A) INTRODUCTION
Bribery is a criminal offence. The Company prohibits any form of bribery. We require compliance, from everyone connected with our business, with the highest ethical standards and anti-bribery laws applicable. Integrity and transparency are of utmost importance to us and we have a zero tolerance attitude towards corrupt activities of any kind, whether committed by employees or by third parties acting for or on behalf of the Company.
B) POLICY
It is prohibited, directly or indirectly, for any employee or person working on our behalf to offer, give, request or accept any bribe i.e. gift, loan, payment, reward or advantage, either in cash or any other form of inducement, to or from any person or Company in order to gain commercial, contractual or regulatory advantage for the Company, or in order to gain any personal advantage for
an individual or anyone connected with the individual in a way that is unethical.
C) SUSPICION
If we suspect that you have committed an act of bribery or attempted bribery, an investigation will
be carried out and, in line with our disciplinary procedure where appropriate, action may be taken against you which may result in your dismissal, or the cessation of our business arrangement with you.
D) REPORTING
If you, as an employee or person working on our behalf, suspect that an act of bribery or attempted bribery has taken place, even if you are not personally involved, you are expected to report this to
a Director. You may be asked to give a written account of events.
Staff are reminded of the Company’s Whistleblowing Policy which is available in this Employee Handbook.
E) GIFTS AND HOSPITALITY
We realise that the giving and receiving of gifts and hospitality as a reflection of friendship or appreciation where nothing is expected in return may occur, or even be commonplace, in our industry. This does not constitute bribery where it is proportionate and recorded properly.
No gift should be given nor hospitality offered by an employee or anyone working on our behalf to any party in connection with our business without receiving prior written approval from a Director.
Similarly, no gift or offer of hospitality should be accepted by an employee or anyone working on our behalf without receiving prior written approval from a Director.
F) RECORD KEEPING
A record will be made by a Director of every instance in which gifts or hospitality are given or received.
As the law is constantly changing, this policy is subject to review and the Company reserves the right to amend this policy without prior notice.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, agents, contractors and suppliers. Staff4you Ltd strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains.
We expect that our suppliers will hold their own suppliers to the same high standards.
Commitments:
We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:
We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationships.
INTRODUCTION
We are an equal opportunities employer. We are committed to equality of opportunity and to providing a service and following practices which are free from unfair and unlawful discrimination. The aim of this policy is to ensure that no applicant or member of staff receives less favorable treatment on the grounds of age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation, or is disadvantaged by conditions or requirements which cannot be shown to be relevant to performance. It seeks also to ensure that no person is victimized or subjected to any form of bullying or harassment.
We value people as individuals with diverse opinions, cultures, lifestyles and circumstances. All employees are covered by this policy and it applies to all areas of employment including recruitment, selection, training, deployment, career development, and promotion. These areas are monitored and policies and practices are amended if necessary to ensure that no unfair or unlawful discrimination, intentional, unintentional, direct or indirect, overt or latent exists.
The compliance manager has particular responsibility for implementing and monitoring the Equality and Diversity in Employment Policy and, as part of this process, all personnel policies and procedures are administered with the objective of promoting equality of opportunity and eliminating unfair or unlawful discrimination.
All employees, workers or self-employed contractors whether part time, full time or temporary, will be treated fairly and with respect. Selection for employment, promotion, training, or any other benefit will be on the basis of aptitude and ability. All employees will be helped and encouraged to develop their full potential and the talents and resources of the workforce will be fully utilised to maximise the efficiency of the Company.
Equality of opportunity, valuing diversity and compliance with the law is to the benefit of all individuals in our Company as it seeks to develop the skills and abilities of its people. While specific responsibility for eliminating discrimination and providing equality of opportunity lies with managers and supervisors, individuals at all levels have a responsibility to treat others with dignity and respect. The personal commitment of every employee to this policy and application of its principles are essential to eliminate discrimination and provide equality throughout the Company.
OUR COMMITMENT AS AN EMPLOYER
1. To create an environment in which individual differences and the contributions of our staff are recognised and valued.
2. Every employee, worker or self-employed contractor is entitled to a working environment that promotes dignity and respect to all. No form of intimidation, bullying or harassment will be tolerated.
3. Training, development and progression opportunities are available to all staff.
4. Equality in the workplace is good management practice and makes sound business sense.
5. We will review all our employment practices and procedures to ensure fairness.
OUR COMMITMENT AS A SERVICE PROVIDER
1. We aim to provide services to which all clients are entitled regardless of age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation, offending past, caring responsibilities or social class
2. We will make sure that our services are delivered equally and meet the diverse needs of our service users and clients by assessing and meeting the diverse needs of our clients.
3. This policy is fully supported by senior management and has been agreed with employee representatives.
4. This policy will be monitored and reviewed annually.
5. We have clear procedures that enable our clients, candidates for jobs and employees to raise a grievance or make a complaint if they feel they have been unfairly treated.
6. Breaches of our equality and diversity policy will be regarded as misconduct and could lead to disciplinary proceedings.
EQUAL OPPORTUNITY POLICY STATEMENTS
AGE
We will:
ensure that people of all ages are treated with respect and dignity;
ensure that people of working age are given equal access to our employment, training, development and promotion opportunities; and
challenge discriminatory assumptions about younger and older people.
DISABILITY
We will:
provide any reasonable adjustments to ensure disabled people have access to our services and employment opportunities;
challenge discriminatory assumptions about disabled people; and
seek to continue to improve access to information by ensuring availability of loop systems, braille facilities, alternative formatting and sign language interpretation.
RACE
We will:
challenge racism wherever it occurs;
respond swiftly and sensitively to racists incidents; and
actively promote race equality in the Company.
GENDER
We will:
challenge discriminatory assumptions about women and men;
take positive action to redress the negative effects of discrimination against women and men;
offer equal access for women and men to representation, services, employment, training and pay and encourage other organisations to do the same; and
provide support to prevent discrimination against transsexual people who have or who are about to undergo gender reassignment.
SEXUAL ORIENTATION
We will:
ensure that we take account of the needs of lesbians, gay men and bisexuals; and
promote positive images of lesbians, gay men and bisexuals.
RELIGION OR BELIEF
We will:
ensure that employees’ religion or beliefs and related observances are respected and accommodated wherever possible; and
respect people’s beliefs where the expression of those beliefs does not impinge on the legitimate rights of others.
PREGNANCY OR MATERNITY
We will:
ensure that people are treated with respect and dignity and that a positive image is promoted regardless of pregnancy or maternity;
challenge discriminatory assumptions about the pregnancy or maternity of our employees; and
ensure that no individual is disadvantaged and that we take account of the needs of our employees’ pregnancy or maternity.
MARRIAGE OR CIVIL PARTNERSHIP
We will:
ensure that people are treated with respect and dignity and that a positive image is promoted regardless of marriage or civil partnership;
challenge discriminatory assumptions about the marriage or civil partnership of our employees; and
ensure that no individual is disadvantaged and that we take account the needs of our employees’ marriage or civil partnership.
EX-OFFENDERS
We will:
prevent discrimination against our employees regardless of their offending background (except where there is a known risk to children or vulnerable adults).
EQUAL PAY
We will:
ensure that all employees, male or female, have the right to the same contractual pay and benefits for carrying out the same work, work rated as equivalent work or work of equal value.
To whom it may concern
We confirm that our business is committed to preventing modern slavery both within our business and its supply chains. We understand that modern slavery refers to the illegal practices of slavery, servitude, forced or compulsory labour and human trafficking.
We confirm that we are taking the steps below to prevent slavery within our business and supply chains:
We have a robust Right to Work check process, including age verification
NI number and bank details also subject to checks
Interviews are always conducted 1-1
All staff trained to made aware of modern slavery and told of helpline number
References taken prior to offering work
Successful applicants provided with a clear contract of employment
System would highlight multiple residents at a single address
All our processes are subject to internal auditing
We understand that we may be audited at any time and compliance with modern slavery commitments is essential to the relationship we have with your company.
Yours faithfully,
Marius Birjovanu
Managing Director
Staff4you Ltd
Key Points
The Whistleblowing Procedure sets out the framework for dealing with allegations of illegal and improper conduct.
Staff4you Ltd is committed to the highest standards of transparency, probity, integrity and accountability.
This procedure is intended to provide a means of making serious allegations about standards, conduct, financial irregularity or possible unlawful action in a way that will ensure confidentiality and protect those making such allegations in the reasonable belief that it is in the public interest to do so from being victimised, discriminated against or disadvantaged.
This procedure does not replace other policies and procedures such as the complaints procedure, the Grievance and Harassment and Bullying Policies and other specifically laid down statutory reporting procedures.
This procedure is intended to ensure that Staff4you Ltd complies with its duty under the Public Interest Disclosure Act 1998.
Scope
This procedure applies to all Staff4you Ltd employees, including Associates and contractors.
This procedure does not replace other Staff4you Ltd policies or procedures. For example, if an employee has a grievance about their working conditions they should use the Staff4you Ltd Grievance Policy or, if they felt that their manager or a colleague was treating them unfavourably, they should use the Staff4you Ltd Harassment and Bullying Policy. Similarly if an employee has a concern about the conduct of a fellow employee in the working environment (e.g. that they are not treating colleagues with respect) they should raise these with their line manager, or if that is not possible, with the CEO, Treasurer of Trustees or through the Charity Commission’s whistle blowing policy whistleblowing@charitycommission.gsi.gov.uk
This procedure applies to, but is not limited to, allegations about any of the following:
Conduct which is an offence or breach of the law
Alleged miscarriage of justice
Serious Health and Safety risks
The unauthorised use of public funds
Possible fraud and corruption · Sexual, physical or verbal abuse, or bullying or intimidation of employees, customers or service users
Abuse of authority
Other unethical conduct
Reporting
Contact Details for Reporting: (in writing) Staff4you Ltd
Staff4you Ltd recognises that the decision to make an allegation can be a difficult one to make. However, whistleblowers who make serious allegations in the reasonable belief that it is in the public interest to do so have nothing to fear because they are doing their duty either to Staff4you Ltd and/or to those for whom Staff4you Ltd or they are providing a service.
Staff4you Ltd will take appropriate action to protect a whistleblower who makes a serious allegation in the reasonable belief that it is in the public interest to do so from any reprisals, harassment or victimisation.
Confidentiality
All allegations will be treated in confidence and every effort will be made not to reveal a whistleblower’s identity unless the whistleblower otherwise requests. However, if the matter is subsequently dealt with through other Staff4you Ltd procedures such as the Disciplinary Procedure.
Similarly, if the allegation results in court proceedings then the whistleblower may have to give evidence in open court if the case is to be successful.
Staff4you Ltd will not, without the whistleblower’s consent, disclose the identity of a whistleblower to anyone other than a person involved in the investigation/allegation.
Anonymous Allegations
This procedure encourages whistleblowers to put their name to an allegation wherever possible as anonymous allegations may often be difficult to substantiate/prove. Allegations made anonymously are much less powerful but anonymous allegations will be considered at the discretion of the CEO/Treasurer Trustee.
In exercising discretion to accept an anonymous allegation the factors to be taken into account:
The seriousness of the issue raised
The credibility of the allegation; and
Whether the allegation can realistically be investigated from factors or sources other than the complainant
Untrue Allegations
No disciplinary or other action will be taken against a whistleblower who makes an allegation in the reasonable belief that it is in the public interest to do so even if the allegation is not substantiated by an investigation. However, disciplinary action may be taken against a whistleblower who makes an allegation without reasonable belief that it is in the public interest to do so (e.g. making an allegation frivolously, maliciously or for personal gain where there is no element of public interest).
Procedure for Making an Allegation
It is preferable for allegations to be made to an employee’s immediate manager to whom they report. However, this may depend on the seriousness and sensitivity of the issues involved and who is suspected of the malpractice. For example, if the whistleblower believes that management is involved it would be inappropriate to raise it directly with them. The whistleblower may then make an allegation direct to any of the following:
The CEO
Treasurer Trustee
If either of the above receive an allegation he/she will consider the allegation and may discuss with either the CEO or other Trustees. The line manager (or either/or both) of the above, after consideration, will discuss with the whistleblower and if they wish to proceed with the allegation will be investigated.
Allegation
Whether a written or oral report is made it is important that relevant information is provided including:
The name of the person making the allegation and a contact point.
The background and history of the allegation (giving relevant dates and names and positions of those who may be in a position to have contributed to the allegation);
The specific reason for the allegation. Although someone making an allegation will not be expected to prove the truth of any allegations, they will need to provide information to the person they have reported to, to establish that that there are reasonable grounds for the allegation.
Someone making an allegation may be accompanied by another person of their choosing during any meetings or interviews in connection with the allegation. However, if the matter is subsequently dealt with through another procedure the right to be accompanied will at that stage be in accordance with the relevant procedure.
Action on receipt of an Allegation
The line manager will record details of the allegation gathering as much information as possible, (within 5 working days of receipt of the allegation) including:
The record of the allegation:
The acknowledgement of the allegation;
Any documents supplied by the whistleblower
The investigator will ask the whistleblower for his/her preferred means of communication and contact details and use these for all communications with the whistleblower in order to preserve confidentiality.
If the allegation relates to fraud, potential fraud or other financial irregularity the Treasurer will be informed within 5 working days of receipt of the allegation. The Treasurer will determine whether the allegation should be investigated and the method of investigation.
If the allegation discloses evidence of a criminal offence it will immediately be reported to the Board of Trustees and a decision will be made as to whether to inform the Police. If the allegation concerns suspected harm to children the appropriate authorities will be informed immediately.
If the issue is around suspected harm to vulnerable adults, the Vulnerable Adults policy, the Mental Capacity Act Policy and the Deprivation of Liberty and Safeguarding Policies should be referred to.
Timetable
An acknowledge the allegation in writing within 10 working days with
An indication of how the XXX propose to deal with the matter
An estimate of how long it will take to provide a final response
An indication of whether any initial enquiries have been made
Information on whistleblower support mechanisms
Indication whether further investigations will take place and if not, why not
Where the allegation has been made internally and anonymously, obviously the XXX will be unable to communicate what action has been taken.
Support
Staff4you Ltd will take steps to minimise any difficulties which may be experienced as a result of making an allegation. For instance, if a whistleblower is required to give evidence in criminal or disciplinary proceedings Staff4you Ltd will arrange for them to receive advice about the procedure and advise on the support mechanisms that are available.
Staff4you Ltd accepts that whistleblowers need to be assured that the matter has been properly addressed. Thus, subject to legal constraints, we will inform those making allegations of the outcome of any investigation.
Responsibility for the Procedure
The CEO and Treasure of Trustees have overall responsibility for the operation of this Procedure and for determining the administrative processes to be followed and the format of the records to be kept.
Monitoring
A Register will record the following details:
The name and status (e.g. employee) of the whistleblower
The date on which the allegation was received
The nature of the allegation
Details of the person who received the allegation
Whether the allegation is to be investigated and, if yes, by whom
The outcome of the investigation
Any other relevant details
The Register will be confidential and only available for inspection by the Board of Trustees.
The CEO will report annually to the Board of Trustees on the operation of the Procedure and on the whistleblowing allegations made during the period covered by the report. The report will be in a form which does not identify whistleblowers.
PRIVACY POLICY – Staff4You LTD
We are committed to protecting the privacy of our candidates, clients and users of our website. We want to comply with the General Data Protection Regulation (GDPR). We are committed to provide a safe and secure user experience ensuring the information you submit to us via our website or through our office is only used for the purposes set out in this policy.
In order for us to keep you informed and present you to relevant opportunities, we will hold your personal data. If you do not allow us to do this we will not be able to represent you, obliged to remove you from our database, and can no longer put you forward for work opportunities.
Why do we collect your personal information?
We are retained by companies to identify and place individuals into new work opportunities. You are an individual that could be of interest to our clients.
What information do we collect?
We may collect personal details, including but not limited to, your name, address and contact details including email address. We may also collect and store other information from your CV including current and previous employers, details of your work, skills, work experience, education, salary, expectations and qualifications.
We will then store other pertinent details relating to our dealings with you, including but not limited to, phone call recordings, records of interviews, opportunities we have put you forward for, references, unspent criminal records and other information you have provided to us including copies of correspondence.
We may store further information where we have placed you into a role or you are employed by us which could include contracts, start and end dates, pay history, criminal record information, umbrella company / limited company details and bank details.
It is unlikely we will process any identifiable data which would be categorised as Special Category under the relevant data protection legislation unless it is to meet a specific legal requirement, for example to evidence fitness for night work or right to work.
Legitimate Interest to process data
Article 6(1)(f) of the GDPR says that we can process your data where it “is necessary for the purposes of our legitimate interests, except where such interests are overridden by the interests or fundamental rights or freedoms of you which require protection of personal data.
We believe that it is reasonable to expect that if you are looking for work, or have posted your CV on a job board, you are happy for us to collect, retain and otherwise use your personal data to offer or provide our recruitment services to you and to assess your experience against our database of vacancies and share that information with potential hirers.
We don’t think that any of the following activities will impact the rights or freedoms of individuals in any way. However, you do have the right to object to us processing your personal data on this basis.
For clients we store your personal data and/or the personal data of individual contacts at your organisation as well as keeping records of our conversations, meetings, registered jobs and placements to provide you with the best service possible.
What will we do with your personal information?
We will hold your personal data:
• To provide services to you and answer your enquiries.
• To maintain our business relationship, where you are a user of our website, a client or a candidate.
• To enable you to submit your CV for general applications, to apply for specific jobs or to subscribe to job alerts.
• To match your details with job vacancies according to your background and experience.
• To assist us in finding the most suitable opportunities and contact you to discuss those work opportunities.
• For the fulfilment and ongoing management of a contract where we have placed or hired you.
• For the purpose of identification and right to work.
• To comply with our legal and regulatory obligations and fulfil contractual obligations to you and our clients.
• To advise on news, industry updates, events and any changes to the services we provide. Where we do so, you will be able to unsubscribe from such communications.
• To provide work references. Information disclosed will be limited to the position you held and dates worked.
• We may also contact you to seek consent to collect, hold, use or disclose your personal information for purposes not listed above.
Job Alerts
To subscribe to job alerts you will be required to provide your email address, which will be used for the purpose of keeping you informed, by email, of the latest jobs in your industry and provide you with industry news. Should you decide you no longer want to receive this information, please contact us to let us know.
Curriculum Vitae, CV
You have the option of submitting your details via our website, your CV via third party job boards or by providing your CV to a consultant. You can do this either for a specific opportunity or for consideration for positions as they come up. Your CV will be stored in our database of candidates and will be accessible by our recruitment consultants. You can update or remove your CV and details at any time by contacting us.
Equal opportunities
We are an equal opportunity business and committed to diversity. All job applicants and members of staff will receive equal treatment and not be discriminated against on the grounds gender, marital status, race, ethnic or national origin, nationality, disability, sexual orientation, pregnancy, maternity, religion or age.
Who will we share your personal information with?
We will only make your personal information visible to the organisations we are working with when you are put forward for an opportunity or where required for the fulfilment and ongoing management of a contract where we have placed or hired you.
We may also disclose your personal information to third parties:
• if we use 3rd parties for running our business processes. An example of this might be that we have our emails or our database hosted in the cloud. Whilst these cloud providers would not typically have direct access to your information, storage is considered processing under the relevant data protection legislation. Similarly, as an example, if we have employed you directly, we would need to send your data as required by law to local tax authorities;
• if we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• if we are under a duty to disclose or share your personal data in order to comply with any legal or contractual obligation, or in order to enforce or apply our terms of use which includes exchanging information with other companies and organisations for the purposes of fraud protection.
Using your information to keep in touch with you
In addition to our typical processing we may use the information we hold about you in order to contact you in the following circumstances:
• To advise you of changes to our terms
• To advise you of any security concerns
• Where permitted by law
How long do we hold it for?
Barring any other legal requirement we will hold your data for no longer than 24 months between meaningful contact. Meaningful contact is communication between us (either verbal or written), where you are actively engaging with our services. If we have placed you either with one of our clients or you have been employed directly by us, we are required by law to hold certain data for a longer period to comply with our legal obligations such as Working Time, Right To Work, Pension, National Minimum / Living Wage, Tax, National Insurance and Agency worker Regulations.
Secure collection and storing of your information
All information that you provide to us, or we collect about you is stored on our secure servers. We understand that this includes confidential information and we have put in place a range of suitable physical, electronic and managerial procedures to safeguard and secure your information.
Our staff have the minimum required access to your data, and are trained to ensure that it is protected, and kept secure.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We do not store your information for longer than is necessary to provide the service, and to ensure that we have appropriate auditable records for business purposes.
Your rights
You have the right to request from us access to your own personal information. This is sometimes known as a ‘subject access request’.
Additionally, you have the right to request from us:
• that any inaccurate information we hold about you is corrected
• that information about you is deleted in certain situations
• that we stop using your personal information for certain purposes
• that your member profile is provided to you in a portable format
• that decisions about you are not made by wholly automated means
Many of the rights listed above are limited to certain defined circumstances and we may not always be able to comply with your request. We will tell you if this is the case.
You also have the right to ask us not to process your personal data for direct marketing. We will inform you if we intend to use your information for this purpose or if we intend to disclose your information to any third party for this purpose. You can exercise your right to prevent us using your information in this way by contacting us.
If you choose to make a request to us to exercise any of these rights, we will aim to respond to you as soon as we reasonably can but no later than one month. We will not charge a fee for dealing with any reasonable request.
If you are unhappy with how we are using your personal information or if you wish to complain about how we have handled a request, then please contact us and we will try to resolve your concerns.
You may also contact the Information Commissioners Office at www.ico.org.uk or 0303 123 1113.
IP Addresses and Cookies
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information. This is statistical data about our users browsing actions and patterns, and does not identify any individual. For the same reason, we may obtain information about your general internet usage by using cookies. The main cookies that we use provide us with valuable data about our website. These are completely anonymous, telling us information such as how many people have visited our website and which pages are the most popular. This allows us to ensure that our website is doing its job and make improvements to help you use the site.
Changes to this privacy notice
Any changes we may make to our privacy notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy notice.
Law and Jurisdiction
This privacy information notice is subject to the laws of England, and the non-exclusive jurisdiction of the English Courts. If you are domiciled in Scotland, Wales or Northern Ireland it can be enforced in your local court system.
Get in touch
Staff4You LTD
19 Gibson Way, Lutterworth, LE17 4YJ
+44 745474050