ETM Policies

ETM Policies

Table of contents:

Equal opportunities
Modern Slavery
Anti-bullying
Recruitment and promotion principles
Confidential reporting
Bribery
Grievance

Equal Opportunities, Diversity and Inclusion Policy

We acknowledge the multi-cultural and diverse nature of the UK workforce and society in general. We
therefore promote a working environment in which diversity is recognised, valued and encouraged. We are
committed to principles of fairness and mutual respect where everyone accepts the concept of individual
responsibility.

We expect you to treat everyone you encounter on our behalf fairly and with respect. We seek to nurture
positive relationships throughout and beyond our workforce. Everyone we employ has a role to play in the
development of our organisation. Nobody should feel excluded by their identity, background or
circumstances. We all have something positive to offer and we welcome the diversity of views and
opinions inclusive organisations embrace.

It is therefore your responsibility to make sure you observe and adhere to this policy at all times. We view
any breach seriously and will investigate, taking disciplinary action where necessary. This may include
dismissal in instances which we consider to be gross misconduct.
We recognise that discrimination in the workplace in any form is unacceptable and, in most cases,
unlawful. Our policy seeks to ensure job applicants and employees are treated fairly and without favour or
prejudice. We are committed to applying this throughout all areas of employment including recruitment
and selection, training and development, benefits, rewards and promotion, dealing with grievances and
disciplinary issues.

We also recognise that equality of opportunity is best achieved by day to day commitment throughout the
organisation and we offer support and training, where necessary, to achieve and maintain this.
Our policy complies with current legislation. We review our policy regularly and will update it when
necessary. However, we recognise that equality, diversity and inclusion are best achieved by everyone’s
day to day commitment. We will consider support and training where necessary to achieve, maintain and
promote our equality, diversity and inclusion agenda.

Protected Characteristics
No job applicant, employee or anyone our organisation deals with, receives less favourable treatment
because of their protected characteristics which are:-

  • Age
  • Disability
  • Gender Reassignment
  • Marriage and Civil Partnership
  • Pregnancy and Maternity
  • Race (including colour, nationality, ethnic or national origin)
  • Religion or Belief
  • Sex
  • Sexual Orientation

Recruitment and Promotion
The selection methods we use for recruitment and promotion are related to the requirements of the job.
We do not seek irrelevant qualifications, experience or skills. Applicants for employment are shortlisted/
selected solely on the basis of their assessed capability for the role.

Our Recruitment and Employment Principles
We abhor recruitment based on harbouring or transporting people into situations of exploitation through
violence, deception or coercion. We condemn employment practices in which people are subjected to
servitude or forced to work against their will.

We embrace principles supportive of equal treatment without discrimination and with the protection of
employment law for all staff. They are broadly based on those developed by the United Nations,
International Labour Organisation, Institute for Human Rights and Business and the Ethical Trading
Initiative.

We treat all staff equally, without discrimination and with respect for their human rights. All staff enjoy the
protection of relevant UK law in respect of their employment.

In particular:-

  • We bear the full costs of recruitment and do not charge staff fees for hiring, placing or promoting
    them.
  • We provide written contracts of employment to all staff as required by law. These documents
    explain everything in a clear and transparent way.
  • We support the right to seek, obtain and hold employment without discrimination and with
    complete respect for dignity.
  • We do not coerce anyone to work for us. When you choose to work for us you do so voluntarily.
  • You must prove your entitlement to work in the UK. However, we do not hold or retain original
    passports, identity documents or residency papers. You should retain such documents personally.
  • Everyone is paid regularly, in accordance with their terms and conditions. Pay rates always meet
    or exceed the UK legal minimum and we provide a written summary of pay and deductions (pay
    slip) on every occasion.
  • Working hours and rest breaks always meet UK law. Details are set out in your Contract of
    Employment.
  • Everyone has the right to join or not join a trade union at their complete discretion.
  • We provide safe and decent working conditions with suitable training as necessary. Our operations
    comply with or exceed statutory health and safety standards.
  • We provide formal grievance provisions through which staff are free to lodge a work-related
    complaint or raise a matter of concern.
  • We do not impede anyone’s freedom of movement or their opportunity to seek employment
    elsewhere.
  • We do not use child labour. UK law governs the work of any young person we employ.

Our Supply Chain
We also encourage our suppliers to endorse such principles to demonstrate their opposition to human
trafficking and modern-day slavery.

Your Responsibilities
Each and every one of us is responsible for the success of this policy and we expect you to observe this
policy at all times. We also expect you to make a positive contribution towards maintaining an
environment of equal opportunity throughout the organisation.

You have individual responsibility to comply with the following:

  • Do not take unlawful discriminatory actions or decisions contrary to the spirit of this policy
  • Do not discriminate against, harass, abuse or intimidate anyone on account of their protected
    characteristics
  • Do not place pressure on any other employee to act in a discriminatory manner
  • Resist pressure to discriminate placed on you by others and report such approaches to an
    appropriate Manager
  • Co-operate when we investigate, including providing evidence of conduct which may amount to
    discrimination
  • Co-operate with any measures introduced to develop or monitor equal opportunity

Discrimination is not just treating one person less favourably than another. It can take place because:-

  • Someone associates with a person with a protected characteristic
  • Someone is believed to possess a protected characteristic (even though they don’t)
  • Something particularly disadvantages people who share a protected characteristic more than
    others

We expect you to treat, and be treated by, other employees and the people our organisation deals with
considerately and with respect.

If you feel subject to discrimination, make clear to the individual concerned that you find it unacceptable.
Face to face discussion at an early stage may be enough to resolve it without involving anyone else.
Alternatively, seek the help of a trusted colleague and ask them to approach whoever has caused you
offence.

If your concerns continue, or you consider an instance to be particularly serious, please implement the
grievance procedure. We assure you that grievances will be dealt with promptly and in a discreet and
caring manner.

Should you feel an individual grievance is not appropriate to the situation, you may consider using our
confidential reporting procedure.

 

Modern Slavery and Human Trafficking Statement July 2023

ETM Group Holdings Ltd takes its responsibilities in respect of modern slavery and human trafficking extremely seriously. We are committed to playing our small part in eradicating this modern-day scourge, which has been described as criminality hidden in plain sight.

Modern slavery is a heinous and often hidden crime. It includes slavery, servitude, forced and compulsory labour and human trafficking. Government research in 2018 established that it costs the UK economy between £3 and £4 billion annually. The National Crime Agency believes that modern slavery has still been on the increase in recent years.
Many victims are from Eastern Europe, Southeast Asia and Africa, lured to the UK under false pretenses or preying on their refugee status. Similarly, British victims tend to have fallen on difficult times, making them vulnerable to the lure of well-paid work which ultimately proves a cruel lie.

We present this statement in anticipation that ETM Group Holdings Ltd. will reach the financial threshold to lodge a statement, as required by section 54 of the Modern Slavery Act 2015, during 2023. ETM Group Holdings Ltd incorporates a number of subsidiaries which are also covered by this statement and set out in the schedule at Appendix A.

We have chosen to submit this statement now, voluntarily. The Board of ETM Group Holdings Ltd endorsed it at its meeting of 18th July 2023. It will review and update it following the publication of its financial statement and annual accounts for 22/23, due around September 2023. By this time we envisage our turnover will exceed the £36 million threshold.

As a main Board/Director with key responsibilities I am proud to present this voluntary statement of our action regarding modern slavery. We fully intend this to be a living policy that informs our culture and development, and it will be updated periodically. It will always be displayed prominently on our website by hyperlink from the home page.

If you wish to ask anything about the content of this statement, I have provided my contact details below and I will be pleased to hear from you.

We are a relatively young Group, founded in 2000, whose activities are within the hospitality sector. From one venue in Clerkenwell, we now have a portfolio of 15 sites. ETM has a reputation for creating lasting experiences for their guests by combining the best seasonal British produce with excellent service in some of London’s most beautiful settings.

We have not encountered any instances of modern slavery or human trafficking in our 20 plus years of existence. Nevertheless, our Board and management team remain aware, vigilant and watchful for possible instances.

Almost all staff recruitment is under our direct control and monitored from application stage onwards. If we employ minors under 18, or facilitate their work experience, we risk assess each situation. A member of local management is always identified as their specific, local contact or mentor.

Where we occasionally utilise agency staff, we only use reputable agencies that meet our standards. Even then, we conduct additional checks which include verifying each agency worker’s right to work in the UK.

We would describe our overall recruitment risk level as very low.

The nature of our activities means that we rely significantly on our supply chain. We source ingredients, food and beverages along with other consumables, smallware, furnishings, office supplies, promotional materials amongst others.

We attempt to ensure that no product/material/service we purchase, or labour used, was subject to slavery, exploitation, coercion or human trafficking. As a relatively small business, our ability to verify such assurances is, of course, limited. Should we discover infringements or have reason to disbelieve assurances we have received, we would review our relationship with that supplier.

Our suppliers fall into three broad categories. Categories one and two are directly subject to our supplier procurement policy. This requires conformity with twenty factors including: –

  • Follows local labour laws and upholds fair wages and working conditions.
  • Adheres to anti-child labour, forced labour and human trafficking policies.

Category three is for occasional, urgent or emergency supplies. In these rare instances we may not be able to utilise normal supplier procurement provisions. However, we still utilise organisations that are known to us or whose practices are verifiable, whenever possible.

We also utilise suppliers for certain services such as cleaning, maintenance etc. Services are again subject to our procurement process. In the case of construction projects, full tendering and due diligence also applies.

We would describe our overall supply chain risk level as low.

We operate a legally compliant, planned approach to procurement and payment. Our organisation is almost completely cashless. We do not see money laundering as a particular risk within our operations or venues.

We also ensure that relevant staff are aware of applicable provisions of the Bribery Act 2010. For instance, our employee handbook contains clear rules about how any gifts and hospitality are to be treated.

We acknowledge that seasonal work can present particular risks; especially where migrant labour is used. This is a very low risk area for our organisation. We do not rely on seasonal or migrant workers at all. Our employee handbook reflects our commitment to employ all our staff in a legally compliant manner.

The nature of certain products we source, such as fruit/wine and vegetables, means that seasonal pickers can be involved. As we have set out earlier, our suppliers must satisfy us that there is no forced labour involved and their seasonal workforce enjoy fair wages and appropriate working conditions. We make occasional contact with, or visits to, suppliers to verify this.

One of the most important factors in our success is undoubtedly our staff. We have already commented on our stringent recruitment principles and commitment to legally compliant terms and conditions of employment. We uphold the highest standards in our human resources policies and practices. We promote equality, diversity and inclusion.

  • You can view our Equal Opportunities, Diversity and Inclusion Policy here [hyperlink]
  • You can view our Recruitment and Promotion Principles here. [hyperlink]

Our recruitment and promotion principles enshrine a modern slavery and human trafficking guarantee. No member of staff is subject to forced labour or coercion: every member of staff enjoys 100% legally compliant employment.

We provide clear guidance to staff about tackling bribery and corruption. We operate specific provisions through which they can confidentially report concerns or ‘blow the whistle’. We have adopted measures to deal with instances of intimidation, bullying or harassment. All members of staff have access to our grievance procedure.

  • You can view our Bribery, Gifts and Hospitality provisions here [hyperlink]
  • You can view our Anti – Bullying and Harassment policy here [hyperlink]
  • You can view our Grievance procedure here [hyperlink]
  • You can view our Confidential Reporting and Whistleblowing policy here [hyperlink]

Provisions such as these reflect our commitment to the highest employment standards and are an important signpost in signalling our opposition to slavery, servitude, forced and compulsory labour and human trafficking.

Signed,

Landen Prescott Brann
CFO / Director
landen@etmgroup.co.uk
Tel: 07712077824

 

Non-Harassment and Non-Bullying Policy

We support your right and opportunity to seek, obtain and hold employment without discrimination and with
respect for your dignity. Our equal opportunities, diversity and inclusion provisions embrace principles
supportive of equal treatment without discrimination. We expect and require everyone to recognise and
observe the statutory protected characteristics.

Harassment and/or bullying in the workplace is unacceptable in any form and is unlawful. We are
committed to providing a working environment which is harmonious and acceptable to all. This also
applies to the people our organisation deals with. Our policy applies whether working at our premises or
remotely as well as to company sponsored events, activities and training. It also applies to work related
communications, paper based or electronic, you may initiate or receive.

We take reasonable steps to deal with any work orientated bullying and harassment complaints we
receive. There are, however, legal limitations to the issues we can currently address.

What is Harassment?
Harassment is “unwanted conduct related to a relevant protected characteristic, which violates an
individual’s dignity or creates an intimidating, hostile, degrading, humiliating or offensive environment for
that individual”.

Harassment is not only unacceptable language or behaviour which causes the recipient to be
embarrassed, offended or threatened; someone may complain about a particular behaviour that they find
offensive, even though it was not directed at them. Neither does the person complaining need to possess
the protected characteristic. It may also be behaviour directed at someone who associates with a person
who has a protected characteristic or because they are believed to possess a protected characteristic
(even if they don’t).

What is Bullying?
Bullying may be characterised as “offensive, malicious, intimidating or insulting behaviour”. It can be an
“abuse or misuse of power through means that undermine, humiliate, denigrate or injure the recipient”.

What is Sexual Harassment?
Sexual harassment is defined as unwanted conduct of a sexual nature. It has the effect of violating dignity
or creating an intimidating, hostile, degrading, humiliating or offensive environment for you. Workplace
sexual harassment is behaviour that distresses you and is, effectively, a form of sexualised bullying.

Your Responsibilities
It is your duty to treat people with respect; appreciating their feelings and considering their well-being in
what you say or do. What may be acceptable to one person may upset and/or intimidate another.
Harassment and bullying take many forms and can range from relatively mild banter to stalking or actual
physical violence. They can be delivered in many ways and this policy applies to all forms of
communication including text messages, email and comments posted on social networking sites.

Some Examples
The following are examples of behaviour which we consider to be unacceptable:

  • Coarse or insensitive jokes and pranks
  • Coarse or insensitive comments about appearance or character
  • Display or distribution of offensive material whether written or pictorial
  • Deliberate exclusion or isolation from conversation or activities
  • Unwelcome familiarity, body contact or stalking
  • Abusive, insulting, or threatening language
  • Demands or threats to intimidate or obtain favours
  • Threatened or actual violence
  • Inappropriate contributions to social networks, blogs or messaging services that potentially violates
    dignity

Some Examples of Sexual Harassment

  • Sexually degrading comments or gestures
  • Staring, leering, whistling and cat calls
  • Sexual teasing, jokes, remarks or questions
  • Ridiculing someone because of their chosen gender identity
  • Text messages, images or emails featuring sexual content
  • Sexual assault, unwelcome sexual advances and touching
  • Offers of rewards for sexual favours or penalties for refusing

These examples are indicative and not intended to be an exhaustive list.

We will investigate all allegations of such behaviour thoroughly. Offenders are liable to disciplinary action
and, in serious cases, dismissal. We conduct investigations fairly and, as far as possible, confidentially.
However, we cannot guarantee to prevent identities or personal details being revealed, especially where
infringements are established.

If you feel you are being harassed or bullied, the first step is to make it clear that you want it to stop. Tell
the person harassing or bullying you that you find such behaviour unacceptable. Face to face discussion
at an early stage is often enough to stop such behaviour. Alternatively, you could seek the help of a
trusted colleague and ask them to approach the person causing offence on your behalf.
If the behaviour continues, or you consider an instance to be particularly serious, please implement the
grievance procedure. We assure you that grievances will be dealt with promptly and in a discreet and
caring manner.

We appreciate that an act of bullying or harassment may impact on your employment even though not
directly connected. For instance, someone may repeatedly follow you to or from work (stalking). You
should advise your line manager, confidentially, about any such issue in the first instance. This will enable
us to consider whether there are any practical ways we can support you.

Where you make or support a complaint in good faith, you will not be victimised for doing so regardless of
the outcome.

We are unable, however, to protect anyone who maliciously makes or supports an untrue complaint.

We take these matters very seriously as malicious complaints of harassment or bullying can have a
serious and detrimental effect upon a colleague and the workplace generally. Any unwarranted allegation
of harassment or bullying made in bad faith will be investigated and dealt with via our disciplinary
procedure.

 

Recruitment and Promotion

The selection methods we use for recruitment and promotion are related to the requirements of the job. We do not seek irrelevant qualifications, experience or skills. Applicants for employment are short-listed/selected solely on the basis of their assessed capability for the role.

Our Recruitment and Employment Principles

We abhor recruitment based on harbouring or transporting people into situations of exploitation through violence, deception or coercion. We condemn employment practices in which people are subjected to servitude or forced to work against their will.

We embrace principles supportive of equal treatment without discrimination and with the protection of employment law for all staff. They are broadly based on those developed by the United Nations, International Labour Organisation, Institute for Human Rights and Business and the Ethical Trading Initiative.

We treat all staff equally, without discrimination and with respect for their human rights. All staff enjoy the protection of relevant UK law in respect of their employment.

In particular:-

  • We bear the full costs of recruitment and do not charge staff fees for hiring, placing or promoting them.
  • We provide written contracts of employment to all staff as required by law. These documents explain everything in a clear and transparent way.
  • We support the right to seek, obtain and hold employment without discrimination and with complete respect for dignity.
  • We do not coerce anyone to work for us. When you choose to work for us you do so voluntarily.
  • You must prove your entitlement to work in the UK. However, we do not hold or retain original passports, identity documents or residency papers. You should retain such documents personally.
  • Everyone is paid regularly, in accordance with their terms and conditions. Pay rates always meet or exceed the UK legal minimum and we provide a written summary of pay and deductions (pay slip) on every occasion.
  • Working hours and rest breaks always meet UK law. Details are set out in your Contract of Employment.
  • Everyone has the right to join or not join a trade union at their complete discretion.
  • We provide safe and decent working conditions with suitable training as necessary. Our operations comply with or exceed statutory health and safety standards.
  • We provide formal grievance provisions through which staff are free to lodge a work-related complaint or raise a matter of concern.
  • We do not impede anyone’s freedom of movement or their opportunity to seek employment elsewhere.
  • We do not use child labour. UK law governs the work of any young person we employ.

 

Whistleblowing Policy

We operate a confidential reporting procedure. It’s available to everyone irrespective of length of service
or position.

Our procedure provides you with access to a safe and effective means of reporting matters of genuine
concern. This could be something inappropriate about the way you believe we run our organisation, or it
could be something inappropriate you believe another employee is doing. It could be perceived
misconduct or some other wrongdoing. It is not intended for personal matters relating to your own
contractual terms and conditions of employment. You must deal with such matters through our grievance
procedure.

We acknowledge that it is never easy to report a concern. This is particularly the case when you observe
serious misconduct or discover unlawful acts. However, we urge you to refer such matters at the earliest
opportunity. This allows us to respond speedily and effectively, before problems worsen. As far as we are
able, we will deal with anything you report promptly and confidentially. To ensure this, it’s important you
follow our procedure.

Guiding Principles
We must all be watchful for unlawful or unethical conduct at work. Preventing and eliminating workplace
wrongdoing is important. We all have a duty to report such inappropriate behaviour or activity.

We will consider matters you raise under this procedure confidentially and will investigate them promptly
and thoroughly.

We will not victimise or penalise you for raising a reasonable belief under this procedure. This also applies
if you come forward with genuine concerns which later turn out not to be justified.

You cannot be instructed to cover up wrongdoing or told not to report genuine concerns. This applies even
if the person telling you to do so is someone in authority such as a Manager. To tell you to behave in this
way is itself a serious disciplinary offence.

If anyone attempts to intimidate, bully, harass or victimise you for reporting something through this
procedure you must tell us. To behave in this way is itself a serious disciplinary offence.

We treat misconduct or wrongdoing uncovered following an investigation under this procedure as a
disciplinary matter. We may also have to report it externally, for instance, to a statutory body.

Our Procedure
Initially, you should report concerns to your Line manager. If you are unsure whether to raise the matter,
you can talk confidentially with that person. If you have concerns that your manager may be involved,
please contact a more senior Manager/Director.

Your line manager will either investigate your allegation personally or refer it to someone more senior. You
will be advised if it is to be referred elsewhere. On conclusion of the investigation, we will advise you of
the outcome. We will explain what action we are taking. If we do not intend to take any action, we will
explain why.

If you do not receive an acknowledgement of your concerns within seven days, please contact a more
senior Manager/Director. You can also do this should you believe investigation has been insufficient. Very
occasionally you may believe your concerns have not been considered at a high enough level. Again,
please contact a more senior Manager/Director in such circumstances. It’s very important to us that you
have complete confidence in this procedure.

Public Interest Disclosures
The law provides special protection for workers who make what are known as “public interest disclosures”.
This is also known as “whistle-blowing”. Officially, they are qualifying disclosures made in accordance with
current public interest disclosure legislation. They only apply when you report something which is in the
public interest. You must reasonably believe it to be so because it concerns:-

  • A criminal offence
  • A miscarriage of justice
  • An act creating risk to health and safety
  • An act causing damage to the environment
  • A breach of another legal obligation we may have
  • Our concealment of any of the above

We do not expect you to provide definitive proof of such wrongdoing. However, you must have a
reasonable belief that it is, has been or is likely to take place. Providing you follow the above procedure
we will investigate urgently. We do not expect you to undertake this aspect yourself. Our guiding
principles are always at the forefront of any investigation we carry out.

It’s possible that our investigation may not satisfy every concern you have. Where the matter is a
protected disclosure you may be able to refer it to a statutory agency. This only applies where you refer
something which you reasonably believe is in the public interest, as defined above. Statutory agencies
include HM Revenues and Customs, Office of Fair Trading, Health and Safety Executive and Environment
Agency.

Making Malicious Allegations
This procedure is intended to enable you to identify or support genuine concerns. Our approach is that we
are interested in the substance of any disclosure. Why you choose to raise or support a concern is not our
focus. We encourage you to come forward with any genuine concern, even if it later turns out not to be
justified. However, we have a fair expectation that you reasonably believe what you are saying to be true.
Your report must be honest and sincere in its intention.

If we identify that you deliberately made or supported false or malicious allegations such as false
allegations made in spite or for personal gain, this would be a disciplinary matter. Following investigation,
should we find that you have done so, this is potentially very serious misconduct or even gross misconduct
which may result in summary dismissal.

Approaching External Organisations
Under no circumstances should you approach a commercial organisation such as a media outlet instead of
utilising this procedure. Neither, in the first instance, should you publish or promote your concerns on
social networking sites, blogs etc. If you do so, you jeopardise our opportunity to investigate your
concerns properly. Such action also negates our promise to deal with matters confidentially. If you fail to
use this procedure it also impedes our ability to provide you with the protections it envisages.

We hope you have complete confidence in our procedure. However, if there are exceptional
circumstances where you feel unable to utilise it to make a public interest disclosure, you should contact
the appropriate statutory agency.

We may consider deliberate violations or breaches of our procedure to be acts of serious misconduct. We
will investigate your actions utilising our disciplinary procedure. Following investigation, should we
conclude your actions amounted to gross misconduct, this may result in summary dismissal.

 

Gifts and Hospitality

The Bribery Act 2010 makes it an offence to offer, promise or give a bribe. It is also an offence to request, agree to receive or accept a bribe.

A bribe is “a financial or other advantage offered or requested with the intention of inducing or rewarding improper performance of a relevant function or activity”. It also applies where you “know or believe that acceptance would constitute improper performance of a function or activity”.

It is our policy to conduct our activities in an open, honest and transparent way. We do not condone the use of corrupt practices or acts of bribery to obtain an unfair advantage. We adhere to the highest ethical standards and this is reflected in every aspect of the way in which we operate.

You must be alert to attempts to influence you inappropriately or to engage in/facilitate bribery. This is especially relevant to those procuring goods or services or dealing with third parties on our behalf. For instance, you may be offered excessive hospitality or gifts to facilitate business dealings. If you are unsure about when and what levels of hospitality are acceptable, please check with your line manager before accepting anything.
You must not seek or accept any inducement designed to influence you inappropriately in the performance of your role.

Do not seek or accept money, gifts or other rewards from customers, suppliers, any other person or organisation with whom we do (or might develop) business. This avoids any misunderstandings or allegations of impropriety. It is important you do not act inconsistently with our standards or, however inadvertently, impugn our integrity. Accepting a gift which influences or seems to influence your actions or decisions on our behalf may do this.

You may accept small, genuine tokens of appreciation or gratitude. However, they must be proportionate, reasonable and of limited monetary value and you must always declare them to your line manager. You must not treat the person/organisation that provides such gifts more favourably than our other clients/suppliers, etc. If you are unsure if the gift is acceptable or if you feel that refusal of the gift or hospitality might cause a difficult situation, check with your line manager first. Similarly, check with your line manager if you are at all unsure about any business gift or hospitality you intend to offer.

This policy does not apply to promotional items such as stationery or pens with a logo or company name, provided the items have no significant monetary value.

We are committed to this policy and take a “zero tolerance” approach to any act of bribery or corruption by a member of staff. We view breaches as serious misconduct which, following investigation, may lead to disciplinary action. The sanction may include summary dismissal if we believe your action amounted to gross misconduct.

 

Grievance Procedure

Introduction
Where possible, you should try to settle minor, day to day, work-related issues informally. Please do this
via your line manager. If the issue concerns your line manager, you can raise it with their manager. We
recommend discussing any concern promptly. This is often the best way to resolve matters speedily,
effectively and without need for formality.

Our Procedure
Our formal grievance procedure allows you to express a complaint or identify a matter of concern still
remaining unresolved. It provides an opportunity for us to consider issues you can’t resolve informally.
You can also use it where you believe an informal approach would be inappropriate. The procedure is
open to you at any time and we always try to deal with issues fairly and consistently.

If you wish to have a grievance formally investigated, please submit it to us in writing. Please provide full
details of the matter and tell us about the solution you are seeking. This should normally be addressed to
your line manager. They will arrange a meeting to discuss and consider it. If the grievance is about your
manager, address it to their manager. Following the meeting we will confirm the outcome in writing.

We follow fair, non-discriminatory procedures and strive for consistency of approach whenever possible.
Matters are normally dealt with privately and confidentially. However, we cannot guarantee to prevent
identities or personal details being revealed in every situation.

Appeal
If you feel a matter has still not been satisfactorily resolved, you may appeal in writing. This must be done
within five days of receiving the written outcome from the meeting. Appeals will be heard, wherever
possible, by a more senior representative of management without any prior involvement in the matter. The
outcome of the appeal is final.

Representation
A work colleague of your choice or trade union representative may accompany you at grievance hearings
or appeals. Union representatives must be certificated by that union to act as a worker’s companion. We
give suitable notice of meetings and will consider one adjournment if the date or time is inconvenient to
your representative.