IMy hb

ol > li { list-style-type: decimal; }

IMy hb

28 September 2021
Company House
Company Road
ComapyCity PE9 2AZ


  • Anti-bribery policy
  • Communications policy
  • Data retention policy New
  • Equal opportunities policy
  • Disciplinary and dismissal procedure policy

Anti-bribery policy


    1. The Employer values its reputation for ethical behaviour. The Employer aims to ensure compliance with all anti-bribery laws and regulations. Bribery is giving someone a financial or other advantage to induce them to perform their functions or activities improperly, or to reward them for having already done so.
    2. An employer will also be liable for failing to implement adequate procedures to prevent bribery by officers, employees, business partners and agents. It is therefore important that all persons (employees, officers, business parties and agents) familiarise themselves with and adhere to this policy.
    3. It is The Employer’s policy to conduct business in an honest way, and without the use of corrupt practices or acts of bribery to obtain an unfair advantage. The Employer will apply a ‘zero tolerance’ approach to any acts of bribery or corruption by any employees, officers, business partners or agents.
    4. Our anti-bribery principles are:

      • The offer, gift, solicitation, or acceptance of bribes (whether cash or any other inducement) to any person or company, wherever they are situated, by any employee, agent or other person or body acting on behalf of The Employer, in order to gain any commercial, contractual or other advantage is strictly prohibited;
      • No company officer, employee, business partner, or agent may offer payments (or anything else of value) to other parties to make those parties act in a manner that will assist The Employer in obtaining or retaining business;
      • No company officer, employee, business partner, or agent may request, agree to receive, or accept payments (or anything else of value) except in accordance with this policy;
      • The Employer operates a zero-tolerance approach to corruption by any officers, employees, business partners or agents working on its behalf; and
      • The Employer requires any officers, employees, business partners or agents to report any suspicious activity that may violate this policy.
    5. Any employee found to have violated this policy and procedures will be subject to disciplinary action, which may include summary dismissal. Any failure to report known or suspected violations may also lead to disciplinary action.

    1. Gifts, entertainment, and hospitality include the receipt or offer of gifts, meals or tokens of appreciation and gratitude, or invitations to events, functions, or other social gatherings, in connection with matters related to The Employer’s business.
    2. Gifts, entertainment, and hospitality can amount to bribery if they are of a nature or scale which shows they were given with the intention of inducing improper conduct from the recipient. Gifts and hospitality are allowed if provided simply to improve a relationship and/or network provided they are reasonable and proportionate.
    3. In order to provide clear guidance The Employer has adopted the following non exhaustive framework for the treatment of gifts and entertainment, whether given to other parties or received:

      • Business gifts that can be accepted can only be of insignificant/nominal value (such as a bottle of wine, flowers, chocolates, or branded merchandise). Any other gifts of more significant value should be discussed with your Line Manager and then refused or returned;
      • Offering or accepting a gift in the form of cash, or cash equivalent vouchers, is strictly prohibited;
      • ‘Quid pro quo’ arrangements (something offered for something in return) are strictly prohibited;
      • All gifts and hospitality involving travel and overnight accommodation requires prior approval from Line Managers;
      • Gifts or hospitality which could influence or appear to influence decisions made on behalf of The Employer should be refused;
      • The acceptance and offer of casual entertainment such as business lunch/dinners, is acceptable within reasonable bounds, as long as it is a normal and appropriate extension of business courtesy;
      • Employees must ensure that offering or accepting a gift or hospitality does not create or appear to create a conflict of interest for those involved;
      • Employees should not offer unjustified advantages to others, directly or indirectly, in connection with business dealings either in monetary form or as some other advantage;
      • Employees should avoid making gifts that could create an appearance of impropriety. No gifts should be given to public officials or other civil servants.
      • Customer and supplier hospitality should not be offered as an incentive for the recipient to make a favourable decision.
      • No donations should be made to any person, firm, or company on behalf of The Employer without the prior written authorisation of your line manager. Donations to political parties and charities which are directly linked to business and/or gaining a business advantage are strictly prohibited.
      • This is guidance only and each case should be considered on an individual basis. Employees should exercise prudence at all times and The Employer recognises that decisions as to what is acceptable may not always be easy. In the event of any doubt, always consult your line manager for guidance.

    1. The Employer values transparency and will maintain a gifts, entertainment, and hospitality register. Any form of gift which exceeds a nominal value, and entertainment or corporate events of any value, must be appropriately recorded in the register.
    2. In the event that an impermissible gift, entertainment, or hospitality has been given or accepted, this transaction must still be recorded in the register.

    1. The prevention, detection and reporting of bribery is the responsibility of all employees. If you feel that any action taken by The Employer or any individual has contravened this policy you should, in the first instance, contact your line manager to discuss, or if the suspected contravention is by your line manager, their line manager.

Communications policy


    1. The Employer expects all its electronic and computer facilities to be used in an effective and professional manner and encourages all employees to develop the skills necessary to do so. These facilities are provided by The Employer at its own expense for its own business purposes to assist its employees in carrying out their duties effectively. It is the responsibility of each employee to ensure that this technology is used for proper business purposes and in a manner that does not compromise The Employer or its employees in any way.
    2. This policy applies to the use of The Employer’s technology whilst at work and also when using The Employer’s technology from outside work e.g., when dialling in from home or using a laptop when away on business. This policy document is to be read in conjunction with the disciplinary procedure. If you have any questions about the application of this policy, please contact your line manager.
    3. Misuse of the internet or email can expose both employees and The Employer to legal or financial liability. For example, employees may enter into unintended contracts, breach copyright or licensing arrangements, incur liability for defamation or harassment or introduce viruses into the system. This policy is designed to safeguard both employees and The Employer from such liabilities. It is important that all employees read it carefully and ensure that any use of the internet or email is in accordance with its terms.
    4. This policy applies to employees of The Employer, workers and other contractors who have access to The Employer’s computer systems. Any reference to an employee is a reference to a worker or contractor also. It also applies to personal use of email or the internet where individuals identify themselves as associated with The Employer. The Employer may occasionally modify this policy to take account of changes in technology, law and best practice and will notify employees in writing of any change.

    1. The Employer may provide computers, laptops, and other equipment for use by employees for business purposes only.
    2. Employees are responsible for the safe keeping of equipment issued to them and for the physical and virtual security of the data and software accessed on it or stored thereon.
  3. E-MAIL

    1. Although the primary reason for allowing employees access to email is to help perform duties more effectively, occasional, and essential personal use of email will be allowed provided that it does not interfere with the performance of work duties.
    2. Employees must be aware that email is not an informal communication tool but has the same authority as any other communication to and from The Employer and should be regarded as published information.
    3. Email, just like any other form of communication, should reflect the highest professional standards at all times. Employees should keep messages brief and to the point, ensure that an appropriate heading is inserted in the subject field and that they check the spelling and grammar before sending. They should also double check the recipient before pressing the send button – not only can it be embarrassing if a message is sent to the wrong person, but it can also result in the unintentional disclosure of confidential information about The Employer.
    4. Employees should not transmit anything in an email or fax message that they would not be comfortable writing (or someone else reading) in a letter or a memorandum. Emails leave a retrievable record. Even when employees think that information has been deleted, it can remain on computers and on The Employer’s back-up system. Emails can be recovered as evidence in court proceedings or reviewed by regulators. Electronic messages are admissible as evidence in legal proceedings and have been used successfully in libel and discrimination cases.
    5. Employees should never assume that internal or external messages are necessarily private and confidential, even if marked as such. The internet is not a secure means of communication, and third parties may be able to access or alter messages which have been sent or received. Employees should not send any information in an email which they would not be happy being publicly available. Matters of a sensitive or personal nature should not be transmitted by email unless absolutely unavoidable and if so, should be clearly marked in the message header as highly confidential. The confidentiality of internal communications can only be ensured if they are delivered personally by hand.
    6. Internet messages should be treated as non-confidential. Anything sent through the internet passes through a number of different computer systems all with different levels of security. The confidentiality of messages may be compromised at any point along the way unless the messages are encrypted.

    1. Employees must not download, send (or store) offensive, demeaning or disruptive messages or images by fax or email. This includes, but is not limited to, messages inconsistent with The Employer’s equal opportunities policy and includes without limitation any sexist or racist material or any material which could be offensive on the grounds of, without limitation, a person’s disability, gender reassignment, their age, their sexual orientation, their marital or civil partnership status or their religion or belief.
    2. Employees should therefore not place on the system or send any message or image which could be regarded as personal, potentially offensive, or frivolous to any recipient or to any other person (even if not sent to them).
    3. If employees receive an email or a fax containing material that is offensive or inappropriate to the office environment, then they must delete it immediately. Under no circumstances should such mail or fax be forwarded either internally or externally.

    1. Access to the internet during working time should be limited to matters relating to employment and be for business purposes only. Any unauthorised use of the internet is strictly prohibited. Unauthorised use includes but is not limited to:-

      • Visiting sites, connecting, posting, or downloading any information unrelated to their employment and in particular pornographic or other offensive or illegal material;
      • Engaging in computer hacking and other related activities;
      • Attempting to disable or compromise security of information contained on The Employer’s computers;
      • Perpetration of any form of fraud or software, music or film piracy;
      • Sending offensive or harassing material to other users;
      • Downloading of commercial software or any copyrighted materials belonging to third parties, unless this is covered or permitted under a commercial agreement or other such licence;
      • Hacking into unauthorised areas;
      • Publishing defamatory and/or knowingly false material about The Employer, colleagues and/or customers on social networking sites;
      • Revealing confidential information about The Employer in any personal online posting, upload, or transmission; and
      • Introducing any form of malicious software into The Employer’s network.
    2. Postings placed on the internet may display The Employer’s address. For this reason, Employees should make certain before posting information that the information reflects the standards and policies of The Employer. Under no circumstances should information of a confidential or sensitive nature be placed on the internet.
    3. Information posted or viewed on the internet may constitute published material. Therefore, reproduction of information posted or otherwise available over the internet may be done only by express permission from the copyright holder. Employees must not act in such a way as to breach copyright or the licensing conditions of any internet site or computer programme.
    4. Employees must not commit The Employer to any form of contract through the internet.
    5. If employees produce, collect and/or process business-related information in the course of their work, the information remains the property of The Employer. This includes such information stored on third-party websites such as webmail’s service providers.

    1. Only authorised software is to be installed on The Employer’s equipment. Employees must not install any other software on The Employer’s computers without prior written permission from the IT department.
    2. All software used on The Employer’s computers must be properly licensed. If unlicensed software is found on The Employer’s computers, the licence fee must be paid and a fine can be imposed. If the unlicensed software is not authorised by The Employer the employee will be personally liable for the licence fee and fine. The Employer reserves the right without prior notice to remove any unauthorised software and delete all non-company data and files from its computers.

    1. All Instant Messaging, Blogging and activity on Facebook, Twitter, Instagram, Myspace, or any other social media site is strictly prohibited during working hours and on The Employer’s computers. Private blogs must not contain any reference to The Employer or its’ activities.
    2. The Employer operates or may operate in the future accounts on social media websites for the promotion of activities and events and as a method of communication. Any official account on any social media website may only be set up with written consent from your line manager. Only authorised employees may use these accounts to post online and access to the account by unauthorised employees is strictly prohibited. All information posted on the internet must comply with confidentiality and data protection policies and copyright laws must be respected, with references or sources cited appropriately
    3. Any employee who becomes aware of inappropriate or distasteful social networking activity should maketheir line manager aware of this as soon as possible.

    1. Employees must not allow other employees to use their password. If it is anticipated that someone may need access to an employee’s confidential files in their absence, they should arrange for the files to be copied to somewhere where that person can access them or give them access to the relevant personal folders.

    1. When using The Employer’s email system, be vigilant. Computer viruses are often sent by email and can cause significant damage to The Employer’s information systems.
    2. Any files or software downloaded from the internet or brought from home must be virus checked before use. Employees should not rely on their own pc to virus check any such programmes but should refer direct totheir line manager/ IT department. If you suspect that a file may contain a virus, do not open it and contact your line manager/ IT department immediately.
    3. Employees must not run any ‘.exe’ files. These should be deleted immediately upon receipt without being opened.

    1. The Employer reserves the right to monitor, intercept and read any internal or external email or fax or to listen to or record any telephone conversation for the purposes of monitoring and record keeping to establish facts, to establish compliance with regulatory or self-regulatory procedures, to prevent or detect crime, to investigate or detect the unauthorised use of The Employer’s telecommunication system or to ascertain compliance with The Employer’s practices or procedures. The Employer may also monitor, intercept, read, listen, or record communications to check whether communications are relevant to the business. The Employer also reserves the right to monitor internet usage to check compliance with obligations as set out above.
    2. The Employer has a right to protect the security of its systems, check that use of the system is legitimate, investigate suspected wrongful acts and otherwise comply with legal obligations imposed upon it.
    3. The Employer also reserves the right to read employees’ emails to check for business emails whilst they are absent or out of the office. The Employer may also access Employees’ voicemail to check for business calls whilst they are absent or out of the office. It may therefore be unavoidable that some personal messages will be read or heard.

    1. Where appropriate, The Employer may provide Employees with a mobile telephone and ‘hands free’ equipment sets for usage in vehicles. This equipment remains, at all times, the property of The Employer and must be returned immediately upon request and/or upon termination of employment. Employees provided with mobile telephones must comply with the following rules:

      • It is strictly prohibited to use mobile telephones whilst driving in a ‘handheld’ position. The Employer adopts a zero-tolerance approach to this and noncompliance may result in disciplinary action, up to and including summary dismissal, being taken against you.
      • All Employees provided with mobile telephones should use the telephone predominantly for work related purposes Is private usage allowed? All usage should be reasonable and sensible.
      • Mobile telephones should not be used abroad without the prior written permission of your line manager who must sanction the lifting of the ‘call barring’ facility. All personal calls made abroad, and all work-related calls made abroad (except where prior approval has been sought and given) must be paid for by the employee.

    1. The Employer considers this policy to be extremely important. If an employee is found to be in breach of this policy, then they will be disciplined in accordance with the disciplinary procedure. In certain circumstances, breach of this policy may be considered gross misconduct resulting in immediate termination of employment without notice or payment in lieu of notice. In addition, or as an alternative, The Employer may withdraw internet or email access.



    1. Style and language:

      • All emails should be addressed and signed off in a polite manner i.e. Dear/ Hello, Regards.
      • Emails do not always translate the emotion or feelings that were intended. Therefore, clear concise language should be used, and a review conducted to ensure that the message would not be misinterpreted.
      • Do not use slang or expletives. This is not acceptable business language.
      • If communicating a difficult issue, it may be appropriate to save as a draft and return to the email later to check the context and message given.
      • Lower case should be used in the majority of communications. Capital letters may be used to highlight or accentuate a point but may be interpreted as aggressive.
      • ‘Urgent stamps’ should only be used if they reflect the nature of the communication.
      • Check your email inbox at least once a day for new messages. Please ensure that you delete any unwanted emails, always reply with history, as the ongoing dialogue will be stored in one place rather than on a number of emails. Do not repeat an email request. It may be appropriate to follow up in person or via the telephone.
      • Conduct regular ‘housekeeping’: delete out-dated items and those items that have been superseded by later messages.
      • Manage the communication contained in emails. Remember they can be stored and printed and used as documentary evidence in libel, harassment, or disciplinary cases.
      • Remember data protection laws and only include suitable and relevant information regarding individuals.
    2. Sending Emails

      • Ensure you title all emails and that this accurately reflects the content of the message.
      • If you are sending an attachment, explain what it is in the document
      • Check the attachment prior to sending it to ensure it is the correct document.
      • Prior to sending an email, check the distribution list, re-read it, use spell check and ensure that it is conveying the correct messages to the readers.
    3. Receiving Emails

      • If you have been sent an email with an attachment and you are unsure what it contains, clarify this with the sender. This is particularly important if it is an .exe file. Do not open this file without checking its content as this can result in importing a virus into The Employer’s network with serious consequences where disciplinary action may be taken.
      • Never open email attachments where the sender is unknown to you, or where the subject matter is nothing to do with our business. Emails with curious messages or enticing subjects are used to encourage recipients to open email attachments that trigger viruses.
      • Do not open or respond to any ‘chain letters’.

    1. General

      • Laptops/workstations must be protected by passwords or other access control methods.
      • Back up takes place automatically when logged onto the server.
      • Ensure that the virus detection software is on your laptop/workstation. If new updates are downloaded follow instructions to re-boot your system.
      • Should you have had to load software from a diskette, CD Rom or other external source, it must be checked for viruses by the virus checker on your system.
      • If you have to leave your laptop/workstation unattended, ensure that it is either password locked or in the case of a laptop out of sight and locked away.
      • Laptops must not be left unattended in cars, as they are specifically uninsured in this situation.
      • Do not use your laptop/workstation for any other purpose than that which it was supplied for. It is not appropriate to utilise your laptop or workstation for personal use such as playing games. Use of the internet should be for business purpose only.
      • The theft or loss of your laptop should be reported immediately to your manager.
      • Laptop users who utilise battery power should discharge the battery completely once a week.

    1. General

      • Please do not share your password with anyone.
      • Make your password easy to remember but difficult to guess. In particular avoid any personal references such as car number plates; repeated characters or recognisable words. Good passwords are a mixture of letters, numbers, and punctuation characters.
      • Ensure that you use a screen saver for when you may wish to leave your workstation unattended for a short time. This should be of an appropriate nature – professional – no pin-ups or offensive material.
      • Do not allow anyone else to use your laptop or workstation whilst you are still logged on. Remember that you are responsible for all actions, which are carried out, under your user account.
      • Remember to close down your laptop/workstation at the end of the working day.

    1. General

      • If your virus checker or a fellow employee advises that a mail attachment has a virus, contact our service provider immediately, and telephone the person who sent you the message to advise them that their computer has a virus infection.
      • If you are told that you have a virus on your laptop/workstation then you should contact our service provider immediately.
      • If your laptop/workstation behaves irregularly by running slower than normal or displays odd characters or messages, changes locations etc then please contact our service provider.

    1. General

      • Change the privacy settings on your profile so that only people you have accepted as friends can see your content.
      • Review who is on your ‘friends list’ on your personal profile. In most situations you should not accept friend requests from clients or customers.
      • Ensure personal blogs have clear disclaimers that the views expressed by the author are theirs alone and do not represent the views of The Employer. Make your writing clear that you are speaking on behalf of yourself and not on behalf of The Employer. Ensure that any information published on the internet complies with The Employer’s confidentiality and data protection policies.
      • Ensure that you are always respectful towards The Employer, other Employees and workers, clients, and customers. You should be aware that any disrespectful comments might be seen as libellous.
      • The Employer trademarks and logos may not be used without written consent.
      • Be aware that in and out of work, at all time, you are an ambassador for The Employer. Any actions captured via images, posts or comments online can reflect on The Employer.

Data retention policy New


    1. The Employer holds many different types of documents containing a variety of data, including customer details, employee information as well as confidential information about the organisation and how it operates. These documents are a vital part of our business and it is important that we ensure that we protect the documents and information contained in them in order to ensure the smooth running of the business and also to comply with the requirements laid down by law.
    2. We have outlined the procedures laid down for retention, review and destruction of documents held by us. The purpose of this policy is to ensure that we only hold documents for as long as necessary and that once they are no longer required, they are destroyed in accordance with the procedures laid down in this policy.
    3. This policy supplements our Data Protection Policy.

    1. This policy sets out The Employer’s approach to managing its information to ensure that records and documents are preserved in line with business and legislative requirements and that data is not retained for any longer than necessary.
  3. SCOPE

    1. This Data Retention Policy applies to:

      • all staff, volunteers, consultants, contractors, trustees and, as appropriate,partnership organisations, partner staff and third parties of The Employer.
      • all records that are created, handled, stored, or processed by The Employer,electronically (soft copy) or in paper (hard copy) form.
      • All those people or groups to whom this policy applies should, as appropriate, be aware of this policy.

    1. Any exceptions or variations to compliance with this policy must be approved by the HR department.
    2. When preparing tender documents and/or negotiating contracts with third parties for services thatinvolve retaining and managing records, reference to this policy will help ensure that consistent data retention obligations are met.
    3. The intention is that only one copy of a record is retained but ensure that before you destroy any records in circumstances where you believe multiple copies of a record exist that at least one copy (or the original) is retained.
    4. Suppliers and their subcontractors must have their own defined retention policy, which must be supported by documented retention requirements and procedures and which mirrors this policy in all material respects.
    5. Unless suppliers (where they act as Data Processors) have a legal obligation to do so, they should not retain The Employer’s data after they have finished providing services to The Employer.

    1. The relevant types of record are:

      • Accounting and Finance.
      • Contracts.
      • Corporate Records.
      • Correspondence and Internal Memoranda.
      • Personal Information.
      • Electronic Records.
      • Grant Records.
      • Insurance Records.
      • Legal.
      • Miscellaneous.
      • Personnel Records.
      • Tax Records.

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

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

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

      • General Principle: Most correspondence and internal memoranda should be retained for the same period as the document to which they pertain or support. For instance, a letter pertaining to a particular contract would be retained as long as the contract (7 years after expiration). It is recommended that records that support a particular project be kept with the project and take on the retention time of that particular project file.
      • Correspondence or memoranda that do not pertain to documents having a prescribed retention period should generally be discarded sooner. These may be divided into two general categories:

        • Those pertaining to routine matters and having no significance. These should be discarded within five years. Some examples include:

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

      • This section sets out the data retention policies and procedure of The Employer, which are designed to help ensure compliance with legal obligations in relation to the retention and deletion of personal information.
      • Personal information that is processed by The Employer for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
      • Without prejudice to the point immediately above, The Employer will usually delete personal data falling within the categories set out below at the date/time set out below:

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

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

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

        • All e-mail—from internal or external sources – is to be deleted after 12 months.
        • Staff will strive to keep all but an insignificant minority of their e-mail related to business issues.
        • The Employer will archive e-mail for 90 days after the staff has deleted it, after which time the e-mail will be permanently deleted.
        • Staff will take care not to send confidential/proprietary information held by The Employerto outside sources.
      • Electronic Documents: including Office 365 and PDF files, retention also depends on the subject matter.
      • The Employer does not automatically delete electronic files beyond the dates specified in this Policy. It is the responsibility of all staff to adhere to the guidelines specified in this policy.
      • In certain cases, a document will be maintained in both paper and electronic form. In such cases the official document will be the electronic document.

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

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

      • Policy and Procedures Manuals – Original:Current version with revision history
      • Annual Reports:Permanent

      • Employee personnel records (including individual attendance records, application forms, job or status change records, performance evaluations, termination papers, withholding information, garnishments, test results, training and qualification records):6 years after separation
      • Employment contracts – Individual: 6 years after separation
      • Employment records correspondence with employment agencies and advertisements for job openings:3 years from date of hiring decision

      • General principle: The Employer must keep books of account or records as are sufficient to establish amount of gross income, deductions, credits, or other matters required to be shown in any such return.
      • These documents and records shall be kept for as long as the contents thereof may become material in the administration of state, and local income, franchise, and property tax laws.
      • Tax-exemption documents and related correspondence:Permanent
      • Tax bills, receipts, statements:7 years
      • Tax returns:Permanent
      • Sales/use tax records:7 years
      • Annual information returns:Permanent

Equal opportunities policy


    1. It is The Employer’s policy not to discriminate against its workers and/or employees because of their gender, marriage and civil partnership, sexual orientation, marital status, any gender reassignment, race, religion or philosophical belief, colour, nationality, ethnic or national origin, disability or age, pregnancy and maternity or trade union membership or the fact that they are a part-time worker or a fixed-term employee. The Employer will not tolerate discrimination by association and/or by perception and will not tolerate discrimination arising from disability. The Employer will not tolerate discrimination, because of any of the above grounds, of customers and/or clients in the provision of goods and services.
    2. The following paragraphs deal with the specific categories of workers and areas of work which we have identified as potentially giving rise to equal opportunities issues and provides more specific guidance on the parameters of our policy and approach to equal opportunities.

    1. This policy applies to The Employer’s employees, whether permanent, temporary, or casual, part-time or on fixed-term contracts, and to individuals such as agency staff and consultants.
    2. In addition, all workers have a duty to act in accordance with this policy, and therefore to treat colleagues with dignity at all times, and not to discriminate against or harass other members of staff, whether junior or senior to them. The Employer will not tolerate any discriminatory practices or behaviour and any such conduct may be viewed as gross misconduct entitling The Employer to dismiss you summarily.

    1. The Human Resources department has overall responsibility for the effective operation of this equal opportunities policy and for ensuring compliance with the relevant statutory framework prohibiting discrimination.
    2. All members of staff are responsible for the success of this policy and must ensure that they familiarise themselves with the policy and act in accordance with its aims and objectives.

    1. The Employer will not unlawfully discriminate because of gender, sexual orientation, marriage and civil partnership, gender reassignment, race, religion or philosophical belief, colour, nationality, ethnic or national origin, disability or age, pregnancy and maternity, trade union membership, or part-time or fixed-term status (“Protected Characteristics”).
    2. This policy applies, without limitation, to the advertising of jobs and recruitment and selection; to training and development; opportunities for promotion; to conditions of service, benefits and facilities and pay; to health and safety and to conduct at work, to grievance and disciplinary procedures and to termination of employment including redundancy.
    3. You are also prohibited from harassing another employee and/or worker on any of the grounds under 4.1. Harassment is defined as any unwanted conduct, related to any of the Protected Characteristics set out in paragraph 4.1 above, that has the purpose or effect of violating your dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment. It is not the intention of the perpetrator that is important when considering whether harassment has taken place but your perception of the behaviour. Harassment can range from extremes such as violence to less obvious forms such as ignoring someone. Forms of harassment might include (without limitation):

      • Physical contact;
      • Bullying;
      • Unwelcome remarks about someone’s race or marital status or any other Protected Characteristic;
      • Persistent criticism;
      • Jokes, offensive language, gossip, lewd or suggestive comments;
      • Posters, obscene gestures, graffiti;
      • Isolation, non-co-operation, and exclusion from social activities;
      • Coercion for sexual favours;
      • Failure to safeguard personal confidential information;
      • Unnecessary body contact; threatened or actual assault or violence;
      • Deliberate exclusion from conversations or work activities because of any Protected Characteristic;
      • Display of “pin ups”, pornography, inflammatory or abusive literature or graffiti:
      • Using email or the internet for the purpose of bullying or making abusive or offensive remarks related to any Protected Characteristic.
    4. You should be aware that, as well as committing a disciplinary offence, an individual found to have discriminated against a fellow employee/worker in the course of their employment may be personally liable to compensate the victim. In addition, harassment for whatever reason may constitute a crime under the Protection from Harassment Act 1997 punishable by imprisonment and/or a fine.

    1. Discrimination may be direct or indirect and it may occur intentionally or unintentionally. Direct discrimination occurs where someone is treated less favourably because they have one of the Protected Characteristics or are thought to have a Protected Characteristic as set out in paragraph 4.1 or because they associate with someone who has a Protected Characteristic.
    2. Indirect discrimination occurs when an unjustifiable requirement, condition or practice is imposed, apparently to all individuals, but has the effect that certain groups of individuals (who share a Protected Characteristic as set out in paragraph 4.1) cannot comply with it or are put at a particular disadvantage.
    3. Discrimination also includes victimisation (less favourable treatment because of action taken to assert legal rights against discrimination or to assist a colleague in that regard) and harassment.

    1. If you believe that you may have been disadvantaged because of any of the Protected Characteristics listed at paragraph 4.1 (or for any other reason) you are encouraged to raise the matter through The Employer’s grievance procedure. If you believe that you may have been harassed because of any Protected Characteristic listed at paragraph 4.1 (or for any other reason), you are encouraged to raise the matter through our grievance policy. Allegations regarding potential breaches of this policy will be treated in confidence and investigated in accordance with the relevant procedure.
    2. Workers who make such allegations in good faith will not be victimised or treated less favourably as a result. False allegations of a breach in this policy, which are found to have been made in bad faith will, however, be dealt with under our disciplinary procedure and may result in summary dismissal on grounds of gross misconduct.
    3. The Employer will not tolerate retaliation against, or victimisation of any employee involved in bringing of a complaint of harassment or bullying under The Employer’s procedure. Such retaliation or victimisation will itself constitute a disciplinary offence, which may in appropriate circumstances lead to dismissal.
    4. If, after investigation, you are proven to have harassed any other worker or otherwise act in breach of this policy, you will be subject to disciplinary action. Such behaviour may constitute gross misconduct and, as such, may result in summary dismissal. The Employer will always take a strict approach to serious breaches of this policy.
    5. As this policy applies equally to The Employer workers’ relations with clients and suppliers, if, after investigation, you are proven to have discriminated against or harassed a client or supplier you will also be subject to disciplinary action.

Disciplinary and dismissal procedure policy


    1. The aim of the disciplinary procedure is to provide a framework within which managers can work with employees to maintain satisfactory standards of conduct and to encourage improvement where necessary.
    2. It is our policy to ensure that any disciplinary matter is dealt with fairly and that steps are taken to establish the facts.

    1. This procedure does not apply to agency workers or self-employed contractors. It is for guidance only and does not form part of your contract of employment. This procedure does not apply to cases involving:

      • genuine sickness absence;
      • proposed redundancies; or
      • poor performance or capability.
    2. Minor conduct issues can normally be resolved informally between you and your manager. These discussions should be held in private and without undue delay whenever there is cause for concern. In some cases, an informal verbal warning may be given. Formal steps will be taken under this procedure if the matter is not resolved, or if informal discussion is not appropriate (for example, because of the seriousness of the allegation).
    3. Except in cases of gross misconduct, you would not normally be dismissed for a first act of misconduct. We will normally give you a warning and a chance to improve. We may not always apply this principle if your probationary period has not yet been completed.
    4. Any steps under this procedure should be taken promptly unless there is a good reason for delay. We may vary any time limits if it is reasonable to do so.
    5. If you have difficulty at any stage of the procedure because of a disability, you should discuss the situation with your manager or a member of the Human Resources department as soon as possible.

    1. Our aim during an investigation or disciplinary procedure is to deal with matters sensitively and with due respect for the privacy of any individuals involved.
    2. All employees must treat as confidential any information communicated to them in connection with an investigation or disciplinary matter.
    3. You will normally be told the names of any witnesses whose evidence is relevant to disciplinary proceedings against you, unless, in our discretion, we believe that a witness’s identity should remain confidential.
    4. Witnesses must treat as confidential any information given to them in the course of an investigation, including the identity of any employees under investigation.

    1. The purpose of an investigation is for us to establish a fair and balanced view of the facts before deciding whether to proceed with a disciplinary hearing. This may involve reviewing any relevant documents, interviewing you and any witnesses, and taking witness statements.
    2. Investigative interviews are solely for the purpose of fact-finding and no decision on disciplinary action will be taken until after a disciplinary hearing has been held.
    3. You do not normally have the right to bring anyone to an investigative interview. However, we may allow you to bring a companion if it helps you to overcome a difficulty caused by a disability, or any difficulty in understanding English.
    4. You must cooperate fully and promptly in any investigation. This will include informing us of the names of any relevant witnesses, disclosing any relevant documents to us and attending any investigative interviews.
    5. The amount of investigation required will depend on the nature of the allegations and will vary from case to case.

    1. In cases of alleged gross misconduct, we may need to suspend an employee from work while an investigation or disciplinary procedure is on-going. The suspension will be for no longer than necessary and we will confirm the arrangements to you in writing. While suspended you should not visit our premises or contact any of our clients, customers, suppliers, contractors, or employees, unless you have been authorised to do so by your line manager.
    2. Suspension of this kind is not a disciplinary sanction and does not imply that any decision has already been made about your case. You will continue to receive your full basic salary and benefits during the period of suspension.


    1. Following any investigation, if we consider there are grounds for disciplinary action, we will inform you in writing of the allegations against you and the basis for those allegations. This will normally include:

      • a summary of relevant information gathered during the investigation;
      • documents which will be used at the disciplinary hearing; and
      • witness statements which will be used at the hearing, except where a witness’s identity is to be kept confidential, in which case we will give you as much information as possible while maintaining confidentiality.
    2. You will have a reasonable opportunity to consider this information before the hearing.

    1. We will give you written notice of the date, time, and place of the disciplinary hearing, which will normally be held between two days and one week after you receive the written notice.
    2. The hearing will be chaired by your line manager. A member of Human Resources may also be present. You may bring a companion with you to the disciplinary hearing (see Right to be accompanied, below).
    3. You must take all reasonable steps to attend the hearing. Failure to attend a hearing without good reason may be treated as misconduct in itself. If you or your companion cannot attend at the time specified, you should inform us immediately and we will seek to agree an alternative time.
    4. The purpose of the disciplinary hearing is to review the evidence and to enable you to respond to any allegations that have been made against you. If you have a companion, he or she may make representations to us and ask questions but should not answer questions on your behalf. You may confer privately with your companion at any time during the hearing.
    5. It will not normally be necessary for witnesses to be questioned or cross-examined at the disciplinary hearing but, in exceptional cases, the manager responsible may decide in conjunction with Human Resources that a fair hearing could not be held otherwise.
    6. The disciplinary hearing may be adjourned if we need to carry out any further investigations. For example, we may decide to re-interview witnesses in light of any points that have been raised at the hearing. You will be given a reasonable opportunity to consider any new information obtained before the hearing is reconvened.
    7. As soon as possible following the disciplinary hearing, we will inform you in writing of our decision (including details of any misconduct that we consider you have committed, and the disciplinary sanction to be applied) together with the reasons for our decision. We will also inform you of your right of appeal. Where possible we will also explain this information to you in person.

    1. If you wish to appeal you should do so in writing to your line manager’s line manager within one week of the date on which you were informed of the decision.
    2. We will give you written notice of the date, time, and place of the appeal hearing. This will normally be between two days and one week after you receive the written notice. In cases of dismissal the appeal will be held as soon as possible
    3. .

    4. Where practicable, the appeal hearing will be held by a manager who is senior to the person who conducted the disciplinary hearing. You may bring a companion with you to the appeal meeting.
    5. If you raise any new matters in your appeal, we may need to carry out further investigation prior to the appeal hearing. If any new information comes to light, we will provide you with the details. You will have a reasonable opportunity to consider this information before the hearing.
    6. Following the appeal, we may:
      • confirm the original decision; or
      • revoke the original decision; or
      • substitute a different disciplinary sanction.
    7. We will inform you in writing of our final decision as soon as possible after the appeal hearing. Where possible we will also explain this to you in person. There will be no further right of appeal.
    8. The date on which any dismissal takes effect will not be delayed pending the outcome of an appeal. However, if the appeal is successful, you will be reinstated with no loss of continuity or pay.
    9. Right to be accompanied:
      • You may bring a companion to any disciplinary or appeal hearings under this procedure. The companion may be either a trade union official or a colleague. You must tell your line manager who your chosen companion is, in good time before the hearing.
      • Acting as a companion is voluntary and employees are under no obligation to do so. Employees will be allowed reasonable time off from duties without loss of pay to act as a companion.
    10. If your choice of companion is unreasonable, we may ask you to choose someone else. For example, this may be the case:
      • if in our opinion your companion may have a conflict of interest or may prejudice the hearing; or
      • if your companion works at another site and someone reasonably suitable is available at the site at which you work; or
      • if your companion is unavailable at the time a hearing is scheduled and will not be available for more than five working days.
    11. We may, at our discretion, allow you to bring a companion who is not an employee or union official (for example, a member of your family) where this will help overcome a particular difficulty caused by a disability, or where you have difficulty understanding English.

    1. We aim to treat all employees fairly and consistently. Disciplinary action previously taken against other employees for similar misconduct will usually be taken into account but should not be treated as a precedent. Each case will be assessed on its own merits. Depending on the seriousness of the matter any of the following stages may be omitted.
    2. Stage 1: verbal warning

      • You may be given a verbal warning for a minor act of misconduct where you have no other active warnings on your disciplinary record.
      • The warning will set out the nature of the misconduct, the change in behaviour required and the likely consequences of further misconduct.
      • A record of the warning will be placed permanently on your personnel file and will remain active for six months from the date it is given, after which time it will normally be disregarded in deciding the outcome of future disciplinary proceedings. Your conduct may be reviewed at the end of this period and if it has not improved sufficiently, we may decide to extend the active period.
    3. Stage 2: first written warning

      • A first written warning will usually be given for:

        • first acts of misconduct where there are no other active warnings on your disciplinary record; or
        • minor misconduct where there is an active verbal warning on your record.
        • The warning will set out the nature of the misconduct, the change in behaviour required and the likely consequences of further misconduct.
        • The warning will be placed permanently on your personnel file and will remain active for six months from the date it is given, after which time it will normally be disregarded in deciding the outcome of future disciplinary proceedings. Your conduct may be reviewed at the end of this period and if it has not improved sufficiently, we may decide to extend the active period.
    4. Stage 3: final written warning

      • A final written warning will usually be given for:
        • misconduct where there is already an active written warning on your record; or
        • cases where there is no active written warning on file, but we consider that the misconduct is sufficiently serious to warrant a final written warning.
      • The warning will set out the nature of the misconduct, the change in behaviour required and the likely consequences of further misconduct.
      • The warning will be placed permanently on your personnel file and will normally remain active for 12 months or, if we decide that the matter is more serious, for a longer period. Your conduct may be reviewed at the end of this period and if it has not improved sufficiently, we may decide to extend the active period. After the active period it will normally be disregarded in deciding the result of future disciplinary proceedings. In exceptional cases verging on gross misconduct, a warning may remain active indefinitely.
    5. Stage 4: dismissal

      • We may decide to dismiss you in the following circumstances:
        • misconduct where there is an active final written warning on your record; or
        • gross misconduct regardless of whether you have received any previous warnings.
      • Gross misconduct will usually result in summary dismissal, that is, dismissal without notice or payment in lieu of notice. In cases not involving gross misconduct you will be given your full contractual notice period, or payment in lieu of notice.
      • As a guideline (and by means of illustration only) the following are examples of what may constitute gross misconduct:

        • Falsification of records such as Expense/Time Sheets, overtime claims, customer orders.
        • Theft, fraud or intent to defraud.
        • Extensive abuse of the Company’s facilities e.g. personal telephone calls, e-mail, Internet or postal service for personal use
        • Reckless or serious misuse of Company vehicle.
        • Falsification of information on appointment.
        • Sleeping on duty.
        • Rudeness to customers of the Company.
        • Viewing, downloading and copying of pornographic or other offensive material
        • Sending defamatory, abusive, sexist, or racist messages
        • Knowingly using Company systems to create and/or distribute viruses
        • Creating and/or distributing illegal copies of software
        • Hacking attacks on Company systems or third party systems
        • Disclosing Company passwords to access Company computers
        • Accepting a gift which could be construed as a bribe.
        • Sexual, racial or any other form of harassment.
        • Conviction for any serious criminal offence whilst an employee.
        • Wilful damage to the property of the Company or other employees.
        • Assault within the work place
        • Inability to work effectively due to the influence of alcohol or illegal drugs.
        • Unauthorised disclosures of confidential information.
        • Unauthorised absence.
        • Serious insubordination.
        • Breach of Health and Safety rules
        • Smoking
        • This list must not be regarded as exhaustive, but merely illustrative.
    6. Alternative sanctions short of dismissal

      • In appropriate cases we may consider some other sanction short of dismissal, such as:

        • demotion;
        • transfer to another department or job;
        • period of suspension without pay;
        • loss of seniority;
        • reduction in pay;
        • loss of future pay increment or bonus;
        • loss of overtime.
        • These sanctions may be used in conjunction with a written warning.