Induction and Training Ref: EPOL/01
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Induction and Training Policy
Integra People Ltd believes that all new employees must be given timely induction training. This
training is regarded as a vital part of staff recruitment and integration into the working
environment. This policy, associated procedures and guidelines define the Company’s
commitment to ensure that all staff are supported during the period of induction, to the benefit of
the employee and Company alike.
AIM
It is the aim of the Company to ensure that staff induction is dealt with in an organised and
consistent manner, to enable staff to be introduced into a new post and working environment
quickly, so that they can contribute effectively as soon as possible. This induction policy,
associated procedures and guidelines aim to set out general steps for managers and staff to
follow during the induction process. It is expected that all managers and staff will adhere to this
policy.
The Company expects that the implementation of good induction practice by
managers/supervisors will:
Enable new employees to settle into the Company quickly and become productive and
efficient members of staff within a short period of time
Ensure that new entrants are highly motivated and that this motivation is reinforced
Assist in reducing staff turnover, lateness, absenteeism and poor performance generally
Assist in developing a management style where the emphasis is on leadership
Ensure that employees operate in a safe working environment
Will reduce costs associated with repeated recruitment, training and lost production.
THE COMPANY’S COMMITMENT
Integra People will:
Issue guidelines to familiarise managers and staff with the induction process
Maintain and update the Induction Policy
Provide a checklist for managers and staff to follow during the induction period
Ensure there is effective monitoring of the induction process particularly in the first three
months
Deal with any problems promptly providing an efficient service for both managers and
staff
Review all policy, procedure and guideline documents on a regular basis.
To comply with relevant REC legislation and communicate this to all members of staff. A
monthly newsletter is sent to all relevant staff to communicate any changes to REC
legislation.
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GUIDELINES FOR MANAGERS/SUPERVISORS
1. GENERAL
Starting a new job is a demanding and often stressful experience. Apart from the obvious
challenge of tackling new tasks, there is also the need to become accustomed to a new
organisation, a new environment and new colleagues. The purpose of induction is to support
new employees during this difficult period and to help them become fully integrated into the
Company as quickly and as easily as possible.
Induction has benefits for all involved in the process. Employees who settle quickly into the
Company will become productive and efficient at an early stage and in turn will experience
feelings of worth and satisfaction.
It is generally recognised that new employees are highly motivated and an effective induction
process will ensure that this motivation is reinforced.
2. BENEFITS OF INDUCTION
The advantages of an effective and systematic induction process are as follows:
To enable new employees to settle into the Company quickly and become productive
and efficient members of staff within a short period of time
To ensure that new entrants are highly motivated and that this motivation is reinforced
To assist in reducing staff turnover, lateness, absenteeism and poor performance
generally
To assist in developing a management style where the emphasis is on leadership
To ensure that new employees operate in a safe working environment
To reduce costs associated with repeated recruitment, training and lost production.
3. INDUCTION CHECKLIST
The Induction checklist is a very useful way of ensuring that information is imparted to new
employees when they are likely to be most receptive. It avoids overloading employees with
information during the first weeks whilst ensuring that all areas are covered.
Managers/supervisors should ensure that these matters have been properly understood whilst
the checklist is being completed, perhaps in the form of a weekly chat with the new entrant.
Arrangements should also be made for the employee to visit any relevant departments with
which they have regular contact in the course of their duties. At the end of the process the
induction checklist should be signed by the relevant parties and placed in the member of staff's
personnel file.
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1. FIRST DAY OF EMPLOYMENT
Preparations should be made for the arrival of the new entrant well in advance, for example,
arrangements should be made to provide desk and equipment etc.
Most new employees tend to be concerned primarily with two matters:
a) whether they can do the job and
b) how they will get on with their new colleagues.
It is therefore important to introduce them to their new workplace and colleagues at the earliest
opportunity. An introductory talk will be appropriate at this time and can be combined with the
provision of general information and exchanging any necessary documentation. This talk should
be as brief as possible, because the employee is unlikely to be receptive to detailed information
at this stage, and should be conducted by someone who is well prepared and has sufficient time
available. Managers/supervisors should refer to the Induction Checklist and use it as a basis for
discussion thus ensuring all documentation is complete.
A tour of the workplace should be arranged for the new entrant allowing the Company / Division
to be viewed as a whole and the recruit to see where he/she fits into the organisation.
The new entrant will want to get to know his/her colleagues and quickly become part of the
team and time should be made for this process. Colleagues should be briefed on the new
entrant’s arrival. If possible one of the new entrants colleagues should be nominated to ensure
that he/she has every assistance in settling in quickly.
2. INDUCTION PROGRAMMES
Induction programmes must be geared to the individual’s needs. Some of the more obvious new
members of staff requiring special attention are as follows:
Graduates
Graduates tend to have a high level knowledge but may not have the skills relevant to the job.
They will want to feel that they are making a contribution from early on and to understand the
organisation of the Company and their role within it. Also they will want to have a clear picture of
future career prospects and to gain broad experience with this in mind. The Trust should provide
the graduate recruit with an adviser - such as a senior manager - who can organise the necessary
breadth of experience and offer advice and support in relation to career progression.
Managers
Whilst many of the points in the checklist apply equally to all new managerial staff, in most cases
individual induction programmes will be necessary. These should be drawn up in consultation
with new managers, taking into account their backgrounds and experience and the nature of their
new roles. Priority should be given to helping new managers establish and maintain relationships
with management colleagues and opportunities should be provided for them to spend time in
other relevant departments to facilitate this process. This will help managers quickly to gain an
understanding of the Company’s philosophies, strategic plans and business plans.
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Ethnic Minorities
In some cases, it may be necessary to design induction programmes with the special needs of
ethnic minorities in mind. Language problems and attitudes amongst existing staff may be areas
requiring particular attention. This is preparation that should be completed before any member of
staff joins the Company. The Company will not tolerate racist or prejudiced behaviour in any form.
Long-term Unemployed
Previously long-term unemployed people who have been recruited may have been absent from
the working environment for some time so it will be helpful to recap on some of the issues relating
to school leavers. these should, of course, be adapted to suit older workers, who may need to
build up confidence and the induction process can be used to update knowledge of basic office
technology (photocopiers, fax machines, telephone systems, etc. as well as computers).
Other Groups
Other groups that may need particular consideration include disabled employees and women
returning to work after having raised a family.
These groups will also require the induction procedure as women returning to work may, like the
long-term unemployed, be out of touch and lacking in confidence. Disabled employees may have
all or a combination of induction needs, but these needs may be compounded by their disabilities.
Part of the induction process for disabled employees will involve checking such things as
wheelchair access to parts of the workplace, toilets and lifts etc. The necessary reasonable
adjustments to the workplace required to accommodate the disabled individual should be
completed prior to them commencing, and carried out in discussion with the individual or their
adviser.
COMPLETING THE INDUCTION PROCESS
Induction can be said to end when the individual become fully integrated into the organisation. Of
course, there is no set timescale within which this will happen and follow up is essential. Giving
new employees the opportunity to ask questions several weeks into employment can be useful,
and the induction checklist will provide this opportunity. In some areas, such as understanding
wider aspects of the organisation, follow up after a number of months may be appropriate.
January 2017
SIGNED:______________________________________________________
Managing Director
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Integra People Ltd
INDUCTION PROGRAMME FOR NEW STAFF
DEPARTMENT ......................................................................
NAME OF EMPLOYEE ......................................................…………..
JOB TITLE ......................................................................
DATE COMMENCED ......................................................…………..
Not all the following subjects are applicable to all departments. Should this be the case, record
N/A.
ITEMS TO COVER WITH EACH NEW EMPLOYEE Complete
The Department
1. The Department Function
2. Introduction to colleagues
3. Introduction to role
4. General layout of office
Conditions of Employment
1. Information on hours of work
2. Bonus scheme and allowances
3. Probationary period
4. Company pension scheme
5. Sickness policy
6. Holiday procedure
7. Uniforms and protective clothing
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Heath and Safety, Fire and security
1. Health and safety information
2. Fire procedure
3. Accident reporting
4. First Aid facilities
Conduct
1. Personal presentation
2. Disciplinary procedure
3. Confidentiality
4. Standard business conduct
Facilities
1. Cloakroom
2. Kitchen
3. Toilets
4. Smoking area
I have been informed about and understand the above items.
Signature:...................................……………………… Date:..............
I confirm that the above Induction Programme has been completed for the above member of
staff.
Signature ...................................……………………… Date:..............
Managing Director
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Communications Policy Ref: EPOL/02
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Communications Policy
1. INTRODUCTION
1.1 Integra People’s communications facilities are provided by Integra and made available to
users for the purposes of the business. A certain amount of limited and responsible personal
use by users is also permitted. All use of our communications facilities is governed by the
terms of this policy, and if our rules and procedures are not adhered to, then use of our
facilities may be curtailed or withdrawn and disciplinary action may thereafter follow. Any
breach of this policy may lead to disciplinary action being taken against you and serious
breaches may lead to summary dismissal.
1.2 At Integra, communication plays an essential role in the conduct of our business. How you
communicate with people not only reflects on you as an individual but also on us as an
organisation. We value your ability to communicate with colleagues, clients and business
contacts, and we invest substantially in information technology and communications systems
which enable you to work more efficiently. We trust you to use them responsibly.
1.3 This policy applies to all individuals working for Integra who use our communications facilities,
whether directors, divisional heads, partners, consultants, administrators, full-time, part-time
or fixed-term employees, trainees, contract staff, temporary staff, agency or home workers.
1.4 Although the detailed discussion is limited to use of email and internet facilities, the general
principles underlying all parts of this policy also apply to telephone communications, fax
machines, copiers and scanners. Note that some elements of personal use of Integra
communications facilities are specifically addressed at items 3.3, 4.3 to 4.5, 9.4 and 9.5, and
10.5. Please read this policy carefully.
2. GENERAL PRINCIPLES
2.1 You must use Integra information technology and communications facilities sensibly,
professionally, lawfully, and consistently with your duties, with respect for your colleagues and
for Integra and in accordance with this policy and Integra other rules and procedures.
2.2 All information relating to our clients/customers and our business operations is confidential.
You must treat our paper-based and electronic information with utmost care.
2.3 Many aspects of communication are protected by intellectual property rights which are
infringed by copying. Downloading, uploading, posting, copying, possessing, processing and
distributing material from the internet may be an infringement of copyright or of other
intellectual property rights.
2.4 Particular care must be taken when using email, company blog or internal message boards
as a means of communication because all expressions of fact, intention and opinion in an
email may bind you and/or Integra and can be produced in court in the same way as other
kinds of written statements.
2.5 The advantage of the internet and email is that they are extremely easy and informal ways of
accessing and disseminating information, but this means that it is also easy to send out ill-
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considered statements. All messages sent on email systems or via the internet should
demonstrate the same professionalism as that which would be taken when writing a letter or
a fax. You must not use these media to do or say anything which would be subject to
disciplinary or legal action in any other context such as sending any discriminatory (on the
grounds of a person's sex, race, disability, age, sexual orientation, religion or belief),
defamatory, or other unlawful material (for example, any material that is designed to be, or
could be construed as, bullying or harassment by the recipient). If you are in doubt about a
course of action, take advice from your supervising line manager or a director of the business.
3. USE OF ELECTRONIC MAIL
3.1 Generally
3.1.1 Always use the email template which contains the appropriate disclaimer notice from
Integra and do not amend this notice in any way.
3.1.2 Do not amend any messages received and, except where specifically authorised by
the other person, do not access any other person’s in-box or other email folders nor
send any email purporting to come from another person.
3.1.3 It is good practice to re-read and check an email before sending.
3.1.4 If you copy an email to others, it may breach the Data Protection Act if it reveals all
the recipients' email addresses to each recipient (e.g. in the case of marketing and
mailing lists).
It can also breach duties of confidentiality (e.g. in the case of internal emails to
members of a staff benefit scheme). Accordingly, it may be appropriate to use the
'Bcc' (blind carbon copy) field instead of the 'Cc' (carbon copy) field when addressing
an email to more than one recipient. If in doubt, seek advice from your line manager
or a director in the business.
Business use
3.1.5 Each business email should include the appropriate Integra business reference.
3.1.6 If the email message or attachment contains information which is time-critical, bear
in mind that an email is not necessarily an instant communication and consider
whether it is the most appropriate means of communication.
3.1.7 If you have sent an important document, always telephone to confirm that the email
has been received and read.
3.1.8 For important emails/ documentations (i.e. Terms of business/ booking forms), file
a hard copy of any email (including any attachments) sent to or received from the
customer/client before filing or deleting the electronic copy. The same applies to all
important internal email transmissions concerning customer/client matters.
3.1.9 In light of the security risks inherent in some web-based email accounts, you must
not email business documents to your personal web-based accounts. You may send
documents to a [customer's/client’s] web-based account if you have the
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[customer's/client’s] express written permission to do so. [However, under no
circumstances should you send price sensitive or highly confidential documents to
a [customer's/client’s] personal web-based email account, even if the
[customer/client] asks you to do so.]
3.1.10 When you need to work on documents remotely they can be saved to a disk or
retrieved over the internet.
3.2 Personal Use
3.2.1 Although Integra’s email facilities are provided for the purposes of our business, we
accept that you may occasionally want to use them for your own personal purposes.
This is permitted on the condition that all the procedures and rules set out in this
policy are complied with. Be aware, however, that if you choose to make use of our
facilities for personal correspondence, you can expect very little privacy because
Integra may need to monitor communications for the reasons given in item 9.1.
You will greatly increase the privacy of any personal email by complying with the
procedures set out in item 3.3.3 below.
3.2.2 Under no circumstances may Integra facilities be used in connection with the
operation or management of any business other than that of Integra or a
customer/client of Integra unless express permission has been obtained from your
line manager or a director.
3.2.3 All personal email you send from Integra facilities must be marked PERSONAL in
the subject heading, and all personal email sent or received must be filed in a
separate folder marked "Personal" in your inbox should you wish to retain it after
reading. Contact IT Support if you need guidance on how to set up and use a
personal folder. All email contained in your inbox and your sent items box are
deemed to be business communications for the purposes of monitoring (see item
9.4).
You must ensure that your personal email use:
(a) does not interfere with the performance of your duties;
(b) does not take priority over your work responsibilities;
(c) is minimal and limited to taking place substantially outside of normal
working hours (i.e. during any breaks which you are entitled to or before
or after your normal hours of work);
(d) does not cause unwarranted expense or liability to be incurred by Integra;
(e) does not have a negative impact on Integra in any way; and
(f) is lawful and complies with this policy.
3.2.4 As with any correspondence made using Integra electronic facilities, you can delete
personal email from the live system, but they will have been copied (perhaps many
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times) onto the backup tapes and in that form will be retained indefinitely. It would
be a very difficult, costly and time-consuming exercise to sift all those tapes in order
to delete an individual's personal email, and if we were to agree to attempt this, it
would be at our convenience, and only on the basis that all the very considerable
costs involved were paid in advance by the person making the request.
3.2.5 By making personal use of our facilities for sending and receiving email you signify
your agreement to abide by the conditions imposed for their use, and signify your
consent to Integra monitoring your personal email in accordance with item 9 of this
policy.
4. USE OF INTERNET AND INTRANET
4.1 We trust you to use the internet sensibly. Bear in mind at all times that, when visiting a website,
information identifying your PC may be logged. Therefore any activity you engage in via the
internet may affect Integra.
4.2 We recognise the need for individuals to have to carry out some personal tasks during working
hours, e.g. for internet banking or online shopping, and this is permitted subject to the same
rules as are set out for personal email use in item 3.3.4 of this policy. If these activities require
additional software to be installed onto your PC then you should submit a request to IT Support
who may be able to arrange this for you. Whenever you need to download software to enable
you to access an online service you must obtain the express permission of a Director of
Integra who will consider the request in line with Integra policy.
4.3 You are strongly discouraged from providing your Integra email address when using public
websites for non-business purposes, such as online shopping. This must be kept to a
minimum and done only where necessary, as it results in you and Integra receiving substantial
amounts of unwanted email.
4.4 Access to certain websites is blocked during normal working hours. If you have a particular
business need to access such sites, please contact a Director of Integra.
You must not:
4.4.1 introduce packet-sniffing or password-detecting software;
4.4.2 seek to gain access to restricted areas of Integra network;
4.4.3 access or try to access data which you know or ought to know is confidential;
4.4.4 intentionally or recklessly introduce any form of spyware, computer virus or other
potentially malicious software; nor
4.4.5 carry out any hacking activities
4.4.6 use Integra systems to participate in any internet chat room or post messages on
any external website, including any message board or blog, unless expressly
permitted in writing to do so by an Integra Director.
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4.5 For your information, breach of items 4.4.1 to 4.4.6 (inclusive) above, would not only
contravene the terms of this policy but could in some circumstances also amount to the
commission of an offence under the Computer Misuse Act 1990, which creates the following
offences:
4.5.1 unauthorised access to computer material i.e. hacking;
4.5.2 unauthorised modification of computer material; and
4.5.3 unauthorised access with intent to commit or facilitate the commission of further
offences.
5. MISUSE OF INTEGRA FACILITIES AND SYSTEMS
5.1 Misuse of Integra facilities and systems, including its telephone, email and internet systems,
in breach of this policy will be treated seriously and dealt with in accordance with Integra’s
disciplinary procedure. In particular, viewing, accessing, transmitting, posting, downloading or
uploading any of the following materials in the following ways, or using any of Integra facilities,
will amount to gross misconduct capable of resulting in summary dismissal (this list is not
exhaustive):
5.1.1 material which is sexist, racist, homophobic, xenophobic, pornographic, paedophilic
or similarly discriminatory and/or offensive;
5.1.2 offensive, obscene, derogatory or criminal material or material which is liable to
cause embarrassment to Integra and any of its staff or its customers/clients or bring
the reputation of Integra and any of its staff or its customers/clients into disrepute;
5.1.3 any defamatory material about any person or organisation or material which
includes statements which are untrue or of a deceptive nature;
5.1.4 any material which, by intent or otherwise, harasses the recipient;
5.1.5 any other statement which is designed to cause annoyance, inconvenience or
anxiety to anyone;
5.1.6 any material which violates the privacy of others or unfairly criticises or
misrepresents others;
5.1.7 confidential information about Integra and any of its staff or [customers/clients];
5.1.8 any other statement which is likely to create any liability (whether criminal or civil,
and whether for you or Integra;
5.1.9 material in breach of copyright and/or other intellectual property rights;
5.1.10 online gambling; or
5.1.11 unsolicited commercial or advertising material, chain letters or other junk mail of any
kind.
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If Integra has evidence of the examples of misuse set out above it reserves the right
to undertake a more detailed investigation in accordance with its disciplinary
procedures.
6. SYSTEM SECURITY
6.1 Security of our IT systems is of paramount importance. We owe a duty to all of our
customers/clients to ensure that all of our business transactions are kept confidential. If at any
time we need to rely in court on any information which has been stored or processed using
our IT systems it is essential that we are able to demonstrate the integrity of those systems.
Every time you use the system you take responsibility for the security implications of what you
are doing.
6.2 Integra’s system or equipment must not be used in any way which may cause damage, or
overloading or which may affect its performance or that of the internal or external network.
6.3 Keep all confidential information secure, use it only for the purposes intended and do not
disclose it to any unauthorised third party.
6.4 Keep your system passwords safe. Do not disclose them to anyone. Those who have a
legitimate reason to access other users' inboxes must be given permission from that other
user. IT Support will provide guidance on how to do this If you have disclosed your password
to anyone else (e.g. in response to a request from the IT staff) ensure that you change your
password once the IT staff no longer need it. Contact IT Support for guidance on how to do
this.
6.5 If a document is highly commercially confidential or price sensitive, you should mark it as
"private and confidential" and password-protect the document itself. Bear in mind that
documents which are NOT marked "private and confidential" can be accessed by all users of
the network
6.6 Copies of confidential information should be printed out only as necessary, retrieved from the
printer immediately, and stored or destroyed in an appropriate manner.You should not
download or install software from external sources without having first received the necessary
authorisation from the Director or line Manager
6.7 No external device or equipment, including discs and other data storage devices, should be
run on or connected to Integra systems without the prior notification to and approval of an
Integra Director
6.8 You should always exercise caution when opening emails from unknown external sources or
where, for any reason, an email appears suspicious. A Director or Line Manager should be
informed immediately in such circumstances.
7. WORKING REMOTELY
7.1 This part of the policy and the procedures in it apply to your use of our systems, to your use
of our laptops, and also to your use of your own computer equipment or other computer
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equipment (e.g. client’s equipment) whenever you are working on Integra business away from
Integra premises (working remotely).
When you are working remotely you must:
7.1.1 password protect any work which relates to INTEGRA business so that no other
person can access your work;
7.1.2 position yourself so that your work cannot be seen by any other person;
7.1.3 take reasonable precautions to safeguard the security of our equipment, and keep
your passwords secret;
7.1.4 inform the police and our IT department (as appropriate) as soon as possible if either
a Integra laptop in your possession or any computer equipment on which you do
Integra work, even if this is personal IT equipment, has been lost or stolen; and
7.1.5 ensure that any work which you do remotely is saved on Integra system or is
transferred to our system as soon as reasonably practicable.
7.2 Pocket computers, mobile phones and similar hand-held devices are easily lost or stolen so
you must password-protect access to any such devices used by you on which is stored any
personal data of which Integra is a data controller or any information relating our business,
our clients or their business.
8. PERSONAL BLOGS AND WEBSITES
8.1 This part of the policy and procedures in it apply to content that you publish on the internet
(e.g. your contributions to blogs, message boards and social networking or content-sharing
sites) even if created, updated, modified or contributed to outside of working hours or when
using personal IT systems.
8.2 Integra recognise that in your own private time you may wish to publish content on the internet.
For the avoidance of doubt, such activities are expressly prohibited during work time or using
Integra systems.
8.3 If you post any content to the internet, written, vocal or visual, which identifies, or could
identify, you as a member of Integra staff and/or you discuss your work or anything related to
Integra or its business, customers or staff, Integra expects you, at all times, to conduct yourself
appropriately and in a manner which is consistent with your contract of employment and with
Integra policies and procedures. It should be noted that simply revealing your name or a visual
image of yourself could be sufficient to identify you as an individual who works for Integra.
8.4 If you already have a personal blog or website which indicates in any way that you work for
Integra you should report this to a Director or line Manager.
8.5 If you intend to create a personal blog or website that will say that you work for Integra or in
any way could identify you as someone who works for Integra then you should report this to
a Director or line Manager.
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8.6 If a blog posting clearly identifies that you work for Integra and you express any idea or opinion
8.7 then you should add a disclaimer such as "these are my own personal views and not those of
Integra.
8.8
8.9 The following matters will be treated as gross misconduct capable of resulting in summary
8.10 dismissal (this list is not exhaustive):
8.7.1 Revealing confidential information about Integra in a personal online posting. This
might include revealing information relating to Integra clients, business plans,
policies, staff, financial information or internal discussions. Consult your manager if
you are unclear about what might be confidential.
8.7.2 Criticising or embarrassing Integra, its clients or its staff in a public forum (including
any website). You should respect the corporate reputation of Integra and the privacy
and feelings of others at all times. If you have a genuine complaint to make about a
colleague or workplace matter the correct procedure is to raise a grievance using
Integra grievance procedure.
8.7.3 Accessing or updating a personal blog or website from Integra computers or during
work time.
If you think that something on a blog or a website could give rise to a conflict of interest and
in particular concerns issues of impartiality or confidentiality required by your role then this
must be discussed with your Director or line manager.
If someone from the media or press contacts you about your online publications that relate to
Integra you should talk to a Director or line manager before responding and Integra press
office must be consulted.
Online publications which do not identify the author as a member of Integra staff and do not
mention Integra and are purely concerned with personal matters will normally fall outside the
scope of Integra communications policy.
9. MONITORING OF COMMUNICATIONS BY INTEGRA
9.1 Integra is ultimately responsible for all business communications but subject to that will, so far
as possible and appropriate, respect your privacy and autonomy while working. Integra may
monitor your business communications for reasons which include:
9.1.1 providing evidence of business transactions;
9.1.2 ensuring that Integra business procedures, policies and contracts with staff are
adhered to;
9.1.3 complying with any legal obligations;
9.1.4 monitoring standards of service, staff performance, and for staff training;
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9.1.5 preventing or detecting unauthorised use of Integra communications systems or
criminal activities; and
9.1.6 maintaining the effective operation of Integra communications systems.
9.2 Integra will monitor telephone, email and internet traffic data (i.e. sender, receiver, subject;
non-business attachments to email, numbers called and duration of calls; domain names of
websites visited, duration of visits, and files downloaded from the internet) at a network level
(but covering both personal and business communications) for the purposes specified at item
9.1. For the purposes of your maintenance of your own personal privacy, you need to be
aware that such monitoring might reveal sensitive personal data about you. For example, if
you regularly visit websites which detail the activities of a particular political party or religious
group, then those visits might indicate your political opinions or religious beliefs. By carrying
out such activities using Integra facilities you consent to our processing any sensitive personal
data about you which may be revealed by such monitoring.
9.3 Sometimes it is necessary for Integra to access your business communications during your
absence, such as when you are away because you are ill or while you are on holiday. Unless
your mailbox settings are such that the individuals who need to do this already have
permission to view your inbox, access will be granted only with the permission of one of the
persons authorised to grant such access.
9.4 Any emails which are not stored in your "Personal" folder in your mailbox and which are not
marked PERSONAL in the subject heading will be treated, for the purpose of availability for
monitoring, as business communications since we will have no way of knowing that they were
intended to be personal. Therefore you must set up a rule to automate the routing of personal
email to your personal folder – ask IT Support for guidance on how to do this. Furthermore,
there is a risk that any person authorised to access your mailbox may have their own preview
pane option as a default setting, which would reveal the content of any of your personal email
not filed in your "Personal" folder, whether or not such email are marked PERSONAL. It is up
to you to prevent the inadvertent disclosure of the content of personal email by filing your
personal email in accordance with this policy. In particular, you are responsible to anybody
outside Integra who sends to you, or receives from you, a personal email, for the
consequences of any breach of their privacy which may be caused by your failure to file your
personal email.
9.5 In certain very limited circumstances we may, subject to compliance with any legal
requirements, access email marked PERSONAL. Examples are when we have reasonable
suspicion that they may reveal evidence of unlawful activity, including instances where there
may be a breach of a contract with Integra.
9.6 All incoming email are scanned by BT Support on behalf of Integra, using virus-checking
software. The software will also block unsolicited marketing email (spam) and email which
have potentially inappropriate attachments. If there is a suspected virus in an email which has
been sent to you, the sender will automatically be notified and you will receive notice that the
email is not going to be delivered to you because it may contain a virus.]
9.7 For more information regarding communications monitoring – please see POL 22 CCTV and
Audio Recording Policy.
Communications Policy Ref: EPOL/02
Issue Date: January 2017
Issue:
3
10. DATA PROTECTION
10.1
As a member of Integra who uses our communications facilities, you will inevitably be involved
10.2 in processing personal data for Integra as part of your job. Data protection is about the privacy
10.3 of individuals, and is governed by the Data Protection Act 1998. This Act defines, among
10.4 others, terms as follows:
10.5
10.6 10.1.1 "data" generally means information which is computerised or in a structured hard
copy form;
10.1.2 "personal data" is data which can identify someone, such as a name, a job title, a
photograph;
10.1.3 "processing" is anything you do with data – just having data amounts to processing;
and
10.1.4 "data controller" is the person who controls the purposes and manner of processing
of personal data – this will be Integra, in the case of personal data processed for the
business.
Whenever and wherever you are processing personal data for Integra you must keep it secret,
confidential and secure, and you must take particular care not to disclose them to any other
person (whether inside or outside Integra unless authorised to do so. Do not use any such
personal data except as authorised by Integra for the purposes of your job. If in doubt get help
from our Data Protection Officer or your Director or Line Manager.
The Data Protection Act gives every individual the right to see all the information which any
data controller holds about them. Bear this in mind when recording personal opinions about
someone, whether in an email or otherwise. It is another reason why personal remarks and
opinions must be made or given responsibly, and they must be relevant and appropriate as
well as accurate and justifiable.
For your information, section 55 of the Data Protection Act provides that it is a criminal offence
to obtain or disclose personal data without the consent of the data controller. "Obtaining" here
includes the gathering of personal data by employees at work without the authorisation of the
employer. You may be committing this offence if without authority of Integra : you exceed your
authority in collecting personal data; you access personal data held by Integra; to control it or
you pass them on to someone else whether inside or outside Integra.
While Integra is a data controller of all personal data processed for the purposes of our
business, you will be a data controller of all personal data processed in any personal email
which you send or receive. Use for social, recreational or domestic purposes attracts a wide
exemption under the Data Protection Act, but if, in breach of this policy, you are using our
communications facilities for the purpose of a business which is not Integra business, then
you will take on extensive personal liability under the Data Protection Act.
To help you understand and comply with Integra obligations as a data controller under the
Data Protection Act you may be offered, and you may also request, training. Whenever you
are unsure of what is required or you otherwise need guidance in data protection, you should
consult our line manager or any member of the Senior Management team. Integra privacy
Communications Policy Ref: EPOL/02
Issue Date: January 2017
Issue:
3
statements and information about our data protection policies can be found on the Integra
shared drive.
11. COMPLIANCE WITH THIS POLICY
11.1 Failure to comply with this policy may result in disciplinary action being taken against you
under Integra disciplinary procedures, which may include summary dismissal, and/or in the
withdrawal of permission to use the firm's equipment for personal purposes. If there is
anything in this policy that you do not understand, please discuss it with your Director or line
manager.
11.2 Please note that the procedures and policies outlined in this policy, and in any related policy,
may be reviewed or changed at any time. You will be alerted to important changes [and
updates will be published on email and saved in the shared drive.
January 2017
Signed:____________________________________________
Managing Director
Ref: EPOL/03
Anti-bribery and Corruption Issue January 2017
Policy
Date:
Issue: 1
Page 1 of 6
Anti-bribery and Corruption Policy
1. Definitions
In this policy “we”, 'us”, and “the Company” mean Integra People Ltd.
“Bribe” means an inducement or reward offered, promised or provided in order to gain any commercial,
contractual, regulatory or personal advantage; “to Bribe” and “Bribery” are construed accordingly.
“Relevant Person” means any individual (whether an officer of employee of the Company, or a
temporary worker, contractor or consultant providing services to or on behalf of the Company) or any
corporate entity who performs functions for or on behalf of the Company.
2. Introduction
One of Integra People’s core values is to uphold responsible and fair business practice. It is committed
to promoting and maintaining the highest level of ethical standards in relation to all of its business
activities. Its reputation for maintaining lawful business practices is of paramount importance and this
Policy is designed to preserve these values. Integra People has a zero tolerance policy towards bribery
and corruption and is committed to acting fairly and with integrity in all of its business dealings and
relationships and to implementing and enforcing effective systems to counter bribery.
3. Purpose and scope of this policy
This Policy sets out the steps all of us must take to prevent bribery and corruption in our business and
to comply with relevant legislation. It is aimed at:
ensuring compliance with anti-bribery laws, rules and regulations, not just within the UK but in
any other country within which the Company may carry out its business or in relation to which
its business may be connected;
enabling any Relevant Person to understand the risks associated with bribery and to encourage
them to be vigilant and effectively recognise, prevent and report any wrongdoing, whether by
themselves or others;
providing suitable and secure reporting and communication channels and ensuring that any
information that is reported is properly and effectively dealt with;
creating and maintaining a rigorous and effective framework for dealing with any suspected
instances of bribery or corruption.
All Relevant Persons are expected to adhere to the principles set out in this Policy.
4. The Bribery Act 2010
The Bribery Act 2010 (the Bribery Act) came into force on 1 July 2011. The Bribery Act affects the
Company in its business relations anywhere in the world.
Under the Bribery Act it is an offence to:
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1. bribe a person i.e. to offer, promise or give a financial or other advantage to another person,
whether within the UK or abroad, with the intention of inducing or rewarding improper conduct;
2. receive a Bribe i.e. to request, agree to receive or accept a financial or other advantage for or in
relation to improper conduct;
3. bribe a foreign public official; and
4. fail to prevent Bribery.
5. Risks of not acting with integrity
Involvement in Bribery or corruption carries many risks. Among them are:
a company which pays or accepts Bribes is not in control of its business and is at risk of blackmail;
if the Company is found guilty of Bribery or even of failing to have adequate procedures in place
to prevent Bribery, it will be subject to unlimited fines;
any person found guilty of Bribery will be subject to fines and/or imprisonment of up to 10 years;
a public exposure, or even allegation, of bribery would entail severe reputational damage. The
Company’s banking or supply facilities might be withdrawn or be available on much less
favourable terms, and the Company could be blacklisted as an approved tenderer for both public
and private sector contracts;
the cost of our insurance cover could increase very significantly; and
good people will not want to work for us.
6. Benefits of acting with integrity
Equally, there are very clear benefits to acting with propriety. These include:
we increase our chances of being selected as a supplier in both the public and private sectors;
we remain in good standing with our banks and our own suppliers and they will want to keep
doing business with us;
a business with high ethical standards is a good place to work; and
it is a requirement of the REC Code of Professional Practice that we act with integrity at all times.
7. Policy statement
All Relevant Persons and Associated Persons are required at all times:
not to commit an offence listed above at section 4 or any other offence;
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to comply with the Bribery Act and any other anti-bribery and anti-corruption legislation that
applies in any jurisdiction in any part of the world in which they or the company might conduct
business.
to act honestly, responsibly and with integrity;
to safeguard and uphold the Company’s core values by operating in an ethical, professional
and lawful manner at all times.
Bribery of any kind is strictly prohibited. Under no circumstances should any provision be made, money
set aside or accounts created for the purposes of facilitating the payment or receipt of a Bribe. Integra
People recognises that industry practice may vary from country to country or from culture to culture.
What is considered unacceptable in one place may be normal or unusual practice in another. You
should seek appropriate guidance from the Company’s Director. All Relevant Persons and all
Associated Persons are expected to adhere strictly at all times to the guidelines set out in this Policy.
If you are in doubt as to what might amount to bribery or what might constitute a breach of this Policy,
refer the matter to David Lewis, Group Managing Director.
8. Gifts and Hospitality
The Company occasionally provides gifts and hospitality to clients, customers, contractors, and
suppliers. This is not prohibited by the Bribery Act provided the following requirements are met:
the gift is not made with the intention of influencing a third party to obtain or retain business or a
business advantage, or to reward the provision or retention of business or a business
advantage;
it complies with local laws;
it is given in the Company’s name, not in the giver’s personal name;
it does not include cash or a cash equivalent (such as gift vouchers);
it is of an appropriate and reasonable type and value and given at an appropriate time;
it is given openly, not secretly;
it is approved in advance by a director of the Company.
In summary, it is not acceptable to give, promise to give, or offer, a payment, gift or hospitality with the
expectation or hope that a business advantage will be received, or to reward a business advantage
already given, or to accept a payment, gift or hospitality from a third party that you know or suspect is
offered or provided with the expectation that it will obtain a business advantage for them.
9. Facilitation payments
Any payment or gift to a public official or other person to secure or accelerate the prompt or proper
performance of a routine government procedure or process, otherwise known as a “facilitation
payment”, is also strictly prohibited. Facilitation payments are not commonly paid in the UK but they are
common in some other jurisdictions.
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10. What are the indicators of bribery?
Common indicators of corruption include those listed below. There may well be others. For example:
• payments are for abnormal amounts (e.g. commission), or made in an unusual way, eg what
would normally be a single payments is made in stages, through a bank account never previously
used, or in a currency or via a country which has no connection with the transaction;
• process is bypassed for approval or sign-off of terms or submission of tender documents,
payments, or other commercial matters; those whose job it is to monitor commercial processes
(e.g [insert person or department specific to Company, e.g. Internal Audit]) may be prevented
from or hindered in doing so;
• individuals are secretive about certain matters or relationships and/or insist on dealing with them
personally. They may make trips at short notice without explanation, or have a more lavish
lifestyle than expected;
• decisions are taken for which there is no clear rationale;
• records are incomplete or missing.
11. Political contributions
You should be aware that such contributions can be (or be seen as) Bribes in disguise. We do not make
donations to political parties. No individual is to make a donation stated to be, or which could be taken
to be, on our behalf without the prior approval of the Board. You may, of course, make political donations
in a personal capacity but please be sensitive to how such contributions could be perceived, especially
by those who are aware of your connection with the Company.
12. Charitable donations
Bribes may even be disguised as charitable donations. We occasionally make charity donations, but
they are approved by the Directors and are recorded. Whilst individuals may of course make personal
donations to charity, they should not do so on behalf of the Company without prior approval from the
Board.
13. Local circumstances
We understand that different parts of the world have different social and cultural customs. This does
not affect our position that we do not pay or accept bribes or act corruptly: we do not and will not.
However, subject to that position, we understand the need to be sensitive to local customs. For
example, there are cultures in which refusing (or even failing to offer) a gift is considered impolite, and
could alienate a key contact. In such cases, please refer to the Finance Department. Heads of the
Finance Department are responsible for establishing variations to this policy in there department,
subject to the agreement of the Director.
14. Exceptional circumstances
In some circumstances a payment is justifiable. If one of our people is faced with a threat to his or her
personal safety or that of another person if a payment is not made, they should pay it without fear of
recrimination. In such cases, however, The Director must be contacted as soon as possible, and the
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payment and the circumstances in which it was made must be fully documented and reported to the the
Director for the business concerned within five working day. Consider carefully whether to involve the
police. There may be cases where this will actually make the situation worse. If, on consideration, this
appears to be the best course of action, always consult the Director first. Such cases will be rare. All
Relevant Persons visiting regions where they are more common should familiarise themselves, prior to
travel, with current guidance relating to those countries. The Director should be consulted if in doubt.
15. Responsibility to report and the reporting procedure
All Relevant Persons are contractually required to take whatever reasonable steps are necessary to
ensure compliance with this Policy and to prevent, detect and report any suspected Bribery or
corruption. All Relevant Persons have a duty to prevent, detect and report any incident of Bribery and
any potential risks of Bribery. If you know or suspect that any Relevant Person plans to offer, promise
or give a Bribe or to request, agree to receive or accept a Bribe in connection with the Company’s
business, you must disclose this to the Director as quickly as possible to allow appropriate action to be
taken promptly.
The Company is committed to taking appropriate action against Bribery and corruption. This may
include either reporting the matter to an appropriate external government department, regulatory
agency or the police and/or taking internal disciplinary action against relevant employees and/or
terminating contracts with associated persons.
The Company will keep your disclosure confidential during any investigation it undertakes to the extent
that this is practical and appropriate in the circumstances. The Company will support anyone who raises
genuine concerns in good faith under this Policy, even if they turn out to be mistaken. The Company is
also committed to ensuring nobody suffers any detrimental treatment as a result of refusing to take part
in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential
bribery or corruption offence has taken place or may take place in the future or because they may assist
in the investigation of an allegation of Bribery or corruption.
16. Record keeping
All accounts, receipts, invoices and other documents and records relating to dealings with third parties
must be prepared and maintained with strict accuracy and completeness. No accounts must be kept
“off the record” to facilitate or conceal improper payments.
17. Monitoring compliance
The Company’s Director has primary responsibility for ensuring compliance with this Policy and will
review its contents on a regular basis. S/he will be responsible for monitoring its effectiveness and will
provide regular reports in this regard to the directors of the Company who have overall responsibility
for ensuring this Policy complies with the Company’s legal and ethical obligations.
18. Training
The Company will provide training to all employees to help them understand their duties and
responsibilities under this Policy. The Company’s zero tolerance approach to Bribery will also be
communicated to all business partners at the outset of the business relationship with them and as
appropriate thereafter.
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19. Sanctions for breach of this Policy
A breach of any of the provisions of this Policy by any Relevant Person who is an officer or employee
of the Company will constitute a disciplinary offence and will be dealt with in accordance with the
Company’s disciplinary procedure. Depending on the gravity of the offence, it may be treated as gross
misconduct and could render the officer or employee liable to summary dismissal.
Breach of this policy by any Relevant Person who is a temporary worker, contractor or consultant
providing his/ her services to the Company may lead to the immediate termination of that temporary
worker’s, contractor’s or consultant’s engagement by the Company.
Breach of this policy by any Relevant Person which is a corporate entity could lead to the suspension
or termination of any relevant contract, sub-contract or other agreement between the corporate entity
and the Company.
January 2017 Managing Director
Signed:
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Disciplinary, Dismissal & Issue January 2017
Grievance Policy
Date:
Issue: 1
Page 1 of 5
Disciplinary, Dismissal & Grievance Policy
GENERAL PRINCIPLES
The following general principles will apply to both the disciplinary, dismissal and grievance
procedures.
Each step and action will be taken without unreasonable delay.
Whenever the employee is invited by the company to attend a meeting, the employee
must take all reasonable steps to attend.
At all stages of the procedure the employee will have the right to be accompanied by
a trade union representative or a work colleague of your choice. If your companion is
unable to attend any such meeting you may suggest an alternative date, provided it is
within 5 working days of the original date.
Timing and location of meetings must be reasonable.
Meetings will be conducted in a manner that enables both the company and employee
to explain their case.
For appeal hearings following a decision the company will as far as reasonably
practicable, be represented by a more senior manager than attended the first meeting
(unless the most senior manager attended that meeting).
Whenever the company or employee is required to send the other a statement, the
original or a copy will suffice.
DISCIPLINARY AND DISMISSAL PROCEDURES
Purpose
We aim to have a fair and systematic approach to the enforcement of standards of conduct
for all employees. The Disciplinary and Dismissal procedures are designed to help and
encourage all employees to achieve and maintain standards of conduct, attendance and job
performance. The company rules and these procedures apply to all employees. The aim is
to ensure consistent and fair treatment for all in the organisation.
Principles
No disciplinary action will be taken against an employee until the case has been fully
investigated. The Company may suspend you with or without pay while an investigation
takes place. Such a suspension will be reviewed as soon as possible and will not normally
exceed [20] working days.
An employee will not be dismissed for a first breach of discipline except in the case of
gross misconduct (when the penalty may be dismissal without either notice or payment
in lieu of notice).
Misconduct will generally fall into two categories, namely “general” misconduct (in
respect of which the general disciplinary action procedure described below applies)
and “gross” misconduct, which is of so serious a nature that it justifies instant dismissal
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for a first offence. Listed below are examples which would normally be considered to
be either general misconduct or gross misconduct. However, it should
be recognised that neither list can be regarded as complete to meet every case, and
also that action described as general misconduct may amount to and be treated as
gross misconduct if the circumstances or the manner of the misconduct are such as to
warrant serious disciplinary action. These lists should be regarded therefore as being
illustrative rather than exhaustive.
Examples of “gross” misconduct
Summary dismissal (dismissal without notice or pay in lieu of notice) may be necessary in
cases of gross misconduct. For guidance, the following are examples of the offences which
may be regarded as gross misconduct and will normally result in summary dismissal. It is
emphasised that this is not an exhaustive list:-
Unauthorised use or disclosure of confidential information or business matters relating
to the company, its clients, temporary workers or applicants.
Acts of violence, including physical assault; unlawful discrimination; drunkenness;
taking of non-prescribed drugs in such a way as to impair the ability to carry out work;
conduct of any kind which endangers the health and safety of others.
A criminal offence committed at work other than a minor road traffic offence committed
in the course of the employment, or an offence committed outside work which is
incompatible with the employee remaining in employment.
Any unauthorised possession or removal of Company products or property, or property
belonging to another employee, client, customer or visitor, fraud (including making
fraudulent or false expense claims), deliberate falsification of records, false
declarations in connection with employment or applications or any other form of
dishonesty.
Theft or fraudulent activity.
Unauthorised absence or gross negligence in the performance of duties.
Acceptance of any bribe, secret profit or unauthorised commission.
Any conduct tending to bring the company or the employee into disrepute or which
results in the loss of custom of a client, temporary or applicant or a loss of business.
Working for or assisting a competitor of the company or seeking to establish a business
which is likely to compete with the company or divulging confidential information
concerning the company and its business.
Refusal to obey a lawful instruction in connection with the employment.
Examples of “general” misconduct
The following may be regarded as reasons for disciplinary action in that they deviate from
accepted standards and constitute general misconduct. The employee’s first offence will
usually result in a verbal or written warning as appropriate. Repetition of offences following a
warning could lead to a written warning or a final written warning as appropriate. Thereafter
any repetition will result in dismissal. It is again emphasised that this is not an exhaustive list:-
Poor job performance.
Poor time-keeping.
Failure to comply with the conditions of your employment contract.
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Unseemly or disruptive conduct.
DISCIPLINARY ACTION
The following is the disciplinary action that may be taken against an employee in cases of
misconduct or unsatisfactory performance:
STAGE 1 – Informal Action: Oral Warning
If an employee’s conduct or performance is unsatisfactory, they will be given an informal oral
warning. However this will be recorded in writing on their personnel file. The warning will be
disregarded after 6 months’ satisfactory service.
STAGE 2 – Formal Written Warning
If the offence is serious, or if there is no improvement in standards after informal action has
been taken in cases of minor misconduct or unsatisfactory performance or there has been
further misconduct within 6 months of any informal action, a written warning will be given. This
written warning will include the reason for the warning and a note that, if there is no
improvement after a specified period, a final written warning will be given. A copy of the written
warning will be given to the employee and a copy will be placed on their personnel file. The
warning will be disregarded after 6 months satisfactory service.
STAGE 3 – Formal Final Written Warning and/ or other Sanction
If following a written warning, conduct or performance remains unsatisfactory, or if a serious
incident occurs, a final written warning will be given making it clear that any recurrence of the
offence or other serious misconduct within a specified period will result in dismissal. A copy of
the written warning will be given to the employee and a copy will be placed on their personnel
file. The warning will then be disregarded after 12 months satisfactory service. As an
alternative or additional to a final written warning there may be a demotion and/ or change of
location, either permanently or for a specific period of time.
STAGE 4 – Dismissal or other Sanction
If there is no satisfactory improvement or if further serious misconduct occurs within 12 months
or if the misconduct is so serious the final step in the procedure may be dismissal, either with
or without notice or payment in lieu of notice, or some other action short of dismissal such as
demotion and/ or change of location, either permanently or for a specific period of time.
DISCIPLINARY PROCEDURE
Informal Discussion
1. Minor breaches of discipline, misconduct, poor time-keeping, etc may result in an
informal discussion with the employee’s immediate superior.
2. Although an informal warning will not form part of the formal disciplinary procedure, it
will be recorded.
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3. It is expected that in most cases an informal discussion will resolve most difficulties.
Where an employee commits a more serious act of misconduct or fails to improve
and maintain that improvement with regard to conduct, behaviour or job performance,
the formal steps detailed below may be taken.
Formal Discussion
Step 1 - Written Statement
The company will inform the employee of the alleged conduct or characteristics, or other
circumstances, which lead the company to contemplate dismissing or taking disciplinary action
against the employee. This shall be done promptly after becoming aware of the
circumstances, and the employee shall be invited to attend a meeting to discuss the matter,
once any necessary investigations have been conducted to establish the facts of the matter.
Step 2 – Meeting
1) The meeting will take place before any action is taken, except in the case where the
disciplinary action consists of a suspension on full pay, in order to investigate the
allegation.
2) The meeting will not take place unless:
- The company has informed the employee of the ground or grounds for contemplating
disciplinary action or dismissal
- The employee has had a reasonable opportunity to consider his/ her response to
that information
3) The employee has the right to be accompanied at the meeting by a work colleague or
a Trade Union representative.
4) After the meeting, the company will inform the employee in writing of its decision and
notify him of the right to appeal against the decision if he is not satisfied with it.
Step 3 – Appeal
1) If the employee does wish to appeal, he must inform the company within 5working
days of receiving the decision, and on doing so the company will invite him to attend a
further meeting.
2) The appeal meeting may not necessarily take place before the dismissal or disciplinary
action takes effect but it will be arranged within a reasonable period of time.
3) The appeal will be dealt with by a more senior manager than at the Step 2 meeting.
Where this is not practicable, the company will hear the appeal and decide the case
as impartially as possible.
4) After the appeal meeting, the company will inform the employee of its final decision.
GRIEVANCE PROCEDURE
If an employee has a problem or concern about their work, working conditions or
relationships with colleague, they should aim to settle their grievance informally with their
line manager.
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If an employee’s grievance cannot be settled informally, or a formal approach is preferable,
the employee should raise it formally with management by following the procedure below.
Step 1 - Written statement
The employee must set out their grievance in writing and send this statement to the
company
Step 2 – Meeting
1) The company will invite the employee to attend a meeting to discuss the grievance,
normally within 5 days, but longer where it is necessary to undertake an investigation to
establish the facts or it is otherwise impracticable.
2) The meeting will not take place unless:
- the employee has informed the company of the basis for the grievance in writing
- the company has had a reasonable opportunity to consider its response to that
information
3) After the meeting the company will inform the employee of its decision, as soon as
practicable, and the company will notify the employee of his right to appeal if he/she
is not satisfied with it.
Step 3 – Appeal
If the employee does wish to appeal, he or she must inform the company within 5 working
days of receiving the decision, and on doing so the company will invite him/ her to attend a
further meeting. After the appeal meeting, the company will inform the employee of its final
decision as soon as is practicable. The company’s decision is final.
January 2017 Managing Director
Signed:
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Whistle Blowing Policy Issue January 2017
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Whistle Blowing Policy
1. INTRODUCTION
The Public Interest Disclosure Act 1998 came into force on 2 July 1999. This Act recognised that
workers have the right to “blow the whistle” and disclose certain information, e.g. the fraudulent
activities of management, malpractice and/or concerns about health and safety.
The Act introduced specific rights for those who disclose information to a third party about an
alleged wrong-doing in defined circumstances. There is no general right for all so-called whistle-
blowers to receive special protection. To qualify, the following issues must be met:
the Disclosure in question must relate to one of the specified categories contained within the
Act; and
the Disclosure must be made in one of the ways specified.
Protection under the Act applies to workers and the definition used is substantially wider than that
used in other employment legislation. It includes not just employees and the common definition of
workers, but also third party contractors including limited company contractors whose work is
controlled by the employer and would therefore cover all, including dentists and doctors, under
statutory schemes and those individuals working under training contracts but not the genuinely self-
employed.
On a practical note, the Care Standards Act 2000, through the Nurses Agencies Regulations &
Domiciliary Care Regulations and the associated standards require the agency or registered person
to have robust procedures for responding to suspicion or evidence of abuse or neglect (including
whistle-blowing) to ensure the safety and protection of service users. However, such a policy
should also encourage the worker to disclose their concerns internally first, thereby limiting the
circumstances in which they are able to make an external Disclosure.
1.1. Subject Matter of the Disclosure
As mentioned above, there are limits on the subject matter that will qualify for protection. A
qualifying Disclosure means any Disclosure of information, which, in the reasonable belief of
the worker making the Disclosure, tends to show one or more of the following:
that a criminal offence has been committed, is being committed or is likely to be committed;
or
that a person has failed, is failing or is likely to fail to comply with any legal obligation to
which he or she is subject; or
that a miscarriage of justice has occurred, is occurring or is likely to occur; or
that the health or safety of an individual has been, or is being or is likely to be endangered;
or
that the environment has been, is being or is likely to be damaged, or
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that information tending to show any massive failing within any one of the proceeding
paragraphs has been, is being or is likely to be deliberately concealed.
The worker simply has to show that they have a reasonable belief that the information disclosed
demonstrates one or more of the above criteria. However, there are two important exceptions
where the Disclosure will not qualify for protection and they are:
if the person making the Disclosure commits an offence by making it, or
it is a matter in which a legal, professional privilege would apply, namely, correspondence
between the employer and their lawyers regarding a specific case.
It is not sufficient for the worker to show that the circumstances give rise to a qualifying
Disclosure, the worker will also have to ensure that the proper procedures are adhered to.
1.2. Procedures for Disclosures
In order to qualify for the whistle-blowing protection, the worker must use one of the six specified
ways to make the Disclosure. The aim of the legislation is to encourage workers to disclose
the information through appropriate internal channels first rather than going directly to an
outside person such as a member of the media.
The six permitted ways of Disclosure are as follows:
1) Disclosure to an Employer or Other Responsible Person
This method of Disclosure will ensure that workers are protected in respect to Disclosures made
in good faith. Where the worker believes that the relevant failure relates solely or mainly to the
conduct of a person other than the employer or to a matter for which that other person has
responsibility, the Disclosure should be made to that other person.
In the context of temporary workers supplied by an employment business, it may well be
appropriate for the temporary worker to raise the concern with the client in the first instance
rather than the agency/employment business.
2) Disclosure to a Legal Adviser
This protects workers who disclose information in the course of obtaining legal advice.
3) Disclosure to a Minister of the Crown
This will only apply where the worker’s employer is an individual appointed under any
enactment by a Minister of the Crown or a body whose members are so appointed. Examples
include the Utility Regulatory Bodies and NHS trusts, i.e. could apply to nurses, care staff and
workers supplied to local authorities.
4) Disclosure to a Prescribed Person
Workers will qualify for protection when they make a Disclosure in good faith to a person
prescribed by an order made by the Secretary of State. The list of prescribed persons was
recently amended and the New Public Interest Disclosure Prescribed Persons Amendment
Order came into force on 1 October 2003 and the relevant list is attached at Appendix A.
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5) Disclosure in Other Cases
Disclosure in other cases apply where the worker makes the Disclosure in good faith,
reasonably believes that the information disclosed and any allegations contained within it are
substantively true, does not make the Disclosure for the purposes of personal gain and meets
one of the specified conditions set out below, namely:
that at the time he or she makes a Disclosure, the worker reasonably believes that he
or she will be subject to detriment by his or her employer if that worker makes a
Disclosure to his or her employer or to a prescribed person;
that in the case where no person is prescribed in relation to the relevant circumstances,
the worker reasonably believes that it is likely that the evidence relating to the relevant
failure would be concealed or destroyed if he or she made the Disclosure to the
employer; or
that the worker has previously made a Disclosure of substantially the same information
to the employer or a prescribed person. Further details are contained within the Act.
6) Disclosure of Exceptionally Serious Breaches
The final type of protected Disclosure is one which covers situations where the subject matter
is serious enough to merit by-passing one of the other procedures. The relevant criteria set out
above must be met together with the matter which must be exceptionally serious. It does not
mean that people will be protected where they act unreasonably, for example, by going straight
to the press where there would clearly have been other less damaging ways to resolve the
matter.
This would be particularly true where there was a whistle-blowing policy which encourages the
worker to raise the matter with the employer or another responsible body first.
1.3. Protection for the Worker
The protection given under the Public Interest Disclosure Act 1998 only applies in certain
situations where the worker makes a protected Disclosure to the bodies named in the Act. The
protection applies to all workers without any restriction on age, however, it is limited and it is
important that the worker follows the correct procedure or else they will be denied the
protection. The protection, which includes financial compensation without the statutory cap
applying in the case of protection against dismissal, further includes the right not to suffer a
detriment as a consequence of making a protected Disclosure.
1.4. Practical Issues
The agency should take whistle-blowing and issues of malpractice seriously.
A whistle-blowing policy, such as that which is available from the REC specifically for nurses
and domiciliary care agencies, should make it clear that the worker wishing to voice his/her
concern should raise the matter with the named person first, who will deal with the matter
objectively. It is important that the agency takes the time to listen to any issues raised and
investigates in an objective and confidential manner. Issues should be dealt with when they
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arise and workers should not be told to wait until they have proof of or to investigate the matters
themselves.
It is important that matters are treated confidentially. If a worker is not happy with the way in
which a matter has been addressed, he/she should be encouraged to raise that fact as a
complaint rather than leaving the matter unresolved.
However, workers who make false allegations maliciously may be subject to the appropriate
action.
If there is not a sufficiently senior person to deal with the complaint within the organisation, then
external routes should be considered. Agencies are referred to the Public Concern At Work
web-site for further information, particularly the practical hints for small organisations. This can
be down-loaded from the following web-site:
www.pcaw.co.uk/policy_pub/checklist.html.
January 2017
Signed:____________________________________________
Managing Director
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Appendix
First Column Second Column
Persons and descriptions of people to
whom disclosures may be made Descriptions of matters about which
Accounts Commission for Scotland and disclosure may be made
auditors appointed by the Commission to
audit the accounts of local government The proper conduct of public business,
bodies. value for money, fraud and corruption in
Audit Commission for England and Wales local government bodies.
and auditors appointed by the Commission
to audit the accounts of local government, The proper conduct of public business,
and health service, bodies. value for money, fraud and corruption in
Certification Officer. local government, and health service,
bodies.
Charity Commissioners for England and
Wales. Fraud, and other irregularities, relating to
the financial affairs of trade unions and
The Scottish Ministers. employers' associations.
Chief Executive of the Criminal Cases The proper administration of charities and
Review Commission. of funds given or held for charitable
Chief Executive of the Scottish Criminal purposes.
Cases Review Commission.
Civil Aviation Authority. The proper administration of charities and
of funds given or held for charitable
The competent authority under Part IV of purposes.
the Financial Services and Markets Act
2000. Actual or potential miscarriages of justice.
Commissioners of Customs and Excise.
Actual or potential miscarriages of justice.
Compliance with the requirements of civil
aviation legislation including aviation
safety.
The listing of securities on a stock
exchange; prospectuses on offers of
transferable securities to the public.
Value added tax, insurance premium tax,
excise duties and landfill tax.
Commissioners of the Inland Revenue. The import and export of prohibited or
restricted goods.
Income tax, corporation tax, capital gains
tax, petroleum revenue tax, inheritance
tax, stamp duties, national insurance
contributions, statutory maternity pay,
statutory sick pay, tax credits, child
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benefits, collection of student loans and
the enforcement of the National Minimum
Wage.
Comptroller and Auditor General of the The proper conduct of public business,
National Audit Office. value for money, fraud and corruption in
relation to the provision of centrally-funded
public services.
Auditor General for Wales. The proper conduct of public business,
value for money, fraud and corruption in
relation to the provision of public services.
Auditor General for Scotland and persons The proper conduct of public business,
appointed by or on his behalf under the value for money, fraud and corruption in
Public Finance and Accountability relation to the provision of public services.
(Scotland) Act 2000 to act as auditors or
examiners for the purposes of Sections 21
to 24 of that Act.
Audit Scotland. The proper conduct of public business,
value for money, fraud and corruption in
public bodies.
Director General of Electricity Supply. The generation, transmission, distribution
and supply of electricity, and activities
ancillary to these matters.
Director General of Gas Supply. The transportation, shipping and supply of
gas through pipes and activities ancillary
to these matters.
Director General of Telecommunications. The provision and use of
telecommunications systems, services and
apparatus.
Director General of Water Services. The supply of water and the provision of
sewerage services.
Water Industry Commissioner for Scotland. The supply of water and the provision of
sewerage services.
Director of the Serious Fraud Office. Serious or complex fraud.
Lord Advocate, Scotland. Serious or complex fraud.
Environment Agency. Acts or omissions which have an actual or
potential effect on the environment or the
management or regulation of the
environment, including those relating to
pollution, abstraction of water, flooding, the
flow in rivers, inland fisheries and
migratory salmon or trout.
Scottish Environment Protection Agency. Acts or omissions which have an actual or
potential effect on the environment or the
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Food Standards Agency. management or regulation of the
environment, including those relating to
Financial Services Authority. flood warning systems and pollution.
General Social Care Council. Matters which may affect the health of any
Care Council for Wales. member of the public in relation to the
Scottish Social Services Council. consumption of food and other matters
Children's Commissioner for Wales. concerning the protection of the interests
Health and Safety Executive. of consumers in relation to food.
Housing Corporation. The carrying on of investment business or
Local authorities which are responsible for of insurance business; the operation of
the enforcement of health and safety banks and building societies, deposit-
legislation. taking businesses and wholesale money
market regimes; the operation of friendly
societies, benevolent societies, working
men's clubs, specially authorised
societies, and industrial and provident
societies; the functioning of financial
markets, investment exchanges and
clearing houses; money laundering,
financial crime, and other serious financial
misconduct, in connection with activities
regulated by the Financial Services
Authority.
Matters relating to the registration of social
care workers under the Care Standards
Act 2000.
Matters relating to the registration of social
care workers under the Care Standards
Act 2000.
Matters relating to the registration of the
social services workforce by the Scottish
Social Services Council.
Matters relating to the rights and welfare of
children.
Matters which may affect the health or
safety of any individual at work; matters,
which may affect the health and safety of
any member of the public, arising out of or
in connection with the activities of persons
at work.
The registration and operation of
registered social landlords, including their
administration of public and private funds
and management of their housing stock.
Matters which may affect the health or
safety of any individual at work; matters,
which may affect the health and safety of
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Information Commissioner. any member of the public, arising out of or
Scottish Information Commissioner. in connection with the activities of persons
National Care Standards Commission. at work.
National Assembly for Wales.
Compliance with the requirements of
Scottish Commission for the Regulation of legislation relating to data protection and
Care. to freedom of information.
Occupational Pensions Regulatory
Authority. Compliance with the requirements of
Office of Fair Trading. legislation relating to freedom of
information.
Rail Regulator.
Standards Board for England. Matters relating to the provision of
regulated care services, as defined in the
Local Commissioner in Wales. Care Standards Act 2000.
Matters relating to the provision of social
care services liable to be registered or
inspected under the Care Standards Act
2000 or the Children Act 1989.
The registration and operation of
registered social landlords, including their
administration of public and private funds
and management of their housing stock.
Matters relating to the provision of care
services, as defined in the Regulation of
Care (Scotland) Act 2001.
Matters relating to occupational pension
schemes and other private pension
arrangements.
Matters concerning the sale of goods or
the supply of services, which adversely
affect the interests of consumers.
Competition affecting markets in the
United Kingdom.
The provision and supply of railway
services.
Breaches by a member or co-opted
member of a relevant authority (as defined
in Section 49(6) of the Local Government
Act 2000) of that authority's Code of
Conduct.
Breaches by a member or co-opted
member of a relevant authority (as defined
in section 49(6) of the Local Government
Act 2000) of that authority's Code of
Conduct.
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Standards Commission for Scotland and the Breaches by a councillor or a member of a
Chief Investigating Officer. devolved public body (as defined in
Section 28 of the Ethical Standards in
Public Life, etc., (Scotland) Act 2000) of
the Code of Conduct applicable to that
councillor or member under that Act.
Treasury. The carrying on of insurance business.
Secretary of State for Trade and Industry. Fraud, and other misconduct, in relation to
companies, investment business,
insurance business, or multi-level
marketing schemes (and similar trading
schemes); insider dealing.
Consumer safety.
Secretary of State for Transport. Compliance with merchant shipping law,
including maritime safety.
Local authorities which are responsible for Compliance with the requirements of
the enforcement of consumer protection consumer protection legislation.
legislation.
Local authorities which are responsible for Compliance with the requirements of food
the enforcement of food standards. safety legislation.
A person ("person A") carrying out Matters falling within the description of
functions, by virtue of legislation, relating to matters in respect of which person B is
relevant failures falling within one or more prescribed by this Order, to the extent that
matters within a description of matters in those matters relate to functions currently
respect of which another person ("person carried out by person A.
B") is prescribed by this Order, where
person B was previously responsible for
carrying out the same or substantially
similar functions and has ceased to be so
responsible.
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Mobile Phone & Driving Ref: EPOL/06
Policy Issue January 2017
Date:
Issue: 1
Mobile Phone & Driving Policy
Integra People Ltd is committed to reducing the risks which our employees face and create when
driving or riding for work.
Employees with a hands-free kit installed in their car should ensure that their use is kept to a
minimum whilst driving. You must only take calls whilst driving if it is safe to do so, and you remain in
proper control of your vehicle. If circumstances change during the call, you must end the call without
delay. You should call back once you have stopped in a safe place and switched off the engine.
Managers must:
Lead by example, both in the way they drive themselves and by not tolerating poor driving practice
among colleagues. They must never make or receive a call on a hand-held mobile phone while
driving.
Line Managers must ensure:
Lead by personal example
Employees understand their responsibilities not to use a hand-held mobile phone while
driving
Employees switch phones to voicemail, or switch them off, while driving, or ask a colleague
who is a passenger to use the phone
Employees plan journeys to include rest stops which also provide opportunities to check
messages and return calls
Work practices do not pressurise employees to use a mobile phone while driving.
Employees who drive for work must:
Never use a hand-held phone while driving
Plan journeys so they include rest stops when messages can be checked and calls returned
Ensure their phone is switched off and can take messages while they are driving, or allow a
colleague who is a passenger to use the phone
Employees with a hands-free kit installed in their car should ensure that their use is kept to a
minimum whilst driving. You must only take calls whilst driving if it is safe to do so, and you
remain in proper control of your vehicle. If circumstances change during the call, you must
end the call without delay. You should call back once you have stopped in a safe place and
switched off the engine.
January 2017
Signed: Managing Director
Uncontrolled When Printed
Company Car Policy Ref: EPOL/07
Issue January 2017
Date:
Issue: 4
Company Car Policy
Issued to: Date:
Issued by:
Date:
Engine Type: Diesel (Y) Make and £
Petrol (Y) Model Value of
Driving licence Vehicle:
checked: (Y) By whom:
Copy of driving (N)
licence (Y) Any points or (Y)
attached: (N) convictions at (N)
time of If yes please state:
signing?
1. General
1.1 You will be notified individually in your employment contract and offer letter if you are entitled to a
Company car as part of your remuneration and benefits package. Your entitlement is subject to the
following terms and conditions of this Policy. If you do not comply with your obligations under this Policy,
the Company shall be entitled, at its sole discretion, to withdraw or limit your use of the Company car.
If you receive a copy car allowance, Integra People expect you to follow the obligations in the points
below.
1.2 This Policy is effective from ……/……/20…. until further notice.
2. Choice of Car
2.1 The Company reserves the right to decide by what means Company cars will be provided (for
example, by lease or purchase).
2.2 You may choose any make and model of car in accordance with the limits and criteria as laid down
by the Company from time to time. The initial limits and criteria are set out in the letter offering you
employment with the Company. The Company reserves the right, at its sole discretion, to amend the
limits and criteria from time to time.
2.3 Before choosing a car, you should obtain written confirmation from the Company Accountant that
the proposed choice, together with any optional extras, will be acceptable to the Company.
2.4 Subject to review by the Company from time to time, Company cars will be renewed every 3 years
or after 70 thousand miles at the Company’s sole discretion.
2.5 Once you have accepted a car you cannot change to car allowance for a period of 12 months.
3. Running and other Costs
3.1 The Company will pay/arrange for the Company car to be comprehensively insured and taxed and
a contribution of £60 per month will be deducted from the employee’s monthly salary as a contribution
to the company car insurance policy.
3.2 You are responsible for ensuring that your Company car is kept clean (both inside and out) and is
maintained in a roadworthy condition. The Company will reimburse all reasonable servicing and
maintenance costs properly incurred (excluding car valet or car wash charges) on the production of
garage invoices.
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3.3 Please see Fuel Card Policy (EPOL09) for details on fuel returns for business and private mileage.
Copies of petrol & VAT receipts must be provided to the Company (credit card receipts alone will not
suffice), and should at least cover the business mileage claimed.
4. Private use of the Car
4.1 You may use the Company car for private mileage, you will not be entitled to nominate any other
named driver and the company car can only be driven by an employee of Integra People Ltd who has
provided a Company Director with their name, address and driving license. The Company reserves the
right to refuse an employee of Integra People to drive a company car.
4.2 You are responsible for paying all the fuel costs of private use of the car incurred by you and any
other employee of Integra People ltd.
5. Your Obligations
You must comply with the following requirements, which are conditions of entitlement to the use or
benefit of a company car:
5.1 To take reasonable care of the car and to keep it in a clean condition;
5.2 To keep the car in a roadworthy condition, regularly serviced and maintained, and to take
appropriate action to remedy any faults;
5.3 Please also refer to the company’s Mobile Phone and Driving Policy (EPOL/06).
5.4 To report to the Company Director at the earliest opportunity any damage to the car or any accident
arising from its use, regardless of how the damage or accident occurred. Failure to do so may lead to
loss of insurance cover for the damage or accident, in which event you will be liable to indemnify the
Company for the loss;
5.4 To report to the Company Director at the earliest opportunity any incident involving the Police which
arises from use of the Company car;
5.5 To ensure that you comply with all of the relevant Company policies whilst using the Company Car,
including the no smoking, drugs and alcohol policies.
5.6 To assist the Company with insurance claims or investigations into accidents, damage or Police
enquiries arising from use of the Company car.
You are responsible for the above matters, whether or not you were personally driving the Company
car at the relevant time.
6. Medical
6.1 You must notify the Company Director of any medical condition that may impair your ability to drive,
including but not limited to; heart conditions, stroke, epilepsy or other neurological conditions,
psychological conditions such as stress, poor or failing eyesight. You must not drive a company car
until cleared by a Director.
6.2 If you are prescribed any medication you must notify the Company Director immediately and must
not drive a company car until you are cleared to do so.
6.3 Even if you are declared safe to drive by your doctor it is at the Company’s discretion and they
reserve the right to withdraw a company car until further notice.
7. Accidents
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7.1 If you and/or the named driver are involved in an ‘at fault’ accident you will become liable to pay the
Company’s insurance excess for the repairs. Further, in such circumstances, the Company reserves
the right to withdraw the Company car and instead to substitute a car allowance commensurate with
your status, in an amount determined in accordance with Company policy.
7.2 If you expressly or impliedly give permission to use the Company car to any person other than an
employee of Integra People, and the Company car is involved in an accident while being used by that
person, you shall, at the Company’s sole discretion, pay for the cost of repairing or replacing the car.
Further, you will indemnify the Company for liability to any third party who suffers loss or damage.
7.3 If, for whatever reason, you cease to hold a valid current driving license and in consequence are
unable to either attend for work normally or (in the Company’s reasonable opinion) carry out your duties
properly and effectively, then unless suitable alternative employment is available, the Company will be
entitled to terminate your employment on notice.
7.4 If you cause damage to a Company Car, either accidentally or maliciously, whether it has been
assigned to you or otherwise you will be liable for the costs to repair the vehicle.
8. Criminal Proceedings
8.1 If you or the Company become involved in criminal proceedings in connection with your use of the
Company car or any use by the named driver or any other person to whom you have expressly or
impliedly given permission to use the car, you will be responsible for all parking fines and charges,
costs, fines, criminal compensation and any other financial liability connected with or arising from such
criminal proceedings. If the Company initially pays some of the above liabilities, you will reimburse such
sums to the Company as soon as possible.
8.2 Any Illegal use of the Company Car whilst on company business will, notwithstanding any other
proceedings that may result from such use, constitute gross misconduct and may result in summary
dismissal.
9. Termination of Employment
9.1 If you are summarily dismissed or are not required by the Company to work out your notice period
(regardless of who gave notice), you shall return the Company car on your last day at work in
accordance with the Company’s instructions, and shall not be entitled to any further use or benefit of
the car or to any compensatory payment in lieu.
9.2 If your employment contract is cancelled due to resignation, redundancy or down to poor
performance where you are still entitled to your full notice period. The Company may, at its sole
discretion, allow you to continue to use the Company car during this notice period or garden leave. If
this permission is not granted by a Director of the Company the company vehicle should be returned
on the last day of work. If permission is granted the company will inform you in writing specifying the
terms and conditions of your continued use.
10. Variations
10.1 The Company reserves the right, at its sole discretion, to amend or vary any of the terms of this
Car Policy from time to time, and will give you one month’s prior notice of any change.
10.2 The Company reserves the right to make changes to the value of the car to which you are entitled.
Any changes will be in writing and will give you one month’s prior notice.
10.3 If the Company decides to change its arrangements for the supply of Company cars, it may be
necessary to replace your existing car with a car of similar value provided under the new arrangements.
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Company Car Policy Ref: EPOL/07
Issue January 2017
Date:
Issue: 4
Employee Acceptance
I have read, understood and agree to accept and abide by Integra People Ltd Company Car Policy.
Signature: Date:
January 2017
Signed:___________________________________________ Managing Director
Uncontrolled When Printed
Maternity, Adoption, Ref: EPOL/08
Paternity & Family Leave Issue January 2017
Date:
Policy Issue: 1
Maternity, Adoption, Paternity & Family Leave Policy
Integra People Ltd recognises that at various stages in employees’ working lives, domestic and family
commitments and responsibilities potentially reduce or hinder their ability to fulfil work responsibilities.
Where such conflicts cannot be resolved, this could result in Integra People losing employees. To
prevent such loss of skilled experienced workers, and to help reduce anxiety and stress among our
workforce, this organisation not only acknowledges those potential conflicts but also offers practical
help through the following family friendly arrangements:
1. Maternity Leave (page 1-3)
2. Adoption Leave (page 3-5)
3. Paternity Leave (page 5-6)
4. Parental Leave (page 6-7)
5. Flexible Working (page 7-9)
6. Time off for Dependants (page 9)
1. Maternity Leave
Integra People’s policy is to comply with both the letter and spirit of the law on maternity rights. To this
end its aim is to inform all female employees of their entitlement to statutory maternity rights and to
ensure that those rights are understood by employees who qualify.
Procedure
Maternity Leave
1. A female employee is not obliged to notify Integra People of her pregnancy until she reaches
the end of the 15th week before her baby is due (the expected week of childbirth (EWC)). An
exception to this is where she is requesting time off for antenatal care, in which case proof of
an appointment can be required after the first appointment.
2. Once a manager has been notified or has become aware of an employee’s pregnancy, the
employee should be referred to the HR department/ HR manager, which/who will check her
entitlement to statutory maternity leave and will respond, in writing within 28 days, telling her
when she is due to return.
3. Employees must provide medical evidence of their EWC in the form of a maternity certificate
or MAT B1 form and is available from the employee’s doctor or midwife after the 20th week of
pregnancy. This must be forwarded to the HR department/HR manager as soon as possible,
but no later than three weeks after the start of the Maternity Pay Period (MPP). No Statutory
Maternity Pay (SMP) will be payable without this certificate.
4. Where the MAT B1 is provided late, the Managing Director will decide whether or not the
employee could have provided it earlier and will advise her of his or her decision.
5. Integra People will carry out risk assessments to assess any possible risks to new and
expectant mothers. Where Integra People feels there may be a risk, then Integra People will
do all it can to eliminate that risk and to warn the employee of the potential dangers.
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6. To qualify for her Statutory Maternity Leave and Statutory Maternity Pay (SMP) the employee
must:
1. tell the HR department/HR manager that she is pregnant
2. inform the HR department/HR manager of her EWC
3. give notice to the HR department/HR manager of when she intends to commence her
maternity leave — this must be given by the end of the 15th week before the EWC if
this is reasonably practicable. If she changes her mind at a later date, she is entitled
to do so, but must inform the HR department/HR manager of the revised start date at
least 28 days before the date in question
4. in the case of a premature birth, she must advise the HR department/HR manager of
the fact as soon as is reasonably practicable and, produce a MAT B2 form —
obtainable from her doctor or midwife.
7. If the above criteria are not met:
1. Integra People can refuse to pay the employee’s SMP
2. in this instance, the HR department/HR manager will provide a written statement
outlining the decision and the reasons supporting the decision
3. if the employee does not agree with the decision, she can refer the matter to HM
Revenue & Customs (HMRC).
8. To give notice the employee should complete Integra People's model letters for maternity
leave and SMP.
9. The maximum entitlement to SMP is 39 weeks’ pay. Employees will receive higher rate SMP
in respect of the first six weeks and the lower rate SMP for the remaining 33 weeks.
10. SMP may be paid to the employee in a lump sum at the start of her maternity leave or
absence.
11. During ordinary and additional maternity leave, all contractual benefits except basic salary or
wages will be maintained.
12. Employees who:
1. are taken into legal custody, or
2. work for another employer
during the MPP must notify Integra People as soon as possible, as their entitlement to
SMP may be affected.
13. Pregnant employees may continue working as close to their EWC as they wish provided they
continue to be capable of doing their job. Integra People reserves the right to require the
employee to be examined by Integra People's doctor where it is felt that her health, or that of
the baby, may be suffering as a result of her continuing to work.
Returning to Work after Ordinary Maternity Leave
1. The employee returning to work after ordinary maternity leave has the right to return to the
same job she had prior to commencement of leave. She is entitled to request flexible working
if she wishes and this will be considered under Integra People’s Flexible Working policy and
procedure.
2. Where the employee wishes to return at the end of the ordinary maternity leave period, she
must provide Integra People with at least eight weeks advance notice.
Returning to Work after Additional Maternity Leave
1. The employee is entitled to return to a similar job. Where this is the case, the terms and
conditions will be no less favourable to the employee.
2. Where the employee wishes to return after her additional maternity leave, she can just turn up
on the day after her additional maternity leave ends. However, where she wishes to return to
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work before the end of her additional maternity leave, she must give Integra People at least
eight weeks notice.
3. Where the employee is too ill to return on the appointed day, she must inform the HR
department/HR manager of the reason and the sickness absence policy and procedure will
apply.
4. Where the employee does not wish to return after her maternity leave she must give her
notice of termination as outlined in Integra People’s terms and conditions to the HR
department/HR manager.
Keeping in Touch during Maternity Leave
1. Integra People is keen to keep in touch with employees during maternity leave and invite
employees to come into work or attend training for up to 10 days during their maternity
absence. These days are to be agreed in advance with management.
2. Employees who carry out work or attend training will not lose their right to SMP or end their
maternity leave in any way. There is no automatic right to be paid any sum additional to SMP
for carrying out work or attending training but this will be at the discretion of and by agreement
with Integra People.
2. Adoption Leave
Integra People encourages employees to have a balance between their work and family
commitments, believing that it ensures a more effective and efficient workforce. This Adoption Leave
Policy has been developed to provide you with guidance as to your entitlements and the procedure to
follow for adoption leave.
Adoption leave is the right to take paid leave when a child up to 18 years of age is newly placed with
you for adoption. Employee will not be treated less favourably, suffer detriment, or be dismissed
because he or she requests, or takes, adoption leave. However, the misuse of adoption leave — such
as the use of leave for reasons other than to care for the child or support the mother or partner, or
failure to follow the correct procedure — may result in disciplinary action being taken against you.
Procedure
Eligibility
1. To qualify for adoption leave you will need to satisfy the following conditions. You must:
1. be newly matched with a child for adoption by an approved adoption agency
2. have worked continuously for Integra People for 26 weeks’ leading into the week in
which you are notified of being matched with a child for adoption
3. forward your Matching Certificate from your adoption agency, to the HR department
28 days before you wish your adoption leave to commence (this is evidence of
adoption to qualify for your entitlement to adoption leave and pay)
4. where adopting jointly with another parent, choose who should take adoption leave.
Entitlement to Leave
1. The primary rationale for adoption leave is to ensure that the new parent can take time off
work to bond with the child once he or she starts living with them.
2. Adoption leave and pay is available to:
1. individuals who adopt
2. one member of a couple where a couple adopt jointly (the couple may choose which
partner takes adoption leave).
3. Those who are eligible are entitled to up to a total of 52 weeks’ leave as follows:
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1. 26 weeks’ ordinary adoption leave
2. 26 weeks’ additional adoption leave.
4. Employees can choose to start their leave on:
1. the date of the child’s placement
2. a fixed date which can be up to 14 days before the expected date of placement
3. any day of the week.
5. Employees are only entitled to one period of leave even if more than one child is placed for
adoption at the same time.
6. Employees must notify the HR department that they intend to take adoption leave within
seven days of being notified by the adoption agency that they have been matched with a child
for adoption, or as soon as reasonably practicable.
7. Employees must tell Integra People when:
1. the child is expected to be placed with you
2. you want your adoption leave to start.
8. Should employees wish to change the date on which they want their leave to start they must
give at least 28 days’ notice.
9. If employees intend to return to work before the end of their adoption leave period, they must
write to the HR department giving eight weeks notice of the date of return.
Entitlement to Pay
1. Ordinary adoption leave is paid at the statutory adoption pay (SAP) rate or 90% of average
weekly earnings if these are less than the SAP rate. It is paid for a maximum of 39 weeks.
2. Statutory adoption leave after the 39th week is unpaid.
3. Should you not qualify for SAP you may be able to seek financial support from your Local
Authority. Additional financial support may be available through:
1. housing benefit
2. council tax benefit, or
3. tax credits.
4. Employees' contractual rights and benefits remain in place while on 52 weeks’ adoption leave
except for the terms relating to salary.
Keeping in Touch
1. Integra People is keen to keep in touch with employees during adoption leave and invite
employees to come into work or attend training for up to 10 days during statutory adoption
leave. Such days are to be agreed in advance with management.
2. Employees who carry out work or attend training will not lose their right to SAP or end their
adoption leave in any way. There is no automatic right to be paid any sum additional to SAP
for carrying out work or attending training but this will be at the discretion of and by agreement
with Integra People.
Returning to Work
1. It is presumed that employees will return to work at the end of their full adoption leave
entitlement. However, if they intend to return to work before the end of the adoption leave
period they must write to the HR department giving at least eight weeks' notice of their
intended date of return. If employees fail to do so. Integra People may delay their return until
the eight week period has expired, or the end of the ordinary or additional adoption leave
period, whichever is earlier.
2. Employees are entitled to return to the same job as before on the same terms and conditions
of employment at the end of ordinary adoption leave, unless a redundancy situation arises.
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3. Employees are entitled to return to the same job at the end of their additional adoption leave,
unless it is not practicable to do so. In such circumstances they will be offered any available
comparable position for their skills and experience, on no worse terms and conditions.
4. If employees cannot return to work at the end of their full adoption leave period because of
illness, they should follow the normal contractual procedures for sickness absence as laid out
in the terms and conditions of employment
5. If employees do not wish to return to work, they are required to give Integra People notice in
accordance with their contractual notice period, as set out in their terms and conditions of
employment.
Procedure for Adoption Leave
1. Employees should:
1. inform the HR department you are adopting within seven days of being notified and
confirm when the child is expected to be placed with you and when you want your
adoption leave to commence
2. also forward Matching Certificate as proof.
2. The HR department should:
1. send the employee a confirmation letter detailing his or her adoption leave pay and
leave entitlements
2. inform payroll and the pension administrator.
3. The employee is to:
1. give eight weeks' notice, if he or she intends to return before the end of his or her full
adoption leave entitlement, or
2. give notice if he or she intends to not return to work.
3. Paternity Leave
Integra People encourages employees to have a balance between their work and family
commitments, believing that this ensures a more effective and efficient workforce. This policy has
been developed to provide guidance as to employees’ entitlements and the procedure to follow if
requesting paternity leave.
No employee will be treated less favourably, suffer detriment or be dismissed because they request or
take paternity leave. However, the misuse of paternity leave — such as the use of leave for reasons
other than to care for the child or support the mother or partner, or failure to follow the correct
procedure — may result in disciplinary action.
If you meet the qualifying conditions you will be entitled to take paternity leave of either one or two
weeks duration. Leave may only be taken in blocks of one or two weeks. Paternity leave must be
completed within 56 days of the actual date of birth of the child. You will only be entitled to one period
of paternity leave even if more than one child is born as a result of the same pregnancy.
Procedure
1. Paternity leave is the right to take paid leave to care for a child or support the mother.
2. In order to qualify for paternity leave in birth situations the employee must be the:
1. child’s biological father, and have, or expect to have responsibility for the child’s
upbringing
2. spouse or partner of the mother (including same-sex partners), and have, or expect to
have, responsibility for the child’s upbringing.
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3. In order to qualify for paternity leave in adoptive situations the employee must be married to,
or the partner of, the adopter (including same-sex partners) and have, or expect to have,
responsibility for the child’s upbringing.
4. In both birth and adoptive situations the employee must:
1. have formally informed his/her manager of his/her intention to take statutory paternity
leave
2. have provided a self-certification form supporting the right to take statutory paternity
leave, if requested by the manager.
5. Paternity leave is for a maximum of two weeks. The employee may take the leave in a block
of one or two consecutive weeks. Leave must be taken within 56 days of the birth of the child
or, in the case of adoption, within eight weeks of the placement.
6. In order to take statutory paternity leave after the birth of a child, the employee must inform
his/her manager of his/her intention to take leave by the end of the 15th week before the
expected week of childbirth (EWC). He/she must specify:
1. the week in which the baby is expected to be born
2. whether he/she intends to take one or two weeks’ leave
3. the date on which he/she intends to start paternity leave.
7. In order to take statutory paternity leave after the adoption of a child, the employee must
notify his/her manager of his/her intention to take leave no later than seven days after the
date on which he/she received notification from the adoption agency of the match with the
child. If the child was adopted from abroad the employee must let his/her employer know the
date on which he/she received notification of the placement and the date on which the child is
expected to enter the UK.
8. Statutory paternity leave may not be taken before the birth or adoption of a child.
9. If the employee falls ill before starting his/her period of paternity leave, he/she may postpone
it. The 56-day period within which employees must take paternity leave is not, however,
extended under these circumstances.
10. The employee may be entitled to statutory paternity pay (SPP) and will be notified
accordingly. SPP is paid at the statutory rate applicable. Should the employee not qualify for
SPP he/she may be able to get Income Support while on paternity leave but enquiries should
be made of the local Social Security Office.
11. Employees are entitled to return from paternity leave to the same job as before, on the same
terms and conditions of employment, unless a redundancy situation arises.
12. If an employee cannot return to work at the end of paternity leave because of illness, he/she
should follow the normal procedures for sickness absence.
13. If the employee does not wish to return to work after paternity leave, he/she is required to give
his/her manager notice in accordance with the contract of employment.
4. Parental Leave
If you meet the qualifying conditions you will be entitled to parental leave of 13 weeks for each child
under the age of 5 or 18 weeks where the child is entitled to disability living allowance under the age
of 18. Parental leave can be taken in blocks of one week. You may not take more than 4 weeks in a
calendar year.
1. Employees who are the parents of one or more children under five years of age and who
have at least one year’s continuous service are entitled to a total of 13 weeks’ unpaid parental
leave. This leave may be taken at any time up to the child’s fifth birthday. This right also
applies to employees who have acquired formal responsibility for a child, e.g. guardians.
2. Employees who have at least one year’s continuous service and who adopt a child under 18
are also entitled to 13 weeks’ parental leave. The right to leave lasts for five years from the
date on which the child was placed for adoption, or until the child reaches the age of 18,
whichever occurs earlier.
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3. Parents of disabled children can take a total of 18 weeks’ parental leave up until the child’s
18th birthday.
4. Employees who work part-time will receive a pro-rata amount of parental leave.
5. An employee may not take parental leave in periods of less than one week (unless the child is
disabled, in which case parental leave can be taken in blocks of a single day or more).
6. An employee may not take more than four weeks’ parental leave per year per child.
7. Applications for parental leave must be made in writing to [the HR manager] and employees
may be required to provide evidence of their responsibility for the child and the child’s age.
8. Employees must give at least 21 days’ notice of an intention to take parental leave and should
specify the dates they wish the period of leave to begin and end.
9. Employees may take time off immediately after the birth or immediately after an adoption
provided that they give 21 days’ notice of the expected week of the child’s birth or adoption.
10. [Your business’ name] reserves the right to postpone a period of parental leave requested for
up to six months (unless the leave is requested for the period immediately after a child is born
or adopted). Postponement may be necessary where [your business’ name] could not cope or
would be harmed by the absence of an employee at the time requested. Postponement will
be confirmed in writing no later than seven days after the employee's notice to take leave has
been received. This will state the reason for the postponement and set out suggested new
dates of parental leave.
11. Employees will remain employed during all periods of parental leave. Certain contractual
terms continue to apply. In particular, the employer’s obligation of trust and confidence, terms
concerning notice, redundancy compensation, and disciplinary and grievance procedures
continue in force. Furthermore, the employee’s obligation of good faith and any express term
prohibiting disclosure of confidential information or participation in a competing business
remain active.
12. No payment will be made for any parental leave taken.
13. Where both parents are employed by Integra People, each will be entitled to parental leave in
respect of each eligible child.
14. Employees returning from parental leave of four weeks or less will be reinstated in their
previous jobs. Employees returning from parental leave of more than four weeks will be
reinstated in their previous jobs wherever possible or, if not, offered similar jobs which have
the same or better terms and conditions as the previous jobs.
5. Flexible Working
Note: From 6 April 2007 the right to request flexible working was extended to carers. The definition of
“carer” will be an employee who is or expects to be caring for an adult who:
is married to, or the partner or civil partner of the employee; or
is a near relative of the employee; or
falls into neither category but lives at the same address as the employee.
The "near relative" definition includes parents, parent-in-law, adult child, adopted adult child, siblings
(including those who are in-laws), uncles, aunts or grandparents and step-relatives.
The following policy and procedure relating to flexible working, does not form part of the employees'
terms and conditions of employment.
Integra People’s Flexible Working Policy outlines Integra People’s commitment to consider flexible
working arrangements for employees who are parents of young, adopted or disabled children. Integra
People recognises the contribution of all its employees and also understands that at some time in
their working lives, employees may find it difficult to fulfil domestic, family and working commitments
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due to having a young family, or adopting, or having a disabled child. Where this occurs, Integra
People will always consider practical help through this flexible working policy.
No employee will be treated less favourably, suffer detriment, or be dismissed because they request,
or take, flexible working.
1. Flexible working is about considering the way work is organised to see whether it is possible
to have different arrangements: the result must always be, however, that Integra People
achieves its core business purpose as efficiently as is possible. Integra People will consider
requests for flexible working by eligible employees who put a request in writing but the onus
of making an application is with the employee. An application where it is considered that
granting flexible working would be detrimental to the business needs of Integra People will be
rejected.
Employees should be aware that if they request and are given agreed flexible working conditions this
is a variation of their terms and conditions of employment and is a permanent change. If an
employee’s circumstances change in relation to the need for flexible working there is no statutory right
for a return to the terms and conditions that applied to them prior to flexible working being granted.
Procedure
Eligibility
1. To be eligible to request flexible working, a person must:
1. be an employee
2. have a child under six years of age, or under 18 years of age if the child is disabled
3. be responsible for the child as its parent and be either a biological parent, guardian,
adopter, foster carer or married to or the partner of such a person
4. have responsibility for the upbringing of the child
5. be making the application to enable him or her to care for the child
6. have worked for Integra People continuously for 26 weeks at the date of the
application for flexible working
7. have not made another application to work flexibly under the right during the past 12
months.
2. The right to apply:
1. is strictly limited to parents, i.e. the right to request flexible working does not apply to
aunts, uncles or grandparents, unless they have formal parental responsibility for the
child
2. applies equally to anyone who has responsibility as a parent of a child
3. is available to employees in same-sex relationships.
3. There are a number of circumstances where an employee may have responsibility as a
parent of a child. The employee must satisfy these relationship requirements if he or she is to
be eligible to request flexible working. To be eligible the employee must be:
1. the biological parent, guardian, adopter or foster carer of the child
2. married to a person as outlined in point 1 above
3. the partner of a person as outlined in the point 1 above
4. live with the child
5. have responsibility for the upbringing of the child.
4. When making a request the employee needs to:
1. state that it is an application for flexible working
2. state whether a previous application has been made to the employer and, if so, when
3. specify the flexible working pattern applied for and the date on which it is proposed
the change should come into effect
4. explain what effect, if any, the employee thinks the proposed change would have on
the employer and how, in his or her opinion, any such effect might be dealt with
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