Policies

 

 July 2019 

Our safeguarding policy 

This policy applies to all Dartington Service Design Staff (‘Lab’) staff, including senior managers and the board of trustees, other paid staff, volunteers and associate workers, agency staff, interns, and it also includes the Centre for Social Policy Fellows or anyone working on behalf of, or with the overarching charity: The Warren House Group at Dartington (WHG). 

The purpose of this policy: 

  • to protect vulnerable people and children who receive any form of service, exposure to, or activity with the Lab, CSP or WHG. This includes the children of adults who work with us too; 

  • to provide staff and volunteers with the overarching principles that guide our approach to safeguarding of vulnerable people and child protection. 

The WHG believes that vulnerable people and children should never experience abuse of any kind.  We have a responsibility to promote the welfare of all vulnerable people and children and to keep them safe.  

 

Legal framework 

This policy has been drawn up on the basis of law and guidance that seeks to protect children, namely: 

  • Children Act 1989; 

  • United Convention of the Rights of the Child 1991; 

  • Data Protection Act 1998 (and the superseding General Data Protection Regulations 2018); 

  • Human Rights Act 1998; 

  • Sexual Offences Act 2003; 

  • Children Act 2004; 

  • Safeguarding Vulnerable Groups Act 2006; 

  • Protection of Freedoms Act 2012; 

  • Children and Families Act 2014; 

  • Care Act 2014; 

  • Social Services and Wellbeing Act 2014; 

  • Special educational needs and disability (SEND) code of practice: 0 to 25 years - Statutory guidance for organisations which work with and support children and young people who have special educational needs or disabilities; HM Government 2014; 

  • Information sharing: Advice for practitioners providing safeguarding services to children, young people, parents and carers; HM Government 2015; 

  • Working together to safeguarding children: a guide to inter-agency working to safeguard and promote the welfare of children; HM Government 2015; 

 

This policy should be read alongside our handbook, policies, procedures and logs on:  

  • Recruitment, induction and training 

  • Dealing with disclosures and concerns about a vulnerable person or child 

  • Managing allegations against staff and volunteers 

  • Recording and information sharing 

  • Code of conduct for staff and volunteers  

  • Safer recruitment procedure 

  • Anti -bullying, Grievance and Whistleblowing 

  • Health and safety 

  • Training, supervision and support for lone workers 

  • Quality assurance 

 

We recognise that: 

  • the welfare of a vulnerable person or child is paramount, as enshrined in the Children Act 1989; 

  • all vulnerable people and children, regardless of age, disability, gender, racial heritage, religious belief, sexual orientation or identity, have a right to equal protect ion from all types of harm or abuse; 

  • some people and children are additionally vulnerable because of the impact of previous experiences, their level of dependency, communication needs or other issues; 

  • working in partnership with vulnerable people and children, their parents, carers and other agencies is essential in promoting vulnerable people’s and children’s welfare. 

 

We will seek to keep vulnerable people and children safe by: 

  • valuing them, listening to and respecting them; 

  • appointing a Designated Safeguarding Officer (DSO) for vulnerable people and children, a Deputy and a Trustee lead for safeguarding, adopting vulnerable people and children protection and safeguarding practices through procedures and a code of conduct for all staff, trustees and volunteers; 

  • reporting annually to the Board of Trustees on any safeguarding matters that have occurred in the past year and measures implemented to reinforce our safeguarding protocols; 

  • maintaining a safeguarding section within the high level WHG ‘Risk Register’; 

  • developing and implementing effective IT policies and related procedures; 

  • providing effective management for staff and volunteers through supervision, support, professional development and quality assurance measures; 

  • recruiting staff and volunteers safely, ensuring all necessary checks are made; 

  • recording and storing information professionally and securely, and sharing information about safeguarding and good practice with children, their families, staff and volunteers via leaflets, posters, one-to one discussions; 

  • using our safeguarding procedures to share concerns and relevant information with agencies who need to know, and involving children, young people, their parents, families and carers appropriately; 

  • using our procedures to manage any allegations against staff and volunteers appropriately; 

  • creating and maintaining an anti-bullying environment and ensuring that we have a policy and procedure to help us deal effectively with any bullying that does arise; 

  • ensuring that we have effective grievance and whistleblowing measures in place; 

  • ensuring that we provide a safe physical environment for our staff and volunteers by applying health and safety measures in accordance with the law, regulatory guidance and best practice. 

 

Contact details 

Key personnel: 

The designated senior person for child protection in the WHG Lab is:  

Brian Warren – Chief Operating Officer 

Contact details:  

01803 762400 Mobile 07817 220009 brian.warren@dartington.org.uk 

The deputy designated person in the WHG is:  

Jenny North – Deputy Director 

Contact details:  

Mobile 07833 734717 Jenny.north@dartington.org.uk 

The nominated child protection trustee for the WHG is:  

Professor John Drew 

Contact details:  

07946 854605 (call or text), or 020 8530 2585 jjhdrew@me.com 

 

Child Exploitation and Online Protection (CEOP) 

www.ceop.police.uk 

NSPCC Helpline 

0808 800 5000 

 

Roles and responsibilities 

All organisations must nominate a senior member of staff to coordinate child protection arrangements and this person is named in this policy guidance. The local authority maintains a list of all designated senior persons (DSPs) for safeguarding and child protection. 

The WHG has ensured that the DSP: 

  • is appropriately trained; 

  • acts as a source of support and expertise to the WHG community; 

  • understands Local Safeguarding Children Boards (LSCB) procedures;  

  • keeps written records of all concerns when noted and reported by the WHG community or when disclosed by a child or vulnerable person, ensuring that such records are stored securely and reported onward in accordance with this policy guidance; 

  • refers cases of suspected neglect and/or abuse to Local Authority Designated Officer (LADO) or police in accordance with this guidance and local procedure; 

  • develops effective links with relevant statutory and voluntary agencies; 

  • ensures that all staff indicate that they have read and understood this policy; 

  • liaises with the nominated trustee as appropriate; 

  • keeps a record of staff child protection professional development. 

 

The deputy designated person is appropriately trained and, in the absence of the designated person, carries out those functions necessary to ensure the ongoing safety and protection of any vulnerable people or children. In the event of the long-term absence of the designated person, the deputy will assume all of the functions above.  

The board of trustees ensures that the Lab has: 

  • a DSP for safeguarding and child protection who is a member of the senior management team and who has undertaken the approved LSCB training in inter-agency working, in addition to basic child protection training; 

  • Procedures for dealing with allegations of abuse made against members of the WHG community; 

  • Safer recruitment procedures that include the requirement for appropriate checks in line with national guidance; 

  • A training strategy that ensures all staff receive child protection training, with refresher training where appropriate; 

  • Arrangements to ensure that all temporary staff and volunteers are made aware of the WHG’s arrangements for vulnerable people and child protection. 

The Trustee Safeguarding Lead: 

  • ensures that the safeguarding policy and procedures are implemented and followed by all staff; 

  • allocates sufficient time and resources to enable the DSP and deputy to carry out their roles effectively; 

  • ensures that all staff feel able to raise concerns about poor or unsafe practice and that such concerns are handled sensitively and in accordance with the Lab’s whistleblowing procedures. 

 

We are committed to reviewing our policy and good practice annually. 


 2019 

Equal Opportunities Policy

1. Equal opportunities statement

The Dartington Service Design Lab (Lab) believes in the dignity of all people and their right to respect and equality of opportunity. We value the strength that comes with difference and the positive contribution that diversity brings to our organisation. 

As an employer we aim to eliminate prejudice and discrimination, and to promote good relations between different groups. 

We recognise that certain individuals and groups of people can experience significant disadvantage in society, including:

  • Minority Ethnic communities; 

  • Women (including pregnant women and nursing mothers); 

  • Disabled people; 

  • Lesbian, gay, bisexual, transgendered, questioning/queer, intersex, Asexual people, or other sexualities, sexes and genders (LGBTQIA+); 

  • Older people, children and young people; 

  • Religious and belief groups; 

And that people can be disadvantaged because of their marital or civil partnership status. 

As an employer, we will ensure that: 

  • Employees do not discriminate against anyone, or influence another employee to discriminate, tolerate or condone discriminatory practices, harass or abuse other employees or members of the public; 

  • We provide a safe, supportive and accessible working environment free from harassment and discrimination for existing and potential employees where individuals’ values, beliefs, identities and cultures are respected; 

  • We will develop inclusive initiatives to redress imbalances in our workforce at all levels, through recruitment, career development and training, and strong community links. 

It is the responsibility of every individual member of staff to uphold these values and act accordingly. We expect our staff to be treated with the same respect and dignity that we offer our supporters, funders and stakeholders. 

2. About this policy

2.1.  This policy sets out our approach to equal opportunities and the avoidance of discrimination at work. It applies to all aspects of employment with us, including recruitment, pay and conditions, training, appraisals, promotion, conduct at work, disciplinary and grievance procedures, and termination of employment.

2.2.  The Head of Operations is responsible for this policy and any necessary training on equal opportunities.

2.3. This policy does not form part of any employee's contract of employment and we may amend it at any time.

3. Discrimination

3.1. You must not unlawfully discriminate against or harass other people including current and former employees, job applicants, clients, customers, suppliers and visitors. This applies in the workplace, outside the workplace (when dealing with customers, suppliers or other work-related contacts, and on work-related trips or events including social events).

3.2. The following forms of discrimination are prohibited under this policy and are unlawful:

(a) Direct discrimination: treating someone less favourably because of a Protected Characteristic. For example, rejecting a job applicant because of their religious views or because they might be gay.

(b) Indirect discrimination:a provision, criterion or practice that applies to everyone but adversely affects people with a particular Protected Characteristic more than others and is not justified. For example, requiring a job to be done full-time rather than part-time would adversely affect women because they generally have greater childcare commitments than men. Such a requirement would be discriminatory unless it can be justified.

(c) Harassment: this includes sexual harassment and other unwanted conduct related to a Protected Characteristic, which has the purpose or effect of violating someone's dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. Harassment is dealt with further in our Anti-harassment and Bullying Policy.

(d) Victimisation: retaliation against someone who has complained or has supported someone else's complaint about discrimination or harassment. 

(e) Disability discrimination: this includes direct and indirect discrimination, any unjustified less favourable treatment because of the effects of a disability, and failure to make reasonable adjustments to alleviate disadvantages caused by a disability.


April 2019 

Anti-harassment and bullying policy

1. About this policy

1.1. The Lab is committed to providing a working environment free from harassment and bullying and to ensure that all staff are treated, and treat others, with dignity and respect.

1.2. This policy covers harassment or bullying that occurs at work and out of the workplace, such as on business trips or at work-related events or social functions. It covers bullying and harassment by staff (which may include consultants, contractors and agency workers) and also by third parties such as customers, suppliers or visitors to our premises. 

1.3. This policy does not form part of any employee's contract of employment and we may amend it at any time.

2. What is harassment?

2.1.  Harassment is any unwanted physical, verbal or non-verbal conduct that has the purpose or effect of violating a person's dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. A single incident can amount to harassment. 

2.2. It also includes treating someone less favourably because they have submitted or refused to submit to such behaviour in the past.

2.3. Unlawful harassment may involve conduct of a sexual nature (sexual harassment), or it may be related to age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation. Harassment is unacceptable even if it does not fall within any of these categories.

2.4. Harassment may include, for example:

(a) unwanted physical conduct or "horseplay", including touching, pinching, pushing and grabbing;

(b) unwelcome sexual advances or suggestive behaviour (which the harasser may perceive as harmless);

(c) offensive e-mails, text messages or social media content;

(d) mocking, mimicking or belittling a person's disability.

2.5. A person may be harassed even if they were not the intended "target". For example, a person may be harassed by racist jokes about a different ethnic group if the jokes create an offensive environment.

3. What is bullying?

3.1. Bullying is offensive, intimidating, malicious or insulting behaviour involving the misuse of power that can make a person feel vulnerable, upset, humiliated, undermined or threatened. Power does not always mean being in a position of authority, but can include both personal strength and the power to coerce through fear or intimidation. 

3.2. Bullying can take the form of physical, verbal and non-verbal conduct. Bullying may include, by way of example:

(a) physical or psychological threats;

(b) overbearing and intimidating levels of supervision;

(c) inappropriate derogatory remarks about someone's performance;

3.3. Legitimate, reasonable and constructive criticism of a worker's performance or behaviour, or reasonable instructions given to workers in the course of their employment, will not amount to bullying on their own.

4. If you are being harassed or bullied

4.1. If you are being harassed or bullied, consider whether you feel able to raise the problem informally with the person responsible. You should explain clearly to them that their behaviour is not welcome or makes you uncomfortable. If this is too difficult or embarrassing, you should speak to your line manager or the Head of Operations, who can provide confidential advice and assistance in resolving the issue formally or informally.

4.2.  If informal steps are not appropriate, or have not been successful, you should raise the matter formally under our Grievance Procedure.

4.3. We will investigate complaints in a timely and confidential manner. The investigation will be conducted by someone with appropriate experience and no prior involvement in the complaint, where possible. Details of the investigation and the names of the person making the complaint and the person accused must only be disclosed on a "need to know" basis. We will consider whether any steps are necessary to manage any on-going relationship between you and the person accused during the investigation.

4.4. Once the investigation is complete, we will inform you of our decision. If we consider you have been harassed or bullied by an employee, the matter will be dealt with under the Disciplinary Procedure as a case of possible misconduct or gross misconduct. If the harasser or bully is a third party such as a customer or other visitor, we will consider what action would be appropriate to deal with the problem. Whether or not your complaint is upheld, we will consider how best to manage any ongoing working relationship between you and the person concerned.

5. Protection and support for those involved

Staff who make complaints or who participate in good faith in any investigation must not suffer any form of retaliation or victimisation as a result. Anyone found to have retaliated against or victimised someone in this way will be subject to disciplinary action under our Disciplinary Procedure.

6. Record-keeping

Information about a complaint by or about an employee may be placed on the employee's personnel file, along with a record of the outcome and of any notes or other documents compiled during the process. These will be processed in accordance with our Data Protection Policy.


Anti-corruption and bribery policy

1. About this policy

1.1. It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships. 

1.2. Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any non-employee who breaches this policy may have their contract terminated with immediate effect.

1.3. This policy does not form part of any employee's contract of employment and we may amend it at any time. It will be reviewed regularly.

2. Who must comply with this policy?

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, interns, agents, contractors, external consultants, third-party representatives and business partners.

3. What is bribery?

3.1.  Bribery means a financial, other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.

3.2. Bribery includes offering, promising, giving, accepting or seeking a bribe.

3.3. All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with your manager or the Head of Operations.

3.4. Specifically, you must not:

(a) give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;

(b) accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else;

(c) give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure;

3.5. You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

4. Gifts and hospitality

4.1. See also Chapter Para 6 – Entertaining; This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services. 

4.2.  A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).

4.3. Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret. Gifts must be given in our name, not your name.  Incentives to research participants fall outside of this policy but should be carefully considered within the best practise guideleines for ethical research. 

4.4. Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers and business partners.

5. Record-keeping

5.1. You must declare and keep a written record in the Hospitality Book, held by the Head of Operations, of all hospitality or gifts given or received over the value of £20. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure. 

5.2. All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept "off-book" to facilitate or conceal improper payments.

6. How to raise a concern

If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must notify the Head of Operations as soon as possible.


Conflicts of Interest

1. Conflicts of Interest

1.1. Employees, and Trustees should all put the interests of the Lab first. A conflict of interest may arise where the objective of the organisation and the interests and loyalties of Trustees, employees do not coincide or appear to clash. The Standards and Key Principles of the Organisation (i.e. the ‘code of conduct’) at Para 5 on Page 2 makes our intentions clear and provides guidance on what standards of behaviour are expected. It should be reviewed annually or as the need arises. 

1.2. Employees, Trustees nor their friends and family should not be favoured especially in terms of service, employment or funding. 

1.3. Trustees and staff have a legal obligation to act in our best interest, and in accordance with our governing document. Such conflicts may create problems, and can:

(a) Inhibit free discussion;

(b) Result in decisions or actions that are not in our interest; 

(c) Risk the impression that the charity has acted improperly;

(d) Even the appearance of a conflict of interest can damage our reputation, so conflicts need to be managed carefully and with transparency. The aim of this policy is to protect both the Lab and the individuals involved from any appearance of impropriety.

2. The law

2.1. The law states that Trustees cannot receive any benefit from their charity in return for any service they provide to the charity unless they have express legal authority to do so. This legal authority will come either from a clause in our governing document or, where there is no adequate clause in the governing document, from the Charity Commission or the Court.

2.2. It is acceptable to repay reasonable out of pocket expenses to Trustees. Any costs that are necessary to allow a Trustee to carry out his or her duties as a Trustee can be classed as expenses and recovered from the Lab or met directly by us. This may include travel costs and the cost of providing care for a dependent whilst attending a Trustee meeting or when undertaking Trustee business. 

2.3. Conflicts of interest may come in a number of different forms:

(a) Direct financial gain or benefit to the Trustee, such as payment to a Trustee for services provided to the Lab or the award of a contract to another organisation in which a Trustee has an interest and from which a Trustee will receive a financial benefit; or the employment of a Trustee in a separate post within the Lab, even when the Trustee has resigned in order to take up the employment. 

2.4. Indirect financial gain, such as employment by the Lab of a relative or friend of a Trustee or external funding for personal interests or loyalties.

2.5. Non-financial gain, such as when a user of the Lab’s services is also a Trustee. 

3. Policy

3.1. Trustees and/or Director and/or staff should declare their interests in connection with their role at the Lab. A Declaration of Interests form can be obtained from Operations for this purpose, listing the types of interests you should declare.  Failure to declare an interest could justify disciplinary action. 

3.2. If you are not sure what to declare, or whether/when your declaration needs to be updated, please err on the side of caution. If you would like to discuss this issue, please contact your supervisor who will consult with the Chair of Trustees for confidential guidance.

3.3. Interests will be recorded on our Register of Interests, which will be maintained by the Secretary to the Trustees.

4. Data Protection

4.1. The information provided will be processed in accordance with data protection principles as set out in the Data Protection Act 1998. Data will be processed only to ensure that Trustees and staff act in the best interests of the Lab. The information provided will not be used for any other purpose.

5. Decisions taken where a trustee or member of staff has an interest

5.1. In the event of the Board having to decide upon a question in which a Trustee or a member of staff has an interest, all decisions will be made by vote, with a two-thirds majority being required. A quorum must be present for the discussion and decision; interested parties will not be counted when deciding whether the meeting is quorate. Interested Board members may not vote on matters affecting their own interests. 

5.2. All decisions under a conflict of interest will be recorded by the Secretary to the Trustees meeting and reported in the minutes of the meeting. The report will record:

(a) the nature and extent of the conflict;

(b) an outline of the discussion;

(c) the actions taken to manage the conflict;

(d)  where a Trustee benefits from the decision, this will be reported in the Annual Report and Accounts in accordance with SORP 2015[1].

6.  Managing contracts/applying for funding

6.1. Any Trustee who has a financial interest in a matter under discussion, should declare the nature of their interest and withdraw from the meeting, unless they have dispensation to speak. 

6.2.  If a Trustee has any interest in the matter under discussion, which creates a real danger of bias, that is, the interest affects their, or a member of their family or household, more than the generality affected by the decision, they should declare the nature of the interest and withdraw from the meeting, unless they have dispensation to speak. 

6.3. If a Trustee has any other interest which does not create a real danger of bias, but which might reasonably cause others to think it could influence their decision, they should declare the nature of the interest, but may remain in the room, participate in the discussion, and vote if they wish. 

6.4. The Chair of Trustees should be consulted if there is any doubt about the application of these rules. Trustees’ interests will be listed in a register. 

6.5.  Any member of staff who also has such conflicts of interest when applying for funding or contracts should also declare their interest to their supervisor and then to Trustees.

7. Other Employment

7.1. You must inform the Lab in writing before taking up any other paid employment and must keep the Lab informed of the nature and hours of any such work.  If it becomes apparent that any such employment is having an adverse effect on the work of the Lab or the staff member’s ability to undertake their job, or their health, it may require the staff member to cease such employment or reduce the hours worked.

8. Intellectual Property

8.1.  Without prejudice to Section 11(2) of the Copyright Designs Patents Act 1988, as a the Lab employee, you agree to assign to the Lab all intellectual property (including but not only limited to copyright material) accredited to you during the period of your employment.

8.2. Any reports, research data, papers, articles or other materials produced by employees on behalf of the Lab will remain the sole property of the Lab.

8.3. This will not include intellectual property that is not connected in any way whatsoever with your employment. You agree to complete any documents, which the Lab requires, to make this clause effective during and after the term of your contract of employment.

8.4.  You agree that this clause shall continue after the termination of your employment.

9. Confidentiality

9.1. You will have access to and be entrusted with information in respect of the business, dealings, transactions and affairs of the Lab, all of which information is or may be confidential. You should not, except in the proper course of your duties either during or after the period of your employment, divulge to any person or persons whatsoever, or otherwise make use of, and shall use their best endeavours to prevent the publication or disclosure of, any private, secret or confidential information concerning the business, dealings, transactions or affairs of the Lab. These restrictions do not apply to information or knowledge which may (otherwise than through the default of an employee) become available to the public generally.

9.2. The Lab is entitled to injunctive relief in order to restrain or prevent any authorised disclosure.

9.3. All notes, memoranda, records and writing made by you relating to the business of the Lab shall be the property of the Lab and shall be surrendered to someone duly authorised at the termination of the employment or at the request of the Lab at any time during the course of the employment.

9.4. You will not at any time (whether before or after the termination of your employment) make any untrue or misleading statement in relation to the Lab or after the termination of the employment represent herself/himself as being employed by or connected with the Lab.

[1] Charities have to prepare accounts in accordance with the Statement of Recommended Practice (SORP) also known as the charity SORP. The most recent version of this was issued in July 2014 and as it applies for financial periods commencing on or after 1 January 2015, it is known as SORP 2015.

 


Whistleblowing policy

1.  About this policy

1.1. We are committed to conducting our business with honesty and integrity and we expect all staff to maintain high standards. Any suspected wrongdoing should be reported as soon as possible.

1.2. This policy covers all employees, officers, consultants, contractors, interns, casual workers and agency 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. What is whistleblowing?

Whistleblowing is the reporting of suspected wrongdoing or dangers in relation to our activities. This includes bribery, fraud or other criminal activity, miscarriages of justice, health and safety risks, damage to the environment, any breach of legal or professional obligations, bringing the Lab into disrespect, bullying or other potential breaches of the disciplinary code.

3. How to raise a concern

3.1. We hope that in many cases you will be able to raise any concerns with your manager. However, where you prefer not to raise it with your manager for any reason, you should contact the Head of Operations or the Director. Contact details are at the end of this policy.

3.2. We will arrange a meeting with you as soon as possible to discuss your concern. You may bring a colleague or union representative (if appropriate) to any meetings under this policy. Your companion must respect the confidentiality of your disclosure and any subsequent investigation. 

4. Confidentiality

We hope that you will feel able to voice whistle-blowing concerns openly under this policy. Completely anonymous disclosures are difficult to investigate. If you want to raise your concern confidentially, we will make every effort to keep your identity secret and only reveal it where necessary to those involved in investigating your concern.

5. External disclosures

5.1. The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases you should not find it necessary to alert anyone externally.

5.2. The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. We strongly encourage you to seek advice before reporting a concern to anyone external. Public Concern at Work operates a confidential helpline. Their contact details are at the end of this policy.

6. Protection and support for whistle-blowers

6.1. We aim to encourage openness and will support whistle-blowers who raise genuine concerns under this policy, even if they turn out to be mistaken.

6.2. Whistle-blowers must not suffer any detrimental treatment as a result of raising a genuine concern. If you believe that you have suffered any such treatment, you should inform the Head of Operations immediately. If the matter is not remedied you should raise it formally using our Grievance Procedure.

6.3. You must not threaten or retaliate against whistle-blowers in any way. If you are involved in such conduct you may be subject to disciplinary action. 

6.4. However, if we conclude that a whistle-blower has made false allegations maliciously or with a view to personal gain, the whistle-blower may be subject to disciplinary action.

6.5. Public Concern at Work operates a confidential helpline. Their contact details are at the end of this policy.

7. Contacts

Whistleblowing Trustee

(In the event of the requirement to discuss a Director or the whole management team)

John Drew (Trustee)

07946 854605 (call or text), or

020 8530 2585

jjhdrew@me.com

Whistleblowing Officer

Brian Warren

Head of Operations

01803 762 400 / 07817 220009

Director 

Tim Hobbs

Director

01803 762420 / 07856 686820

Public Concern at Work 

(Independent whistleblowing charity)

Helpline: (020) 7404 6609

E-mail: whistle@pcaw.co.uk

Website: www.pcaw.co.uk

 


Social Media Policy

1. About this policy

1.1. 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, Whisper, Instagram, Vine, Tumblr etc. and all other social networking sites, Internet postings and blogs. It applies to use of social media for business purposes as well as personal use that may affect our business in any way.

1.3.  This policy does not form part of any employee's contract of employment and we may amend it at any time. 

2. Personal use of social media

2.1. Occasional personal use of social media during working hours is permitted so long as it does not involve unprofessional or inappropriate content, does not interfere with your employment responsibilities or productivity and complies with this policy.

3. Prohibited use

3.1. You must avoid making any social media communications that could damage our business interests or reputation, even indirectly.

3.2. You must not use social media to defame or disparage us, our staff or any third party; to harass, bully or unlawfully discriminate against staff or third parties; to make false or misleading statements; or to impersonate colleagues or third parties.

3.3. You must not express opinions on our behalf via social media, unless expressly authorised to do so by your manager. You may be required to undergo training in order to obtain such authorisation.

3.4. You must not post comments about sensitive business-related topics, such as our performance, or do anything to jeopardise our trade secrets, confidential information and intellectual property. You must not include our logos or other trademarks in any social media posting or in your profile on any social media.

3.5. The contact details of business contacts made during the course of your employment are our confidential information. On termination of employment you must provide us with a copy of all such information, delete all such information from your personal social networking accounts and destroy any further copies of such information that you may have.

3.6. Any misuse of social media must be reported to the Head of Operations. 

4. Guidelines for responsible use of social media

4.1. You should make it clear in social media postings, or in your personal profile, that you are speaking on your own behalf. Write in the first person and use a personal e-mail address.

4.2. Be respectful to others when making any statement on social media and be aware that you are personally responsible for all communications which will be published on the Internet for anyone to see.

4.3.  If you disclose your affiliation with us on your profile or in any social media postings, you must state that your views do not represent those of your employer (unless you have been authorised to speak on our behalf as set out in paragraph 3.3). You should also ensure that your profile and any content you post are consistent with the professional image you present to clients and colleagues.

4.4. If you are uncertain or concerned about the appropriateness of any statement or posting, refrain from posting it until you have discussed it with your manager.

4.5.  If you see social media content that disparages or reflects poorly on us, you should contact your line manager.

5. Breach of this policy

5.1. Breach of this policy may result in disciplinary action up to and including dismissal. Any member of staff suspected of committing a breach of this policy will be required to co-operate with our investigation, which may involve handing over relevant passwords and login details.

5.2. You may be required to remove any social media content that we consider to constitute a breach of this policy. Failure to comply with such a request may in itself result in disciplinary action.

6. Reporting Security Incidents

6.1.  All staff shall report any security incident, weakness or significant software malfunction at the earliest opportunity to the Head of Operations.  Any member of staff identifying a security incident shall record the details in the Security Incident Log Book held in the Operations Office, Higher Mills.

 


Health and safety policy

1.  About this policy

1.1. This policy sets out our arrangements for ensuring we meet our health and safety obligations to staff and anyone visiting our premises or affected by our work.  Those employees who work and operate from home either permanently or temporarily, should always make themselves familiar and comply with all local health, safety, environmental and emergency procedures.

1.2. The Director has overall responsibility for health and safety and the operation of this policy.

1.3. This policy does not form part of any employee's contract of employment and we may amend it at any time. We will continue to review this policy to ensure it is achieving its aims.

2. Your responsibilities

2.1. All staff share responsibility for achieving safe working conditions. You must take care of your own health and safety and that of others, observe applicable safety rules and follow instructions for the safe use of equipment. 

2.2. You should report any health and safety concerns immediately to the H&S Coordinator - Operations Support or the H&S Manager - the Head of Operations – their responsibilities are set out at paras 12 and 13.

2.3. You must co-operate with managers on health and safety matters, including the investigation of any incident.

2.4. Failure to comply with this policy may be treated as misconduct and dealt with under our Disciplinary Procedure.

3. Information and consultation

We will inform and consult directly with all staff regarding health and safety matters.

4. Training

4.1 . We will ensure that you are given adequate training and supervision to perform your work competently and safely appropriate training to your role. 

5. Equipment

You must use equipment in accordance with any instructions given to you. Any equipment fault or damage must immediately be reported to your line manager. Do not attempt to repair equipment unless trained to do so.

6. Accidents and first aid

6.1. Details of first aid facilities and the names of trained first aiders will be provided to individuals during their induction.  Those in staff operating from satellite offices should familiarise themselves with locally trained personnel and follow their procedures.

6.2. Regardless of where the incident happened, all accidents and injuries at work, however minor, should be reported to Operations Support and recorded in the Accident Book, which is kept in the Operations Office.

7. Fire safety

7.1. All staff should familiarise themselves with the fire safety and emergency instructions to any office where they are permanently or temporarily working, including their own home work environment. 

7.2. If you hear a fire alarm, leave the building immediately by the nearest fire exit and go to the fire assembly point.

7.3. Fire drills will be held at least every 12 months and must be taken seriously. We also carry out regular fire risk assessments and regular checks of fire extinguishers, fire alarms, and escape routes.

8. Risk assessments and measures to control risk

We carry out general workplace risk assessments annually. The purpose is to assess the risks to health and safety of employees, visitors and other third parties as a result of our activities, and to identify any measures that need to be taken to control those risks.

9. Computers and display screen equipment

9.1. As your computer/laptop screen or other display screen equipment (DSE) is a significant part of your work, you are entitled to an assessment and regular eyesight tests by an optician at our expense. 

9.2. Further information on workstation assessments, eye tests and the use of DSE can be obtained from Operations Support.

10. Stress at Work

10.1. The Health and Safety Executive (HSE) reminds employers of its legal obligations to control stress at work under the 1974 Health and Safety at Work Act, and the Management of Health and Safety at Work Regulations 1992, 1999 – particularly in incorporating stress as a potential workplace hazard in any workplace risk assessment. 

11. Alcohol and Drugs Misuse 

11.1. The Lab is committed to the promotion of good health and well-being of all its employees.

11.2. Lab will deal with all employees who are experiencing problems from drug, alcohol or substance misuse in a fair manner and will encourage them to seek professional support.  Dealing with misuse positively reduces the risk of accidents, however it is a disciplinary offence for any employee to be unfit for work due to the influence of alcohol, drugs or substances. Any member of staff found to be under the influence of drugs, alcohol or other substances whilst at work will be sent/taken home.

11.3. Tackling drug, alcohol and substance misuse in the workplace is an essential requirement of the Lab if it is to carry out its obligations under the provisions of the Health and Safety at Work Act 1974 and Misuse of Drugs Act 1971.

11.4. It is a criminal offence for any employee to possess, supply, offer to supply, or produce controlled drugs.  The Lab is liable to be prosecuted if it allows controlled drugs to be supplied, or offered for supply, or to be produced or taken onto its premises.  The Lab forbid the possession, use of distribution of non-prescribed illegal drugs on its site. If anyone on the Lab business is found to be involved in any of these activities, this will be treated as gross misconduct.  In addition, the police will be informed of any activities connected with controlled drugs on the Lab property.

12. Health and Safety Manager’s Responsibilities

12.1. The Head of Operations is responsible to the Director for:

(a) The planning, implementation, control, monitoring and review of the Lab’s Health and Safety policy, and specific arrangements and procedures. (assisted by the Health and Safety Coordinator).  

(b) Coordinating the management teams in implementation of the Health and Safety policy and its arrangements and procedures and act as the focal point for advice. 

(c) Conducting regular inspections of the office location, and check working practices in them. 

(d) Ensuring that Accidents and Incidents are recorded and reported, if appropriate, to the Health and Safety Executive, and that appropriate remedial action is taken.  

(e) Annual review of the provision of First Aid (May), emergency procedures (September) and safety procedures (September). 

13. Health and Safety Coordinator’s Responsibilities

13.1. The Health and Safety Coordinator is responsible to the Head of Operations and the Director for discharging their responsibilities, in regards to the relevant statutory provisions.  In this respect shall:

(a) Act as advisor to the Head of Operations on all matters HS&W and assist in planning, implementation, control, monitoring and review of the Unit’s Health and Safety policy, and specific arrangements and procedures planning;

(b) Be familiar with the contents of the policy and ensure that the policy and a safety compliance file is readily available to all employees; 

(c) Implement Fire Safety Procedures and ensure all employees, students and others are aware of it; 

(d) Nominate any fire safety personnel arrange training and regular fire drills; 

(e) Ensure the upkeep and maintenance of all equipment in relation to Fire Safety, (fixed systems, portable appliances and building infrastructure) ensuring they are readily available and useable at all times; 

(f) Ensure that fire safety risk assessments are suitable and sufficient; 

(g) Arrange the annual fire safety inspections and when there are changes to the fire safety risk assessment; 

(h) Where appropriate include fire safety in the regular health and safety reports to the Trustees;  

(i) Act as Asbestos Manager for the Buckfast Abbey site; 

(j) Monitor the formal defect reporting procedure;  

(k) Monitor that accidents, illnesses and incidents are reported and investigated and proper notifications are made to HSE. 


Smoking Policy

1. About this policy

1.1. We are committed to protecting your health, safety and welfare and that of all those who work for us by providing a safe place of work and protecting all workers, service users, customers and visitors from exposure to tobacco smoke or the vapour generated by e-cigarettes or similar devices.  This policy applies to all types of smoking, e-cigarettes or similar devices.

1.2. All of our workplaces (including our vehicles) are smoke-free in accordance with the Health Act 2006 and associated regulations. All staff and visitors have the right to a smoke-free environment.

1.3. This policy does not form part of any employee's contract of employment and it may be amended at any time.

1.4.  If you wish to suggest improvements to the policy or experience particular difficulty complying with it you should discuss the situation with your line manager.

2. Where is smoking banned?

2.1. Smoking is not permitted within our offices. The ban applies 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.

2.2. Anyone using our vehicles, whether as a driver or passenger, must ensure the vehicles remain smoke-free.

3. Where is smoking permitted?

You may only smoke outside and well away from the buildings/workplaces during breaks. When smoking outside, you must dispose of cigarette butts and other litter appropriately.

4. Breaches of the policy

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

4.2. Smoking in smoke-free premises or vehicles is also a criminal offence and may result in a fixed penalty fine and/or prosecution.