the lift proceeds, do it as smoothly as possible.
Keep close to the load
Keep the load close to the trunk for as long as possible. Keep heaviest side of the load next to the trunk. If a close approach to the load is not possible, slide it towards you before trying to lift.
Don’t jerk - Lift smoothly, raising the chin as the lift begins, keeping control of the load.
Move the feet - Don’t twist the trunk when turning to the side.
Put down first, then adjust
If precise positioning of the load is necessary, put it down first, then slide it into the desired position.
If in doubt, get help.
NEVER put your health at risk - if you’re unsure, always ask for assistance.
SLD carry out on-site manual handling training assessments, records of which will be held on file. Below is a list of general products that are used by SLD that will be lifted as part of routine works, The Manual handling hierarchy as set out above will be followed at all times. SLD provide lifting and moving equipment to enable materials to be moved from place to place, always ensure that lifting / moving equipment is NEVER overloaded – if you are unsure – ASK YOUR SUPERVISOR!!
I understand that i must assess all loads prior to moving, pushing, or pulling any item, and use mechanical means (where possible) safely and within the Safe Working Limitations.

Competency / Qualifications

Please tick and provide photos (FRONT AND REAR) of relevant Training:
CSCS
CISRS
SSSTS/SMSTS
First Aid
Asbestos Awareness
Abrasive Wheel
Telescopic Handler
CCDO
Working At Height and Harness
Confined Spaces
Traffic Banksman
Fire Marshall
Slinger Signaller
Transporting Loads
Mobile Boom
Scissor Lift
Static Boom
Driving licence
If you hold any other qualification ensure that the office is aware and holds a copy for office records.

Health and Safety Policy Procedure

The following items have been explained to the inductee; (Policies can be found in the central drive/6. Important documents/H&S policies)

Allocation of Safety Responsibilities on site.
The Company’s Health Safety Policy & Procedures. ( H&S, Manual Handling, COSHH, Driving, etc).
The company's policy suite (Environmental & sustainability, Equal opportunity & DDA, Anti bribery & corruption, Anti slavery & human trafficking, Drugs & alcohol, Driving for work, etc)
Task Specific Method Statements & Relevant parts of the Construction Phase Plan
No deviation of the Method Statements, Risk/ COSHH Assessments without first consulting the Site Supervisor/ Contracts Manager and permission has been given in writing i.e. appropriate changes have been made to the relevant paper work.
Site Specific Rules
General Hazards in and around the Work area
Fire and Emergency Procedures (including the location of Fire Assembly Point and Fire Extinguisher location/ use)
First Aid – Names and Locations of First Aiders, Location of First Aid Facilities and rules for their use
Follow manual handling hierarchy as set out in manual handling training/assessments and use mechanical means where possible.
Use Protective Clothing and Equipment in the correct manner and store/maintain in good condition.
Procedures for Reporting Accidents, Injuries and Near Misses.
Welfare- Location of Canteen, Toilets, Dry Room etc and other Welfare matters.
The Importance of Hygiene and Health.
Smoking Area

Completion

Name and Signature

Site Rules

1. All visitors and deliveries to report to Site office.
2. All personnel working on this site must have a CSCS Card or equivalent, and they must demonstrate competency for the work they are carrying out.
3. All operatives must receive a site induction into the specific Method Statement and risk assessments for their work areas.
4. Hard hats, high visibility jackets, safety footwear and gloves are mandatory, along with any other necessary Personal Protective Equipment as identified by way of Risk Assessment.
5. No parking on site without prior permission.
6. No unauthorised persons on this site.
7. Working hours on site are:
• 7:30am – 5:00pm Monday – Friday
• 7:30am – ........... (specific to site and contract - to be agreed)
• No working on Sundays or Public Holidays unless approved by the management
8. First Aid facilities are located in the Site office, and also company vehicles..
9. Materials must be stored in agreed locations and in an approved manner.
10. All rubbish and waste materials to be deposited in skips provided.
11. Please use Welfare facilities provided:
• Food must not be consumed on the working site.
12. Accidents must be reported immediately to the Project/Site Manager, and entered into the site accident book.
13. Only those with competency training certificates will be permitted to operate mobile plant or equipment.
14. Safe access must be maintained to all working areas.
15. Under no circumstances are fences, hoarding, or barriers to be moved / adapted without authorisation.
17. Trailing electrical cables are to be avoided as far as possible.
18. All tools used on site must be 110v or less.
29. Shirts and long trousers must be worn.
20. Smoking only permitted in designated areas.
21. Mobile phones should not be used if Health and Safety is compromised.
22. No under 18’s should work on the site without prior consent from the Director, and an appropriate risk assessment in place.
Name & signature

Sub Contractor Details

Sub-contractor verification details

Trading Name
Full Name
Date of Birth
Registered Address / Post code
Contact No:
NI Number
UTR Number
CSCS no.
Email Address
Date
HMRC contact number 0845 366 7899
Sub-contractor signature

Bank details

Bank name:
Account no:
Sort code:
NB: bank details are to be completed and provided to your Site Supervisor PRIOR to the first Friday of work commencement. Failure to supply will result in payment delay.

PPE (Personal Protective Equipment) issued Register

Hard hat
Hi - Visibility clothing
Ear defenders
Safety glasses
Gloves
R.P.E. / Dust protection
Foul weather gear
Foot protection
Harness
Other
Date issued/ checked
Signed
Checked by? Name and Signature

Training Policy

We will not allow anyone on site if they do not hold an in date CSCS card. Plant operatives must only operate items of plant and equipment that they hold competency evidence for. Anyone caught completing tasks without the appropriate competency evidence will be reprimanded.
Any training provided will be held on our records and you will be provided with a copy. If you decide to leave within a year of the training start date you will be liable for the cost of the training. You will be entitled to keep the training evidence however you will have to provide us with payment to cover the training completed. Manual handling training will be carried out on site and you must ensure that you are aware of the procedure for manual handling (assessing the weights of items etc) as set out in the H&S policy.
To accept the terms and conditions of this policy please sign and date below.
I agree to the above training policy

PPE Policy

The business takes its employees health extremely seriously and have many measures to ensure that employees are safe whilst working. One of these measures is ensuring every employee is provided with top quality Personal Protective Equipment. We ensure that the appropriate PPE is provided for the job with hard hats, gloves, glasses and hi-vis jackets being an essential. We will not allow anyone to neglect site rules regarding PPE as they are put in place to protect your personal health. Distributed PPE is recorded and we expect operatives to look after and maintain the PPE that is issued to them. If PPE is lost or damaged because of misuse, the cost of the PPE will be stopped from the operative’s wages. When RPE (Respiratory Protective Equipment) is provided, Operatives must be clean shaven and take a compulsory face fit test to ensure that the RPE provided is suitable and sufficient. Failure to shave for religious (or other) reasons, SLD (on request and prior agreement) will provide the operative with full face RPE, but will cover the cost up to £20, the residue will be deducted from the operatives wages at source. We have created this policy to ensure that safety is taken seriously and so is the PPE.
If you decide to stop working for the business the PPE issued will need to be returned, or paid for in full.
To accept the terms and conditions of this policy please sign and date below.
I agree to the above PPE policy

COSHH Assessment

You MUST ; Ensure that there is a COSHH Assessment in place for the substance you are using, read the label; never use substances without labelling or identification on the packaging and fully understand the information stated. You know how to use and handle the substance i.e. what harm it may cause, if any, and the potential routes of entry i.e. inhalation, absorption, ingestion etc.
You fully understand never to mix substances, know how to store correctly, and understand what to do if the substance leaks, spills to ground or escapes to the air.
You agree to wear the Personal Protective Equipment stated COSHH risk assessment and work in accordance with work methods and safe systems of work.
You know what the first aid measures are, and agree not to eat, drink or smoke when using hazardous substances.
I agree to the above COSHH statement

Safe Driving Policy Statement

There are procedures in place to minimize, as far as reasonably practicable, the likelihood that operatives are injured in road traffic accidents while on company business.
While driving vehicles on company business, all staff must comply with traffic legislation, be conscious of road safety and demonstrate safe driving and other good road safety habits. The following actions on company business will be viewed as serious breaches of conduct and dismissal may be a consequence:
• Drinking or under the influence of drugs while driving.
• Driving while disqualified, or not correctly licensed or insured.
• Reckless or dangerous driving causing death or injury.
• Failing to stop after a crash
• Using hand-held mobile while driving a vehicle.
• Smoking whilst driving a company vehicle.
• Any actions that warrant suspension of a license
You must allow adequate time in the planning of road journeys and that staff cease driving immediately if they feel the onset of tiredness, and ensure that all vehicles used on company business meet EU safety standards and are maintained in accordance with the manufactures maintenance schedule.
You must not drive under conditions which are unsafe and/or likely to create an unsafe environment, physical distress, fatigue, etc and where necessary will arrange specific driver training.
Mobile phones (other than hands-free) must not be used while driving, with the use of hands-free mobile phones being strongly discouraged while driving.
I agree to the safe driving policy

Drug and Alcohol Policy Statement

It is recognized that both the health of the individual and safety in the work place are paramount in achieving the goals of the business as a whole.
The policy sets out our approach to Drugs and Alcohol, enabling us to both comply with the requirements of the Health & Safety at Work Act 1974, the Misuse of Drugs Act 1971, the Medicines Act 1968, the Transport and Works Act 1992 and where relevant the Railways (Safety Critical Work) Regulations 1994 and any future legislative requirements that involve the misuse of Drugs and/or Alcohol.
The policy statement requires all employees, sub-contractors or any other persons working at or visiting a site controlled by or being worked on regardless of their job function;
• Must not come to work in an unfit state due to the influence of drugs and alcohol.
• Must not bring illegal drugs or alcohol onto a site controlled by or being worked on. Anybody found in possession could be liable to the Company disciplinary procedure. For clarity any alcohol such as normal shopping where there was no intention of using the substance on the premises is exempt from this rule.
• Must not cover up or collude with colleagues whose behaviour and performance is or could be affected by taking illegal or medical drugs or consumption of alcohol.
• Must check with their doctor, Practice Nurse, Occupational Health or Pharmacist about the side effects of prescribed medication.
• Must inform their supervisor or manager if you are taking medication (whether prescribed or bought over-the-counter) that may affect their ability to carry out their job.
• Must not discontinue an agreed course of treatment for a drug or related problem without good reason.
• Must never drive or operate machinery if they are affected by or believe they are affected by drugs, alcohol, and prescribed medication or over the counter medication.
• Must tell their supervisor/ manager, Health & safety Department if they believe they have or may have a drug or alcohol related problem.
• Must undergo testing for drugs or alcohol when requested to do so by our approved testing agency.
I agree to the drug and alcohol policy

Environmental Policy

The scope of registration and approval for the environmental system covers the provision of construction and recycling.
It is recognized that all activated, products and services within the defined scope of our environmental management system can cause impacts on the environment. We are committed to operating our business responsibly; we will comply with or exceed all applicable legal and other requirements, which relate to our environmental aspects and we will do all we can to prevent the incidence of pollution wherever possible. It is our declared policy to operate with and to maintain good relations with all regulatory bodies, to minimize any significant environmental impacts of new developments through the use of integrated environmental management procedures and planning and to set an example of leadership in the field of environmental management.
It is our policy to take all reasonably practicable steps to meet and exceed all necessary requirements and to continually improve both our environmental performance and environmental management system through the implementation of the following:
• Assessing and regularly re-assessing the environmental effects of our activities
• Use of continuous improvement techniques and procedures
• Training of employees in environmental issues
• Minimizing the production of waste
• Minimizing material wastage
• Minimizing energy wastage
• Promoting the use of recyclable and renewable materials
• Reducing and/ or limiting the release of pollutants to water, land, and air
• Controlling noise and dust emissions from operations
• Minimizing the risk to the general public and employees from the operations and
activities are undertaken by the business.
This will be achieved by-
• Commitment to the continuous improvement of our processes through the development of environmental performance evaluation procedures and associated indicators so as to minimize any adverse impact on the environment.
• Seeking practical ways of reducing emissions to land, air, and waterways through the adoption of sound practices that will include the reduction of material waste, energy consumption, recycling and consideration of alternative processes.
• Training and communication – each employee will be encouraged to take personal responsibility to minimize their adverse impact on the environment.
• Actively promoting energy-efficient products, processes, and systems to our clients and subcontractors
• Managing energy efficiency through appropriate investment in processes, controls and continuous improvements
• Promoting the recycling of products, packaging, and materials
• Providing support and advice to staff, suppliers and other stakeholders on environmental matters relating to our operations and ensuring that all staff and subcontractors are made aware of this policy and associated procedures concerning our impact on the environment.
• Monitoring, auditing and reviewing our performance, and ensuring this policy is reviewed for continuing suitability during the management review process.
This policy is available to the public on request.
I agree to the environmental policy

Anti Slavery & Human Trafficcing

This policy applies to all persons working for us on our behalf in any capacity, including employees at all levels such as directors, Managers, Supervisors, General operatives, Office employees, contractors and suppliers.

The business strictly prohibits the use of human trafficking and modern slavery in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of it supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.
Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view that the person in question is being exploited. Modern slavery and human trafficking is a crime and violates fundamental human rights.

Commitments

We are a company that expects everyone with us or on our behalf to support and uphold the following measures to safeguard against modern slavery.

• We have a zero-tolerance approach to modern slavery in our organisation or supply chain. • The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy. • We are committed to engaging with our stakeholders and supplier to address the risk of modern slavery in our operations and supply chain. • We take a risk based approach to our contracting process and keep them under review. We will assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with any third parties. With our risked based approach, we may also assess the merits of writing to suppliers requiring them comply with our code of conduct, which sets out the minimum standards required to combat modern slavery and trafficking. • Consistent with our risk based approach we may require: • to our organisation to confirm their compliance with our code of conduct.
• Suppliers engaging workers through third party to obtain that third parties agreement to adhere to the code. • As part of ongoing risk assessment due to diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our code of conduct. • If we find that other individuals or organisations or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and weather that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.
I agree to the anti slavery and human trafficcing policy

Anti Bribery & Anti corruption Policy

This anti-bribery policy exists to set out the responsibilities of the business and those who work for us in regards to observing and upholding our zero-tolerance position on bribery and corruption. • It also exists to act as a source of information and guidance for those working for the business. It helps them recognise and deal with bribery and corruption issues, as well as understand their responsibilities. We are committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented. the business has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate. • will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in regards to our conduct both at home and abroad. • the business recognises that bribery and corruption are punishable by up to ten years of imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business, and take our legal responsibilities seriously. This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK). The policy also applies to Officers, Trustees, Board, and/or Committee members at any level. • In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties. • Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery and corruption. Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision. A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage. • Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law. • Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company’s compliance manager. What is and what is NOT acceptable This section of the policy refers to 4 areas: 1. Gifts and hospitality. 2. Facilitation payments. 3. Political contributions. 4. Charitable contributions. the business accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements: It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits. • It is not made with the suggestion that a return favour is expected. • It is in compliance with local law. • It is given in the name of the company, not in an individual’s name. • It does not include cash or a cash equivalent (e.g. a voucher or gift certificate). • It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion). • It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift. • It is given/received openly, not secretly. • It is not selectively given to a key, influential person, clearly with the intention of directly influencing them. • It is not above a certain excessive value, as pre-determined by the company’s compliance manager (usually in excess of £100). • It is not offer to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s compliance manager. • Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is declared to the compliance manager, who will assess the circumstances. •the business recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each. • As good practice, gifts given and received should always be disclosed to the compliance manager. Gifts from suppliers should always be disclosed. The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the compliance manager should be sought. • Facilitation Payments and Kickbacks - the business does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action. • the business does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage. • the business recognises that, despite our strict policy on facilitation payments and kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may put their/their family’s personal security at risk. Under these circumstances, the following steps must be taken: • Keep any amount to the minimum. • Ask for a receipt, detailing the amount and reason for the payment. • Create a record concerning the payment. • Report this incident to your line manager. • Political Contributions – the business will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage. • Charitable Contributions –the business accepts (and indeed encourages) the act of donating to charities – whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes. • Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery. • We will ensure that all charitable donations made are legal and ethical under local laws and practices, and that donations are not offered/made without the approval of the compliance manager. Employee Responsibilities • As an employee of the business , you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other antibribery and corruption information you are given. • All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy. • If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify the compliance manager. • If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. the business has the right to terminate a contractual relationship with an employee if they breach this anti-bribery policy. What happens if I need to raise a concern? This section of the policy covers 3 areas: 1. How to raise a concern. 2. What to do if you are a victim of bribery or corruption. 3. Protection. 1. How to raise a concern • If you suspect that there is an instance of bribery or corrupt activities occurring in relation to the business, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behaviour can be considered bribery or corruption, you should speak to your line manager, the compliance manager, the director, or the Head of Governance and Legal. • the business will familiarise all employees with its whistleblowing procedures so employees can vocalise their concerns swiftly and confidentially. 2. What to do if you are a victim of bribery or corruption: • You must tell your compliance manager as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity. 3. Protection: • If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery or corruption, the business understands that you may feel worried about potential repercussions. the business will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken. • the business will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption. • Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised. • If you have reason to believe you’ve been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform your line manager or the compliance manager immediately. Training and communication • the business will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked annually to formally accept that they will comply with this policy. •the business anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third-parties at the outset of business relations, and as appropriate thereafter. •the business will provide relevant anti-bribery and corruption training to employees etc. where we feel their knowledge of how to comply with the Bribery Act needs to be enhanced. As good practice, all businesses should provide their employees with antibribery training where there is a potential risk of facing bribery or corruption during work activities. Record keeping • the business will keep detailed and accurate financial records, and will have appropriate internal controls in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts and acts of hospitality are subject to managerial review. Monitoring and reviewing • the business compliance manager is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness. • Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice. • Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the compliance manager. • This policy does not form part of an employee’s contract of employment and the business may amend it at any time so to improve its effectiveness at combatting bribery and corruption.
I agree to the anti bribery and anti corruption policy