COPs May draft

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled4.7 Workers with expired leave to remainIt is the responsibility of the site/branch to maintain records and check ID due to expire using the relevant Universe reports.If the worker has applied for further leave to remain then process a Home Office Employer Checking Service. If the worker no longer has the right to work then they must be informed as such, stopped from working, their contract terminated and P45 processed.If the statutory excuse is not re-established in time, they must be stopped from working until it is established again.It must be re-emphasised that 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.4.8 Student workersInternational students (those from outside of the EEA) are allowed to work in the UK (including work placements) providing their conditions of entry allow.Student visitors (people entering the UK either as visitors or as students who undertake a period of study of 6 months or less are NOT permitted to undertake work in the UK. This includes work placements that form part of a course/period of study undertaken as a student/child visitor.Students who applied to the Home Office on or after 4 July 2011 on a course at or above NQF 6/QCF6/ SCQF 9 at a UK higher education institution or a short-term study abroad degree programme at an overseas higher education institution are allowed to:• work for up to 20 hours per week during term time• work full-time during vacationsStudents who applied to the Home Office on or after 4 July 2011 on a course below these levels at a UK higher education institution are allowed to:• work for up to 10 hours per week during term time• work full-time during vacationsStudents who applied to the Home Office before 4 July 2011 are allowed to:• work for 20 hours per week if studying a course at or above UK degree level or a foundation degree course, and/or if the Tier 4 (General) application was made on or before 2 March 2010; OR• work for 10 hours per week if studying a course that is below UK degree level and is not a foundation degree course, and the Tier 4 (General) application was made on or after 3 March 2010.• work full-time during vacations.Before employing a foreign student, at the point of registration you now must obtain evidence of the academic term and vacation dates and a letter of confirmation of study. Only the following evidence is considered as acceptable and without these documents you will be unable to place the individual out to work.• A printout from the student’s education institution’s website or other material published by the institution setting out its timetable for the student’s course of study – you should check the website to confirm that this is genuine• A copy of a letter or email addressed to the student from their education institution confirming term dates and details of the students course: or• A letter addressed to Staffline as the employer from the education institution confirming term dates and details of the student’s course.• You should also check that the educational institution is an acceptable travelling distance from the workers living and working locationPage 50

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 51In the event that a student informs you that they have completed their course early, the education sponsor is required to inform the Home Office and the student’s permission to be in the UK will normally be cur-tailed to end earlier, in line with the new end date of their studies. During this time the student is permitted to work full time provided the conditions attached to their permission to study in the UK permitted them to work.Please note that if a student advises you that they have finished their course 6 months early, this does NOT entitle them to work full time for the duration of their original permission to be in the UK. During working time, it is the Consultant’s responsibility to control hours of working to ensure that the appropriate weekly limits are adhered to. In vacation periods, paperwork from the learning establishment will be required to prove that the student is not required to study or attend their classes.The Compliance Team issue a weekly Compliance Breach report that details hours worked by international students. The hours are monitored in order to assess whether a worker has breached their working hour restrictions stated on their Visa. It’s important that both student fields listed below are ticked on the system accordingly, when registering an international student.• Are you a student?• Do you hold a student visa?4.9 False documentsThe Compliance team email any documents believed to be false to UKVI prior to approval, to obtain statutory excuse, then act accordingly depending on response• Positive – candidate can be registered and response is scanned and attached into personal file• Negative – candidate can’t be registered, documents and response are kept on our system for future reference and training purposes. Under no circumstance should you place a person out to work, nor make them aware of our findings if their ID has been confirmed as false by the Home Office.Evidence of individual cases are confidential and would only be available to the customer if the potential candidate is working at that site (i.e. TUPE transfer or work permit extension of current temporary worker/employee). Compliance will keep the site fully updated.4.10 Worker authorisation processAll applicants must have their details recorded on the database system immediately at application. The details entered must include all of the mandatory fields as required, and must be accurately completed, with reference to the position they have applied for. If the worker has registered online or through a tablet then it is the responsibility of the representative to ensure the details have been entered correctly.If, at any point during the registration process an applicant has been rejected, this must also be noted on the worker card in the system, with details of the reasons why added to the notes section. The worker status should be updated to rejected at ad response/interview. It is the responsibility of the Consultant to complete. Records must be kept to assist in resolving allegations of discrimination or inaccurate recruitment practices, as well as monitoring Staffline recruitment procedures.Upon successful completion of the application process, the worker’s details must be updated on the database system immediately. It is the interviewing Consultant’s responsibility to ensure the worker card is fully completed with documentation uploaded in the correct section immediately following the interview.

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 52Compliance will conduct a comprehensive audit at every site at least once a year. During the audit they will be checking sample workers registered at the site to ensure the registration process has been followed correctly as per appendix 1.4.11 Compliance Breach report auditA Staffline location will appear as non-compliant on the weekly Compliance Breach report issued by the Compliance team at Shared Services for any of the following reasons:1. Failing to adhere to registration processes:• None, insufficient or incorrect ID documentation being received• Documentation not being signed off as original seen by the interviewing consultant • ID documentation not being scanned and uploaded to worker card2. Right to work documentation not being sufficiently checked• Failing to check visas to establish the right to work in the UK3. Placing a worker out to work on expired ID or right to work documentation• Worker has been placed to work prior to entering the details on the database system b. Placing a non-EC national to work on expired ID or right to work documentation4. Allowing a worker on a student visa to work for more than the hours stipulated within their conditions of stay5. Workers working excessive hours and so not adhering to the Working Time Regulations6. Client Details Forms must be completed twice a year with the client7. By failing to complete the stipulated forms and upload them to the correct sections of the database system you are in breach of the We Are Compliant Policy and this may lead to Disciplinary Action.All of the above are to be adhered to in accordance with Home Office legislation. If a Staffline representative places a worker out to work for whom they have not received and uploaded the correct right to work documentation, they are knowingly putting a potentially illegal worker out to work.Seven weekly routine checks (see next page) are performed every Wednesday for the previous week’s work. A draft list of non-compliances is produced and distributed to:• The contract manager/coordinator at the site concerned• Their line manager • The divisional directorNB: All of the above points would result in a breach of the We Are Compliant Policy and this may lead to disciplinary action.

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 53Those non-compliances are allocated to a category:• Legal/license requirement – the most serious category, failure to comply has put the business at immediate risk of breaking the law(s)• Staffline Operating Procedure – failure to comply has breached Staffline policy and the continuing breach could result in laws being broken; and• Best/customer practice – no law has been broken, but industry/customer standard is to comply with the activity. The site has until close of play Friday to formally respond to Compliance to explain the reason for the non-compliance. The following Monday morning, the final Compliance Breach report is distributed to the divisional directors. Any site with a non-compliance in the “legal/license” category will be written to individually.The other two categories will be reported on and reviewed on a regular basis.4.12 How to remain compliantPlease refer to separate document on the Compliance SharePoint called How to be Compliant. There are reports within Universe and SQL Operation reports that sites and branches can run to ensure compliance. These reports can be run as many times as you wish.1. Worked prior to approval – (As per appendix 1) With Staffline Universe - Scan, Check, Start giving you the functionality to approve your own workers, there should be no workers appearing on this report. You will be held accountable should the client place the worker out to work without your knowledge, as Staffline would still be held responsible and therefore put us at risk of breaching the law2. ID expired – We recommend you run the ‘Document expiry dates’ report found in custom reports on Universe a minimum of once a month, to ensure that none of your Non-EC workers are placed out to work with an expired ID. It will help you to not only remain compliant but also help you plan the attendance of your workforce as you’ll know if certain workers won’t be available without updated RTW3. Opt out – The Average Hours Report, found within ‘custom reports’ in Universe acts as a warning report for the opt out report. The Working Time Regulations is based on an average of 48 hours worked over a 17 week period. This report allows you to select the weeks you wish to capture and filter to show all those that have worked over the opt out and those that have not agreed to this. For those that appear as working more than they have agreed to, you will be required to stop working them immediately and confirm with them that they are happy to continue and if so, they must amend their opt out agreement on Universe before they re-commence work. This is entirely their choice and you must not force them to work more than they choose to under any circumstance.4. Client Details forms – you are required to complete a Client Details form with your client every six months. Once completed please upload to the customer card in the files section. After this is done please notify the compliance department. You will find the most up to date CDF on the Compliance SharePoint page on Yammer.5. Students – We recommend you run the Student Working Hours report weekly to ensure that none of your Non-EC students work past their Visa restrictions stated on their Visa unless they are on holiday and therefore not in term time6. Worked 12 days plus – The Working Consecutive Days report should be run to ensure that workers are receiving adequate rest breaks. A worker is entitled to receive one day off every 7 days worked and two in 14. A worker should never be asked to work more than 12 days continuous. This report should help you keep a track of how many days in a row your workers have worked

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled7. Worked 78 hours plus – Run the report Workers Instances of Exceeding Hours for your required project code and enter 70 hours. This will generate a warning report. This way you can see if any of your workers are due a day off before it hits 78 hours.For help and advice on new starters, please refer to the document new starter process or call the Compliance Team on 0115 9437844. Further guidance on working hours can be found at https://www.gov.uk/maximum-weekly-working-hours.4.13 Settlement Status1. The UK Government have introduced an EU Settlement Scheme and are inviting applications. If successful this will allow individuals and families to remain in the UK after 30 June 2021.2. Applications are being invited from EU, EEA or Swiss Citizens and/or their family members (EEA also includes Iceland, Liechtenstein and Norway). 3. The following also need to apply:• those born in the UK but who are not a British Citizen• those who have a UK permanent residence document• family members of EU, EEA, or Swiss citizens who do not need to apply (including if they are from Ireland)• EU, EEA or Swiss citizens with a British citizen family member4. Others who may be able to apply include:• someone who used to have an EU, EEA or Swiss family member living in the UK but have separated or the family member has died.• a family member of a British citizen and you lived together • a family member of an EU,EEA or Swiss citizen who also has joint British citizenship 5. Further details on the scheme can be found here: https://www.gov.uk/settled-status-eu-citizens-families/eligibilityPage 54

5WORKER INFORMATION

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled5 WORKER INDUCTION1. A Client Details Form must be completed for each client. It should be reviewed every six months by the Experience Management team to check in with the client contact to make sure that any changes regarding H&S from their perspective have been reflected and updated on the form. This is to conform to GLAA licensing standard 6 on Health & Safety and further guidance is available from the Compliance Team2. A job card must be completed in Universe for each job role that is open for Staffline workers to fill at each of the respective client’s sites, examples of which are available as comparable templates3. It is a legal requirement of both the Conduct of Employment Agencies and Employment Businesses Regulations 2003 and the Gangmasters Licensing standards that workers are issued with the job briefing sheet. Once a worker is inputted to the job planning sheet against this role for the first time they will be emailed an electronic copy of the job briefing, the details of which are taken from the job card4. The job briefing sheet should contain the following legally required information:• The identity of the client, and if applicable the nature of their business• The date the work is to commence and the duration or likely duration of the work• The type of work• Location and hours required to work• The rate of remuneration that will be paid and any expenses payable by or to the temporary worker• Any risks to health and safety known in relation to the assignment and the steps the client has taken to prevent or control such risks• The experience, training, qualifications and any authorisation required by law or a professional body considered necessary by the client or by law to work in the assignment.5. All worker induction requirements and arrangements must be agreed with the client and recorded on the health & safety section of the Client Details Form. The information regarding induction that should be agreed is as follows:• Content of induction training.• Who will carry out the induction training?• In what format will the induction training be delivered?• Where will the induction training take place?• How long should the induction training take?• How will comprehension of H&S training be assessed?• Arrangements for payment for time on induction training?• Arrangements for provision and recording of job specific H&S training?• Recording and storage of induction and job specific training records• Confirmation that the agreed H&S induction and job specific training arrangements cover the risks and controls identified by risk assessments?A copy of the Client Details Form has been included in this manual with guidelines following as to the type of information that needs to be included on the form with further guidance and advice being made available by the Compliance team via email, Yammer and the company Intranet.6. All workers should receive an induction prior to commencing work. This may be immediately after registration or at some other arranged time. If a worker attends induction they must be paid for this time in full• Induction Assessment questionnaire – completed by the worker after the Induction presentation. Marked by a Consultant and wrong answers explained to the workerPage 56

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled7. The induction should consist of:• Induction presentation – to be presented by Staffline Consultant or the Client as agreed• Induction Assessment questionnaire – completed by the worker after the Induction presentation. Marked by a Consultant and wrong answers explained to the worker• All workers on or before their first day at a site should receive a First Day Induction Site Tour conducted by a Staffline representative prior to commencing work. A First Day Induction Record Sheet should be completed by the Staffline representative8. It is the Experience Manager’s responsibility to ensure that all workers are signed off following their induction, using the Staffline Induction Sign Off. This form should only be completed AFTER induction, not at the point of registration, and will be in addition to any other sign-off documentation requested by the customer9. Once completed, the Staffline Induction Sign Off Form is the only one that you will need to scan and upload to the contractor card on the database system in order to comply with the We Are Compliant Policy10. All Job Cards are audited by the Compliance team to ensure that they are fully completed correctly. The completed job card will be cascaded automatically to the job brief which is issued to the worker. If the job card is incorrect or missing information, the job card will not get approved by the Compliance team. Providing incorrect information to the worker, breaches GLAA licensing standard 6, so it is vital this information is accurate and completed in full. Page 57

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledWorker Registration PrinciplesStaffline Representative’s Name ……………………… Location ……….………...............…In the performance of your duties as a representative for the Company you are expected to comply at all times with these principles and the Company Operating Manual (a copy of which you have been provided with):1. Consultants may only interview and register applicants once they have signed this document, attended Company Operating Procedures training and have been approved to do so by their manager2. Consultants may only register applicants in person in a Company / Client interview location approved by the Experience Manager3. Consultants must not allow applicants to complete registration documents on behalf of others nor to take blank registration paperwork out of the interview location4. Consultants must not under any circumstances accept money, favours or any gifts at all from applicants or workers5. No individual who is, or is suspected of acting as, an agent or gangmaster or labour organiser may be used to introduce applicants to the Company. If you suspect that an individual or a business is acting in this manner, including as an unlicensed gangmaster, you must raise these suspicions immediately with your Manager. You must not, where such suspicions exist, under any circumstances, make any arrangements, including for the introduction of workers, with that individual or business6. Consultants must not act as landlords or be involved in the provision of accommodation or transport to work to workers7. Consultants must not use a supplier for labour outside of Staffline without authorisation from their manager in writing and approval from the Compliance Team8. Consultants must not allow an unauthorised agent or individual to introduce job applicants into the Company9. Consultants must notify their manager when they are informed by an applicant or worker that they have paid money to anyone to be introduced to the Company10. Consultants should not register applicants under 16 years of age. Applicants under 18 years of age may only work certain shifts and require specific risk assessments11. Consultants are required to comply with legal requirements when assessing eligibility to work. This policy must be applied to all nationalities to avoid allegations of discrimination12. Nobody other than an authorised Consultant may choose which workers are selected or despatched to work13. Interviews, Registration and Inductions should be conducted in English where possible unless approved by a Manager14. All employees are instructed to raise any knowledge or suspicions of illegal or dubious activities regarding agents, workers or colleagues to the HR Department on 0115 943 7842 immediately. You may be requested to detail the facts and your concerns confidentially in writing15. All recruitment processes and advertisements must not show that any particular nationalities are excluded or treated more favourably than others. All adverts must be advertised in the UK in English as well as being advertised overseas where necessary.Page 58

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 59Samples of Registration documents will be audited during compliance inspections to assess adherence to company procedures. Breach of these rules or failure to inform as instructed above whether deliberately or by omission may, depending on the circumstances and subject to disciplinary investigation and hearing, be regarded as a gross misconduct or gross negligence offence, warranting summary dismissal. Managers who knowingly allow these practices to continue will also be held blameworthy.I confirm that I have read and understood the above principles. I agree to comply with these and to raise any queries regarding their application with my Manager, The People Team or Compliance.Consultant’s Signature………………………………………..… Date………………………….

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 60

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 61

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 62

6AUDITS

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled6 AUDITSThere are two types of audits that you will experience during your time working for Staffline and these are: -External audits – these are carried out by your client or a third-party auditor. Sometimes these audits can be spread between visiting site and NG2 and will mainly look at your site-specific day to day processes on how you manage your workforce and fulfil your clients service requirements in an ethical way and in line with our policies and processes. When some of the audit is completed at NG2 they will be looking at our back office functions too.Internal audits – these are run from Compliance Team, by a team of auditors which are out in the field in their regions to visit our sites and check that our sites are fully compliant. The auditors check that our locations are complying with the internal Company Operating Procedures, the GLAA Licensing Standards, the Conduct of Employment Agencies and Employment Business Regulations and the National Minimum Wage Regulations. 6.1 External auditsOn the occasion that one of our clients audit us at NG2, either directly or through a third party external audit body, a member of our Audit Team will arrange and lead the audit, supported by an operational management representative from that account. This site presence is essential to assist on the site specifics part of the audit and for the relationship with their client. The Compliance Auditor Team commit that any information gathered in the audit will be held confidentially and only be shared with the appropriate stakeholders.There are many different types of audit that may be used in an external audit but there are two very popular versions that you will come across: -6.1.2 SMETAThis stands for Sedex Members Ethical Trade Audit and is one of the most widely used ethical audit formats in the world and is heavily backed by retailers like the big supermarkets. The audit itself is based around Sedex’s four pillars of Labour, Health and Safety, Environment and Business Ethics and incorporates measures in the Ethical Trading Initiative (ETI). The audits are usually two fold, the first part is usually at NG2 where the auditor will look at our policies, certificates and company financials and then the second part at site where the auditor will interview a random selection of workers, have a look around site and have a look at a random selection of worker records. Once the audit is complete, a report is uploaded to our Sedex platform and this is then available for all of our customers on Sedex to view along with any non-conformances. In the event of any minor non-conformance the auditor will advise that we can provide the corrective action through evidence sent over by email, for a major non-conformance we have to have an auditor re-attend to re-audit the non-conformance. All non-conformances on our audits will remain on the platform until they have been closed off.N.B. The SMETA audit is not just carried out on us, it is often carried out on a number of our clients’ sites and the one they have will also involve us as the agency supplying. Please ensure that if you hear that your customer is having one you fully engage and remember that any non-conformances that we pick up go against your client and this could have a negative effect on the relationship.6.1.3 ComplyerThe other main audit tool used by external auditors is the ALP audit tool (called Complyer), this focuses on the GLAA licensing standards, so is used widely in the food industry. We have access to a copy of this audit in Compliance so if you want to read trough the questions before you start then please get in touch with us.Throughout the course of your contract the client may also carry out audits on a regular basis, it is important that you understand the importance of passing these audits to help ensure you have a smooth working relationship with your client.Page 64

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledThere are three main steps to be prepared for an external audit:1. Secure the date of the audit in your diary and ask for a checklist detailing what the auditor will be looking at on the day2. Make sure that you have looked at the checklist in advance to make sure that you have all the correct information in preparation for your audit3. Ensure you have allocated the time aside to assist the auditor on the day and have enough cover in your office.All of the documents that you should need for the audit are on the Compliance SharePoint, located in the Compliance group on Yammer.However, if you can’t see something on there that you need, just contact the Compliance team, and they will assist.Top tips• Welcome the auditor and ensure that you have a room booked, or adequate comfortable space aside for the audit to take place• Be prepared and be calm and confident in the presence of the auditor, take your time to go through the audit, don’t rush through, there is no need and you might miss something, give the time needed to the auditor, they don’t like to feel that they are a nuisance to you• If a non-conformance is identified, don’t panic, listen and take a note so that you know what needs to be rectified• When the audit is completed, ask the auditor when you can expect to receive a report and don’t be afraid to ask for feedback on how they think it went• Learn from the experience, reflect on how you think it went, any changes you would make for the next time?• Non conformances will only be flagged if a process wasn’t in place or up to the standard that the auditor expected, so learn from it, resolve quickly and thoroughly. It could just be a small detail that wasn’t right on the day.If there are non- conformances flagged in your audit report and you are not sure how to resolve them or of your understanding, then just contact the Compliance team and we will help you.6.2 Internal auditsThe Compliance Auditor Team will conduct an audit on each site within Staffline Recruitment Ltd at least once a year in order to provide Senior Management with a high assurance that all areas of the business are working ethically, in line with UK Law and Legislation and to the levels expected internally.Each of the audits will cover the following areas: • Compliance with the National Minimum Wage Regulations• Workers’ Pay and Benefits• Eligibility to Work and Contractual Arrangements• Compliance with the BEIS Regulations• Compliance with the GLAA Licensing Standards• Health and Safety at Work• Transportation of Workers (where appropriate)• Compliance with DVLA Standards (for sites employing drivers)• Site’s understanding of Modern SlaveryPrior to each audit, the Auditor will send to site a letter detailing the date of the audit and a list of documents required on the day of the audit so that they can be prepared. However unannounced audits take place randomly too. Page 65

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledThe consequences of failing an audit can damage not only your relationship with your client, but our reputation too, as the negative impact can make them lose confidence in your ability and they may fear a risk to their brand name. Once the Auditor has attended site they will complete an audit report which will be sent no later than three working days after the date of the audit to the Experience Manager and Regional Experience Manager. The report will advise the site whether they have scored a red, amber or green audit, and advise of a corrective action plan or recommendations if appropriate. In the case of a red audit, the site will then be subject to an un-announced re-audit and this will either be done remotely or through attendance on site dependent on the nature of the non-conformance identified, in these cases, the original audit report will also be sent to the Regional Director and Regional Managing Director.Page 66

7MANAGING WORKER PAYMENTS & DEDUCTIONS

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled6 MANAGING WORKER PAYMENTS AND DEDUCTIONSStaffline is committed to ensuring that every worker is paid in a timely and accurate manner in line with their worked hours and will endeavour to pay all workers on the Friday for the previous week’s worked hours. As a Staffline contractor, holiday pay is accrued based on hours worked and a contractor may book a planned holiday at their own discretion, without this having a detrimental impact upon their eligibility to be selected for further work. For more details on this please see section 8 - Managing Holidays.6.1 Deductions and paymentsA deduction is anything that is taken from a worker’s pay before they receive it.A payment is an amount paid by the worker separate to their pay e.g. by direct debit, etc. and so is not shown on the payslip. We aim to no longer issue cheques to workers and instead, we request that you encourage your workforce to open their own bank account or apply for a pre-paid card to receive their wages each week.6.1.1 Personal Protective Equipment (PPE)• Personal Protective Equipment (PPE) is any piece of clothing or accessory that the worker must wear in order to do their job safely and within hygiene requirements in certain working environments• Staffline will loan the worker, without charge, PPE required for work at client sites• No deduction or payment will be taken for PPE• The actual cost to Staffline of items issued will be deducted if not returned at the end of the contract.6.1.2 Work wear (non-PPE)• Workers who earn in excess of Minimum Wage and for whom the wearing of particular workwear is optional and who are freely able to purchase the workwear from elsewhere. If purchased from Staffline the cost will be deducted from pay but will not take it below minimum wage• Workers on Minimum Wage and for whom the wearing of particular workwear is optional and who are freely able to purchase the workwear from elsewhere – If purchased from Staffline this must not be done by a deduction from wages. A payment method not linked to wages such as direct debit or a cash payment may be made by the worker• Workers who earn in excess of Minimum Wage but must wear workwear or must obtain the workwear from Staffline or the client – Staffline will loan items needed for particular client sites. No deduction or payment will be taken. The cost of items issued will be deducted if not returned in at the end of the contract• Workers on Minimum Wage who must wear workwear or must obtain the workwear from Staffline or the Client – Staffline will loan items needed for particular client sites. No deduction or payment will be taken. The cost of items issued will be deducted if not returned in at the end of the contract.6.1.3 Other work-related itemsThese are items and services necessary to do the job and include: tools; time and attendance swipe cards; locker keys; identity cards / security passes.It also includes services such as medicals; drug & alcohol tests.• Workers on Minimum Wage – Staffline will loan items needed for particular client sites. No deduction or payment will be taken. The cost of items issued will be deducted if not returned in at the end of the contract• Workers who earn in excess of Minimum Wage – An upfront refundable deposit will be taken which will be repaid if you return these items in reasonable condition at the end of the contract.Page 68

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled6.1.4 Optional items• For an item to be genuinely optional it must not be a contractual requirement nor a condition of being offered work that the worker has to purchase the item from Staffline; and the worker freely chooses to purchase the item from Staffline• This would include the use of optional transport• In such cases deductions from wages reduce pay for Minimum Wage purposes but payment methods separate to wages do not• Should the worker wish to use the transport facilities they must complete the Instruction to pay Direct Debits form attached to the Staffline Application Form and sign the appropriate section in the BANK ACCOUNT DETAILS AND PAYMENT AUTHORITY or complete the relevant fields on Universe within the bank details section.6.2 Process for making deductionsWhere it is identified a deduction is allowable for the purchase of an item by a worker or for the purpose of obtaining a refundable deposit, the following conditions will apply:1. The worker must have been issued with, have had explained and signed a Deduction Authority Form2. Explain to the worker that in order to comply with National Minimum Wage rules, if it is not possible to deduct the full amount due in the first available pay period, then the amounts deducted will be spread over a series of pay periods3. The cost of the item charged to the worker must not exceed the item cost to Staffline (exclusive of VAT)4. Once completed and signed, the location must forward a copy of the signed deduction authority to Payroll, provide a copy of the form to the worker, and retain the original copy on the workers file5. The branch/site will process the deduction(s) as appropriate6. Payroll and Compliance will audit all deduction requests to ensure that they fall within the National Minimum Wage rules and also the legislation for taking deductions from wages. Should the deduction request not meet the legislative requirements, the deduction request will be rejected and returned to the site / branch with the reason why it has been refused.6.3 Deductions for overpaymentsWhere a worker has been overpaid in error, prior to any recovery of the overpayment, the worker must:a. be informed of the amount they have been overpaid; andb. be informed of our intention to recover the full amount in the next available pay period; and c. have agreed to the recovery of the overpayment by signing a Pay Advance / Overpayment Recovery Form.In the event the worker objects to having the full amount recovered in the first available pay period, a repayment schedule must be agreed with the worker that is reasonable and acceptable to both Staffline and the worker.Where agreement cannot be reached with a worker at the location the matter should be escalated to Staffline HR.6.4 Recovery for non-returned itemsWhere a worker has paid a refundable deposit, or an item has been provided free of charge to a worker, the company may retain the deposit or charge the worker from wages owed (including any outstanding holiday entitlement), in the event they:1. Fail to return an item provided following completion of the relevant assignment(s) for which the item was required; or2. Fail to return the item on the termination of their employment.Page 69

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPayroll will automatically P45 any worker for whom they are advised to make a deduction for non- return of items. If Payroll need to reinstate the worker because they are in fact continuing to work they will refund the worker for the money deducted.Such deductions are allowable without further notification to the worker and will not affect pay for National Minimum Wage purposes.6.5 Other DeductionsThere are certain circumstances where deductions have to be taken for items / situations that do not fall within the normal workwear / locker key / swipe cards deductions. These could be driver fines, training costs or deductions for accommodation. Deductions for accommodation is only permissible in the Agriculture Sector where the workers are living on site at the farm. Should you need to process a deduction in any of the above scenarios, please contact the Compliance Team who will be able to advise how to process these types of deductions and the forms that will need to be completed.All deductions sent to the Payroll department will be audited by both Payroll and Compliance and any that are requested by site that are unlawful deductions will be rejected and the site informed.Page 70

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 71Deduction / Payment Authority FormInformation for WorkersStaffline will loan you, without charge, Personal Protective Equipment (PPE) required for work at client sites. The cost of items issued will be deducted if you fail to return these in reasonable condition at the end of the contract.Staffline will loan you required workwear, locker keys, swipe cards etc. needed for particular client sites. If you earn in excess of the minimum wage an upfront refundable deposit will be taken for such items which will be repaid if you return these items in reasonable condition at the end of the contract. If you are paid at minimum wage there will be no deposit taken but the cost will be deducted if you fail to return these items in reasonable condition at the end of the contract.You may be given the choice to purchase workwear which is optional to wear i.e. not required by Staffline or the client. If you choose to purchase this and earn in excess of the minimum wage you may have the cost deducted from your pay in a way that does not take it below minimum wage. If you choose to purchase this and are paid at minimum wage you will be required to make a separate payment.Items issuedNumber of itemsCost per item £PurchaseDepositRecoveryPPE - Size:Safety footwearHi Vis JacketHi Vis VestHard HatEar DefendersWellington BootsLightweight Waterproof SuitWaterproof TrousersWaterproof JacketWork WearAbove NMWNMWRequired work wear can only be Recovery. Optional work wear is Payment on NMW or Deduction of above NMWJacketT-ShirtTrousersEquipmentAbove NMWNMWLocker KeySwipe CardIdentity CardWorker’s Authority to DeductFor purchased items – I am aware the items are optional and have freely chosen to purchase the items from Staffline. I authorise Staffline to deduct the cost of items above in total or via instalments so as not to reduce my pay below minimum wage. Where pay is at minimum wage I have made a separate payment.For items where a deposit has been paid – I understand that deposits will be refunded if I return the item in a reasonable condition. I authorise Staffline to deduct the deposits above in total or via instalments so as not to reduce my pay below minimum wage.For non-returned items recovered from final monies due – I authorise Staffline to deduct from any pay due to me the cost of items provided to me and not returned in a reasonable condition at assignment completion.Worker Name:Signature:Date:Emp no: Office use only

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 72Overpayment Recovery FormI confirm that:• I have received an overpayment of wages of £............................ gross from Staffline.• I agree and authorise for Staffline to make deductions to recover the amount from my net pay in accordance with the following schedule:Pay weekAmount to deduct££££££If in any pay week my pay is not sufficient to enable Staffline to deduct the amount specified, I authorise outstanding monies due to be deducted in any subsequent pay period.Worker Name:Worker’s SignatureDate:Representative Name:Representative Signature:Date:

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 73HMRC RegulationsOur obligation as an employer is to make sure that at least the NMW rate is paid to all our workers. This rate increases year on year and we must keep in line with the changes of the hourly wage and ensure we do not breach the National Minimum Wage Regulations (NMW) 1999.Working timeThe regulations detail ‘Time’ work, this is where a worker is available at or near a place of work. Time work includes hours when a worker is available, and required to be available, at or near a place of work for the purposes of working unless the worker is at home. Any time spent at the workplace for our workers, per-forming work related duties is classed as working time and is to be paid time to all.Examples of tasks classed as working time:1. Queuing to get into the workplace2. Going through a security gateBoth procedures must be undertaken by the worker for them to be at work.More examples of tasks classed as working time:1. Getting changed into Personal Protective Equipment / Clothing (PPE)2. Washing hands before starting work3. Attending an induction / training for the jobAll these tasks are undertaken in preperation to start work.Rest breaksIt is important to remember that break times for our workers must be taken in full, to give them the ap-propriate downtime they need to rest. This means that any time taken for a worker to prepare themselves to get ready to take their break which is determined by the site rules, must be paid time to the worker, so should not eat into their allocated break time.One common example of this is at some workplaces, workers when leaving the production area, must take off their PPE & wash their hands before leaving the area to go into the canteen.End of shiftIf any such duties such as getting changed out of their PPE ready for site departure need to be completed, then this time must be considered too. Workers should not be performing any work-related tasks that we ask them to do as mandatory to follow our site rules in their own unpaid time.Unlawful deductionsDeductions from a worker’s pay can reduce pay for NMW purposes.PPE: We cannot deduct at time of issue, can only deduct if they do not return it at the end of their contract and have authorised us in writing to deduct the cost of the items.Transport: We can only deduct via Direct debit. We cannot deduct from their wages directly and must be agreed by the worker for the transport option.Lateness: If our workers are late, we must not round up to the next 15 minutes past the hour to pay them from. We must pay them by the minute.

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 74Getting it right, first time, every time. Points to remember• Paying our workers correctly should be second nature to us, take your time and be confident that you have captured all of your workers hours in your weekly payrolls• Be compliant with the NMW regulations, a breach cannot only be costly but would also cause Staffline huge reputational damage• Take a moment to think, if you are asking your workers to undertake a task, its classed as working time, if in doubt, call the compliance team for advice.A NMW breach and the cost for our business• For a NMW breach with the HMRC, a business will be issued with a notice of underpayment which includes a requirement not only to make good any underpayment but also to pay a financial penalty which can be up to 200% of the arrears, capped at £20,000 per worker. • The underpayment includes remediation for all workers affected in the breach up to x 6 years back pay. In other words, all workers that have not been paid for that time over the last 6 years have to be allocated the amount of pay that have been missed. This is likely to be thousands of pounds.Reporting inIf you need any advice on how to be compliant to the HMRC regulations, then please email the compliance team on [email protected] are more than happy to help and support you and your site.If you spot a breach of the NMW / HMRC regulations, then please call:• Compliance team immediately on 0115 943 7844• Steve Samson our Compliance Manager on 07966 833436 • Jane Bladon, our Compliance Director on 07976 928975

8ACCOMMODATION

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled8 Accommodation for Staffline workersStaffline does not provide or effectively provide accommodation for workers. However, in order to assist some workers, especially those that may be arriving from their home countries, and who have not made any arrangements for accommodation, Staffline will assist in pointing workers towards suitable letting agents within the local area.Workers are and must always remain free, to choose their own accommodation, and many will utilise friends and family initially with regards to accommodation until such time as they are settled into working in the UK.For those that have not made any arrangements, Staffline will provide a list of local letting agents, via a disclaimer that workers may choose to approach for accommodation if they so wish. Staffline have no ongoing relationship or contract with any of these letting agents and do not get involved with facilitating the landlord/tenant relationship. As per the overseas recruitment process the letting agent agrees housing terms, handles the deposit, and assists with all other accommodation related activities. Staffline is not involved with any financial transaction with the letting agents.In view of the fact that Staffline maintains high ethical standards, checks are made in all cases to ensure that the requirements within GLAA Standard 4.1 (Quality of Accommodation) are met by all letting agents who offer accommodation to Staffline workers. The Staffline Compliance Team ensure that all agent lists are regularly reviewed and that any issues or complaints by workers are urgently investigated. If the findings are negative and especially in cases where workers may be put at risk by unsafe accommodation or overcrowding for example, then the letting agent would be removed from the list offered to any future workers. For guidance in case of any reported issues by Staffline workers GLAA Standard 4.1 states:The accommodation must be maintained in a good state of repair, must contain adequate kitchen, bathroom and any toilet facilities for the number of occupants and must not be overcrowded. Any category 1 hazards as assessed under the Housing Health and Safety Rating System must be properly resolved.The details of what constitutes a Category 1 accommodation hazard can be found below within this link:https://www.derby.gov.uk/media/derbycitycouncil/contentassets/documents/policiesandguidance/DASHLL29HazardsBooklet.pdfAdverse media in terms of accommodation for any Staffline worker can result in brand damage so it is important that all Staffline employees report any serious issues immediately to the Compliance Team. Page 76

9AGRICULTURAL WORK

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled9 Agricultural workStaffline has a number of contracts with clients within agriculture and with the peaks and troughs associated with seasonal produce, demand for workers varies throughout the year in different parts of the UK. Agricultural workers can, dependant on where they are located, be subject to different legislation and in particular rates of pay, which is set according to the role they perform.There is an AWO (Agricultural Wages Order) in force in Wales, Scotland and Northern Ireland so any Staffline worker working within agriculture in any of these countries will come under this current legislation.An agricultural worker is described as someone who works in:• Farming and rearing animals• Growing produce including non-edible crops like bulbs, plants and flowers• Forestry, market gardens and nurseries• Maintaining meadow or pasture land, woodlands and reed beds. It is likely that most Staffline workers will come under that described within the second bullet point, as pickers, or planters of fresh produce destined for the retail market. Staffline employees should be aware of the relevant legislation within the particular country where the worker is supplied to the client and more detailed guidance can be found here:https://www.gov.uk/agricultural-workers-rightsAs the agricultural sites to which workers are deployed are often remote, accommodation may also be offered by the client for the duration of the workers’ contract. Although Staffline remains the workers’ employer throughout, the provision of this accommodation is considered to be contractual and as such the accommodation offset would apply, which is a deduction of a maximum amount per week (currently £52.85).Further guidance can be found here:https://www.gov.uk/national-minimum-wage-accommodation/accommodation-chargesIf the accommodation provided to the Staffline workers by the client is in caravans (which is common amongst agricultural workers and sites) then there is additional and specific guidance to be aware of.Most sites if large enough, will, and should be registered with the local authority and all should adhere to strict regulations in terms of safety. Additional risks are posed by shared cooking facilities, gas canisters and general site issues that can and do result in accidents.Additional guidance on these rules and regulations and in particular safety can be found here:https://public-library.safetyculture.io/products/fpc-accommodation-self-assessment-checklistPage 78

10MANAGING WORKING HOURS

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled10 MANAGING WORKING HOURS10.1 The legal & ethical requirementsThe Working Time Regulations give workers the following rights and protections:1. The right not to be required to work on average more than 48 hours per week averaged over a 17 week period2. The right to 11 hours’ rest period per day3. The right to a day off per week or two days off in fourteen4. A right to an in-work rest break of 20 minutes if the working day is longer than 6 hours (30 minutes after 5 ½ hours in agriculture)5. For night workers – If your assignment requires you to regularly work for at least three hours between 23.00 and 06.00, you have the right to work a limit of an average of eight hours work in 24-hour period, averaged over 17 weeks and the right to request a free health assessment to confirm your fitness for night work.The Ethical Trading Initiative Base Code 6.2 states:6.2: In any event, workers shall not on a regular basis be required to work in excess of 48 hours per week and shall be provided with at least one day off for every 7 day period on average. Overtime shall be voluntary, shall not exceed 12 hours per week, shall not be demanded on a regular basis and shall always be compensated at a premium rate.N.B. This is a requirement of the ETI Base Code, to which most retailers are signatory to and to which they audit across their supply chain.The GLAA Licensing Standards require:Critical – A licence holder must not force or coerce a worker to work against their will.5.1 Major – A worker must be able to take legal minimum rest periods.5.2 Major – A worker must not be forced to work more than 48 hours a week on average unless they agree to work beyond this limit. Any agreement must be voluntary, in writing and signed by the worker. A worker must be free to amend or cancel this agreement, subject to notice requirements.10.2 Applying the Working Time Requirements• In accordance with their contractual terms, workers on a Contract for Services are not obliged to accept any assignment offered by Staffline• Staffline consultants must not force, pressurise or coerce workers into working against their will• Staffline consultants must not threaten a worker with any detriment if a worker refuses to work a particular shift or overtime• Arrangements with regard to the management of working hours should be agreed with the client and recorded on the Client Details Form• Staffline location managers should implement appropriate monitoring and control systems to ensure that working hours are managed in accordance with client or Staffline requirements• Workers who feel coerced into working any hours against their wishes or who are not provided with statutory rest breaks are invited to contact their Staffline representative or, in confidence, the Staffline Helpline on 0115 9437844• Please see the separate rules for working hours for young workers.Page 80

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled10.3 The right not to be required to work on average more than 48 hours per week• Staffline consultants shall manage their accounts such that workers shall not on a regular basis work in excess of 48 hours per week• Staffline consultants shall manage their accounts such that workers shall not work in excess of 60 hours per weekN.B. These two limits above are as per those set in the ETI Base Code and are not a legal requirement. Where the client has a culture of high working hours it shall be a commercial decision by the appropriate Staffline manager as to whether these limits are exceeded. However this is the limit to which the retailers’ supply chain are expected to adhere and in all cases this should be a subject of dialogue and agreement between Staffline and the client• Workers shall indicate their 48 hour opt in / opt out preference on the application form• Payroll monitor working hours and particularly those who have not opted out and who are averaging 45 hours or more worked per week over the last 17 week period. Staffline consultants should approach such workers for them to consider their position regarding the 48 hour opt out• Workers who have not opted out of the 48 hour working limit who have exceeded the 48 hour limit will appear on the Payroll report and their working hours should be limited to ensure that they fall below the 48 hour limit.10.4 Night work• A night worker is someone who regularly works at least three hours during the “night period”. The “night period” is usually between 2300 and 0600• Workers can also be classed as “Night Workers” if there is a collective agreement (eg Trade Union Agreement) that states that their work is “Night Work”• Additional rules apply to “Night Workers” hours. A “Night Worker” may not exceed an average of 8 hours work per 24 hours. The average is typically worked out over 17 weeks but it can be over a longer period up to 52 weeks as long as the client and workers agree, e.g. by Collective Work Force Agreement. If the “Night Worker” does regular overtime then this has to be included in the average calculation. If the overtime is not regular and only occasional then this should not be included in the average calculation• A “Night Worker” may not exceed an average of 48 hours per week averaged over the applicable reference period• The process for calculating these hours can be found at http://www.direct.gov.uk/en/Employment/Employees/WorkingHoursAndTimeOff/DG_174557• Staffline consultants shall manage their accounts as such that workers shall not work in excess of these requirements• To comply fully with the Working time regulations and HSE rules, we must provide all of our night workers moving forward with this option to a free health assessment, in the form of the questionnaire• You will see the option on the questionnaire for the worker to sign box F if they choose not to complete and decline the offer, this is their choice and fine for us to accept. This form is the site responsibility to get completed by all of their night workers• This is not something that we have to back track to get all of our workers to sign, just for all new starters moving forward, however if you choose to ask your current workforce to complete these, that’s entirely up to you• Also, whether you choose to ask all candidates to complete this form at the interview/ registration process, or separately to give out to just your night worker new starters, again this is up to you to put in place whatever process suits• To keep in-line with our paperless working policy, please shred the form once completed and scanned onto the workers card in the system, accessible in the event of an audit or HSE reported accidentPage 81

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled• If the situation arises that the worker gives detail on the questionnaire to a health issue that either he/she or you are concerned about, then if your client has an occupational health department, then feel free to ask them if they can assess the workers condition to advise further, or you could refer them to their own GP for a check and a fit note to declare them fit for night work. The first option is the easiest and less cost.• As mentioned in the Compliance Toolkit, all night workers must be offered a night working questionnaire. This can be in the form of a paper document or via the supplementary application found within Agreements on Universe. Although it is optional for them to complete, the legal requirement for us, as their employer, is to at least offer it to them. Therefore, it is your responsibility to ensure your workers are made aware of the questionnaire and advise accordingly.10.5 Daily and weekly breaks• Staffline consultants should ensure that all workers have an in-work rest break of 20 minutes if the working day is longer than 6 hours. N.B. There is no requirement for this break to be paid• Staffline consultants shall manage their accounts such that workers have one day off per week or two days off in fourteen• Staffline consultants shall manage their accounts such that workers do not work excessive hours in a day. Workers have a right to 11 hours’ rest period per day.10.6 Young workers’ hours• A young worker is a person who is between 16 and 18 years of age• Should a young worker be employed, a Young Persons Risk assessment needs to be completed prior to starting work• A young worker is not allowed to work more than 8 hours per day, more than 5 days per week and is not allowed to work on a nightshift• A young worker must have a 30 minute rest break after 4.5 hours at work• More information on employing young workers can be found in the Human Resource Operating Procedures guide.Page 82

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 83

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 84

11TERMINATION OF CONTRACT

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolled11 TERMINATION OF CONTRACT11.1 RetirementThe Company has no normal retirement age for workers. In practice, if workers are fit and able for work they should be allowed to register and be able to continue working. Fit and able should be construed in terms of workers’ ability to perform work and not their age.11.2 Termination of contract – workers on Contract for ServicesThe worker may terminate their contract with Staffline at any time, either verbally or in writing without any period of notice.Staffline may terminate the worker’s contract at any time, either verbally or in writing without any period of notice.To process a worker as a leaver and to generate the issue of a P45 the Staffline consultant should open the relevant Universe contractor card and select a leave date. In all cases enter the reason for leaving and a comment on the worker’s performance.Payroll will then automatically print the P45 and will either post direct to the worker or send to the relevant Staffline office accord to the instruction on the P45 request sheet.If the P45 is delivered to the branch/OnSite a comment should be entered in the relevant notes section of the worker card: ‘P45 received from Head Office’ and the worker called to let them know it is waiting to be picked up. File it in a secured filing cabinet so only the authorised people in the office have access to it when the worker comes to pick it up.Workers can also set their profile to left by logging onto Universe and setting a leave date.11.3 Termination of contract – employees on Contract of EmploymentIf the employee has been employed by Staffline for less than one month, they are not required to give any notice of termination. However, they are required to put their request in writing to the Staffline representative. If Staffline wish to terminate their employment contract, no notice is required.If the employee has been continuously employed for between one month and two years by Staffline, they are required to give the Company one week’s notice in writing of their decision to resign. If the employee has been continuously employed for more than two years, they are required to give an additional week’s notice per year of employment, up to a maximum of 12 weeks’ notice.The same terms of notice apply if Staffline wish to terminate the contract of employment, with up to 12 weeks’ notice to the employee in writing.If the employee only advises Staffline verbally of their wish to resign, and refuses to put their notice in writing, it is advisable for the consultant to write to the employee confirming their verbal resignation, citing date and time it was given.If a Contract of Employment is being terminated by Staffline due to the outcome of a disciplinary process, notice periods for termination of contract may not apply.11.4 Auto P45 processWhere a worker has not done any work for 13 complete weeks, the Payroll system is set to automatically generate a P45 which is posted to the Worker’s home address.Page 86

APPENDIX 1 - COMPLIANCE TOOLKIT

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledContentsDocument details82Transition to using trailblazing technology82Establishing a Statutory Excuse82Using the Staffline Universe - Scan, Check, Start application and your role83Non-EU workers87Right to Work Checklist (UKVI)88Universe requirements89Reports92Document detailsDocument HistoryVersionDateAuthorAmendments0.119/06/2019Steven SamsonInitial draft1.020/06/2019Steven SamsonUpdates following feedback2.024/06/2019Steven SamsonUpdates following feedback3.028/06/2019Steven SamsonUpdates to terminology and additional information under table (B)4.005/07/2019Steven SamsonTable (B) updated and reinstatement process added5.026/07/2019Steven SamsonTable (A) updated6.010/10/2019James RdzanekTable (B) updated and Non-EU Students information updated6.123/12/2019James RdzanekNew OnePay procedure and updates to DVLA and Companies House checks procedures6.221/01/2020James RdzanekReinstatement Process updatedPage 88

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledTransition to using trailblazing technologyOur biometric right to work checking technology know as Staffline Universe - Scan, Check, Start is a fantastic application that gives you the functionality to approve your own workers without the need for Compliance to double check the ID is acceptable. However, with great power comes great responsibility! There are still many processes that need to be followed in order for your workers to become compliant and the responsibility will lie with those using the application, checking the worker profiles and approving on the system for work. This guide has been created to help you with the transition into using the application and details further work that is required to remain compliant.We plan on using this trailblazing technology to optimise performance across the business which in-turn will help deliver an unprecedented level of customer service to our clients and workers.It will allow you to get candidates out to work quicker than ever, to meet your client requests and free your time to focus on the customer experience.Establishing a Statutory ExcuseEstablishing a Statutory Excuse protects the business from a Civil Penalty and potential imprisonment for the person responsible for placing someone out to work with a fraudulent ID or without correct right to work in the UK. You must ensure that the ID scanned by the app is the ORIGINAL and not a copy of the ID.There are 3 easy steps to remember on how to establish a statutory excuse:Penalties can include:1. Up to £20,000 fine per illegal worker2. Employers can face up to five years in prison for ‘knowingly’ employing an illegal worker and an unlimited fine3. Can have a negative impact on Staffline and client’s brand 4. Closure of the businessPage 89

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledThe application does provide us with a statutory excuse if used correctly with the original ID but the below personal validations section on Universe needs to be completed for all workers to protect the business and our workers:Using the application and your roleFollowing on from the ‘Biometrics Right to Work Guide’ when checking the response of the application you must ensure you only approve those with the correct right to work.Page 90GREEN: If the result is green, you need to tick the approval verification box in the Worker Portal to confirm that the right to work check adheres to Company Policy (Shown on the next page).Please note: Double check the document and ensure all information on the ID match that on the system inc; Nationality, DOB, Expiry date, Names etc. are accurate before proceeding with approval verification process.AMBER: Means additional checks required. Please complete these checks as per your Compliance training. Once done you can then self-certify as per the green flag process. Not all Ambers can be accepted (Please refer to tables A and B in this document for clarity).Please note: Double check the document and ensure all information on the ID match that on the system inc; Nationality, DOB, Expiry date, Names etc. are accurate before proceeding with approval verification process.

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledFraudulent IDShould you believe the candidate has provided you with fraudulent ID, please do not make the person aware of your suspicions and proceed with the registration as normal. Under no circumstance should you offer them work. Please contact Compliance via the method above or email/call for an urgent response and Compliance will advise on the next steps.Approval verification processOnce yes has been selected, the worker will appear as compliant on Universe.Please ensure that the image taken using the application captures the whole ID with no parts cut off the scan or parts covered accidentally.We are aware that some sites may only have one phone with multiple different users to process the result. Should there be a non-compliance revolving the outcome, the site will have to confirm to Compliance who was accountable for the breach.Responsibility to Brand SafetyIt’s vital the application is used in the correct way to protect our business and ensure we are in-line with UK Visas and Immigration (UKVI) legislation. Please do not click ‘Yes’ as shown above if you are not confident that the candidate has provided you with adequate right to work in the UK. The person using the application to conduct right to work and facial similarity checks is solely responsible for ensuring the app is used correctly, in-line with our user guides, company policy and UKVI Legislation (Official UKVI checklist provided in this guide). Page 91RED: Means stop. Contact the Compliance team via selecting ‘No’ to the approval verification section and send a Compliance request through who will advise on further actions if needed.Please note: If ‘No’ is selected and a Compliance request is sent, the worker will appear in the Compliance portal to verify the applications response. The deadline to provide a response is 48 hours during workdays. Please only send through if you have doubts over the applications response. If the result shows that the ID provided is non-genuine then please refer to Compliance as described, and Compliance will report the worker to the Home Office accordingly. If the result is green, tick the Yes button here.

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 92The person approving the worker on Universe is responsible for ensuring that the ID outcome and facial similarity checks are acceptable as per above. They are also responsible for checking Universe Requirements on the workers’ profile are completed in full, prior to approving and therefore, prior to sending out to work (full details on Universe Requirements provided in this guide).Using the application and your role continuedWe’ve created 2 tables below to help guide you when using the application. It details which colour will be flagged for a specific ID that is scanned and what additional documents are needed.A. Outcome response guide to acceptable documentsB. Outcome response guide to non-acceptable documentsPlease refer to these tables when using the application for clarity on what we can/cannot accept.Outcome response guide to acceptable documents (A)National CategoryID CategoryFlagOutcomeBritish Expired/valid PassportGreenOK to approve without further documentation as long as it bears a true resemblanceEUExpired/valid PassportGreenOK to approve without further documentation as long as it bears a true resemblanceEUExpired/valid ID CardGreenOK to approve without further documentation as long as it bears a true resemblance. Both sides of ID card must be scanned and uploadedBritish/IrishBirth/Adoption certificateAmberProof of NI required (Must be Government issued or doc issued by a previous employer (Pay slip, P45 etc.)Non-EUCertificate of NaturalisationAmberProof of NI required (Must be Government issued or doc issued by a previous employer (Pay slip, P45 etc.)Non-EUForm for affixing VisaAmberProof of NI required (Must be Government issued or doc issued by a previous employer (Pay slip, P45 etc.)Non-EUImmigration Status DocumentAmberProof of NI required (Must be Government issued or doc issued by a previous employer (Pay slip, P45 etc.)Non-EUResidence DocumentationAmberCan be accepted in an expired or valid passportNon-EUTier 3 Visa (Paper)AmberNeeds to be held in a valid passport and passport scanned as proofNon-EUTier 4 Visa (Paper)AmberNeeds to be held in a valid passport and student paperwork requiredNon-EUTier 5 Visa (Paper)AmberNeeds to be held in a valid passport and passport scanned as proofNon-EUTier 3 Visa (BRP)AmberVisa needs to be validNon-EUTier 4 Visa (BRP)AmberVisa needs to be valid and student paperwork requiredNon-EUTier 5 Visa (BRP)AmberVisa needs to be valid

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 93Non-EUGeneral non-Tier VisaAmberPlease refer to the remarks stated on the Visa. If the Visa states that no-work is permitted, then we cannot acceptNon-EUEmployer Checker Service (ECS)N/AStaffline Universe - Scan, Check, Start is not configured to check an ECS – If the ECS has been completed by a Staffline rep and has received a positive verification then this will be OK to accept. Please note that the ECS needs to be scanned to UniverseEUBlue Residence PermitN/AStaffline Universe - Scan, Check, Start is not configured to check this document. This can be accepted as right to work in the UK. This is issued for EU Nationals only and would not be issued to other nationalities.Please note: 1. Damaged or tampered ID – We cannot accept the described documents as per UKVI ruling2. Change of Name documents - Staffline Universe - Scan, Check, Start is not configured to check these documents – we can accept the following alongside a Birth Certificate and proof of NI; Deed Poll, Decree Absolute and Marriage Certificates. There must be a clear link between the change of names and the ID provided3. NI proof - When scanning an NI card as proof of NI, you must ensure that both sides are scanned and uploaded4. Facial similarity and impostors – you must be satisfied that the document belongs to the person presenting the document to avoid employing imposters in our business. The application will help you with this aspect of checking IDs.5. Facial similarity and old ID - If the application does not recognise the person from the ID provided compared with the person in front of you but you are sure that they are the same, you can by-pass the response and approve but you must be satisfied that the document belongs to the person presenting the document.Outcome response guide to non-acceptable document (B)National CategoryID CategoryFlagOutcomeNon-EUEEA FP VisaAmberCannot accept - Application will flag this as Amber as the worker may have right to work but this ID does not provide Staffline with a statutory excuse and therefore we cannot acceptNon-EUEU Settlement Scheme Family PermitAmberCannot accept - Application will flag this as Amber as the worker may have right to work but this ID does not provide Staffline with a statutory excuse and therefore we cannot acceptNon-EUTier 1 Visa (Paper)AmberCannot accept - Application will flag this as Amber as these types of visas are valid forms for Right to Work documentation for somecompanies. However, Staffline cannot accept

Non-EUTier 1 Visa (BRP)AmberCannot accept - Application will flag this as Amber as these types of visas are valid forms for Right to Work documentation for somecompanies. However, Staffline cannot acceptNon-EUTier 2 Visa (Paper)AmberCannot accept - Application will flag this as Amber as these types of visas are valid forms for Right to Work documentation for somecompanies. However, Staffline cannot acceptNon-EUTier 2 Visa (BRP)AmberCannot accept - Application will flag this as Amber as these types of visas are valid forms for Right to Work documentation for somecompanies. However, Staffline cannot acceptNon-EUAlien PassportRedCannot accept - Worker needs to provide valid Visa alongside this documentNon-EUTravel DocumentRedCannot accept - Worker needs to provide valid Visa (an Immigration Status Document is OK)Additional information on table (B): Alien Passports and Travel Documents cannot be accepted. These may look like acceptable documents but please ensure that any passport checked specifically states ‘Passport’ and nothing else. A tip is to also check the nationality stated on the ID matches the ID provided.Please note: Some of the above types of documents in table (B) will appear as Amber on the app as somecompanies can accept them but they cannot be accepted by Staffline due to the nature of our business and the Visa stipulations, which can include the type of work they are permitted to do, thus prohibiting them from working for Staffline. This has been advised by UKVI. If you are unsure of any documents, please refer to these tables or contact your Regional Compliance contact for guidance.If you are provided with one of the above IDs and therefore cannot accept them, please ensure you select ‘No’ to the ‘Please confirm if the right to work check outcome adheres to Company Policy’ as shown opposite.Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 94

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 95Non-EU WorkersThe Eligibility for work section is required for all Non-EU workers that require Visas – ‘Yes’ will need to be selected for both ‘Do you need a work permit to work in the UK?’ and ‘Do you hold a work permit?’ Once actioned you’ll see an option for type of work permit and an expiry date field pop up which both need completing.The expiry date needs to be inputted accurately to avoid a Civil Penalty for someone working with an expired Visa. Please ensure the ID that is due to expire first is inputted into this field; (this is applicable for documents that are inter-dependant on each other to prove right to work in the UK i.e. Passport and paper Visa).Non-EU studentsThe last two questions need to be selected as ‘Yes’ if the Non-EU worker is a student. If these are not selected, we’ll be unable to monitor their hours worked to ensure they do not work past their restricted hours as stated on their Visa, thus potentially breaking the law. (See Reports section further in guide for more details).Should someone work more than their restricted hours or on an expired Visa, Staffline could be found liable for a Civil Penalty. This would result in disciplinary action for the individual responsible, so take extra care when completing this section to avoid any non-compliances.Student paperwork is required to show proof of confirmation of study and the students’ academic term and vacation dates. The official Home Office guidance states that they consider acceptable evidence originating from the education institution which is sponsoring the student to be one of the following:1. A printout from the student’s education institution’s website or other material published by the institution setting out its timetable for the student’s course of study, (you should check the website to confirm the link is genuine); or2. A copy of a letter or email addressed to the student from their education institution confirming term time dates for the student’s course; or3. A letter addressed to you as the employer from the education institution confirming the term time dates for the student’s course.We recommend asking for updated student paperwork every six months as best practice. Please get in contact with Compliance if you are unsure of what you can accept.

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledRight to work checklist (UKVI)The below tables show you more detailed information on what you can accept, based on the most up-to date employers guide to right to work checks, found on the UK Visas and Immigration website below:https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/773780/An_employer_s_guide_to_right_to_work_checks_-_January_2019.pdfPage 96

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 97Please use these checklists for further information on acceptable documents.Universe requirementsAside checking acceptable right to work, you will also need to ensure that the Universe requirements have been fulfilled before approving your candidates for work. Please follow this guide for the minimum requirements to become compliant.Personal Information: You will need to ensure that all the information within the worker profile is accurate, this will aid us with our Modern Slavery / labour exploitation investigations and ensure we are adhering to our company regulators.

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledSome of the key fields include:• Name of worker• Date of birth• Nationality• Expiry dates (Including driving documentation)• Working Time Regulations opt-out• Contact details• Email address – each worker should have a valid email address• Eligibility for work section (Applicable to Non-EU workers).Validations: All validations need to be completed (four (4) for non-drivers and six (6) for drivers) The validations are found at the bottom within the Personal Information, Skills & Experience and (For drivers only) Licence, taco and CPC tabs, example below:Profile Percentage: The profile needs to be completed to show as 100%. If the profile shows as anything less, you will notice the reasons known as ‘Registration issues’ shown underneath the percentage bar. These will need to be amended before approving.Page 98

Document Number: CP049 Company Operating Procedures for Managing Workers – May 2020All printed copies are uncontrolledPage 99Agreements: The agreements will need to be completed if paperwork is no longer used at the site. The basic agreements consist of the Contract, Application Form (Extended Application Details) and Night Worker Questionnaire (NWQ – Supplementary application). The below shows an example of a completed agreements section for a PAYE/Non-driver example: Please note: The applicable Contract and Extended Application Details need to be completed.The Supplementary Application (NWQ) is optional and therefore does not need to be completed but MUST be offered at the very least, if they are a night worker.Limited Company Workers – You must ensure that a Companies House check is completed for all Ltd workers within your workforce. This check must show that the company is active, and the worker is a director of the business. A Companies House check must be carried out every three (3) months and uploaded to Universe. Please also double check that the worker is using a business bank account rather than personal. This must be stated to show a clear audit trail in case you are asked to evidence your due diligence during an audit. Ltd company workers and drivers will have other options within the agreements section that are applicable to their work and must be completed. Please see below example of an outstanding agreements section for an Ltd/driver example: Bank Details: The bank details must fall in-line with our bank account policy as per our COPs. Under no circumstance should we pay more than two people into one bank account. If the bank account holders name is not that of the worker, then they must be related and both working for Staffline. The Universe number of the account holder and the relationship of the workers to prove that they are both working for Staffline and related, must be stated to show a clear audit trail in case you are asked to evidence your due diligence during an audit.