plan.com
Staff handbook

Welcome to plan communications limited

1. Welcome to plan.com – As you will know by now we are Telecommunications Company headquartered in the Isle of Man and operating within the United Kingdom. We’re an innovative and creative team with a passion for simplifying business connectivity through the power of technology and we try to instil this passion into everything we do.
2. Your contract sets out you individual terms with the company and the handbook offers you guidance on how our processes work, what documentation is required and where to go to find all sorts of other things you may need during your career with plan.com.
3. This handbook is non-contractual which means it will change from time to time to make sure its relevant and reflects how we do things.

   Our History

4. Co-Founders Dan Craddock and Keith Curran launched plan.com in 2014 with an ambitious vision – to use digital technology to transform the business mobile channel – one of the fastest growing but under-utilised telecoms markets in the world.
5. In less than seven years, this determination saw our market- share and revenue growth sky rocket, earning us the coveted No1 ranking in the 2018 Sunday Times Tech Track 100 and a placement in every edition since. We’re also ranked in the FT 1000 list of Europe’s Fastest Growing Companies and have been recognised for the Best Use of Innovation at the UK Tech Business Awards in 2020 and 2021. As an early market leader in the Business Mobile channel, our technical expertise and investment has seen our rapid expansion into all aspects of business communications, from hosted voice and fixed line to Internet of Things and Broadband technology.
6. Today we provide more than business communications. We’ve set the industry standard with my.plan, the ultimate connectivity platform. Where mobile and office-based communications converge to deliver a level of insight and control that is beyond anything that any telecoms network can, or ever will deliver.
7. Our growth has been impressive but our people and culture are EXCEPTIONAL.

plan.com values – Trust, Passion, Excellence

1. Our company values are our DNA, they’re what separate us from other companies. Our values are, TRUST, PASSION, EXCELLENCE  – they reflect our business beliefs, principles and decisions and influence how we deliver our business through our behaviours, relationships and decision making.   Our values apply to everyone in the business and we demonstrate our values in everything that we do.
2. Equal Opportunities and values – At plan.com we believe that everyone in the organisation should be able to achieve his or her full potential in an environment characterised by dignity and mutual respect.
   This means that everyone who works with us, or applies to work with us will be treated fairly and valued equally. All conditions of service and job requirements will fit with the needs of the business and those who work in it, regardless of age, disability, race, nationality, ethnic or national origin, gender, religion, beliefs, sexual orientation, domestic circumstances, social and employment status, gender reassignment, political affiliation or trade union membership or any other judgemental or stereo typical view negatively applied to our people.
   At plan.com we strive to be a place where people want to work, creating opportunities for all, led by those who are capable of helping you to become the very best that you can be.

Using the staff handbook

1. This non-contractual Staff Handbook sets out the main policies and procedures that you will need to be aware of while working for us. You probably won’t sit down and read this cover to cover but as you progress through your plan.com journey you should familiarise yourself with the various sections.
2. You must comply with the standards and policies contained within it which have been designed to protect and simplify processes to ensure consistency. Any questions you may have with regard to its contents or what you have to do to comply with it should be referred to your line manager, Human Resources Team or the Director of People.
3. The policies and procedures that set out our behaviours in this handbook apply to everyone, directors, interns, contractors/consultants, temps and casual staff(collectively referred to as staff in this policy) of Plan Communications Limited (trading as plan.com). As well as any company, firm or organisation affiliated with the Company, or a member of the Company’s group, from time to time. They do not form part of the terms of your contract with us, which are provided to you separately.

Responsibility for the staff handbook

1. Our board of directors (the Directors) has overall accountability for the operation of the processes within this Staff Handbook. The HR team in collaboration with other teams where specific specialism is required, will maintain it and make sure it contains information that is useful and supportive and meets our obligations as a responsible employer within the framework of legislation and best practice.
2. The Staff Handbook will be reviewed frequently by the board in conjunction with the Human Resources Team to ensure that its provisions continue to meet our legal obligations and reflect best practice.
3. Managers have a specific responsibility to ensure that they operate in accordance with the provisions set out in this Staff Handbook, to ensure that all staff understand the way things work and the standards of behaviour and safety expected of them. Our directors, managers and team leaders (everyone with a people management responsibilities) have a specific responsibility to set an appropriate standard of performance and behaviour. Leading by example, as ambassadors for our values, policies and procedures.
4. Everyone should ensure that they take the time to read and understand the content of this handbook and act in accordance with its aims and objectives. Where you find any gaps or improvements we can make please let the HR team know, who will update this handbook from time to time.
5. Questions about the content or application of the handbook should be directed to your line manager, the HR Team or a Director.
6. It’s important to us that we know how to contact you so it’s important that you keep your personal information up to date. Most importantly, we will need to know who to contact should you be taken ill whilst in the office. You will be expected to keep your home address, next of kin and emergency contact telephone numbers up to date.

Dress code and appearance

Dress Code 

1. The purpose of our dress code is to ensure that we dress in a way that reflects the professional image of the business. To do this we provide basic guidelines on appropriate clothing and appearance at work which include:
   1. promote a positive image and staff look professional;
   2. supporting religious/belief in terms of appropriate work wear and disability in the application of the dress code.
   3. take account of Health, Safety and Wellbeing requirements;
2. Any enquiries regarding the operation of our dress code (including whether an article of clothing is suitable to wear to work) should be made to your line manager.

   Appearance

3. Your appearance also impacts on the reputation of the business with partners, clients, suppliers and in the community generally. It is important that you look clean and smart at all times when at work, dressing in a manner appropriate to your working environment and the type of work you do, particularly when you may be in contact with clients, other business contacts or the general public.
4. You may be asked to cover up visible tattoos or to remove or cover up visible body piercings depending on the type of work that you do.
5. Staff should not wear casual, gym or beach wear to work. This includes track suits, sweat-shirts, hoodies, casual or sports t-shirts or beach shorts, combat trousers, jogging bottoms, or leggings. Clothing should not be dirty, frayed or torn. Tops should not carry wording or pictures that might be offensive or cause damage to our reputation. It is inappropriate to wear clothing such as cut-off shorts, crop tops, see through material or clothes that expose areas of the body normally covered at work.
6. Footwear must be safe and clean and take account of health and safety considerations. Trainers and plastic flip-flops are not acceptable.
7. Staff should not wear clothing or jewellery that could present a health and safety risk.

   Religious and cultural dress

8. Staff may wear religious and cultural dress providing it does not impede their ability to undertake their role or compromises the health and safety of the wearer, their colleagues or any other person. For further information please contact the HR team.

   Implementing and reviewing our dress code

9. Managers are responsible for ensuring that staff observe the standards set by this dress code.
10. Failure to comply with the dress code may result in being sent home to change (in your own time) and possibly formal disciplinary action being taken.

Employment Policy

1. Our Company Policy
   1. Our HR / personnel policies and procedures meet legislative requirements and are regularly reviewed and updated
   2. We provide all our employees with a Staff Handbook, and updates (as and when required);
   3. We are an equal opportunities employer and apply equal opportunities throughout our recruitment and selection, training, promotion, reward, retention, development or any other employment practices;
   4. We will endeavour to provide a workplace free from all forms of illegal discrimination, and provide equality of opportunity to every employee and job applicant;
   5. We will endeavour to provide a workplace free from sexual or other forms of harassment, and deal with any allegations of harassment or bullying promptly and confidentially;
   6. Any complaints of discrimination will be treated seriously and acted upon promptly;
   7. Our recruitment and selection decisions will be based solely on an applicant’s knowledge, skills, qualifications and ability to do the job role;
   8. We will take steps to assess an applicant’s suitability for a job role via our recruitment and selection procedures and by conducting various pre-employment checks;
   9. We will comply with our requirements as an employer, undertaking any immigration procedures (visa or work permit applications and renewals), as required. If the Company is unable to obtain any necessary visa or work permit, then the Company’s offer of employment will be withdrawn. Where the Company is unable to renew or extend a visa or work permit, then the employee’s employment will be terminated;
   10. We offer coaching and training to help equip staff to perform in their present job, and develop and prepare them for any future responsibilities;
   11. Employees are encouraged to discuss any concerns or issues at the earliest opportunity with management;
   12. Where the Company receives requests to provide references on behalf of any employee / ex-employee, these will be dealt with by the HR Team. No other individual is authorised to provide a reference (whether in writing or via telephone) on behalf of the Company
   13. We will provide employees, contractors and workers with an Employee Privacy Notice detailing how we collect and use their personal data during and after their working relationship with us.
2. Pre-employment Checks
   1. It is the Company’s policy to employ the very best and suitable applicants. In order to support this requirement, the Company will take steps to assess an applicant’s suitability for a job role via its recruitment and selection procedures and by conducting various pre-employment checks which it deems to be satisfactory. Pre-employment checks may include (but may not be limited to) identity and nationality verification, education and/or professional qualification verification, employment and personal references, credit checks, and Disclosure and Barring Service (DBS) checking procedures (Criminal background check).
   2. Offers of employment will be conditional upon the receipt of satisfactory pre-employment checks. Where the Company is unable to complete or obtain pre-employment checks to its satisfaction, then the Company’s offer of employment will be withdrawn. The Company reserves the right to conduct any pre-employment checks which it deems appropriate.
   3. Only authorised staff will complete pre-employment checking procedures, the details of which will be held confidentially with restricted access. Usually background checks are only initiated at the offer of employment stage; however, the Company may, from time to time, initiate additional checks at any time during an individual’s employment with the Company, such as in the event that there are reasons to believe circumstances have changed which may affect an employee’s job role; or where additional legislation or regulation or company policy requires it.
3. Immigration, Work Permit, UK Visa, or Settled Status confirmation
   1. We are required by law to ensure that all employees are entitled to work in the United Kingdom and/or the Isle of Man (as applicable). Assumptions about immigration and work permit status will not be made based on appearance or apparent nationality. All prospective staff, regardless of nationality, must be able to produce original documents (such as a passport or birth certificate) before employment starts, to satisfy current immigration and control of employment legislation.

Equal opportunities policy

1. plan.com is an equal opportunities employer. We are committed to ensuring equality of opportunity, fairness of treatment, dignity at work, and the elimination of all forms of discrimination in the workplace. It is the Company’s policy to treat all people, including job applicants, equally and fairly, irrespective of their age, disability, gender reassignment, marriage and civil partnership status, pregnancy and maternity, race, religion or belief, sex, sexual orientation (‘protected characteristics’) or trade union membership or non-membership.
   All employees are expected to treat all others with dignity and respect, including colleagues, clients, visitors, suppliers and business associates.
2. The Company endeavours to ensure that no policy, procedure, provision, rule, requirement, condition or criterion is imposed on any person without justification if it would be likely to put that person at a disadvantage on any of the above grounds. We will take appropriate steps to accommodate the requirements of different religions, cultures, and domestic responsibilities.
3. You must not unlawfully discriminate against or harass other people including employees, job applicants, clients, customers, suppliers or visitors. This applies in the workplace, outside the workplace (when dealing with customers, suppliers or other work-related contacts), and on work-related trips or events including social events.
4. Under the Employment Act there are 9 personal characteristics which are specifically protected in law. As a business we extend this to commit to treat everyone with dignity and respect. The 9 protected personal characteristics are:
   • Age
   • Disability
   • Gender Reassignment
   • Marriage and civil Partnership
   • Pregnancy and maternity
   • Race
   • Religion or belief
   • Sex
   • Sexual Orientation

   What is discrimination

5. Discrimination can take lots of different forms the following forms of discrimination are unlawful and are therefore prohibited:
   • Direct Discrimination: treating someone less favourably because of a ‘protected characteristic’. For example, rejecting a job applicant because of their religious views or because of their race.
   • Indirect Discrimination: a provision, criterion or practice that applies to everyone but adversely affects people with a particular ‘protected characteristic’ more than others and is not justified. For example, a company has a policy only to promote a person who has successfully obtained a post-graduate qualification which could be discriminatory against a 21-year-old who is less likely to have such a qualification.
   • Harassment: this includes sexual harassment and other unwanted conduct related to a ‘protected characteristic’, which has the purpose or effect of violating someone’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. Harassment is dealt with under the Company’s Anti-Harassment and Bullying Procedure – see clause 7.3
   • Victimisation: retaliation against someone who has complained or has supported someone else’s complaint about discrimination or harassment.
   • Disability discrimination, this includes direct and indirect discrimination, any unjustified less favourable treatment because of the effects of a disability, and failure to make reasonable adjustments to alleviate disadvantages caused by a disability, where practicable.

   Equal Opportunities in Recruitment and Selection

   1. Recruitment, promotion and other selection exercises including redundancy selection will be conducted on the basis of merit against objective criteria that avoids discrimination. Shortlisting should be completed by more than one person.
   2. Advertisements must avoid stereotyping or using wording that may discourage particular groups from applying.
   3. Job applicants must not be asked questions which might suggest an intention to discriminate on grounds of a ‘protected characteristic’. For example, applicants must not be asked whether they are pregnant or planning to have children; what church they attend or whether they would be prepared to attend the company ‘running club’.
   4. Job applicants must not be asked about health or disability before a job offer is made, except in the very limited circumstances allowed by law. For example – to check that the applicant could perform an intrinsic part of the job (taking account of any reasonable adjustments), or to see if any adjustments might be needed at interview because of a disability.
   5. Where necessary, job offers can be made conditional on a satisfactory medical check. Health or disability questions may be included in equal opportunities monitoring forms, which must not be used for selection or decision-making purposes.
   6. We will check that all employees are entitled to work in the country of their office. Assumptions about immigration status must not be made based on appearance or apparent nationality. All prospective employees, regardless of nationality, must be able to produce original documents (such as a passport) before employment starts.
6. Disability – If you are disabled or become disabled, we encourage you to tell us about your condition so that we can consider what reasonable adjustments or support may be appropriate.
7. Part-Time and Fixed-Term Work – Part-time and fixed-term employees will be treated the same as comparable full-time or permanent employees and enjoy no less favourable terms and conditions (on a pro-rata basis where appropriate), unless different treatment is justified.
8. Our Equality Commitment
   The Company is committed to:
   1. Ensuring that all staff responsible for recruiting and making employment decisions understand the legal, moral and business reasons for providing equal opportunities at work, and that decisions made will be based solely on job-related criteria and the individual’s merits and abilities;
   2. Ensuring that criteria in selection, promotion, training and development, and performance reviews will be based solely on the person’s merit and their ability to accomplish the work
   3. Ensuring that at all times and in every aspect of recruitment, selection, training and development that everyone is dealt with in a non-discriminatory way;
   4. Providing training and development based on an objective assessment of an individual’s need and ability;
   5. Providing a working environment that is free from any forms of discrimination, harassment or intimidation; and operating procedures for effectively resolving any complaints received;
   6. Ensuring that employees are treated fairly, and any decisions made about them will not be based on bias, prejudice or stereotyping;
   7. Treating any breaches of the Company’s Equal Opportunities Policy as misconduct, or potentially gross misconduct.
9. The Company is committed to the implementation of this policy and ensuring that it is fully effective. The overall responsibility for the policy and its monitoring lies with the Directors and the Steering Group. It is the personal responsibility of ALL employees at every level within the Company to comply with the spirit and terms of this policy, which extends to the treatment of employees, prospective employees, and clients.
10. All people involved in the recruitment, selection, management, promotion and development of employees are responsible for the practical application of the policy. The Company recognises that the provision of equal opportunities in the workplace is not only good management practice, but it also makes sound business sense. A breach of the Company’s Equal Opportunities Policy and any unfair or unlawful discrimination will not be tolerated and will be dealt with under the Company’s Disciplinary Policy and Procedure. In serious cases, this could lead to dismissal.
11. Any employee who believes that they have been unfairly discriminated against should raise their concern in the first instance with their Manager or, HR, or with a Director of the Company. Managers are required to treat any reports of discrimination seriously and if they suspect that there may be inappropriate conduct, they must take action immediately. All concerns and complaints raised must be investigated in a fair, timely and confidential manner.
12. All employees should refrain from taking discriminatory actions or decisions which are contrary to either the letter of or to the spirit of the Company’s Equal Opportunities Policy. No employee should instruct, induce, or attempt to induce or pressurise any other person to act in breach of this policy.
13. Employees should not bring forward an untrue or malicious claim. If they are suspected of doing so this will be dealt with under the Company’s Disciplinary Policy and Procedure.
14. All employees are encouraged to address and / or report behaviours which breach the Company’s Equal Opportunities Policy.
15. Equal Opportunity Training and Awareness – All staff will be given appropriate training with regard to equal opportunities which will be co-ordinated through the HR team and include using computer based training modules to ensure that everyone is kept up to date.
16. Managers will be expected to ensure that their own training is up to date and visibly applied; and that their team and other direct reports are aware of the standards required and that they are applied.
17. Equality and Staff Training and Development – Staff training needs will be identified through regular staff reviews. All staff will be given appropriate access to training to enable them to progress within the organisation and all promotion decisions will be made on the basis of merit.
    1. Our conditions of service, benefits and facilities are reviewed regularly to ensure that they are available to all staff who should have access to them and that there are no unlawful obstacles to accessing them.

    Equality and Termination of employment

18. We will ensure that redundancy criteria and procedures are fair and objective and are not directly or indirectly discriminatory.
19. We will also ensure that disciplinary procedures and penalties are applied without discrimination, whether they result in disciplinary warnings, dismissal or other disciplinary action.
    Equality and Part-time, limited – term and agency workers
20. Both part-time and limited-term staff will be treated the same as comparable full-time or permanent staff, and enjoy no less favourable terms and conditions (pro-rata’d as appropriate), unless different treatment is objectively justified.

    Breaches of this policy

21. If you believe that you may have been discriminated against you are encouraged to raise the matter informally in the first instance with the person that you believe has acted inappropriately. If you don’t feel that you can do this you should raise the issue with your manager or with one of the HR team if more appropriate. You can also address such issues formally through the Grievance Procedure. If you are uncertain where to start please don’t hesitate to have an informal conversation with one of the HR Team who will be happy to discuss the situation and will be able to explain what options are available and how to access them.
22. All allegations regarding potential breaches of this policy will be treated in confidence and investigated in accordance with the relevant procedure. Staff who make such allegations in good faith will not be victimised or treated less favourably as a result. False allegations which are found to have been made in bad faith will, however, be dealt with under our Disciplinary Procedure.
23. Any member of staff who is found to have committed an act of discrimination or harassment will be subject to disciplinary action. Such behaviour may constitute gross misconduct and, as such, may result in summary dismissal.

Anti-harassment and bullying policy

1. The purpose of this policy is to ensure that all staff are treated and treat others with dignity and respect, free from harassment and bullying. All staff should take the time to ensure they understand what types of behaviour are unacceptable under this policy.
2. This policy covers harassment or bullying which occurs both in and out of the workplace, such as on business trips or at events or work-related social functions. It covers bullying and harassment by staff and also by third parties such as customers, suppliers or visitors to our premises.
3. Staff must treat colleagues and others with dignity and respect, and should always consider whether their words or conduct could be offensive. You must consider how your words or actions will be received not necessarily how you intended them. Even unintentional harassment or bullying is unacceptable and could result in disciplinary action.

   What is harassment?

4. Harassment is any unwanted physical, verbal or non-verbal conduct which has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. A single incident can amount to harassment.
5. It also includes treating someone less favourably because they have submitted or refused to submit to such behaviour in the past.
6. Unlawful harassment may involve conduct of a sexual nature (sexual harassment), or it may be related to age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation. Harassment is unacceptable even if it does not fall within any of these categories.
7. Harassment is normally characterised by more than one incident of unacceptable behaviour, particularly if it reoccurs, once it has been made clear by the victim that they consider it offensive. One incident may constitute harassment if it is sufficiently serious. Harassment on any grounds, will not be tolerated.
8. Harassment may include, for example:
   1. unwanted physical conduct or “horseplay”, including touching, pinching, pushing, grabbing, brushing past someone, invading their personal space, and more serious forms of physical or sexual assault;
   2. unwelcome sexual advances or suggestive behaviour (which the harasser may perceive as harmless), and suggestions that sexual favours may further a career or that a refusal may hinder it;
   3. continued suggestions for social activity after it has been made clear that such suggestions are unwelcome;
   4. sending or displaying material that is pornographic or that some people may find offensive (including e-mails, text messages, video clips and images sent by mobile phone or posted on the internet);
   5. offensive or intimidating comments or gestures, or insensitive jokes or pranks;
   6. mocking, mimicking or belittling a person’s disability;
   7. racist, sexist, homophobic or ageist jokes, or derogatory or stereotypical remarks about a particular ethnic or religious group or gender;
   8. outing or threatening to out someone as gay or lesbian; or
   9. ignoring or shunning someone, for example, by deliberately excluding them from a conversation or a workplace social activity.
9. An employee may be harassed even if they were not the intended “target”. For example, a person may be harassed by racist jokes about a different ethnic group if the joke resulted in what the employee considered to be an offensive environment.
   It should be noted that the examples above do not have to occur on Company premises or time and that they can apply in terms of employees, clients or visitors, or any other person who employees may come into contact with through their links to the Company.

   What is bullying?

10. Bullying is a gradual wearing down process comprising a sustained form of psychological abuse that makes victims feel demeaned and inadequate. Bullying can take many forms. It is generally accepted as unwanted behaviour that offends, persecutes or excludes someone. It includes treating individuals in a demeaning and unacceptable way and can be intimidating, malicious or insulting, or a misuse of power to undermine, humiliate, threaten or cause injury.
    1. Workplace bullying can range from extreme forms such as violence and intimidation to less obvious actions like deliberately ignoring someone at work. These can be split into two categories and must be viewed in terms of the distress they cause the individual.
    2. The obvious – include: shouting or swearing at people in public and private; persistent criticism; ignoring or deliberately excluding people; persecution through threats and instilling fear; spreading malicious rumours; constantly undervaluing effort; dispensing disciplinary action that is totally unjustified; spontaneous rages, often over trivial or minor matters.
    3. The less obvious – include: withholding information or supplying incorrect information; ignoring or exclusion of one of the team, deliberately sabotaging or impeding work performance; removing areas of responsibility and imposing menial tasks.
11. Legitimate, reasonable and constructive criticism of a worker’s performance or behaviour, or reasonable instructions given to workers in the course of their employment, will not amount to bullying on their own.
    1. It should be noted that the examples above do not have to occur on Company premises or time and that they can apply in terms of employees, clients, or visitors or any other person who employees may come into contact with through their links to the Company.
       1. Managers are responsible for:
          • Monitoring the working environment to ensure that acceptable standards of conduct are observed at all times and to model appropriate behaviour themselves;
          • Treating all issues raised seriously and confidentially;
          • Immediately notifying a Director of the Company of any bullying or harassment complaints, or suspicions of such behaviour going on;
          • Taking any other actions as required of them by the Company in relation to dealing with acts of bullying or harassment.
       2. All employees are responsible for:
          • Co-operating with any measures introduced by the Company to manage bullying or harassment in the workplace;
          • Refraining from taking any actions which could be considered or construed as acts of bullying or harassment;
          • Bringing to the attention of their Manager or a Director of the Company immediately any concerns relating to bullying or harassment at work;
          • Not bringing forward an untrue or malicious claim or deliberately misleading the Company during any investigation. If an employee is suspected of doing so this will be dealt with under the Company’s Disciplinary Policy and Procedure; and
          • Resolving any issues on an informal basis, where possible. If employees feel comfortable in doing so they should:
            • Report their observations of the offender’s behaviour clearly and accurately;
            • Explain the impact of the offender’s behaviour on them;
            • Clearly state that they want the behaviour to stop;
            • If possible, describe an alternative behaviour that creates a more positive interaction.
          • An employee who feels that they are the subject of retaliation due to raising a concern in relation to this policy should report the situation to a Director of the Company as soon as possible.
12. Staff should disclose any instances of harassment or bullying of which they become aware to the Human Resources Team or a Director.

Managing a complaint

Process for handling a complaint of bullying, harassment of victimisations

Step 1 – Informal steps

1. If you believe you are being bullied or harassed, you should initially consider raising the problem informally with the person responsible, if you feel able to. You should explain clearly to them that their behaviour is not welcome or makes you uncomfortable. If this is too difficult or embarrassing, you should speak to your line manager or the Human Resources Team, who can provide confidential advice and assistance in resolving the issue formally or informally.
2. If you are not certain whether an incident or series of incidents amount to bullying or harassment, you should initially contact your line manager or the Human Resources Team informally for confidential advice.
3. If informal steps have not been successful or are not possible or appropriate, you should follow the formal procedure set out below.

   Raising a formal complaint

4. If you wish to make a formal complaint about bullying or harassment, you should submit it in writing to your line manager; if the complaint is against your line manager, you should direct your complaint to the Director of People , whose role is to achieve a solution wherever possible and to respect the confidentiality of all concerned. Where this is not possible your complaint will be forwarded to another senior manager to carry out an formal investigation and meeting which will reach a decision.
5. Your written complaint should set out full details of the conduct in question, including the name of the harasser or bully, the nature of the harassment or bullying, the date(s) and time(s) at which it occurred, the names of any witnesses and any action that has been taken so far to attempt to stop it from occurring.
6. Once you have submitted your complaint the person against whom you have complained will be formally informed of it. They will be given an opportunity to respond and seek their own support.
7. As a general principle, the decision whether to progress a complaint is up to you. However, we have a duty to protect all staff and may pursue the matter independently if, in all the circumstances, we consider it appropriate to do so.

   Formal investigations

8. Where it isn’t possible to resolve the issue informally, we will investigate complaints in a timely and confidential manner. Individuals not involved in the complaint or the investigation should not be told about it. The investigation will be conducted by someone with appropriate experience and wherever possible, no prior involvement in the complaint. The investigation should be thorough, impartial and objective, and carried out with sensitivity and due respect for the rights of all parties concerned.
9. We will arrange a meeting with you, usually within one week of receiving your complaint, so that you can give your account of events. You have the right to be accompanied by a colleague or a trade union representative of your choice, who must respect the confidentiality of the investigation. You will be given a provisional timetable for the investigation. The investigator may arrange further meetings with you as appropriate throughout the investigation.
10. Where your complaint is about an employee, we may consider a precautionary suspension on full pay or making other temporary changes to working arrangements pending the outcome of the investigation, if circumstances require. This would be a last resort, and every effort will be made to avoid any kind of precautionary suspension. The investigator will also meet with the alleged harasser or bully who may also be accompanied by a colleague or trade union representative of their choice to hear their account of events. They have a right to be told the details of the allegations against them, so that they can respond.
11. Where your complaint is about someone other than an employee, such as a contractor, customer, service user, supplier, or visitor, we will consider what action may be appropriate to protect you and anyone involved pending the outcome of the investigation, bearing in mind the reasonable needs of the business and the rights of that person. Where appropriate, we will attempt to discuss the matter with the third party.
12. It may be necessary to interview witnesses to any of the incidents mentioned in your complaint. If so, the importance of confidentiality will be emphasised to them.
13. At the end of the investigation, the investigator will submit a report to a Director (or their delegate) nominated to consider/’hear’ the complaint. The Director (or delegate) will arrange a meeting with you, usually within a week of receiving the report, in order to discuss the outcome and what action, if any, should be taken. You have the right to be bring a colleague or a trade union representative to the meeting. A copy of the report and the Director’s findings will be given to you and to the alleged harasser.

    Action following the investigation

14. If the Director considers that harassment or bullying has occurred, prompt action will be taken to address it.
15. Where the harasser or bully is an employee the matter will be dealt with as a case of possible misconduct or gross misconduct under our Disciplinary Procedure.
16. Where the harasser or bully is a third party, appropriate action might include putting up signs setting out acceptable and unacceptable behaviour; speaking or writing to the person and/or their superior about their behaviour; or, in very serious cases, ‘banning’ them from the premises for a period of up to 14 days pending the outcome of an investigation (or such longer period as is deemed appropriate or necessary by the Company acting reasonably) or terminating a contract with them.
17. Whether or not your complaint is upheld, we will consider how best to manage the ongoing working relationship between you and the alleged harasser or bully. It may be appropriate to arrange some form of mediation / facilitation, it may not always be possible to change the duties, working location or reporting lines of one or both parties but this will also be considered where appropriate.
18. Any staff member who deliberately provides false information or otherwise acts in bad faith as part of an investigation may be subject to action under our Disciplinary Procedure.

    Appeals

19. You will receive a letter confirming the decision of the Director (or their delegate). This letter will out line how you should appeal the decision if you are not satisfied with the outcome. Wherever possible, an alternative Director to the one who carried out the original investigation will hear your appeal. You will be required to provide a formal written request for an appeal within 7 calendar days from the date of the letter confirming outcome of the grievance; stating the reason for your appeal. ,
20. We will hold an appeal meeting, normally within one week of receiving your written appeal. This will be dealt with impartially and wherever possible, by a manager who has not previously been involved in the case (although they may ask anyone previously involved to be present). You may bring a colleague or trade union representative to the meeting.
21. We will confirm our final decision in writing, usually within one week of the appeal hearing. This is the end of the procedure and there is no further appeal.

    Protection and support for those involved

22. Staff who make complaints or who participate in good faith in any investigation conducted under this policy must not suffer any form of retaliation or victimisation as a result.
23. If you believe you have suffered any such treatment you should inform your line manager or the Human Resources Team . If the matter is not remedied you should raise it formally using our Grievance Procedure.
24. Anyone found to have retaliated against or victimised someone for making a complaint under this procedure will be subject to disciplinary action under our Disciplinary Procedure.

Anti-corruption, bribery and gifts from third parties – policy

1. The Company is committed to operating a zero-tolerance approach to the making or receiving of bribes or corrupt payments, in any form. We are committed to doing the right things, in the right way to ensure that the highest standards of honesty and integrity are maintained and that we comply with applicable anti-bribery legislation.
2. Bribery is the offering, promising, giving, accepting or soliciting of an advantage as an inducement for action which is illegal or a breach of trust. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. It may include any payment, benefit or gift offered or given with the purpose of influencing a decision or outcome. The bribe may not be of a large value; it could be an invitation to a sporting event or a luncheon.
3. Bribery and corruption are criminal offences and are punishable by imprisonment of up to 10 years, a fine, or both.
4. If the Company is found to have taken part in bribery it could also face an unlimited fine and have its business reputation seriously damaged. We will therefore operate and enforce effective systems to counter bribery and any employee who fails to comply with this policy will be dealt with under the Company’s Disciplinary Policy and Procedure, which could result in summary dismissal. The employee may also be subject to criminal prosecution.
5. The policy sets out, in general terms, what is and is not acceptable. However, if you are in any doubt as to whether action or conduct could amount to bribery, you should refer to the matter to a Director.
6. The policy does not directly form part of any employee’s Contract of Employment and it may be amended at any time.
7. The purpose of this policy is to establish controls to ensure compliance with all applicable anti-bribery legislation, and to ensure that the Company’s business is conducted in a socially responsible manner.
8. This policy applies to all employees of the Company (or any subsidiary companies). It also applies to all external consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents or any other person associated with the Company (or any of its subsidiary companies). For the purpose of this policy, these will all be referred to as ‘employees’.
9. ‘Third party’, for the purpose of this policy, means any individual or organisation that you may come into contact with during the course of your work for the Company (or any subsidiary companies), and includes actual and potential clients, customers, business contacts, business partners, agents, distributors, suppliers, advisers, and Government and public bodies (including their advisors, officials, representatives, politicians and political parties).
10. The prevention, detection and reporting of any bribery in any form is the responsibility of all employees.
11. Bribes – Employees must not engage in any form of bribery, either directly or through any third party (e.g. an agent). Bribery of a foreign public official anywhere in the world is strictly prohibited.

    Facilitation Payments and ‘Kickbacks’

12. Facilitation payments are a form of bribery made for the purpose of expediting or facilitating the performance of a public official for a routine Government action, and not to obtain or retain business or any improper business advantage. These are usually made to lower level officials and typically involve small cash payments.
13. No employee should make a facilitation payment unless there is a risk to the employee’s personal safety or security or his / her family. If this situation arises, the amount paid should be kept to a minimum, a record should be kept concerning details of the payment, and it should be reported to a Director.
14. A Director will be responsible for maintaining a register of all facilitation payments that are made and for evaluating the business risk and developing strategies to minimise such facilitation payments being made in the future.

    Gifts, Hospitality and Entertainment

15. All employees are expected to conduct themselves with integrity, impartiality and honesty at all times. Accordingly, all employees are required to follow these rules regarding gifts, hospitality and entertainment.

    Employees must not offer or give any gift or hospitality:

    • Which could be regarded as illegal or improper, or which violates the recipient’s policies; or
    • To any public employee or Government officials or representatives, or politicians or political parties; or
    • Which exceeds £100 in value for each individual gift or each hospitality event, unless approved in writing in advance by a Director.

    Employees should not accept any gift or hospitality from the Company’s business partners if:

    • It exceeds £100 in value for each individual gift or each hospitality event, unless approved in writing in advance by a Director; or
    • It is in cash; or
    • There is any suggestion that a favour is expected or implied in return for acceptance.
      
      
16. Any gift or hospitality should be reasonable and justifiable and the intention behind it should be considered in all occasions. Subject to restrictions above, any gift or hospitality offered/given by an employee on behalf of the Company must first be authorised by a Director before they are offered/given. Similarly, any gift or hospitality received by an employee must always be declared and disclosed to a Director as soon as it occurs. The Company reserves the right to direct that any gift received by an employee from a third party in the course of work be also distributed to/shared with all other employees, where practicable.
17. If it is not considered appropriate to decline the offer of a gift, the gift may be accepted, provided that it is declared to, and authorised by, a Director.

    Political and Charitable Contribution

18. The Company’s policy is not to make donations, whether in cash or in kind, in support of any political parties or candidates, as this could be perceived as an attempt to gain an improper business advantage. We respect the right of individual employees to make personal contributions, provided they are not made in any way to obtain advantage in a business transaction.
19. Whilst we encourage employees to become involved in supporting charities by providing their time, in-kind services or direct financial contributions, employees must ensure that any charitable contributions made are not used as a way to conceal bribery.
20. The Company will only make charitable donations that are both legal and ethical. Donations should not be offered or made without the prior approval of a Director.
21. The Company will publicly disclose all donations it makes to charities.

    Record keeping

22. It is important that the Company keeps financial records and has appropriate internal control mechanisms in place to evidence the business reason(s) for making payments to third parties.
23. All employees must declare all gifts or hospitality offered or accepted, which will be subject to management review.
24. All expense claims submitted relating to gifts or hospitality, or expenses incurred to a third party, must be submitted following the Company’s Expenses Policy. In all cases, the reason for the expenditure must be properly recorded.
25. A Director will be responsible for maintaining a Gift, Hospitality and Entertainment Register to record relevant items that are offered or accepted.

    Raising a Concern

26. We believe it is essential to create an environment in which employees feel able to raise any matters of genuine concern without fear of disciplinary action being taken against them, that they will be taken seriously and that the matters will be investigated appropriately and, as far as practicable, be kept confidential.
27. We take all matters of malpractice, improper action or wrongdoing very seriously and employees are encouraged to raise incidents or behaviours that are not in accordance with this policy.
28. Any employee who has a concern regarding this policy or has any suspicion of malpractice should consider raising this in the first instance to their Manager at the earliest opportunity. Your Manager has a responsibility to listen and respond to any matter that is of concern to you. Concerns can be raised verbally or in writing. Your Manager will determine whether he / she is able to investigate the concern directly, keeping a Director updated, if appropriate, of progress and its conclusion.
29. If your Manager is unable to resolve the issue, he / she will normally escalate the concern to a Director.
30. If you feel that you cannot raise your concern with your Manager, for whatever reason, you should contact a Director who will consider the matter and manage any investigation.
31. If you are offered a bribe by a third party, or are asked to make one, or suspect that this may occur in the future, or believe that you are a victim of another form of unlawful activity, you should raise the matter confidentially using the procedure above.

    Protection

32. The Company is committed to ensuring that 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 actual or potential bribery or corruption has occurred or may take place in the future. Detrimental treatment includes threats, disciplinary action, dismissal or other unfavourable treatment connected with raising a concern. If you believe that you have suffered detrimental treatment, you should contact the Director immediately, or you have the option of raising a grievance under the Company’s Grievance Procedure.

    Communication

33. Employees will be advised of this policy during their induction with the Company. The Company’s zero tolerance approach to bribery will also be communicated to all suppliers, contractors and business partners at the outset of the business relationship with them, and as appropriate thereafter.

    Overall Responsibility

34. The overall responsibility for the policy lies with the Directors. The Directors have day-to-day responsibility for implementing this policy and for monitoring its use and effectiveness. Internal control systems and procedures will be regularly audited to monitor their effectiveness. Any improvements identified will be made as soon as is practicable. All employees are responsible for the success of this policy and should ensure they use it to disclose any suspected danger, wrongdoing or bribery. Employees are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Directors.

    How to raise a concern

35. You are encouraged to raise concerns about any issue or suspicion of bribery or corruption at the earliest possible stage.
36. If you are offered a bribe, or are asked to make one, or if you believe or suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must report it in accordance with our Whistleblowing Policy as soon as possible which you can find at section xx below.
37. If you are unsure about whether a particular act constitutes bribery or corruption, raise it with your manager or a Director immediately.

    Training and communication

38. Training on this policy forms part of the induction process for all new workers. All existing workers will receive update training from time to time to ensure you understand your responsibilities.
39. Our zero-tolerance approach to bribery and corruption extends to all suppliers, contractors and business partners and we will not the outset of our business relationship with them and as appropriate thereafter.

    Potential risk scenarios: “red flags”

40. The following is a list of possible red flags that may arise during the course of you working for us 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 us, you must report them promptly by using the procedure set out in the Whistleblowing Policy set out below at paragraph :
    1. you become aware that a third party engages in, or has been accused of engaging in, improper business practices;
    2. you learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a “special relationship” with foreign government officials;
    3. a third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us;
    4. 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;
    5. a third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business;
    6. a third party requests an unexpected additional fee or commission to “facilitate” a service;
    7. a third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services;
    8. a third party requests that a payment is made to “overlook” potential legal violations;
    9. a third party requests that you provide employment or some other advantage to a friend or relative;
    10. a third party requests that a payment is made to “overlook” potential legal violations;
    11. you receive an invoice from a third party that appears to be non-standard or customised;
    12. you notice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided;
    13. 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; or
    14. you are offered an unusually generous gift or offered lavish hospitality by a third party.

Expenses policy

Reimbursement of expenses

1. We will reimburse expenses properly incurred, which have been agreed and authorised in advance, in accordance with this policy. Any attempt to claim expenses in breach of this policy may result in disciplinary action.
2. This policy may change from time to time and the revised procedure will be published and/or available through your line manager.
3. Expenses will only be reimbursed if they are:
   1. claimed using forms that are available from your line manager or the Human Resources team or the Finance Team and submitted to your line manager in the first instance, or the Human Resources or Finance team;
   2. submitted within 45 days of being incurred;
   3. supported by relevant documents (for example, VAT receipts, tickets, and credit or debit card slips); and
   4. where required, authorised in accordance with instructions in force at the time the expense was incurred.
4. Claims for authorised expenses submitted in accordance with this policy will be paid directly into your bank/building society account.
5. Each team may have a specific deadline for submitting expenses claims and credit card statements. It is the responsibility of the employee to ensure that they have submitted their claim etc in the correct format for the team, for example the Sales Team have to submit claims by the first Friday of the following month. Other teams with less expenses claims, may have a quicker system. Always check the process and timescale for claiming before you incur expenses.
6. Any questions about the reimbursement of expenses should be put to your line manager or the Human Resources or Finance Teams before you incur the relevant costs.

   Travel expenses

7. We will reimburse the reasonable cost of necessary travel in connection with our business. The most economic means of travel should be chosen if practicable/possible. The following are not treated as travel in connection with our business:
   1. travel between your home and usual place of work;
   2. travel which is mainly for your own purposes; and
   3. travel which, while undertaken on our behalf, is similar or equivalent to travel between your home and your usual place of work.
8. Any additional costs incurred by you whilst travelling in connection with our business, such as parking or rail ticket fines and the costs of purchasing discount or loyalty cards (such as railcards) are only recoverable by you under this expenses policy at our sole discretion.
9. Travel Expenses – Personal Car Expenses
   1. Where it is cost effective for you to use your car for business travel, and you have been authorised to do so, you can claim a mileage allowance on proof of mileage in accordance with the current authorised mileage rates authorised by the Isle of Man Government or to the UK’s HMRC Travel, Mileage and Fuel Rates reviewed annually.
   2. Details of the current mileage rates can be obtained from your line manager, the Human Resources or Finance Teams. You can also claim for any necessary parking costs which need to be supported by a receipt or the display ticket.

   Accommodation and other overnight expenses

10. If you are required to stay away overnight in the course of your duties you should discuss accommodation arrangements with your line manager or the Human Resources or Finance Teams in advance. Where possible, arrangements will be made by the Human Resources or Finance Teams on your behalf, but where this is not possible you will be advised of the documentation that you will need to submit to reclaim expenses.
11. Whilst on overnight stays in the course of your duties, we will reimburse your reasonable evening meal and breakfast expenses up to the amount of £20 per meal (including drinks) provided they are supported by receipts.

    Entertaining clients

12. You may entertain clients only where your proposal has been agreed in advance with your line manager or a Director.
13. A proposal to entertain clients should be made in writing and should include the following details:
    1. what form of entertainment is proposed (for example, a meal at an identified restaurant);
    2. who will be attending both from our business and from the client;
    3. how it is considered that our business interests will be furthered by your proposal; and
    4. the costs it is anticipated will be incurred.
14. Your line manager will discuss your proposal with you and, subject to authorisation, . you will be advised of the documentation that you will need to submit to reclaim expenses.
15. If you are invited to an event or given any kind of gift from a customer or partner or other 3rd party you should always declare it through the ‘Gifts and Hospitality Register’ by contacting the Head of Compliance or by completing the register found on my.hub.

Annual leave and public holiday policy

The Company will provide employees with paid time-off work as holiday leave. Annual leave is defined as pre-approved, pre-scheduled time away from work.

Entitlement

1. Our holiday year runs from 1 January to 31 December. If your employment starts or finishes part way through the holiday year, your holiday entitlement shall be calculated on a pro-rata basis rounded up to the nearest whole day.
2. Unless stated otherwise in your employment contract, you are entitled to a minimum of:
   1. 23 days’ paid holiday in each holiday year (or the pro rata equivalent if you work part time) in addition to the usual public holidays in either the Isle of Man or England and Wales depending in which jurisdiction you work (or days in lieu where you are required to work on a public holiday); and
   2. one half day’s additional holiday to be taken on or during the week of your birthday.
3. Your holiday entitlement in each holiday year is provided to you on a “use it or lose it” basis and must be taken during the year in which it accrues.
4. Unless the contrary is agreed between us, or is stated in any other policy (such as in cases of sickness absence, maternity leave (or equivalent)), or is required by law, any holiday not taken by the end of the relevant holiday year will be lost and you will not receive any payment in lieu.

   Requesting holiday

5. All holiday must be approved in advance by your line manager and must only be taken when it does not place an unreasonable burden on the rest of the team or the company as a whole.
6. All holidays must be booked through People HR
7. Line managers are asked to either approve or reject holiday requests within 5 days of receipt, wherever possible.
8. You are required to give as much notice as possible of holiday requests and you should not make travel arrangements until approval has been given.
9. We may require you to take (or not to take) holiday on particular dates, such as when we are closed, particularly busy, or at a critical stage of project delivery, or during your notice period.
10. All annual leave must be captured on People HR before it will be considered to be booked.
11. The Company will endeavour to honour a holiday a new starter has already scheduled which was booked prior to their employment offer date and which they have raised at interview or during the recruitment process. The time off may be paid or unpaid depending on the person’s annual leave allocation for the year.

    Annual Leave and Sickness

12. Holiday entitlement continues to accrue during periods of sick leave.
13. If you are sick whilst on annual leave, you may be entitled to have the annual leave allowance reclassified as sick leave and the holidays allocated back to your holiday entitlement. In order for this to happen, you would need to supply evidence of the sickness to the Company i.e. a medical or doctor’s certificate to cover the period of absence.
14. Annual leave carried forward which is not related to Corona Virus will be lost if not used in the year it was carried into.

    Annual Leave and long term absence – If you are absent through sickness for a continuous period of more than 26 weeks, your holiday and bank / public holiday entitlement will be reduced proportionally based upon the amount of sickness absence above 26 weeks and as outlined by legislation. Should an employee find themselves in this situation, please speak to HR who will calculate and confirm the exact holiday entitlement based on their individual absence records.

    Long-term sickness absence – there is a statutory right to carry forward any unused annual leave that has not been taken specifically because of Corona Virus, for up to a period of 2 years.

    Maternity, Paternity, Adoption, Parental or Shared Parental Leave

15. Your holiday entitlement continues to accrue during periods of maternity, paternity, adoption, parental or shared parental leave (collectively “family leave”).
16. If you are planning to take a period of family leave that is likely to last beyond the end of the holiday year, you should discuss your holiday plans with your manager in good time before starting the leave. Any holiday entitlement that cannot reasonably be taken before starting your family leave may be carried over to the next holiday year.
17. Any holiday carried over should be taken immediately before returning to work or within 6 weeks of such return. The Company, at its discretion, reserves the right to require an employee to take all or part of their outstanding holiday entitlement before their date of termination of employment.
18. Where applicable, payment in lieu will be made for any outstanding unused holiday entitlement at the date of termination of employment, with an employee’s final salary payment. Unless agreed by a Manager, holiday may not be taken during an employee’s notice period. The company may insist that accrued but untaken annual leave is taken during a notice period. Generally, each day of your untaken entitlement shall be paid at 1/260th of your full-time equivalent basic salary or proportion of it for part time employees.
19. If, at the time of leaving, an employee has taken holidays in excess of their pro-rata entitlement, the Company reserves the right to recover and deduct any monies due to the Company from the employee’s final salary.
20. Employees who take annual leave which has not been approved in advance by management will be subject to the Company’s Disciplinary Policy and Procedure.

Absence policy

1. This policy sets out our procedures for reporting absence and for the management of absence in a fair and consistent way.
2. Absence can vary from short intermittent periods of ill-health to a continuous period of long-term absence and have a number of different causes (for example, injuries, recurring conditions, or a serious illness requiring lengthy treatment).
3. We wish to ensure that the reasons for absence are understood in each case and investigated where necessary. In addition, where needed and reasonably practicable, measures will be taken to assist those who have been absent by reason of sickness to return to work.
4. We may vary the procedures set out in this policy, including any time limits, as appropriate in any case.

   Disability

5. We are aware that sickness absence may result from a disability. Your manager will want to support your return to work will ensure that any reasonable adjustment that can be made has been considered
6. If you consider that you are affected by a disability or any medical condition which affects your ability to undertake your work, you should inform your line manager or the Human Resources Team who will be able to support you in finding the most effective adjustments to suit you and the business.

   Sickness absence reporting procedure

7. If you do not have an absence reporting procedure in your contract, or subsequently agreed with your line manager, you should follow the procedure set out below.
   1. If you are taken ill or injured while at work: you should report to your line manager or to the HR Team immediately. They will agree whether you need simply to go home or whether an ambulance or other intervention is required. Managers must consider whether the individual is well enough to drive themselves home and whether there is anyone at home to care for the individua
   2. If you cannot attend work because you are ill or injured: you should normally telephone your line manager or the Human Resources Team as early as possible and no later than 30 minutes (for operational teams you may be required to contact your line manager up to 2 hours prior to your shift start time) after the time when you are normally expected to start work. The following details should be provided:
   3. The nature of your illness.
   4. If possible, the expected length of your absence from work.
   5. Contact details.
   6. Any outstanding or urgent work that requires attention.
8. Managers should ensure that:
   1. Any sickness absence that is notified to them is recorded and reported to the Human Resources Team and entered onto People HR System.
   2. Arrangements are made, where necessary, to cover work and to inform colleagues and clients (while maintaining confidentiality).
9. It is your responsibility to maintain contact with your line manager. However, all managers are required to ensure this contact is maintained. You should expect to be contacted during your absence by your department or your line manager or the Human Resources Team who will want to enquire after your health and be advised, if possible, as to your expected return date.

   Evidence of incapacity

10. For sickness absence of up to seven calendar days you must complete a self-certification form which is available through People HR, your line manager can help you complete this or advice can be received from the Human Resources Team.
11. For absence of more than a week you must obtain a certificate from your doctor stating that you are not fit for work and the reason(s) why. This should be forwarded to your line manager or the Human Resources Department immediately, or as soon as possible. If your absence continues, further medical certificates must be provided to cover the whole period of absence. You will be required to complete an SC1(available on line at: https://www.gov.im/media/1345897/sc1-april-2018.pdf) for absences of 4 days or more.
12. If your doctor provides a medical certificate stating a date from which you will be fit for work you should inform your line manager or the Human Resources Team immediately. We will discuss with you any additional measures that may be needed to facilitate your return to work, taking account of your doctor’s advice. This may take place at a return to work interview (see paragraph 13.22). If appropriate measures cannot be taken, you will remain on sick leave and we will set a date to review the situation.
13. Where we are concerned about the reason for absence, or the level of frequent short-term absences has raised concern, we may require a medical certificate for each absence regardless of duration.

    Unauthorised absence

14. If you do not follow the reporting procedure your absence will be considered to be unauthorised; such cases will be dealt with under the Disciplinary Procedure.
15. If you do not report for work and have not telephoned your line manager or the Human Resources Team to explain the reason for your absence, your line manager or the Human Resources Team will try to contact you, by telephone and by email if necessary. This should not be treated as a substitute for reporting sickness absence.

    Sick pay

16. The company provides you with Company Sick Pay of up to 5 days in a rolling 12-month period, provided that you comply with the Company’s notification procedures. Any further absence will not receive company sick pay and employees are required to apply for benefits under the Isle of Man statutory sickness / incapacity benefit payments provisions issued by Isle of Man Government. Any Company sick pay you receive will be deemed to include any applicable Government sickness or social security benefits recoverable by you (whether or not recovered) in respect of your sickness or injury.
17. No company sick pay will be paid in during the probationary or notice period. During this period your entitlement to payment during sickness absence is limited to your entitlement under IOM incapacity benefit or other Government sickness benefits. Any Company sick pay you receive over and above any applicable Government sickness benefits is entirely at the discretion of the Company and will be deemed to include any applicable Government sickness or social security benefits recoverable by you (whether or not recovered) in respect of your sickness or injury.

    Keeping in Touch during sickness absence

18. If you are absent on sick leave you should expect to be contacted from time to time by your line manager or the Human Resources Team in order to discuss your wellbeing, expected length of continued absence from work and any of your work that requires attention. Such contact is intended to provide reassurance and will be kept to a minimum. You may wish to arrange a mutually convenient time with your line manager for these calls.
19. If you have any concerns while absent on sick leave, whether about the reason for your absence or your ability to return to work, you should feel free to contact your line manager or the Human Resources Team at any time.

    Medical examinations

20. You may be asked to agree to consent to a medical examinations (at the expense of the Company) by a doctor or occupational health physician nominated by the Company, should the Company require it.
21. The employee agrees that any report produced in connection with any such examination may be disclosed to the Company and the Company may discuss the contents of the report with a relevant doctor or occupational physician.

    Return-to-work interviews

22. If you have been absent on sick leave we may, at our discretion, arrange for you to have a return-to-work interview with your line manager and/or the Human Resources Team.
23. A return-to-work interview enables us to confirm the details of your absence and what reasonable adjustments might make your return to work easier. It also gives you the opportunity to raise any concerns or questions you may have, and to bring any relevant matters to our attention.
24. Where your doctor has provided a certificate stating that you “may be fit for work” we will usually hold a return-to-work interview to discuss any additional measures that may be needed to facilitate your return to work, taking account of your doctor’s advice. We are committed to helping employees return to work from long-term sickness absence. we will, where appropriate and possible, support a return to work by:
    1. Obtaining medical advice;
    2. Making reasonable adjustments to the workplace, working practices and working hours;
    3. Considering alternative roles or redeployment; and/or
    4. Agreeing a return to work programme with everyone affected.
25. Where regular unexplained absences occur or where there is no reasonable expectation of a return to work it may be necessary to use the capability or disciplinary procedures.

Capability procedure

1. The primary aim of this procedure is to provide a framework within which managers can work with employees to maintain satisfactory performance standards and to encourage improvement where necessary.
2. It is our policy to ensure that concerns over performance are dealt with fairly and that steps are taken to establish the facts and to give employees the opportunity to respond at a hearing before any formal action is taken.
3. What is covered by the policy? This policy is used to deal with poor performance but may include the management of non attendance at work.

   Identifying performance issues

4. In the first instance, performance issues should normally be dealt with informally between you and your line manager as part of day-to-day management. Where appropriate, a note of any such informal discussions may be placed on your personnel file but will be ignored for the purposes of any future capability hearings. The formal procedure should be used in any case where an earlier informal discussion has not resulted in a satisfactory improvement. Informal discussions may help:
   1. clarify the required standards;
   2. identify areas of concern;
   3. establish the likely causes of poor performance and identify any training needs; and/or
   4. set targets for improvement and a time-scale for review.
5. The capability procedure provides a supportive process which is designed to improve overall performance. However, in cases where improvement cannot be found the process may result in dismissal.
6. During the probation period the process will be different and will involve much shorter periods to demonstrate improvement.
7. If we have concerns about your performance, we will talk to you about it, ensuring you fully understand what is required and what you need to do to improve. We will do our best to take into consideration any external issues which are causing your performance to deteriorate.
8. You will be provided with a written explanation as to the problems identified and what you will need to do to improve. Wherever possible, you will be given a time scale in which to achieve an improvement.
9. In exceptional circumstances the process can be started at one of the later stages; this could be when the standard is known or where there is no reasonable expectation of an improvement in the required performance.

   Confidentiality

10. Our aim is to deal with performance matters sensitively and with due respect for the privacy of any individuals involved. All employees must treat as confidential any information communicated to them in connection with a matter which is subject to this capability procedure.
11. You, and anyone accompanying you (including witnesses), must not make electronic recordings of any meetings or hearings conducted under this procedure.
12. You will normally be told the names of any witnesses whose evidence is relevant to your capability hearing, unless we believe that a witness’s identity should remain confidential.

    Notification of a capability hearing

13. If we consider that there are grounds for taking formal action over alleged poor performance, you will be required to attend a capability hearing. We will notify you in writing of our concerns over your performance, the reasons for those concerns, and the likely outcome. If we decide after the hearing that your performance has been unsatisfactory. We will also include the following where appropriate:
    1. A summary of relevant information gathered as part of any investigation.
    2. A copy of any relevant documents which will be used at the capability hearing.
    3. A copy of any relevant witness statements, 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.
14. We will give you written notice of the date, time and place of the capability hearing. The hearing will be held as soon as reasonably practicable, but you will be given a reasonable amount of time, to prepare your case based on the information we have given you.

    Right to be accompanied at hearings

15. You may bring a companion to any capability hearing or appeal hearing under this procedure. The companion may be either a trade union representative or a colleague. You must tell the manager conducting the hearing who your chosen companion is, in good time before the hearing.
16. A companion is allowed reasonable time off from duties without loss of pay but no-one is obliged to act as a companion if they do not wish to do so.
17. If your choice of companion is considered by the employer to be unreasonable we may require you to choose someone else, for example:
    1. if in our opinion your companion may have a conflict of interest or may prejudice the hearing; or
    2. if your companion works at another site and someone reasonably suitable is available at the site at which you work; or
    3. if your companion is unavailable at the time a hearing is scheduled and will not be available for more than five working days.
18. We may, at our discretion, allow you to bring a companion who is not a colleague or union representative (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.

    Procedure at capability hearings

19. If you or your companion cannot attend the hearing you should inform us immediately and we will usually arrange an alternative time. You must make every effort to attend the hearing, and failure to attend without good reason may be treated as misconduct in itself. If you fail to attend without good reason, or are persistently unable to do so (for example, for health reasons), we may have to take a decision based on the available evidence.
20. The hearing will normally be held by your line manager or a more senior manager and there may also be an independent note taker present. You may bring a companion with you to the hearing (see paragraph 14.15 to paragraph 14.18). Your companion may make representations, ask questions, and sum up your case, but will not be allowed to answer questions on your behalf. You may confer privately with your companion at any time during the hearing.
21. You may ask relevant witnesses to appear at the hearing, provided you give us sufficient advance notice to arrange their attendance. You will be given the opportunity to respond to any information given by a witness. However, you will not normally be permitted to cross-examine witnesses unless, in exceptional circumstances, we decide that a fair hearing could not be held otherwise.
22. The aims of a capability hearing will usually include:
    1. Setting out the required standards that we believe you may have failed to meet, and going through any relevant evidence that we have gathered.
    2. Allowing you to ask questions, present evidence, call witnesses, respond to evidence and make representations.
    3. Establishing the likely causes of poor performance including any reasons why any measures taken so far have not led to the required improvement.
    4. Identifying whether there are further measures, such as additional training or supervision, which may improve performance.
    5. Where appropriate, discussing targets for improvement and a time-scale for review.
    6. If dismissal is a possibility, establishing whether there is any likelihood of a significant improvement being made within a reasonable time and whether there is any practical alternative to dismissal, such as redeployment.
23. A hearing may be adjourned if we need to gather any further information or give consideration to matters discussed at the hearing. You will be given a reasonable opportunity to consider any new information obtained before the hearing is reconvened.
24. We will inform you in writing of our decision and our reasons for it, usually within one week of the capability hearing. Where possible we will also explain this information to you in person.

    Stage 1 hearing: first written warning or improvement note

25. Following a Stage 1 capability hearing, if it is decided that your performance is unsatisfactory, we will give you a first written warning or an improvement note, setting out:
    1. The areas in which you have not met the required performance standards.
    2. Targets for improvement.
    3. Any measures, such as additional training or supervision, which will be taken with a view to improving performance.
    4. A period for review.
    5. The consequences of failing to improve within the review period, or of further unsatisfactory performance.
26. The warning/improvement note will normally remain active for six months from the end of the review period, after which time it will be disregarded for the purposes of the capability procedure.
27. After the active period, the warning will remain permanently on your personnel file but will be disregarded in deciding the outcome of future capability proceedings.
28. Your performance will be monitored during the review period and we will write to inform you of the outcome:
    1. if your line manager is satisfied with your performance, no further action will be taken;
    2. if your line manager is not satisfied, the matter may be progressed to a Stage 2 capability hearing; or
    3. if the manager feels that there has been a substantial but insufficient improvement, the review period may be extended.

    Stage 2 hearing: final written warning

29. If your performance does not improve within the review period set out in a first written warning or an improvement note, or if there is further evidence of poor performance while your first written warning or improvement note is still active, we may decide to hold a Stage 2 capability hearing. We will send you written notification as set out in paragraph 14.13 to paragraph 14.14. You will be entitled to bring a supporter with you to this meeting who can be a colleague or a trade union representative.
30. Following a Stage 2 capability hearing, if it is decided that your performance is unsatisfactory, we will give you a final written warning, setting out:
    1. the areas in which you have not met the required performance standards;
    2. targets for improvement;
    3. any measures, such as additional training or supervision, which will be taken with a view to improving performance;
    4. a period for review; and
    5. the consequences of failing to improve within the review period, or of further unsatisfactory performance.
31. A final written warning will normally remain active for 12 months from the end of the review period. After the active period, the warning will remain permanently on your personnel file but will be disregarded in deciding the outcome of future capability proceedings.
32. Your performance will be monitored during the review period and we will meet with you and write to inform you of the outcome:
    1. if your line manager is satisfied with your performance, no further action will be taken;
    2. if your line manager is not satisfied, the matter may be progressed to a Stage 3 capability hearing; or
    3. if the manager feels that there has been a substantial but insufficient improvement, the review period may be extended.

    Stage 3 hearing: dismissal or action short of dismissal

33. We may decide to hold a Stage 3 capability hearing if we have reason to believe:
    1. your performance has not improved sufficiently within the review period set out in a final written warning;
    2. your performance is unsatisfactory while a final written warning is still active; or
    3. your performance has been grossly negligent such as to warrant dismissal without the need for a final written warning.

    We will send you written notification of the hearing as set out in paragraph 14.13 to paragraph 14.14. You will be reminded of your entitlement to bring a supporter to such a meeting.

34. Following the hearing, if we find that your performance is unsatisfactory, we may consider a range of options including:
    1. Dismissing you;.
    2. Redeploying you into another suitable job at the same or lower level;
    3. Extending an active final written warning and setting a further review period (in exceptional cases where we believe a substantial improvement is likely within the review period);
    4. Giving a final written warning (where no final written warning is currently active);
35. Dismissal will normally be with full notice or payment in lieu of notice, unless your performance has been so negligent such as to amount to gross misconduct, in which case we may dismiss you without notice or any pay in lieu of notice.
36. The capability procedure may be invoked at any of its stages if the case warrants it, or where there is no prospect of incremental improvement. Caution should be applied so as not to not apply the overarching intent of support and growth.

    Appeals against action for poor performance

37. If you feel that a decision about poor performance under this procedure is wrong or unjust you should appeal in writing, stating your full grounds of appeal, to the Human Resources Department or a Director within one week of the date on which you were informed in writing of the decision.
38. If you are appealing against dismissal, the date on which dismissal takes effect will not be delayed pending the outcome of the appeal. However, if your appeal is successful you will be reinstated with no loss of continuity of service or pay.
39. If you raise any new matters in your appeal, we may need to carry out further investigation. If any new information comes to light we will provide you with a summary including, where appropriate, copies of additional relevant documents and witness statements. You will have a reasonable opportunity to consider this information before the hearing.
40. We will give you written notice of the date, time and place of the appeal hearing. This will normally be two to seven days after you receive the written notice.
41. The appeal hearing should not be a complete re-hearing, in that additional information that wasn’t available at the outset can be considered. However, if this is necessary the rationale for it needs to be made clear to the other party. It may be a review of the fairness of the original decision in the light of the procedure that was followed and any new information that may have come to light. The appeal must be dealt with as impartially as possible with clear rationale for decisions taken.
42. Where possible, the appeal hearing will be conducted by a more senior manager or a Director who has not been previously involved in the case. An independent note-taker and the manager who conducted the capability hearing will also usually be present. You may bring a companion with you to the appeal hearing (see paragraph 14.15 to paragraph 14.18).
43. A hearing may be adjourned if we need to gather any further information or give consideration to matters discussed at the hearing. You will be given a reasonable opportunity to consider any new information obtained before the hearing is reconvened.
44. Following the appeal hearing we may:
    1. confirm the original decision;
    2. revoke the original decision; or
    3. substitute a different penalty.
45. We will inform you in writing of our final decision as soon as possible, usually within one week of the appeal hearing. Where possible we will also explain this to you in person. There will be no further right of appeal.

The disciplinary policy

1. The aim of the Disciplinary Policy and procedure is to set out the standards of conduct expected of all staff and to provide a framework within which managers can work with staff to maintain those standards and encourage improvement where necessary. We may amend our Disciplinary policy and procedure as required from time to time.
2. It is our policy to ensure that any disciplinary matter is dealt with fairly and consistently and in accordance with the Disciplinary Procedure.
3. If you are in any doubt as to your responsibilities or the standards of conduct expected you should speak to your line manager or to the HR Team.

   Rules of conduct

4. While working for us you must maintain a professional and responsible standard of conduct. In particular you should:
   1. observe the terms and conditions of your contract, particularly with regard to:
      1. hours of work and punctuality;
      2. confidentiality; and
      3. Anti Bribery and Corruption Policy.
5. ensure that you understand and follow our Code of Conduct which is set out in this Staff Handbook;
   1. observe all our policies, procedures and regulations which are included in this Staff Handbook or notified to you from time to time by means of notice boards, e-mail, the intranet or otherwise;
   2. Specifically, to adhere to all information security measures as applied through policy and practice. All managers will be held accountable for the cascade of effective information security training and suitable awareness in the application of rules in the delivery of services.
   3. take reasonable care in respect of the health and safety of colleagues and third parties and comply with our Health and Safety Policy;
   4. comply with all reasonable instructions given by managers; and
   5. act at all times in good faith and in the best interests of the company, its customers and staff.
6. Failure to maintain satisfactory standards of conduct may result in action being taken under our Disciplinary Procedure.

   Misconduct

7. The following are examples of matters that will normally be regarded as misconduct and will be dealt with under our Disciplinary Procedure:
   1. Breaches of our policies including the Sickness Absence Policy, Information and Communications Systems Policy, and Health and Safety Policy; Equality, Diversity and Inclusion Policy;
   2. Minor breaches of your contract;
   3. Damage to, or unauthorised use of, our property;
   4. Poor timekeeping;
   5. Time wasting;
   6. Unauthorised absence from work;
   7. Refusal to follow instructions and/or corporate policies;
   8. Excessive use of our telephones or your own mobile telephone for personal calls;
   9. Excessive personal e-mail or internet usage;
   10. Obscene language or other offensive behaviour;
   11. Negligence in the performance of your duties; or
   12. Smoking in no-smoking areas.
   13. A failure to observe information security and other data protection standards.
       

       This list is intended as a guide and is not exhaustive.

   Gross misconduct

8. Gross misconduct is a serious breach of contract and includes misconduct which, in our opinion, is likely to prejudice our business or reputation or irreparably damage the working relationship and trust between us. Gross misconduct can be a single incident or a culmination of other more minor incidents and will be dealt with under our Disciplinary Procedure and will normally lead to dismissal without notice or pay in lieu of notice (summary dismissal).
9. The following are examples of matters that are normally regarded as gross misconduct:
   1. Theft, fraud or unauthorised removal of our property or the property of a colleague, contractor, customer or member of the public; forgery or other dishonesty, including fabrication of expense claims and time sheets;
   2. Physical violence or bullying; threatened violence, or behaviour which provokes violence or other aggressive behaviour;
   3. Deliberate and serious damage to property, the office buildings, fittings, or equipment, or the property of a colleague, contractor, customer or member of the public;
   4. Serious misuse of our property (including company computers or software) or name;
   5. Deliberately accessing internet sites containing inappropriate material including but exclusively, racist, homophobic, pornographic, offensive or obscene material;
   6. Serious insubordination; repeated or serious failure to obey instructions, or any other serious act of insubordination;
   7. Unlawful discrimination or harassment;
   8. Behaviour that could damage the reputation of the organisation;
   9. Serious incapability at work brought on by alcohol or illegal drugs; or being under the influence of alcohol, illegal drugs or other substances during working hours;
   10. Causing loss, damage or injury through serious negligence;
   11. Serious breach of health and safety rules or serious misuse of safety equipment;
   12. Serious breach of confidence including unauthorised use or disclosure of confidential information or failure to ensure that confidential information in your possession is kept secure;
   13. Accepting or offering a bribe or other secret payment or other breach of our anti-corruption and bribery policy;
   14. Accepting a gift above the value of £100 from a customer, supplier, contractor or other third party in connection with your employment without prior consent from your line manager;
   15. Conviction for a criminal offence that in our opinion may affect our reputation or our relationships with our staff, customers or the public, or otherwise affects your suitability to continue to work for us;
   16. Possession, use, supply or attempted supply of illegal drugs;
   17. Serious neglect of duties, or a serious or deliberate breach of your contract or operating procedures;
   18. Knowing breach of statutory rules affecting your work;
   19. Unauthorised use, processing or disclosure of personal data contrary to our Data Protection Policy;
   20. Harassment of, or discrimination against, employees, contractors, clients or members of the public, related to gender, marital or civil partner status, gender reassignment, race, colour, nationality, ethnic or national origin, disability, religion or belief or age contrary to our Equal Opportunities Policy or our Anti-harassment and Bullying Policy;
   21. Refusal to disclose any of the information required by your employment or any other information that may have a bearing on the performance of your duties;
   22. Giving false information as to qualifications or entitlement to work (including immigration status) in order to gain employment or other benefits;
   23. Knowingly taking parental, paternity or adoption leave when not eligible to do so or for a purpose other than supporting a child;
   24. Making a disclosure of false or misleading information under our Whistleblowing Policy maliciously, for personal gain, or otherwise in bad faith;
   25. Making untrue allegations in bad faith against a colleague;
   26. Victimising a colleague who has raised concerns, made a complaint or given evidence or information under our Whistleblowing Policy, Anti-corruption and bribery policy, Anti-harassment and Bullying Policy, Grievance Procedure, Disciplinary Procedure or otherwise;
   27. Serious misuse of our information technology systems (including misuse of developed or licensed software, use of unauthorised software and misuse of e-mail and the internet) contrary to our Information and Communications Systems Policy which is to includes inappropriate use of Facebook, Twitter or other social media sites such that it would bring the company into disrepute;
   28. Undertaking unauthorised paid or unpaid employment during your working hours;
   29. Unauthorised entry into an area of the premises to which access is prohibited.
       

       This list is intended as a guide and is not exhaustive.

Disciplinary procedure

1. The aims of this Disciplinary Procedure and its associated Disciplinary Rules are to set out the standards of conduct expected of all staff and 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 and to give employees the opportunity to respond before taking any formal action.

   What is covered by the procedure?

3. This procedure is used to deal with misconduct. It does not apply to cases involving sickness absence, proposed redundancies or poor performance. In those cases reference should be made to the Capability Procedure and the Redundancy Policy procedure, found within this handbook.
4. Minor conduct issues can often be resolved informally between you and your line manager. These discussions should be held in private and without undue delay whenever there is cause for concern. Where appropriate, a note of any such informal discussions may be placed on you r personnel file but will be ignored for the purposes of any future capability hearings. In some cases an informal verbal warning may be given, which will not form part of your disciplinary records. 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).
5. You will not normally be dismissed for a first act of misconduct, unless we decide it amounts to gross misconduct or you have not yet completed your probationary period.
6. If you have difficulty at any stage of the procedure because of a disability, you should discuss the situation with your line manager or a member of the Human Resources Department as soon as possible.

   Confidentiality

7. Our aim is to deal with disciplinary matters sensitively and with due respect for the privacy of any individuals involved. All employees must treat as confidential any information communicated to them in connection with an investigation or disciplinary matter.
8. You, and anyone accompanying you (including witnesses), must not make electronic recordings of any meetings or hearings conducted under this procedure.
9. You will normally be told the names of any witnesses whose evidence is relevant to disciplinary proceedings against you, unless we believe that a witness’s identity should remain confidential.

   Investigations

10. The purpose of an investigation is for us to establish a fair and balanced view of the facts relating to any disciplinary allegations against you, before deciding whether to proceed with a disciplinary hearing. The amount of investigation required will depend on the nature of the allegations and will vary from case to case. It may involve interviewing and taking statements from you and any witnesses, and/or reviewing relevant documents. The Human Resources Department will usually appoint an Investigating Officer to carry out the investigation.
11. 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.
12. You do not normally have the right to bring a companion to an investigative interview. However, we may allow you to bring a companion if it helps you to overcome any disability, or any difficulty in understanding English.
13. You must co-operate 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 investigative interviews if required.

    Criminal charges

14. Where your conduct is the subject of a criminal investigation, charge or conviction we will investigate the facts before deciding whether to take formal disciplinary action.
15. We will not usually wait for the outcome of any prosecution before deciding what action, if any, to take. Where you are unable or have been advised not to attend a disciplinary hearing or say anything about a pending criminal matter, we may have to take a decision based on the available evidence.
16. A criminal investigation, charge or conviction relating to conduct outside work may be treated as a disciplinary matter if we consider that it is relevant to your employment.

    Suspension

17. In some circumstances we may need to suspend you from work. The suspension will be for no longer than is necessary to investigate the allegations and we will confirm any allegations made against you and the arrangements to you in writing. While suspended you should not visit our premises or contact any of our clients, customers, suppliers, contractors or staff, unless you have been authorised to do so by a Director.
18. Suspension of this kind is not a disciplinary penalty and does not imply that any decision has already been made about the allegations. You will continue to receive your full basic salary and benefits during the period of suspension. You may be required to avoid contact with members of staff and not visit company property during a suspension.

    Notification of a hearing

19. Following any investigation, if we consider there are grounds for disciplinary action, you will be required to attend a disciplinary hearing. We will inform you in writing of the allegations against you, the basis for those allegations, and what the likely range of consequences will be if we decide after the hearing that the allegations are true. We will also include the following where appropriate:
    1. Confirmation of the allegations made against you;
    2. A summary of relevant information gathered during the investigation;
    3. A copy of any relevant documents which will be used at the disciplinary hearing; and
    4. A copy of any relevant witness statements, 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.
20. We will give you written notice of the date, time and place of the disciplinary hearing. The hearing will be held as soon as reasonably practicable, but you will be given a reasonable amount of time, usually two to seven days, to prepare your case based on the information we have given you.

    The right to be accompanied

21. You may bring a companion to any disciplinary hearing or appeal hearing under this procedure. The companion may be either a trade union representative or a colleague. You must tell the Human Resources Team or a Director who your chosen companion is advance of the hearing.
22. A companion is allowed reasonable time off from duties without loss of pay but no-one is obliged to act as a companion if they do not wish to do so.
23. Provided that your choice of companion falls within those permitted under paragraph 16.21 and does not place an unreasonable burden on the scheduling of the hearing, your choice of companion is absolute and we will respect that choice. However, if your choice of companion is conflicted an their attendance either compromises the case or anyone participating in it.
24. We may, at our discretion, allow you to bring a companion who is not a colleague or union representative (for example, a member of your family) where this will help overcome a disability, or where you have difficulty understanding English.

    Procedure at disciplinary hearings

25. If you or your companion cannot attend the hearing you should inform us immediately and we will arrange an alternative time. You must make every effort to attend the hearing, and failure to attend without good reason may be treated as misconduct in itself. If you fail to attend without good reason, or are persistently unable to do so (for example for health reasons), we may have to take a decision in your absence, based on the available evidence.
26. The hearing will be chaired by a senior manager, Human Resources or a Director. The Investigating Officer and/or a member of the Human Resources Team will also be present. You may bring a companion with you to the disciplinary hearing (see paragraph 16.21 to paragraph 16.24).
27. At the disciplinary hearing we will go through the allegations against you and the evidence that has been gathered. You will be able to respond and present any evidence of your own. Your companion 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.
28. You may ask relevant witnesses to appear at the hearing, provided you give us sufficient advance notice to arrange their attendance. You will be given the opportunity to respond to any information given by a witness. However, you will not normally be permitted to cross-examine witnesses unless, in exceptional circumstances, we decide that a fair hearing could not be held otherwise.
29. We may adjourn the disciplinary hearing if we need to carry out any further investigations such as re-interviewing witnesses in the light of any new points you have raised at the hearing. You will be given a reasonable opportunity to consider any new information obtained before the hearing is reconvened.
30. We will inform you in writing of our decision and our reasons for it, usually within one week of the disciplinary hearing. Where possible we will also explain this information to you in person.

    Disciplinary penalties

31. The usual penalties for misconduct are set out below. No penalty can be imposed without a hearing. We aim to treat all employees fairly and consistently, and a penalty imposed on another employee for similar misconduct will usually be taken into account but should not be treated as a precedent. On occasion, it may be necessary, to go directly to stage 2 or to stage 3. Each case will be assessed on its own merits.
32. Stage 1 – Verbal warning or first written warning. It will usually be appropriate for a first act of misconduct where there are no other active written warnings on your disciplinary record.
33. At the disciplinary hearing we will go through the allegations against you and the evidence that has been gathered. You will be able to respond and present any evidence of your own. Your companion 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.
    1. where there is already an active written warning on your record; or
    2. that we consider sufficiently serious to warrant a final written warning even though there are no other active warnings on your record.
34. Stage 3 – Dismissal. It will usually only be appropriate for:
    1. any misconduct during your probationary period;
    2. further misconduct where there is an active final written warning on your record; or
    3. any gross misconduct regardless of whether there are active warnings on your record. Gross misconduct will usually result in immediate dismissal without notice or payment in lieu of notice (summary dismissal). Examples of gross misconduct are set out in our Disciplinary Rules, which are contained in the Staff Handbook.
35. Alternatives to dismissal. In some cases we may at our discretion consider alternatives to dismissal. These will usually be accompanied by a final written warning. Employees are not bound to accept an alternative to dismissal. Examples include:
    1. Demotion – a new contract of employment would be drawn up and may include changed terms and conditions of employment. This penalty will require that a new contract of employment is raised to reflect what could be reduced or changed terms and conditions of service. An employee is not bound to accept demotion.
    2. Transfer to another department or job. Transfer’s are not always appropriate nor possible and the will also require a new contract of employment and possibly new terms and conditions of employment (such as salary and grade etc).

    The effect of a warning

36. A verbal warning is only applicable in very minor cases where the employer is confident that the required change is possible.
37. Written warnings will set out the nature of the misconduct, the change in behaviour required, the period for which the warning will remain active, and the likely consequences of further misconduct in that active period.
38. A first written warning will usually remain active for six months and a final written warning will usually remain active for 12 months. In exceptional cases verging on gross misconduct a final written warning may state that it will remain active indefinitely. Your conduct may be reviewed at the end of a warning’s active period and if it has not improved sufficiently we may decide to extend the active period.
39. After the active period, the warning will remain permanently on your personnel file but may be disregarded in deciding the outcome of future disciplinary proceedings.

    Appeals against disciplinary action

40. If you feel that disciplinary action taken against you is wrong or unjust you should appeal in writing, stating your full grounds of appeal, to a Director who was otherwise uninvolved in the original disciplinary proceedings within one week (5 working days) of the date on which you were informed of the decision.
41. If you are appealing against dismissal, the date on which dismissal takes effect will not be delayed pending the outcome of the appeal. However, if your appeal is successful you will be reinstated with no loss of continuity of service or pay.
42. If you raise any new matters in your appeal, we may need to carry out further investigation. If any new information comes to light we will provide you with a summary including, where appropriate, copies of additional relevant documents and witness statements. You will have a reasonable opportunity to consider this information before the hearing.
43. We will give you written notice of the date, time and place of the appeal hearing. This will normally be two to seven days after you receive the written notice.
44. The appeal hearing may be a complete re-hearing of the matter or it may be a review of the fairness of the original decision in the light of the procedure that was followed and any new information that may have come to light. This will be at our discretion depending on the circumstances of your case. In any event the appeal will be dealt with as impartially as possible.
45. Where possible, the appeal hearing will be conducted impartially by a more senior manager or a Director who has not been previously involved in the case. The Investigating Officer and/or a member of the Human Resources Department and/or the manager who conducted the disciplinary hearing will also usually be present. You may bring a companion with you to the appeal hearing (see paragraph 16.21 to paragraph 16.24).
46. We may adjourn the appeal hearing if we need to carry out any further investigations in the light of any new points you have raised at the hearing. You will be given a reasonable opportunity to consider any new information obtained before the hearing is reconvened.
47. Following the appeal hearing we may:
    1. confirm the original decision;
    2. revoke the original decision; or
    3. substitute a different penalty.
48. We will inform you in writing of our final decision as soon as possible, usually within one week of the appeal hearing. Where possible we will also explain this to you in person. There will be no further right of appeal.

Grievance policy and procedure

1. It is our policy to ensure that all employees have access to a procedure to help deal with any grievances relating to their employment fairly and without unreasonable delay. We aim to investigate any formal grievance you raise, hold a meeting to discuss it with you, inform you in writing of the outcome, and give you a right of appeal if you are not satisfied.
2. Issues that may cause grievances include:
   1. terms and conditions of employment;
   2. health and safety;
   3. work relations;
   4. bullying and harassment;
   5. new working practices;
   6. working environment;
   7. organisational change; and
   8. discrimination.

   Using this procedure

3. If you have difficulty at any stage of the Grievance Procedure because of a disability or because English is not your first language, you should discuss the situation with your line manager or the Human Resources Department as soon as possible.
4. This Grievance Procedure should not be used to complain about dismissal or disciplinary action. If you are dissatisfied with any disciplinary action, you should submit an appeal under the appropriate procedure in this Staff Handbook.
5. We have a separate Anti-harassment and Bullying Policy that may be useful if you have been the victim of bullying or harassment or wish to report an incident of bullying or harassment involving other people. It is set out in this Staff Handbook.
6. We operate a Whistleblowing Policy (see paragraph 15 below) to enable employees to report illegal activities, wrongdoing or malpractice. However, where you are directly affected by the matter in question, or where you feel you have been victimised for an act of whistleblowing, you may raise the matter under this Grievance Procedure.
7. Written grievances will be placed on your personnel file along with a record of any decisions taken and any notes or other documents compiled during the grievance process. These will be processed in accordance with our Data Protection Policy.

   Raising grievances informally

8. Most grievances can be resolved quickly and informally through discussion with your line manager or the Human Resources Department. If you feel unable to speak to your manager, for example, because the complaint concerns him or her, then you should speak informally to a more senior manager or a Director. If this does not resolve the issue, you should follow the formal procedure below.

   Formal written grievances

9. If your grievance cannot be resolved informally you should put it in writing and submit it to your line manager or the Human Resources Department, indicating that it is a formal grievance. If the grievance concerns him or her, you may submit it instead to a Director.
10. The written grievance should contain a brief description of the nature of your complaint, including any relevant facts, dates, and names of individuals involved. In some situations we may need to ask you to provide further information.

    Investigations

11. In some cases it may be necessary for us to carry out an investigation into your grievance. The amount of any investigation required will depend on the nature of the allegations and will vary from case to case. It may involve interviewing and taking statements from you and any witnesses, and/or reviewing relevant documents. The investigation may be carried out by your line manager or the Human Resources Department or someone else appointed by us.
12. You must co-operate fully and promptly in any investigation. This may include informing us of the names of any relevant witnesses, disclosing any relevant documents to us and attending interviews, as part of our investigation.
13. We may initiate an investigation before holding a grievance meeting where we consider this appropriate. In other cases we may hold a grievance meeting before deciding what investigation (if any) to carry out. In those cases we will hold a further grievance meeting with you after our investigation and before we reach a decision.

    Right to be accompanied

14. You may bring a companion to any grievance meeting or appeal meeting under this procedure. The companion may be either a trade union representative or a colleague. You must tell the person holding the grievance meeting who your chosen companion is, in good time before the meeting.
15. At the meeting, your companion 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 meeting.
16. Acting as a companion is voluntary and your colleagues are under no obligation to do so. If they agree to do so they will be allowed reasonable time off from duties without loss of pay to act as a companion.
17. Provided that your choice of companion falls within those permitted under paragraph 17.14 and does not place an unreasonable burden on the scheduling of the hearing, your choice of companion is absolute and we will respect that choice. :

    Grievance meetings

18. We will arrange a grievance meeting, normally within one week of receiving your written grievance.
19. You and your companion (if any) should make every effort to attend grievance meetings. If you or your companion cannot attend at the time specified, you should inform us immediately and we will try, within reason, to agree an alternative time.
20. The purpose of a grievance meeting is to enable you to explain your grievance and how you think it should be resolved, and to assist us to reach a decision based on the available evidence and the representations you have made.
21. After an initial grievance meeting we may carry out further investigations and hold further grievance meetings as we consider appropriate. Such meetings will be arranged without unreasonable delay.
22. Your companion at a grievance meeting 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 meeting.
23. We will write to you, usually within one week of the final grievance meeting, to inform you of the outcome of your grievance and any further action that we intend to take to resolve the grievance. We will also remind you of your right of appeal. Where appropriate we may hold a meeting to give you this information in person.

    Appeals

24. If the grievance has not been resolved to your satisfaction you may appeal in writing to a Director, stating your full grounds of appeal, within one week of the date on which the decision was sent or given to you.
25. We will hold an appeal meeting, normally within one week of receiving your written appeal. This will be dealt with impartially by a more senior manager or Director who has not previously been involved in the case (although they may ask anyone previously involved to be present). You have a right to bring a companion to the meeting (see paragraphs 17.14 to paragraph 17.17).
26. We will confirm our final decision in writing, usually within one week of the appeal hearing. This is the end of the procedure and there is no further appeal.

Whistleblowing policy

1. The Company is committed to the highest standards of quality, honesty, openness, accountability and transparency. The Whistleblowing Policy is primarily for concerns where the interests of others or of the Company itself are at risk.
2. This policy is non-contractual and does not form part of an employee’s terms and conditions of employment. It may be subject to review at any time by the Company.
3. An important aspect of accountability and transparency is a mechanism to enable employees to voice concerns in a responsible and effective manner in the form of a Protected Disclosure. It is a fundamental term of every contract of employment that employees will faithfully serve their employer and not disclose confidential information about their employer’s affairs.
4. Nevertheless, where an individual discovers information which they believe shows serious malpractice or wrongdoing within the Company, whether past, present or likely to happen, then this information should be disclosed internally without fear of reprisal, detriment or dismissal. There should be arrangements to enable this to be done independently of line management. The Company has established a procedure to deal with whistleblowing concerns raised.
5. The staff member does not have to be able to prove the allegations, but should have a reasonable and genuine belief that the information being disclosed is true and substantially serious. The concern must be made in good faith and not for personal gain. The Company understands that some allegations may prove to be unfounded, but we would prefer the issue or concern to be raised, rather than run the risk of not detecting a problem early on.
6. An employee who raises a genuine concern under this policy will not be at risk of losing their job or suffering any form of retribution or harassment as a result. Provided an employee has acted in good faith, it does not matter if they are mistaken. This policy does not, however, extend to anyone who maliciously raises a concern that they know is untrue.
7. The Company will treat all disclosures in a confidential and sensitive manner. The identity of the individual making the allegation may be kept confidential so long as it does not hinder or frustrate any investigation. However, the investigation process may reveal the source of the information and the individual making the disclosure may need to provide a statement as part of the evidence required. The Company encourages individuals to put their name to any disclosures they make.
8. The main aim of the policy is to enable employees of the Company to raise concerns internally and at a high level and to disclose information which the employee believes shows malpractice or impropriety. This policy covers concerns which are in the public interest and may at least initially be investigated separately but might then lead to the invocation of other procedures e.g. disciplinary procedures.
9. These concerns could include (the list is not exhaustive):
   1. Financial malpractice or impropriety or fraud;
   2. Corruption or bribery;
   3. Failure to comply with a legal obligation;
   4. Actions which endanger the health or safety of employees or the public;
   5. Actions which cause damage to the environment;
   6. Criminal activity or offences;
   7. Improper conduct or unethical behaviour;
   8. Standards of care;
   9. Attempts to conceal any of the above.
10. The policy is not designed to question financial or business decisions taken by the Company nor should it be used to reconsider any matters which have already been addressed under harassment, grievance / complaint, disciplinary or other Company procedures.
11. This policy applies to all employees of the Company. It also applies to all external consultants, contractors and agency staff whilst working within the Company.
12. It is important to the Company that any fraud, misconduct or wrongdoing by any of its employees is internally reported and properly dealt with. The Company therefore encourages all individuals to raise any concerns that they may have about the conduct of others in the Company or the way in which the Company is run. It is not necessary for the person to have proof that such an act is being, has been, or is likely to be, committed – a reasonable belief is sufficient. The individual has no responsibility for investigating the matter – it is the Company’s responsibility to ensure that an investigation takes place.
13. Everyone should be aware of the importance of preventing and eliminating wrongdoing at work. You should be watchful for illegal or unethical conduct and report anything of that nature that you become aware of.
14. Employees have the right to make an appropriate external disclosure (in accordance with IOM whistleblowing legislation) without going through the internal procedure first. The Company, however, encourages employees to raise concerns with a Director of the Company prior to doing so, unless there are genuine and well-founded grounds for not doing so.
15. The Company recognises there may be matters that cannot be dealt with internally and external authorities will need to become involved. Where this is necessary, we reserve the right to make such a referral without the staff member’s consent.
16. If an individual makes an allegation in good faith, which is not confirmed by subsequent investigation, no action will be taken against that individual. In making a disclosure the individual should exercise due care to ensure the accuracy of the information. If, however, an individual makes malicious or vexatious allegations, and particularly if he or she persists with making them, disciplinary action may be taken against that individual which may result in summary dismissal.
17. If misconduct is discovered as a result of any investigation, the disciplinary procedure will be used, in addition to any appropriate external measures.
18. An instruction to cover up wrongdoing is itself a disciplinary offence. If told not to raise or pursue any concern, even by a person in authority such as a Manager, you should not agree to remain silent. You should report the matter to a Director of the Company as soon as possible.
19. The overall responsibility for the policy lies with the Managing Director. Employees are encouraged to raise concerns to a Director of the Company at any time.
20. If there is evidence of criminal activity, then the Investigating Officer should inform the Police. The Company will ensure that any internal investigation does not hinder a formal Police investigation.
21. Due to the varied nature of these sorts of complaints, which may involve internal investigators and / or the Police, it is not possible to lay down precise timescales for such investigations. The Investigating Officer should ensure that the investigations are undertaken as quickly as possible without affecting the quality and depth of those investigations.

The media

1. Without exception, all employees must direct contact with, or queries from, the media (e.g. newspaper, radio, television etc.) to a Director of the Company without attempting to answer any questions that are put to them.
2. The media is not a relevant external body. Employees should not contact the media with allegations about the Company. Disclosing information in an inappropriate way (e.g. contacting the media) could result in disciplinary action being taken against the employee, which could include dismissal.

Maternity, paternity, adoption, parental (IOM) leave

1. Maternity – it is the company’s policy to comply with statutory maternity regulations and health and safety at work requirements. Employees will not be subject to any detriment by the company for taking or requesting maternity leave.
2. Maternity Leave – Employees are entitled to take 26 weeks’ Ordinary Maternity Leave (‘OML’), irrespective of their length of service or the number of hours worked each week, provided they comply with certain notification requirements. Some employees may be eligible to Additional Maternity Leave (‘AML’), this is a further 26-week period that starts the day after the employee’s OML ends. To qualify for AML, by the beginning of the 14th week before the expected week of childbirth (‘EWC’), the employee must have completed 26 weeks’ continuous employment and have complied with the notification requirements.
3. Employees are prohibited from returning to work during the 2-week period immediately after the birth of their child. Compulsory leave runs concurrently with OML and is not an additional entitlement
4. Notification Requirements – Where possible, employees should verbally inform the Company of their pregnancy as soon as possible. Employees should notify their Manager, in writing, when they receive medical confirmation of their pregnancy (via a signed Form MATB1). This will normally be provided to them by their medical practitioner after their 20th week of pregnancy. The MATB1 should be provided to the Company by the 15th week before the EWC and should state:
   1. That the employee is pregnant;
   2. The week in which the employee’s child is due (note that for these purposes a week begins on a Sunday);
   3. Whether the employee intends to take OML and AML;
   4. When the employee wants her maternity leave to start (this date cannot be earlier than the 11th week before the EWC)
5. The Company will take appropriate steps to cover periods of maternity leave, where possible. Employees will be encouraged to keep in touch with the Company whilst on maternity leave and the Company will place employees on circulation lists for internal memoranda and will be included in invitations to work-related social events.
6. Prior to the employee’s return to work, they may be invited for an informal meeting with their Manager to discuss their return to work. This will include:
   1. Updating the employee on developments at work
   2. Considering whether any retraining needs have arisen because of process changes or new technical or other developments;
   3. Giving the employee the opportunity of indicating whether they wish to be considered for flexible working (please note that flexible working requests should be made as soon as possible as the process can take up to 14 weeks to complete).
   4. The meeting will also provide an opportunity to discuss and explain any necessary and unavoidable changes to the employee’s work which may have occurred during their maternity leave
7. Employees can choose to start their maternity leave at any time after the start of the 11th week before the EWC, up until the birth of their child. The only exception to this is if an employee is absent from work wholly or partly because of their pregnancy at any time after the start of the 4th week before EWC. In this case, the Company reserves the right to require an employee to start their maternity leave on the first day after their absence. In this situation an employee does not need to notify their Manager that they intend their maternity leave to start, but they will not be entitled to OML unless they have notified their Manager as soon as is reasonably practicable that they are absent from work wholly or partly because of pregnancy and the date their absence began. Such notification must be in writing.
8. If an employee gives birth before their OML has started, it will begin on the day that follows childbirth. Again, in such circumstances, employees do not need to notify their Manager of the date on which they intend to start OML, but they will not be entitled to OML unless they have notified their Manager as soon as is reasonably practicable that they have given birth and the date on which birth occurred. Such notification must be in writing
9. If an employee notifies the Company of their intended start date or that their OML period has been triggered due to premature absence or premature childbirth, the Company will notify the employee, in writing, of the date on which the employee’s OML period will end or the date on which any chosen AML period will end.
10. Employees who have properly notified the Company of the date on which they wish to start their maternity leave, may vary that date provided they notify their Manager, in writing, of the variation at least 28 days before the new commencement date.

    Ante-Natal Care

11. Employees are entitled to take reasonable time off during their normal working hours to receive ante-natal care. Any time off will be paid at the employee’s normal basic rate of pay. Employees should try to arrange any appointments at the start or end of their working day, whenever possible. Ante-natal care includes: doctor / GP appointments, hospital clinics, relaxation/parent craft classes (if these are recommended by the employee’s doctor / GP
12. Employees may be required to produce an appointment card or some other document confirming all appointments other than the first. Employees should advise the Manager that they will be sent as far in advance of their appointments as possible.

    Pregnancy Risk Assessment

13. Once an employee informs the Company that she is pregnant a risk assessment of her job role will be completed, and the Company will discuss what actions to take if any problems are identified.
14. If an employee is employed in a position which has been identified as posing a risk to her health or that of her unborn child, she will be notified immediately, and arrangements will be made to eliminate that risk. For this reason, employees are required to notify their Manager as soon as they are aware that they are pregnant. Arrangements will then be made to alter their working conditions or, if this is not possible, they will be offered a suitable alternative job for the duration of their pregnancy wherever practicable.
15. If there is no alternative work, the Company reserves the right to suspend the employee on full pay until they are no longer at risk. These alternative arrangements may continue for 6 months after the birth of the employee’s child if they are still considered to be at risk.
16. Any employee who has concerns about their health and safety at any time should contact their Manager or a Director of the Company to discuss this as soon as possible.

    Maternity Pay

17. Employees who meet qualifying conditions based on their recent employment and earnings record may claim Maternity Allowance from the Isle of Man Government for up to 39 weeks which will be at the rate in force at the time.
18. To claim Maternity Allowance, employees should complete a Form MA1(IOM) and submit this to the Incapacity Benefits Section, Social Security Division. Claims should be made in or after the 14th week before the EWC. Maternity Allowance will be paid direct to employees by the Isle of Man Government and is usually paid to an Isle of Man bank or building society account on a fortnightly basis.
19. In addition, employees with 2 years qualifying service will benefit from company maternity pay as follows:
    • 3 months full pay (based on basic salary)
    • 3 months half pay (based on basic salary)
20. Employees will continue to receive their contractual benefits during their OML, apart from remuneration, which may be replaced by Maternity Allowance (where eligible, up to the maximum 39 weeks).
21. In the Isle of Man, employers are not required to pay Company Maternity Pay to their employees. However, the Company recognises the need for employees to have a good work-life balance and so operates a discretionary Company Maternity Pay scheme. The Company will pay three month’s salary less normal payroll deductions to the employee in the payroll following the commencement of their maternity leave; this will be based on the employee’s normal basic hourly rate of pay.
22. From time to time the company offers additional benefits to expectant mothers and fathers. These are not contractual and may change from time to time.
23. Where an employee does not return to work for a period of 12 months, part or all of the enhanced maternity provision will be claimed back by the company.

    Eligibility to Maternity Pay

24. To be entitled to Company Maternity Pay you must have:
    1. Been continuously employed by the Company for at least 2 years by the commencement of maternity leave;
    2. Confirmed to your Manager that you intend to return to work;
    3. If you resign or are dismissed within 12 months of returning from maternity leave, you may be liable to repay all or, at the Company’s discretion, some of the Company Maternity Pay payments made to you.
    4. Having benefitted from the Company Maternity Pay Scheme, an employee will not be entitled to benefit from the scheme again until a further 2 years of continuous service with the Company has been completed following their return to work from maternity leave.

    Annual Leave and Family Leave During Pregnancy

25. Employees will continue to accrue their contractual holiday entitlement during OML. During AML, there is no entitlement to contractual annual leave in excess of the statutory minimum. Annual leave cannot be taken during maternity leave. However, employees may apply to use any unused holiday either immediately before or after their maternity leave period, subject to the Company’s normal annual leave request procedure.

    Performance Review

26. Employees may receive a performance review / appraisal in advance of commencing their planned period of maternity leave. Upon their return to work a further review may take place to discuss any training needs, agree any new performance objectives (where relevant), and discuss any other Company changes that may have affected the department or the employee’s job role.

    Legal Rights during Maternity Leave

27. During OML, an employee has a statutory right to continue to benefit from the terms and conditions of employment which would have applied to her had she been in work instead of on leave, except for terms relating to salary or wages. An employee returning to work after OML is entitled to benefit from any general improvements to the rate of pay which may have been introduced for her grade or class of work while she was absent on maternity leave as if she had not been away from work. The employee’s entitlement to any bonus paid during the period of absence will depend on the bonus scheme in place and any affected employees should discuss this with a Director.
28. Unlike OML, the AML period is not required to be counted for the purpose of assessing seniority, pensions rights and other payments based on the individual’s length of service – such as pay increases linked to length of service. In these instances, the period of employment before the start of AML will be ‘joined up’ with the period of employment on her return to work as if they were continuous.
29. The employee’s contract of employment continues during AML, but only certain contractual rights remain in force, namely the employer’s obligation of trust and confidence, the employer’s requirement to give notice of termination, redundancy payment provisions, disciplinary and grievance procedures. The employee is bound by the implied obligation of good faith, requirements for notice of termination of employment, confidentiality, rules as to acceptance of gifts or other benefits, and rules as to participation in another business.

    Keeping In Touch Days

30. The Company is keen to keep employees informed of any developments during their maternity leave and may invite employees to attend training or meetings (as appropriate) for up to 10 days in total (without it affecting their eligibility to Maternity Allowance / pay).
31. Employees are under no obligation to work these days and will not be subject to any detriment should they choose not to do so. The Company is under no obligation to offer these days and will contact employees if the opportunity for any such days arises. ‘Keeping in touch’ days may only be worked if both the employee and their Manager agree and these cannot be within any period of ‘compulsory maternity leave’ i.e. the two weeks immediately after the birth of the employee’s child. Any days or hours which an employee attends work will be paid at the employee’s normal basic rate of pay

    Returning To Work

32. An employee who resumes work after OML is entitled to return to the same job on the same terms and conditions of employment as if she had not been absent, unless a redundancy situation has arisen, in which case she is entitled to be offered a suitable alternative job.
33. After AML an employee is entitled to return to work to the same job, on the same terms and conditions as if she had not been absent. However, if there is some reason why it is not reasonably practicable for her to return to the same job she should be offered a similar job on terms and conditions which are no less favourable than her original job.
34. The Company will assume that employees will return to work after maternity leave, unless it is advised otherwise.
35. If an employee wishes to return to work before their chosen maternity leave period has ended they must give at least 28 days’ notice of the date on which they intend to return to work
36. If, for health and safety reasons, an employee was doing a different job while they were pregnant, they may be required to return to that different job for a short time if they are still at risk when they return to work.
37. If an employee cannot return to work at the end of their maternity leave because of illness, they should follow the Company’s normal reporting procedures for sickness absence.
38. If an employee does not wish to return to work following maternity leave they are required to give the Company notice, in writing, in accordance with their contractual notice period. This notice should be provided to their Manager or a Director of the Company.

Paternity leave policy

1. The Company’s Paternity Leave Policy is to comply with statutory paternity rights. The Company will not subject employees to any detriment because they have taken or sought to take paternity leave.
2. Employees will be eligible for Paternity Leave if they:
   1. Have or expect to have responsibility for the child’s upbringing; and
   2. Are either the biological father of the child, or the mother’s husband or partner (including same sex partner); an
   3. Have worked continuously for the Company for 26 weeks before the 15th week before the baby is due (the ‘qualifying week’) and from the 15th week before the baby is due up to the date of birth and be taking time off either to support the mother or to care for the new baby; and
   4. Have given the correct notice and complied with any requirements to provide supporting evidence.
   5. A ‘partner’ is someone who lives with the mother of the baby in an enduring family relationship but is not an immediate relative. ‘Partner’ may include a female partner in a same-sex couple.

   Paternity Leave

3. Paternity Leave is for a maximum of 2 weeks. Employees can choose to take either one week or two consecutive weeks’ paternity leave (not occasional days or separate weeks). Leave cannot start until the birth of the baby. Otherwise, an employee can choose to start their leave
4. On the date of the baby’s birth (whether this is earlier or later than expected); or
5. On a date falling such number of days after the date on which the child is born (whether this is earlier or later than expected) as the person notifies the Company; or
6. On a fixed date, chosen by the person and notified to the Company, which falls after the first day of the EWC.
7. Paternity leave can start on any day of the week, as long as the employee has given the required notice to the Company. Paternity leave must be completed:
8. Within 56 days of the actual date of the birth of the child; or
9. If the child is born earlier than expected, between the birth and 56 days from the first day of the expected week of birth.
10. Only one period of leave will be available to employees even if more than one child is born as the result of the same pregnancy.
11. If a person specifies the date of birth as the day they wish to start their leave and they are at work that day, the leave will begin on the next day

    Notification Requirements – Paternity Leave

12. Employees are required to inform their Manager, in writing, of their intention to take paternity leave by the 15th week before the EWC, unless this is not reasonably practicable. The Company should be advised in writing of:
    1. The week the baby is expected;
    2. Whether the employee wishes to take one or two weeks’ leave;
    3. When the employee wishes the leave to commence.
13. Paternity leave requests are subject to management approval and will take into account business requirements. All leave requests should be approved in advance by the employee’s Manager (or Director), who will communicate the decision to the employee in writing.
14. The Company may require employees to provide a signed declaration that they wish to take paternity leave to care for a child and that they satisfy the eligibility criteria as set out in this procedure.
15. If an employee has given notice of their intention to take paternity leave and wishes to change the date that their paternity leave begins, they must give the Company 28 days’ written notice before the new period of leave is due to start. This notice should be provided in writing to their Manager (or Director).
16. Employees who take paternity leave which has not been approved in advance by Management will be subject to the Company’s Disciplinary Policy and Procedure.

    Paternity Pay

17. Eligible employees will be entitled to receive 2 weeks’ Paternity Allowance, a benefit payable directly by the Isle of Man Government. Paternity Allowance will be at the rate which is in force at the time.
18. In addition, during the two weeks of paternity leave you will receive your normal salary for the period of leave. To be entitled to Company Paternity Pay you must have:
19. At least 6 months’ continuous service up to the date of commencement of your paternity leave;
20. Confirmed to your Manager that you intend to return to work; in the view of the employer have an acceptable work and attendance record
21. If you resign or are dismissed within twelve months of returning from paternity leave, you may be liable to repay all or, in its discretion, some of the Company Paternity Pay payments made to you.

    plan.com – Baby Bonus

22. Plan Communications will also provide a non contractual Baby Bonus of £1000 to demonstrate its support for the growing families of its’ employees at such an important time in their lives. The baby bonus is non contractual and will be paid through normal payroll following the birth of your baby. This bonus will be reclaimed if you leave your employment within 12 months of returning to work following the birth of your baby.

    Rights during Paternity Leave

23. Employees are entitled to receive their normal terms and conditions of employment during the first two weeks of paternity leave, any additional leave taken may be unpaid. Employees will continue to be bound by any obligations arising out of their Contract of Employment with the Company during paternity leave.

    Return to Work following Paternity Leave

24. An employee is entitled to return to the same job following an isolated period of paternity leave (birth), or a period of paternity leave (birth) which followed on from a period of ordinary adoption leave or a period of parental leave of up to 4 weeks. In any other case the employee is entitled to return to the same job or, if that is not practicable, another job which is suitable and appropriate.
25. If an employee cannot return to work at the end of their paternity leave, because of illness, they should follow the Company’s normal absence reporting procedures.
26. If an employee does not wish to return to work following paternity leave they are required to give the Company notice, in writing, in accordance with their contractual notice period.

    PARENTAL LEAVE – (ISLE OF MAN – DISABLED CHILD)

27. It is the Company’s policy to comply with statutory parental leave regulations. The Company will endeavour to support eligible employees who wish to take time off from work to balance their work and family commitments. Employees will not be subject to any detriment by the Company for taking or requesting parental leave.

    Parental Leave – (Isle of Man)

28. Parental Leave is for a total maximum of 18 weeks in respect of a disabled child and is unpaid. If an employee has responsibility for more than one disabled child, they can take up to 18 weeks’ leave in all in respect of each child. Parental leave should be taken before the child’s 18th birthday, provided that the Company has been given the appropriate notice and has not exercised its right to postpone the leave.
29. Employees may not take more than 4 weeks’ leave in respect of an individual disabled child during a particular year (‘year’ for this purpose means 12 months from the date when the employee first became entitled to take parental leave).
30. Where the leave is taken in blocks of less than one week, a ‘normal working’ week is deducted from an employee’s overall entitlement to 18 weeks only when the short periods of leave add up to what would be a normal or average working week.
31. Employees will be eligible for parental leave if they:
    1. Have worked for the Company continuously for a minimum of 1 year, provided they have, or expect to have, parental responsibility for a disabled child and the purpose of the leave is to care for the child;
    2. Have given the correct notice and complied with any requirements to provide supporting evidence.
    3. Note: an employee may carry forward any unused entitlement to leave from a previous employer, but they must work for the Company for at least 1 year before any further leave can be taken;
       1. Only the following people have parental responsibility for a child:
       2. The mother;
       3. The father, if he is or was married to the mother, or if parental responsibility is given to him by a court order or a formal agreement with the mother;
       4. A guardian appointed by the court, or by a deceased parent
       5. A person in favour of whom a residence order is made;
       6. Adoptive parents.
32. The disabled child does not need to be living with the employee for the employee to be entitled to parental leave. For the purposes of parental leave, a disabled child is one in respect of whom Disability Living Allowance is payable
33. The purpose of parental leave is to care for a disabled child. This means looking after the welfare of the child and can include making arrangements for the child’s welfare. The leave may be taken to enable a parent to spend more time with a child. It may also be used, for example:
    1. To accompany the child during a stay in hospital
    2. To take the child to see a specialist;
    3. To inspect a new school;
    4. To settle the child into new childcare arrangements;
    5. To enable a family to spend more time together e.g. taking the child to stay with grandparents.

    Notification Requirements – Parental Leave

34. Employees should notify their Manager, in writing, of their intention to take parental leave at least 21 days before the date on which the leave is to begin. Notification must specify the dates on which the leave is to begin and end.
35. Employees will be required to provide evidence (e.g. the child’s birth certificate, confirmation of receipt of Disability Living Allowance etc.) of their entitlement to parental leave and may be required to sign a declaration stating that they satisfy the eligibility criteria as set out in this procedure.
36. The Company will take appropriate steps to cover periods of parental leave, where possible. Employees will be encouraged to keep in touch with the Company whilst on parental leave and the Company will place employees on circulation lists for internal memoranda and will be included in invitations to work-related social events.
37. Where the Company is unable to agree to the time requested as unpaid parental leave, this may be deferred to another time. The Company will allow an employee to take a period of parental leave of the length requested within 6 months of the date on which it was due to begin. It must finish before the child’s 18th birthday.
38. Employees who have properly notified the Company of the date on which they wish to start their parental leave, may vary that date provided they notify their Manager, in writing, of the variation at least 21 days before the new commencement date.

    Rights during Parental Leave

39. Employees will continue to receive their contractual benefits during parental leave, apart from remuneration. During parental leave, employees will continue to be bound by any obligations arising out of their Contract of Employment with the Company.

    Returning to Work following Parental Leave

40. Employees are entitled to return to the same job following parental leave on the same terms and conditions of employment as if they had not been absent, unless a redundancy situation has arisen; or (if more than 4 weeks’ leave is taken – because it followed on from other statutory leave) to a similar job which is suitable and appropriate under the circumstance
41. The Company will assume that employees will return to work after parental leave, unless it is advised otherwise
42. If an employee cannot return to work at the end of their parental leave because of illness, they should follow the Company’s normal absence reporting procedures
43. If an employee does not wish to return to work following parental leave they are required to give the Company notice, in writing, in accordance with their contractual notice period. This notice should be provided to the employee’s Manager or a Director.

Adoption leave

1. It is the Company’s policy to comply with statutory adoption leave regulations. Employees will not be subject to any detriment by the Company for taking or requesting adoption leave. Where a couple are adopting jointly, one of them may opt to take adoption leave and the other paternity leave (adoption).
2. Where an individual is adopting, they may take adoption leave. If they have a partner, their partner may also be entitled to take paternity leave (adoption)
3. Employees will be eligible for Ordinary Adoption Leave (‘OAL’) if they:
   1. Have been matched with a child to be placed with them by an adoption agency
   2. Where the child is to be adopted by a couple jointly, have chosen to be treated as the adopter for this purpose
   3. Have notified the agency that they agree that the child should be placed with them, and of the date of placement; and
   4. Have notified the Company that they want to take adoption leave within 7 days of the date on which they were notified of having been matched with the child.
4. Employees will be eligible for Additional Adoption Leave (‘AAL’) if they:
   1. Have had the child placed with them for adoption;
   2. Have continuously worked for the Company for 26 weeks, ending with the week (beginning on a Sunday) in which they were notified of having been matched with the child; and
   3. Have taken OAL (which did not end prematurely with the cancellation of the placement or the dismissal of the employee).
5. Employees will be eligible for Paternity Leave (Adoption) if they
   1. Are married to, or the unmarried partner of, the child’s adopter
   2. Have or expect to have main responsibility, with the adopter, for the child’s upbringing;
6. In addition, they must have worked continuously with the Company for 26 weeks, ending with the week (beginning on a Sunday) in which the adopter is notified of having been matched with a child (the ‘matching week’) and continue to work for the Company from the matching week up to the date of placement
7. Have given the correct notice and complied with any requirements to provide supporting evidence; an
8. Be taking time off either to support the adopter or to care for the newly placed child
9. ‘partner’ is someone who lives with the mother of the baby in an enduring family relationship but is not an immediate relative. ‘Partner’ may include a partner in a same-sex couple
10. In the case of adoption, the employee is newly matched with a child for adoption by an approved adoption agency (formally becoming a step-parent of a partner’s child does not qualify)
11. For employees who qualify, Adoption Leave is for a maximum of 52 weeks. This is made up of 26 weeks’ OAL followed by 26 weeks’ AAL. An eligible employee can choose to take either one week or two consecutive weeks’ paternity leave. Leave cannot be taken as odd days, or as two separate weeks. Further information can be found in the Company’s Paternity Leave Policy.
12. Employees can take only one period of leave, even if more than one child is placed for adoption at the same time

    Notification Requirements – Adoption Leave

13. Employees are required to inform their Manager, in writing, of their intention to take adoption leave no more than 7 days after the date on which the adopter is notified as having been matched with the child. If that is not reasonably practicable, the Company must be notified as soon as possible thereafter.
14. The Company should be advised in writing of:
    1. The date on which the adopter was notified as having been matched with the child;
    2. The employee’s intention to take adoption leave and the length of leave chosen;
    3. The date on which the child is expected to be placed with the adopter; and
    4. The date the employee intends to start adoption leave or paternity leave (adoption).
15. The Company will take appropriate steps to cover periods of adoption leave, where possible. Employees will be encouraged to keep in touch with the Company whilst on adoption leave and the Company will place employees on circulation lists for internal memoranda and will be included in invitations to work-related social events
16. The Company may require employees to provide a signed declaration that they wish to take adoption leave to care for a child and that they satisfy the eligibility criteria as set out in this procedure and ask for additional documentation e.g. adoption agency details.
17. Paternity Leave: An employee must advise the Company that they intend to take paternity leave no more than 7 days after the day the adopter is notified of being matched with the child or, if this is not possible, as soon as is reasonably practicable. If the adopter is told, before any period of paternity leave has started, that the placement will not be made, the employee will not be able to take paternity leave. If the child is placed and then dies or is returned to the adoption agency, the employee will be entitled to paternity leave.
18. The Company will advise employees of the start and end dates of adoption leave or paternity leave (adoption) within 28 days of receiving the employee’s notification
19. Prior to an employee returning to work from adoption leave, they may be invited for an informal meeting to discuss their return to work. This will include:
    1. Updating the employee on developments at work;
    2. Considering whether any retraining needs have arisen because of process changes or new technical or other developments;
    3. Giving the employee the opportunity of indicating whether they wish to be considered for flexible working (please note that flexible working requests should be made as soon as possible as the process can take up to 14 weeks to complete)
20. The meeting will also provide an opportunity to discuss and explain any necessary and unavoidable changes to the employee’s work which may have occurred during their adoption leave.
21. Employees can choose to start their leave either
    1. From the date on which the child is placed with the adopter; or
    2. Up to 14 days before the date the employee expects the child to start living with them
22. The Company will advise employees of the date on which their Adoption Leave will end. This may be 26 weeks or 52 weeks after it starts. Employees can return to work earlier than this as long as they provide the Company with 28 days’ notice
23. If an employee has given notice of their intention to take adoption leave or paternity leave (adoption) and wishes to change the date that their adoption leave begins, they must give the Company 28 days’ written notice before the leave is due to start. This notice should be provided in writing to the employee’s Manager or a Director.

    Adoption Pay

24. Eligible employees may claim Adoption Allowance or Paternity Allowance (Adoption) from the Isle of Man Government which will be at the rate in force at the time. Adoption Allowance is available for up to 39 weeks. Paternity Allowance (Adoption) is available for up to 2 weeks depending on the length of leave taken.
25. Whilst certain adoption allowances and benefits are available from the Isle of Man Government, there is no obligation on employers on the Isle of Man to pay their staff during adoption or adoption leave (paternity). The Company however considers it appropriate to implement its own Company Adoption Pay scheme. The scheme will operate as described in the above sections for Company Maternity Pay and Company Paternity Pay. For the purposes of Company Adoption Pay, the type of Company pay made will be based on the type of adoption leave you have elected to take – adoption leave or adoption leave (paternity)
26. To be entitled to Company Adoption Pay or Company Adoption Pay (Paternity) you must have:
    1. At 6 months’ continuous service up to the date of commencement of your adoption or paternity leave (adoption);
    2. Confirmed to your Manager that you intend to return to work; in the view of the Employer have an acceptable work and attendance record If you resign or are dismissed within twelve months of returning from the leave, you may be liable to repay all or, in its discretion, some of the payments made to you
    3. Upon returning to work after adoption leave, Company Adoption Pay as set out above will not be available to you again until you have at least a further two years’ continuous service

    Rights during Adoption Leave

27. Employees are entitled to receive their normal terms and conditions, except for terms relating to salary or wages, throughout their adoption leave. Note: during a period of AAL the Company does not have to count this time for assessing contractual rights which are dependent on length of service or a period of qualifying service such as seniority, pension rights, pay increments. For these purposes, service (including OAL) before AAL is joined up with service after return to work as if they were continuous.
28. During paternity / adoption leave, employees will continue to be bound by any obligations arising out of their contract with the Company.
29. Employees may have a performance review in advance of commencing their planned period of adoption leave. Upon their return to work a further review may take place to discuss any training needs, agree any new performance objectives (where relevant), and discuss any other Company changes that may have affected the department or the employee’s job rol

    Keeping In Touch Days – Adoption Leave

30. Company is keen to keep employees informed of any developments during their adoption leave and may invite employees to attend training or meetings (as appropriate) for up to 10 days in total (without it affecting their eligibility to statutory Adoption Allowance).
31. Employees are under no obligation to work these days and will not be subject to any detriment should they choose not to do so. The Company is under no obligation to offer these days and will contact employees if the opportunity for any such days arises. ‘Keeping in touch’ days may only be worked if both the employee and their Manager agree. Any days or hours which an employee attends work will be paid at the employee’s normal basic rate of pa

    Returning to Work

32. An employee is entitled to return to the same job following an isolated period of OAL which followed on from two or more periods of statutory leave, which did not include any period of AML or AAL or a period of parental leave of up to 4 weeks. In any other case they are entitled to return to the same job or, if that is not practicable, another job which is suitable and appropriate.
33. If an employee cannot return to work at the end of their adoption leave, because of illness, they should follow the Company’s normal absence reporting procedures.
34. Employees will not be subject to any detriment by the Company because they have taken or sought to take adoption leave.
35. The Company will assume that employees will return to work after adoption leave, unless it is advised otherwise.
36. If an employee does not wish to return to work following adoption leave they are required to give the Company notice, in writing, in accordance with their contractual notice period. This notice should be provided in writing to the employee’s Manager.

Compassionate leave

1. Compassionate leave is designed to help a member of staff where they need to deal with necessary arrangements for or assist a close relative who is seriously or critically ill or has recently passed away

   Entitlement

2. Compassionate leave is available in respect of unforeseen domestic distress with regard to spouse or partner, child, stepchild, grandchild, parent, step-parent, parent-in-law, grandparent, brother or sister, stepbrother or stepsister, or brother or sister-in-law on a discretionary basis.
3. Compassionate leave will be unpaid although the business may consider paid compassionate leave in exceptional circumstances.
4. Compassionate leave should be agreed in advance wherever possible. We will respect your privacy during periods of compassionate leave, however we reserve the right to contact you with a view to discussing and agreeing any expected return date with you.
5. A member of staff who is unable to return to work following a period of compassionate leave should contact their line manager or the Human Resources Team. It may be appropriate to take a period of annual leave or unpaid leave in those circumstances.

   Requesting compassionate leave

6. We recognise that it may not always be possible to request compassionate leave in advance. However, where it is possible, you should make a request to your line manager or the Human Resources Team. You should tell them the reasons for your request and the number of days leave you would like to take.
7. Where it is not possible to request leave in advance you should contact your line manager or the Human Resources Team as soon as possible to explain the reason for your absence and the number of days you expect to be absent. Someone can do this on your behalf if necessary.
8. In exceptional circumstances we may have to refuse a request for compassionate leave. If so your line manager or the Human Resources Team will give you a written explanation for the refusal. If you are dissatisfied with this decision you may make a complaint under our Grievance Procedure within 7 days of receipt of the written reasons for refusal.

Flexible working policy

1. The Company acknowledges the importance for employees in achieving a work life balance and will consider all flexible working requests seriously. We will endeavour to grant requests where practicably possible to do so. Each request will be considered on a case-by-case basis and with the best business interests in mind.
2. Aims and Objectives -The aims of the policy are to ensure that flexible working requests are reviewed in a fair and consistent manner. It provides a framework for Managers and provides employees with guidance on the procedure they should follow.
3. Eligibility – This policy applies to all employees of the Company and excludes contractors, casual/zero hour contracts.

   Main Principles of the Policy

4. The Company will consider all written requests for flexible working arrangements on an individual by individual basis, and will consider the needs of the business and the team when making a decision.
5. Employees may request a permanent variation of their employment contract in respect of, for example:
   • a) the hours they are required to work e.g. less hours / part-time working;
   • b) the times when they are required to work e.g. different days, starting work earlier or later;
   • c) their place of work e.g. working from home for all or part of the working week;
   • d) job-sharing
   • e) working term-time only
   • f) working shifts
6. Where an application for flexible working hours is authorised, a permanent variation in the employee’s contract of employment will result, unless the Company agrees otherwise. This means that once a change has been made, the employee does not have the right to revert back to their previous working arrangements.
7. Employees may make further applications for contract variations (whether their first application was successful or not) provided they are made at least 12 (twelve) months after the date of the previous application.
8. If the Company is not sure that the flexible working request is workable it may, at its sole discretion, allow the flexibility for a trial period. If the trial is not working successfully the Company will advise the employee as soon as possible and the trial will end with reasonable notice.
9. Procedure for making a flexible working request:
   1. Employees are encouraged to discuss their request informally with their line manager in the first instance.
   2. You will then provide a formal written application to your line manager.
   3. Your line manager will consider the implications of the flexible working request on the delivery of the business of the team.
   4. Just because someone else is able to work flexibly does not mean that you have an automatic right to work flexibly. Each case will be considered on the impact the altered working pattern will have on the delivery of the business.
   5. The most successful requests come from employees who have thought about what the issues might be facing the team. If allowing a flexible working request unreasonably impacts on another member of the team or the business the request may be refused.
   6. Your manager will commit to respond to your request within 1 month.
   7. You are entitled to appeal the decision to the Director of People. To do this you must put your appeal in writing and send it to the Director of People within 5 working days of the date your request is refused.

Homeworking policy

1. plan.com is an office based business. However, we support homeworking in appropriate circumstances either occasionally (to respond to specific circumstances or to complete particular tasks) and in some cases on a regular (full or part-time basis). In addition, occasional or permanent homeworking can, in certain circumstances, be a means of accommodating a disability and can be requested as a means of flexible working under our Flexible Working Policy.
2. However, when considering homeworking the needs of our business will always take priority and those who are allowed to work from home must comply with this policy.
3. You must seek permission to work from home on every occasion. HR will be notified and where appropriate logged through People HR. Applying for homeworking
4. After successful completion of their probationary period, any member of staff can make an application for homeworking, which will be considered on its merits. However, not all staff and not all jobs are suitable for homeworking.
5. If you wish to apply to work from home you will need to be able to show that you can:
   1. work independently, motivate yourself and use your own initiative;
   2. manage your workload effectively and complete work to set deadlines;
   3. identify and resolve any new pressures created by working at home; and
   4. adapt to new working practices including maintaining contact with your line manager or supervisor and colleagues at work.
6. To be considered for homeworking you must submit a written application to your line manager or the Human Resources Team. Your application must state:
   1. why you consider your job to be suitable for homeworking and how you will deliver your role and the wider team and corporate expectations .
   2. whether you wish to work from home on a permanent basis or for a fixed period. In either case you should state the date from which you wish the arrangements to start and, if you wish to work from home for a fixed period, the date on which you want the arrangements to finish. You should try to give us as much notice as possible and, in any event, make your application at least a week before your proposed start date so that your request can be considered;
   3. whether you wish to work from home for all or part of your working week and, if only part, which days you propose to work from home;
   4. how you would organise your work from home including how you would ensure the security of documents and information, where appropriate;
   5. the extent to which you could be available to come to work on days you are proposing to work from home if needed, for example to cover if colleagues are off sick, to cope with high or unexpected levels of work or to attend meetings or training days;
   6. if different from your current hours of work, the hours of work that you propose apply when you are working at home; and
   7. how you envisage maintaining contact with your line manager or supervisor, team and wider business associates, and how your work will be set and progress monitored.
7. It may assist your application for homeworking if you first discuss your proposal with your line manager or supervisor informally. This may identify potential problems with your application, such as a need to be in the office on occasions you had not considered, which your application can then address.
8. In considering your application your line manager or the Human Resources Team may invite you to a meeting to discuss your proposals.
9. If your request is refused we will give you written reasons for the refusal. If you are not happy with the decision you may Appeal the decision or raise a grievance.
10. If your application is accepted the agreed arrangements will be recorded in writing.
11. Any terms on which it is agreed that you may work from home will include the following:
    1. We reserve the right to terminate the homeworking arrangements, subject to reasonable notice.
    2. You will be subject to the same performance measures, processes and objectives that would apply if you worked in the office.
    3. If you receive an unsatisfactory appraisal or review or are subject to a verbal or written warning for any reason your homeworking arrangements will be terminated immediately and you will be expected to return to work in the office.
    4. Your line manager or supervisor will remain responsible for supervising you, will regularly review your homeworking arrangements and take steps to address any perceived problems. They will also inform you of meetings or training sessions that you must be able to attend in the office and ensure that you are kept up to date with circulars and information relevant to your work.
    5. Working from home may affect your home and contents insurance policy. You must make any necessary arrangements with your insurers before commencing homeworking.

    Working at home: equipment

12. It is your responsibility to ensure that you have sufficient and appropriate equipment for working from home. We are not responsible for the provision, maintenance, replacement, or repair in the event of loss or damage to any personal equipment used by you when working for us.
13. We are not responsible for associated costs of you working from home including the costs of heating, lighting, electricity or telephone calls.
14. All equipment and information must be kept securely. In particular, private and confidential material must be kept secure at all times. Your line manager or your supervisor must be satisfied that all reasonable precautions are being taken to maintain confidentiality of material in accordance with our requirements.

    Working at home: health and safety

15. Staff working at home on a regular basis have the same health and safety duties as other staff. They must take reasonable care of their own health and safety and that of anyone else who might be affected by their actions.
16. We retain the right to check home working areas for health and safety purposes. The need for such inspections will depend on whether work is undertaken at or from home and the nature of the work undertaken.
17. Staff working at home must not have meetings in their home with customers and must not give customers their home address or telephone number.
18. Staff must ensure that their working patterns and levels of work both over time and during shorter periods are not detrimental to their health and wellbeing.
19. Staff must use their knowledge, experience and any training to identify and report any health and safety concerns to their line manager or their supervisor.

Learning and development policy

1. We recognise that in a rapidly changing world it is important to have a continuous learning and talent approach in order that employees can continually learn, adapt and develop their skills and capabilities. Our success is reliant on a flexible and knowledgeable workforce. Everyone has a unique contribution to make to our organisational success. Our employees’ performance affects the Company’s performance.
   1. The Learning & Development Policy provides a framework to support the continuous development of employees. This includes regularly reviewing learning and development needs as part of the Company’s performance management process, providing support to individuals to obtain relevant qualifications, encouraging continuous professional and personal development, and focusing on talent management and succession planning activities.
   2. All employees will be treated equally regarding access to learning and development opportunities and will be encouraged to develop their potential.
2. Aims and objectives – The aim of the policy is to align learning and development opportunities with the goals of the Company. Learning and development needs will be identified at various levels:
   • Company needs;
   • Business Unit / Department;
   • Individual.
   1. The policy (and associated procedure) sets out guidance for employees and Managers regarding learning and development activities that may be progressed and outlines the Company’s approach to the continuous learning and development of its people.
   2. By having a focused approach to learning and development it will assist in enabling the Company to achieve its goals and priorities, support the development of its people to enable them to increase their skills and capabilities in order to be more effective and adaptable, and enhance their future career opportunities.
3. Eligibility – This policy (and associated procedure) applies to all employees of the Company from the start of their career with us.
4. Main Principles – Learning and development needs will be identified via the regular review of employee performance and prioritised in terms of their likely effectiveness on Company and individual performance (considered in conjunction with the cost of investment in the learning activity), and appropriate learning and development solutions will be planned and delivered.
   1. Talent management and succession planning will focus on identifying the ‘stars’ of the future as well as developing those that simply want to be the best they can be. We will structure specific learning and development plans to enable a continuous development of talent into key positions / job roles within the Company. These may be long-term programmes and include mentoring, coaching, learning, education, training and if appropriate secondment.
   2. The Company places great importance on professional qualifications and the attainment of qualifications is an important factor in personal career development within the Company. The Company encourages and supports relevant programmes of job-related and business-related development.
   3. We strive to provide everyone with:
      • Equality of opportunity in all aspects of their learning and development;
      • An Induction Programme providing a structured familiarisation process into the Company, their job role, team and Department;
      • An understanding of the direction and goals of the Company;
      • Clear and measurable goals for their performance at work;
      • Regular formal review of their performance (through 121, 15/5 and formal performance reviews);
      • A Manager who is committed to your development and the teams;
      • Supervisory / management skills training, where appropriate;
      • Health and Safety training.

      We expect our employees to take some of this responsibility for their own development themselves by:

      • Sharing responsibility for the identification of their development needs;
      • Taking advantage of development opportunities;
      • Taking an active part in performance management and development schemes;
      • Sharing their knowledge with others.
   4. We will contribute to your development in all sorts of ways, such as:
      • Performance review appraisal process: regular review of you performance with the opportunity to discuss what you’d like to see more of and which parts of your role you may need support with.
      • 360-degree feedback: feedback received from other internal stakeholders/colleagues to assist in your personal development planning.
      • Personal development planning: a structured framework for identifying development needs, planning appropriate solutions and monitoring their achievement.
      • Coaching: improving skills and performance by coaching activities, usually in a person’s existing job role, but also to support career transitions.
      • Mentoring: typically, experienced Managers will support others by a structured longer-term mentoring programme. External mentors may be used, where required.
      • On-the-job learning: usually delivered on a one-to-one basis and is a specified, planned and structured activity. Employees are able to practice what they have learned immediately and feedback and encouragement is provided. This can include: induction, job rotation, secondments, work-shadowing, assignments and projects
      • Off-the-job learning: carried out away from the workplace and may include attendance at conferences, outdoor learning activities e.g. teambuilding and leadership development.
      • Mandatory training: this is training that is deemed essential to the safe and efficient functioning of the Company and / or the safety and wellbeing of people e.g. Health and Safety training, Equality Training.
      • Formal training programmes: these may be internal or external and will be instructor-led, typically with the focus being on changing behaviours of people.
      • Study support: assistance provided to enable employees to enhance their skills and knowledge
      • Education & qualifications: support of vocational and management education, enabling employees to improve their skills and knowledge and acquire qualifications.
      • Distance learning: using learning materials received either by post or electronically.
      • Workwize (E-learning): learning that is delivered using electronic technology to large numbers of people e.g. Company Induction. This is a flexible approach whereby employees can learn in their own time.
      • Cross-functional team projects: exposing employees to different areas and enabling them to learn about other aspects of the Company to broaden their experience.
      • Knowledge management: at the end of projects, teams may gather to review how they have worked and to record ‘lessons learned’. This encourages people to work together and to improve systems, processes etc.
      • Bite-sized learning: small chunks of training, usually 1 or 2 hours in duration e.g. breakfast meetings, lunch ‘n’ learn seminars etc
      • Learning interventions will be assessed for their effectiveness and learning objectives will be identified. Managers will contribute to assessing and evaluating performance ‘before’ and ‘after’ learning activities have occurred.
5. Training Funding Agreement – Where your chosen career path involves a long term and often expensive learning or educational programme we may ask you to sign a ‘training funding agreement’. A TFA is an agreement of exactly what is expected from you in terms of ‘exams’, final qualification and exactly what the company will support in terms of cost, in terms of study time and any ‘claim back’ of costs should you decide to leave the business shortly after committing to the course. Because every piece of learning is very different, each case will be taken on its merits and its applicability to the business. Further advice can be received from the HR Team.
6. Time Off to Learn – You will be required to identify any time requirements in the training funding agreement (in advance of starting your course). You will need to identify whether the course will be achieved through modular assessment or through examination. Before any commitment can be agreed you should discuss the implications of this with your line manager and HR will provide you with a reflective training funding agreement. To book ‘time of to learn’ you should book the time through your line manager and ensure it is captured on People HR.
7. Changes to agreed study or training arrangements – You must tell us in writing if:
   1. you do not start the agreed study or training for any reason (for example, if it is cancelled);
   2. you do not complete the agreed study or training; or, if you fail any part of the study programme;
   3. you undertake (or wish to undertake) a different course of study or training.
8. You should also tell us immediately if you become aware of any changes to agreed study or training, including changes to the timing or content of the course. The Director of People is responsible for the efficacy of this policy, its compliance with legislation and its regular review.

Time off for public duties policy

1. We wish to enable staff to perform any public duties that they may be committed to undertake and so will give them time off to do so where it does not conflict with the operational needs of our business. We are not obliged to grant staff paid leave for these purposes. The circumstances in which we are prepared to do so are set out below.

   Jury service

2. You should tell your line manager or your supervisor or the Human Resources Team as soon as you are summoned for jury service and provide a copy of your summons if requested.
3. Depending on the demands of our business we may request that you apply to be excused from or defer your jury service.
4. Employers are not required to pay staff while they are absent on jury service. You will be advised at court of the expenses and loss of earnings that you can claim. We pay basic pay to staff who are doing jury service less any amounts you can claim from the court for lost earnings for up to five working days. Payment for time off beyond five working days may be paid at our discretion.

   JVoluntary public service

5. Employees are entitled to a reasonable amount of unpaid time off work to carry out certain public duties.
6. Public service duties include service as a:
   1. a justice of the peace;
   2. a member of a local authority;
   3. a member of a statutory tribunal;
   4. a governor of a school maintained by the Department of Education and Children
7. If you are unsure whether a public service that you perform is covered by this policy you should speak to the Human Resources Team.
8. As soon as you are aware that you will require time off for performance of a public service you should notify your line manager or the Human Resources Team in writing, providing full details of the time off that is being requested and the reasons for your request. In order that arrangements can be made to cover your duties in your absence you should make your request in good time.
9. We will agree to requests for time off to undertake public duties wherever reasonably possible having regard to the criteria set out in this policy. If it is not possible to accept a request you will be given written reasons for our decision.
10. Each request for time off will be considered on its merits, in the circumstances in which it is made including:
    1. Whether the activity is reasonable in relation to your employment.
    2. How much time off is reasonably required for the duty in question.
    3. How much time off you have already taken for the public duty in question.
    4. How your absence will affect our business.

Adverse weather and travel disruption policy

1. This policy applies where it becomes impossible or dangerous for employees to travel in to work because of:
   1. extreme adverse weather such as heavy snow;
   2. industrial action affecting transport networks; or
   3. major incidents affecting travel or public safety.
2. On these occasions we recognise that a flexible approach to working arrangements may be necessary to accommodate the difficulties employees face and to protect health and safety, while still keeping the business running as effectively as possible.

   Travelling to work

3. You should make a genuine effort to report for work at your normal time. This may include leaving extra time for the journey and/or taking an alternative route. Travel on foot or by bicycle should be considered where appropriate and safe.
4. If you are unable to attend work on time or at all, you should telephone your line manager or supervisor or the Human Resources Team before your normal start time on each affected day or as soon as practicable thereafter.
5. If you are unable to attend work, you should check the situation throughout the day in case it improves. Information may be available from local radio stations, the police, transport providers or the internet. If conditions improve sufficiently, you should report this to your line manager or the Human Resources Department and attend work unless told otherwise.
6. If you do not make reasonable efforts to attend work or fail to contact your manager or the Human Resources Team without good reason, you may be subject to disciplinary proceedings for misconduct. We will consider all the circumstances including the distance you have to travel, local conditions in your area, the status of roads and/or public transport, and the efforts made by other employees in similar circumstances.

   Alternative working arrangements

7. You may be required to work from home, where possible, or from an alternative place of work, if available. Your line manager or the Human Resources Team will advise you of any such requirement. You will receive your normal pay in these circumstances.
8. If you are able to work, you may sometimes be expected to carry out additional or varied duties during such periods. However, you will not be required to do anything you cannot do competently or safely.

   Late starts and early finishes

9. If you arrive at work late or ask to leave early, you will usually be expected to make up any lost time. Your line manager has the discretion to waive this requirement in minor cases, or (in the case of lateness) where they are satisfied you have made a genuine attempt to arrive on time.
10. Your line manager has the discretion to allow you to leave early and should have regard to the needs of the business and your personal circumstances.
11. Where half the normal working day or more is lost this will be treated as absence and dealt with as set out below.

    Absence and pay

12. If you are absent from work due to extreme weather or other disruptions to travel, you are not generally entitled to be paid for the time lost.
13. Absence in all other cases can be treated in a variety of ways. You should discuss your preference with your line manager, who retains overall discretion in the matter. A number of options are set out below:
    1. Treating the absence as annual leave. If not enough annual leave entitlement remains, you may choose to borrow up to two days from the next leave year.
    2. Making up the lost hours within a reasonable time.
    3. Treating the absence as special unpaid leave.
14. If, in exceptional circumstances, we decide to close the workplace, you will be paid as if you had worked your normal hours.

Health and safety policy

1. We are committed to ensuring the health and safety of our staff and customers and anyone affected by our business activities and to providing a safe environment for all those attending our premises through regular assessments of risks in the workplace.
2. In particular we are committed to maintaining safe and healthy working conditions through control of the health and safety risks arising from our work activities, provision and maintenance of safe plant and equipment, ensuring the safe handling and use of substances, consulting with our staff and providing appropriate information, instruction, training and supervision and taking steps to prevent accidents and cases of work-related ill health.

   What is covered by this policy?

3. In accordance with our health and safety duties, we are responsible for:
   1. Assessing risks to health and safety and identifying ways to overcome them.
   2. Providing and maintaining a healthy and safe place to work and a safe means of entering and leaving our premises, including emergency procedures for use when needed.
   3. Providing information, instruction, training and supervision in safe working methods and procedures as well as working areas and equipment that are safe and without risks to health.
   4. Ensuring that equipment has all necessary safety devices installed, that equipment is properly maintained and that appropriate protective clothing is provided.
   5. Promoting co-operation between members of staff to ensure safe and healthy conditions and systems of work by discussion and effective joint consultation.
   6. Regularly monitoring and reviewing the management of health and safety at work, making any necessary changes and bringing those to the attention of all staff.
4. The Human Resources Team and the board have overall responsibility for health and safety and the operation of this policy.
5. All staff must also recognise that everyone shares responsibility for achieving healthy and safe working conditions. You must consider the health and safety implications of your acts and/or omissions and take reasonable care for your health and safety and that of others.
6. Any health and safety concerns should be reported to the Human Resources Department.

   Standards of workplace behaviour

7. You must co-operate with the supervisors and managers on health and safety matters and comply with any health and safety instructions.
8. You must take reasonable care of your own health and safety and that of others by observing safety rules applicable to you and following instructions for the use of equipment (including safety equipment and protective clothing).
9. Any health and safety concern, however trivial it might seem, including any potential risk, hazard or malfunction of equipment, must be reported to your line manager.
10. You must co-operate in the investigation of any accident or incident that has led, or which we consider might have led, to injury.
11. Failure to comply with health and safety rules and instructions or with the requirements of this policy may be treated as misconduct and dealt with under our Disciplinary Procedure.

    Information and consultation

12. We are committed to providing information, instruction and supervision on health and safety matters for all staff as well as consulting with them regarding arrangements for health and safety management.

    Equipment

13. All staff must use equipment in accordance with operating instructions, instructions given by managers and any relevant training. Any fault with, damage to or concern about any equipment or its use must immediately be reported to your line manager or IT Department.
14. Employees must ensure that health and safety equipment is not interfered with and that any damage is immediately reported.
15. No member of staff should attempt to repair equipment unless trained and designated to do so. Failure to report damage to or a fault with equipment or failure to use it as directed may result in action under our Disciplinary Procedure.

    Accidents and first aid

16. Any accident at work involving personal injury should be reported to your line manager or the Human Resources Department so that details can be recorded in the Accident Book. All staff must cooperate with any resulting investigation.
17. Details of first aid facilities and trained first aiders are available from the Human Resources Department. When an accident or illness occurs contact the nominated first aider for your team or area. Give your name, location and brief details of the problem.
18. If you suffer an accident at work you (or someone on your behalf) must report that fact to your manager as soon as possible. All accidents should be reported, however trivial. The accident will be recorded in our Accident Book which is kept in the Human Resources Department.

    Emergency evacuation and fire precautions

19. You should familiarise yourself with the instructions about what to do in the event of fire which are displayed on notice boards and available from the Human Resources Department. You should also know where the fire extinguishers are, ensure that you are aware of your nearest fire exit and alternative ways of leaving the building in an emergency.
20. Fire wardens are responsible for the effective evacuation of designated areas. In the event of a suspected fire or fire alarm you must follow their instructions.
21. Regular fire drills will be held to ensure that our fire procedures are effective and to ensure you are familiar with them. These drills are important and must be taken seriously.
22. You should notify your manager as soon as possible if there is anything (for example, impaired mobility) that might impede your evacuation in the event of a fire.
23. If you discover a fire you should not attempt to tackle it unless you have been trained or feel competent to do so. You should operate the nearest fire alarm and, if you have sufficient time, call reception or a nominated fire officer and report the location of the fire.
24. On hearing the fire alarm you should remain calm and walking quickly, not running, evacuate the building immediately following the instructions of the fire wardens. Do not stop to collect personal possessions, do not use the lifts, and do not re-enter the building until you are told that it is safe to do so.

No-smoking policy

1. We are committed to protecting your health, safety and welfare and that of all those who work for us by providing a safe place of work and protecting all workers, service users, customers and visitors from exposure to smoke.
2. All of our workplaces (including our vehicles) are smoke-free (and electronic appliance/Vape free) and all staff and visitors have a right to a clean breathing environment.

   Scope and implementation of the policy

3. Smoking is banned in any enclosed or substantially enclosed premises within our workplace. The ban applies to anything that can be smoked and includes, but is not limited to, all types of vape, cigarettes, pipes (including water pipes such as shisha and hookah pipes), cigars and herbal cigarettes.

   Breaches of the policy

4. Breaches of this policy will be dealt with under our Disciplinary Procedure and, in serious cases, may be treated as gross misconduct leading to summary dismissal.

Alcohol and drugs and substance misuse policy

1. We are committed to providing a safe, healthy and productive working environment for all our staff, customers and visitors. This includes ensuring that all staff are fit to carry out their jobs safely and effectively in a working environment which is free from alcohol and drug misuse.
2. All staff are expected to arrive at work fit to carry out their jobs and to be able to perform their duties safely without any possible limitations due to the use or after effects of alcohol or drugs (whether prescribed, over the counter or illegal).
3. Misuse of alcohol and drugs can lead to reduced levels of attendance, reduced efficiency and performance, impaired judgement and decision making and increased health and safety risks, not only for the individual but also for others. Irresponsible behaviour or the commission of offences resulting from the misuse of alcohol or drugs may damage our reputation and, as a result, our business.
4. Employees who attend work having taken drugs or alcohol will be sent home and may be subject to disciplinary action.

   Scope and purpose of the policy

5. This policy is principally intended to deal with alcohol and drug problems which, in the context of this policy are any drinking or taking of drugs, whether intermittent or continual, which interferes with work performance in relation to attendance, efficiency, productivity or safety.
6. This policy applies equally to “one-off” incidents or offences caused by alcohol or drug misuse either at or outside work and evidence of an ongoing problem. Breaches of this policy will be dealt with under our Disciplinary Procedure.
7. The purpose of this policy is to increase awareness of the effects of alcohol and drug misuse and its likely symptoms and to ensure that:
   1. All staff are aware of their responsibilities regarding alcohol and drug misuse and related problems.
   2. Staff who have an alcohol or drug-related problem are encouraged to seek help, in confidence, at an early stage.
   3. Staff who have an alcohol or drug-related problem affecting their work are dealt with sympathetically, fairly and consistently.

   Personnel responsible for implementation of the policy

8. Managers have an important role to play in identifying problems at work that are being caused or contributed to by alcohol or drug misuse.
   1. Where a manager considers that a deterioration in work performance and/or changes in patterns of behaviour may be due to alcohol or drug misuse they should seek advice and assistance from the Human Resources Team or a Director.
   2. When a member of staff arrives at work and a manager reasonably believes that they are under the influence of alcohol or drugs, they shall immediately contact the Human Resources Team or a Director in order that an investigation can be undertaken.
9. If you notice a change in a colleague’s pattern of behaviour you should encourage them to seek assistance through their manager. If they will not seek help themselves you should draw the matter to the attention of your manager. You should not attempt to cover up for a colleague whose work or behaviour is suffering as a result of an alcohol or drug-related problem.
10. If you believe that you have an alcohol or drug-related problem you should seek specialist advice and support as soon as possible. If you don’t know how to find that support speak to the HR team who will be happy to help.

    Alcohol and drugs at work

11. We expect you to demonstrate responsible behaviour at work, work-related functions and work-related social events and to act in a way that will not have a detrimental effect on our reputation. If you entertain clients or represent us at external events where alcohol is served, you are considered to be “at work” regardless of whether you do so outside normal working hours. Consequently, we will expect you to remain professional and fit for work at all times.
    Managers should act to prevent excessive consumption of alcohol by any member of staff and should take steps to deal with any unacceptable conduct that occurs at work place functions. Any such behaviour may lead to action under our Disciplinary Procedure.
12. We reserve the right to require you to either not attend or to leave work premises if we reasonably suspect that you either are, or will turn up, under the influence or alcohol or other substances. Such absence will then be treated as unauthorised absence and dealt with under our Disciplinary Procedure.
13. We expect all our staff to comply with the drink/drug-driving legislation at all times. Our reputation will be damaged if you are convicted of a drink-driving offence and, if your job requires you to drive and you lose your licence, you may be unable to continue to do your job. Committing a drink-driving offence outside or during working hours or while working for us may lead to action under our Disciplinary Procedure and could result in dismissal.

Stress management policy

1. The Company is committed to protecting the health (mental health as well as physical health), safety and welfare of its employees by providing a supportive working environment. To enable individuals to cope successfully with the demands and pressures of work, reasonable and appropriate improvements to the working environment will be made and suitable support will be provided to those whose health and well-being are being affected by work-related stress.
2. It is the Company’s responsibility to provide a supportive environment for dealing with stress related issues; however, employees must take responsibility for raising their concerns as early as possible in order for the Company to investigate and resolve genuine problems.
3. This policy applies to all employees of the Company. It is non-contractual and does not form part of an employee’s terms and conditions of employment. The content may be subject to revision from time to time.
4. The Health and Safety Executive defines stress as “the adverse reaction people have to excessive pressure or other types of demand placed on them”. This makes an important distinction between pressure, which can be a positive state if managed correctly, and stress which can be detrimental to health. Pressure may arise from external factors or work or a combination of both. Every job has its own pressures and demands appropriate to the role.
5. Some pressure at work is inevitable and total elimination of this pressure is neither possible nor desirable. Every job brings its own set of tasks, responsibilities and day-to-day problems. The pressures and demands these place upon employees are an unavoidable feature in working life. Some pressure can be positive. It is often the tasks and challenges faced at work that provide the structure to the working day and keep individuals motivated. These are often key in providing a sense of achievement and job satisfaction. However, an individual’s ability to deal with pressure is not limitless and it is important that this pressure does not become sustained stress. It must be recognised that different people have different stress thresholds. Some of the most common causes of work-related stress are known to be excessive workloads, deadline pressures, aggressive management, poor communication, unsupportive work environment and problems maintaining work-life balance.
6. Outside domestic pressures, such as family, finance, and bereavement are also potential causes of stress and can frequently compound workplace pressure. These should also be taken into consideration where they are likely to have an impact on an individual at work.
   The Company maintains this Stress Management Policy to deal with the issue of stress in the workplace, whatever the cause. The policy is designed to assist staff affected by stress in a non-judgmental and supportive manner. The policy sets out the way in which the Company will meet its legal obligations to monitor workloads and stress in the workplace. The Company is committed to managing stress through active intervention where necessary by:
   1. Monitoring workloads;
   2. Active supervision of employees;
   3. Maintaining an ‘open door’ environment where employees can raise any concerns regarding stress or anxiety at any time.
7. Managers are responsible for the implementation of the policy and the Company is responsible for providing the necessary resources.
8. To enable individuals to cope successfully with the demands and pressures of work, reasonable and appropriate improvements to the working environment will be made and suitable support will be provided to those whose health and well-being are being affected by work-related stress, where possible.
9. Employees who have concerns should raise these with their Manager or the Managing Director as early as possible in order for the concerns to be investigated.
10. Stress is a person’s natural reaction to excessive pressure or demand placed on them. Stress in itself is not a disease but if it is excessive it can lead to mental and/or physical illness. Certain levels of pressure are acceptable and normal, helping individuals to meet the challenges that occur in everyday lives. To an extent it helps people perform well and reach their full potential. However, when demands and pressures become excessive and the challenges faced are beyond a person’s control, positive stress can become negative stress. Unacceptable stress generally builds up over a period of time and is often the result of negative factors, which are beyond control. These types of pressures can be harmful to individuals if sustained over a long period of time.
    

    Employees should consider the following self-help actions to help combat stress:

    • Talk to someone: It may be that you need to talk to someone e.g. a doctor/GP, occupational health advisor, specialist counsellor. If you require assistance, please contact a Director.
    • Take time to look at the situation: It is very easy to become so immersed in stressful situations that you cannot afford the time or the personal space to stand back and reappraise your objectives in life and your methods for achieving them. Are you in the right job? Do you have the right qualities for making it the success you want? Are your priorities right? Are you making space for your own interests and leisure?
    • Learn relaxation techniques: The art of relaxation not only includes relaxing at the end of the day, at the weekend or on holiday, but also involves being able to pause when you need to throughout the day.
    • Exercise: Maintain good habits, exercise regularly.
    • Diet: People under stress tend to over or under eat or slip into the habit of rushed inadequate meals. Under stress, the body uses up energy much more quickly than usual and a healthy diet is important.
    • Identify when you are stressed and report: It is the responsibility of each employee to seek assistance as early as possible if they consider they are manifesting symptoms of stress. Speak to your Manager or a Director to discuss the situation.
11. All Managers have a personal responsibility to ensure that the policy is consistently and appropriately implemented and to ensure that all individuals for whom they are responsible are aware that they have an obligation at all times to uphold and promote the policy.
12. Managers should provide a supportive environment in which employees can approach their Manager. The acceptance and recognition of stress as a genuine problem requires management support and action. Managers should tackle signs of stress whilst being aware of their limitations to deal with stress problems.
13. Managers are responsible for making sure that work does not make their employees ill. If a Manager notices that someone is particularly vulnerable because of their circumstances, they should look at how their work is organised and see if there are ways to relieve the pressures so that they do not become excessive. However, unless they know otherwise, they could assume that all their employees are mentally capable of withstanding reasonable pressure from work.

    Employees are expected to:

    1. Raise issues of concern with their Manager or a Director at the earliest opportunity;
    2. Accept opportunities for counselling when recommended; Take advantage of training and developmental opportunities offered;
    3. For those employees with an undefined working week, seek to manage their own working time in a way that does not create undue stress for themselves;
    4. Seek to take appropriate breaks during the working day and to take their annual leave entitlement supportively.

Data protection policy

1. Everyone has rights with regard to how their personal information is handled. During the course of our activities we will collect, store and process personal information about our staff, and we recognise the need to treat it in an appropriate and lawful manner.
2. The types of information that we may be required to handle include details of current, past and prospective employees, suppliers, customers and others that we communicate with. The information, which may be held on paper or on a computer or other media, is subject to certain legal safeguards specified in the Data Protection Act 2002 (the Act) and other regulations. The Act imposes restrictions on how we may use that information.

   Status of the policy

3. This part of our handbook sets out our rules on data protection and the legal conditions that must be satisfied in relation to the obtaining, handling, processing, storage, transportation and destruction of personal information.
4. The Money-Laundering Reporting Officer and the Human Resources Team are responsible for ensuring compliance with the Act and with this part of our handbook. Any questions or concerns about the operation of this part of our handbook should be referred in the first instance to Nicola Patterson.
5. If you consider that our provisions for complying with the Act have not been followed in respect of personal data about yourself or others you should raise the matter with your line manager immediately.

   Definition of data protection terms

6. Data is information which is stored electronically, on a computer, or in certain paper-based filing systems.
7. Data subjects for the purpose of this policy include all living individuals about whom we hold personal data. A data subject need not be a UK national or resident. All data subjects have legal rights in relation to their personal data.
8. Personal data means data relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal data can be factual (such as a name, address or date of birth) or it can be an opinion (such as a performance appraisal).
9. Data controllers are the people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed. They have a responsibility to establish practices and policies in line with the Act. We are the data controller of all personal data used in our business.
10. Data users include employees whose work involves using personal data. Data users have a duty to protect the information they handle by following our data protection and security policies at all times.
11. Data processors include any person who processes personal data on behalf of a data controller. Employees of data controllers are excluded from this definition but it could include suppliers which handle personal data on our behalf.
12. Processing is any activity that involves use of the data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.
13. Sensitive personal data includes information about a person’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. Sensitive personal data can only be processed under strict conditions, and will usually require the express consent of the person concerned.

    Data protection principles

14. Anyone processing personal data must comply with the eight enforceable principles of good practice. These provide that personal data must be:
    1. Processed fairly and lawfully.
    2. Processed for limited purposes and in an appropriate way.
    3. Adequate, relevant and not excessive for the purpose.
    4. Accurate.
    5. Not kept longer than necessary for the purpose.
    6. Processed in line with data subjects’ rights.
    7. Secure.
    8. Not transferred to people or organisations situated in countries without adequate protection.

    Fair and lawful processing

15. The Act is intended not to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the data subject. The data subject must be told who the data controller is (in this case Plan Communications Limited, who the data controller’s representative is (in this case the Money-Laundering Reporting Officer, the purpose for which the data is to be processed by us, and the identities of anyone to whom the data may be disclosed or transferred.
16. For personal data to be processed lawfully, certain conditions have to be met. These may include, among other things, requirements that the data subject has consented to the processing, or that the processing is necessary for the legitimate interest of the data controller or the party to whom the data is disclosed. When sensitive personal data is being processed, more than one condition must be met. In most cases the data subject’s explicit consent to the processing of such data will be required.
17. Processing for limited purposes – Personal data may only be processed for the specific purposes notified to the data subject when the data was first collected or for any other purposes specifically permitted by the Act. This means that personal data must not be collected for one purpose and then used for another. If it becomes necessary to change the purpose for which the data is processed, the data subject must be informed of the new purpose before any processing occurs.
18. Adequate, relevant and non-excessive processing – Personal data should only be collected to the extent that it is required for the specific purpose notified to the data subject. Any data which is not necessary for that purpose should not be collected in the first place.
19. Accurate data – Personal data must be accurate and kept up to date. Information which is incorrect or misleading is not accurate and steps should therefore be taken to check the accuracy of any personal data at the point of collection and at regular intervals afterwards. Inaccurate or out-of-date data should be destroyed.
20. Timely processing – Personal data should not be kept longer than is necessary for the purpose. This means that data should be destroyed or erased from our systems when it is no longer required.
21. Processing in line with data subject’s rights – Data must be processed in line with data subjects’ rights. Data subjects have a right to:
    1. Request access to any data held about them by a data controller.
    2. Prevent the processing of their data for direct-marketing purposes.
    3. Ask to have inaccurate data amended.
    4. Prevent processing that is likely to cause damage or distress to themselves or anyone else.
22. Information/Data security We must ensure that appropriate security measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data. Data subjects may apply to the courts for compensation if they have suffered damage from such a loss.
23. We have introduced a process that will enable us to monitor the appropriate handling of information and data across our business. This process is audited by an external body every 2 years. Maintaining high standards of information security is a requirement of every employee and our adherence to these standards will be measured against the ISO 270001 (an international standard required by most responsible businesses and also some of our partners).
24. The Act requires us to put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. Personal data may only be transferred to a third-party data processor if he agrees to comply with those procedures and policies, or if he puts in place adequate measures himself.
25. Maintaining data security means guaranteeing the confidentiality, integrity and availability of the personal data, defined as follows:
    1. Confidentiality means that only people who are authorised to use the data can access it.
    2. Integrity means that personal data should be accurate and suitable for the purpose for which it is processed.
    3. Availability means that authorised users should be able to access the data if they need it for authorised purposes. Personal data should therefore be stored on our central computer system instead of individual PCs.
26. Security procedures include:
    1. Entry controls. Any stranger seen in entry-controlled areas should be reported.
    2. Secure lockable desks and cupboards. Desks and cupboards should be kept locked if they hold confidential information of any kind. (Personal information is always considered confidential.)
    3. Methods of disposal. Paper documents should be shredded. Floppy disks and CD-ROMs should be physically destroyed when they are no longer required.
    4. Equipment. Data users should ensure that individual monitors do not show confidential information to passers-by and that they log off from their PC when it is left unattended.
27. Dealing with subject access requests – A formal request from a data subject for information that we hold about them must be made in writing. A fee is payable by the data subject for provision of this information. Any member of staff who receives a written request should forward it to their manager immediately.
28. Providing information over the telephone – Any member of staff dealing with telephone enquiries should be careful about disclosing any personal information held by us. In particular they should:
    1. Check the caller’s identity to make sure that information is only given to a person who is entitled to it.
    2. Suggest that the caller put their request in writing if they are not sure about the caller’s identity and where their identity cannot be checked.
    3. Refer to their line manager for assistance in difficult situations. No-one should be bullied into disclosing personal information.

Information and communications systems policy

1. Our electronic communications systems and equipment are intended to promote effective communication and working practices within our organisation, and are critical to the success of our business. This part of our handbook deals mainly with the use (and misuse) of computer equipment, e-mail, the internet, telephones, Blackberries, personal digital assistants (PDAs) and voicemail, but it applies equally to the use of fax machines, copiers, scanners, CCTV, and electronic key fobs and cards. It outlines the standards we require users of these systems to observe, the circumstances in which we will monitor use of these systems and the action we will take in respect of breaches of these standards.
2. All staff are expected to protect our electronic communications systems and equipment from unauthorised access and harm at all times. Failure to do so may be dealt with under our Disciplinary Procedure and, in serious cases, may be treated as gross misconduct leading to summary dismissal.

   Equipment security and passwords

3. Staff are responsible for the security of the equipment allocated to or used by them, and must not allow it to be used by anyone other than as permitted by this handbook.
4. If given access to the e-mail system or to the internet, staff are responsible for the security of their terminals. If leaving a terminal unattended or on leaving the office they should ensure that they lock their terminal or log off to prevent unauthorised users accessing the system in their absence. Staff without authorisation should only be allowed to use terminals under supervision.
5. Desktop PCs and cabling for telephones or computer equipment should not be moved or tampered with without first consulting your line manager or supervisor or the IT Department.
6. Passwords are unique to each user and must be changed regularly to ensure confidentiality. Passwords must be kept confidential and must not be made available to anyone else unless authorised by the IT Department. For the avoidance of doubt, on the termination of employment (for any reason) staff must provide details of their passwords to the IT Department and return any equipment, key fobs or cards to their line manager, supervisor or the IT Department.
7. Staff who have been issued with a laptop, PDA or Blackberry must ensure that it is kept secure at all times, especially when travelling. Passwords must be used to secure access to data kept on such equipment to ensure that confidential data is protected in the event of loss or theft. Staff should also be aware that when using equipment away from the workplace, documents may be read by third parties, for example, passengers on public transport.

   Systems and data security

8. Staff should not delete, destroy or modify existing systems, programs, information or data, which could have the effect of harming our business or exposing it to risk.
9. Staff should not download or install software from external sources without authorisation from the IT Department. This includes software programs, instant messaging programs, screensavers, photos, video clips and music files. Incoming files and data should always be virus-checked by the IT Department before they are downloaded.
10. You are not permitted to access the following from the company’s network: online radio, audio and video streaming, instant messaging and webmail (such as Hotmail or Yahoo) and social networking sites (such as Facebook, YouTube, Twitter). This list may be modified from time to time. You are permitted to make reasonable use of professional networking sites (such as LinkedIn) provided that it does not distract you from your ability to work.
11. No device or equipment should be attached to our systems without the prior approval of the IT department. This includes any USB flash drive, MP3 or similar device, PDA or telephone. It also includes use of the USB port, infra-red connection port or any other port.
12. We monitor all e-mails passing through our system for viruses. Workers should exercise caution when opening e-mails from unknown external sources or where, for any reason, an e-mail appears suspicious (for example, if its name ends in .ex). The IT Department should be informed immediately if a suspected virus is received. We reserve the right to block access to attachments to e-mails for the purpose of effective use of the system and for compliance with this part of our handbook. We also reserve the right not to transmit any e-mail message.
13. Staff should not attempt to gain access to restricted areas of the network, or to any password-protected information, unless specifically authorised.
14. Staff using laptops or wi-fi enabled equipment must be particularly vigilant about its use outside the office and take any precautions required by the IT Department from time to time against importing viruses or compromising the security of the system. The system contains information which is confidential to our business and/or which is subject to data protection legislation. Such information must be treated with extreme care and in accordance with our Data Protection Policy.

    E-mail etiquette and content

15. E-mail is a vital business tool, but an informal means of communication, and should be used with great care and discipline. Staff should always consider if e-mail is the appropriate means for a particular communication and correspondence sent by e-mail should be written as professionally as a letter or fax. Messages should be concise and directed only to relevant individuals. Our standard disclaimer and your approved email signature should always be included. Hard copies of e-mails should be kept on the appropriate file.
16. Staff should ensure that they access their e-mails at least once every working day, stay in touch by remote access when travelling and use an out of office response when away from the office for more than a day. They should endeavour to respond to e-mails marked “high priority” within 24 hours.
17. Staff should not send abusive, obscene, discriminatory, racist, harassing, derogatory or defamatory e-mails. Anyone who feels that they have been harassed or bullied, or are offended by material received from a colleague via e-mail should inform their line manager.
18. Staff should take care with the content of e-mail messages, as incorrect or improper statements can give rise to claims for discrimination, harassment, defamation, breach of confidentiality or breach of contract. Staff should assume that e-mail messages may be read by others and not include anything which would offend or embarrass any reader, or themselves, if it found its way into the public domain.
19. E-mail messages may be disclosed in legal proceedings in the same way as paper documents. Deletion from a user’s inbox or archives does not mean that an e-mail cannot be recovered for the purposes of disclosure. All e-mail messages should be treated as potentially retrievable, either from the main server or using specialist software.
20. In general, staff should not:
    1. send or forward private e-mails at work which they would not want a third party to read;
    2. send or forward chain mail, junk mail, cartoons, jokes or gossip;
    3. contribute to system congestion by sending trivial messages or unnecessarily copying or forwarding e-mails to those who do not have a real need to receive them;
    4. sell or advertise using our communication systems or broadcast messages about lost property, sponsorship or charitable appeals;
    5. agree to terms, enter into contractual commitments or make representations by e-mail unless appropriate authority has been obtained. A name typed at the end of an e-mail is a signature in the same way as a name written at the end of a letter;
    6. download or e-mail text, music and other content on the internet subject to copyright protection, unless it is clear that the owner of such works allows this;
    7. upload or introduce external content to the network, whether by e-mail, USB flash drive or similar device or means without prior approval from your supervisor, line manager or the IT Department;
    8. send messages from another worker’s computer or under an assumed name unless specifically authorised; or
    9. send confidential messages via e-mail or the internet, or by other means of external communication which are known not to be secure.
21. Staff who receive a wrongly-delivered e-mail should return it to the sender. If the e-mail contains confidential information or inappropriate material (as described above) it should not be disclosed or used in any way.

    Use of the internet

22. When a website is visited, devices such as cookies, tags or web beacons may be employed to enable the site owner to identify and monitor visitors. If the website is of a kind described in paragraph 34.31, such a marker could be a source of embarrassment to the visitor and us, especially if inappropriate material has been accessed, downloaded, stored or forwarded from the website. Such actions may also, in certain circumstances, amount to a criminal offence if, for example, the material is pornographic in nature. This is further considered in paragraph 34.30 to paragraph 34.32.
23. Staff should therefore not access any web page or any files (whether documents, images or other) downloaded from the internet which could, in any way, be regarded as illegal, offensive, in bad taste or immoral. While content may be legal in the UK, it may be in sufficient bad taste to fall within this prohibition. As a general rule, if any person (whether intended to view the page or not) might be offended by the contents of a page, or if the fact that our software has accessed the page or file might be a source of embarrassment if made public, then viewing it will be a breach of our Information and Communications Systems Policy.
24. Staff should not under any circumstances use our systems to participate in any internet chat room, post messages on any internet message board or set up or log text or information on a blog or wiki, even in their own time.

    Personal use of systems

25. We permit the incidental use of internet, e-mail and telephone systems to send personal e-mail, browse the internet and make personal telephone calls subject to certain conditions set out below. Personal use is a privilege and not a right. It must be neither abused nor overused and we reserve the right to withdraw our permission at any time.
26. The following conditions must be met for personal usage to continue:
    1. 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);
    2. personal e-mails must be labelled “personal” in the subject header;
    3. use must not interfere with business or office commitments;
    4. use must not commit us to any marginal costs; and
    5. use must comply with the policies set out in this handbook including the Equal Opportunities Policy, Anti-harassment Policy, Data Protection Policy and Disciplinary Procedure.
27. Staff should be aware that personal use of our systems may be monitored (see paragraph 34.28 to paragraph 34.29) and, where breaches are found, action may be taken under the disciplinary procedure (see paragraph 34.30 to paragraph 34.32). We reserve the right to restrict or prevent access to certain telephone numbers or internet sites if we consider personal use to be excessive.

    Monitoring of use of systems

28. Our systems enable us to monitor telephone, e-mail, voicemail, internet and other communications. For business reasons, and in order to carry out legal obligations in our role as an employer, use of our systems including the telephone and computer systems, and any personal use of them, is continually monitored. Monitoring is only carried out to the extent permitted or as required by law and as necessary and justifiable for business purposes.
29. We reserve the right to retrieve the contents of messages or check searches which have been made on the internet for the following purposes (this list is not exhaustive):
    1. to monitor whether the use of the e-mail system or the internet is legitimate;
    2. to find lost messages or to retrieve messages lost due to computer failure;
    3. to assist in the investigation of wrongful acts; or
    4. to comply with any legal obligation.

    Inappropriate use of equipment and systems

30. Access is granted to the internet, telephones and other electronic systems for legitimate business purposes only. Incidental personal use is permissible provided it is in full compliance with our rules, policies and procedures (including this policy, the Equal Opportunities Policy, Anti-harassment Policy, Data Protection Policy and Disciplinary Procedure).
31. Misuse or excessive use or abuse of our telephone or e-mail system, or inappropriate use of the internet in breach of this policy will be dealt with under our Disciplinary Procedure. Misuse of the internet can, in certain circumstances, constitute a criminal offence. In particular, misuse of the e-mail system or inappropriate use of the internet by participating in online gambling or chain letters or by creating, viewing, accessing, transmitting or downloading any of the following material will amount to gross misconduct (this list is not exhaustive):
    1. pornographic material (that is, writing, pictures, films and video clips of a sexually explicit or arousing nature);
    2. offensive, obscene, or criminal material or material which is liable to cause embarrassment to us or to our clients;
    3. a false and defamatory statement about any person or organisation;
    4. material which is discriminatory, offensive, derogatory or may cause embarrassment to others;
    5. confidential information about us or any of our staff or clients (which you do not have authority to access);
    6. any other statement which is likely to create any liability (whether criminal or civil, and whether for you or us); or
    7. material in breach of copyright.
       

       Any such action will be treated very seriously and is likely to result in summary dismissal.

32. Where evidence of misuse is found we may undertake a more detailed investigation in accordance with our Disciplinary Procedure, involving the examination and disclosure of monitoring records to those nominated to undertake the investigation and any witnesses or managers involved in our Disciplinary Procedure. If necessary such information may be handed to the police in connection with a criminal investigation.

Social media policy

1. We recognise that the internet provides unique opportunities to participate in interactive discussions and share information on particular topics using a wide variety of social media, such as Facebook, Twitter, blogs and wikis. However, employees’ use of social media can pose risks to our confidential and proprietary information, and reputation, and can jeopardise our compliance with legal obligations.
2. To minimise these risks, to avoid loss of productivity and to ensure that our IT resources and communications systems are used only for appropriate business purposes, we expect employees to adhere to this policy.

   Scope and purpose of the policy

3. This policy deals with the use of all forms of social media, including Facebook, LinkedIn, Twitter, Wikipedia, all other social networking sites, and all other internet postings, including blogs.
4. It applies to the use of social media for both business and personal purposes, whether during office hours or otherwise. The policy applies regardless of whether the social media is accessed using our IT facilities and equipment or equipment belonging to members of staff.
5. Breach of this policy may result in disciplinary action up to and including dismissal. Disciplinary action may be taken regardless of whether the breach is committed during working hours, and regardless of whether our equipment or facilities are used for the purpose of committing the breach. Any member of staff suspected of committing a breach of this policy will be required to co-operate with our investigation, which may involve handing over relevant passwords and login details.
6. Staff may be required to remove internet postings which are deemed to constitute a breach of this policy. Failure to comply with such a request may in itself result in disciplinary action.

   Personnel responsible for implementing the policy

7. The IT Department and Marketing Department have overall responsibility for the effective operation of this policy. Questions regarding the content or application of this policy should be directed to the IT Department or the Marketing Department.
8. All managers have a specific responsibility for operating within the boundaries of this policy, ensuring that all staff understand the standards of behaviour expected of them and taking action when behaviour falls below its requirements.
9. All staff are responsible for the success of this policy and should ensure that they take the time to read and understand it. Any misuse of social media should be reported to the IT Department or the Marketing Department.

   Compliance with related policies and agreements

10. Social media should never be used in a way that breaches any of our other policies. If an internet post would breach any of our policies in another forum, it will also breach them in an online forum. For example, employees are prohibited from using social media to:
    1. breach our Information and Communications Systems Policy;
    2. breach our obligations with respect to the rules of relevant regulatory bodies;
    3. breach any obligations they may have relating to confidentiality;
    4. breach our Disciplinary Rules;
    5. defame or disparage the organisation or its affiliates, customers, clients, business partners, suppliers, vendors or other stakeholders;
    6. breach our Anti-harassment and Bullying Policy;
    7. breach our Equal Opportunities Policy;
    8. breach our Data Protection Policy (for example, never disclose personal information about a colleague online);
    9. breach any other laws or ethical standards (for example, never use social media in a false or misleading way, such as by claiming to be someone other than yourself or by making misleading statements).
11. Staff should never provide references for other individuals on social or professional networking sites, as such references, positive and negative, can be attributed to the organisation and create legal liability for both the author of the reference and the organisation.
12. Employees who breach any of the above policies will be subject to disciplinary action up to and including termination of employment.
13. Personal use of social media – Personal use of social media is never permitted during working time or by means of our computers, networks and other IT resources and communications systems.

    Monitoring

14. The contents of our IT resources and communications systems are our property. Therefore, staff should have no expectation of privacy in any message, files, data, document, facsimile, telephone conversation, social media post conversation or message, or any other kind of information or communications transmitted to, received or printed from, or stored or recorded on our electronic information and communications systems.
15. We reserve the right to monitor, intercept and review, without further notice, staff activities on social media, , including but not limited to postings and activities, to ensure that our rules are being complied with and for legitimate business purposes (such as monitoring staff absence) and you consent to such monitoring and your use of such resources and systems whether or not such postings or activities occurred through the use of our IT resources and communications systems. This might include, without limitation, the monitoring, interception, accessing, recording, disclosing, inspecting, reviewing, retrieving and printing of transactions, messages, communications, postings, log-ins, images, recordings and other uses of the systems as well as keystroke capturing and other network monitoring technologies.
16. We may store copies of such data or communications for a period of time after they are created, and may delete such copies from time to time without notice.
17. Do not use our IT resources and communications systems for any matter that you wish to be kept private or confidential from the organisation.
18. For further information, please refer to our Information and Communications Systems Policy.

    Business use of social media

19. If your duties require you to speak on behalf of the organisation in a social media environment, you must still seek approval for such communication from your manager, who may impose certain requirements and restrictions with regard to your activities.
20. Likewise, if you are contacted for comments about the organisation for publication anywhere, including in any social media outlet, direct the inquiry to the Marketing Department and do not respond without written approval.
21. The use of social media for business purposes is subject to the remainder of this policy.

    Recruitment

22. We may use internet searches to source and acquire top talent. Where we do this, we will act in accordance with our data protection and equal opportunities obligations.
23. We reserve the right to require you to amend any social media activity that indicates that you are involved with us in any capacity that is in any way inaccurate, damaging to our reputation or misleading.

    Responsible use of social media

24. The following sections of the policy provide staff with common-sense guidelines and recommendations for using social media responsibly and safely.
25. We reserve the right to ask you to amend any social media activity by you that is in any way inconsistent with the guidelines set out below. Failure to do so may be treated as misconduct and dealt with under our Disciplinary Procedure.
26. Protecting our business reputation:
    1. Staff must not post disparaging or defamatory statements about:
       1. our organisation (including our staff);
       2. our clients;
       3. suppliers and vendors; and
       4. other affiliates and stakeholders,
          

          but staff should also avoid social media communications that might be misconstrued in a way that could damage our business reputation, even indirectly.

    2. Staff should make it clear in social media postings that they are speaking on their own behalf. Write in the first person and use a personal e-mail address when communicating via social media.
    3. Staff are personally responsible for what they communicate in social media. Remember that what you publish might be available to be read by the masses (including the organisation itself, future employers and social acquaintances) for a long time. Keep this in mind before you post content.
    4. If you disclose your affiliation as an employee of our organisation, you must also state that your views do not represent those of your employer. For example, you could state, “the views in this posting do not represent the views of my employer”. You should also ensure that your profile and any content you post are consistent with the professional image you present to clients and colleagues.
    5. Avoid posting comments about sensitive business-related topics, such as our performance. Even if you make it clear that your views on such topics do not represent those of the organisation, your comments could still damage our reputation.
    6. If you are uncertain or concerned about the appropriateness of any statement or posting, refrain from making the communication until you discuss it with your manager.
    7. If you see content in social media that disparages or reflects poorly on our organisation or our stakeholders, you should contact your manager. All staff are responsible for protecting our business reputation.
27. Respecting intellectual property and confidential information:
    1. Staff should not do anything to jeopardise our valuable trade secrets and other confidential information and intellectual property through the use of social media.
    2. In addition, staff should avoid misappropriating or infringing the intellectual property of other companies and individuals, which can create liability for the organisation, as well as the individual author.
    3. Do not use our logos, brand names, slogans or other trademarks, or post any of our confidential or proprietary information without prior written permission.
    4. To protect yourself and the organisation against liability for copyright infringement, where appropriate, reference sources of particular information you post or upload and cite them accurately. If you have any questions about whether a particular post or upload might violate anyone’s copyright or trademark, ask the IT Department or the Marketing Department before making the communication.
28. Respecting colleagues, clients, partners and suppliers:
    1. Do not post anything that your colleagues or our customers, clients, business partners, suppliers, vendors or other stakeholders would find offensive, including discriminatory comments, insults or obscenity.
    2. Do not post anything related to your colleagues or our customers, clients, business partners, suppliers, vendors or other stakeholders without their written permission.

Redundancy policy

1. It is our intention to manage our business in a manner which results in secure employment for our employees. We will always try to avoid the need for compulsory redundancies but sometimes these may be necessary. The pattern or volume of our business or methods of working may change and requirements for employees may reduce.

   The purpose of the policy

2. The purpose of this policy is to ensure that, whenever reduction in employee numbers may become necessary:
   1. we communicate clearly with all affected employees and ensure that they are treated fairly;
   2. we try to find ways of avoiding compulsory redundancies;
   3. we consult with employees; and
   4. any selection for compulsory redundancy is undertaken fairly and reasonably.

   Avoiding compulsory redundancies

3. Where we are proposing to make redundancies we will enter into consultation with all affected employees on an individual basis.
4. In the first instance we will consider steps that might, depending on the circumstances, be taken to avoid the need for compulsory redundancies. Examples of such steps include:
   1. Reviewing the use of agency staff, self-employed contractors and consultants.
   2. Restricting recruitment in affected categories of employee and in those areas into which affected employees might be redeployed.
   3. Reducing overtime in affected departments to that needed to meet contractual commitments or provide essential services.
   4. Freezing salaries for a specified period.
   5. Considering the introduction of short-time working, job-sharing or other flexible working arrangements, where these are practicable.
   6. Identifying suitable alternative work with us or with any other companies within the Group that might be offered to potentially redundant employees.
   7. Inviting applications for early retirement or voluntary redundancy. In all cases the acceptance of a volunteer for redundancy will be a matter of our discretion and we reserve the right not to offer voluntary redundancy terms or to refuse an application where it is not in the interests of our business to do so.
5. Any measures adopted must not adversely affect our business and our ability to serve our customers.

   Making compulsory redundancies

6. When it is not possible to avoid making compulsory redundancies, all affected employees will be advised that compulsory redundancies cannot be avoided. They will be consulted on the procedure that will then be followed and the criteria that will be applied.
7. In every situation, the company will follow the legislative requirements of either the Isle of Man or the UK as appropriate.
8. The criteria used to select those employees who will potentially be made redundant will be objective, transparent and fair and based on the skills required to meet our existing and anticipated business needs.
9. Those employees who have been provisionally selected for redundancy will be consulted with individually.
10. Where selection for redundancy is confirmed, employees selected for redundancy will be given notice of termination of employment in accordance with their contracts and written confirmation of the payments that they will receive. Employees will be given the opportunity to appeal against this decision.
11. We will continue to look for alternative employment for redundant employees and inform them of any vacancies that we have until their termination dates. The manner in which redundant employees will be invited to apply for and be interviewed for vacancies will be organised depending on the circumstances existing at the time. Alternative employment may be offered subject to a trial period where appropriate.
12. Where we are unable to offer alternative employment we will assist employees look for work with other employers. Employees under notice of redundancy may be entitled to take a reasonable amount of paid time off work to look for alternative employment or to arrange training for future employment.