COPs May draft

COMPANY OPERATING PROCEDURESIssued: May 2020

Page 1ContentsChapter numberDescriptionPage numberForewordOur Vision & Values21GLAA & Staffline Compliance52Modern Slavery113Contractor Registration Procedure194Preventing Illegal Working465Worker Information556Audits637Managing Worker Payments & Deductions678Accomodation759Agriculture Work7710Managing Working Hours7911Termination of Contract85Appendix 187Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled

FOREWORD

FIVE STRATEGIC PRIORITIES TO DELIVER OUR 2020 TRANSFORMATIONDigital Strategy: Embed our Trailblazing Technology across every part of the business to deliver true automation, delivering efficiencies and effectiveness that our competitors cannot match.Commercial Model: Commercialise our culture, so that our industry leading proposition carries a premium price.Culture: Further develop our People First Culture to ensure that we become the recruiter of choice for our customers and employees.Performance: Create a new focus on Business Performance, measure effectively and react both quickly and intelligently.Business Model: Develop an agile, efficient and Highly Effective Business.OUR BRAND PILLARSAs a customer centric business, the customer is at the heart of everything we do. Our customers include candidates, workers, clients and internal colleagues.We believe in simplicity and making recruitment easierIn a fast-moving marketplace our approach is precise. We make the world of work simple, meeting today’s recruitment challenges with our straightforward service.We care about people and making every interaction countPeople are at the heart of what we do, and we always put our customers first. Our reputation is made each time we connect, and we work hard to make people feel valued. We protect and support our employees and strive to give them the best possible experience. We have a relentless passion to lead and shape the industryAs a market leader we’re always looking forward. We have our sights set on the future and we’re committed to enabling the future of work . We champion best practice and innovation, and empower our people to do the same, pushing boundaries and always exploring what’s possible.Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 3

OUR VISIONTo continue to be the trusted market leader, providing the only destination for blue collar workers and employers to connect across the UK.OUR BRAND PURPOSETo make our customers more successful and to drive long term transformation of the recruitment industry, championing best practices and innovation. OUR VALUESWe are a values-led organisation. This is how we do business:Teamwork: We work together across the business to achieve more for our customers.Respect: We make time to understand, trust and support each other and to achieve shared success.Commitment: We always strive to exceed expectations.Reliability: We always get the job done for our customers.Creativity: We’re innovative. We find new and exciting ways of getting things done.Integrity: We uphold the highest ethical standards and take mandatory compliance very seriouslyDocument Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 4

1GLAA & STAFFLINE COMPLIANCE

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled1 GANGMASTERS & LABOUR ABUSE AUTHORITY & STAFFLINE COMPLIANCE1.1 Gangmasters & Labour Abuse Authority (GLAA)A “gangmaster” is an individual or business that provides labour, (casual or permanent) to a customer within the following industries: agriculture, horticulture, shellfish gathering, food processing and packaging. The Gangmasters and Labour Abuse Authority (hereafter known as the GLAA) is a government agency set up to protect vulnerable workers from exploitation. It is a non-departmental public body that operates a licensing scheme where labour providers are assessed to check they meet the licensing standards. These standards cover health and safety, accommodation, pay, transport and training. The GLAA check that the business or individual is fit to hold and retain a valid licence and that tax, National Insurance and VAT regulations are met.A labour provider must have a GLAA licence to supply labour within the regulated sectors, it is a criminal offence to supply workers without a licence or use an unlicensed labour provider. The GLAA have the power to arrest any individual who supplies workers within the regulated sector without a valid licence.In 2016 GLAA Labour Abuse Prevention Officers were given additional powers (including arrest) to investigate cases of serious exploitation and abuse within any sector where workers are supplied. This legislation was introduced as part of the Modern Slavery Act 2015 and the Immigration Act of 2016.1.2 What are the benefits of licensing?Licensing creates a “level playing field” as all workers should receive fair treatment, which encompasses the pay, benefits and conditions they are entitled to. Licensed labour providers are not then undercut by those who pay less than the minimum wage or avoid tax and industry standards are raised.Labour users can check their workers come from a legitimate provider and by signing up to an active check on the GLAA website they are informed if their labour provider’s licence is revoked.Consumers can be assured that their food has been picked and packed in an ethical environment.Illegal activities which lead to a loss of public revenue – i.e. income tax, VAT and NI – are reduced.1.3 What does the GLAA do?As the GLAA operates on intelligence, if your site receives a visit or an enquiry from a GLAA officer there will be a good reason for this and you are required to both co-operate fully and also (although they may know already) notify the Compliance Team immediately. The GLAA have three main types of officers, Compliance Officers, Enforcement Officers and Labour Abuse Prevention Officers. Listed below is a brief description of what each role entails:• Compliance Officers: deal with all applications for licences, and also conduct investigations into allegations of non-compliance where a current licence is in force. Compliance inspections will entail visiting sites, mostly unannounced, interviewing workers and management before completing a report that goes to the Head of Licencing at the GLAA for a decision. They also have the powers to deal with any aspect of illegality such as trading without a licence.• Enforcement Officers: will primarily deal with those that supply workers without a valid licence, and this can include those that supply to other labour providers so for example agents used in other countries to recruit on behalf of a UK based labour provider. Page 6

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled• Labour Abuse Prevention Officers: will deal with serious cases of exploitation and abuse no matter where they occur. Similar to Enforcement Officers they often work with other agencies to ensure protection for vulnerable workers in the UK. 1.4 GLAA Licensing StandardsFit & Proper Test checks that we are fit to hold a licence and that we trade legally and compliantly. Pay & Tax Matters checks that we pay our workers and that we calculate the correct National Insurance and tax contributions. The information on our workers’ payslips and our company details are also checked to ensure that we are trading legally. Payment of holiday pay to our workers is also checked in order to ensure that we pay what our workers are entitled to and if they leave we pay what is outstanding. We also have systems in place to alert us if a worker has not worked for us for while and we then check to see if they have left and if so pay them any outstanding holiday pay.Prevention of Forced Labour & Mistreatment of Workers standard looks at how we treat our workers, ensuring that they have no pay issues or complaints with Staffline, and any that have been raised are dealt with in a timely and satisfactory manner, and that we maintain accurate records of any complaints.Accommodation Licensing standard sets out the guidelines that we would have to adhere to if we were to provide accommodation to our workers. We do not directly provide this service although we do help workers find somewhere to live if required.Working Conditions checks the workplaces of our workers to ensure they have adequate facilities. This includes sanitary facilities, rest areas and changing facilities. The standard also monitors excessive working hours and any discrimination issues.Health & Safety evaluates risk assessments and the assigning responsibility of necessary protocols to ensure our workers are safe and fully aware of the details in the assignments they undertake on our behalf.Recruiting Workers & Worker Arrangements ensures that we comply with the outlined processes within our Company Operating Procedures, that we do not charge for any work-finding activities and that we fulfil our contractual obligations as outlined within their contracts with Staffline. Staffline strives to ensure that prior to the commencement of any contract none of our workers have been subjected to any exploitation or Modern Slavery offences.Sub-contracting & Using Other Labour Providers sets out the rules we must adhere to if we have the need to use other labour providers to assist us in fulfilling supply to our clients. ALL secondary suppliers used must hold a GLAA licence.1.5 How does Staffline comply with the GLAA Licensing Standards?The Staffline Group has defined processes and procedures for the registration and management of our contracted workers to ensure that we remain fit and proper to hold a GLAA licence. These are detailed within this Company Operating Procedures manual and supporting documentation.In addition, the Group has also outlined a We Are Compliant policy that specifically details our operational commitments to our Workers alongside each of the defined GLAA standards and UK Border Agency legislation. As of 2013, any Staffline employee that is deemed to be negligent in adherence to these policies may be subject to Disciplinary action.Staffline has a firm commitment to the GLAA and other enforcement agencies to ensure that any issue with any worker is identified, where necessary reported, and thereafter dealt with as quickly as possible.Page 7

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledWe also work hard to ensure that the risks of worker issues are reduced by continuing to review our processes and policies.1.6 We Are Compliant1.6.1 Eligibility to WorkWe ensure our Workers:1. Have relevant acceptable ID for all British and European Citizens in accordance with Home Office ruling - all pages copies, signed, dated and scanned to file2. Have a UK, Irish or Channel Islands birth certificate – copied, signed, dated and scanned to file3. Have proof of National Insurance – copied, signed, dated and scanned to file – both sides of the NI card if provided4. Have an in-date visa or biometric residence card to accompany a passport for Non-EC Workers – copied, signed, dated and scanned to file5. All Non-EC Students have a letter of confirmation of study and holiday timetable for their academic year and scanned to file6. All Non-EC Students will not be worked over their hours stipulated on their visas except during holiday periods7. Will not be placed out to work on expired passports or visas if they are Non-EC Nationals.1.6.2 Paying our WorkersWe will:1. Provide all Workers with a Contractor / Employee Handbook including a relevant contract2. Pay all Workers hours that are shown on their timesheets and will not withhold any pay, resolving any disputes as quickly as possible3. Not charge any Workers for work finding activities4. Pay all Workers approved holiday pay, including on termination any that is outstanding5. Pay all our Workers at least the National Minimum Wage6. Pay all our Workers at least the National Minimum Wage for Agricultural Workers if applicable in Scotland, Wales or Northern Ireland7. Not make any deductions from our Workers wages which takes them under National Minimum Wage and only to recover amounts for items loaned on termination of employment, provided that those items have not been returned by the worker8. Advise our workforce that our preferred method of payment for our worker wages will always be their own bank account. However, if they do not own one, then pre-paid debit cards can be used as an alternative. We aim to no longer issue cheques for our workers.Page 8

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled1.6.3 Managing WorkersWe will:1. Ensure our Workers have signed the WTR Options on their Application Form2. Ensure they only work a maximum of 48 hours if they have not opted out 3. Not force our Workers to work extra days, hours or through breaks against their wishes for fear of some detriment4. Not threaten, bully, intimidate, physically or mentally mistreat our Workers5. Not provide or effectively provide accomodation for any of our workers6. Check and confirm that should we use a third party labour provider outside of the Staffline Group, the labour provider holds a current GLAA Licence and that they are annually audited by the Staffline Compliance Team. 1.6.4 Health & SafetyWe agree to review and update Client Details Forms for all our clients every six months and scan to the customer card to cover the following:1. Who is responsible for the Health & Safety of our Workers whilst working on the client’s premises2. We agree with our clients how to ensure that the day-to-day Health & Safety of our Workers is managed on an on-going basis3. To confirm that there is sufficient First Aid provision on site4. To confirm the accident reporting procedure and ensure all accidents are recorded accuratley and retained5. To confirm the RIDDOR reporting procedure6. To identify any H&S risks that our Workers may be prone to whilst on site7. To identify the responsibility for communication for any new H&S policies8. We will provide confirmation of induction and health & safety training which will be scanned to Workers’ files9. We will provide confirmation of any job specific training that our Workers have undertaken which will be scanned to the Workers file10. We will provide confirmation of issue of PPE if provided which will be scanned to the Workers file.Page 9

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled1.7 Audits and general information pointsA GLAA inspection of any kind is based on allegations received and is scored based on the evidence on its findings and it is this score that determines the impact on our licence.Standards that are designated as critical are worth 30 points, this includes three sections covering the assessment of whether a licence holder is fit and proper. (Fit and Proper, Competency and Correcting Any Additional Licensing Conditions). Other areas that are worth 30 points are withholding of pay or holiday pay (pay queries), paying a worker below the National Minimum Wage, using a second tier supplier who is not GLAA-licensed, and charging of fees and providing of additional services, if this is not conducted properly. Most of the other standards are worth eight points, with a failure to report some significant chnages attracting 16 points.The best outcome for any GLAA Compliance Inspection is to achieve is 0 points so being assessed as compliant. If the inspection score is below 30 points, then additional licence conditions may be attached to our licence and we will be given a defined period of time, normally three months, to rectify the non-compliances and this will be checked by the GLAA. If we then failed to provide evidence that we had corrected the identified issue our licence could be at risk.If the inspection score is 30 or above, our licence may be revoked and we may have to cease trading in the sectors regulated by the GLAA.All Staffline employees must comply with these operating procedures and the We Are Compliant Policy. These are written alongside UK Visa and Immigration Office, Home Office, Inland Revenue and GLAA standards. Any deficiencies in procedures must be immediately rectified.Page 10

2MODERN SLAVERY

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled2 MODERN SLAVERY2.1 What is human trafficking and worker exploitation?Human trafficking is the fastest growing criminal industry in the world, second in size only to the drugs trade. Over a two-year period, the UK Human Trafficking Centre reported cases of human trafficking increasing by 67% in the UK. Hidden labour exploitation is one of the end results of human trafficking in the UK. Whilst it is unlikely that this criminal activity will be stopped completely, there are steps that we can take to minimise the impact that this crime has on our business.Hidden labour exploitation is the exploitation of applicants or workers by third party individuals, gangs or any other party to that of the employer or the labour provider. This can also include rogue individuals working within these businesses without the knowledge of the company management. Hidden labour exploitation and human trafficking for labour exploitation includes payment for work- finding services and work-related exploitation such as forced use of accommodation and the forced taking of identification documents as well as personal bank details. It is understood that these actions are often well hidden by the perpetrators. It is often that the victims themselves are reluctant and frightened to come forward stating that they are a victim of this unnecessary crime.2.2 Who is at risk?Migrant workers are particularly susceptible to coercion and deception for a number of reasons:• They may have limited language skills• They may be uncertain of their legal status in the UK and fear being sent back to their country of origin• They may be distrustful of authority• They may be used to living and working in conditions which are unpleasant or hazardous• They may expect to pay for work in the UK as it is common practice in their own country• The abuse is diffuse and difficult to identify and attribute.Victims may be inhibited from making a formal complaint and acting as a witness against their exploiters through any of the above or one or a combination of:• A lack of knowledge of their rights or access to enforcing them, particularly through mechanisms that they perceive to be confidential• A belief that no-one can or will do anything about it• Being psychologically damaged by their abuser• Being trapped through financial, alcohol, or drug dependency• Acceptance of the situation as the norm or an unfortunate necessity.Page 12

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled2.2.1 The Modern Slavery Act 2015The Modern Slavery Act is new legislation that was passed by the British Government in April 2015 and has been introduced to protect people against slavery and servitude. The Act covers three main areas, these being the following:• Slavery, servitude and forced compulsory labour• Human trafficking• Worker exploitationThe Act has been introduced as it is estimated that in the UK there are currently between 10,000 and 13,000 people trapped in modern day slavery. The Act will protect and help those that are victims of the above offences and will impose heavier sentences on those that are found guilty of committing these crimes. The maximum prison sentence for those found guilty under the Modern Slavery Act has increased from 14 years to life imprisonment. For more information on the Modern Slavery Act please visit http://www.legislation.gov.uk/ukpga/2015/30/contents/enacted.2.3 Policies2.3.1 Preventing Hidden Labour and ExploitationPREVENTING HIDDEN LABOUR AND EXPLOITATION POLICY BACKGROUND INFORMATIONDue to the size of our business, number of locations and high volumes of workers, we are likely to be targeted by unlicensed gangmasters/organised gangs attempting to infiltrate Staffline by supplying workers who are open to exploitation.WHAT IS HIDDEN LABOUR EXPLOITATION?Hidden labour exploitation is the exploitation of applicants or workers by third party individuals, gangs or any other party to that of the employer or the labour provider. This can also include rogue individuals working within businesses such as ours without the knowledge of the company management. Hidden labour exploitation and human trafficking for labour exploitation includes payment for work-finding services and work-related exploitation such as forced use of accommodation, and the forced taking of identification documents as well as personal bank details. It is understood that these actions are often well hidden by the perpetrators. The victims themselves are often very reluctant or even too frightened to come forward to state that they are a victim of such exploitation for fear of repercussions; which could include violence or other forms of intimidation or persecution.POLICY STATEMENTStaffline Recruitment commits to developing and adopting a positive and proactive approach in tackling the hidden exploitation of migrant workers.COVERAGEThis policy will apply to all Staffline offices and OnSites and any company that falls under the Staffline Group of Companies.RESPONSIBILITYThe responsibility to uphold this policy lies with all staff involved in the recruitment, managing and supply of Workers on a day-to-day basis.Page 13

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled2.3.2 Worker Engagement PolicyWORKER ENGAGEMENT POLICYThis Policy is intended to be read in conjunction with the Worker Registration Principles and the Company Operating Procedures. The scope of the policy is to ensure that all Staffline Representatives who directly engage in either recruiting workers or manage them on a day to day basis adhere to this policy and is in addition to the Worker Registration Principles and Company Operating Procedures. In order to ensure you adhere to the above, the following must be undertaken at all times: 1. All workers must be met with either in person by a Staffline Representative and must complete the registration documents at the time of interview or following an online application2. To ensure you remain fully compliant, all documentation must be completed by the worker, not by someone on their behalf. If in the situation of a physical application form being completed at the time of interview, it is your responsibility to make sure that the applicant completes it on their own3. During and after registration, direct communication must be made by the Staffline Representative to the worker and must not be made through any third party (even if it’s a relative or friend). All communication must be logged on the individuals profile page within the universe notes section4. At the time of placement for work, confirm that all details for the job, shift times, pay rates and location etc. are given to and understood by the worker, to ensure that the contractor has all the relevant information 5. We actively discourage any payment from our workers for work finding fees, if you find any evidence of this happening at any time doing the workers recruitment journey, then please raise the concern with the Compliance team6. At no point during the workers time with Staffline, should we ever take & hold their Identification documents from them 7. Staffline does not provide accommodation for workers, nor individuals working for Staffline as a permanent employee rent accommodation to workers 8. Extreme care should be taken when processing the payrolls for our workers to make sure that they are paid correctly, every time. If there is an exceptional instance of any missing hours spotted or reported in from one of our workers, then we must rectify as quickly as possible to cover the full payment owed to the worker9. All of our front line representatives that co-ordinate with our workers on a day to day basis commit to look after them, and spot and report in any signs of mistreatment, or Modern Slavery10. All of our workers have access to remedy. They have access to grievance procedures and our third party confidential helpline.Spotting signs of Modern SlaveryAll Staffline permanent members of staff commit to understanding what Modern Slavery is and how It affects and can infiltrate our business. Whilst the Compliance investigations team will look into all instances and issues flagged reported into them, our operational teams understand the common indicators of forced labour and will alert the compliance team in the first instance of any concerns raised. Any updates from the Compliance team and training tips are demonstrated through the Internal Yammer pages and are regularly updated with new information, shared with the wider business. Our training processes are also regularly reviewed and adapted to include new information cascaded down from the government authorities and experts in this field. Page 14

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledRed Flag means that you may need to investigate further, as there may be signs of labour exploitation. If in any doubt, contact our Investigations Manager – Paul McAnulty or our Director of Compliance and Ethical Standards Jane Bladon.2.4 Have Your SayOur people take full responsibility in their roles and ensure a focus on customer experience is at the heart of every task. We give our staff the tools to help them do their jobs, ensuring longer time is spent with the customer, with enhanced focus on the worker and their experience. By improving the experience, we will drive improved performance and financial results. By asking ourselves “What is the perfect experience and how can we help all our workers feel they’d like to stay with Staffline for a long time, and recommend others to join us?”, we will ensure that all our customers feel valued and respected.Word of mouth is one of the most powerful tools at our disposal and by ensuring all customers have a positive experience, we will increase the strength of our brand, increase the satisfaction of our clients and increase client retention and promoters.Page 15

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 162.5 What can we do to help?There are things that we can look out for as key indicators for potential issues within our business and these are called Red Flags. Please look out for these and if you suspect that this may be occurring within your location, please contact the Compliance Team - [email protected] or 0115 943 7844.Compliance have access to a portal that shows all workers within Universe that share details including; duplicate bank details, multiple addresses and duplicate telephone numbers. The portal is updated every hour with new information regarding details being shared and Compliance analyse the data and work through the duplicate details that have appeared in order to ensure the welfare of our workforce.Although sharing of details may seem harmless, it’s classed as a Red Flag that could mean something much more sinister is occurring. Any Red Flag that arises is investigated extensively by our Compliance Team to spot any signs of Modern Slavery or Worker Exploitation.Using the portal, we identify areas of concern and investigate them using various different methods depending on the detail captured.• Duplicate bank account checks – We will allow a maximum of two people to share a bank account. The two people must be related e.g. spouses or family members. A worker cannot share a bank account with a friend• Multiple addresses – We monitor over five occupants per property.We gather information about the property and get in contact with the Staffline representative at the applicable site to confirm that the details are correct, that the workers are comfortable and happy with their sharing arrangements and if they have any other concerns after speaking with the workers directly such as; signs of overcrowding or being controlled by an outside party, i.e. an illegal gangmaster operating. We record all responses and if we are concerned with overcrowding or poor conditions, we contact the local councils to investigate further.• Duplicate email address checks – Workers must now obtain a unique email address. For information on how to set up a free Hotmail email address, please download the instructions from the Compliance SharePoint page on Yammer • Duplicate telephone numbers – We allow a maximum of three to share a mobile number if they are family. Close friends residing together can share numbers for a maximum of three weeks, at which point they will need to obtain their own numbersShould your workers appear on this portal, you will be contacted by Compliance to confirm the relevant information to ascertain if your workers are at risk or exploitation or not. You will be expected to investigate directly with your workers and report back to Compliance as soon as possible. The responsibility to protect our workers lies with the entire business, not just Compliance and those managing workers directly play an instrumental role in safeguarding them. Help us, help more victims of human trafficking in the UK.

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 172.5 Stronger Together questions and answersBelow are some of the questions that have arisen as a result of the Stronger Together initiative.Stronger TogetherExploitation and Human TraffickingQ.) Who is at risk?A.) Any isolated or vulnerable individual. Evidence confirms that it is mainly migrant workers who are the victims of forced labour.Q.) Why are they at risk?A.) They may have limited English language skills, they may be distrustful of authority, they may be used to hazardous and unpleasant living and working conditions. They have a belief that no-one can or will do anything about it. Being trapped through financial dependency.Q.) Who are the potential unlicensed perpetrators?A.) Illegally operating gangmasters, informal factory supervisors or other workers or rogue workforce managers. They may also be individuals who are remote from the worker’s environment such as those who exert control, or in some cases even rogue landlordsQ.) What are the main signs I should look out for?A.) Applicants appearing frightened, agitated or secretive. Workers saying that they rent their property from a landlord who works for Staffline. Workers delivered to site in big numbers by a minibus.Workers’ physical appearance may show signs of injury and malnourishment and their general appearance may be unkempt.A large number of workers in the same address, or sharing the same mobile number/ email address.Q.) What should I do if I suspect exploitation happening at my site?A.) Contact our Compliance department as a matter of priority on the details below: [email protected] or call 0115 943 7844.All reports can be treated confidentially if you wish.

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 182.6 Example cases of traffickingThe following are examples of actual trafficking cases where arrests and custodial sentences have been given.May 2018 - DaventryA group of four Romanian workers disclosed having had their bank cards taken from them; being made to pay £600 each for a NI number and not being permitted use of the kitchen or bathroom at the house they were residing at with their exploiters. Four individuals have gone through NRM (National Referral Mechanism) and new jobs given at another site. Exploiters has been arrested.May 2018 - Northern IrelandThree men were fined £765 after admitting gangmaster offences. After pleading guilty on acting as unlicensed gangmasters the company were found to have been operating a business without a GLAA license. Eight workers were found working in poor conditions.July 2018 – Shropshire OnSite contract manager noticed one female worker was being sent to work under the name of her exploiter and wasn’t paid for eight months. Her brother had his cheques stolen by the same exploiter. Both victims had their passports and ID cards taken by their exploiter. Victims were placed in a hotel and provided with clothes, food and toiletries. GLAA were unable to retrieve true ID for the female victim enabling her to continue work. Recommendations were made for them to accept an NRM referral which they have accepted. All uncashed cheques were cancelled. The male applied for a OnePay account and a fast-tracked faster payment for £1,600 was processed in his account.July 2018 – WisbechLithuanian man was arrested for being an unlicensed gangmaster. The GLAA and police conducted several raids in Wisbech finding 13 Lithuanian nationals who were found in poor conditioned properties. They were supported by British Red Cross and Salvation Army. April 2019 – KentA group of former employees who worked on UK farms producing eggs for high street brands were rescued. A Judge ruled that the company had failed to pay 6 Lithuanian workers due minimum wage. They had made unlawful deductions from wages and failed to provide adequate facilities to wash, rest, eat and drink. The company are facing criminal prosecution and compensation payments for over £1m.October 2019 – LintonMembers of the Romanian mafia changed their names in order to infiltrate our business. They then attempted to introduce a number of new workers to our business and took the victims’ Onepay cards from them. The victims were found across 4 sites in the Suffolk area and were rescued and taken into the NRM. The offenders form part of a wider investigation and are well-known to police. The police investigation remains ongoing.February 2020 – RugbyA group of Romanian workers disclosed having worked for Staffline for 3 months without ever having received any wages. When interviewed it was found that their Onepay cards had been taken by 2 other contractors who also transported the workers to work each day. The 7 victims were rescued and taken into the NRM and the 2 offenders and other family members were arrested.

3CONTRACTORREGISTRATIONPROCEDURE

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled3 WORKER REGISTRATION PROCEDURE3.1 The Worker pre-interview and interview3.1.1 The pre-interviewThe purpose of this stage is to screen out unsuitable candidates and those who do not meet the necessary requirements. All Staffline Consultants and their managers must have signed a copy of the Worker Registration Principles (attached in this procedure) prior to conducting worker interviews.1. Greet the applicant with his/her name, shake hands2. Introduce yourself and your role. Introduce Staffline and outline the interview procedure including any medicals, drug & alcohol tests etc required3. Explain the nature of work available, shift times, pay rates and locations to be absolutely sure the candidate wants and is able to do the work available4. Confirm that the candidate has their bank account details. If the candidate has forgotten their details you may choose to suspend the interview at this stage or continue and allow them to provide the details at a later stage5. Workers are required to be paid into their own bank account. In accordance with the Anti-Money Laundering Act and Gangmasters Licensing legislation, Staffline has a strict policy with regards to workers/employees sharing a bank account where we are asked to pay wages to that account: • Under no circumstances will we pay more than two people in to any one bank account• We will allow a maximum of two people to share a bank account. The two people may be related e.g. spouses or family members. If one account is used by two people both need to work for Staffline• One of the two must be the account holder, i.e. we will not pay two of our workers in to another (third) person’s account under any circumstance• Please always quote the account holder’s name and Universe number and not the worker’s name, this will give a clearer audit trail and minimise the amount of times you will be contacted to ascertain the account holder details6. Confirm that the candidate has brought appropriate ID to establish the statutory excuse, prove their right to work in the UK. Refer to the Prevention of Illegal Working checklist for acceptable ID for each nationality7. Where the person appears under the influence of drugs or alchohol or where their hygiene, appearance or attitude would be unacceptable to clients then you should make a choice as to whether to allow them to continue with the interview process or find an appropriate reason not to continue, avoiding a confrontational situation. You should though bear in mind that an unkempt appearance can also be an indicator of Modern Slavery so if in doubt report it8. Where an understanding of English is required, the client site specific test or Staffline General Aptitude Test should be given to the candidate to complete. Test completion should be monitored to ensure that there is no cheating, is completed without help and according to any requirements specified by the client. The pre-interviewer should form a view on how this has been completed and the English standard required as to whether to allow the applicant to the Interview stage9. Where its not acceptable to progress to the interview stage end the process as appropriate at this stage, rescheduling where the applicant needs to bring additional ID documentation or bank details. No worker should be placed on any client site without first having undergone an ID check no matter how urgent the contract or shortage of available workersPage 20

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled10. Once the applicant has satisfied the above criteria, they will be required to complete the online application form and will be informed that all fields must be completed, including the direct debit form, as it contains the bank details for wages payment11. The candidate should also be provided with any client specific health questionnaires and aptitude tests, if required, plus any other site specific agreed documentation – food handlers / night workers agreement12. Where an applicant meets the criteria and it is acceptable to progress to the interview stage, an appointment will be scheduled for the applicant to attend the office or site in order to participate in a one to one interview.3.1.2 The interview1. Check through the online application form thoroughly to ensure all areas have been completed and use open ended questions to explore any issues. In particular ask how the worker was recruited and who they encountered as part of that process and also if they paid any money to any other person to get the job2. Explain the 48 Hour Opt Agreement so the applicant understands what they have signed3. Explain any direct debits that may apply to his/her assignments and check that bank details are in the applicant’s name and have been recorded correctly• Ask the candidate to see their bank account proof to verify that it is their account that they will be paid into and not someone else’s4. For paper application users, the applicant completes the bank account details check that the name corresponds with their name. Ensure the Bank Account Details and Payment Authority and Bank Details and Instruction to pay Direct Debits sections are completed and signed fully and correctly. Detach the direct debit guarantee and give this to the applicant. Scan the form with all the other new starter documents.You do not need to send the Direct Debit Form to the bank or building society as the notification process is now done electronically through the Payroll system. On Universe you will notice the Bank Details section will have the relevant fields to be agreed by the worker should they opt for Direct Debit or Transport etc. Should these be agreed, the Payroll department will follow an automated process and apply for direct debit to the worker’s bank direct through the BACS software. If you do not place a tick in this field then no application of direct debit will be issued to the worker’s bank5. To reinstate a worker that has been set to LEFT, you need to remove the leave date entered on Universe. A worker can be reinstated in any tax year6. Ensure any Client specific elements of the selection process have been completed7. Complete the For Interviewer Completion Only section. THIS IS MANDATORY. Write your name next to Interviewer Name and check off the boxes when completed. This area confirms all the relevant checks have been made8. Explain fully each section of the relevant handbook. All workers must be made aware of when they are paid, how they will be paid, how their holiday is accrued. Talking through these issues using the Handbook at this stage will avoid problems later9. Go through the relevant contract and its details with the applicant before you ask them to sign. Ensure that they understand how assignments will be offered and what the contract means. Retain the relevant copies for their file10. Explain to the applicant the procedure that must be followed if they are unable to attend work. Ensure that they have a contact number for their representative.Page 21

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledExplain to them that if they fail to turn up for an assignment then this will reflect on our decision to offer them further work, and for those on Swedish Derogation or Direct Employee contracts could involve disciplinary proceedings.The applicant should leave the office with the relevant handbook, contract and an Assignment Details Form (if applicable).Please note – at the point of registration, do not issue a client pre-employment medical questionnaire. If you have one of these to be completed, issue at the point of induction or after work has been offered.3.2 Setting up a new Worker1. Refer to the Universe Manual under Creating a Contractor Card to set up and input worker details. Please refer to appendix 1 to see what the minimal Compliance Universe Requirements are, to become compliant.• Check first through Universe that a contractor card does not already exist for the applicant. Check in the full register, not just for your site, as the worker may have previously worked for Staffline at a completely different location. Ensure that this full check has been completed before you begin a new card on the system, as duplicate cards are unacceptable• The Universe contractor card should be updated immediately following interview, with all the relevant documentation uploaded to the card for the authorisation process to be completed prior to the worker being placed out to work.2. Please note, if you have sourced candidate via a Welfare to Work scheme, record on contractor card in Today’s Status box by selecting the relevant provider’s details. Scan the Application Form, Contract, ID and upload according to the Scanning Procedure.3. Start a contractor file and file all relevant documents.It is your responsibility to ensure full compliance to legal obligations for all the workers that you place to work. Any non-adherence will be addressed by the Compliance Department.Universe and beyondIf tablets are installed at your site, workers are able to register via this method. They will be able to enter their own details onto the system and complete the relevant sections. A paper application form and a hard copy of the contractor handbook is not required when workers register via tablets, as all the information found on these documents are stated on their Universe record, a copy of the contract will also be emailed to the worker directly. Please note - they must have a valid email address to be able to access their Universe record.If you are required/authorised to use paperwork for your site, please ensure that all three pages of the worker application form are scanned. Once scanned, page three can be separated from the main form and issued direct to the applicants’ bank / building society if they have agreed to the direct debit.ONLINE APPLICATION FORMS ARE COMPLETED BY THE CANDIDATENO HARD COPIES OR PHOTOCOPIESPage 22

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 23Make sure email address belongs to applicant, if not leave blankMake sure all are circled either Yes or NoOne option only MUST be circledEmployment history MUST be completed, even if it is their first job in the UK. Obtain employment / education history from home country

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 24Make sure all are circled either Yes or No. If Yes, ensure details givenOnly sign ONE optionAll sections MUST be completedGDPR consent option

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 25If applicant is not using their own bank account, the account holder must be an immediate family member and they must work for Staffline

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled3.3 General Data Protection Regulation (GDPR)3.3.1 PRIVACY AND DATA PROTECTION POLICYPurposeSTAFFLINE RECRUITMENT LTD (Staffline) recognizes the importance of having effective and meaningful privacy protections in place when it collects, uses, and discloses Personal Information. These protections are necessary to instill confidence in Staffline, whose employees may secure Personal Information to Staffline and are themselves subject to local privacy and data protection laws, as well as to ensure Staffline’s own compliance with such laws.Staffline does apply protective measures when handling Personal Information under its control or in its possession, both from a regulatory compliance and commercial perspective. The purpose of this Policy Statement on Privacy and Data Protection (“Policy”) is to establish privacy standards applicable throughout Staffline. In addition to the Policy, Staffline will comply with more restrictive local privacy and data protection laws or standards that apply.ScopeThis Policy applies to the collection, use, and disclosure of Personal Information by Staffline or authorized third- party agents in any format, including electronic, paper, or verbal. Staffline may develop more detailed guidance or procedures to address discrete privacy concerns involving individual Staffline projects, activities, or initiatives, as appropriate. Where Staffline personnel are unsure whether information qualifies as Personal Information under the Policy, they should consult the Data Protection Officer, [email protected] purposes of the Policy, the following terms and definitions should apply:Personal InformationInformation that on its face or in combination with other information in Staffline’s control or possession identifies an individual, regardless of the format in which it is displayed (paper, electronic, etc.). This could include information, such as name and contact details, and other work-related, of persons representing existing or potential Staffline members, persons responding to Staffline surveys and research tools, persons representing Staffline, Staffline suppliers or vendors, and/ or persons submitting information to Staffline online.This Policy Statement supersedes any previous policy of Staffline concerning Privacy and Data Protection. In the event of any conflict or inconsistency between this Policy Statement and any other materials previously distributed by Staffline, this Policy Statement governs. Personal Information excludes information that Staffline cannot reasonably attribute to an individual or could only attribute to an individual after expending disproportionate effort or expense or information that has been aggregated or rendered anonymous through the application of coding or other similar techniques.Sensitive Personal InformationPersonal Information pertaining to an individual’s race, ethnic origin, health, sexual orientation, religious, philosophical or political beliefs, commission of criminal offences, or other information that has been expressly designated as such under local laws applicable to Staffline or its clients.Page 26

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 27Policy1. Legitimate and Fair UseStaffline will only collect, use, or disclose Personal Information by lawful and fair means, in accordance with applicable laws, and fully observing the legal rights of individuals. Staffline will only obtain or use Personal Information to fulfil Staffline’s legitimate business purposes, such as (but not limited to) evaluating applications for employment with Staffline (including any of its individual programs), maintaining Staffline accounts, maintaining regular communications with Staffline contractors, complying with applicable legal and regulatory requirements, and protecting Staffline’s legal rights and interests. Staffline will use the minimum amount of Personal Information necessary to accomplish its business objectives. Staffline prohibits any unauthorized use of Personal Information by Staffline personnel or its agents.2. Notice to IndividualsStaffline strives to ensure that its collection and use of Personal Information remains transparent to the relevant individuals. Staffline takes reasonable steps to supply individuals with an appropriate form of notice to inform them about; the purposes for which Staffline collects and uses the Personal Information, how to contact Staffline if the individual has any issues or concerns about Staffline’s use of the Personal Information, third parties with whom Staffline shares the Personal Information (including international transfers of the Personal Information and disclosures within the Staffline network or across Staffline programs), and the choice and means Staffline offers individuals for limiting the use and disclosure of the Personal Information, unless the notice would be impracticable or impossible under the circumstances.Notices can be provided in plain language, take a written form, and be supplied to individuals before their Personal Information is first collected or, if that is not possible, as soon as practicable thereafter. Staffline has decide the appropriate mechanism for imparting notice considering the relationship with the relevant individual, the circumstances under which the Personal Information is collected, and other relevant factors. For the avoidance of doubt:• Where Staffline obtains Personal Information from individuals by means of Staffline application, Staffline will include within the documentation where appropriate, written notices.• Where Staffline captures Personal Information by means of benchmarking surveys, questionnaires, and related research tools, Staffline should include within the surveys and tools appropriate written notices and only proceed to collect and use the Personal Information captured via such devices where the respondent has agreed to such processing. In the absence of such agreement, Staffline should not process the Personal Information contained in the relevant survey or tool.• Where Staffline obtains Personal Information from individuals online, Staffline should provide such individuals with an appropriate form of notice that considers how the Information is collected, which may take the form of an online privacy statement, policy, or other informational disclosures.

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 283. Individual ChoiceStaffline believes individuals should be able to decide how Staffline collects and uses their Personal Information to the greatest extent possible. Whenever possible or required by law, Staffline should obtain the consent of an individual before collecting or processing their Personal Information and, where an individual withholds or later withdraws their consent, respect their indicated wishes. Staffline will strive to obtain the consent of individuals where Staffline collects and processes Sensitive Personal Information, while recognizing it may in some instances be necessary to process such information to protect adequately Staffline’s legal rights and interests. When seeking an individual’s consent, Staffline should provide the individual with enough information to allow the individual to make an informed decision, allow the individual to later withdraw their consent, and refrain from penalizing the individual for withholding their consent. For the avoidance of doubt:• Staffline does ensure that any benchmarking surveys, questionnaires, and related research tools capturing Personal Information contain a mechanism for securing the consent of the respondent, and that the relevant individual has affirmatively indicated their consent.• Staffline allows individuals to decide whether their Personal Information will be used for other purposes besides those appearing in any notices furnished to the individual, other than where necessary to protect Staffline’s legal rights and interests.• Staffline respects an individual’s decision not to receive marketing and promotional communications from Staffline.4. Information IntegrityStaffline will only use Personal Information in accordance with any notices provided to or consents obtained from individuals and should not later process Personal Information for any additional, incompatible purposes unless it has re-notified the individual or where required or expressly permitted by law. Staffline should only collect Personal Information that is relevant considering the business purposes the Personal Information is meant to serve and employ reasonable means to keep the Personal Information accurate, complete, up-to-date and reliable. Staffline materials and forms used to collect Personal Information should be prepared in such a manner that only pertinent Personal Information is captured.5. Information SecurityStaffline has implemented appropriate administrative, technical, and organizational measures, including those appearing in Staffline’s Information Security Policy, to safeguard the Personal Information under its control or in its possession against loss, theft, misuse, unauthorized access, modification, disclosure, or destruction. Staffline does ensure that any Sensitive Personal Information it holds is subject to safeguards reflecting the correspondingly greater harm that would arise from its unauthorized use or disclosure. Staffline will only retain Personal Information for so long as reasonably required to serve Staffline’s legitimate business needs and the Personal Information subsequently should be anonymized, deleted, or destroyed.Staffline does restrict access to Personal Information to Staffline personnel or third-party agents who have a legitimate business need for such access given their roles and responsibilities. Staffline will only disclose Personal Information to third-party agents who expressly agree to and can protect the Personal Information to the same degree as Staffline. In the event Staffline learns or reasonably believes that a third-party agent is failing to apply adequate privacy protections to the Personal Information, Staffline will take immediate steps to rectify the situation.

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 296. Information Access and CorrectionStaffline will allow individuals to review in an intelligible format the Personal Information that Staffline holds relating to them, unless such access would be inappropriate or unnecessary. Instances where access may legitimately be denied include such access that would materially prejudice Staffline’s legitimate business interests or legal rights, adversely affect the privacy rights of third parties, or impose a disproportionate burden upon Staffline given the privacy risks to the individual. Where access is refused, Staffline will endeavour to inform individuals as to the reasons for the denial. If an individual evidence to Staffline’s satisfaction that their Personal Information is inaccurate or incorrect, Staffline will promptly correct or amend the relevant Personal Information.7. Disclosures to Third PartiesStaffline places substantial importance on protecting the confidentiality of Personal Information. For that reason, Staffline will inform individuals whenever their Personal Information may be disclosed to non-agent third parties, if practicable. Staffline will not disclose Personal Information to non-agent third parties except where it serves a legitimate business purpose and where reasonable assurances are given that the Personal Information will be legitimately processed and appropriately protected. 8. International Transfers of Personal InformationPrior to the international transfer of Personal Information, Staffline will implement any additional measures that are required under any applicable laws regulating such transfer and only transfer Personal Information in furtherance of Staffline’s own legitimate business needs.9. ComplianceStaffline maintains an active program to ensure compliance with and maintain awareness about the Policy. The Director of Compliance and Ethics is responsible for implementing and overseeing the administration of the Policy. All Staffline personnel and third-party agents are required to adhere to this Policy and any associated or supporting policies. Failure to do so may be grounds for disciplinary action up to and including termination.10. Enforcement & Complaint ResolutionStaffline is committed to assisting individuals in protecting their privacy and in providing opportunities to raise concerns about the processing of their Personal Information. Complaints relating to this Policy should be raised pursuant to the procedures set forth in Staffline’s Company Operating Procedures.

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 303.3.2 General Data Protection Regulation (GDPR)• We have an obligation to protect our workers personal and sensitive data once we receive it, so we will be mindful when processing personal data, this includes worker ID, addresses, contact details etc• Worker details and personal documents such as ID, will be input and uploaded to a secure system. We will carefully consider how we process this information and monitor the relevant data, to ensure we are GDPR compliant at all times• Staffline places substantial importance on protecting the confidentiality of Personal Information. For that reason, Staffline should inform individuals whenever their Personal Information may be disclosed to non-agent third parties, if practicable. Staffline will not disclose Personal Information to non-agent third parties, except where it serves a legitimate business purpose and where reasonable assurances are given that the Personal Information will be legitimately processed and appropriately protected. Staffline should provide individuals with notice of any third parties with whom it shares personal information for the third party’s direct marketing purposes• In-line with our paperless working policy (see below) once relevant documents such as Staffline application packs have been scanned and uploaded to the system, they are then to be shredded to avoid a data protection breach – this includes copies of ID. Original documents such as but not limited to; passport or ID cards, will be given immediately back to the owner. Copies of IDs made for scanning purposes, will be shredded immediately after they have been scanned and uploaded to the system• For full details on what we do with personal information we collect and the ways in which we may collect that information, please refer to our privacy policy by visiting the following website: https://www.staffline.co.uk/privacy-policy.3.3.3 Paperless Working PolicyWhat is GDPR?The new EU General Data Protection Regulation (GDPR) came into force on 25 May 2018 (including in the UK regardless of its decision to leave the EU) and will impact every organisation which holds or processes personal data. It has introduced new responsibilities, including the need to demonstrate compliance, more stringent enforcement and substantially increased penalties than the previous Data Protection Act (DPA) which was it superseded.How does this affect Staffline?As a labour provider, we hold huge amounts of personal data on our workers, including date of birth, home address, national insurance number, copies of passports to name but a few. GDPR enshrines in law what we, as a data controller, have to do in order to safeguard that data. What is personal data? Personal data is defined as any information that could identify an individual, and whereby the breach of said data could cause the individual personal harm or distress. What are the consequences of losing personal data? GDPR gives the Information Commissioner’s Office (ICO) the power to levy a fine of 4% of group turnover) or €20m, whichever is greater for serious breaches of personal data. (This would be over €40m for Staffline Group (for 2018)).

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 31What is Staffline doing to prevent personal data breaches? There are four main areas: 1. IT systems: updating our IT to minimise the risk of data breaches2. Educating employees about how GDPR works3. Commercial contracts: ensuring our supplier and customer contracts give us the appropriate protection where data is shared between us and suppliers/customers4. Paperless working: reducing the amount of paper that is handled within the business, to minimise the risk of data breaches. What is paperless working?We handle vast amounts of data within documents on a daily basis, most of which is received in paper copy initially. Virtually all of that data can be retained electronically. When the data is stored electronically, the risk of losing that data is far less than retaining paper copies. With immediate effect, we will be implementing paperless working which means the default response to any piece of data is “scan and shred”. On the next page is an extensive list of data that we routinely receive and how you should handle that data. Remember, when you receive data, you should ask yourself “Do I have the right to store this data, do I need it in order to find someone a job and pay them?” if the answer is no, you should not retain the data. If the answer is yes, the next question is “how do I store it” to which the reply will almost always be “scan and shred”. Where do I upload the data?Universe users: There is a generic drop-down filter within Universe for uploading documents against a worker.

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 32Once you have uploaded the document onto Universe, you must delete the original scan from your network drive (or wherever your scanner saves images to). Why are there so many drop-down filters?Under GDPR we can only retain data for as long as we have a lawful purpose for doing so, which is often determined by the relevant legislation or regulation. For example: for insurance purposes we may need to retain an application form for three years (to protect against personal accident claims) but there is no need to retain a CV beyond six months and therefore after seven months we would delete the worker’s CV but retain their application form. As such, we need to have separately identifiable pieces of data. What if the document I need is not included in the list of routinely received data? All document types have been considered and included in the attached list. If you want to retain something else the first question you should ask is “Do I have the right to store this data/document, do I need it in order to find someone a job and pay them?”. If the answer is yes, then contact [email protected] for a response. Anything else?Staffline will be operating a zero-tolerance policy with regard to paperless working and we will be conducting regular audits of our sites to ensure this policy is being adhered to. Failure to do so could result in disciplinary action.

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 33Retention PeriodsDocumentJustificationSuggested File TypeRetention PeriodAbsence DocumentsContractAbsence Documents3 yearsAccident DocumentsContractAccident Report Form 3 yearsAddition forms including adjustment formsContractAddition Form3 yearsAllergen awareness /policy / testContractClient Specific Document3 yearsApplication Form Legal ObligationsApplication Form Page 1 3 yearsAssessment and Training Records Legal Obligationsincluding food safetyInduction Paperwork 3 yearsAviation Reference Pack including Legal Obligations5 year reference and DHL CAA Authority formReference 3 yearsBriefing documents including Job BriefContractJob Brief 3 yearsCar Insurance DocumentsLegal ObligationsCar Insurance Documents3 yearsCar Registration detailsLegal ObligationsCar Registration details3 yearsChange of Details FormLegal ObligationsChange of Details Form 3 yearsChange of name document including marriage certificate and change of name deedLegal ObligationsChange of Name document 3 yearsClient Detail Form including all client documentationLegal ObligationsClient Detail Form 3 yearsCommunisis Reference Pack - including credit checkLegal ObligationsReference 3 yearsConsent FormLegal ObligationsConsent Form3 yearsContract. Contract for Services sign off from HandbookLegal ObligationsContract for Services 6 yearsContract. Swedish Derogation sign Legal Obligationsoff from HandbookSwedish Derogation Contract 6 yearsCRB DocumentationLegal ObligationsDisclosure Documentation3 yearsCVContractCV 6 MonthsDeduction formsContractDeduction/Payment Form 3 yearsDisciplinary Information/Documents including investigation reports/Incident ReportsContractDisciplinary Documentation12 months after disciplinary date

DocumentJustificationSuggested File TypeRetention PeriodDriving Licence including Driv-ing Qualification card and DVLA licence CheckLegal ObligationsDrivers Licence 3 yearsDrugs/Alcohol Documentation including sign off and results ContractDrugs/Alcohol Documentation6 MonthsElectronic Timesheets/ T&A re-cords including fingerprint scan-nersContractShared Drive3 yearsExpenses including receipts ContractExpenses including receipts 6 yearsFlexible Working DocumentationContractFlexible Working Doc- 3 yearsumentationFork lift Truck licence Legal ObligationsFork lift Truck Licence 3 yearsForm of Authority for referencesLegal ObligationsForm of Authority 3 yearsGrievance Documentation includ-ing recorded conversation notesContractGrievance Documen-tation 3 yearsHealth and Safety Policies includ-ing Hygiene, Ammonia SafetyContractHealth and Safety Policies3 yearsHealth Assessment documentsContractHealth Assessment Documents3 yearsHoliday RequestContractHoliday Request 6 yearsHR documentation including exit interview and appraisal docu-mentsLegal ObligationsHR Document 3 yearsID documents including pass-ports/visa, ID cards and birth certificatesLegal ObligationsID Card, Passport, Visa, Birth Certificate3 yearsInduction records including night worker questionnaire and sign offContractInduction Paperwork 3 yearsInterview NotesContractInterview Notes3 yearsJob Brief ContractJob Brief 3 yearsLimited Company Information including VAT Certificate, Compa-nies House Check and Certificate of IncorporationContractVAT Certificate, Com-panies House Check and Certificate of Incorporation6 yearsMaternity, Paternity and Parental leave documents including MATB1 and Paternity FormsContractMaternity Document, 6 yearsPaternity Documenta-tion, Sick notesMedical Consent FormsContractMedical Consent Forms3 yearsNational Insurance Documents - including P45 and benefit lettersContractNational Insurance Proof 3 yearsDocument Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 34

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 35DocumentJustificationSuggested File TypeRetention PeriodOne Pay DocumentsContractOne Pay Documentation3 yearsP45 from previous employmentContractNational Insurance Proof 3 yearsPaper Timesheets/ T&A recordsContractShared Drive6 yearsPay Query FormsContractPayroll Enquiry 3 yearsPension Documentation ContractPension Documentation 6 yearsPerformance/One-to-one DocumentationContractPerformance/One-to- 3 yearsone DocumentationPrivacy NoticeContractPrivacy Notice3 yearsQualifications/ Certificates documentationContractQualification documentation3 yearsReference documentationContractReference 3 yearsRegistration Pack; Application Form, Contract documents and ID ContractContractor Application Pack 3 yearsReview NotesContractReview Notes3 yearsRisk assessments including young person and pregnancy assessmentsContractPregnancy Risk Assessment, Under 18 Risk Assessment3 yearsSick notesContractSick notes6 yearsSite particular documents including aptitude and language test and confidentiality clauseContractClient Specific Document3 yearsStarter/Leaver Interview DocumentationContractStarter/Leaver Interview Documentation3 yearsStudent Documentation including confirmation of study and completion of studyContractStudent Declaration Documents 3 yearsSwedish Derogation Assignment Detail FormsContractAssignment Details Form 3 yearsSwedish Derogation Resignation FormContractSD Resignation Document 3 yearsSwedish Derogation sign off from Legal ObligationsHandbookSwedish Derogation Contract 3 yearsUKVI Employers Checking ServiceLegal ObligationsUKVI Employers Checking Service3 yearsVisa Documentation including visa Legal ObligationsextensionsVisa/HO Doc Time Period 3 yearsWorker Surgery details Legitimate InterestsWorker Surgery details 3 years

DocumentJustificationSuggested File TypeRetention PeriodWorking Time Regulation opt Out FormContractWorking Time Regulations opt Out Form3 yearsWorkwear and equipment receipts including accommodation formsContractWorkwear Receipts, Accommodation Form3 years3.3.4 GDPR adviceFor advice on GDPR, please email [email protected] any questions regarding a breach in data protection, please use the contact details below:Email: [email protected]: The DPOStaffline Recruitment Limited19 & 20 The TriangleNG2 Business ParkNottinghamNG2 1AETelephone: 0115 697 5697Fax: 0115 985 2823Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 36

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled3.5 Change of details formOnce your workers have registered with you, they may change their contact or other details during their time at Staffline.If workers do wish to change their details, can you please ask the worker to complete the form on the next page to record any chnages and obtain their signature as their authorisation for the changes.This will prevent any confusion or miscommunication, making sure that the details on our system are changed correctly. Keep these blank forms handy at your sites.In line with our Paperless Working Policy, the change of details form must be shredded as soon as it has been uploaded to the system.It is imperative that the official Staffline change of details form is completed, signed by both the worker and the site representative, in order to authorise the desired change of details. If this form has not been completed and scanned onto the system as proof the change has been authorised, then the details in the system should not be updated.Page 37

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Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled3.6 Process for the use of UK and overseas labour supply agenciesWhilst we endeavour to source all workers ourselves, there may be occasions where the use of other agencies is necessary to fulfil client demands.The following process applies in order to ensure the agencies we use to supply us with workers are legally and ethically compliant, and present no risk to our workers or reputation damage to the business. Labour supply agencies that provide workers free of charge are able to do this because the workers may be paying a fee. This is not acceptable to Staffline as it puts our workers and reputation at risk. The process for approval of labour supply agencies is as follows:Only the Compliance auditors can authorise the use of an outside labour supply agency in the UK and overseas. All requests to use an outside labour supply agency must be submitted to the Compliance department, who will be responsible for ensuring the proposed supplier is deemed to be compliant. This will include as a minimum:1. Ensuring that the labour supply agency is in possession of a current GLAA licence as verified on the GLAA website2. Registering the supplier with the Active Check facility on the GLAA website at to be informed of any changes to the status of the labour supply agency3. Checking with the site that either contracts or terms and condition of business have been agreed between the branch or OnSite location and labour supply agency are agreed and retained by both parties prior to supply4. Determining whether a fuller audit should be conducted on the labour supply agency.Please ensure that the following process is used when setting up an outside supplier in the UK:• Please email Compliance with the details of the Labour Provider you wish to use. Compliance will run some checks on the Labour Provider and approve usage• If the chosen Labour Provider is OK to use, send the 2nd tier supplier agreement to the chosen supplier. This is to be signed by the chosen provider and the Staffline Representative who is negotiating the agreement• At the point of negotiations the chosen Labour Provider needs to be made aware that they will be subject to a Compliance Audit within the first month of supply. This is to comply with the Modern Day Slavery Bill to ensure transparency within our supply chain• Once signed by both parties, the agreement is to be emailed to [email protected] • Once everything is agreed the chosen Labour Provider needs to be set up with finance as a vendor.To request labour coming from abroad, please contact the Resourcing Centre.3.6.1 Using the Resourcing Centre for overseas recruitmentThe Resourcing Centre use a network of GLAA licenced agents across Europe. The aim of the team is to fulfil vacancies placed by sites using approved overseas GLAA licenced agencies offering a smooth and efficient solution to enable sites to fill their client requirements. Sites and Branches may request staff through overseas channels if they experience difficulties recruiting through local recruitment avenues including using our in-house services.Please ask the Resourcing Centre for the ideal recruitment criteria which the site needs to meet to use overseas recruitment as a suitable option.Page 39

If your booking fulfils the required criteria you will need to complete the overseas order form and send this to [email protected] giving at least three weeks’ notice. The order must be approved by your Regional Manager / Account Director prior to placing the order with the Resourcing Centre.The Worker Welfare form needs to be signed by the client preferably, so they are aware that we guarantee 30 hours minimum per week for the overseas arrivals for the period of 8 weeks.Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 40

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled3.6.2 Overseas worker welfare formPage 41

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Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled3.6.3 Overseas recruitment order formPage 43

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Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 45

4PREVENTING ILLEGAL WORKING

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledThe following chapter will give you an overview of The Prevention of Illegal Working. For a more in-depth document on how to remain compliant for registering workers using Staffline Universe - Scan, Check, Start; please see appendix 1.4 PREVENTING ILLEGAL WORKING4.1 Establishing the statutory excuseStaffline takes its responsibility to prevent illegal working extremely seriously.Staffline, in its role as an employment business, is liable for a civil penalty of up to £20,000 for each illegal worker it engages. A statutory excuse to the civil penalty can be established by following the three step process laid out in this procedure.If at any stage any Staffline consultant knows that a worker is working illegally, Staffline loses its right to the statutory excuse and commits a criminal offence with a potential fine and/or imprisonment.4.2 Staffline preventing illegal working rulesAll Staffline representatives are specifically instructed:1. To establish the statutory excuse for all workers, limited company workers and permanent staff. The responsibility to establish the statutory excuse rests with the interviewing Consultant2. If using paper application forms, to complete the relevant boxes on page 2 of the application forms as evidence that the statutory excuse checks have been completed3. Not to allow any worker to work before a statutory excuse has been established4. Not to allow any worker to work who the Consultant knows, or has reason to suspect, is an illegal worker.4.3 Establishing the statutory excuse – step 1In order to acquire the excuse interviewers are required to check the validity of the document and satisfy themselves that the individual is the person named in the documents they have presented and is entitled to do the work in question by carrying out the following checks. Failure to conduct these checks and to demonstrate that they have been completed will mean that the statutory excuse has not been established.• Check that all passports that require a signature have been signed by the worker, in order to validate the document• Check any photographs in the documentation are consistent with the appearance of the individual• Check the dates of birth listed to ensure that these are consistent across documents and that you are satisfied that these correspond with the appearance of your prospective or current employee• Check that the expiry dates of any limited leave to enter or remain in the UK have not passed• Check any UK Government endorsements (stamps, visas, etc.) to confirm the individual is able to do the type of work offered• Satisfy yourself that the documents are genuine and have not been tampered with and belong to the holder• If the individual provides two documents which have different names, ask for a further document to explain the reason for this – a marriage certificate, divorce decree, deed poll document or statutory declaration.Page 47

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledInterviewers are not expected to be an expert on forged documents. Staffline will only be required to pay a civil penalty if:• The falsity is reasonably apparent i.e. if an individual, who is untrained in the identification of false documents, examining it carefully but briefly and without the use of technological aids, could reasonably be expected to realize that the document in question is not genuine• Where it is reasonably apparent that the person presenting the document is not the person referred to in that document, even if the document itself is genuine.4.5 Establishing the statutory excuse – step 2Documents must be scanned and uploaded according to the appropriate scanning procedure. N.B. All scans must be readable to establish the statutory excuse. Please refer to appendix 1 for clarity on using Staffline Universe - Scan, Check, Start to establish a statutory excuse. All parts of the original document must be scanned:• Any page containing the holder’s personal details – specifically any page that provides details of nationality, his or her photograph, date of birth, signature, date of expiry or biometric details• Any page containing UK Government endorsements, noting the date of expiry and any relevant UK immigration endorsement which allows your prospective or current employee to do the type of work you are offering.Other documents should be scanned in their entirety.In the case of a Biometric Residence Permit, National Identity Card or UK National Insurance card, BOTH sides of the card must be scanned if used as proof of identity or national insurance.Page 48The Personal Validations section on Universe also allows you to confirm if and when you have seen the original ID. Simply ensure this is completed to establish a statutory excuse.For the most up to date right to work checklist, please use the following link:https://www.gov.uk/government/publications/right-to-work-checklist

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled4.5.1 UK Visas and Immigration (UKVI) informationBiometric residence permit (BRP) checking serviceYou can now check the job applicants right to work in the UK. The applicant will need a biometric residence permit (BRP) to use this service and you will need to obtain permission from the applicant to check their details. The applicant can use the link: https://www.gov.uk/prove-right-to-work Once the applicant has granted you permission you can check details of a job applicant’s right to work in the UK, including:• the types of work they’re allowed to do• how long they can work in the UK for, if there’s a time limit.You will need:• their BRP number• a security code - you’ll be sent one if the applicant gives you permission to check their details.You will still need to see the original document in person and sign and date when it was seen, to establish a statutory excuse. https://www.gov.uk/view-right-to-work4.6 Non EC / Commonwealth Nationals who are a family member of an EEA CitizenIf a Non EC / Commonwealth National holds a valid EEA Residence Card as the family member of an EEA national, the passport itself can be expired. The passport will have to be endorsed with a current in date EEA Residence Card (providing of course they are the rightful holder). Only the documents exampled below will be accepted in an expired passport for the above persons.Page 49