ANTI-CORRUPT ION AND BRIBERY POLICY
Vigilo Security Limited (hereinafter known as “the Company”) conducts all of its business in an honest and ethical manner. The Company takes a zero-tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all its business dealings and relationships, and implements and enforces effective systems to counter bribery. The Company will uphold all laws relevant to countering bribery and corruption, including the Bribery Act 2010.
Bribery and corruption are punishable for individuals by up to ten years' imprisonment and if the Company is found to have taken part in corruption it could face an unlimited fine, be excluded from tendering for public contracts and face damage to its reputation. The Company therefore takes its legal responsibilities very seriously.
In this policy, third party means any individual or organisation you come into contact with during the course of your work for the Company, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.
Who is covered by the policy?
This policy applies to all individuals working at all levels and grades, including senior managers, engineers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with the Company, or any of the Company’s sub-contractors or their employees, wherever located (collectively referred to as workers in this policy).
What is bribery?
A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.
Examples:
offering a bribe
You offer a potential client tickets to a major sporting event, but only if they agree to do business with the Company.
This would be an offence as you are making the offer to gain a commercial and contractual advantage. The Company may also be found to have committed an offence because the offer has been made to obtain business for the Company. It may also be an offence for the potential client to accept your offer.
receiving a bribe
A supplier gives your nephew a job, but makes it clear that in return they expect you to use your influence in the Company to ensure the Company continues to do business with them.
It is an offence for a supplier to make such an offer. It would be an offence for you to accept the offer as you would be doing so to gain a personal advantage.
Gifts and hospitality
This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties.
The giving or receipt of gifts is not prohibited, if the following requirements are met:
it is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits;
it complies with UK law;
it is given in the Company’s name, not in your name;
it does not include cash or a cash equivalent (such as gift certificates or vouchers);
it is appropriate in the circumstances. for example, small gifts at Christmas time;
taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time; and
it is given openly, not secretly.
Gifts should not be offered to, or accepted from, government officials or representatives, or politicians or political parties, without the prior approval of your line manager.
What is not acceptable? (see also Potential risk scenarios: ‘red flags’ Section of this Policy)
It is not acceptable for you (or someone on your behalf) to:
give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given.
give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to "facilitate" or expedite a routine procedure.
accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them.
accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by the Company in return.
threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy.
engage in any activity that might lead to a breach of this policy.
Your responsibilities
You must ensure that you read, understand and comply with this policy.
The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for the Company or under the Company’s control. All workers are required to avoid any activity that might lead to, or suggest, a breach of this policy.
You must notify your line manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. For example, if a client or potential client offers you something to gain a business advantage with the Company, or indicates to you that a gift or payment is required to secure their business. Further "red flags" that may indicate bribery or corruption are set out below.
Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct.
Record keeping
You must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review.
You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with the Company’s expenses policy and specifically record the reason for the expenditure.
How to raise a concern
You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised with your line manager. Concerns should be reported by following the procedure set out in the Company’s public interest disclosure (whistleblowing) policy.
What to do if you are a victim of bribery or corruption
It is important that you tell your line manager as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity.
Protection
Workers who refuse to accept or offer a bribe, or those who raise concerns or report another's wrongdoing, are sometimes worried about possible repercussions. The Company aims to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken.
The Company are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform your line manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our grievance procedure.
Potential risk scenarios: ‘red flags’
The following is a list of possible red flags that may arise during the course of you working for the Company and which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only.
if you encounter any of these red flags while working for the Company, you must report them promptly to your line manager:
you become aware that a third party engages in, or has been accused of engaging in, improper business practices;
you learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them;
a third party insists on receiving a commission or fee payment before committing to sign up to a contract with the Company, or carrying out a government function or process for the Company;
a third party requests payment in cash and/or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made;
a third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business;
a third party requests an unexpected additional fee or commission to "facilitate" a service;
a third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;
a third party requests that a payment is made to "overlook" potential legal violations;
a third party requests that you provide employment or some other advantage to a friend or relative;
you know or suspect there is falsification within the Company accounts or other records.
you receive an invoice from a third party that appears to be non-standard or customised;
a third party insists on the use of side letters or refuses to put terms agreed in writing;
you notice that the Company has been invoiced for a commission or fee payment that appears large given the service stated to have been provided;
a third party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us;
You are offered an unusually generous gift or offered lavish hospitality by a third party.
You notice that there are donations to charities that either exceed amounts agreed or may breach legislation on such donations.
You know or suspect any other activity that may result in a conflict of interest or bring into question the honesty and integrity of the Company.
ANTI-HARASSMENT POLICY
Policy statement
The Company seeks to provide a work environment in which all employees are treated with respect and dignity and that is free of harassment and bullying based upon an employee's race, colour, ethnic origin, nationality, national origin, religion or belief, sex, sexual orientation, gender reassignment, age, marital or civil partnership status or disability.
Employees must not harass, bully or intimidate other employees on these grounds. Such harassment not only contravenes the Company's policy but it may also constitute unlawful discrimination. Such behaviour will be treated as potential gross misconduct under the Company's disciplinary procedure and could render the employee liable to summary dismissal. Employees should bear in mind that they can be held personally liable for any act of unlawful harassment. Employees who commit serious acts of harassment may also be guilty of a criminal offence.
All employees are responsible for conducting themselves in accordance with this policy and the Company will not condone or tolerate any form of harassment, bullying or intimidation, whether engaged in by employees or by outside third parties who do business with the Company.
Employees should draw the attention of their line manager to suspected cases of harassment, bullying or intimidation. They must not victimise or retaliate against an employee who has made allegations or complaints of harassment or who has provided information about such harassment. Such behaviour will be treated as potential gross misconduct under the Company's disciplinary procedure. Employees should support colleagues who suffer such treatment and are making a complaint.
This policy covers bullying and harassment in the workplace and in any work-related setting outside the workplace, for example, business trips and work-related social events.
Bullying and harassment
Bullying is offensive or intimidating behaviour or an abuse or misuse of power which undermines or humiliates an employee.
Harassment occurs where, on the ground of an employee’s race, colour, ethnic origin, nationality, national origin, religion or belief, sex, sexual orientation, gender reassignment, age, marital or civil partnership status or disability, a person engages in unwanted conduct that:
• Has the purpose of violating the employee’s dignity at work, or of creating an intimidating, hostile, degrading, humiliating or offensive work environment for the employee; or
• Is reasonably considered by the employee to have the effect of violating his or her dignity at work, or of creating an intimidating, hostile, degrading, humiliating or offensive work environment for the employee, even if this effect was not intended by the person responsible for the conduct.
Conduct may be harassment whether or not the person intended to offend. Something intended as a ‘joke’ or as ‘office banter’ may offend another person. This is because different employees find different levels of behaviour acceptable and everyone has the right to decide for themselves what behaviour they find acceptable to them.
Behaviour which a reasonable person would realise would be likely to offend an employee will always constitute harassment without the need for the employee having to make it clear that such behaviour is unacceptable, for example, touching someone in a sexual way. With other forms of behaviour, it may not always be clear in advance that it will offend a particular employee, for example, office banter and jokes. In these cases, the behaviour will constitute harassment if the conduct continues after the employee has made it clear, by words or conduct, that such behaviour is unacceptable to him or her. A single incident can amount to harassment if it is sufficiently serious.
Harassment also occurs where, on the ground of the employee’s rejection of or submission to unwanted conduct of the kind specified above, a person treats the employee less favourably than he or she would treat him or she had he or she not rejected, or submitted to, the unwanted conduct.
Examples
Bullying and harassment may be verbal, non-verbal, written or physical. Examples of unacceptable behaviour covered by this policy include, but are not limited to, the following:
• Unwelcome sexual advances, requests for sexual favours, and other conduct of a sexual nature.
• Subjection to obscene or other sexually suggestive or racist comments or gestures.
• The offer of rewards for going along with sexual advances or threats for rejecting sexual advances.
• Jokes or pictures of a sexual or racial nature.
• Demeaning comments about an employee’s appearance.
• Questions about a person’s sex life.
• The use of nick names related to an employee’s sex, sexual orientation, gender reassignment, race, religion, age or disability.
• Picking on or ridiculing an employee.
• Isolating an employee or excluding him or her from social activities or relevant work related matters.
Reporting and investigation of complaints
All allegations of harassment or bullying will be dealt with seriously, confidentially and speedily. The Company will not ignore or treat lightly grievances or complaints of harassment from members of a particular race, colour, ethnic origin, nationality, national origin, religion or belief, sex, sexual orientation or age or from employees, who have undergone gender reassignment, are married, have entered into a civil partnership or have a disability.
While the Company encourages employees who believe they are being harassed or bullied to notify the offender (by words or by conduct) that his or her behaviour is unwelcome, the
Company also recognises that actual or perceived power and status disparities may make such confrontation impractical.
In the event that such informal, direct communication between employees is either ineffective or impractical or the situation is too serious to be dealt with informally, the following steps should be followed in reporting a complaint of harassment or bullying:
1. Any employee who believes he or she has been or is being harassed or bullied in violation of this policy, or who wishes to report an incident of harassment or bullying, should report the situation to their line manager. If the employee does not wish to speak to their line manager, they can instead speak to an alternative manager or to a member of the Personnel Department.
2. Such reports should be made promptly so that investigation may proceed and any action taken expeditiously.
3. All allegations of harassment or bullying will be taken seriously. The allegation will be promptly investigated and, as part of the investigatory process, the employee will be interviewed and asked to provide a written witness statement setting out the nature and details of the incident or complaint and the basis for it. Confidentiality will be maintained during the investigatory process to the extent that this is practical and appropriate in the circumstances. However, in order to effectively investigate an allegation, the Company must be able to determine the scope of the investigation and the individuals who should be informed of or interviewed about the allegation. For example, the identity of the complainant and the nature of the allegations must be revealed to the alleged harasser so that he or she is able to fairly respond to the allegations. The Company reserves the right to arrange for another manager to conduct the investigation other than the manager with whom the employee raised the matter.
4. The Company will also invite the employee to attend at least one meeting at a reasonable time and place at which his or her complaint can be discussed and the employee must take all reasonable steps to attend that meeting. The employee has the right to be accompanied at that meeting by either a trade union official or a fellow employee of their choice.
5. Once the investigation has been completed and after the meeting with the employee has taken place, the employee will be informed in writing of the outcome and the Company's conclusions and decision as soon as possible. The employee will also be notified in writing of his or her right to appeal against the Company’s decision if he or she is not satisfied with it. The Company is committed to taking appropriate action with respect to all complaints of harassment or bullying which are upheld. If appropriate, disciplinary proceedings will be brought against the alleged harasser (see below).
6. If the employee wishes to appeal against the Company’s decision, he or she must appeal in writing to a more senior manager or to a Director of the Company within five working days of the Company’s decision. On receipt of such a request, a more senior manager or a Director (who may not be the person to whom the employee addressed their appeal) shall make arrangements to hear the appeal at an appeal meeting and at that meeting the employee may again, if they wish, be accompanied by either a trade union official or a fellow employee of their choice. The employee must take all reasonable steps to attend that meeting. Following the meeting, the relevant manager or Director will inform the employee in writing of the Company’s final decision on the employee’s appeal.
7. If an employee’s complaint is upheld and the harasser remains in the Company’s employment, the Company will take all reasonable steps to ensure that the employee does not have to continue to work alongside the harasser if he or she does not wish to do so. The Company will discuss the options with the employee.
8. If an employee’s complaint is not upheld, arrangements will be made for the employee and the alleged harasser to continue or resume working and to repair working relationships.
9. Employees will not be penalised or victimised for raising a complaint, even if it is not upheld, unless the complaint was both untrue and made in bad faith.
10. Alternatively, the employee may use the Company’s grievance procedure to make a complaint.
Disciplinary action
Any employee of the Company who is found to have harassed another employee in violation of this policy will be subject to appropriate disciplinary action under the Company's disciplinary procedure. Such behaviour may be treated as potential gross misconduct and could render the employee liable to summary dismissal.
In addition, line managers who had knowledge that such harassment had occurred in their departments but who had taken no action to eliminate it will also be subject to disciplinary action under the Company's disciplinary procedure.
Training
The Company will take such measures as may be necessary to ensure the proper training, supervision and instruction to enable line managers to deal more effectively with complaints of bullying and harassment.
The Company will also provide training to all employees to help them understand their rights and responsibilities under this policy and what they can do to create a work environment that is free of bullying and harassment.
SOCIAL & CORPORATE RESPONSIBILITY
The company as part of its ambitious vision of a corporate socially aware modern security industry, has implemented far reaching initiatives designed to minimise the impact of its trading activities on society, economy and the environment.
The company we believe that doing business in a responsible, sustainable way goes hand in hand with doing business successfully.
We recognise that we must integrate our business values and operations to meet the expectations of our stakeholders. Stakeholders include customers, employees, regulators, investors, suppliers, the community, other third parties and the environment.
We recognise that our social, economic, health & safety and environmental responsibilities to these stakeholders are integral to our business. We aim to demonstrate these responsibilities through our actions and within our corporate policies inclusive of not causing any risk/hazard to these stakeholders.
Our approach to what has become an essential part of our operating culture is what sets us apart from our competitors. Social awareness is more than just words, it is how we operate, from employee welfare to community support.
The following sections provide a brief synopsis of how we are working towards a safer, cleaner and more sustainable environment.
ENVIRONMENT
The company has a responsibility to manage both the direct and indirect environmental impacts arising from its operations. Environmentally sustainable operating systems are implemented wherever possible to manage our direct impact on our base environment and that of the wider community.
The introduction of our ‘AWARE’ strategy has empowered all stakeholders within the company to adopt an approach to business that openly seeks to source, adopt and promote environmentally aware products and services, from recycled stationary to community based printers and service providers, thereby reducing our Carbon footprint.
Other initiatives adopted to reduce our impact on our environment include the following;
• Recycling of paper, card and plastics
• Introduction of the ‘Paper free Drive’, a movement towards a paper free working environment
• Promotion of the use of Public transport
• The adoption of low emission (CO2) company vehicles
HEALTH & SAFETY
The health, safety and welfare of all employees of The company is of paramount importance, that’s why we have introduced far reaching reforms to make the working environment as safe and secure as possible. Some of the reforms introduced include the following;
• Introduction of Breathe HR – to monitor personnel files & training
• Establishment of a dedicated control room designed to safeguard the interests of all personnel deployed in lone working situation.
The above initiatives go hand in hand with a conscious operating culture tailored to the individual requirements of personnel working in the field, from someone to talk to at all times, to a set of policies and procedures designed to ensure that company employees remain protected, nurtured and developed throughout their career with the company.
CHARITY
Charitable work has always been an important part of the the company commitment to the local community and the country as a whole. After all we are in a people business, therefore supporting charities that provide a worthwhile service to disadvantaged sections of our community is something we are passionate about. Currently we are actively supporting the ABF with donations to events held throughout the year and undertaken by our consultants and staff.
CUSTOMER CARE POLICY
The company has a straight forward approach to customer care, service and support essentially we treat our customers as we would like to be treated ourselves.
• We enjoy good, on-going working relationships with our clients. Typically, this allows our staff to create friendly and supportive partnerships with all the members of your team.
• Clients are provided with telephone numbers for all key members of the project team, so there is always someone available to talk to you.
• We provide an online issue logging system that allows you to track the progress of each issue online - 24/7.
We'll go the extra mile to ensure that your issues are addressed. Typically our offices are open for 24 hours a day and we'll also answer and respond to support calls outside the contracted hours if someone is available.
Quality statement
• Through our commitment to quality and customer service we provide a quality front line service to our customers.
• Customers who call our offices will have their telephone calls answered quickly. Personal callers will not be expected to queue for too long and their enquiries will be answered promptly and courteously.
• All of our staff takes personal responsibility for ensuring a quality outcome for your project.
• We will provide Standard Service Level Agreements (SLAs) for customer care and complaints and will honour these commitments to our customers.
Access
• Our customers are provided with support by telephone, fax, email and open 24/7 access to online logging application.
Support hours
• Phase One Security support is typically available 24/7.
• Our online logging application system is available all day and every day of the year, including Bank Holidays.
• Customers with a 24/7 contract are provided with an out of hours service.
Targets
Our main customer care targets are to:
• Answer all telephone calls at the first point of contact.
• Respond to emails on the same business day. Where a substantive response is likely to take longer, we'll send an acknowledgement and explain when you can expect to receive a full reply.
• Provide an on-going support service to our customers.
Managing the process
• We track and monitor enquiries to ensure our promises are delivered. Phase One Security will then analyse comments and complaints to learn what can be done to improve our services for the future.
• Wherever possible, services will be delivered and supported electronically.
• Customer care targets will be integral to the performance management systems of Phase One Security.
• Regular meetings will be held between front and back office to maintain service levels and communication.
Related policies
See also the following company policies:
• Environmental
• Ethical
• Equal opportunities
• Quality
• Health and safety
BUSINESS ETHICS (ACS)
An ethical approach to business is what sets us apart from our competitors, from an ethical approach in the way we source goods and services to the way we conduct ourselves whilst looking after entire client portfolio
As an organisation we have from the start strived to enhance the reputation of the security industry, from being one of the first organisations to support the introduction of the Private Security Industry Act, to our enthusiastic embrace of the SIA Approved Contractor Scheme (ACS).
You can’t get it right 100% of the time, but you can learn from mistakes and evolve the service provided to ensure that client satisfaction remains at the forefront. Part of this commitment to getting it right is our ACS accreditation an achievement which proclaims our commitment to enhancing the image of the security industry through safeguarding employee rights, protecting the environment and by giving something back to the community.
ACS accreditation tells our clients that we have signed up to some of the most stringent quality criteria in the service industry, thereby providing peace of mind secure in the knowledge that the company you’ve chosen to look after your interests, is a company that conforms to the highest ideals, in terms of quality and professionalism.
DATA PROTECTION POLICY
Introduction
In the course of your work you may come into contact with or use confidential information about employees, clients, customers and suppliers, for example their names and home addresses. The Data Protection Act 1998 contains principles affecting employees’ and other personal records. Information protected by the Act includes not only personal data held on computer but also certain manual records containing personal data, for example employee personnel files that form part of a structured filing system. The purpose of this policy is to ensure you do not breach the Act. If you are in any doubt about what you can or cannot disclose and to whom, do not disclose the personal information until you have sought further advice from the Company’s Data Protection Officer (see below). You should be aware that you can be criminally liable if you knowingly or recklessly disclose personal data in breach of the Act. A serious breach of data protection is also a disciplinary offence and will be dealt with under the Company’s disciplinary procedure. If you access another employee’s personnel records without authority, this constitutes a gross misconduct offence and could lead to your summary dismissal.
This policy does not form part of an employee’s contract of employment but it is a condition of employment that employees abide by this policy and therefore any failure to follow it can result in disciplinary proceedings.
The data protection principles
There are eight data protection principles that are central to the Act. The Company and all employees must comply with these principles at all times in their information handling practices. In brief, the principles say that personal data must be:
1. Processed fairly and lawfully and must not be processed unless certain conditions are met in relation to personal data and additional conditions are met in relation to sensitive personal data. The conditions are either that the employee has given his consent to the processing, or the processing is necessary for the various purposes set out in the Act. Sensitive personal data may only be processed with the explicit consent of the employee and consists of information relating to:
o Race or ethnic origin.
o Political opinions and trade union membership.
o Religious or other beliefs.
o Physical or mental health or condition.
o Sexual life.
o Criminal offences both committed and alleged.
2. Obtained only for one or more specified and lawful purposes, and must not be processed in any manner incompatible with those purposes.
3. Adequate, relevant and not excessive in relation to the purposes for which it is processed. The Company will review employees’ personnel files on a regular basis to ensure they do not contain a backlog of out-of-date or irrelevant information and to check there is sound business reason requiring information to continue to be held.
4. Accurate and where necessary kept up-to-date. If your personal information changes, for example you change address or you get married and change your surname, you must inform your line manager as soon as practicable so that the Company’s records can be updated. The Company cannot be responsible for any such errors unless the employee has notified the Company of the relevant change.
5. Not kept for longer than is necessary. The Company will keep personnel files for no longer than six years after an employee has left the Company’s employment. Different categories of data will be retained for different periods of time, depending on legal, operational and financial requirements. Any data which the Company decides it does not need to hold for a particular period of time will be destroyed after approximately one year. Data relating to unsuccessful job applicants will only be retained for a period of one year.
6. Processed in accordance with the rights of employees under the Act.
7. Secure Appropriate technical and organisational measures must be taken against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, data. Personnel files are confidential and are stored as such in locked filing cabinets. Only authorised employees have access to these files. For a list of authorised employees, please contact one of our Area Managers. Files will not be removed from their normal place of storage without good reason. Data stored on diskettes or other removable storage media is kept in locked filing cabinets. Data held on computer is also stored confidentially by means of password protection, encryption or coding and again only the above employees have access to that data. The Company has network back-up procedures to ensure that data on computer cannot be accidentally lost or destroyed.
8. Not transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection relation to the processing of personal data.
Employees’ consent to personal information being held
The Company holds personal data about its employees and, by signing your contract of employment; you have consented to that data about you being processed by the Company. Agreement to the Company processing your personal data is a condition of your employment.
The Company also holds limited sensitive personal data about its employees and, by signing this policy; you give your explicit consent to our holding and processing that data, for example sickness absence records, particular health needs and equal opportunities monitoring data.
Employees’ rights to access personal information
Under the Act, employees have the right on request to receive a copy of the personal data that the Company holds about them, including personal data held on personnel files that form part of a relevant filing system, and to demand that any inaccurate data held be corrected or removed. They also have the right to seek compensation where damage and distress have been caused to them as a result of any breach of the Act by the Company.
Employees have the right, on request:
• To be told by the Company whether and for what purpose personal data about them is being processed.
• To be given a description of the personal data concerned and the recipients to whom it is or may be disclosed.
• To have communicated in an intelligible form the personal data concerned, and any information available to the Company as to the source of the data.
• To be informed in certain circumstances of the logic involved in computerised decision-making.
Upon request, the Company will provide you with a statement regarding the personal data held about you. This will state all the types of personal data the Company holds and processes about you and the reasons for which they are processed.
If you wish to access a copy of any personal data being held about you, you must make a written request for this and the Company reserves the right to charge you a fee of £10.00 for the supply of the information requested. If you wish to make a request, please complete a Personal Data Request Form, which can be obtained from the Data Protection Officer. Once completed, it should be returned to the Data Protection Officer. The Company will respond promptly and in any case within 40 calendar days of receiving the request. Note that the Company will always check the identity of the employee making the request before processing it.
If you wish to make a complaint that this policy has not been followed in respect of personal data the Company holds about you, you should raise the matter with the Data Protection Officer / Area Manager. If the matter is not resolved, it should be raised as a formal grievance under the Company’s grievance procedure.
Exemptions
There are a number of exemptions from the data protection regime set out in the Act, for example:
• Confidential references that are given, but not those received by the Company from third parties. Only designated line managers can give Company references.
• Confidential references will not be provided unless the Company is sure this is the employee’s wish.
• Management forecasts and management planning (including documents setting out management plans for an employee’s future development and progress).
• Data which is required by law to be publicly available.
• Documents subject to legal professional privilege.
Employees’ obligations in relation to personal information
You should ensure you comply with the following guidelines at all times:
• Do not give out confidential personal information except to the data subject. In particular, it should not be given to someone, either accidentally or otherwise, from the same family or to any other unauthorised third party unless the data subject has given their explicit consent to this.
• Be aware that those seeking information sometimes use deception in order to gain access to it. Always verify the identity of the data subject and the legitimacy of the request, particularly before releasing personal information by telephone.
• Only transmit personal information between locations by fax or e-mail if a secure network is in place, for example, a confidential fax machine or encryption is used for e-mail.
• If you receive a request for personal information about another employee, you should forward this to the Data Protection Officer, who will be responsible for dealing with such requests.
• Ensure that any personal data which you hold is kept securely, either in a locked filing cabinet or, if it is computerised, it is password protected.
Compliance with the Act is the responsibility of all employees. Any questions or concerns about the interpretation of this policy should be taken up with the Data Protection Officer.
DISCIPLINARY PROCEDURE POLICY
Whilst the Company does not wish to impose unreasonable rules of conduct on its employees, certain standards of behaviour are necessary to maintain good employment relations and discipline in the interest of all employees. The Company prefers that discipline be voluntary and self-imposed and in the great majority of cases this is how it works.
However, from time to time, it may be necessary for the Company to take action towards individuals whose level of behaviour or performance is unacceptable.
This disciplinary procedure is in two parts. Section A generally applies to those employees who have less than one year’s continuous employment with the Company, although the
Company reserves the right to apply Section B instead to any such employee. Section B applies to those employees who have one or more years’ continuous employment with the Company.
This disciplinary procedure is entirely non-contractual and does not form part of an employee’s contract of employment.
Section A
Before taking a decision to dismiss an employee on the grounds of misconduct or poor performance, the Company will, as a general rule and subject to any permitted statutory exceptions, comply with the following procedure:
Stage 1: Notification of allegations
The Company will notify the employee in writing of the allegations against him or her and will invite the employee to a disciplinary meeting to discuss the matter. The Company will also notify the employee of the basis for the complaint of alleged misconduct or poor performance.
Stage 2: Disciplinary meeting
Having given the employee a reasonable opportunity to consider his or her response to the allegations, a disciplinary meeting will then take place at which the employee will be given the chance to state his or her case. The employee may be accompanied, if requested, by a trade union official or a fellow employee of his or her choice. The employee must take all reasonable steps to attend that meeting. Following the meeting, the employee will be informed of the Company’s decision in writing and notified of his or her right to appeal against it.
Stage 3: Appeals
If the employee wishes to appeal against the Company’s decision, he or she can do so to a Director of the Company within five working days of the decision. Appeals should be made in writing and state the grounds for appeal. The employee will be invited to attend an appeal meeting chaired by a senior manager or a Director.
At the appeal meeting, the employee will again be given the chance to state his or her case and will have the right to be accompanied by a trade union official or a fellow employee of his or her choice. Following the appeal meeting, the employee will be informed of the appeal decision in writing. The Company’s decision on an appeal will be final.
The Company reserves the right not to follow this Section A procedure in relation to the imposition of a period of suspension with pay on, or the issuing of a disciplinary warning to, any employee who has less than one year’s continuous employment with the Company.
Section B
Minor faults will be dealt with informally through counselling and training. However, in cases where informal discussion with the employee does not lead to an improvement in conduct or performance or where the matter is considered to be too serious to be classed as minor, for example, unauthorised absences, persistent poor timekeeping, sub-standard work performance, etc. the following disciplinary procedure will be used. At all stages of the procedure, an investigation will be carried out.
The Company will notify the employee in writing of the allegations against him or her and will invite the employee to a disciplinary hearing to discuss the matter. The Company will also notify the employee of the basis for the complaint of alleged misconduct or poor performance. Having given the employee a reasonable opportunity to consider his or her response to the allegations, a formal disciplinary hearing will then take place, conducted by a manager, at which the employee will be given the chance to state his or her case, accompanied if requested by a trade union official or a fellow employee of his or her choice.
The employee must take all reasonable steps to attend that meeting. Following the meeting, the employee will be informed in writing of the Company’s decision in accordance with the stages set out below and notified of his or her right to appeal against that decision. It should be noted that an employee's behaviour is not looked at in isolation but each incident of misconduct is regarded cumulatively with any previous occurrences.
Stage 1: Written warning
The employee will be given a formal WRITTEN WARNING. He or she will be advised of the reason for the warning, how they need to improve their conduct or performance, the timescale over which the improvement is to be achieved, that the warning is the first stage of the formal disciplinary procedure and the likely consequences if the terms of the warning are not complied with. The written warning will be recorded but nullified after six months, subject to satisfactory conduct and performance.
Stage 2: Final written warning
Failure to improve performance in response to the procedure so far, a repeat of misconduct for which a warning has previously been issued, or a first instance of serious misconduct or serious poor performance, will result in a FINAL WRITTEN WARNING being issued. This will give details of, and grounds for, the complaint, how he or she needs to improve their conduct or performance, the timescale over which the improvement is to be achieved and warn that dismissal will probably result if the terms of the warning are not complied with.
This final written warning will be recorded but nullified after twelve months, subject to satisfactory conduct and performance.
Stage 3: Dismissal
Failure to meet the requirements set out in the final written warning will normally lead to DISMISSAL with appropriate notice. A decision of this kind will only be made after the fullest possible investigation. Dismissal can be authorised only by a senior manager or a Director.
The employee will be informed of the reasons for dismissal, the appropriate period of notice, the date on which his or her employment will terminate and how the employee can appeal against the dismissal decision.
Gross misconduct
Offences under this heading are so serious that an employee who commits them will normally be summarily dismissed. In such cases, the Company reserves the right to dismiss without notice of termination or payment in lieu of notice. Examples of gross misconduct include:
• Any breakage of the law, such as theft and unauthorised possession of Company property, fraud, deliberate falsification of records or any other form of dishonesty.
• Wilfully causing harm or injury to another employee, physical violence, bullying or grossly offensive behaviour.
• Deliberately causing damage to the Company’s property.
• Causing loss, damage or injury through serious carelessness.
• Wilful refusal to obey a reasonable management instruction.
• Incapacity at work through an excess of alcohol or drugs.
• A serious breach of health and safety rules.
• Harassing or victimising another employee on the grounds of race, colour, ethnic origin, nationality, national origin, religion or belief, sex, sexual orientation, gender reassignment, marital status, age and/or disability.
The above is intended as a guide and is not an exhaustive list.
Suspension
In the event of serious or gross misconduct, an employee may be suspended on full basic pay while a full investigation is carried out. Such suspension is a neutral act, which does not imply guilt or blame, and will be for as short a period as possible.
Appeals
An employee may appeal against any disciplinary decision, including dismissal, to a Director of the Company within five working days of the decision. Appeals should be made in writing and state the grounds for appeal. The employee will be invited to attend an appeal hearing chaired by a senior manager or a Director. At the appeal hearing, the employee will again be given the chance to state his or her case and will have the right to be accompanied by a trade union official or a fellow employee of his or her choice. Following the appeal hearing, the employee will be informed of the appeal decision and the reasons for it, in writing.
The Company’s decision on an appeal will be final.
Drugs and Alcohol Policy
The company is committed to providing a safe and work environment with the appropriate safeguards. For health, safety, moral and financial reasons the business will enforce this policy.
The company will take action so as it is reasonably practicable, to prevent any substance abuse which increases the potential for accidents, ill health, absenteeism, sub-standard performance or which would otherwise adversely affect its employees or other persons.
This policy shall equally to all employees including directors, management, administration, supervisors and officers. This policy shall also apply to workers, sub-contractors and relevant third parties (other persons) whilst the company has a statutory duty for their protection.
Objectives
• To ensure Health and Safety of individuals is not compromised by the actions of others that are under the influence of drugs or alcohol or;
• Those individuals do not possess or supply any drugs of abuse whilst at work.
• To encourage a safer and healthier working environment for our people.
• To ensure that anyone suspected of being under the influence of alcohol or drugs is treated in a fair and consistent manner.
• To ensure that anyone who advises their line manager that they have a drug or alcohol related problem is given the necessary support to resolve their problems and commit to the agreed course of treatment.
• To ensure all persons under our control tell their supervisor or manager if they are taking any medication.
• To ensure relevant persons undergo testing for drugs and alcohol when requested to do so.
• Where applicable, to support the requirements of our clients and the market sector in which we work by imposing a stricter policy.
In the context of this policy the following definitions apply:
Substance – Alcohol, illicit drugs, prescription drugs, over the counter medication, solvents or any other substance that when used can affect and individuals, perception/actions.
Abuse – the use of illegal drugs and deliberate misuse of prescribed drugs, over the counter medication or other substances such as solvents and alcohol.
The company recognises that substance abuse can be a serious medical condition. The business will provide employees with the appropriate and reasonable assistance to obtain the necessary treatment if advised voluntarily by the employee. In all cases this will be dealt with in strict confidence, Subject to the requirements of the law.
The company will provide appropriate guidance and information to all employees relating to substance abuse and the safe use of alcohol.
The company will be set the Cut off Levels for Drugs and Alcohol; this shall be recorded Drugs and Alcohol Standard.
No employees of The company(and other persons as defined above) shall abuse substances, be above specified alcohol limits, supply others with, or be in possession of any substance ( other than prescription drugs and over the counter medication) whilst engaged on Carillion Infrastructure business.
Employees (and other persons as defined above) taking prescription or over the counter medication, which may affect performance at work, must notify their Supervisor/manager.
The company reserve the right to require all employees (and other persons as defined above) to undergo alcohol and drug screening tests and searches a laid down in the company procedures. Failure or refusal to take any such test will render the employee subject to disciplinary action or, in the case of others lead to the exclusion from the company
The responsibilities for the implementation of shall be defined in specific the company Procedures.
This policy will be made available to all employees and other parties as defined above through briefings, Induction and displayed in site file and on the company website.
This policy will be regularly reviewed for its effectiveness in line with the company Health and Safety Policy and arrangement.
ENVIRONMENTAL POLICY
We are committed to deliver quality service to our clients in an effective, responsive and professional way while proudly keep and maintain the following key features.
Protection of the environment in which we live and operate is part of the companies values and principles and we consider it to be sound business practice. Care for the environment is one of our key responsibilities and an important part of the way in which we do business.
In this policy statement we commit our company to:
• Complying with all relevant environmental legislation, regulations and approved codes of practice;
• Protecting the environment by striving to prevent and minimize our contribution to pollution of land, air, and water;
• Seeking to keep wastage to a minimum and maximize the efficient use of materials and resources;
• Managing and disposing of all waste in a responsible manner;
• Providing training for our staff so that we all work in accordance with this policy and within an environmentally aware culture;
• Regularly communicating our environmental performance to our employees and other significant stakeholders;
• Developing our management processes to ensure that environmental factors are considered during planning and implementation;
• Monitoring and continuously improving our environmental performance.
The policy statement will be regularly reviewed and update as necessary. The management team endorses these policy statements and is fully committed to their implementation.
EQUAL OPPORTUNITIES POLICY
Commitment to equal opportunities
The company is committed to the principle of equal opportunities in employment. The company is opposed to any form of less favourable treatment or financial reward through direct or indirect discrimination, harassment, victimisation to employees or job applicants on the grounds of race, religious beliefs, political opinions, creed, colour, ethnic origin, nationality, marital/parental status, sex, sexual orientation or disability and to any form of less favourable treatment on the grounds of handicap or age.
The company recognises our obligations under the Sex Discrimination Act, The Equal Pay Act, Article 119 of the Treaty of Rome, The Race Relations Act, The Employment Equality (Sexual Orientation) Regulations 2003 and The Employment Equality (Religion or Beliefs) Regulations 2003, the Employment Equality (Age) Regulations 2006, and the Codes of Practice published by the Equal Opportunities Commission, the Commission for Racial Equality and the European Commission:
• For the elimination of discrimination on the grounds of sex, sexual orientation or marital status and for the promotion of equal opportunity in employment.
• For the elimination of racial discrimination and the promotion of equal opportunity in employment.
• For the elimination of discrimination in pay between men and women who do the same work, or work of a similar nature or work of equal value.
• For the elimination of discrimination on the grounds of religion or beliefs.
• For the elimination of discrimination on the grounds of age.
Employment Practices
You have a personal responsibility to adhere to the principles of equal opportunity and maintaining racial harmony. The company will actively promote equal opportunities in our business to ensure that individuals receive treatment that is fair and equitable and consistent with their relevant aptitudes, potential skills and abilities. Employees will be recruited and selected, promoted and trained on the basis of objective criteria. Sexual, racial and other forms of harassment will not be tolerated. The company will treat unfair discriminatory conduct by any member of staff as a disciplinary offence.
Advertising and Publicity
Any job advertisements – whether “internal” or “external” will acknowledge the rights of all individuals to apply for the position(s) being advertised, regardless of race, religious beliefs, political opinions, creed, colour, ethnic origin, nationality, marital/parental status, sex, sexual orientation or disability, handicap or age.
No publicity material – of any form, whether printed or electronic – shall in any way exhibit or infer discrimination of any form.
Monitoring and Review Arrangements
The company will regularly monitor our policies to ensure that we pursue an effective policy of equal opportunity.
Grievance and Disciplinary Procedures
The company will ensure that any employee who feels that he or she has been treated unfairly or subjected to direct or indirect unfair discrimination can raise the matter through the appropriate grievance procedure when every effort will be made to secure a satisfactory resolution. Any employee making a complaint of unfair discrimination will be protected from any victimisation in any form.
Training
The company will train, develop and promote on the basis of merit and ability and encourage employees and applicants from all races.
Rehabilitation of Offenders
The company will not discriminate against anyone who has a spent conviction under the Rehabilitation of Offenders Act 1974.
Equal Pay
Men and women are entitled to be paid equally without any bias on the grounds of sex and that this right is set out in the Treaty of Rome and is enforceable under UK Law.
All reasonable steps will be taken to ensure that male and female staff receives equal pay for the same work and for work rated as equivalent and for work of equal value.
Harassment at work
Harassment is unsolicited and unwelcome workplace behaviour that adversely affects the dignity of the recipient. Where such behaviour is motivated by gender, sexual orientation, marital status, race, colour, national or ethnic origin, nationality, age or disability it also amounts to infringement of equal employment opportunity.
The company is committed to ensuring that no harassment or victimisation at work, whatever the motivation, is overlooked or condoned. Such behaviour can range from extreme forms such as violence or bullying to less obvious actions like practical jokes and ridiculing colleagues or subordinates.
Conduct becomes harassment if it persists after the recipient has made clear that it is regarded as offensive, although a single offensive act can amount to harassment if it is so serious as to be obviously offensive towards the recipient.
Any form of harassment is a potential disciplinary matter.
Sexual harassment at work
Sexual harassment is a particular form of harassment. It is conduct at work directed towards an employee by another employee or group of employees which is of a sexual nature, or which is based on a person's sex, and which is regarded as unwelcome or offensive to the recipient.
• The following examples illustrate the sort of conduct that may be treated as sexual harassment:
• Unwanted physical contact or conduct which is intimidating, or physically or verbally abusive. Harassment can also be non-verbal, for example, staring or gestures.
• Suggestions that sexual favours may further a person's career, or that refusal may hinder it.
• Sexual advances, propositions, suggestions or pressure for sexual activity at or outside work.
• Derogatory or demeaning remarks based on gender, or the display of sexually explicit material in the workplace.
• Sexual harassment is a denial of equal employment opportunity and has the effect of insulting and demeaning the employee who is harassed.
Racial Discrimination
Racial harassment is a particular form of harassment. It is conduct at work directed towards an employee by another employee or group of employees which is of a racial nature, or which is based on a person's race, colour or origins, and which is regarded as unwelcome or offensive to the recipient.
The following are examples that illustrate the sort of conduct that may be treated as racial harassment:
• Jokes about race.
• Offensive names used.
• References to people by offensive racist descriptions.
• Verbal or physical abuse because of a person’s race or colour.
• Detrimental behaviour because of a person’s race.
• Denial of opportunity because of race.
This policy applies to verbal and physical actions as well as any other form of communication including electronic communication such as text messages, emails, and faxes as well as written communications.
If you believe you are the subject of harassment you should make a formal complaint.
Depending on the seriousness of the allegation, the alleged harasser may be suspended on full pay while the matter is being investigated under our disciplinary procedures.
The aim throughout is to resolve the complaint of harassment sensitively, impartially, effectively and quickly.
There will be no victimisation of any employee for making or supporting or assisting a complaint of harassment – even if the complaint is not upheld – provided the action was taken in good faith.
Age Discrimination
Discrimination or harassment on grounds of age by employers is prohibited in the areas of recruitment, promotion and training. There can be direct and indirect age discrimination.
It is unlawful for an employer to discriminate against a person in the arrangements made for the purpose of determining to whom employment should be offered; in the terms on which that person is offered employment; and by refusing to offer, or deliberately not offering, employment.
Similarly, it is unlawful for an employer to discriminate against that person in the terms of employment; in the opportunities for promotion, a transfer, training, or receiving any other benefit; by refusing or deliberately not affording that person any such opportunity; or by dismissing or subjecting that person to any other detriment.
There are certain circumstances when some of the Regulations may not apply in relation to genuine occupational requirements of employment.
LONE WORKER POLICY
This policy is to ensure that there are adequate systems in place to ensure the health, safety and welfare of lone workers in order to reduce the risks of lone working as far as is reasonably possible and practicable.
Security systems including CCTV and Access Control are designed to reduce the need for lone working where possible. If this is not possible, safe work practices should be implemented, in line with the findings of a general risk assessment, to avoid or minimise the possibility of abuse.
The objectives of this policy are to ensure
• Lone workers are identified.
• Those risks inherent in lone worker situations are assessed and suitable precautionary measures taken.
There is a local safe system of work which:
• Records the whereabouts of lone workers.
• Tracks the movement of lone workers.
• Follows an agreed system for locating staff who deviate from their expected movement pattern.
• Identifies when lone working is no longer appropriate.
Organisational responsibilities
• Maintain a log of the locations of employees considered to be lone workers.
• Maintain contact with staff that works alone, both internally and externally.
• Implement systems to identify that staffs who does not report or return at the expected time.
• Ensure systems are in place to take action to contact / locate staffs that has failed to make contact or return at the expected time.
• Raise the appropriate level of alert / alarm and inform the manager on call if staff cannot be contacted / located within 60 minutes after the expected time of contact or return.
• If staff cannot be located, then contact the police.
• Monitor and update this policy as appropriate.
Safe System of Work
• Radios should be used when employees are within radio frequency distance of each other (example: check point or nightclub).
• Personnel attack alarms should be used when employees are working in non-built up or high risk areas.
• Mobile phones should be used to make hourly check calls when staffs are on-site.
• Mobile patrols should be made when patrolling sites near to the site employees are working.
MOBILE DEVICES & REMOTE WORKING POLICY
1. Introduction
Current models of delivery of services and flexible working practices are such that staff may need to access Company information from a location that is not their normal work base. For example, individuals may not have a static work base or they may need occasionally to work away from their normal place of work. In addition, flexible working practices mean that some staff may be working from home on a regular or ad hoc basis. Developments in technology are such that it is now possible to process information using various types of portable (mobile) electronic devices such as laptops, tablet notebooks and USB memory sticks enabling staff not only to work at different locations but also while they are ‘on the move’. While these developments in technology and changes to working practice bring many benefits they also introduce risks to the organisation, individual staff members and the security of Company information. Information is no longer retained in the work base where it is automatically backed up but is moving about the city, region or country on a variety of devices. The convenience of these devices, their small size and capacity to hold large amounts of information, presents their greatest risk. They can easily be lost, mislaid or stolen. It is important that information, whether held on mobile devices or accessed remotely, is protected by adequate security.
2. Objective
The purpose of this policy is to protect Company information that is processed remotely or is stored on portable devices. It forms part of an overall suite of information governance policies and should be read in conjunction with the Information Security Policy in particular.
3. Scope
This policy covers:
Remote working, that is, working on Company information or accessing the Company network in a place that is not your normal work base or work station.
The use of portable processing devices, which includes portable computers such as laptops and notebooks, smart phones such as blackberries, personal digital assistants (PDAs), digital cameras, mobile phones, portable hard drives and any other mobile devices which processes information.
In particular, the policy covers:
• Connection to the Company network – remotely and with portable devices
• The processing of Company information away from Company premises
• The processing of Company information on portable devices
• The secure transfer of information
• The security of portable devices and information
• The use of home computers and personal mobile devices
4. Compliance with this policy
This policy applies to all users of Company systems and equipment including company employees and non-Company employees who work within the company or under contract to it. This includes, but is not limited to, staff on secondment to the Company, students on placement and people working in a voluntary capacity.
For convenience, the term ‘staff’ is used in this document to refer to all those to whom the policy applies.
All staff are required to comply with this policy.
This policy is based on current law and accepted standards of good practice; your duty to handle company and person identifiable information appropriately arises out of common law, legal obligations, staff employment contracts and professional obligations.
Any breaches of this policy may result in your employment or your association with the Company being terminated. It may also bring into question any professional registration that you may hold and may result in disciplinary, civil or criminal proceedings.
If there is anything that isn’t clear or which you do not understand in this policy you must contact your line manager, in the first instance, or the Managing Director for further information.
Please note that the procedures and policies outlined in this policy and any related policy may be changed at any time. You will be alerted to this via established Company communication routes such as team brief, weekly and monthly round up, intranet and internet.
5. Generic responsibilities of staff and the Company
All managers are responsible for ensuring that the staff they manage are aware of the Remote working and Portable Devices policy and their individual responsibility for complying with it. They should ensure their staff are equipped to fulfil those responsibilities; this will include covering it at local induction and by identifying and meeting specific and generic training needs through personal development plans.
Managers should ensure ALL new staff have signed the Confidentiality and Information Security Declaration. Managers are required to countersign this declaration to indicate that they have checked that the member of staff has read the relevant information governance policies and has had an opportunity to ask questions about anything they do not understand.
Senior managers should ensure that managers within their Service are aware of their responsibilities in relation to informing staff about acceptable standards of information governance.
All staff must ensure that they are aware of the requirements and standards of behaviour that apply.
All staff are responsible for reporting information incidents and near misses, including breaches of this policy, using the Company’s Incident Reporting Policy.
The Company’s incident reporting process can be obtained from line managers in the first instance. Further information can be obtained from the Managing Director.
The Managing Director is responsible for overseeing the implementation of this policy including monitoring compliance. She is also responsible for ensuring it is reviewed periodically.
6. Direct connection to the Company network
All electronic processing devices connecting directly to the Company network must be protected by up to date anti-virus software. Where the device does not update automatically, it is the responsibility of the user to ensure that the anti-virus software is up to date.
Personal devices (that is, devices that are not provided by the company) such as home personal computers, laptops, portable hard drives, media players (such as ipods, iphone) but with the exception of personal digital assistants, must not be connected directly to the Company network.
The direct connection of personal digital assistants to the Company network (whether personal or provided by the Company for business use) requires prior authorisation from the Managing Director.
7. Remote Connection to the Company network
Connection to the Company network remotely (that is, via web services or remote services) requires authorisation from the Managing Director and will be subject to authentication procedures specified by her.
8. The use of portable devices
Only encrypted laptops and USB sticks that have been provided/authorised for use by the Managing Director may be used. Note: the use of Company and Non-Company provided Blackberry/iPhone devices is covered later within this section.
The use of personal USB Memory Sticks is not permitted on COMPANY equipment.
Note: The exception is for external people for the purposes of giving presentations, transferring data for example (see section 15). Unencrypted USB sticks will be read only. Staff who are currently holding Company data on personal USB sticks should contact the IT Service Desk to enable the information to be transferred to the Company Network.
The procurement of portable media must be authorised by the Managing Director.
The use of portable media must be in line with company policy and authorised by your line manager or the Managing Director.
Portable devices can be used to transport information or to enable information to be worked on remotely.
All information, whether confidential or otherwise, must only be transferred using encrypted portable media.
Portable devices should only be used to transport confidential or sensitive information when other more secure methods are not available.
Portable media is a means for transferring data. It is not intended to be a long-term storage medium nor is it an adequate back up device. The companies network provides all users with the facilities to save information securely in shared folders that are backed-up on a daily basis.9
Note: CDs and DVDs may be used to store information where this is part of the organisational record.
Always transfer documents back to their normal storage area as soon as possible. Failure to do this may result in problems with the version control or the loss of information if the portable device is lost or corrupted.
Always remove information from portable media after it is no longer needed.
Blackberry/iPhones/any other mobile device.
Company provided Blackberry devices:
a) With be configured to receive e-mails from the employees mail box only.
b) Must not be used for receiving or making personal calls at any time.
Personal (employee supplied) Blackberry/i Phone devices:
A) Should be configured by the employee to receive e-mails from their Company e-mail inbox. As the Company cannot insist that such devices exclude personal e-mail accounts, employees are encouraged not to view their own personal e-mail account(s) during working hours.
B) Should not be used for making or receiving personal calls during working hours.
C)
In the event of loss, theft or damage to your Company provided portable device, you should contact your line manager as soon as possible.
You must ensure that any suspected or actual breaches of security are reported to your line manager or to the Managing Director.
9. Passwords or passphrases
Passwords or passphrases must not be written down and kept with the portable device or in an obvious place in an identifiable manner, for example, in your diary under ‘laptop password’.
Always set a password hint to help you to remember. Make sure this is not too obvious.
If you suspect someone may know your password you should change it immediately. If the device is a pool device, you should inform your line manager.
The IT Department can reset passwords during office hours only.
10. Information held on Company portable devices
Confidential Company information may only be held on Company portable devices with the permission of your line manager or Managing Director.
Information must not be stored permanently on portable devices. If it is necessary to use a portable device to process information, the information should be transferred to the Company server at the earliest opportunity and then deleted from the device. Unauthorised software must not be installed onto Company portable devices. Information must be virus checked before transferring onto Company computers. This will be done automatically for non-confidential information that is sent via email. (Confidential information must not be sent via email unless it is part of a process agreed and authorised by the Managing Director.
11. Information held on Personal portable devices
Company information must not be stored on non-Company equipment, for example, home personal computers, laptops, portable hard drives, PDAs and mobile phones unless it is part of an agreed process authorised by the Managing Director. An exception is the synchronisation of your calendar, task list and address book with non-Company PDAs, which is permitted.
PERSONAL SEARCH POLICY
Introduction
The company will only undertake a personal search if this is a requirement of the client. All aspects of the company’s operations are governed by the Codes of Practice issued by SIA (the Service Industry Authority) and under no circumstances will Phase One Security, or its employees, act in any manner that is in conflict with those SIA codes of practice.
This Personal Search Policy is a generic document and will be reinforced by a specific Risk Assessment relating to the premises or venue where Phase One Security is operating.
This policy refers to all Phase One Security operations where personal searches may be required, but the reference to the company’s operatives” will generally refer to Security Guards and/or Door Supervisors.
Client Requirements
Personal searches will only be undertaken where the client has indicated that these are required.
The company will require clients to allow the display of the following notice if personal searches are to be undertaken:
“the company reserves the right to operate a random search policy, and we ask that patrons kindly cooperate with such a request, failure to do so may result in refusal of admission.”
Search Criteria
Searches may be carried out for a variety of reasons but in general terms will relate to:
• Alcohol being bought in to the premises
• Drugs
• Dangerous weapons
Depending on the client requirements, either all members of the public wishing to gain entry
to the premises or venue, or a random selection of the public will be searched. Under no circumstances will there be any form of discrimination when deciding which members of the public should undergo a random search.
An “electronic random search selector” will be used to determine which members of the public are asked to undergo the search procedure.
The members of the public may also be asked to produce photo identification with proof of age when entering licensed premises.
Such requests for proof of age will be made prior to any search operations, and if right of entry is refused on the grounds of age, then no body search or search of bags or belongings will take place.
Right to Refuse
It must be understood that any member of the public may refuse to undergo a search. This is their prerogative and the company’s operatives have no right to insist on either a body search or a search of belongings. If, however, any individual refuses to undergo a search when reasonably required to do so, they will be refused entry to the premises or venue in question.
Under no circumstances may the company’s operatives use any force or threats when asking the public to undergo a search.
Public Dignity
The company’s operatives will, at all times, be treated with courtesy and respect even if they are verbally aggressive.
In the case of body searches, not matter how superficial, female members of the public may only be searched by female operatives and male members of the public may only be searched by male operatives.
In the case of more comprehensive body searches the members of the public concerned have the right to ask for that search to take place in a “private” location. In such cases there must always be a witness present – either another operative or a representative of the client. Such witnesses shall always be of the same gender as the individual being searched.
Identification of Drugs or Weapons
If, during the course of a search, non-prescription drugs, or dangerous weapons are found on the person, or in the possession of, members of the public, the operatives will always call the police - although it should be noted that the operatives have no right to detain the members of the public concerned.
In the case of alcohol being found in the possession of a member of the public wishing to enter the premises or venue, they will be refused entry until such time that they are able to prove that they are no longer in possession of the alcohol concerned.
12. Security of information and portable devices
Confidential information, whether manual or electronic, and portable devices must be protected by adequate security, for example, they must be:
• Kept out of sight, for example, in the locked boot of the car, when transported.
• Not left unattended, for example, not left in the car boot overnight or when shopping.
• Locked away when not being used.
• Kept secure and guarded from theft, unauthorised access and adverse environmental events particularly when taken home.
13. Maintenance of Company portable devices
Company equipment must be returned to the IT Department for a “health check” at regular intervals as specified by the IT Department or at their specific request.
14. Use of portable media by external visitors to the Company
External visitors, for example, lecturers, contractors, company representatives, auditors, etc. must not connect any device, including USB sticks and laptops, or insert any media to any equipment belonging to the company without authorisation.
The staff member responsible for the visitor may give this authorisation but they must ensure that the device is virus-scanned before any documents are opened. If a virus alert is generated, the member of staff is to stop using the device and inform the IT Service Desk immediately.
Unencrypted USB sticks will be accessible as read only.
15. Further information
Further information can be obtained from the Managing Director.
Questions about the use of portable devices or any problems in accessing the Company system should be directed to the IT Department. Support is available Monday to Friday, 9am to 5pm. There is no out of hours or home support.
QUALITY POLICY
The policy of the Company is to provide products and services of a high standard at competitive prices to meet the customer's contract, specification and quality requirements.
To meet these requirements, and achieve quality in all areas of work the Company's policy is to operate a Quality Management System to BS EN ISO 9001 : 2008.
The scope of the Quality Management System is the provision of Static Guarding & Surveillance in accordance with relevant British/European Standards, Norms, Industry Codes of Practice, Police Policies and Certification Body Rules & Criteria for Registration & Guidance Documents.
The continued realisation of this policy is vital in view of the growth of quality awareness among our customers.
Quality Objectives are set and monitored through the Quality Management Processes to ensure continual improvement of the Quality System.
The Quality Assurance Procedures defined in the Quality Manual and supporting documentation are mandatory for all staff. All staff are directly responsible for the Quality of their own work and shall be made aware of Quality Assurance requirements.
Periodic audits and reviews will ensure that the methods employed progress in line with practical experience, customer requirements and worldwide technical developments in our specialised fields.
RECRUITMENT AND SELECTION POLICY
The recruitment and selection process is crucially important to any equal opportunities policy. We will endeavour through appropriate training to ensure that employees making selection and recruitment decisions will not discriminate, whether consciously or unconsciously, in making these decisions.
Promotion and advancement will be made on merit and all decisions relating to this will be made within the overall framework and principles of this policy.
Job descriptions, where used, will be revised to ensure that they are line with our equal opportunities policy.
We will adopt a consistent, non-discriminatory approach to the advertising of vacancies.
All applicants who apply for jobs with us will receive fair treatment and will be considered solely on their ability to do the job.
Interview questions will be related to the requirements of the job and will not be of a discriminatory nature.
SOCIAL MEDIA POLICY
Policy statement
This policy is intended to help staff make appropriate decisions about the use of social media such as blogs, wikis, social networking websites, podcasts, forums, message boards, or comments on web-articles, such as Twitter, Facebook, LinkedIn etc
This policy outlines the standards we require staff to observe when using social media, the circumstances in which we will monitor your use of social media and the action we will take in respect of breaches of this policy.
This policy does not form part of any contract of employment and it may be amended at any time.
Who is covered by the policy
This policy covers all individuals working at all levels and grades, including senior managers, officers, directors, employees, consultants, contractors, trainees, homeworkers, part-time and fixed-term employees, casual and agency staff and volunteers (collectively referred to as staff in this policy).
The scope of the policy
All staff are expected to comply with this policy at all times to protect the privacy, confidentiality, and interests of our company and our services, employees, partners, customers, and competitors.
Breach of this policy may be dealt with under our [refer to your Disciplinary Procedure] and, in serious cases, may be treated as gross misconduct leading to summary dismissal.
Responsibility for implementation of the policy
The Director has overall responsibility for the effective operation of this policy.
The Director is responsible for monitoring and reviewing the operation of this policy and making recommendations for changes to minimise risks to our operations.
All staff are responsible for their own compliance with this policy and for ensuring that it is consistently applied. All staff should ensure that they take the time to read and understand it. Any breach of this policy should be reported to Director
Questions regarding the content or application of this policy should be directed to Director
Using social media sites in our name
Only the [position of relevant persons] is/are permitted to post material on a social media website in our name and on our behalf. Any breach of this restriction will amount to gross misconduct.
FSA requirements
The FSA has strict requirements regarding the promotion of insurance products and broker services, including on social media. The FSA rules apply to all communications made by you in your capacity as our employee or which in any way relate to our services and insurance products.
All communications we make using social media which promote our services or any insurance products can only be made by Director and must have been through our formal approval process. Otherwise, you must not make any communication using social media which promotes our services or any insurance products. This means that broadly:
• you must not recommend, advise, discuss, promote or mention any specific
• insurance products;
• you must not discuss or recommend our insurance broking services; or
• you must not invite or encourage any customer or potential customer to
• contact you in order to do either of the above. Any breach of these restrictions will amount to gross misconduct.
If you are in any doubt as to what you can and cannot say using social media, then please contact Director
Using work-related social media
Include this section where you allow all employees to use work-related social media
We recognise the importance of the internet in shaping public thinking about our company and our services, employees, partners and customers. We also recognise the importance of our staff joining in and helping shape industry conversation and direction through interaction in social media.
You are therefore permitted to interact on [approved] social media websites about industry developments and regulatory issues. [include the following if you wish to limit which social media websites are suitable for work related use:] Approved social media websites are as set in 1.1
Before using work-related social media you must:
• have read and understood this policy and [refer to other relevant policies]; and
• have sought and gained prior written approval to do so from [position of
relevant person]
Personal use of social media sites
Include this section where you allow personal use of social media
We permit the incidental use of social media websites for personal use subject to certain conditions set out below. However, this is a privilege and not a right. It must neither be abused nor overused and we reserve the right to withdraw our permission at any time at our entire discretion.
The following conditions must be met for personal use to continue:
• use must be minimal and take place substantially out of normal working hours (that
• is, during lunch hours, before 9 am or after 5.30 pm);
• use must not breach any of the rules set out in paragraph 9 below.
• use must not interfere with business or office commitments;
• use must comply with our policies including the [refer to your relevant policies such as your Equal Opportunities Policy, Anti-Harassment Policy, Data Protection Policy and Disciplinary Procedure].
Rules for use of social media
Whenever you are permitted to use social media in accordance with this policy, you must adhere to the following general rules:
There are no exceptions, you are not to discuss work or mention our company on any of your social media
Always write in the first person, identify who you are and what your role is, and use the following disclaimer “The views expressed are my own and don’t reflect the views of my employer”.
Do not upload, post, forward or post a link to any abusive, obscene, discriminatory, harassing, derogatory or defamatory content.
Any member of staff who feels that they have been harassed or bullied, or are offended by material posted or uploaded by a colleague onto a social media website should inform [insert position of relevant person who may be their line manager or in the human resources department].
Never disclose commercially sensitive, anti-competitive, private or confidential information. If you are unsure whether the information you wish to share falls within one of these categories, you should discuss this with [insert position of relevant person who may be their line manager or in the human resources department].
Do not upload, post or forward any content belonging to a third party unless you have that third party's consent.
It is acceptable to quote a small excerpt from an article, particularly for the purposes of commenting on it or criticising it. However, if you think an excerpt is too big, it probably is. Quote accurately, include references and when in doubt, link, don't copy.
Before you include a link to a third party website, check that any terms and conditions of that website permit you to link to it. All links must be done so that it is clear to the user that they have moved to the third party's website.
When making use of any social media platform, you must read and comply with its terms of use.
Do not post, upload, forward or post a link to chain mail, junk mail, cartoons, jokes or gossip.
Be honest and open, but be mindful of the impact your contribution might make to people’s perceptions of us as a company. If you make a mistake in a contribution, be prompt in admitting and correcting it.
You are personally responsible for content you publish into social media tools – be aware that what you publish will be public for many years.
Don't escalate heated discussions, try to be conciliatory, respectful and quote facts to lower the temperature and correct misrepresentations. Never contribute to a discussion if you are angry or upset, return to it later when you can contribute in a calm and rational manner.
If you feel even slightly uneasy about something you are about to publish, then you shouldn’t do it. If in doubt, always discuss it with [position of relevant person such as line manager] first.
Don’t discuss colleagues, competitors, customers or suppliers without their prior approval.
Always consider others’ privacy and avoid discussing topics that may be inflammatory e.g. politics and religion.
Avoid publishing your contact details where they can be accessed and used widely by people you did not intend to see them, and never publish anyone else's contact details.
Before your first contribution on any social media site, observe the activity on the site for a while before launching in yourself to get a feel for the style of contributions, the nature of the content and any ‘unwritten’ rules that other contributors might follow.
Activity on social media websites during office hours should complement and/or support your role and should be used in moderation.
If you notice any content posted on social media about us (whether complementary or critical) please report it to the Directors
Monitoring use of social media websites
Staff should be aware that any use of social media websites (whether or not accessed for work purposes) may be monitored and, where breaches of this policy are found, action may be taken under our [refer to your Disciplinary Procedure].
We reserve the right to restrict or prevent access to certain social media websites if we consider personal use to be excessive. Monitoring is only carried out to the extent permitted or as required by law and as necessary and justifiable for business purposes.
Misuse of social media websites can, in certain circumstances, constitute a criminal offence or otherwise give rise to legal liability against you and us. It may also cause embarrassment to us and to our clients.
In particular uploading, posting forwarding or posting a link to any of the following types of material on a social media website, whether in a professional or personal capacity, will amount to gross misconduct (this list is not exhaustive):
• pornographic material (that is, writing, pictures, films and video clips of a
• sexually explicit or arousing nature);
• a false and defamatory statement about any person or organisation;
• material which is offensive, obscene, criminal discriminatory, derogatory or
• may cause embarrassment to us, our clients or our staff;
• confidential information about us or any of our staff or clients (which you do not have express authority to disseminate);
• any other statement which is likely to create any liability (whether criminal or civil, and whether for you or us); or
• material in breach of copyright or other intellectual property rights, or which
• invades the privacy of any person. Any such action will be addressed under the [refer to your Disciplinary Procedure] and is likely to result in summary dismissal.
Where evidence of misuse is found we may undertake a more detailed investigation in accordance with our [refer to your Disciplinary Procedure], involving the examination and disclosure of monitoring records to those nominated to undertake the investigation and any witnesses or managers involved in the investigation. If necessary such information may be handed to the police in connection with a criminal investigation.
If you notice any use of social media by other members of staff in breach of this policy please report it to [position of relevant person such as line manager]
Monitoring and review of this policy
The Director shall be responsible for reviewing this policy annually to ensure that it meets legal requirements and reflects best practice.
SUSTAINABILITY POLICY
The company is committed to promoting sustainability. Concern for the environment and promoting a broader sustainability agenda are integral to the company’s professional activities and the management of the organisation. We aim to follow and to promote good sustainability practice, to reduce the environmental impacts of all our activities and to help our clients and partners to do the same.
Principles
Our Sustainability Policy is based upon the following principles:
• To comply with, and exceed where practicable, all applicable legislation, regulations and codes of practice.
• To integrate sustainability considerations into all our business decisions.
• To ensure that all staff are fully aware of our Sustainability Policy and are committed to implementing and improving it.
• To minimise the impact on sustainability of all office and transportation activities.
• To make clients and suppliers aware of our Sustainability Policy, and encourage them to adopt sound sustainable management practices.
• To review, annually report, and to continually strive to improve our sustainability performance.
Practical steps
In order to put these principles into practice we will consider the following aspects of our activities:
Transport
• Walk, cycle and/or use public transport to attend meetings, site visits etc., apart from in exceptional circumstances where the alternatives are impractical and/or cost prohibitive.
• Travel to mainland Europe within a 500km radius (excluding Scandinavia) normally will be undertaken by train.
• Include the full costs of more sustainable forms of transport in our financial proposals, rather than the least cost option which may involve travelling by car or air.
• Where the only practical alternative is to fly, we will include costs of appropriate offsets.
• Avoid physically travelling to meetings etc. where alternatives are available and practical, such as using teleconferencing, video conferencing or web cams, and efficient timing of meetings to avoid multiple trips. These options are also often more time efficient, while not sacrificing the benefits of regular contact with clients and partners.
• To reduce the need to travel to meetings and elsewhere, and facilitate regular client contact, we will provide a web cam to clients free of charge for the duration of a project where appropriate.
• Reduce the need for our staff to travel by supporting alternative working arrangements, including home working etc., and promote the use of public transport by locating our offices in accessible locations.
Purchase of equipment and consumption of resources
• Minimise our use of paper and other office consumables, for example by double siding all paper used, and identifying opportunities to reduce waste.
• As far as possible arrange for the reuse or recycling of office waste, including paper, computer supplies and redundant equipment.
• Reduce the energy consumption of office equipment by purchasing energy efficient equipment and good housekeeping.
• Purchase electricity from a supplier committed to renewable energy.
• Seek to maximise the proportion from renewable energy sources, whilst also supporting investment in new renewable energy schemes.
• Ensure that timber furniture and any other timber products are recycled or from well-managed, sustainable sources and are Forest Stewardship Council (FSC) certified. Purchase fair-trade and/or organic beverages.
Working practices and advice to clients
• Undertake voluntary work with the local community and / or environmental organisations and make donations to seek to offset carbon emissions from our activities.
• Ensure that any associates that we employ take account of sustainability issues in their advice to clients.
• Include a copy of our Sustainability Policy, whenever requested, in our proposals to clients.
3
Monitoring and reporting
Our Sustainability Policy are monitored and reported on annually (from January 2009), against the objectives, targets, indicators and targets as detailed below.
Sources of impact Objectives Policies and Targets Indicators Actions (2010)
Office energy consumption
• To minimise energy consumption
• To minimise the impact of the energy used by supporting renewable energy sources
• All lighting to use low energy bulbs
• As office equipment is replaced, purchase the most energy efficient equipment when compared with alternatives of a similar cost and performance
• Maximise the proportion of electricity used from renewable energy sources, whilst also supporting investment in new renewable energy schemes.
• Total carbon dioxide emissions from PWL office energy use and average per FTE and £ turnover
• Total Phase One Security office energy use and average per FTE and £ turnover
• Proportion of total Phase One Security electricity used from renewable sources
• Ensure computer equipment is set to go to standby when left for a short period and equipment turned off at night where practical
• Install thermostat for heating, if practicable
• Develop target for the proportion of electricity from renewable and investment in new schemes. Produce advice for employees.
Paper
• To minimise paper use.
• Total paper consumption per FTE will not increase.
• Total direct paper consumption and average per FTE and £.
• Baseline for monitoring paper use to be established and paper use.
• To minimise the impacts of producing the paper used.
• All direct paper consumption will be on 100% recycled paper.
• 50% of paper consumption through print orders will be on recycled paper.
• All new printers to be capable of duplex printing.
• Produce advice for employees.
Waste generation
• To minimise the amount of waste generated.
• To maximise the proportion of waste recycled.
• All waste office paper and toner cartridges will be recycled.
• All glass, cans and plastic bottles will be sorted and recycled.
• All redundant office equipment will be sold or donated for reuse or recycled.
• As office equipment is replaced, purchase the most resource efficient equipment. (e.g. toner waste etc.) Compared with alternatives of a similar cost and performance. Number / weight of bags of rubbish generated per annum and average per FTE and £ turnover.
• Number/ weight of bags of paper recycled per year.
• Develop system to record waste generated.
Water use
• To minimise office water use.
• As equipment is replaced, purchase the most water efficient equipment when compared with alternatives of a similar cost and performance.
• Review measures that could be taken to reduce water use.
• Produce advice for employees.
Working environment
• To reduce the impact of emissions / toxins from office equipment.
• Create a healthy working environment – including having plants in the office.
Consumption of other products
• To reduce the impact of beverages purchased and to support Fair-trade.
• To reduce the impact of products purchased (including product miles).
• 100% of tea and coffee purchased Fair-trade.
• All waste bags to be made from recycled and / or biodegradable plastic.
• Use re-used office equipment where practical.
Local community
• To support local businesses and contribute to our local community and the environment
• Purchase products and use suppliers locally wherever practical
• Two days voluntary work by every employee per year.
TRAINING POLICY
The company is committed to a structured training and development programme of its staff vocational and refresher training in order to fulfil the high standards of service to ensure success and to comply with legislation – Private Security Industry Act 2001.
The Company’s policy statement on training is as follows: -
“To provide training at all levels of such duration and scope as is compatible with the efficient discharge of the task involved and the safety of the employee. Whether conducted “in house” or “contracted out” training at all levels must be conducted by qualified trainers in an environment conductive to effective training.
To provide training at all levels specific to assignment and required specialist skills, also to provide continuation, refresher and contingency training.
This policy is approved by the Director and is supported by all levels of management within the company.
TRANSFEER OF UNDERTAKING
(PROTECTION OF EMPLOYMENT) REGULATIONS
“TUPE”
The Transfer of Undertaking (Protection of Employment) Regulations 2006 (TUPE) governs the transfer of ownership of a trade, business or other undertaking from one provider to another.
The basis of the regulations is that the transfer shall not terminate the contract of employment of any person employed by the transferor. On completion of the transfer, all the transferor’s rights, powers, duties and liabilities under the contract of employment are transferred to the company. This includes all terms and conditions under the contract of employment.
This policy will be reviewed annually should any changes take place to regulation.
VETTING PROCEDURES
Introduction
All individuals applying for employment with the company will undergo a thorough vetting procedure.
In accordance with legislation in England and Wales, all security operatives must be accredited by the Service Industry Authority (SIA) and for this reason much of the vetting will – Indeed must – be undertaken by the SIA.
Vetting by the company
All job applicants will be required to produce the following documents in support of their application:
• Photo identity (typically passport or official identity document in the case of a foreign national)
• Two recent utility bills to give proof of abode
• Driving licence
• Proof of possession of SIA licence
The definitive check of whether someone holds a valid SIA licence is not the licence itself but the Register of Licence Holders; there is also a Register of Revoked and Suspended Licences. Both registers are available 24 hours a day on the SIA website. The company will use both registers regularly to protect their customers, their reputation and to help reduce their own liability.
The company will not carry out “right to work checks” since these (from 2007) these form part of the SIA vetting process when issuing Licences. However it is understood that the ultimate responsibility regarding right to work rests with the company as the employer.
All applicants with existing experience in the security industry will be required to provide at least two references of which one must be from a recent employer and one from a client having direct experience of working with that operative.
The company will contact at least two of the referees mentioned in order to check these references / credentials.
Vetting by SIA
SIA undertakes considerable vetting leading to the issue of Licences.
Amongst the vetting processes undertaken by SIA are:
Right to Work
Since July 2007, SIA has worked with the UK Border Agency (UKBA) to check the right to work in the United Kingdom of all SIA licence applicants who are non-EEA nationals.
SIA also checks the right to work of SIA licence holders from outside the EEA (i.e. Individuals who have met SIA licensing criteria and have been granted a licence). Where the recorded right to work of a licence holder expires before their SIA licence, a further check is undertaken with the UKBA.
If the results of these checks suggest that the individual's right to work has expired, SIA will write to inform them of their intention to revoke their SIA licence(s) unless they can demonstrate a renewed right to work. They have 21 days to provide this evidence. If SIA does not receive a response within the 21 days the decision to revoke their licence will automatically take effect
Criminal Record Checks
SIA will always carry out a criminal record check on anyone who applies for a licence. If that individual has a criminal record, it does not necessarily mean that they will not get a licence.
However, if the individual has any convictions, warnings, cautions, absolute / conditional discharges, admonishments or charges awaiting trial for offences SIA will make a decision according to:
• Whether the offences are included in the lists of SIA defined offences
• The classification of seriousness of the offences (SIA produces lists that classify offences according to degrees of seriousness)
• The actual sentence or disposal given to the applicant for the offence
Access to a person’s criminal record is usually restricted under the provisions of the Rehabilitation of Offenders Act 1974. However, as it is in the public interest for the SIA to have full disclosure of a person’s criminal record in order to assess their suitability for a licence, the SIA is are exempt from this restriction and are allowed full access to the applicants criminal record. We are able to consider all offences on record including spent convictions.
Additional Training
SIA recognises that everyone working in the private security industry has the right skills and knowledge to do their job well and safely. For this reason – in order to receive an SIA Licence - it will be necessary for security operatives to obtain a recognised qualification by taking a training course and passing an exam in order to get a front line licence in the following sectors:
• Cash and Valuables in Transit
• Close Protection
• Door Supervision
• Public Space Surveillance CCTV
• Security Guard
VIOLENCE AT WORK POLICY
The company operates a zero tolerance to violence policy.
Employees within the security industry who deal directly with the public and may at some stage face aggressive or violent behaviour.
This may include:
• Physical violence – including kicking, spitting, hitting or pushing, as well as more extreme violence with weapons.
• Verbal abuse – including shouting, swearing or insults, racial or sexual abuse; Threats and intimidation.
•
Guidelines to eliminate/minimise violence at work:
• Ban repeat offenders from using the premise.
• Working with the police and local authorities to identify repeat offenders.
• Using CCTV as a deterrent and to identify and prosecute offenders.
• Working with other premise in the area to ban offenders from all premises in the area.
• Report all incidents that occur in the incident report folder.
The company is committed to taking all reasonable precautions necessary to secure the safety and health of all employees and in helping to combat violence and aggression.
The Company will endeavour to support those members of staff who have been assaulted or suffered verbal abuse in their working role. This commitment extends to the protection of those employees who work on client premises.
ADVERSE PUBLICITY PROCEDURE
ADVERSE PUBLICITY POLICY
The Company recognises the importance of addressing adverse publicity about the Company itself and about the Security industry in general.
The Company’s policy is to ensure that as part of its normal induction and training programs, all Company representatives are made aware of the need to report any service related issues that may have an adverse effect on the reputation of the Company and therefore on the reputation of the industry in general, to a senior member of the Management Team.
Customer complaints and incidents of adverse publicity are processed according to the documented procedures that follow and are kept confidential to Company representatives only.
In respect of such situations / incidents that are made known to the Company by the media or by people or organisations other than the Customer/Client, only the Managing Director or the Company legal representative will communicate with such parties, if any communication at all is considered necessary or appropriate.
