Handbook SWG

5.2 When considering your application the following are examples of the factors that will be taken into account:(a) The purpose of, or reasons for, the career break.(b) The period of absence requested.(c) Your performance record.(d) The number and length of any previous career breaks taken.(e) The operational needs of our business.(f) The need to retain your skills, knowledge and experience.(g) Our ability to cover your duties on a temporary basis.(h) The potential benefits of the proposed career break.5.3 We will try to respond to your request in writing within 10 working days of receipt of your writtenapplication.5.4 We may hold a meeting to discuss your request if we think this will be helpful.5.5 If your request for a career break is refused we will explain the reasons for our decision. If you believe youhave been unreasonably refused a career break or have been victimised for requesting one, you may raise agrievance under our Grievance Procedure.5.6 If we accept your request we will write to confirm the start and return dates for your career break and willset out the changes to your terms of employment. You must sign and return a copy of the letter to accept thechanges and until this is received your career break will not have been agreed.6. CONDITIONS FOR TAKING A CAREER BREAK6.1 Career breaks can be granted for up to 2 years.6.2 In order to take a career break you will have to resign from employment. Where practicable we will returnyou to the job in which you were employed before your career break, although this cannot be guaranteed. If wecannot return you to the same job we will take reasonable steps to find you a similar job to that in which youworked before your break. After you return, your employment will be treated as continuous with the periodbefore the career break.6.3 In some cases, we may only be able to agree to a career break on condition that you remain available:(a) To cover for holidays, sickness absence or to assist during peak workloads.(b) To attend training courses or meetings to be updated on workplace developments.(c) To visit the workplace on up to 20 keeping-in-touch days each year, pro-rated if your career break is for lessthan a year.(d) You may in some circumstances be permitted to take more than one career break while working for usprovided that there has been a gap of at least 5 years since returning from your last career break and the totaltime taken by way of career breaks does not exceed 3 years. A fresh application must be made under this policyfor each career break requested.7. DURING A CAREER BREAK7.1 Where possible, you will be given at least one month notice of any requirement to attend work and anykeeping-in-touch days during your career break. These will be paid at the rate of pay applicable before the startof your career break and any period of work during a career break will count towards your service-relatedVersion 1 07/08/2018Document Control: BDM J Gough

benefits.7.2 [Unless specifically agreed at the time your career break is approved, you will not be obliged to do any workor attend any events during a career break and will not be penalised for declining to do so; nor is your linemanager or a senior manager obliged to offer you work while you are on a career break. Any arrangements forworking during the career break must be agreed with your line manager or HR including the work to be doneand arrangements for payment. Work could include any activity done under the contract of employment, butmay also include training or other events.7.3 You will share in the responsibility for keeping in touch with us and with your department during your careerbreak. We will keep you up to date with changes in policy, personnel, developments and news and publicationsby sending updates to you. You should make arrangements to be kept up to date with developments with yourline manager. You are expected to maintain any professional links and to keep up to date with any significantdevelopments in your area of work.7.4 You must tell your line manager or HR about any change of address or other contact or personal detailsduring your career break.7.5 In the event that during your absence the role from which you are taking a career break is affected byreorganisation, restructuring or redundancy, every effort will be made to consult with you as appropriate.7.6 You must obtain prior written approval from a Director before undertaking paid work for anyone else duringyour career break.8. RETURNING FROM A CAREER BREAK8.1 We are committed, as far as is reasonably practicable, to offering you priority consideration for any postwithin the same undertaking doing the same type of work at the same grade as you carried out before yourcareer break.8.2 When approving your request for a career break we will agree when you will need to contact us before yourreturn date to confirm arrangements. It is likely to be 8 weeks before your return date.8.3 Consideration will be given to a request to return earlier than an agreed date although it may not be possibleto accommodate such a request.8.4 If you are prevented from returning to work on your return date due to ill-health, you must contact HR assoon as possible in accordance with our Sickness Absence Policy.8.5 If you are unable to return to work in accordance with previously agreed arrangements for any reason otherthan ill-health you must immediately contact your line manager or HR. In exceptional cases, consideration mightbe given to extending the period of your career break, providing that your overall period of absence does notexceed 2 years.8.6 If you wish to terminate your employment while on a career break, unless the amount of notice requiredfrom you to do so has been varied by agreement with us, you will be required to give notice in accordance withthe terms of your contract.8.7 On your return your line manager and SHEQ Manager will organise for you to attend a re-induction process.This will include training on any new systems or procedures that have been introduced during your absence andbriefing on any changes that have taken place that will affect you.Version 1 07/08/2018Document Control: BDM J Gough

SCHEDULE 27TIME OFF FOR TRAINING POLICY1. ABOUT THIS POLICY1.1 We are committed to developing the skills of our employees and recognise that training can benefit us andour staff. Staff should receive training appropriate to their role, subject to business need, operational andbudgetary considerations.1.2 Eligible employees also have a statutory right to request time off work for study or training. The purpose ofthis policy is to provide a framework within which we can consider those requests.1.3 No-one who requests time off under this policy will be subjected to any detriment or lose any careeropportunities as a result.1.4 This policy does not form part of any employee’s contract of employment and we may amend it at any time.2. WHO IS COVERED BY THIS POLICY?2.1 This policy applies to employees. It does not apply to agency workers, consultants or self-employedcontractors.2.2 Some employees aged 18 or under are subject to special laws on education and training, and may not becovered by this policy, depending on their age and qualifications. Further information about training for youngemployees is available from the HR department.3. PERSONNEL RESPONSIBLE FOR THIS POLICY3.1 The board has overall responsibility for the effective operation of this policy and for ensuring compliancewith the relevant statutory framework. Day-to-day responsibility for operating the policy and ensuring itsmaintenance and review has been delegated to the Business Development Manager.3.2 Managers have a specific responsibility to ensure the fair application of this policy and all members of staffare responsible for supporting colleagues and ensuring its success.3.3 Managers are responsible for identifying and monitoring staff training and development needs on anongoing basis. Employees who wish to undertake any form of training relevant to their role should raise thematter informally with their managers in the first instance.4. WHEN CAN STAFF REQUEST TIME OFF TO TRAIN?4.1 To be eligible to make a formal request under this policy, you must:(a) be an employee;(b) have worked for us continuously for 26 weeks at the date your request is made;(c) have made no previous formal requests under this policy in the last 12 months.4.2 We will ignore the fact that a request was made less than 12 months ago in the following circumstances:(a) if we agreed to the earlier request but the training was cancelled or you were unable to start it because ofunforeseen circumstances that were not your fault; or(b) if you withdrew the earlier request because it was not valid.5. WHAT TYPE OF TRAINING IS COVERED?5.1 Any type of study or training can be requested under this policy. It does not matter how or where it takesplace. For example, it could be:Version 1 07/08/2018Document Control: BDM J Gough

(a) training provided in the workplace;(b) a one-day training course provided by an external training provider;(c) a part-time college course;(d) an online training module (e-learning);(e) a distance learning course.5.2 The study or training does not need to lead to a formal qualification. The only limitation is that it must befor the purpose of:(a) improving your effectiveness at work; and(b) improving the performance of our business.6. MAKING A FORMAL TIME OFF TO TRAIN REQUEST6.1 To make a formal request under this policy you should submit it in writing to your line manager or HRdepartment. Please include the following information:(a) a statement that the request is made under this policy or under section 63D of the Employment Rights Act1996;(b) the date of the request;(c) the subject matter of the study or training;(d) where and when it would take place;(e) who would provide or supervise it;(f) what qualification (if any) it would lead to;(g) how you think the study or training would improve your effectiveness at work;(h) how you think the study or training would improve the performance of the business; and(i) if you have made any previous application under this policy, the date of that application and how it was made(for example, whether it was by email or letter and who you sent it to).6.2 If we agree to your request without the need for a meeting, we will tell you in writing and include theinformation in Paragraph 8.1.6.3 We will treat your request as withdrawn if:(a) you tell us you are withdrawing the request;(b) you fail to attend two meetings under Paragraph 7 or Paragraph 10 without reasonable cause; or(c) you unreasonably refuse to provide information we need to consider your request.In those cases your line manager or HR will write to confirm that your request has been treated as withdrawn.You will not normally be able to make another formal request for 12 months from the date of your originalrequest (see Paragraph 4).Version 1 07/08/2018Document Control: BDM J Gough

7. MEETING7.1 Your line manager will arrange to hold a meeting with you at a mutually convenient time and place, usuallywithin 28 days of receiving your formal request (unless Paragraph 7.2 applies or we have agreed a longer timelimit in writing under paragraph 11). The meeting may also be attended by a member of the Human ResourcesDepartment.7.2 If the person who would ordinarily hold the meeting is on annual leave or sick leave at the time of yourrequest, the meeting will be held within 28 days of their return or within 8 weeks of your request, whichever issooner. If necessary you should contact the Human Resources Department or Business Development Managerwho will appoint someone else to hold the meeting.7.3 The meeting will be used to discuss your request and, if appropriate, explore any alternatives.7.4 You may bring a colleague to the meeting as a companion if you wish. Your companion may speak duringthe meeting and confer privately with you, but should not answer questions on your behalf.7.5 If your chosen companion is unable to attend at the time set for the meeting, you should contact your linemanager and we will try to rearrange the meeting. If the meeting cannot be rearranged within seven days of theoriginal date, we may suggest that you bring a different companion or come alone.7.6 We will tell you our decision in writing within 14 days of the meeting unless we have agreed a longer timelimit in writing (see Paragraph 11).8. IF WE AGREE TO YOUR REQUEST8.1 Where we agree to all or part of your request we will give you a written and dated notice containing thefollowing information:(a) which part of your request is agreed;(b) if any part is not agreed, the information in Paragraph 9.1;(c) the subject of the agreed study or training;(d) where and when it will take place;(e) who will provide or supervise it;(f) what qualification (if any) it will lead to;(g) any changes to your working hours in order to accommodate the agreed study or training;(h) whether you will be paid for carrying out the study or training;(i) how any tuition fees or other direct costs of the agreed study or training will be met.8.2 In some cases we may suggest changes to your request. For example, we may suggest a different course ofstudy or training, or we may suggest an alternative time or place. These may be discussed at the meeting or mayrequire discussion afterwards. The written notice of our decision will set out any changes that you have agreedto. We will ask you to sign and return a copy of the notice to show your agreement.8.3 We do not have to pay you while you are taking time off for study or training requested under this policy,unless this is necessary in order to comply with minimum wage legislation. However, in some cases we mayagree to pay you for some or all of the time off.8.4 We do not have to pay the costs of study or training requested under this policy (including any associatedcosts such as travel expenses). However, in some cases we may agree to meet some or all of those costs.Version 1 07/08/2018Document Control: BDM J Gough

9. IF WE REJECT ALL OR PART OF YOUR REQUEST9.1 Where we reject all or part of your request, we will give you a written and dated notice containing thefollowing information:(a) which part of your request is rejected;(b) if any part is agreed, the relevant information in Paragraph 8.1 above;(c) which of the grounds for rejection set out below applies and why; and(d) the appeal procedure.9.2 We may reject your request for any of the following reasons:(a) that the proposed study or training would not in our view improve your effectiveness at work and theperformance of the business;(b) the burden of additional costs;(c) detrimental effect on ability to meet customer demand;(d) inability to reorganise work among existing staff;(e) inability to recruit additional staff;(f) detrimental impact on quality;(g) detrimental impact on performance;(h) insufficiency of work during the periods that you propose to work;(i) planned structural changes; or(j) any other reasons that the Government sets out in future regulations.10. APPEAL10.1 You may appeal if we reject all or part of your request. Your appeal must:(a) be in writing and dated;(b) set out the grounds on which you are appealing; and(c) be sent to the Human Resources Department or a Director no more than 14 days after you receive thewritten notice of our decision.10.2 We may decide to uphold your appeal in full without a meeting. In all other cases, the Human ResourcesDepartment will arrange for an appeal meeting to take place within 14 days of receiving your appeal, unless wehave agreed a longer time limit in writing (see Paragraph 11). The meeting will be held at a convenient time forall those attending and you may bring a colleague as a companion.10.3 The appeal meeting will be held by a member of the senior management team. Your manager and/or amember of the Human Resources Department may also be present.10.4 We will tell you the outcome of the appeal in writing within 14 days of the meeting, unless we have agreeda longer time limit in writing (see Paragraph 11). That decision will be final and you will not be able to makeanother formal request until 12 months after the date of your original request.Version 1 07/08/2018Document Control: BDM J Gough

10.5 If we uphold your appeal, we will give you the information set out in Paragraph 8.1 above.10.6 If we reject your appeal, we will explain our reasons to you in writing.11. IF WE NEED MORE TIMEThere may be exceptional occasions when it is not possible to adhere to the time limits in this policy. Forexample, we may need to delay holding a meeting or notifying you of the decision. We will ask for youragreement to extend the time limit, and will confirm in writing any agreement reached. In many cases this willbe in your interests as it will enable the appropriate person to consider your request properly.12. CHANGES TO AGREED STUDY OR TRAINING ARRANGEMENTS12.1 You must tell us in writing immediately if:(a) you do not start the agreed study or training for any reason (for example, if it is cancelled);(b) you do not complete the agreed study or training; or(c) you undertake (or wish to undertake) a different course of study or training.12.2 You should also tell us immediately if you become aware of any changes to agreed study or training,including changes to the timing or content of the course.Version 1 07/08/2018Document Control: BDM J Gough

SCHEDULE 28TIME OFF FOR PUBLIC DUTIES POLICY1. ABOUT THIS POLICY1.1 We wish to enable employees to perform any public duties that they may be committed to undertake andso will give them time off to do so where it does not conflict with the operational needs of our business. We arenot legally obliged to grant paid leave for these purposes. The circumstances in which we are prepared to do soare set out below.1.2 This policy applies to all employees.1.3 This policy does not form part of any employee’s contract of employment and we may amend it at any time.2. PERSONNEL RESPONSIBLE FOR IMPLEMENTING THE POLICY2.1 The board has overall responsibility for the effective operation of this policy and for ensuring compliancewith the relevant statutory framework. Day-to-day responsibility for operating the policy and ensuring itsmaintenance and review has been delegated to the Business Development Manager.2.2 Managers have a specific responsibility to ensure the fair application of this policy and all members of staffare responsible for supporting colleagues and ensuring its success.3. JURY SERVICE3.1 You should tell your line manager as soon as you are summoned for jury service and provide a copy of yoursummons if requested.3.2 Depending on the demands of our business we may request that you apply to be excused from or defer yourjury service.3.3 We are not required by law to pay you while you are absent on jury service. You will be advised at court ofthe expenses and loss of earnings that you can claim. However, we will pay basic pay to employees on juryservice less any amounts you can claim from the court for lost earnings for up to 10 working days. Time offbeyond 10 working days may be paid at our discretion.4. VOLUNTARY PUBLIC DUTIES4.1 Employees are entitled to a reasonable amount of unpaid time off work to carry out certain public duties,including duties as a tribunal member, magistrate, local councillor, member of an NHS Trust, prison visitor, policestation lay visitor or school governor.4.2 If you are unsure whether a public service that you perform is covered by this policy you should speak tothe Human Resources Department.4.3 As soon as you are aware that you will require time off for performance of a public service you should notifyyour line manager, Accounts Department or the Human Resources Department in writing, providing full detailsof the time off that is being requested and the reasons for your request. In order that arrangements can be madeto cover your duties in your absence you should make your request in good time.4.4 Each request for time off will be considered on its merits taking account of all the circumstances, includinghow much time is reasonably required for the activity, how much time you have already taken, and how yourabsence will affect the business.4.5 We may grant you up to 5 days’ paid leave in any 12-month period to perform public duties that are notpaid. Any additional leave will be granted on an unpaid basis subject to the exercise of our discretion to grantfurther paid leave.5. RESERVE FORCES DUTIES5.1 We are aware that employees who are members of the Reserve Forces (the Territorial Army, Royal NavyVersion 1 07/08/2018Document Control: BDM J Gough

Reserve, Royal Marines Reserve or Royal Auxiliary Air Force) may be called-up at any time to be deployed onfull-time operations, and are expected to attend regular training.5.2 We offer up to 10 days special unpaid leave per year (in addition to existing paid holiday entitlements) forreservists to undertake training. In exceptional circumstances we may grant additional unpaid leave in order forthese commitments to be met.5.3 If we receive notice that you have been called-up for active service we may apply to an adjudication officerfor the notice to be deferred or revoked if your absence would cause serious harm to our business (which couldnot be prevented by the grant of financial assistance).5.4 Once your military service has ended you may submit a written application for reinstatement to youremployment. This should be made by the third Monday following the end of your military service and you shouldnotify us of the date on which you will be available to restart work.5.5 If it is not reasonable and practicable to reinstate you into your former employment we will offer you themost favourable alternative on the most favourable terms and conditions which are reasonable and practicable.5.6 When calculating the length of your continuous employment with us, the period of absence on militaryservice will not be counted. The period of employment before your mobilisation and the period after yourreinstatement will be treated as continuous.Version 1 07/08/2018Document Control: BDM J Gough

SCHEDULE 29ADVERSE WEATHER AND TRAVEL DISRUPTION POLICY1. ABOUT THIS POLICY1.1 This policy applies where it becomes impossible or dangerous for employees to travel in to work becauseof:(a) extreme adverse weather such as heavy snow;(b) industrial action affecting transport networks; or(c) major incidents affecting travel or public safety.1.2 On these occasions we recognise that a flexible approach to working arrangements may be necessary toaccommodate the difficulties employees face and to protect health and safety, while still keeping the businessrunning as effectively as possible.1.3 This policy applies to all employees. It does not apply to agency workers, consultants or self-employedcontractors.1.4 This policy does not form part of any employee’s contract of employment and we may amend it at any time.2. TRAVELLING TO WORK2.1 Employees should make a genuine effort to report for work at their normal time. This may include leavingextra time for the journey and/or taking an alternative route. Travel on foot or by bicycle should be consideredwhere appropriate and safe.2.2 Employees who are unable to attend work on time or at all should telephone their line manager or a seniormanager before their normal start time on each affected day.2.3 Employees who are unable to attend work should check the situation throughout the day in case it improves.Information may be available from local radio stations, the police, transport providers or the internet. Ifconditions improve sufficiently, employees should report this to their line manager or a senior manager andattend work unless told otherwise.2.4 Employees who do not make reasonable efforts to attend work or who fail to contact their manager or asenior manager without good reason may be subject to disciplinary proceedings for misconduct. We willconsider all the circumstances including the distance they have to travel, local conditions in their area, the statusof roads and/or public transport, and the efforts made by other employees in similar circumstances.3. ALTERNATIVE WORKING ARRANGEMENTS3.1 Employees may be required to work from home, where possible, or from an alternative place of work, ifavailable. Line managers or a senior manager will advise them of any such requirement. Such employees willreceive their normal pay.3.2 Employees who are able to work may sometimes be expected to carry out additional or varied duties duringsuch periods. However, employees should not be required to do anything they cannot do competently or safely.4. LATE STARTS AND EARLY FINISHES4.1 Employees who arrive at work late or who ask to leave early will usually be expected to make up any losttime. Managers have the discretion to waive this requirement in minor cases, or (in the case of lateness) wherethey are satisfied the employee has made a genuine attempt to arrive on time.4.2 Managers have the discretion to allow staff to leave early and should have regard to the needs of thebusiness and the employee’s personal circumstances.Version 1 07/08/2018Document Control: BDM J Gough

4.3 Where half the normal working day or more is lost this will be treated as absence and dealt with as set outbelow.5. ABSENCE AND PAY5.1 Employees who are absent from work due to extreme weather or other travel disruptions are not entitledto be paid for the time lost.5.2 However, as a gesture of good will, we will treat up to three days of absence caused by disruption in anyannual leave year as special paid leave. Employees will only be eligible where their line manager or a seniormanager is satisfied that they have made a genuine effort and could not reasonably be expected to attend workor work at home.5.3 Absence in all other cases can be treated in a variety of ways. Employees should discuss their preferencewith their line manager, who retains overall discretion in the matter. A number of options are set out below:(a) Treating the absence as annual leave. [If not enough annual leave entitlement remains, an employee maychoose to borrow up to two days from the next leave year.](b) Treating the absence as flexitime or time off in lieu.(c) Making up the lost hours within a reasonable time.(d) Treating the absence as special unpaid leave.5.4 If, in exceptional circumstances, we decide to close the workplace, employees will be paid as if they hadworked their normal hours.6. SCHOOL CLOSURES AND OTHER CHILDCARE ISSUES6.1 Adverse weather sometimes leads to school or nursery closures or the unavailability of a nanny orchildminder.6.2 In cases such as these where childcare arrangements have been disrupted, employees may have a statutoryright to reasonable time off without pay. For further information, see our Time Off for Dependants Policy.Version 1 07/08/2018Document Control: BDM J Gough

SCHEDULE 30HEALTH AND SAFETY POLICY STATEMENTHealth and Safety at Work etc Act 1974This is the Health and Safety Policy Statement of SWG Construction (BUILD& RENOVATE) Ltd.As Managing Director, I will commit the company to the highest standards of Health and Safety and willcomply with all statutory duties on Health and Safety.This company will provide Safe and Healthy Working Conditions for our employees and the self-employedworking under our control and will ensure that the conduct of their work does not endanger employees ofothers and the public.Sufficient time and resources will be allowed for health and safety and the Company will: • Ensure adequate risk assessments have been carried out and appropriate measures are in place to control potential risks arising from the work activities. • Consult with our employees on matters affecting their health and safety. • Provide and maintain safe plant and equipment and require contractors to similarly satisfy requirements. • Ensure safe handling, use of substances, and safe disposal of any surplus or generated waste • Provide information, instruction and supervision for employees. • Ensure tools and work equipment are fit for purpose and operatives are trained, competent and authorised to use such tools and equipment. • Ensure all employees are competent to do their tasks, and source adequate training as necessary and appropriate. • Aim to prevent accidents and cases of work-related ill health. • Maintain safe and healthy working conditions. • Ensure that any deliberate breach of health and safety rules and procedures lead to disciplinary action. • Review and revise this policy annually.As Managing Director, I will set a good personal example to others in complying with duties lay upon me andwill expect all employees to co-operate with the company in respect of this policy to ensure this it is carriedout.The full and signed Health and Safety Policy is available from the SHEQ Manager or Business Development Manager.

SCHEDULE 31NO-SMOKING POLICY1. ABOUT THIS POLICY1.1 We are committed to protecting your health, safety and welfare and that of all those who work for us byproviding a safe place of work and protecting all workers, service users, customers and visitors from exposureto smoke.1.2 All of our workplaces (including our vehicles) are smoke-free in accordance with the Health Act 2006 andassociated regulations. All staff and visitors have the right to a smoke-free environment.1.3 This policy covers all employees, officers, consultants, contractors, volunteers, trainees, casual workers andagency workers. Anyone visiting our premises or using our vehicles must comply with the smoking restrictionsset out in this policy.1.4 This policy does not form part of any employee’s contract of employment and it may be amended at anytime.1.5 If you wish to suggest improvements to the policy or experience particular difficulty complying with it youshould discuss the situation with your line manager or Business Development Manager.2. PERSONNEL RESPONSIBLE FOR IMPLEMENTING THE POLICY2.1 The board has overall responsibility for the effective operation of this policy and for ensuring compliancewith the relevant statutory framework. Day-to-day responsibility for operating the policy and ensuring itsmaintenance and review has been delegated to the Business Development Manager.2.2 Managers have a specific responsibility to ensure the fair application of this policy and all members of staffare responsible for supporting colleagues and ensuring its success.3. WHERE IS SMOKING BANNED?3.1 Smoking is not permitted in any enclosed or substantially enclosed premises within our workplace. The banapplies to anything that can be smoked and includes, but is not limited to, cigarettes, electronic cigarettes, pipes(including water pipes such as shisha and hookah pipes), cigars and herbal cigarettes.3.2 No-smoking signs are displayed at the entrances to enclosed or substantially enclosed premises at ourworkplace.3.3 Anyone using our vehicles, whether as a driver or passenger, must ensure the vehicles remain smoke-free.Any of our vehicles that are used primarily for private purposes are excluded from the smoking ban.4. WHERE IS SMOKING PERMITTED?You may only smoke outside in designated areas during breaks. When smoking outside, you must dispose ofcigarette butts and other litter appropriately in the receptacles provided.5. BREACHES OF THE POLICY5.1 Breaches of this policy by any employee will be dealt with under our Disciplinary Procedure and, in seriouscases, may be treated as gross misconduct leading to summary dismissal.5.2 Smoking in smoke-free premises or vehicles is also a criminal offence and may result in a fixed penalty fineand/or prosecution.Version 1 07/08/2018Document Control: BDM J Gough

SCHEDULE 32STRESS AT WORK POLICY1. ABOUT THIS POLICY1.1 We are committed to identifying, tackling and preventing the causes of work-related stress and to providingappropriate support and consideration to staff suffering from stress, on a confidential basis where appropriate.In particular, we will:(a) Promote a culture of open communication, participation and encouragement. Through training, effectiveplanning and allocation of workloads and ensuring feedback is provided on performance, we want staff todevelop their skills and confidence and to feel able to raise any concerns they have about their work or workingenvironment.(b) Use staff development, staff support systems and policies reflecting current good practice to help staffunderstand and recognise the causes of stress and to address work-related stress and the impact of externalstressors at work.(c) Provide a workplace free from harassment, bullying and victimisation.(d) Address violence, aggression and other forms of inappropriate behaviour through disciplinary action.(e) Ensure risk assessments include or specifically address workplace stress.(f) Maintain an appraisal process to ensure the suitability of workloads, supported by a capability procedure.(g) Facilitate requests for flexible working where reasonably practicable in accordance with our Flexible WorkingPolicy.(h) Follow comprehensive change management procedures.(i) Provide support and signposting for staff affected by or absent by reason of stress.1.2 This policy covers all employees, officers, consultants, contractors, volunteers, trainees, casual workers andagency workers.1.3 This policy does not form part of any employee’s contract of employment and we may amend it at any time.2. PERSONNEL RESPONSIBLE FOR THE POLICY2.1 2.1 The board has overall responsibility for the effective operation of this policy and for ensuringcompliance with the relevant statutory framework. Day-to-day responsibility for operating the policy andensuring its maintenance and review has been delegated to the Business Development Manager. We willmonitor the development and dissemination of good practice, the recognition of the symptoms of stress,awareness of and effectiveness of this policy to ensure it is achieving its stated objectives.2.2 All managers have a responsibility and will be given training on best practice and are encouraged to seekadvice from a Mental Health First Aider on how to recognise stress in the staff they manage.2.3 You must ensure that you familiarise yourself with the policy and act in accordance with its aims andobjectives. You must speak to your manager if you experience or are aware of a situation that may lead to astress problem. You must plan and organise your work to meet personal and organisational objectives and co-operate with support, advice and guidance you may be offered by a Mental Health First Aider, your line managerand/or the Human Resources Department.3. WHAT IS STRESS?3.1 Stress is the adverse reaction people have to excessive pressures or demands placed on them. Stress is notan illness but, sustained over a period of time, it can lead to mental and/or physical illness.Version 1 07/08/2018Document Control: BDM J Gough

3.2 There is an important distinction between working under pressure and experiencing stress. Certain levels ofpressure are acceptable and normal in every job. They can improve performance, enable individuals to meettheir full potential and provide a sense of achievement and job satisfaction. However, when pressure becomesexcessive it produces stress.3.3 Pressures outside the workplace, whether the result of unexpected or traumatic events such as accidents,illness, bereavement, family breakdown or financial worries, can result in stress. They can also compound normalworkplace pressures.3.4 We recognise that what triggers stress and the capacity to deal with stress varies from person to person.Individuals react to similar situations in different ways.4. LEGAL OBLIGATIONS4.1 We have a legal duty to take reasonable care to ensure that your health is not put at risk by excessivepressures or demands arising from the way work is organised.4.2 This policy takes account of our obligations under the Health and Safety at Work etc Act 1974, Managementof Health and Safety at Work Regulations 1999, Employment Rights Act 1996, Protection from Harassment Act1997, Working Time Regulations 1998 and Equality Act 2010.5. SUPPORT5.1 We have measures in place to assist staff who may be suffering from stress:(a) Training on stress management, to assist staff and managers in recognising and coping with stress.(b) Mental Health First Aiders who can provide information and signpost staff to additional support services.(c) SWG Wellness Scheme encouraging a healthy mind and body in and outside of work.5.2 Managers should work with the Human Resources Department and the SWG Wellness Scheme to providesupport to staff suffering from stress. They should:(a) Promote a culture of open communication and encouragement.(b) Effectively plan and provide feedback on performance.(c) Ensure that staff receive necessary training.(d) Monitor workloads and reallocate work where necessary to avoid harmful levels of stress.(e) Ensure that staff understand the standards of behaviour expected of them and others, and act on behaviourthat falls below those standards.6. RESOLVING STRESS6.1 If you believe you are suffering from stress you should discuss this with your manager or a member of theSWG Wellness Scheme in the first instance. If you feel unable to do so you should contact a Mental Health FirstAider.6.2 Once an issue affecting your health comes to the attention of SWG, steps will be taken to address that issue.Those steps may include any of the following:(a) A workload review, reallocation of work, monitoring of future workload or possible redeployment. OurCapability Procedure may be applied.(b) Where appropriate, investigation under our Disciplinary and/or Grievance Procedures.(c) Referral for medical advice, treatment and/or a medical report to be any specialist or GP who has beenVersion 1 07/08/2018Document Control: BDM J Gough

treating you.(d) If you are on sickness absence, discussion of an appropriate return to work programme. Our SicknessAbsence Policy may be applied.7. ABSENCE DUE TO STRESS7.1 If you are absent due to stress you should follow the sickness absence reporting procedure contained inyour contract and/or our Sickness Absence Policy.7.2 In cases of prolonged or repeated absence the procedure set out in our Sickness Absence Policy and/orCapability Procedure will apply.8. CONFIDENTIALITY8.1 Confidentiality is an important part of this policy. Every member of staff is responsible for observing thehigh level of confidentiality that is required, whether they are suffering from stress, supporting a colleague whois suffering from stress or because they are otherwise involved in the operation of a policy or procedure dealingwith stress.8.2 Breach of confidentiality may give rise to disciplinary action.8.3 However, there are occasions when matters reported by a member of staff suffering from stress may haveto be put to third parties. For example, where duties need to be reallocated within a team or where, as the resultof reported bullying or misconduct, a disciplinary investigation and/or proceedings take place. If this is the case,matters will be discussed with the member of staff concerned before any action is taken.9. PROTECTION FOR THOSE REPORTING STRESS OR ASSISTING WITH AN INVESTIGATION9.1 Staff who report that they are suffering from stress, who support a colleague in making such a report orwho participate in any investigation connected with this policy in good faith will be protected from any form ofintimidation or victimisation.9.2 If you feel you have been subjected to any such intimidation or victimisation, you should seek support fromyour line manager, the Human Resources Department and/or SWG Wellness Scheme. You may also raise acomplaint in accordance with our Grievance Procedure.9.3 If, after investigation, you are found to have provided false information in bad faith, you will be subject toaction under our Disciplinary Procedure.Version 1 07/08/2018Document Control: BDM J Gough

SCHEDULE 33SUBSTANCE MISUSE POLICY1. ABOUT THIS POLICY1.1 We are committed to providing a safe, healthy and productive working environment. This includes ensuringthat all staff are fit to carry out their jobs safely and effectively in an environment which is free from alcohol anddrug misuse.1.2 The purpose of this policy is to increase awareness of the effects of alcohol and drug misuse and its likelysymptoms and to ensure that:(a) All staff are aware of their responsibilities regarding alcohol and drug misuse and related problems.(b) Staff who have an alcohol or drug-related problem are encouraged to seek help, in confidence, at an earlystage.(c) Staff who have an alcohol or drug-related problem affecting their work are dealt with sympathetically, fairlyand consistently.1.3 This policy is not intended to apply to “one-off” incidents or offences caused by alcohol or drug misuse ator outside work where there is no evidence of an ongoing problem, which may damage our reputation, andwhich are likely to be dealt with under our Disciplinary Procedure.1.4 We recognise that some of our staff may become dependent on alcohol or drugs. We also recognise thatsuch dependencies can be successfully treated. We wish to promote a culture which understands and issympathetic to the problems associated with alcohol and drug misuse in which staff with dependency problemsare encouraged to seek help and are supported. We also will not accept staff arriving at work under the influenceof alcohol or drugs, and/or whose ability to work is impaired in any way by reason of the consumption of alcoholor drugs, or who consume alcohol or take drugs (other than prescription or over the counter medication, asdirected) on our premises.1.5 This policy covers all employees, officers, consultants, contractors, volunteers, trainees, casual workers andagency workers.1.6 This policy does not form part of any employee’s contract of employment and we may amend it at any time.2. PERSONNEL RESPONSIBLE FOR THIS POLICY2.1 The board has overall responsibility for the effective operation of this policy and for ensuring compliancewith the relevant statutory framework. Day-to-day responsibility for operating the policy and ensuring itsmaintenance and review has been delegated to the Business Development Manager.2.2 All managers have a specific responsibility to operate within the boundaries of this policy, to ensure that allstaff understand the standards of behaviour expected of them and to take action when behaviour falls below itsrequirements.2.3 Managers will, if appropriate, be given training in:(a) The nature and causes of alcohol and drug problems.(b) The effect of alcohol and drug misuse on workplace safety and performance.(c) The assistance that can be provided by outside agencies.3. IDENTIFYING A PROBLEM3.1 If you notice a change in a colleague’s pattern of behaviour you should encourage them to seek assistancethrough their manager, The SWG Wellness Scheme or the Human Resources Department. If they will not seekhelp themselves you should draw the matter to the attention of your manager. You should not attempt to coverVersion 1 07/08/2018Document Control: BDM J Gough

up for a colleague whose work or behaviour is suffering as a result of an alcohol or drug-related problem.3.2 If you believe that you have an alcohol or drug-related problem you should seek specialist advice andsupport as soon as possible.4. ALCOHOL AND DRUGS AT WORK4.1 Alcohol and drugs can lead to reduced levels of attendance, reduced efficiency and performance, impairedjudgement and decision making and increased health and safety risks for you and other people. Irresponsiblebehaviour or the commission of offences resulting from the use of alcohol or drugs may damage our reputationand, as a result, our business.4.2 You are expected to arrive at work fit to carry out your job and to be able to perform your duties safelywithout any limitations due to the use or after effects of alcohol or drugs. In this policy drug use includes theuse of controlled drugs, psychoactive (or mind-altering) substances formerly known as “legal highs”, and themisuse of prescribed or over-the-counter medication.4.3 You should not drink alcohol during the normal working day, at lunchtime, at other official breaks and atofficial work-based meetings and events. Drinking alcohol while at work without authorisation or working underthe influence of alcohol may be considered serious misconduct.We expect you to demonstrate responsible behaviour at work, work-related functions and work-related socialevents and to act in a way that will not have a detrimental effect on our reputation. If you entertain clients orrepresent us at external events where alcohol is served, you are considered to be “at work” regardless ofwhether you do so outside normal working hours. Consequently, we will expect you to remain professional andfit for work at all times.Managers should act to prevent excessive consumption of alcohol by any member of staff and should take stepsto deal with any unacceptable conduct. Any such behaviour may lead to disciplinary action.4.4 You must comply with drink-driving laws and drug-driving laws at all times. Conviction for drink-driving ordrug-driving offence may harm our reputation and, if your job requires you to drive, you may be unable tocontinue to do your job. Committing a drink-driving or drug-driving offence while working for us or outsideworking hours may lead to action under our Disciplinary Procedure and could result in dismissal.4.5 If you are prescribed medication you must seek advice from your GP or pharmacist about the possible effecton your ability to carry out your job and whether your duties should be modified or you should be temporarilyreassigned to a different role. If so you must tell your line manager or the Human Resources Department]without delay.5. SEARCHES5.1 We reserve the right to conduct searches for alcohol or drugs on our premises, including, but not limited to,searches of lockers, filing cabinets and desks, bags, clothing, packages [ANY FURTHER ITEMS].5.2 Any alcohol or drugs found as a result of a search will be confiscated and action may be taken under ourDisciplinary Procedure.6. DRUG SCREENING6.1 We may operate a rolling programme of random drug testing and/or in cases where there is reasonablecause to suspect that an individual’s performance is impaired as the result of drug misuse will be asked toparticipate in a drug screening programme.6.2 Drug screening will be conducted by an external provider. Arrangements will be discussed with affectedmembers of staff at the start of each screening programme.7. MANAGING SUSPECTED SUBSTANCE MISUSE7.1 Where a manager considers that a deterioration in work performance and/or changes in patterns ofbehaviour may be due to alcohol or drug misuse they should seek advice and assistance from Human ResourcesVersion 1 07/08/2018Document Control: BDM J Gough

or Mental Health First Aider.7.2 If your manager has reason to believe that you are suffering the effects of alcohol or drugs misuse, they willinvite you to an investigatory interview. The purpose of the interview is to:(a) discuss the reason for the investigation and seek your views on, for example, the deterioration of your workperformance and/or behaviour; and(b) where appropriate, offer to refer you for medical and/or specialist advice.7.3 If you arrive at work and a manager reasonably believes you are under the influence of alcohol or drugs,they shall immediately contact Human Resources or a more senior manager in order that you can be providedwith assistance and an investigation can be undertaken.7.4 If you agree to be referred to the HR Department, your manager will request an urgent appointment andprepare a letter of referral, a copy of which will be provided to you.7.5 HR may ask for your consent to approach your GP for advice. A report will be sent to your manager who willthen reassess the reasons for their investigatory meeting with you and decide on the way forward.7.6 If, as the result of the meeting or investigation, your manager continues to believe that you are sufferingthe effects of alcohol or drugs misuse and you refuse an offer of referral to appropriate treatment providers thematter may be dealt with under our Disciplinary Procedure.8. PROVIDING SUPPORT8.1 Alcohol and drug-related problems may develop for a variety of reasons and over a considerable period oftime. We are committed, in so far as possible, to treating these problems in a similar way to other health issues.We will provide support where possible with a view to a return to full duties. This may include:(a) Referral to appropriate treatment providers, where necessary in conjunction with your GP.(b) Time off work to attend treatment and recognition of any periods of absence for such treatment as periodsof sickness absence.(c) Adjusting your duties or other support during treatment and for an agreed period thereafter, subject tooperational requirements and feasibility.8.2 If you do not finish a programme of treatment, or your recovery and return to work does not go as planned,your manager or the Human Resources Department will meet with you to decide what further action if anyshould be taken.9. CONFIDENTIALITY9.1 We aim to ensure that the confidentiality of any member of staff experiencing alcohol or drug-relatedproblems is maintained appropriately. However, it needs to be recognised that, in supporting staff, some degreeof information sharing is likely to be necessary.9.2 If you seek help with an alcohol or drug-related problem directly from Human Resources and you wish tokeep matters confidential from your manager and colleagues, this will be respected unless there is reason tobelieve that this could put you, your colleagues or anyone else at risk or carries some other material risk for thebusiness. In those circumstances Human Resources will encourage you to inform your manager and will give yousufficient time to do so before discussing the matter with them.10. PERFORMANCE AND DISCIPLINARY ISSUES10.1 If you agree to undertake appropriate treatment and/or rehabilitation for an acknowledged alcohol ordrug-related problem, we may decide to suspend any ongoing disciplinary action against you for relatedmisconduct or poor performance, pending the outcome of the treatment.Version 1 07/08/2018Document Control: BDM J Gough

10.2 Our intention is to support all staff with alcohol or drug-related problems to regain good health. Dependingon the progress made on the course of treatment, any disciplinary action may be suspended for a specifiedperiod, discontinued or restarted at any time as we see fit.Version 1 07/08/2018Document Control: BDM J Gough

SCHEDULE 34RELATIONSHIPS AT WORK POLICY1. ABOUT THIS POLICY1.1 This policy governs personal relationships in the workplace. When we use the phrase “personal relationship”in this policy we mean any emotional or romantic relationship which goes beyond the normally acceptedboundaries of the professional sphere between colleagues. This will include formal, family relationships (forexample, where people are married or living together). It will also include less formal situations (for example,where the parties consider that they are “seeing each other” or “going out together”).1.2 This policy applies to all personal relationships between any member of staff, regardless of whether thoseinvolved work in the same team, department, division or office, or at the same site.1.3 This definition is not intended to be exhaustive. Given the sensitive nature of personal relationships, all staffare required to use common sense in assessing whether or not this policy is relevant to them. If any person isunsure whether this policy applies to their circumstances, they should speak to HR in confidence about theirsituation.1.4 We respect the right of all our staff to a private life. We also understand that many people meet theirpartners at work and that personal relationships between staff are inevitable. For the avoidance of doubt, thispolicy is not intended to prohibit staff from having a personal relationship with a work colleague. It is intendedto set out guidelines for their conduct within the workplace and to provide a framework for managers to dealsensitively, consistently and fairly with personal relationships which may affect the business.1.5 This policy applies to all employees, directors, officers, consultants, contractors, freelancers, volunteers,trainees, casual workers, zero hours workers and agency workers regardless of seniority.1.6 This policy does not form part of any contract of employment or other contract to provide services, and wemay amend it at any time. It will be reviewed regularly.2. PURPOSE OF THIS POLICY2.1 In many cases a personal relationship between staff will not interfere with work. However, sometimes apersonal relationship will be or become problematic because it adversely impacts on other colleagues ornegatively affects business efficiency. Personal relationships can be particularly problematic where they involvemembers of the same team or are between a supervisor or manager and subordinate.2.2 This means that personal relationships are potentially a legitimate management concern. In issuing thispolicy, we seek to address the following, non-exhaustive, issues which may arise where there is a personalrelationship:3. MANAGEMENT GUIDELINES3.1 Where a manager becomes aware that a member of their team is in a personal relationship with a colleague,they are required to treat this sensitively and, as far as possible, in confidence.3.2 Most personal relationships should not have a significant impact on the workplace or efficiency of work.However, managers need to recognise their responsibility to all team members and to the needs of the business.3.3 No action should be taken simply because a staff member is in a personal relationship with a colleague. Onlyif there is an issue or risk as outlined above should action be considered.3.4 Managers will know that they must not discriminate against staff on various protected grounds. They shouldparticularly consider the characteristics of sex, sexual orientation and age before taking any action as a result ofa personal relationship. For example, it should not be assumed that the more junior person in a couple will betransferred out of a team, as this could be indirectly discriminatory.3.5 Managers should be aware that conduct directed towards a colleague for personal reasons may beVersion 1 07/08/2018Document Control: BDM J Gough

unwanted and that, in some circumstances, this could amount to unlawful harassment for which the employercould be liable. We will take any grievances (formal or informal) very seriously and investigate these withoutdelay. Managers should escalate any complaints of this nature to HR as soon as possible.3.6 Any information regarding personal relationships is confidential and likely to be protected under dataprotection laws. Managers are reminded about their data protection obligations under the law Data ProtectionPolicy, including ensuring the security of such information.3.7 Managers are also reminded that we have a duty to protect the health and safety of our staff and that thisincludes mental health. If a manager has concerns regarding the health impact of a personal relationship on amember of staff they should bring this to the attention of HR without delay.3.8 Given the highly sensitive nature of personal relationships, managers should seek the assistance of HRbefore dealing with any issues which may arise. They should also ensure that a formal note is taken of anymeetings to discuss personal relationships.4. CONDUCT OF THOSE IN PERSONAL RELATIONSHIPS4.1 Any members of staff who are in a personal relationship are expected to conduct themselves in aprofessional manner at work at all times in respect of such relationship. This means being considerate of thefeelings of their other colleagues in their day-to-day dealings and being discrete in any discussions regardingtheir private life within the workplace. Public displays of affection are inappropriate in the work sphere.4.2 Our equipment and resources are provided for work purposes only. Any inappropriate use in furtherance ofa personal relationship will be treated as a disciplinary matter.4.3 Our confidentiality rules continue to apply regardless of any personal relationship. Staff must ensure thatthey protect all confidential and commercially sensitive information from unauthorised disclosure.4.4 Where the personal relationship involves those in a direct or indirect reporting line or inmanager/subordinate roles, both parties are required to disclose this by informing to HR, in confidence, as soonas reasonably practicable. While there is no formal requirement for staff who are not also in amanager/subordinate relationship to disclose any personal relationship, they should consider whether it maybe appropriate to inform their line manager in any event or whether, having regard to their general duties ofgood faith towards their employer, they do so in relevant circumstances. For example, if there is a risk of aconflict of interest or perceived conflict of interest arising.4.5 As a matter of policy, colleagues who are in a personal relationship should not also be inmanager/subordinate roles in the workplace. Where such a personal relationship arises, both parties arerequired to inform HR, in confidence, as soon as reasonably practicable. We will then liaise with those involvedto agree a plan to minimise the impact of the personal relationship on the business. This is likely to involvetransferring one or both of the partners from their current role. This will only be done with the agreement ofthose affected. If this is not possible for operational reasons, then we will consider putting in place appropriatesafeguards to ensure transparency and fairness.4.6 Failure to disclose a personal relationship as required by this policy will be treated as a disciplinary matterand, subject to investigation, could result in disciplinary action, up to and including dismissal.5. DISCRIMINATION, HARASSMENT AND OTHER POLICIES5.1 All staff are reminded that they are subject to our policies on equality and diversity, discrimination andharassment, confidentiality and data protection and that breach of these policies may result in disciplinaryaction, up to and including dismissal.5.2 We are committed to providing a workplace which is fair and equal. Nobody will be disadvantaged,discriminated against or otherwise subjected to a detriment because they are in a personal relationship. Anymember of staff who has concerns about their treatment should raise this informally with their line manager inthe first instance (if appropriate), or otherwise use the formal grievance procedure.Version 1 07/08/2018Document Control: BDM J Gough

5.3 We will not tolerate any form of harassment of our staff and will take any allegations extremely seriously.Staff are reminded to consider their legal obligations towards colleagues. These may be especially pertinent atthe beginning or end of a relationship, when professionalism and discretion will be particularly important.Version 1 07/08/2018Document Control: BDM J Gough



























SCHEDULE 36CCTV POLICY1. POLICY STATEMENT1.1 We believe that CCTV and other surveillance systems have a legitimate role to play in helping to maintain asafe and secure environment for all our staff and visitors. However, we recognise that this may raise concernsabout the effect on individuals and their privacy. This policy is intended to address such concerns. Imagesrecorded by surveillance systems are personal data which must be processed in accordance with data protectionlaws. We are committed to complying with our legal obligations and ensuring that the legal rights of staff,relating to their personal data, are recognised and respected.1.2 This policy is intended to assist staff in complying with their own legal obligations when working withpersonal data. In certain circumstances, misuse of information generated by CCTV or other surveillance systemscould constitute a criminal offence.2. DEFINITIONS2.1 For the purposes of this policy, the following terms have the following meanings:CCTV: means fixed and domed cameras designed to capture and record images of individuals and property.Data: is information which is stored electronically, or in certain paper-based filing systems. In respect of CCTV,this generally means video images. It may also include static pictures such as printed screen shots.Data subjects: means all living individuals about whom we hold personal information as a result of the operationof our CCTV (or other surveillance systems).Personal data: means data relating to a living individual who can be identified from that data (or other data inour possession). This will include video images of identifiable individuals.Data controllers: are the people who, or organisations which, determine the manner in which any personal datais processed. They are responsible for establishing practices and policies to ensure compliance with the law. Weare the data controller of all personal data used in our business for our own commercial purposes.Data users: are those of our employees whose work involves processing personal data. This will include thosewhose duties are to operate CCTV cameras and other surveillance systems to record, monitor, store, retrieveand delete images. Data users must protect the data they handle in accordance with this policy and our DataProtection Policy.Data processors: are any person or organisation that is not a data user (or other employee of a data controller)that processes data on our behalf and in accordance with our instructions (for example, a supplier which handlesdata on our behalf).Processing: is any activity which involves the use of data. It includes obtaining, recording or holding data, orcarrying out any operation on the data including organising, amending, retrieving, using, disclosing or destroyingit. Processing also includes transferring personal data to third parties.Surveillance systems: means any devices or systems designed to monitor or record images of individuals orinformation relating to individuals. The term includes CCTV systems as well as any technology that may beintroduced in the future such as automatic number plate recognition (ANPR), body worn cameras, unmannedaerial systems and any other systems that capture information of identifiable individuals or information relatingto identifiable individuals.3. ABOUT THIS POLICY3.1 We currently use CCTV cameras to view and record individuals on and around our premises. This policyoutlines why we use CCTV, how we will use CCTV and how we will process data recorded by CCTV cameras toensure we are compliant with data protection law and best practice. This policy also explains how to make aVersion 1 07/08/2018Document Control: BDM J Gough

subject access request in respect of personal data created by CCTV.3.2 We recognise that information that we hold about individuals is subject to data protection legislation. Theimages of individuals recorded by CCTV cameras in the workplace are personal data and therefore subject to thelegislation. We are a data controller and we have registered our use of CCTV with the Information Commissioner.We are committed to complying with our legal obligations and seek to comply with best practice suggestionsfrom the Information Commissioner’s Office (ICO).3.3 This policy covers all employees and other individuals working and/or visiting our premises.3.5 This policy is non-contractual and does not form part of the terms and conditions of any employment orother contract. We may amend this policy at any time. The policy will be regularly reviewed to ensure that itmeets legal requirements, relevant guidance published by the ICO and industry standards.3.6 A breach of this policy may, in appropriate circumstances, be treated as a disciplinary matter. Followinginvestigation, a breach of this policy may be regarded as misconduct leading to disciplinary action, up to andincluding dismissal.4. PERSONNEL RESPONSIBLE4.1 The board of directors has overall responsibility for ensuring compliance with relevant legislation and theeffective operation of this policy. Day-to-day management responsibility for deciding what information isrecorded, how it will be used and to whom it may be disclosed remains with The Board. Day-to-day operationalresponsibility for CCTV cameras and the storage of data recorded is the responsibility of the Yard Manager.4.2 Responsibility for keeping this policy up to date has been delegated to the Business Development Manager.5. REASONS FOR THE USE OF CCTV5.1 We currently use CCTV as outlined below. We believe that such use is necessary for legitimate businesspurposes, including:(a) to prevent crime and protect buildings and assets from damage, disruption, vandalism and other crime;(b) for the personal safety of staff, visitors and other members of the public and to act as a deterrent againstcrime;(c) to support law enforcement bodies in the prevention, detection and prosecution of crime;(d) to assist in day-to-day management, including ensuring the health and safety of staff and others;(e) to assist in the effective resolution of disputes which arise in the course of disciplinary or grievanceproceedings;(f) to assist in the defence of any civil litigation, including employment tribunal proceedings.This list is not exhaustive and other purposes may be or become relevant.6. MONITORING6.1 CCTV monitors the exterior and interior of the building 24 hours a day and this data is continuously recorded.6.2 Camera locations are chosen to minimise viewing of spaces not relevant to the legitimate purpose of themonitoring. As far as practically possible, CCTV cameras will not focus on private homes, gardens or other areasof private property.6.3 Surveillance systems will not be used to record sound.6.4 Images are monitored by authorised personnel during working hours only.Version 1 07/08/2018Document Control: BDM J Gough

6.5 Staff using surveillance systems will be given appropriate training to ensure they understand and observethe legal requirements related to the processing of relevant data.7. HOW WE WILL OPERATE ANY CCTV7.1 Where CCTV cameras are placed in the workplace, we will ensure that signs are displayed at the entranceof the surveillance zone to alert individuals that their image may be recorded. Such signs will contain details ofthe organisation operating the system, the purpose for using the surveillance system and who to contact forfurther information, where these things are not obvious to those being monitored.7.2 Live feeds from CCTV cameras will only be monitored where this is reasonably necessary, for example toprotect health and safety.7.3 We will ensure that live feeds from cameras and recorded images are only viewed by approved members ofstaff whose role requires them to have access to such data. This may include HR staff involved with disciplinaryor grievance matters. Recorded images will only be viewed in designated, secure offices.8. USE OF DATA GATHERED BY CCTV8.1 In order to ensure that the rights of individuals recorded by the CCTV system are protected, we will ensurethat data gathered from CCTV cameras is stored in a way that maintains its integrity and security. This mayinclude encrypting the data, where it is possible to do so.8.2 Given the large amount of data generated by surveillance systems, we may store video footage using a cloudcomputing system. We will take all reasonable steps to ensure that any cloud service provider maintains thesecurity of our information, in accordance with industry standards.8.3 We may engage data processors to process data on our behalf. We will ensure reasonable contractualsafeguards are in place to protect the security and integrity of the data.9. RETENTION AND ERASURE OF DATA GATHERED BY CCTV9.1 Data recorded by the CCTV system will be stored digitally using a hard drive. Data from CCTV cameras willnot be retained indefinitely but will be permanently deleted once there is no reason to retain the recordedinformation. Exactly how long images will be retained for will vary according to the purpose for which they arebeing recorded. For example, where images are being recorded for crime prevention purposes, data will be keptlong enough only for incidents to come to light. In all other cases, recorded images will be kept for no longerthan 30. After 30 days data is deleted.9.2 At the end of their useful life, all images stored in whatever format will be erased permanently and securely.Any physical matter such as tapes or discs will be disposed of as confidential waste. Any still photographs andhard copy prints will be disposed of as confidential waste.10. USE OF ADDITIONAL SURVEILLANCE SYSTEMS10.1 Prior to introducing any new surveillance system, including placing a new CCTV camera in any workplacelocation, we will carefully consider if they are appropriate by carrying out a privacy impact assessment (DPIA).10.2 A PIA is intended to assist us in deciding whether new surveillance cameras are necessary andproportionate in the circumstances and whether they should be used at all or whether any limitations should beplaced on their use.10.3 Any PIA will consider the nature of the problem that we are seeking to address at that time and whetherthe surveillance camera is likely to be an effective solution, or whether a better solution exists. In particular, wewill consider the effect a surveillance camera will have on individuals and therefore whether its use is aproportionate response to the problem identified.10.4 No surveillance cameras will be placed in areas where there is an expectation of privacy (for example, inchanging rooms) unless, in very exceptional circumstances, it is judged by us to be necessary to deal with veryserious concerns.Version 1 07/08/2018Document Control: BDM J Gough

11. COVERT MONITORING11.1 We will never engage in covert monitoring or surveillance (that is, where individuals are unaware that themonitoring or surveillance is taking place) unless, in highly exceptional circumstances, there are reasonablegrounds to suspect that criminal activity or extremely serious malpractice is taking place and, after suitableconsideration, we reasonably believe there is no less intrusive way to tackle the issue.11.2 In the unlikely event that covert monitoring is considered to be justified, it will only be carried out with theexpress authorisation of the Board of Directors. The decision to carry out covert monitoring will be fullydocumented and will set out how the decision to use covert means was reached and by whom. The risk ofintrusion on innocent workers will always be a primary consideration in reaching any such decision.11.3 Only limited numbers of people will be involved in any covert monitoring.11.4 Covert monitoring will only be carried out for a limited and reasonable period of time consistent with theobjectives of making the recording and will only relate to the specific suspected illegal or unauthorised activity.12. ONGOING REVIEW OF CCTV USE12.1 We will ensure that the ongoing use of existing CCTV cameras in the workplace is reviewed at least every12 months to ensure that their use remains necessary and appropriate, and that any surveillance system iscontinuing to address the needs that justified its introduction.13. REQUESTS FOR DISCLOSURE13.1 We may share data with other group companies [and other associated companies or organisations, forexample shared services partners] where we consider that this is reasonably necessary for any of the legitimatepurposes set out above in Paragraph 5.1.]13.2 No images from our CCTV cameras will be disclosed to any [other] third party, without express permissionbeing given by a Director. Data will not normally be released unless satisfactory evidence that it is required forlegal proceedings or under a court order has been produced.13.3 In other appropriate circumstances, we may allow law enforcement agencies to view or remove CCTVfootage where this is required in the detection or prosecution of crime.13.4 We will maintain a record of all disclosures of CCTV footage subject to document retention guidelines.13.5 No images from CCTV will ever be posted online or disclosed to the media.14. SUBJECT ACCESS REQUESTS14.1 Data subjects may make a request for disclosure of their personal information and this may include CCTVimages (data subject access request). A data subject access request is subject to the statutory conditions fromtime to time in place and should be made in writing.14.2 In order for us to locate relevant footage, any requests for copies of recorded CCTV images must includethe date and time of the recording, the location where the footage was captured and, if necessary, informationidentifying the individual.14.3 We reserve the right to obscure images of third parties when disclosing CCTV data as part of a subjectaccess request, where we consider it necessary to do so.15. COMPLAINTS15.1 If any member of staff has questions about this policy or any concerns about our use of CCTV, then theyshould speak to their manager or the Business Development Manager in the first instance.15.2 Where this is not appropriate or matters cannot be resolved informally, employees should use our formalgrievance procedure.16. REQUESTS TO PREVENT PROCESSINGVersion 1 07/08/2018Document Control: BDM J Gough

16.1 We recognise that, in rare circumstances, individuals may have a legal right to object to processing and incertain circumstances, to prevent automated decision making (see Articles 21 and 22 of the GDPR). For furtherinformation regarding this, please contact the Business Development Manager.Version 1 07/08/2018Document Control: BDM J Gough

SCHEDULE 38IT AND COMMUNICATIONS SYSTEMS POLICY1. ABOUT THIS POLICY1.1 Our IT and communications systems are intended to promote effective communication and workingpractices within our organisation. This policy outlines the standards you must observe when using these systems,the circumstances in which we will monitor your use, and the action we will take in respect of breaches of thesestandards.1.2 This policy covers all employees, officers, consultants, contractors, volunteers, trainees, casual workers,agency workers and anyone who has access to our IT and communication systems.1.3 Misuse of IT and communications systems can damage the business and our reputation. Breach of this policymay be dealt with under our Disciplinary Procedure and, in serious cases, may be treated as gross misconductleading to summary dismissal.1.4 This policy does not form part of any employee’s contract of employment and we may amend it at any time.2. PERSONNEL RESPONSIBLE FOR THE POLICY2.1 The Board has overall responsibility for the effective operation of this policy and for ensuring compliancewith the relevant statutory framework. Day-to-day responsibility for operating the policy and ensuring itsmaintenance and review has been delegated to the Business Development Manager.2.2 Managers have a specific responsibility to ensure the fair application of this policy and all members of staffare responsible for supporting colleagues and ensuring its success.2.3 A Director will deal with requests for permission or assistance under any provisions of this policy, and mayspecify certain standards of equipment or procedures to ensure security and compatibility.3. EQUIPMENT SECURITY AND PASSWORDS3.1 You are responsible for the security of the equipment allocated to or used by you, and must not allow it tobe used by anyone other than in accordance with this policy.3.2 You are responsible for the security of any computer terminal used by you. You should lock your terminalor log off when leaving it unattended or on leaving the office, to prevent unauthorised users accessing thesystem in your absence. Anyone who is not authorised to access our network should only be allowed to useterminals under supervision.3.3 Desktop PCs and cabling for telephones or computer equipment should not be moved or tampered withwithout first consulting a Director.3.4 You should use passwords on all IT equipment, particularly items that you take out of the office. You mustkeep your passwords confidential and change them regularly. You must not use another person’s username andpassword or make available or allow anyone else to log on using your username and password unless authorisedby a Director. On the termination of employment (for any reason) you must provide details of your passwordsto a Director and return any equipment, key fobs or cards.3.5 If you have been issued with a laptop, tablet computer, smartphone or other mobile device, you must ensurethat it is kept secure at all times, especially when travelling. Passwords must be used to secure access to datakept on such equipment to ensure that confidential data is protected in the event of loss or theft. You shouldalso be aware that when using equipment away from the workplace, documents may be read by third parties,for example, passengers on public transport.4. SYSTEMS AND DATA SECURITY4.1 You should not delete, destroy or modify existing systems, programs, information or data (except asauthorised in the proper performance of your duties).Version 1 07/08/2018Document Control: BDM J Gough

4.2 You must not download or install software from external sources without authorisation from a Director.This includes software programs, instant messaging programs, screensavers, photos, video clips and music files.Incoming files and data should always be virus-checked by a Director before they are downloaded. If in doubt,staff should seek advice from a Director.4.3 You must not attach any device or equipment to our systems without authorisation from a Director. Thisincludes any USB flash drive, MP3 player, tablet, smartphone or other similar device, whether connected via theUSB port, infra-red connection or in any other way.4.4 We monitor all emails passing through our system for viruses. You should exercise particular caution whenopening unsolicited emails from unknown sources or an email which appears suspicious (for example, if itcontains a file whose name ends in .exe). Inform a Director immediately if you suspect your computer may havea virus. We reserve the right to delete or block access to emails or attachments in the interests of security. Wealso reserve the right not to transmit any email message.4.5 You should not attempt to gain access to restricted areas of the network, or to any password-protectedinformation, except as authorised in the proper performance of your duties.4.6 You must be particularly vigilant if you use our IT equipment outside the workplace and take suchprecautions as we may require from time to time against importing viruses or compromising system security.The system contains information which is confidential and/or subject to data protection legislation. Suchinformation must be treated with extreme care and in accordance with our Data Protection Policy.5. EMAIL5.1 Although email is a vital business tool, you should always consider if it is the appropriate method for aparticular communication. Correspondence with third parties by email should be written as professionally as aletter. Messages should be concise and directed only to relevant individuals. Our standard disclaimer shouldalways be included.5.2 You should access your emails at least once every working day, stay in touch by remote access whentravelling in connection with our business, and use an out of office response when away from the office for morethan a day. You should endeavour to respond to emails marked “high priority” within 24 hours.5.3 You must not send abusive, obscene, discriminatory, racist, harassing, derogatory, defamatory, or otherwiseinappropriate emails. Anyone who feels that they have been harassed or bullied, or are offended by materialreceived from a colleague via email should inform their line manager or the Human Resources Department.5.4 You should take care with the content of email messages, as incorrect or improper statements can give riseto claims for discrimination, harassment, defamation, breach of confidentiality or breach of contract. Rememberthat you have no control over where your email may be forwarded by the recipient. Avoid saying anything whichwould cause offence or embarrassment if it was forwarded to colleagues or third parties, or found its way intothe public domain.5.5 Email messages may be disclosed in legal proceedings in the same way as paper documents. Deletion froma user’s inbox or archives does not mean that an email cannot be recovered for the purposes of disclosure. Allemail messages should be treated as potentially retrievable, either from the main server or using specialistsoftware.5.6 In general, you should not:(a) send or forward private emails at work which you would not want a third party to read;(b) send or forward chain mail, junk mail, cartoons, jokes or gossip;(c) contribute to system congestion by sending trivial messages, copying or forwarding emails to those who donot have a real need to receive them, or using “reply all” unnecessarily on an email with a large distribution list;Version 1 07/08/2018Document Control: BDM J Gough

(d) sell or advertise using our communication systems or broadcast messages about lost property, sponsorshipor charitable appeals;(e) agree to terms, enter into contractual commitments or make representations by email unless appropriateauthority has been obtained. A name typed at the end of an email is a signature in the same way as a namewritten at the end of a letter;(f) download or email text, music and other content on the internet subject to copyright protection, unless it isclear that the owner of such works allows this;(g) send messages from another person’s email address (unless authorised) or under an assumed name; or(h) send confidential messages via email or the internet, or by other means of external communication whichare known not to be secure.5.7 If you receive an email in error you should inform the sender.5.8 Do not use your own personal email account to send or receive email for the purposes of our business. Onlyuse the email account we have provided for you.6. USING THE INTERNET6.1 Internet access is provided primarily for business purposes. Occasional personal use may be permitted asset out in Paragraph 7.6.2 When a website is visited, devices such as cookies, tags or web beacons may be employed to enable the siteowner to identify and monitor visitors. If the website is of a kind described in Paragraph 9.1, such a marker couldbe a source of embarrassment to the visitor and us, especially if inappropriate material has been accessed,downloaded, stored or forwarded from the website. Such actions may also, in certain circumstances, amount toa criminal offence if, for example, the material is pornographic in nature. This is further considered underParagraph 9.6.3 You should not access any web page or download any image, document or other file from the internet whichcould be regarded as illegal, offensive, in bad taste or immoral. Even web content which is legal in the UK maybe in sufficient bad taste to fall within this prohibition. As a general rule, if any person (whether intended toview the page or not) might be offended by the contents of a page, or if the fact that our software has accessedthe page or file might be a source of embarrassment if made public, then viewing it will be a breach of this policy.6.4 You should not under any circumstances use our systems to participate in any internet chat room, postmessages on any internet message board or set up or log text or information on a blog or wiki, even in your owntime.6.5 The following must never be accessed during working hours from our network: online radio, audio and videostreaming, instant messaging and webmail (such as such as Gmail or Hotmail) and social networking sites (suchas Facebook, Twitter, Bebo, YouTube, Second Life). This list may be modified from time to time.7. PERSONAL USE OF OUR SYSTEMS7.1 We permit the incidental use of our internet, email and telephone systems to send personal email, browsethe internet and make personal telephone calls subject to certain conditions set out below. Personal use is aprivilege and not a right. It must not be overused or abused. We may withdraw permission for it at any time orrestrict access at our discretion.7.2 Personal use must meet the following conditions:(a) use must be minimal and take place substantially out of normal working hours (that is, during lunch hours,before 9 am or after 5.30 pm);(b) personal emails should be labelled “personal” in the subject header;Version 1 07/08/2018Document Control: BDM J Gough

(c) use must not interfere with business or office commitments;(d) use must not commit us to any marginal costs; and(e) use must comply with this policy (see in particular Paragraph 5 and Paragraph 6) and our other policiesincluding the Equal Opportunities Policy, Anti-harassment Policy, Data Protection Policy and Disciplinary Rules.7.3 You should be aware that personal use of our systems may be monitored (see Paragraph 8) and, wherebreaches of this policy are found, action may be taken under the disciplinary procedure (see Paragraph 9). Wereserve the right to restrict or prevent access to certain telephone numbers or internet sites if we considerpersonal use to be excessive.8. MONITORING8.1 Our systems enable us to monitor telephone, email, voicemail, internet and other communications. Forbusiness reasons, and in order to carry out legal obligations in our role as an employer, use of our systemsincluding the telephone and computer systems, and any personal use of them, may be continually monitored byautomated software or otherwise. Monitoring is only carried out to the extent permitted or as required by lawand as necessary and justifiable for business purposes.8.2 A CCTV system monitors the exterior of the building 24 hours a day. This data is recorded.8.3 We reserve the right to retrieve the contents of email messages or check internet usage (including pagesvisited and searches made) as reasonably necessary in the interests of the business, including for the followingpurposes (this list is not exhaustive):(a) to monitor whether the use of the email system or the internet is legitimate and in accordance with thispolicy;(b) to find lost messages or to retrieve messages lost due to computer failure;(c) to assist in the investigation of alleged wrongdoing; or(d) to comply with any legal obligation.9. PROHIBITED USE OF OUR SYSTEMS9.1 Misuse or excessive personal use of our telephone or email system or inappropriate internet use will bedealt with under our Disciplinary Procedure. Misuse of the internet can in some circumstances be a criminaloffence. In particular, it will usually amount to gross misconduct to misuse our systems by participating in onlinegambling, forwarding chain letters, or by creating, viewing, accessing, transmitting or downloading any of thefollowing material (this list is not exhaustive):(a) pornographic material (that is, writing, pictures, films and video clips of a sexually explicit or arousingnature);(b) offensive, obscene, or criminal material or material which is liable to cause embarrassment to us or to ourclients;(c) a false and defamatory statement about any person or organisation;(d) material which is discriminatory, offensive, derogatory or may cause embarrassment to others (includingmaterial which breaches our Equal Opportunities Policy or our Anti-harassment and Bullying Policy);(e) confidential information about us or any of our staff or clients (except as authorised in the properperformance of your duties);(f) Unauthorised software;Version 1 07/08/2018Document Control: BDM J Gough

(g) any other statement which is likely to create any criminal or civil liability (for you or us); or(h) music or video files or other material in breach of copyright.Any such action will be treated very seriously and is likely to result in summary dismissal.9.2 Where evidence of misuse is found we may undertake a more detailed investigation in accordance with ourDisciplinary Procedure, involving the examination and disclosure of monitoring records to those nominated toundertake the investigation and any witnesses or managers involved in the Disciplinary Procedure. If necessarysuch information may be handed to the police in connection with a criminal investigation.Version 1 07/08/2018Document Control: BDM J Gough

SCHEDULE 39SOCIAL MEDIA POLICY1. ABOUT THIS POLICY1.1 This policy is in place to minimise the risks to our business through use of social media.1.2 This policy deals with the use of all forms of social media, including Facebook, LinkedIn, Twitter, Google+,Wikipedia, Instagram and all other social networking sites, internet postings and blogs. It applies to use of socialmedia for business purposes as well as personal use that may affect our business in any way.1.3 This policy covers all employees, officers, consultants, contractors, volunteers, trainees, casual workers andagency workers.1.4 This policy does not form part of any employee’s contract of employment and we may amend it at any time.2. PERSONNEL RESPONSIBLE FOR IMPLEMENTING THE POLICY2.1 The Board has overall responsibility for the effective operation of this policy, but has delegated day-to-dayresponsibility for its operation to the Business Development Manager.2.2 Responsibility for monitoring and reviewing the operation of this policy and making recommendations forchange to minimise risks lies with the Business Development Manager who will review this policy annually toensure that it meets legal requirements and reflects best practice.2.3 Managers have a specific responsibility for operating within the boundaries of this policy, ensuring that allstaff understand the standards of behaviour expected of them and taking action when behaviour falls below itsrequirements.2.4 All staff are responsible for the success of this policy and should ensure that they take the time to read andunderstand it. Any misuse of social media should be reported to the Business Development Manager. Questionsregarding the content or application of this policy should be directed to Business Development Manager.3. COMPLIANCE WITH RELATED POLICIES AND AGREEMENTS3.1 Social media should never be used in a way that breaches any of our other policies. If an internet post wouldbreach any of our policies in another forum, it will also breach them in an online forum. For example, you areprohibited from using social media to:(a) breach our IT and Communications Systems Policy;(b) breach our obligations with respect to the rules of relevant regulatory bodies;(c) breach any obligations contained in those policies relating to confidentiality;(d) breach our Disciplinary Policy or procedures;(e) breach our Anti-harassment and Bullying Policy];(f) breach our Equal Opportunities Policy;(g) breach our Data Protection Policy (for example, never disclose personal information about a colleagueonline); or(h) breach any other laws or regulatory requirements.3.2 Staff should never provide references for other individuals on social or professional networking sites, assuch references, positive and negative, can be attributed to the organisation and create legal liability for boththe author of the reference and the organisation.Version 1 09/08/2018Document Control: BDM J Gough

3.3 Staff who breach any of the above policies will be subject to disciplinary action up to and includingtermination of employment.4. PERSONAL USE OF SOCIAL MEDIAOccasional personal use of social media during working hours is permitted so long as it does not involveunprofessional or inappropriate content, does not interfere with your employment responsibilities orproductivity and complies with this policy.5. PROHIBITED USE5.1 You must avoid making any social media communications that could damage our business interests orreputation, even indirectly.5.2 You must not use social media to defame or disparage us, our staff or any third party; to harass, bully orunlawfully discriminate against staff or third parties; to make false or misleading statements; or to impersonatecolleagues or third parties.5.3 You must not express opinions on our behalf via social media, unless expressly authorised to do so by yourmanager. You may be required to undergo training in order to obtain such authorisation.5.4 You must not post comments about sensitive business-related topics, such as our performance, or doanything to jeopardise our trade secrets, confidential information and intellectual property. You must notinclude our logos or other trademarks in any social media posting or in your profile on any social media.5.5 The contact details of business contacts made during the course of your employment are our confidentialinformation. On termination of employment you must provide us with a copy of all such information, delete allsuch information from your personal social networking accounts and destroy any further copies of suchinformation that you may have.5.6 Any misuse of social media should be reported to the Business Development Manager.6. BUSINESS USE OF SOCIAL MEDIA6.1 If your duties require you to speak on behalf of the organisation in a social media environment, you muststill seek approval for such communication from your manager, who may require you to undergo training beforeyou do so and impose certain requirements and restrictions with regard to your activities.6.2 Likewise, if you are contacted for comments about the organisation for publication anywhere, including inany social media outlet, direct the enquiry to the Business Development Manager and do not respond withoutwritten approval.6.3 The use of social media for business purposes is subject to the remainder of this policy.7. GUIDELINES FOR RESPONSIBLE USE OF SOCIAL MEDIA7.1 You should make it clear in social media postings, or in your personal profile, that you are speaking on yourown behalf. Write in the first person and use a personal email address.7.2 Be respectful to others when making any statement on social media and be aware that you are personallyresponsible for all communications which will be published on the internet for anyone to see.7.3 If you disclose your affiliation with us on your profile or in any social media postings, you must state thatyour views do not represent those of your employer (unless you are authorised to speak on our behalf as setout in Paragraph 5.3). You should also ensure that your profile and any content you post are consistent with theprofessional image you present to clients and colleagues.7.4 If you are uncertain or concerned about the appropriateness of any statement or posting, refrain fromposting it until you have discussed it with your manager.7.5 If you see social media content that disparages or reflects poorly on us, you should contact your managerVersion 1 09/08/2018Document Control: BDM J Gough

or the Business Development Manager.8. MONITORING8.1 We reserve the right to monitor, intercept and review, without further notice, staff activities using our ITresources and communications systems, including but not limited to social media postings and activities, forlegitimate business purposes which include ascertaining and demonstrating that expected standards are beingmet by those using the systems and for the detection and investigation of unauthorised use of the systems(including where this is necessary to prevent or detect crime).8.2 For further information, please refer to our IT and Communications Systems Policy.9. RECRUITMENTWe may use internet searches to perform due diligence on candidates in the course of recruitment. Where wedo this, we will act in accordance with our data protection and equal opportunities obligations.10. BREACH OF THIS POLICY10.1 Breach of this policy may result in disciplinary action up to and including dismissal. Any member of staffsuspected of committing a breach of this policy will be required to co-operate with our investigation.10.2 You may be required to remove any social media content that we consider to constitute a breach of thispolicy. Failure to comply with such a request may in itself result in disciplinary action.Version 1 09/08/2018Document Control: BDM J Gough

SCHEDULE 40REDUNDANCY POLICY1. ABOUT THIS POLICY1.1 We will always try to avoid the need for compulsory redundancies but sometimes these may be necessary.The pattern or volume of our business or methods of working may change and requirements for employees mayreduce.1.2 The purpose of this policy is to ensure that, whenever reduction in employee numbers may becomenecessary:(a) we communicate clearly with all affected employees and ensure that they are treated fairly;(b) we try to find ways of avoiding compulsory redundancies;(c) we consult with employees; and(d) any selection for compulsory redundancy is undertaken fairly, reasonably and without discrimination.1.3 This policy applies to all employees. It does not apply to agency workers, consultants or self-employedcontractors.1.4 This policy will be reviewed from time to time to ensure that it reflects our legal obligations and our businessneeds.1.5 This policy does not form part of any employee’s contract of employment and we may amend it at any time.2. AVOIDING COMPULSORY REDUNDANCIES2.1 Where we are proposing to make redundancies we will enter into consultation with all affected employeeson an individual basis and, where appropriate, also with employee representatives.2.2 In the first instance we will consider steps that might, depending on the circumstances, be taken to avoidthe need for compulsory redundancies. Examples of such steps include:(a) Reviewing the use of agency staff, self-employed contractors and consultants.(b) Restricting recruitment in those areas into which affected employees might be redeployed.(c) Reducing overtime to that needed to meet contractual commitments or provide essential services.(d) Freezing salaries for a specified period.(e) Considering the introduction of short-time working, job-sharing or other flexible working arrangements,where these are practicable.(f) Identifying suitable alternative work with us or with any other companies within the Group that might beoffered to potentially redundant employees.(g) Inviting applications for early retirement or voluntary redundancy. In all cases the acceptance of a volunteerfor redundancy will be a matter of our discretion and we reserve the right not to offer voluntary redundancyterms or to refuse an application where it is not in the interests of our business to do so.2.3 Any measures adopted must not adversely affect our business and our ability to serve our customers.3. MAKING COMPULSORY REDUNDANCIES3.1 When it is not possible to avoid making compulsory redundancies, we will advise all affected employeesVersion 1 09/08/2018Document Control: BDM J Gough