Adoption Leave Policy
1. About this policy
1.1 This policy sets out the arrangements, and entitlements for adoption leave
and pay for employees who are adopting a child through a UK adoption
agency.
1.2 Arrangements for time off for adoption appointments are set out in our Time
off for Adoption Appointments Policy.
1.3 In some cases, you and your spouse or partner may be eligible to opt into the
shared parental leave (SPL) scheme which gives you more flexibility to share
the leave and pay available in the first year. You will need to give us at least
eight weeks notice to opt into SPL, and one of you must take at least two
weeks’ adoption leave. For information about SPL, see our Shared Parental
Leave (Adoption) Policy.
1.4 This policy only applies to employees and does not apply to agency workers
or self-employed contractors. It does not form part of any employee’s contract
of employment and we may amend it at any time.
2. Entitlement to adoption leave
2.1 You are entitled to adoption leave if you meet all the following conditions:
2.1.1 You are adopting a child through a UK or overseas adoption
agency.
2.1.2 The adoption agency has given you written notice that it has
matched you with a child for adoption and tells you the date the
child is expected to be placed into your care with a view to adoption
(Expected Placement Date).
2.1.3 You have notified the agency that you agree to the child being
placed with you on the Expected Placement Date.
2.1.4 Your spouse or partner will not be taking adoption leave with their
employer (although they may be entitled to take paternity leave).
2.2 The maximum adoption leave entitlement is 52 weeks, consisting of 26 weeks’
Ordinary Adoption Leave (OAL) and 26 weeks’ Additional Adoption Leave
(AAL).
3. Notification requirements
3.1 Not more than seven days after the agency notifies you in writing that it has
matched you with a child (or where that is not reasonably practicable, as soon
as reasonably practicable), you must give us notice in writing of the Expected
Placement Date, and your intended start date for adoption leave (Intended
Start Date).
3.2 We will then write to you within 28 days to inform you of your expected return
date assuming you take your full entitlement to adoption leave.
3.3 Once you receive the matching certificate issued by the adoption agency, you
must provide us with a copy.
4. Starting adoption leave
4.1 OAL may start on a predetermined date no more than 14 days before the
Expected Placement Date, or on the date of placement itself, but no later.
4.2 If you want to change your Intended Start Date please tell us in writing. You
should give us as much notice as you can, but wherever possible you must
tell us at least 28 days before the original Intended Start Date (or the new
start date if you are bringing the date forward). We will then write to you within
28 days to tell you your new expected return date.
5. Adoption pay
5.1 Statutory adoption pay (SAP) is payable for up to 39 weeks provided you
have at least 26 weeks’ continuous employment with us at the end of the
Qualifying Week and your average earnings are not less than the lower
earnings limit set by the government each tax year. The first six weeks SAP
are paid at 90% of your average earnings and the remaining 33 weeks are at
a rate set by the government each year. For further information please speak
to Human Resources.
5.2 You will qualify for company adoption pay if you have been continuously
employed during the 26-week period ending with being designated first parent
in case of adoption of a child under the age of 4. The leave must be taken
within the 3 months of the child’s arrival for adoption. The adoption must be
validated by an official act for the employee to benefit from the leave. You
must not have received any company adoption pay from our employment
during the 12-month period ending with being designated first parent. This is
paid at the rate of your normal basic salary during adoption leave for up to 14
weeks and includes any SAP that may be due for that period.
6. During adoption leave
6.1 All the terms and conditions of your employment remain in force during OAL
and AAL, except for the terms relating to pay.
6.2 Holiday entitlement will continue to accrue at the rate provided under your
contract. If your adoption leave will continue into the next holiday year, any
holiday entitlement that cannot reasonably be taken before starting your
adoption leave can be carried over and must be within three months of
returning to work unless your manager agrees otherwise. Please discuss your
holiday plans with your manager in good time before starting your adoption
leave. All holiday dates are subject to approval by your manager.
6.3 If you are a member of the pension scheme, we shall make employer pension
contributions during OAL and any further period of paid adoption leave based
on your normal salary, in accordance with the pension scheme rules. Any
employee contributions you make will be based on the amount of any
adoption pay you are receiving, unless you inform Payroll that you wish to
make up any shortfall.
7. Keeping in touch
7.1 We may make reasonable contact with you from time to time during your
adoption leave although we will keep this to a minimum. This may include
contacting you to discuss arrangements for your return to work.
7.2 You may work (including attending training) on up to ten “keeping-in-touch”
days during your adoption leave. This is not compulsory and must be
discussed and agreed with your line manager.
7.3 You will be paid at your normal basic rate of pay for time spent working on a
keeping-in-touch day and this will be inclusive of any adoption pay
entitlement.
8. Returning to work
8.1 You must return to work on the expected return date unless you tell us
otherwise. If you wish to return to work early, you must give us at least eight
weeks’ notice of the date. It is helpful if you give this notice in writing. You may
be able to return later than the expected return date if you request annual
leave or parental leave, which will be at our discretion.
8.2 You are normally entitled to return to work in the position you held before
starting adoption leave, on the same terms of employment. However, if you
have taken AAL and it is not reasonably practicable for us to allow you to
return to the same position, we may give you another suitable and appropriate
job on terms and conditions that are not less favourable.
8.3 As per the Maternity Leave, Adoption Leave and Shared Parental Leave
(Amendment) Regulations 2024, in the case of redundancy, employees on
adoption leave are statutorily entitled to be automatically given a suitable
alternative role over other employees.
8.4 The protection stated above (clause 8.3) will continue for a period of 18
months from either the date of the placement (for UK adoptions), or 18
months from the date of entry into Great Britain (overseas adoption).
8.5 If you want to change your hours or other working arrangements on return
from adoption leave you should make a request under our Flexible Working
Policy. It is helpful if such requests are made as early as possible.
8.6 If you decide you do not want to return to work you should give notice of
resignation in accordance with your contract.
Alcohol and Drugs Misuse Policy
1. Introduction
Dunton is committed to promoting a safe, healthy, and productive work environment.
Misuse of alcohol and drugs can impair the health and well-being of our employees,
interfere with job performance, and pose significant safety risks.
This policy outlines the company’s stance on alcohol and drugs misuse and provides
guidelines for the prevention, identification, and handling of such issues within the
workplace.
Breaches of the policy may be viewed as gross misconduct and may result in
disciplinary action up to and including dismissal without notice.
2. Employee responsibilities:
2.1. The employee must not test positive for drugs and/or be over the limit for
alcohol when reporting for work or during working time.
2.2. Alcohol will only be available to employees in restricted quantities at special
events such as Christmas parties and Summer BBQs at head office only and
designated supervisors will be appointed to assist. Alcohol will not be sold on
site. Drugs are not permitted on any Dunton sites or offices.
2.3. If the employee is taking medication or herbal remedies that may affect their
work performance, or the safety, of themself or others, they must inform the
Company as soon as possible of which medication the individual is taking and
the possible side effects.
3. Support for employees with alcohol or drug problems:
3.1. If the employee has or believes they may have an alcohol or drug problem,
they should inform the Company and seek medical advice before it affects their
performance or conduct at work.
3.2. In addition, Dunton offers an Employee Assistance Program that provides
confidential support and resources for employees dealing with alcohol or drug-
related issues. Employees are encouraged to seek help voluntarily before their
job performance is affected.
3.3. Employees who disclose alcohol or drug misuse issues will be supported in
seeking treatment and rehabilitation. The Company will treat any absence due
to drug and alcohol abuse in the same way as sickness absence on condition
that they have obtained professional help and are receiving treatment.
However, the employee must not be under the influence of alcohol or drugs at
work throughout this time of support.
3.4. Returning to work after rehabilitation requires medical clearance and may
include regular monitoring and follow-up.
3.5. The use, possession, storage, transportation, promotion and/or sale of illegal
drugs are forbidden in any situation connected to the Company. The Company
reserves the right to involve the relevant authorities if it is deemed appropriate.
3.6. The employee is also expected to comply with any third-party site rules,
policies and procedures.
4. Procedure:
4.1. The Company will take all reasonable steps to prevent employees, agency
workers and contractors carrying out work-related activities, if they are
considered to be unfit or unsafe to undertake the work as a result of drug or
alcohol consumption.
4.2. Random alcohol/drugs testing will be carried out on any member of staff. This
will be decided through a random generator and any staff member employed
either at head office or site can be selected for testing.
4.3. Testing will be conducted in accordance with applicable laws and regulations,
ensuring confidentiality and respect for employees’ privacy.
4.4. If the employee is suspected to be under the influence of alcohol or drugs
during working hours or on Company premises, the Company reserves the
right to send the individual home.
4.5. An alcohol/drugs test will be carried out in all cases where an employee has
had any involvement in a workplace accident or in any incident that has caused
or could have caused a danger to health or safety. Testing will also be carried
out where management has grounds to believe or suspect that an employee
is or may be under the influence of alcohol or drugs.
4.6. Violation of this policy may be viewed as a gross misconduct offence and dealt
with under the Company’s Disciplinary Procedure, which could result in
dismissal without notice. If the Company has reasonable grounds to believe
that the employee was under the influence of drugs and/or alcohol at work,
he/she will not be paid for that day.
Anti-corruption and bribery policy
1. About this policy
1.1 It is our policy to conduct all our business in an honest and ethical manner.
We take a zero-tolerance approach to bribery and corruption and are
committed to acting professionally, fairly and with integrity in all our business
dealings and relationships.
1.2 Any employee who breaches this policy will face disciplinary action, which
could result in dismissal for gross misconduct. Any non-employee who
breaches this policy may have their contract terminated with immediate effect.
1.3 This policy does not form part of any employee’s contract of employment, and
we may amend it at any time. It will be reviewed regularly.
2. Who must comply with this policy?
This policy applies to all persons working for us or on our behalf in any capacity,
including employees at all levels, directors, officers, agency workers, seconded
workers, volunteers, interns, agents, contractors, external consultants, third-party
representatives, and business partners.
2.1 We recognise that within the construction industry in which Dunton operates,
there may have been certain ‘common’ practices possibly carried out on other
sites, by other companies. Dunton does not support these practices, and all
employees should be aware of them and ensure they do not subject
themselves to such practices. These include:
2.1.1 Selling of scrap metal obtained from any demolition related activity
on site for cash or cash equivalents. At Dunton all scrap metal
gained from these activities should be traded through a bona-fide
merchant such as EMR, and ensure delivery note records are
maintained on site and at head office and that all payments made
are directly to the Dunton business account from the merchant. No
cash transactions are allowed.
2.1.2 Selling of recycled aggregates, stone, bricks or any reclaimed
materials for cash or cash equivalents. At Dunton, the resale of any
product from site should be via a bona-fide company and we must
ensure delivery note records are maintained on site and at head
office and all payments should be made directly to the Dunton
business account. No cash transactions are allowed.
2.1.3 Signing off on additional hours for plant and labour hire, in excess
of the actual working hours delivered on site.
2.1.4 Signing off on additional materials supplied, in excess of the actual
volumes delivered.
2.1.5 Signing off on additional waste or soil disposal loads, in excess of
the actual loads removed.
2.1.6 Offering free supply of goods and services to third parties, using
Dunton resources or suppliers.
3. What is bribery?
3.1 Bribe means a financial or other inducement or reward for action which is
illegal, unethical, a breach of trust or improper in any way. Bribes can take the
form of money, gifts, loans, fees, hospitality, services, discounts, the award of
a contract or any other advantage or benefit.
3.2 Bribery includes offering, promising, giving, accepting or seeking a bribe.
3.3 All forms of bribery are strictly prohibited. If you are unsure about whether a
particular act constitutes bribery, raise it with either your Line Manager, the
HR department, or our Whistleblowing Officer.
3.4 Specifically, you must not:
3.4.1 give or offer any payment, gift, hospitality or other benefit in the
expectation that a business advantage will be received in return, or
to reward any business received.
3.4.2 accept any offer from a third party that you know or suspect is made
with the expectation that we will provide a business advantage for
them or anyone else; or
3.4.3 give or offer any payment (sometimes called a facilitation payment)
to a government official in any country to facilitate or speed up a
routine or necessary procedure.
3.5 You must not threaten or retaliate against another person who has refused to
offer or accept a bribe or who has raised concerns about possible bribery or
corruption.
4. Gifts and hospitality
4.1 This policy does not prohibit the giving or accepting of reasonable and
appropriate hospitality for legitimate purposes such as building relationships,
maintaining our image or reputation, or marketing our products and services.
4.2 A gift or hospitality will not be appropriate if it is unduly lavish or extravagant
or could be seen as an inducement or reward for any preferential treatment
(for example, during contractual negotiations or a tender process).
4.3 Gifts must be of an appropriate type and value depending on the
circumstances and taking account of the reason for the gift. Gifts must not
include cash or cash equivalent (such as vouchers) or be given in secret. Gifts
must be given in our name, not your name.
4.4 Promotional gifts of low value such as branded stationery may be given to or
accepted from existing customers, suppliers, and business partners.
4.5 At Dunton we are committed to comply with the Vinci and Soletanche
Freyssinet Group’s policy on ethics and conduct and the anti-corruption code
of conduct. In September 2024, that policy was expanded to include details
about gifts and invitations and the measures we are taking as a business to
protect all our employees from the risk of exposure.
4.6 The policy included various scenarios which all employees should consider as
being high risk of exposure. These included:
4.6.1 Gifts such as cash, wine, travel, hotel stays, information, corporate
events, sports events, payments of expenses, renovations, tuition
fees, employment opportunities for family and friends, use of other
companies’ property etc.
4.6.2 Invitations to social or sporting events, industry dinners concerts,
plays, meals, drinks, transport, lodgings and training etc.
4.7 It is recognised and accepted that the occasional offer and acceptance of a
modest gift or invitation can be a usual part of business life. However, if the
gift is offered or given in the wrong way, the company and the employee could
face legal, reputational and financial risk.
4.8 The policy is therefore offered as a comprehensive guide on how you may
give or receive gifts and invitations. The policy contains detailed scenarios,
but the key areas to watch are to ensure that any gifts offered and received
are not:
4.8.1 Cash or cash equivalents.
4.8.2 Lavish and expensive.
4.8.3 Anything relating to gambling, lottery tickets, adult entertainment or
the sex industry.
4.8.4 Given to influence someone’s behaviour towards another party,
Client or supplier or influence a decision on procurement or
tendering practice.
4.8.5 Offered without any legitimate business purpose.
4.8.6 Offered frequently.
4.8.7 Casting doubt on the honesty of the giver or recipient.
4.8.8 Going to embarrass the employee, the company, client, supplier or
any other associated party.
4.8.9 In excess of the threshold of £200, unless authorised in writing by
the employee’s line manager.
4.9 (If in doubt you should always obtain approval from your line manager. All gifts
should be approved by the giver’s and receiver’s organisation )
5. Record-keeping
5.1 You must declare and keep a written record of all hospitality or gifts given or
received. You must also submit all expenses claims relating to hospitality, gifts
or payments to third parties in accordance with our expenses policy and
record the reason for expenditure.
5.2 All accounts, invoices, and other records relating to dealings with third parties
including suppliers and customers should be prepared with strict accuracy
and completeness. Accounts must not be kept “off-book” to facilitate or
conceal improper payments.
6. How to raise a concern
If you are offered a bribe, or are asked to make one, or if you suspect that any
bribery, corruption or other breach of this policy has occurred or may occur, you must
notify your manager or Human Resources as soon as possible.
7. VINCI Compliance
7.1 As part of VINCI group, we are committed to ensuring that VINCI’s Anti
Corruption Code of Conduct is applied. All employees are to respect and
comply with these rules. Each employee must remain vigilant to these rules
and take individual responsibility in ensuring that they are adhered to.
7.2 All staff who are issued with a company laptop and online account must
complete the mandatory online Anti-corruption course during their
employment. Details of where to find this course is communicated by Human
Resources. For more information on mandatory courses, please see our IT
and communications systems policy.
7.3 We encourage all our staff to read VINCI’s Code of Ethics and Conduct and
Anti Corruption Code of Conduct.
Anti-bullying and harassment Policy
1. About this policy
1.1 Dunton is committed to providing a working environment free from bullying,
harassment and sexual harassment. We are committed to providing a work
environment where everyone is treated with dignity and respect. This policy
outlines the steps Dunton will take to prevent and address harassment in
compliance with UK employment law.
1.2 This policy covers harassment (including sexual harassment) or bullying
which occurs at work and out of the workplace, such as on business trips or at
work-related events or social functions. It covers harassment and sexual
harassment by staff (which may include consultants, contractors and agency
workers).
1.3 This policy does not form part of any employee’s contract of employment, and
we may amend it at any time.
2. What is bullying?
2.1 Bullying is offensive, intimidating, malicious or insulting behaviour, unwanted,
involving the misuse of power that can make a person feel vulnerable, upset,
humiliated, undermined or threatened. Power does not always mean being in
a position of authority but can include both personal strength and the power to
coerce through fear or intimidation.
2.2 Bullying can take the form of physical, verbal and non-verbal conduct. Bullying
may include, by way of example:
2.2.1 physical or psychological threats.
2.2.2 Spreading malicious rumours about someone.
2.2.3 Consistently putting someone down and undermining them
2.2.4 overbearing and intimidating levels of supervision.
2.2.5 Deliberately giving someone a heavier workload than everyone
else.
2.2.6 inappropriate derogatory remarks about someone’s performance.
2.2.7 Excluding someone from team social events.
2.3 Bullying could involve a pattern of behaviour or a one-off incident. It could
happen face-to-face, online, by phone or in writing. It can be verbal and non-
verbal. It is not always obvious to others.
2.4 Although bullying is often connected to a power imbalance, that does not
mean that it always involves a more senior person bullying a more junior
person. It can also be directed at someone more senior than the bully. It may
take the form of spreading rumours, refusing to follow instructions,
undermining authority, making fun of or mocking the more senior person or
spreading rumours about them.
2.5 Legitimate, reasonable and constructive criticism of a worker’s performance or
behaviour, or reasonable instructions given to workers in the course of their
employment, will not amount to bullying on their own.
3. If you are being bullied
3.1 If you are being bullied, consider whether you feel able to raise the problem
informally with the person responsible. You should explain clearly to them that
their behaviour is not welcome or makes you uncomfortable. If this is too
difficult or embarrassing, you should speak to your line manager OR Human
Resources, who can provide confidential advice and assistance in resolving
the issue formally or informally.
3.2 If informal steps are not appropriate, or have not been successful, you should
raise the matter formally under our Grievance Procedure.
3.3 We will investigate complaints in a timely and confidential manner. The
investigation will be conducted by someone with appropriate experience and
no prior involvement in the complaint, where possible. Details of the
investigation and the names of the person making the complaint and the
person accused must only be disclosed on a “need to know” basis. We will
consider whether any steps are necessary to manage any ongoing
relationship between you and the person accused during the investigation.
3.4 Once the investigation is complete, we will inform you of our decision. If we
consider you have been bullied by an employee, the matter will be dealt with
under the Disciplinary Procedure as a case of possible misconduct or gross
misconduct. If the bully is a third party such as a customer or other visitor, we
will consider what action would be appropriate to deal with the problem.
Whether or not your complaint is upheld, we will consider how best to manage
any ongoing working relationship between you and the person concerned.
4. What is harassment?
4.1 Harassment is any unwanted physical, verbal or non-verbal conduct that has
the purpose or effect of violating a person’s dignity or creating an intimidating,
hostile, degrading, humiliating or offensive environment for them.
4.2 It also includes treating someone less favourably because they have
submitted or refused to submit to such behaviour in the past.
4.3 Unlawful harassment may involve conduct of a sexual nature (sexual
harassment (see clause 5)), or it may be related to age, disability, gender
reassignment, marital or civil partner status, pregnancy or maternity, race,
colour, nationality, ethnic or national origin, religion or belief, sex or sexual
orientation. Harassment is unacceptable even if it does not fall within any of
these categories.
4.4 Protected characteristics include age, disability, gender reassignment, race,
religion or belief, sex, and sexual orientation. A single incident can amount to
harassment.
4.5 Harassment may include, for example:
4.5.1 offensive e-mails, text messages or social media content.
4.5.2 mocking, mimicking or belittling a person’s disability.
4.6 A person may be harassed even if they were not the intended “target”. For
example, a person may be harassed by racist jokes about a different ethnic
group if the jokes create an offensive environment. Even if you did not intend
to harass someone, if your behaviour has this effect on someone else, then
you may be found to have harassed them. They may only be a bystander to
behaviour you directed at someone else, but they may still have been
harassed.
4.7 Behaviour can still be harassment even if the person being harassed does not
complain or ask for it to stop.
4.8 We define harassment as behaviour that creates a hostile, humiliating,
degrading or similarly offensive environment in relation to a protected
characteristic. Name-calling, lewd comments, excluding colleagues, making
insensitive jokes and displaying pornographic material are all examples of
harassment.
4.9 The law protects people who are harassed because they are thought to have
a certain protected characteristic when they do not or they are linked to
someone who has a certain protected characteristic even if they don’t have it
themselves.
5. What is Sexual Harassment?
5.1 Sexual harassment is unwanted conduct of a sexual nature. It may include,
but is not limited to:
5.1.1 Inappropriate or unwanted physical conduct
5.1.2 unwelcome sexual advances or suggestive behaviour (which the
harasser may perceive as harmless)
5.1.3 Unwelcome sexual advances or requests for sexual favours.
5.1.4 Sending or displaying sexually explicit materials.
5.1.5 Making sexually suggestive comments, jokes, or gestures.
5.1.6 Any other conduct of a sexual nature that creates an intimidating,
hostile, or offensive environment.
6. Responsibilities
6.1 Employer Responsibilities
6.1.1 We will ensure the workplace is free from harassment.
6.1.2 We will provide training and resources on harassment prevention.
6.1.3 We will assess the risk of harassment in the workplace and keep
our risk assessment under regular review. We encourage you to
come forward with any areas in which you believe harassment
protection could be improved. Please let your line manager or HR
know.
6.1.4 We will take immediate and appropriate action when harassment is
reported.
6.1.5 We will ensure confidentiality and protect employees from
retaliation.
6.1.6 We will record and monitor sexual harassment complaints and
remedial actions to observe any patterns of unwanted behaviour.
6.2 Employee Responsibilities
6.2.1 Treat everyone with respect and dignity in all communications you
have with them, whether face-to-face, over the phone or in writing.
6.2.2 Engage in training and resources on harassment prevention.
6.2.3 Refrain from any form of harassment.
6.2.4 Report any incidents of harassment to your line manager, the HR
department, or our Whistleblowing Officer.
6.2.5 Cooperate with investigations into harassment complaints.
7. Third Party Harassment
7.1 Dunton is committed to creating a workplace free of harassment. This
objective extends beyond acts of harassment by those working for us to
harassment by third parties such as customers, visitors, clients, and suppliers.
7.2 You are encouraged to report any third-party harassment you are a victim of,
or witness, in accordance with this Policy.
7.3 We will take active steps to prevent third-party harassment of staff. Action may
include but is not limited to warning notices to customers or recorded
messages at the beginning of telephone calls.
7.4 We will assess the risk of third-party harassment in the workplace and
undertake to keep our risk assessment under regular review. We encourage
you to come forward with any areas in which you believe our third-party
harassment protection could be improved. Please let either your line manager,
HR, or our Whistleblowing Officer, know. For more details on our
Whistleblowing procedure, please see our Whistleblowing policy.
7.5 If any third-party harassment of staff occurs, we will take steps to remedy any
complaints and to prevent it happening again. Action may include warning the
harasser about their behaviour, banning them from our premises, reporting
any criminal acts to the police, and sharing information with other branches of
the business.
8. Reporting Procedure and Investigations
8.1 If you are being harassed, or witness harassment, consider whether you feel
able to raise the problem informally with the person responsible. You should
explain clearly to them that their behaviour is not welcome or makes you
uncomfortable. If this is too difficult or embarrassing, you should speak to your
line manager OR HR, who can provide confidential advice and assistance in
resolving the issue formally or informally.
8.2 If informal steps are not appropriate, or have not been successful, you should
raise the matter formally under our Grievance Procedure.
8.3 We will investigate complaints in a timely and confidential manner. The
investigation will be conducted by someone with appropriate experience and
no prior involvement in the complaint, where possible. Details of the
investigation and the names of the person making the complaint and the
person accused must only be disclosed on a “need to know” basis. We will
consider whether any steps are necessary to manage any ongoing
relationship between you and the person accused during the investigation.
8.4 Once the investigation is complete, we will inform you of our decision. If we
consider you have been harassed or sexually harassed by an employee, the
matter will be dealt with under the Disciplinary Procedure as a case of
possible misconduct or gross misconduct. If the harasser is a third party such
as a customer or other visitor, we will consider what action would be
appropriate to deal with the problem. Whether or not your complaint is upheld,
we will consider how best to manage any ongoing working relationship
between you and the person concerned.
9. Protection and support for those involved
Staff who make complaints or who participate in good faith in any investigation must
not suffer any form of retaliation or victimisation as a result. Anyone found to have
retaliated against or victimised someone in this way will be subject to disciplinary
action under our Disciplinary Procedure.
10. Record-keeping
Information about a complaint by or about an employee may be placed on the
employee’s personnel file, along with a record of the outcome and of any notes or
other documents compiled during the process.
11. Training and Awareness
Regular training on harassment prevention will be provided to all employees. New
employees will receive training as part of their induction process.
Carer’s Leave Policy
1. About this policy
1.1 The law recognises and we respect that there may be occasions when you will
need to take time off work to provide or arrange care for a dependant with a long-
term care need. The purpose of this policy is to set out the circumstances in
which we will give employees paid time off work to deal with these situations. For
time off for dependants to deal with unexpected events, please see our Time off
for Dependants Policy.
1.2 No-one who takes time off in accordance with this policy will be subjected to any
detriment, disciplinary action, or dismissal for exercising this statutory right, in
line with the Carer’s Leave Act 2023.
1.3 This policy does not form part of any contract of employment or other contract to
provide services, and we may amend it at any time.
2. Who does this policy apply to?
2.1 This policy applies to employees only. It does not apply to agency workers,
consultants, self-employed contractors, volunteers or interns.
3. Who is responsible for this policy?
3.1 The Board of Directors (Board) has overall responsibility for the effective
operation of this policy. Direct responsibility for overseeing its implementation
depends upon the HR Director. Suggestions for changes to this policy should be
reported to the HR Director.
3.2 Any questions you may have about the day-to-day application of this policy
should be referred to the HR Department in the first instance.
4. Time off
4.1 You have a statutory right to take up to one week of paid time off work in each
rolling 12-month period to provide or arrange care for a dependant with a long-
term care need.
4.2 A dependant for the purposes of this policy is:
(a) your spouse, civil partner, child or parent;
(b) a person who lives in the same household as you, but who is not your
tenant, lodger, boarder or employee; or
(c) anyone else who reasonably relies on you to provide or arrange care for
them.
4.3 A dependant has a long-term care need if:
(a) they have an illness or injury (whether physical or mental) that requires,
or is likely to require, care for more than three months;
(b) they have a disability for the purposes of the Equality Act 2010; or
(c) they require care for a reason connected with their old age.
4.4 This list is non-exhaustive, and other individuals may qualify where a reasonable
degree of reliance exists.
5. Amount of time off
5.1 You may take a minimum of half a working day’s leave under this policy and up to
a maximum of one week’s leave per year.
5.2 You do not need to take the days consecutively, provided that you take no more
than the equivalent of one working week’s leave in each rolling 12-month period.
5.3 For employees whose working hours vary:
(a) If you have been employed for at least one year, a week’s leave is
calculated based on the average weekly working hours over the past 12
months.
(b) If you have been employed for less than one year, it is calculated based
on the average hours worked since your start date.
6. Exercising the right to time off
6.1 To take leave under this policy, you must give as much notice as is reasonable
and practical under the circumstances. The notice must include:
(a) A statement that you are entitled to take carer’s leave under this policy;
and
(b) The days you intend to take as carer’s leave and whether you will take a
full or a half day.
6.2 If you fail to notify us appropriately, you may be subject to disciplinary
proceedings under our Disciplinary Procedure for taking unauthorised time off.
7. Employer’s Right to Postpone Leave
7.1 In some circumstances, where the operation of the business would be
significantly disrupted if you took leave, we may need to postpone your carer’s
leave. If we do this:
(a) We will provide a written explanation within seven days of your request.
(b) We will allow you to take the same amount of leave you have requested
at a mutually convenient time within one month of the first day you
originally requested.
8. Protection from Detriment and Dismissal
8.1 Employees have a statutory right to take carer’s leave and will not suffer any
detriment, disciplinary action, or dismissal for exercising this right. Any concerns
about treatment related to taking carer’s leave should be reported to the HR
Department immediately.
9. Interaction with Other Leave Policies
9.1 Carer’s leave is distinct from other forms of statutory leave, such as maternity,
paternity, or adoption leave. Additionally, employees may also request flexible
working arrangements under the Flexible Working (Amendment) Regulations
2023 to help manage their caring responsibilities. If you require ongoing
adjustments, you should discuss this with your line manager or HR.
10. Review and Amendments
This policy will be reviewed regularly to ensure it remains in line with UK legislation and
best practices. Any amendments will be communicated to employees accordingly.
Compassionate Leave Policy
1. About this policy
1.1 Compassionate leave is designed to help you deal with traumatic personal
circumstances such as the death of a close relative or where a close relative
has a life-threatening illness or injury.
1.2 This policy does not form part of any employee’s contract of employment, and
we may amend it at any time.
2. When compassionate leave may be available
2.1 You may take compassionate leave of up to 5 days (with the first three days
being paid leave, the remainder being unpaid leave) where a close relative
has died, is critically ill with a life-threatening illness, or has suffered a life-
threatening injury.
2.2 In the event of the death of a child, including a stillbirth, please see our
Parental Bereavement Leave Policy which applies instead of this policy. We
may grant further unpaid compassionate leave in this situation at our
discretion.
2.3 We will consider requests for compassionate leave due to other traumatic
events or difficult personal circumstances on a case-by-case basis.
2.4 If you are still unable to return to work following compassionate leave you
should contact your line manager. We may at our discretion grant you further
unpaid compassionate leave in those circumstances. Alternatively, you may
be able to take a period of annual leave, subject to your manager’s approval.
3. Requesting compassionate leave
3.1 We recognise that it may not always be possible to request compassionate
leave in advance. However, where it is possible, you should make a request
to your line manager. You should tell them about the reasons for your request
and the number of days leave you would like to take.
3.2 Where it is not possible to request leave in advance you should contact your
line manager as soon as possible to tell them the reason for your absence
and the number of days you expect to be absent. Someone can do this on
your behalf if necessary.
3.3 In exceptional circumstances we may have to refuse a request for
compassionate leave and will give you a written explanation of the reasons.
1. INTERPRETATION
1.1 Definitions:
Automated Decision-Making (ADM): when a decision is made which is based solely
on Automated Processing (including profiling) which produces legal effects or
significantly affects an individual. The UK GDPR prohibits Automated Decision-Making
(unless certain conditions are met) but not Automated Processing.
Automated Processing: any form of automated processing of Personal Data
consisting of the use of Personal Data to evaluate certain personal aspects relating to
an individual, in particular to analyse or predict aspects concerning that individual’s
performance at work, economic situation, health, personal preferences, interests,
reliability, behaviour, location or movements. Profiling is an example of Automated
Processing.
Company name: Dunton Environmental Limited.
Company Personnel: all employees, workers, contractors, agency workers,
consultants, directors, members and others.
Consent: agreement which must be freely given, specific, informed and be an
unambiguous indication of the Data Subject’s wishes by which they, by a statement or
by a clear positive action, signify agreement to the Processing of Personal Data
relating to them.
Controller: the person or organisation that determines when, why and how to process
Personal Data. It is responsible for establishing practices and policies in line with the
UK GDPR. We are the Controller of all Personal Data relating to our Company
Personnel and Personal Data used in our business for our own commercial purposes.
Criminal Convictions Data: means personal data relating to criminal convictions and
offences and includes personal data relating to criminal allegations and proceedings.
Data Subject: a living, identified or identifiable individual about whom we hold
Personal Data. Data Subjects may be nationals or residents of any country and may
have legal rights regarding their Personal Data.
Data Privacy Impact Assessment (DPIA): tools and assessments used to identify
and reduce risks of a data processing activity. DPIA can be carried out as part of
Privacy by Design and should be conducted for all major system or business change
programmes involving the Processing of Personal Data.
Data Protection Officer (DPO): the person required to be appointed in specific
circumstances under the UK GDPR. Where a mandatory DPO has not been
appointed, this term means a data privacy manager or other voluntary appointment of
a DPO or refers to the Company data privacy team with responsibility for data
protection compliance.
Explicit Consent: consent which requires a very clear and specific statement (that is,
not just action).
UK GDPR: the retained EU law version of the General Data Protection Regulation
((EU) 2016/679). Personal Data is subject to the legal safeguards specified in the UK
GDPR.
Personal Data: any information identifying a Data Subject or information relating to a
Data Subject that we can identify (directly or indirectly) from that data alone or in
combination with other identifiers we possess or can reasonably access. Personal
Data includes Special Categories of Personal Data and Pseudonymised Personal
Data but excludes anonymous data or data that has had the identity of an individual
permanently removed. Personal data can be factual (for example, a name, email
address, location or date of birth) or an opinion about that person’s actions or
behaviour.
Personal Data Breach: any act or omission that compromises the security,
confidentiality, integrity or availability of Personal Data or the physical, technical,
administrative or organisational safeguards that we or our third-party service providers
put in place to protect it. The loss, or unauthorised access, disclosure or acquisition,
of Personal Data is a Personal Data Breach.
Privacy by Design: implementing appropriate technical and organisational measures
in an effective manner to ensure compliance with the UK GDPR.
Privacy Guidelines: the Company privacy and UK GDPR related guidelines provided
to assist in interpreting and implementing this Data Protection Policy and Related
Policies, available here, available from your line manager.
Privacy Notices (also referred to as Fair Processing Notices) or Privacy Policies:
separate notices setting out information that may be provided to Data Subjects when
the Company collects information about them. These notices may take the form of
general privacy statements applicable to a specific group of individuals (for example,
employee privacy notices or the website privacy policy) or they may be stand-alone,
one-time privacy statements covering Processing related to a specific purpose.
Processing or Process: any activity that involves the use of Personal Data. It
includes obtaining, recording or holding the data, or carrying out any operation or set
of operations on the data including organising, amending, retrieving, using, disclosing,
erasing or destroying it. Processing also includes transmitting or transferring Personal
Data to third parties.
Pseudonymisation or Pseudonymised: replacing information that directly or
indirectly identifies an individual with one or more artificial identifiers or pseudonyms
so that the person, to whom the data relates, cannot be identified without the use of
additional information which is meant to be kept separately and secure.
Related Policies: the Company’s policies, operating procedures or processes related
to this Data Protection Policy and designed to protect Personal Data, available from
your line manager.
Special Categories of Personal Data: information revealing racial or ethnic origin,
political opinions, religious or similar beliefs, trade union membership, physical or
mental health conditions, sexual life, sexual orientation, biometric or genetic data.
2. Introduction
2.1 This Data Protection Policy sets out how Dunton Environmental Limited (“we”,
“our”, “us”, “the Company”) handle the Personal Data of our customers,
suppliers, employees, workers and other third parties.
2.2 This Data Protection Policy applies to all Personal Data we Process regardless
of the media on which that data is stored or whether it relates to past or present
employees, workers, customers, clients or supplier contacts, shareholders,
website users or any other Data Subject.
2.3 This Data Protection Policy applies to all Company Personnel (“you”, “your”).
You must read, understand and comply with this Data Protection Policy when
Processing Personal Data on our behalf and attend training on its requirements.
This Data Protection Policy sets out what we expect from you for the Company
to comply with applicable law. Your compliance with this Data Protection Policy
is mandatory. Related Policies and Privacy Guidelines are available to help you
interpret and act in accordance with this Data Protection Policy. You must also
comply with all such Related Policies and Privacy Guidelines. Any breach of
this Data Protection Policy may result in disciplinary action.
2.4 Where you have a specific responsibility in connection with Processing such as
capturing Consent, reporting a Personal Data Breach, conducting a DPIA as
referenced in this Data Protection Policy or otherwise then you must comply
with the Related Policies and Privacy Guidelines.
2.5 This Data Protection Policy (together with Related Policies and Privacy
Guidelines) is an internal document and cannot be shared with third parties,
clients or regulators without prior authorisation from the DPO.
3. Scope
3.1 We recognise that the correct and lawful treatment of Personal Data will
maintain confidence in the organisation and will provide for successful business
operations. Protecting the confidentiality and integrity of Personal Data is a
critical responsibility that we take seriously at all times. The Company is
exposed to potential fines of up to £17.5 million or 4% of total worldwide annual
turnover, whichever is higher and depending on the breach, for failure to comply
with the provisions of the UK GDPR.
3.2 All line managers are responsible for ensuring all Company Personnel comply
with this Data Protection Policy and need to implement appropriate practices,
processes, controls and training to ensure that compliance.
3.3 The DPO is responsible for overseeing this Data Protection Policy and, as
applicable, developing Related Policies and Privacy Guidelines. That post is
held by Sam Gellion, and they can be reached at 0121 356 4360 and
samuel.gellion@duntonenvironmental.co.uk
3.4 Please contact the DPO with any questions about the operation of this Data
Protection Policy or the UK GDPR or if you have any concerns that this Data
Protection Policy is not being or has not been followed. In particular, you must
always contact the DPO in the following circumstances:
3.4.1 if you are unsure of the lawful basis which you are relying on to
process Personal Data (including the legitimate interests used by the
Company) (see paragraph 1.2);
3.4.2 if you need to rely on Consent and/or need to capture Explicit
Consent (see paragraph 6);
3.4.3 if you need to draft Privacy Notices (see paragraph 7);
3.4.4 if you are unsure about the retention period for the Personal Data
being Processed (see paragraph 11);
3.4.5 if you are unsure about what security or other measures you need to
implement to protect Personal Data (see paragraph 12.1);
3.4.6 if there has been a Personal Data Breach (paragraph 13);
3.4.7 if you are unsure on what basis to transfer Personal Data outside the
UK (see paragraph 14);
3.4.8 if you need any assistance dealing with any rights invoked by a Data
Subject (see paragraph 15);
3.4.9 whenever you are engaging in a significant new, or change in,
Processing activity which is likely to require a DPIA (see paragraph
19) or plan to use Personal Data for purposes other than what it was
collected for;
3.4.10 if you plan to undertake any activities involving Automated
Processing including profiling or Automated Decision-Making (see
paragraph 20);
3.4.11 if you need help complying with applicable law when carrying out
direct marketing activities (see paragraph 21); or
3.4.12 if you need help with any contracts or other areas in relation to
sharing Personal Data with third parties (including our vendors) (see
paragraph 22).
4. Personal data protection principles
4.1 We adhere to the principles relating to Processing of Personal Data set out in
the UK GDPR which require Personal Data to be:
4.1.1 Processed lawfully, fairly and in a transparent manner (Lawfulness,
Fairness and Transparency);
4.1.2 collected only for specified, explicit and legitimate purposes (Purpose
Limitation);
4.1.3 adequate, relevant and limited to what is necessary in relation to the
purposes for which it is Processed (Data Minimisation);
4.1.4 accurate and where necessary kept up to date (Accuracy);
4.1.5 not kept in a form which permits identification of Data Subjects for
longer than is necessary for the purposes for which the data is
Processed (Storage Limitation);
4.1.6 Processed in a manner that ensures its security using appropriate
technical and organisational measures to protect against
unauthorised or unlawful Processing and against accidental loss,
destruction or damage (Security, Integrity and Confidentiality);
4.1.7 not transferred to another country without appropriate safeguards
being in place (Transfer Limitation); and
4.1.8 made available to Data Subjects and allow Data Subjects to exercise
certain rights in relation to their Personal Data (Data Subject’s Rights
and Requests).
4.2 We are responsible for and must be able to demonstrate compliance with the
data protection principles listed above (Accountability).
5. Lawfulness, fairness, transparency
1.2 Lawfulness and fairness
5.1 Personal data must be Processed lawfully, fairly and in a transparent manner
in relation to the Data Subject.
5.2 You may only collect, Process and share Personal Data fairly and lawfully and
for specified purposes. The UK GDPR restricts our actions regarding Personal
Data to specified lawful purposes. These restrictions are not intended to prevent
Processing but ensure that we Process Personal Data fairly and without
adversely affecting the Data Subject.
5.3 The UK GDPR allows Processing for specific purposes, some of which are set
out below:
5.3.1 the Data Subject has given his or her Consent;
5.3.2 the Processing is necessary for the performance of a contract with
the Data Subject;
5.3.3 to meet our legal compliance obligations;
5.3.4 to protect the Data Subject’s vital interests; or
5.3.5 to pursue our legitimate interests (or those of a third party) for
purposes where they are not overridden because the Processing
prejudices the interests or fundamental rights and freedoms of Data
Subjects. The purposes for which we process Personal Data for
legitimate interests need to be set out in applicable Privacy Notices.
5.4 You must identify and document the legal ground being relied on for each
Processing activity.
6. Consent
6.1 A Controller must only process Personal Data on the basis of one or more of
the lawful bases set out in the UK GDPR, which include Consent.
6.2 A Data Subject consents to Processing of their Personal Data if they indicate
agreement clearly either by a statement or positive action to the Processing.
Consent requires affirmative action so silence, pre-ticked boxes or inactivity are
unlikely to be sufficient. If Consent is given in a document which deals with
other matters, then the Consent must be kept separate from those other
matters.
6.3 Data Subjects must be easily able to withdraw Consent to Processing at any
time and withdrawal must be promptly honoured. Consent may need to be
refreshed if you intend to Process Personal Data for a different and
incompatible purpose which was not disclosed when the Data Subject first
consented.
6.4 When processing Special Category Data or Criminal Convictions Data, we will
usually rely on a legal basis for processing other than Explicit Consent or
Consent if possible. Where Explicit Consent is relied on, you must issue a
Privacy Notice to the Data Subject to capture Explicit Consent.
6.5 You will need to evidence Consent captured and keep records of all Consents
in accordance with Related Policies and Privacy Guidelines so that the
Company can demonstrate compliance with Consent requirements.
7. Transparency (notifying Data Subjects)
7.1 The UK GDPR requires Controllers to provide detailed, specific information to
Data Subjects depending on whether the information was collected directly from
Data Subjects or from elsewhere. The information must be provided through
appropriate Privacy Notices which must be concise, transparent, intelligible,
easily accessible, and in clear and plain language so that a Data Subject can
easily understand them.
7.2 Whenever we collect Personal Data directly from Data Subjects, including for
HR or employment purposes, we must provide the Data Subject with all the
information required by the UK GDPR including the identity of the Controller
and DPO, how and why we will use, Process, disclose, protect and retain that
Personal Data through a Privacy Notice which must be presented when the
Data Subject first provides the Personal Data.
7.3 When Personal Data is collected indirectly (for example, from a third party or
publicly available source), we must provide the Data Subject with all the
information required by the UK GDPR as soon as possible after collecting or
receiving the data. We must also check that the Personal Data was collected
by the third party in accordance with the UK GDPR and on a basis which
contemplates our proposed Processing of that Personal Data.
7.4 If you are collecting Personal Data from Data Subjects, directly or indirectly,
then you must provide Data Subjects with a Privacy Notice in accordance with
our Related Policies and Privacy Guidelines.
8. Purpose limitation
8.1 Personal Data must be collected only for specified, explicit and legitimate
purposes. It must not be further Processed in any manner incompatible with
those purposes.
8.2 You cannot use Personal Data for new, different or incompatible purposes from
that disclosed when it was first obtained unless you have informed the Data
Subject of the new purposes and they have Consented where necessary.
9. Data minimisation
9.1 Personal Data must be adequate, relevant and limited to what is necessary in
relation to the purposes for which it is Processed.
9.2 You may only Process Personal Data when performing your job duties requires
it. You cannot Process Personal Data for any reason unrelated to your job
duties.
9.3 You may only collect Personal Data that you require for your job duties: do not
collect excessive data. Ensure any Personal Data collected is adequate and
relevant for the intended purposes.
9.4 You must ensure that when Personal Data is no longer needed for specified
purposes, it is deleted or anonymised in accordance with the Company’s data
retention guidelines.
10. Accuracy
10.1 Personal Data must be accurate and, where necessary, kept up to date. It must
be corrected or deleted without delay when inaccurate.
10.2 You will ensure that the Personal Data we use and hold is accurate, complete,
kept up to date and relevant to the purpose for which we collected it. You must
check the accuracy of any Personal Data at the point of collection and at regular
intervals afterwards. You must take all reasonable steps to destroy or amend
inaccurate or out-of-date Personal Data.
11. Storage limitation
11.1 Personal Data must not be kept in an identifiable form for longer than is
necessary for the purposes for which the data is processed.
11.2 The Company will maintain retention policies and procedures to ensure
Personal Data is deleted after a reasonable time for the purposes for which it
was being held, unless a law requires that data to be kept for a minimum time.
11.3 You must not keep Personal Data in a form which permits the identification of
the Data Subject for longer than needed for the legitimate business purpose or
purposes for which we originally collected it including for the purpose of
satisfying any legal, accounting or reporting requirements.
11.4 You will take all reasonable steps to destroy or erase from our systems all
Personal Data that we no longer require in accordance with all the Company’s
applicable records retention schedules and policies. This includes requiring
third parties to delete that data where applicable.
11.5 You will ensure Data Subjects are informed of the period for which data is stored
and how that period is determined in any applicable Privacy Notice.
12. Security integrity and confidentiality
1.3 Protecting Personal Data
12.1 Personal Data must be secured by appropriate technical and organisational
measures against unauthorised or unlawful Processing, and against accidental
loss, destruction or damage.
12.2 We will develop, implement and maintain safeguards appropriate to our size,
scope and business, our available resources, the amount of Personal Data that
we own or maintain on behalf of others and identified risks (including use of
encryption and Pseudonymisation where applicable). We will regularly evaluate
and test the effectiveness of those safeguards to ensure security of our
Processing of Personal Data. You are responsible for protecting the Personal
Data we hold. You must implement reasonable and appropriate security
measures against unlawful or unauthorised Processing of Personal Data and
against the accidental loss of, or damage to, Personal Data. You must exercise
particular care in protecting Special Categories of Personal Data and Criminal
Convictions Data from loss and unauthorised access, use or disclosure.
12.3 You must follow all procedures and technologies we put in place to maintain
the security of all Personal Data from the point of collection to the point of
destruction. You may only transfer Personal Data to third-party service
providers who agree to comply with the required policies and procedures and
who agree to put adequate measures in place, as requested.
12.4 You must maintain data security by protecting the confidentiality, integrity and
availability of the Personal Data, defined as follows:
12.4.1 Confidentiality means that only people who have a need to know and
are authorised to use the Personal Data can access it;
12.4.2 Integrity means that Personal Data is accurate and suitable for the
purpose for which it is processed; and
12.4.3 Availability means that authorised users are able to access the
Personal Data when they need it for authorised purposes.
12.5 You must comply with and not attempt to circumvent the administrative,
physical and technical safeguards we implement and maintain in accordance
with the UK GDPR and relevant standards to protect Personal Data.
13. Reporting a Personal Data Breach
13.1 The UK GDPR requires Controllers to notify any Personal Data Breach to the
Information Commissioner and, in certain instances, the Data Subject.
13.2 We have put in place procedures to deal with any suspected Personal Data
Breach and will notify Data Subjects or any applicable regulator where we are
legally required to do so.
13.3 If you know or suspect that a Personal Data Breach has occurred, do not
attempt to investigate the matter yourself. Immediately contact the person or
team designated as the key point of contact for Personal Data Breaches (your
line manager OR Sam Gellion – GDPR Officer. You should preserve all
evidence relating to the potential Personal Data Breach.
14. Transfer limitation
14.1 The UK GDPR restricts data transfers to countries outside the UK to ensure
that the level of data protection afforded to individuals by the UK GDPR is not
undermined. You transfer Personal Data originating in one country across
borders when you transmit, send, view or access that data in or to a different
country.
14.2 You may only transfer Personal Data outside the UK if one of the following
conditions applies:
14.2.1 the UK has issued regulations confirming that the country to which
we transfer the Personal Data ensures an adequate level of
protection for the Data Subject’s rights and freedoms;
14.2.2 appropriate safeguards are in place such as binding corporate rules
(BCR), standard contractual clauses approved for use in the UK, an
approved code of conduct or a certification mechanism, a copy of
which can be obtained from the DPO;
14.2.3 the Data Subject has provided Explicit Consent to the proposed
transfer after being informed of any potential risks; or
14.2.4 the transfer is necessary for one of the other reasons set out in the
UK GDPR including the performance of a contract between us and
the Data Subject, reasons of public interest, to establish, exercise or
defend legal claims or to protect the vital interests of the Data Subject
where the Data Subject is physically or legally incapable of giving
Consent and, in some limited cases, for our legitimate interest.
15. Data Subject’s rights and requests
15.1 Data Subjects have rights when it comes to how we handle their Personal Data.
These include rights to:
15.1.1 withdraw Consent to Processing at any time;
15.1.2 receive certain information about the Controller’s Processing
activities;
15.1.3 request access to their Personal Data that we hold;
15.1.4 prevent our use of their Personal Data for direct marketing purposes;
15.1.5 ask us to erase Personal Data if it is no longer necessary in relation
to the purposes for which it was collected or Processed or to rectify
inaccurate data or to complete incomplete data;
15.1.6 restrict Processing in specific circumstances;
15.1.7 challenge Processing which has been justified on the basis of our
legitimate interests or in the public interest;
15.1.8 request a copy of an agreement under which Personal Data is
transferred outside of the UK;
15.1.9 object to decisions based solely on Automated Processing, including
profiling (ADM);
15.1.10 prevent Processing that is likely to cause damage or distress to the
Data Subject or anyone else;
15.1.11 be notified of a Personal Data Breach which is likely to result in high
risk to their rights and freedoms;
15.1.12 make a complaint to the supervisory authority; and
15.1.13 in limited circumstances, receive or ask for their Personal Data to be
transferred to a third party in a structured, commonly used and
machine-readable format.
15.2 You must verify the identity of an individual requesting data under any of the
rights listed above (do not allow third parties to persuade you into disclosing
Personal Data without proper authorisation).
15.3 You must immediately forward any Data Subject request you receive to your
line manager OR the GDPR Designated Officer.
16. Accountability
16.1 The Controller must implement appropriate technical and organisational
measures in an effective manner, to ensure compliance with data protection
principles. The Controller is responsible for, and must be able to demonstrate,
compliance with the data protection principles.
16.2 The Company must have adequate resources and controls in place to ensure
and to document UK GDPR compliance including:
16.2.1 appointing a suitably qualified DPO (where necessary) and an
executive accountable for data privacy;
16.2.2 implementing Privacy by Design when Processing Personal Data
and completing DPIAs where Processing presents a high risk to
rights and freedoms of Data Subjects;
16.2.3 integrating data protection into internal documents including this Data
Protection Policy, Related Policies, Privacy Guidelines or Privacy
Notices;
16.2.4 regularly training Company Personnel on the UK GDPR, this Data
Protection Policy, Related Policies and Privacy Guidelines and data
protection matters including, for example, Data Subject’s rights,
Consent, legal basis, DPIA and Personal Data Breaches. The
Company must maintain a record of training attendance by Company
Personnel; and
16.2.5 regularly testing the privacy measures implemented and conducting
periodic reviews and audits to assess compliance, including using
results of testing to demonstrate compliance improvement effort.
17. Record keeping
17.1 The UK GDPR requires us to keep full and accurate records of all our data
Processing activities.
17.2 You must keep and maintain accurate corporate records reflecting our
Processing including records of Data Subjects’ Consents and procedures for
obtaining Consents.
17.3 These records should include, at a minimum, the name and contact details of
the Controller and the DPO, clear descriptions of the Personal Data types, Data
Subject types, Processing activities, Processing purposes, third-party
recipients of the Personal Data, Personal Data storage locations, Personal Data
transfers, the Personal Data’s retention period and a description of the security
measures in place. To create the records, data maps should be created which
should include the detail set out above together with appropriate data flows.
18. Training and audit
18.1 We are required to ensure all Company Personnel have undergone adequate
training to enable them to comply with data privacy laws. We must also regularly
test our systems and processes to assess compliance.
18.2 You must undergo all mandatory data privacy related training and ensure your
team undergo similar mandatory training.
18.3 You must regularly review all the systems and processes under your control to
ensure they comply with this Data Protection Policy and check that adequate
governance controls and resources are in place to ensure proper use and
protection of Personal Data.
19. Privacy by Design and Data Protection Impact Assessment (DPIA)
19.1 We are required to implement Privacy by Design measures when Processing
Personal Data by implementing appropriate technical and organisational
measures (like Pseudonymisation) in an effective manner, to ensure
compliance with data privacy principles.
19.2 You must assess what Privacy by Design measures can be implemented on all
programmes, systems or processes that Process Personal Data by taking into
account the following:
19.2.1 the state of the art;
19.2.2 the cost of implementation;
19.2.3 the nature, scope, context and purposes of Processing; and
19.2.4 the risks of varying likelihood and severity for rights and freedoms of
Data Subjects posed by the Processing.
19.3 Controllers must also conduct DPIAs in respect to high-risk Processing.
19.4 You should conduct a DPIA (and discuss your findings with the DPO) when
implementing major system or business change programs involving the
Processing of Personal Data including:
19.4.1 use of new technologies (programs, systems or processes), or
changing technologies (programs, systems or processes);
19.4.2 Automated Processing including profiling and ADM;
19.4.3 large-scale Processing of Special Categories of Personal Data or
Criminal Convictions Data; and
19.4.4 large-scale, systematic monitoring of a publicly accessible area.
19.5 A DPIA must include:
19.5.1 a description of the Processing, its purposes and the Controller’s
legitimate interests if appropriate;
19.5.2 an assessment of the necessity and proportionality of the Processing
in relation to its purpose;
19.5.3 an assessment of the risk to individuals; and
19.5.4 the risk mitigation measures in place and demonstration of
compliance.
20. Automated Processing (including profiling) and Automated Decision-
Making
20.1 Generally, ADM is prohibited when a decision has a legal or similar significant
effect on an individual unless:
20.1.1 a Data Subject has Explicitly Consented;
20.1.2 the Processing is authorised by law; or
20.1.3 the Processing is necessary for the performance of or entering into a
contract.
20.2 If certain types of Special Categories of Personal Data or Criminal Convictions
Data are being processed, then grounds (b) or (c) will not be allowed but the
Special Categories of Personal Data and Criminal Convictions Data can be
Processed where it is necessary (unless less intrusive means can be used) for
substantial public interest like fraud prevention.
20.3 If a decision is to be based solely on Automated Processing (including profiling),
then Data Subjects must be informed when you first communicate with them of
their right to object. This right must be explicitly brought to their attention and
presented clearly and separately from other information. Further, suitable
measures must be put in place to safeguard the Data Subject’s rights and
freedoms and legitimate interests.
20.4 We must also inform the Data Subject of the logic involved in the decision
making or profiling, the significance and envisaged consequences and give the
Data Subject the right to request human intervention, express their point of view
or challenge the decision.
20.5 A DPIA must be carried out before any Automated Processing (including
profiling) or ADM activities are undertaken.
21. Direct marketing
21.1 We are subject to certain rules and privacy laws when marketing to our
customers.
21.2 For example, a Data Subject’s prior consent is required for electronic direct
marketing (for example, by email, text or automated calls). The limited
exception for existing customers known as “soft opt-in” allows organisations to
send marketing texts or emails if they have obtained contact details in the
course of a sale to that person, they are marketing similar products or services,
and they gave the person an opportunity to opt out of marketing when first
collecting the details and in every subsequent message.
21.3 The right to object to direct marketing must be explicitly offered to the Data
Subject in an intelligible manner so that it is clearly distinguishable from other
information.
21.4 A Data Subject’s objection to direct marketing must be promptly honoured. If a
customer opts out at any time, their details should be suppressed as soon as
possible. Suppression involves retaining just enough information to ensure that
marketing preferences are respected in the future.
21.5 You must comply with the Company’s guidelines on direct marketing to
customers.
22. Sharing Personal Data
22.1 Generally, we are not allowed to share Personal Data with third parties unless
certain safeguards and contractual arrangements have been put in place.
22.2 You may only share the Personal Data we hold with another employee, agent
or representative of our group (which includes our subsidiaries and our ultimate
holding company along with its subsidiaries) if the recipient has a job-related
need to know the information and the transfer complies with any applicable
cross-border transfer restrictions.
22.3 You may only share the Personal Data we hold with third parties, such as our
service providers, if:
22.3.1 they have a need to know the information for the purposes of
providing the contracted services;
22.3.2 sharing the Personal Data complies with the Privacy Notice provided
to the Data Subject and, if required, the Data Subject’s Consent has
been obtained;
22.3.3 the third party has agreed to comply with the required data security
standards, policies and procedures and put adequate security
measures in place;
22.3.4 the transfer complies with any applicable cross-border transfer
restrictions; and
22.3.5 a fully executed written contract that contains UK GDPR-approved
third party clauses has been obtained.
22.4 You must comply with the Company’s guidelines on sharing data with third
parties.
23. Changes to this Data Protection Policy
23.1 We keep this Data Protection Policy under regular review.
23.2 This Data Protection Policy does not override any applicable national data
privacy laws and regulations in countries where the Company operates.
24. Acknowledgement of receipt and review
I, [EMPLOYEE NAME], acknowledge that on [DATE], I received and read a copy of
the Dunton Environmental Limited’s Data Protection Policy and understand that I am
responsible for knowing and abiding by its terms. This Data Protection Policy does not
set terms or conditions of employment or form part of an employment contract.
Signed ……………………………………………………….
Printed Name ……………………………………………….
Date ………………………………………………………….
Schedule 27
Privacy notice for employees, workers and contractors
1. What is the purpose of this document?
Dunton Environmental Limited is committed to protecting the privacy and security of
your personal information.
This privacy notice describes how we collect and use personal information about
you during and after your working relationship with us, in accordance with the UK
General Data Protection Regulation (UK GDPR).
It applies to all employees, workers and contractors.
1.1 Dunton Environmental Limited is a “controller”. This means that we are
responsible for deciding how we hold and use personal information about you.
We are required under data protection legislation to notify you of the information
contained in this privacy notice.
1.2 This notice applies to current and former employees, workers and contractors.
This notice does not form part of any contract of employment or other contract
to provide services. We may update this notice at any time but if we do so, we
will provide you with an updated copy of this notice as soon as reasonably
practical.
1.3 It is important that you read and retain this notice, together with any other
privacy notice we may provide on specific occasions when we are collecting or
processing personal information about you, so that you are aware of how and
why we are using such information and what your rights are under the data
protection legislation.
2. Data protection principles
We will comply with data protection law. This says that the personal information we
hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not
used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those
purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
3. The kind of information we hold about you
Personal data, or personal information, means any information about an individual
from which that person can be identified. It does not include data where the identity
has been removed (anonymous data).
There are certain types of more sensitive personal data which require a higher level
of protection, such as information about a person’s health or sexual orientation.
Information about criminal convictions also warrants this higher level of protection.
3.1 We will collect, store, and use the following categories of personal information
about you:
3.1.1 Personal contact details such as name, title, addresses, telephone
numbers, and personal email addresses.
3.1.2 Date of birth.
3.1.3 Gender.
3.1.4 Marital status and dependants.
3.1.5 Next of kin and emergency contact information.
3.1.6 National Insurance number.
3.1.7 Bank account details, payroll records and tax status information.
3.1.8 Salary, annual leave, pension and benefits information.
3.1.9 Start date and, if different, the date of your continuous employment.
3.1.10 Leaving date and your reason for leaving.
3.1.11 Location of employment or workplace.
3.1.12 Copy of driving licence.
3.1.13 Recruitment information (including copies of right to work
documentation, references and other information included in a CV or
cover letter or as part of the application process).
3.1.14 Employment records (including job titles, work history, working hours,
holidays, training records and professional memberships).
3.1.15 Compensation history.
3.1.16 Performance information.
3.1.17 Disciplinary and grievance information.
3.1.18 CCTV footage and other information obtained through electronic
means such as swipe card records.
3.1.19 Information about your use of our information and communications
systems.
3.1.20 Photographs.
3.1.21 Results of HMRC employment status check, details of your interest
in and connection with the intermediary through which your services
are supplied.
3.2 We may also collect, store and use the following more sensitive types of
personal information:
3.2.1 Information about your race or ethnicity, religious beliefs, sexual
orientation and political opinions.
3.2.2 Trade union membership.
3.2.3 Information about your health, including any medical condition,
health and sickness records, including:
3.2.4 where you leave employment and under any share plan operated by
a group company the reason for leaving is determined to be ill-health,
injury or disability, the records relating to that decision;
3.2.5 details of any absences (other than holidays) from work including
time on statutory parental leave and sick leave; and
3.2.6 where you leave employment and the reason for leaving is related to
your health, information about that condition needed for pensions
and permanent health insurance purposes.
3.2.7 Genetic information and biometric data.
3.2.8 Information about criminal convictions and offences.
4. How is your personal information collected?
4.1 We collect personal information about employees, workers and contactors
through the application and recruitment process, either directly from candidates
or sometimes from an employment agency or background check provider. We
may sometimes collect additional information from third parties including former
employers, credit reference agencies or other background check agencies.
4.2 We will collect additional personal information in the course of job-related
activities throughout the period of you working for us.
5. How we will use information about you
We will only use your personal information when the law allows us to. Most
commonly, we will use your personal information in the following circumstances:
1. Where we need to perform the contract we have entered into with you.
2. Where we need to comply with a legal obligation.
3. Where it is necessary for legitimate interests pursued by us or a third party and
your interests and fundamental rights do not override those interests.
We may also use your personal information in the following situations, which are
likely to be rare:
1. Where we need to protect your interests (or someone else’s interests).
2. Where it is needed in the public interest or for official purposes.
6. Situations in which we will use your personal information
6.1 We need all the categories of information in the list above primarily to allow us
to perform our contract with you and to enable us to comply with legal
obligations. In some cases we may use your personal information to pursue
legitimate interests, provided your interests and fundamental rights do not
override those interests. The situations in which we will process your personal
information are listed below.
6.1.1 Making a decision about your recruitment or appointment.
6.1.2 Determining the terms on which you work for us.
6.1.3 Checking you are legally entitled to work in the UK.
6.1.4 Paying you and, if you are an employee or deemed employee for tax
purposes, deducting tax and National Insurance contributions (NICs).
6.1.5 Enrolling you in a pension arrangement in accordance with our
statutory automatic enrolment duties.
6.1.6 Liaising with the trustees or managers of a pension arrangement
operated by a group company, your pension provider and any other
provider of employee benefits.
6.1.7 Administering the contract we have entered into with you.
6.1.8 Business management and planning, including accounting and
auditing.
6.1.9 Conducting performance reviews, managing performance and
determining performance requirements.
6.1.10 Making decisions about salary reviews and compensation.
6.1.11 Assessing qualifications for a particular job or task, including
decisions about promotions.
6.1.12 Gathering evidence for possible grievance or disciplinary hearings.
6.1.13 Making decisions about your continued employment or engagement.
6.1.14 Making arrangements for the termination of our working relationship.
6.1.15 Education, training and development requirements.
6.1.16 Dealing with legal disputes involving you, or other employees,
workers and contractors, including accidents at work.
6.1.17 Ascertaining your fitness to work.
6.1.18 Managing sickness absence.
6.1.19 Complying with health and safety obligations.
6.1.20 To prevent fraud.
6.1.21 To monitor your use of our information and communication systems
to ensure compliance with our IT policies.
6.1.22 To ensure network and information security, including preventing
unauthorised access to our computer and electronic communications
systems and preventing malicious software distribution.
6.1.23 To conduct data analytics studies to review and better understand
employee retention and attrition rates.
6.1.24 Equal opportunities monitoring.
6.2 Some of the above grounds for processing will overlap and there may be
several grounds which justify our use of your personal information.
7. If you fail to provide personal information
If you fail to provide certain information when requested, we may not be able to
perform the contract we have entered into with you (such as paying you or
providing a benefit), or we may be prevented from complying with our legal
obligations (such as to ensure the health and safety of our workers).
8. Change of purpose
8.1 We will only use your personal information for the purposes for which we
collected it, unless we reasonably consider that we need to use it for another
reason and that reason is compatible with the original purpose. If we need to
use your personal information for an unrelated purpose, we will notify you and
we will explain the legal basis which allows us to do so.
8.2 Please note that we may process your personal information without your
knowledge or consent, in compliance with the above rules, where this is
required or permitted by law.
9. How we use particularly sensitive personal information
“Special categories” of particularly sensitive personal information, such as
information about your health, racial or ethnic origin, sexual orientation or trade
union membership, require higher levels of protection. We need to have further
justification for collecting, storing and using this type of personal information. We
have in place an appropriate policy document and safeguards which we are required
by law to maintain when processing such data. We may process special categories
of personal information in the following circumstances:
1. In limited circumstances, with your explicit written consent.
2. Where we need to carry out our legal obligations or exercise rights in connection
with employment.
3. Where it is needed in the public interest, such as for equal opportunities.
Less commonly, we may process this type of information where it is needed in
relation to legal claims or where it is needed to protect your interests (or someone
else’s interests) and you are not capable of giving your consent, or where you have
already made the information public.
10. Situations in which we will use your sensitive personal information
In general, we will not process particularly sensitive personal information about
you unless it is necessary for performing or exercising obligations or rights in
connection with employment. On rare occasions, there may be other reasons
for processing, such as it is in the public interest to do so. The situations in
which we will process your particularly sensitive personal information are listed
below.
10.1.1 We will use information about your physical or mental health, or
disability status, to ensure your health and safety in the workplace
and to assess your fitness to work, to provide appropriate workplace
adjustments, to monitor and manage sickness absence and to
administer benefits including statutory maternity pay, statutory sick
pay, pensions and permanent health insurance. We need to process
this information to exercise rights and perform obligations in
connection with your employment.
10.1.2 We will use information about your race or national or ethnic origin,
religious, philosophical or moral beliefs, or your sexual life or sexual
orientation, to ensure meaningful equal opportunity monitoring and
reporting.
11. Do we need your consent?
We do not need your consent if we use special categories of your personal
information in accordance with our written policy to carry out our legal
obligations or exercise specific rights in the field of employment law. In limited
circumstances, we may approach you for your written consent to allow us to
process certain particularly sensitive data. If we do so, we will provide you with
full details of the information that we would like and the reason we need it, so
that you can carefully consider whether you wish to consent. You should be
aware that it is not a condition of your contract with us that you agree to any
request for consent from us.
12. Information about criminal convictions
We may only use information relating to criminal convictions where the law allows
us to do so. This will usually be where such processing is necessary to carry out our
obligations and provided, we do so in line with our Data Protection Policy.
12.1 We do not envisage that we will hold information about criminal convictions.
12.2 We will only collect information about criminal convictions if it is appropriate
given the nature of the role and where we are legally able to do so. Where
appropriate, we will collect information about criminal convictions as part of the
recruitment process or we may be notified of such information directly by you
in the course of you working for us.
12.3 We are allowed to use your personal information in this way to carry out our
obligations We have in place an appropriate policy and safeguards which we
are required by law to maintain when processing such data.
13. Automated decision-making
Automated decision-making takes place when an electronic system uses personal
information to make a decision without human intervention. We are allowed to use
automated decision-making in the following circumstances:
1. Where we have notified you of the decision and given you 21 days to request a
reconsideration.
2. Where it is necessary to perform the contract with you and appropriate measures
are in place to safeguard your rights.
3. In limited circumstances, with your explicit written consent and where appropriate
measures are in place to safeguard your rights.
If we make an automated decision on the basis of any particularly sensitive personal
information, we must have either your explicit written consent or it must be justified
in the public interest, and we must also put in place appropriate measures to
safeguard your rights.
13.1 You will not be subject to decisions that will have a significant impact on you
based solely on automated decision-making, unless we have a lawful basis for
doing so and we have notified you.
13.2 We do not envisage that any decisions will be taken about you using automated
means, however we will notify you in writing if this position changes.
14. Data sharing
We may have to share your data with third parties, including third-party service
providers and other entities in the group.
We require third parties to respect the security of your data and to treat it in
accordance with the law.
We may transfer your personal information outside the UK.
If we do, you can expect a similar degree of protection in respect of your personal
information.
15. Why might you share my personal information with third parties?
We will share your personal information with third parties where required by
law, where it is necessary to administer the working relationship with you or
where we have another legitimate interest in doing so.
16. Which third-party service providers process my personal information?
16.1 “Third parties” includes third-party service providers (including contractors and
designated agents) and other entities within our group. The following activities
are carried out by third-party service providers: payroll, pension administration,
benefits provision and administration, IT services
16.2 We will share personal data regarding your participation in any pension
arrangement operated by a group company with the trustees or scheme
managers of the arrangement in connection with the administration of the
arrangements.
17. How secure is my information with third-party service providers and other
entities in our group?
All our third-party service providers and other entities in the group are required
to take appropriate security measures to protect your personal information in
line with our policies. We do not allow our third-party service providers to use
your personal data for their own purposes. We only permit them to process your
personal data for specified purposes and in accordance with our instructions.
18. When might you share my personal information with other entities in the
group?
We will share your personal information with other entities in our group as part
of our regular reporting activities on company performance, in the context of a
business reorganisation or group restructuring exercise, for system
maintenance support and hosting of data.
19. What about other third parties?
19.1 We may share your personal information with other third parties, for example in
the context of the possible sale or restructuring of the business. In this situation
we will, so far as possible, share anonymised data with the other parties before
the transaction completes. Once the transaction is completed, we will share
your personal data with the other parties if and to the extent required under the
terms of the transaction.
19.2 We may also need to share your personal information with a regulator or to
otherwise comply with the law. This may include making returns to HMRC,
disclosures to stock exchange regulators and disclosures to shareholders such
as directors’ remuneration reporting requirements.
Transferring information outside the UK
We will transfer the personal information we collect about you to the following
country outside the UK [France] in order to perform our contract with you. There
are adequacy regulations in respect of that country. This means that the country
to which we transfer your data are deemed to provide an adequate level of
protection for your personal information.
However, to ensure that your personal information does receive an adequate
level of protection we have put in place the following appropriate measure[s] to
ensure that your personal information is treated by those third parties in a way
that is consistent with and which respects UK law on data protection: BINDING
CORPORATE RULES. If you require further information about this protective
measure, you can request it from Health, Safety & Wellbeing department.
20. Data security
We have put in place measures to protect the security of your information. Details
of these measures are available upon request.
Third parties will only process your personal information on our instructions and
where they have agreed to treat the information confidentially and to keep it secure.
20.1 We have put in place appropriate security measures to prevent your personal
information from being accidentally lost, used or accessed in an unauthorised
way, altered or disclosed. In addition, we limit access to your personal
information to those employees, agents, contractors and other third parties who
have a business need to know. They will only process your personal information
on our instructions and they are subject to a duty of confidentiality.
20.2 We have put in place procedures to deal with any suspected data security
breach and will notify you and any applicable regulator of a suspected breach
where we are legally required to do so.
21. Data retention
22. How long will you use my information for?
22.1 We will only retain your personal information for as long as necessary to fulfil
the purposes we collected it for, including for the purposes of satisfying any
legal, accounting, or reporting requirements. To determine the appropriate
retention period for personal data, we consider the amount, nature, and
sensitivity of the personal data, the potential risk of harm from unauthorised use
or disclosure of your personal data, the purposes for which we process your
personal data and whether we can achieve those purposes through other
means, and the applicable legal requirements.
22.2 In some circumstances we may anonymise your personal information so that it
can no longer be associated with you, in which case we may use such
information without further notice to you. Once you are no longer an employee,
worker or contractor of the company we will retain and securely destroy your
personal information in accordance with applicable laws and regulations.
23. Rights of access, correction, erasure, and restriction
24. Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and
current. Please keep us informed if your personal information changes during
your working relationship with us.
25. Your rights in connection with personal information
25.1 Under certain circumstances, by law you have the right to:
25.1.1 Request access to your personal information (commonly known as
a “data subject access request”). This enables you to receive a copy
of the personal information we hold about you and to check that we
are lawfully processing it.
25.1.2 Request correction of the personal information that we hold about
you. This enables you to have any incomplete or inaccurate
information we hold about you corrected.
25.1.3 Request erasure of your personal information. This enables you to
ask us to delete or remove personal information where there is no
good reason for us continuing to process it. You also have the right
to ask us to delete or remove your personal information where you
have exercised your right to object to processing (see below).
25.1.4 Object to processing of your personal information where we are
relying on a legitimate interest (or those of a third party) and there is
something about your particular situation which makes you want to
object to processing on this ground. You also have the right to object
where we are processing your personal information for direct
marketing purposes.
25.1.5 Request the restriction of processing of your personal
information. This enables you to ask us to suspend the processing of
personal information about you, for example if you want us to
establish its accuracy or the reason for processing it.
25.1.6 Request the transfer of your personal information to another party.
25.2 If you want to review, verify, correct or request erasure of your personal
information, object to the processing of your personal data, or request that we
transfer a copy of your personal information to another party, please contact
[POSITION] in writing.
26. No fee usually required
You will not have to pay a fee to access your personal information (or to
exercise any of the other rights). However, we may charge a reasonable fee if
your request for access is clearly unfounded or excessive. Alternatively, we
may refuse to comply with the request in such circumstances.
27. What we may need from you
We may need to request specific information from you to help us confirm your
identity and ensure your right to access the information (or to exercise any of
your other rights). This is another appropriate security measure to ensure that
personal information is not disclosed to any person who has no right to receive
it.
28. Right to withdraw consent
In the limited circumstances where you may have provided your consent to the
collection, processing and transfer of your personal information for a specific
purpose, you have the right to withdraw your consent for that specific
processing at any time. To withdraw your consent, please contact Sam Gellion
– GDPR Officer. Once we have received notification that you have withdrawn
your consent, we will no longer process your information for the purpose or
purposes you originally agreed to, unless we have another legitimate basis for
doing so in law.
29. Data protection officer
We have appointed a [data protection officer (DPO) to oversee compliance with
this privacy notice. If you have any questions about this privacy notice or how
we handle your personal information, please contact the DPO You have the
right to make a complaint at any time to the Information Commissioner’s Office
(ICO)].
30. Changes to this privacy notice
30.1 We reserve the right to update this privacy notice at any time, and we will
provide you with a new privacy notice when we make any substantial updates.
We may also notify you in other ways from time to time about the processing of
your personal information.
If you have any questions about this privacy notice, please contact the
HR Director
30.2 I,___________________________ (employee/worker/contractor name),
acknowledge that on _________________________ (date), I received a copy
of Dunton Environmental Limited’s privacy notice for employees, workers and
contractors and that I have read and understood it.
Signature ……………………………………………………….
Printed Name ……………………………………………….
Disciplinary and Capability Procedure
1. About this procedure
1.1 This procedure is intended to help maintain standards of conduct and
performance and to ensure fairness and consistency when dealing with
allegations of misconduct or poor performance.
1.2 Minor conduct or performance issues can usually be resolved informally with
your line manager. This procedure sets out formal steps to be taken if the
matter is more serious or cannot be resolved informally.
1.3 This procedure applies to all employees regardless of length of service. It
does not apply to agency workers or self-employed contractors.
1.4 This procedure does not form part of any employee’s contract of employment,
and we may amend it at any time.
2. Investigations
2.1 Before any disciplinary hearing is held, the matter will be investigated. Any
meetings and discussions as part of an investigation are solely for the
purpose of fact-finding and no disciplinary action will be taken without a
disciplinary hearing.
2.2 In some cases of alleged misconduct, we may need to suspend you from
work while we carry out the investigation or disciplinary procedure (or both).
While suspended, you should not visit our premises or contact any of our
clients, customers, suppliers, contractors or staff, unless authorised to do so.
Suspension is not considered to be disciplinary action.
3. The hearing
3.1 We will give you written notice of the hearing, including sufficient information
about the alleged misconduct or poor performance and its possible
consequences to enable you to prepare. You may be given copies of relevant
documents and witness statements.
3.2 You may be accompanied at the hearing by a trade union representative or a
colleague, who will be allowed reasonable paid time off to act as your
companion.
3.3 You should let us know as early as possible if there are any relevant
witnesses you would like to attend the hearing or any documents or other
evidence you wish to be considered.
3.4 We will inform you in writing of our decision, usually within one week of the
hearing.
4. Disciplinary action and dismissal
The usual penalties for misconduct or poor performance are:
4.1.1 Stage 1: First written warning. Where there are no other active
written warnings on your disciplinary record, you will usually receive
a first written warning. It will usually remain active for six months.
4.1.2 Stage 2: Final written warning. In case of further misconduct or
failure to improve where there is an active first written warning on
your record, you will usually receive a final written warning. This
may also be used without a first written warning for serious cases of
misconduct or poor performance. The warning will usually remain
active for 12 months.
4.1.3 Stage 3: Dismissal or other action. You may be dismissed for
further misconduct or failure to improve where there is an active
final written warning on your record, or for any act of gross
misconduct. Examples of gross misconduct are given below
(paragraph 6). You may also be dismissed without a warning for any
act of misconduct or unsatisfactory performance during your
probationary period.
We may consider other sanctions short of dismissal, including demotion or
redeployment to another role (where permitted by your contract), and/or extension of
a final written warning with a further review period.
5. Appeals
5.1 You may appeal in writing within one week of being told of the decision.
5.2 The appeal hearing will, where possible, be held by someone other than the
person who held the original hearing. You may bring a colleague or trade
union representative with you to the appeal hearing.
5.3 We will inform you in writing of our final decision as soon as possible, usually
within one week of the appeal hearing. There is no further right of appeal.
6. Gross misconduct
6.1 Gross misconduct will usually result in dismissal without warning, with no
notice or payment in lieu of notice (summary dismissal).
6.2 Gross misconduct is a serious breach of contract and includes misconduct
which, in our opinion, is likely to prejudice our business or reputation or
irreparably damage the working relationship and trust between us. This may
include misconduct committed outside of work. The following are examples of
matters that are normally regarded as gross misconduct:
6.2.1 theft or fraud.
6.2.2 physical violence or bullying.
6.2.3 deliberate and serious damage to property.
6.2.4 serious misuse of the organisation’s property or name.
6.2.5 deliberately accessing internet sites containing pornographic,
offensive, or obscene material.
6.2.6 serious insubordination.
6.2.7 unlawful discrimination, victimisation, harassment, or sexual
harassment.
6.2.8 bringing the organisation into serious disrepute.
6.2.9 serious incapability at work brought on by alcohol or illegal drugs.
6.2.10 causing loss, damage, or injury through serious negligence.
6.2.11 a serious breach of health and safety rules.
6.2.12 a serious breach of confidence.
This list is intended as a guide and is not exhaustive.
Dress Code Policy
1. About this policy
1.1 We encourage everyone to maintain an appropriate standard of dress and
personal appearance at work. The purpose of our dress code is to establish
basic guidelines on appropriate clothing and appearance at our workplace, so
that we:
1.1.1 promote a positive and professional image.
1.1.2 respect the needs of men, women and all other genders from all
cultures and religions.
1.1.3 make any adjustments that may be needed because of disability.
1.1.4 take account of health and safety requirements; and
1.1.5 help staff and managers decide what clothing it is appropriate to
wear to work.
1.2 Managers are responsible for ensuring that this dress code is observed and
that a common-sense approach is taken to any issues that may arise. Any
enquiries regarding the operation of our dress code (including whether an
article of clothing is suitable to wear to work) should be made to your line
manager or Human Resources.
1.3 Failure to comply with the dress code may result in action under our
Disciplinary Procedure.
1.4 We will review our dress code periodically to ensure that it reflects appropriate
standards and continues to meet our needs.
1.5 This policy does not form part of any employee’s contract of employment, and
we may amend it at any time.
2. Appearance
2.1 While working for us you represent us with clients and customers and the
public. Your appearance contributes to our reputation and the development of
our business.
2.2 It is important that you appear clean and smart at all times when at work,
particularly when you may be in contact with clients, other business contacts
or the general public.
2.3 Different departments may have specific clothing requirements, for example,
because their work is customer-facing or raises health and safety concerns. It
is important that you dress in a manner appropriate to your working
environment and the type of work you do.
2.4 Footwear must be safe and clean and take account of health and safety
considerations.
2.5 Where we provide safety clothing and equipment, including protective
footwear, it should be worn or used as appropriate and directed.
2.6 You should not wear clothing or jewellery that could present a health and
safety risk.
3. Religious and cultural dress
3.1 You may wear appropriate religious and cultural dress (including clerical
collars, head scarves, skullcaps, and turbans) unless it creates a health and
safety risk to you or any other person or otherwise breaches this policy.
3.2 Where necessary, Human Resources can give further information and
guidance on cultural and religious dress in the workplace.
3.3 Priority is always given to health and safety requirements. Where necessary,
advice will be taken from the Health, Safety and Wellbeing Manager.
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EXPENSES POLICY
FEBRUARY 2023
1
Expenses Policy – update February 2023
Contents
1. Introduction
2. Company Expectations and Policy Compliance (Employees’ and Managers’ Responsibilities)
3. Bribery and Corruption
4. Business Mileage
5. Other Allowable Expenses
6. Exception
7. Submission for Authorisation
1. Introduction
The expenses policy applies to all employees of Dunton and has been introduced to ensure we have
clarity, consistency and adherence to current legislation. It is a framework that covers how an
employee can claim and be reimbursed for reasonable and authorised expenses that are incurred
while doing business for Dunton.
Employees should ensure they are familiar with and abide by the policy and managers need to
ensure they and their teams comply with the policy guidelines.
The policy aims to:
• Provide regular and timely reimbursements to employees
• Control costs
• Prevent fraud; and
• Ensure the company complies with its tax and legal obligations
Any concerns regarding the policy should be directed to Victoria Allen (Head of Finance), or Elizabeth
Brittle (Health Safety & Wellbeing Manager).
2. Company Expectations and Policy Compliance (Employees’ and Managers’
Responsibilities)
As an employee (claimant), we ask that you;
• Behave honestly, responsibly, and within the guidelines of this policy and keep costs to a
minimum.
• Expenses should be pre-approved by your line manager and submitted as soon as possible
after the month end and by the 15th of the following month to allow time for Director
approval prior to accounts processing.
• The correct expense form must be used, with all requested information provided
including reason for journey or purchase.
• Provide VAT receipts (not just credit card slips) so we can reclaim any VAT paid as HMRC
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requires them. This includes mileage claims where VAT fuel receipts should be provided
to the value (or more) of the claim submitted.
• For staff/business entertaining, full names of all attendees and their organisation to be
included.
• Late submissions will not be re-imbursed unless by prior approval by a Director.
• No claims over 3 months old will be processed.
As a manager (approver), we expect you to;
• Check that purchases/mileage comply with the policy and that there is a valid business reason
for the expenditure.
• Check that the costs have actually been incurred (receipts provided) and full details have been
provided, including postcodes for travel ‘to’ and ‘from’ locations.
• Approve them promptly
• Ensure they’re claimed promptly and within 3 months
Where employees do not comply with policy, we can delay reimbursement or rejects claims.
Persistent or deliberate non-compliance may result in disciplinary action.
A manager cannot authorise an expense claim from which they benefit. The company would expect
the most senior manager to reclaim any expense incurred where they were party to that spend.
This ensures the approver of the claim is independent of this spend.
What are the consequences of submitting false claims?
The submission of false claims might include but is not limited to;
• Claiming for costs you have not incurred
• Claiming mileage for journeys that have not taken place
• Claiming incorrect number of miles for journeys; and
• Submission of someone else’s receipts e.g. fuel not for your car
Submitting a false claim for expenses may lead to disciplinary proceedings, up to and including
dismissal, and if applicable, deductions from your pay.
3. Bribery and Corruption
Dunton has a zero-tolerance approach to bribery. Please refer to the Anti-Bribery and Corruption
Policy.
4. Business Mileage
Employees are entitled to claim mileage to and from a temporary place of work. A temporary workplace
is a location that you visit on an ad-hoc basis and is different from your main place of work. Mileage to
your permanent place of work should not be claimed and would be subject to tax and national
insurance.
Mileage reimbursement rates
The latest mileage reimbursement rates as at 1st March 2023 are as follows and are subject to change in
line with HMRC advisory rates which are usually reviewed every 3 months.
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Non Company Car Drivers – privately owned/leased vehicles
Rate per mile for first 10,000
miles in tax year
Rate per mile for over 10,000
miles in tax year
Car Allowance (paid by Dunton
through payroll)
30p 25p
No Company Car or Car
Allowance
45p 25p
Company Car Drivers – cars owned and provided by the company
Engine Size Petrol – rate per mile LPG – rate per mile
1400cc or less 13p 10p
1401cc to 2000cc 15p 11p
Over 2000cc 23p 17p
Engine Size Diesel – rate per mile
1400cc or less 13p
1401cc to 2000cc 15p
Over 2000cc 20p
The advisory electricity rate for fully electric cars is 9p per mile, whilst Hybrid vehicles are reimbursed in
line with the fuel type of the vehicle.
Company vans should have fuel cards provided for business use and therefore no mileage expenses are
claimable. Pick-up Trucks are viewed as Commercial Vehicles by HMRC and therefore a rate of 25p per
mile is allowable.
You must be insured for using your car for business purposes.
All vans and vehicles must be kept in a road worthy condition and maintained in accordance with the
manufacturer’s requirements.
Fuel Cards
Fuel cards will only be issued to those requiring a van. Fuel cards must be used if they have been
issued to you. They can only cover fuel and oil and they must not cover any other expenses.
Fuel cards are not for personal use, and you must only use your own fuel card for the assigned vehicle.
All users should complete a monthly mileage log, and these will be regularly audited.
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5. Other Allowable Expenses
Mobile phones and internet connectivity
Use free wi-fi whenever possible. Reasonable internet connectivity charges may not be added to a
hotel bill unless already part of the negotiated rate or approved by a Director.
Air, rail and road travel
All bookings should be made in economy/standard class (unless you can beat the price by booking
early, in which case higher classes are acceptable). If possible, the Administrative team will make
bookings.
Rail Travel
You should always travel standard class except where there is an over-riding business need but must
obtain a Director’s approval before booking a first-class ticket.
Where possible, you should take advantage of:
• Cheap-day return tickets/cheap single one-way tickets there and back
• Restricted travel options (off peak hours)
• Booking as far ahead in advance as possible.
Car Expenses
The employee can claim parking fees incurred during company business if it could not be avoided
and with approval from their line manager. Car park costs cannot be claimed if it relates to your
permanent place of work.
Fines for parking and traffic offences will not be reimbursed.
You should give careful thought to the total cost of car journeys, e.g. parking, using long-term
parking over short-term where appropriate and congestion charges should be avoided.
London Congestion Charges and Dartford Crossing
If unavoidable and only by prior arrangement with your line manager, these charges should be
booked in advance of your journey with the administrative department, who will register your
vehicle and pay the charge on your behalf.
Unplanned and unavoidable last-minute use should be reported immediately to the administrative
team to avoid any penalty charges being incurred.
Toll Roads
Toll roads should only be used where sensible and cost effective and should not be used as a matter
of course.
Sundry car expenses
Sundry car expenses cannot be claimed where an employee is in their own vehicle or the employee’s
vehicle is funded through a company car allowance benefit. If in doubt you should seek
authorisation before incurring an expense.
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Eye Tests & Glasses (solely for VDU use)
The cost of an eye test may be claimed once every two years if the claimant is a display screen
equipment user (DSE) or a plant driver/operator. Proof of eye test should be provided including the
opticians stamp and a maximum claim of £20 will be reimbursed.
If glasses are solely for VDU use (must be verified by an optician’s stamp) the company will
contribute a maximum of £50 towards the cost of the glasses.
Taxis
Always try to use public transport instead of taxis (unless you are in an unsafe area).
Always keep a receipt that includes the date. You can’t claim trips from work to home unless there is
Director prior agreement.
6. Accommodation
Employees are allowed to book overnight accommodation where their business related round trip is
in excess of 6 hours, i.e., 3 hours each way.
The booking of accommodation will typically be made for you at the nearest Premier Inn or Travel
Lodge to your location.
Any additional charges that may be incurred, such as WI-FI, must be agreed in advance by the
employee’s line manager.
Book hotels through Administration. You are responsible for all hotel cancellations unless it could
not be avoided. The Administration team will endeavor to book on-site parking.
Always inform your line manager and/or colleagues of your overnight location so we can comply
with Duty of Care requirements.
7. Food and Entertainment
Meals & Subsistence
Breakfast (after overnight stay) Breakfast may be claimed following overnight
accommodation at same hotel – Maximum claim of £10
Breakfast may be claimed at a restaurant that is not at
the overnight accommodation hotel – Maximum claim
of £6
Refreshments (journey over 2 hrs) Refreshments may be claimed while travelling on
business to and from temporary workplaces where the
journey time is two hours or more. Maximum claim of
£3 per journey with a maximum of two claims per day.
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Working lunch (for meetings only) Lunch at your normal place of work or anywhere else
cannot be claimed even if on business. Only costs for
food purchased for a working lunch for a meeting can be
claimed where the following criteria have been met: •
Basic lunch items only were provided e.g. sandwiches •
There was no opportunity for any person to
obtain/purchase their own personal lunch prior to the
meeting • The meeting attendees continued working
through the lunch The names of all attendees must be
detailed with the receipt and attached to the claim
Dinner (before overnight stay) An evening meal may be claimed when staying
overnight while working at a temporary workplace.
Maximum claim of £30 including drinks with meal, tips
and room service charges (50% of total cost must be for
food). Additional drinks cannot be claimed.
Dinner (return home after 9pm) An evening meal may be claimed after working at
temporary workplace and arriving home later than 9pm.
Maximum claim of £20.
Client meals/Entertainment
Business entertaining costs need to be reasonable in the circumstances and in keeping with the
strength of the guests’ relationship with the company. Any item above £100 will need to be
authorised by the relevant Director prior to the expense being incurred.
Claims for business entertaining may include those for:
• Customers or potential customers.
• Suppliers and external contacts.
• All company employees that are present during the entertaining.
You must state the name and company of all attendees on the expense form and Dunton’s Anti-Bribery
and Corruption policy must be considered.
8. Other
Professional Subscriptions
The membership fees of one professional body will be refunded provided the membership is job
related.
9. Exceptions
There may be a business reason to claim for something not included in the policy. The business
reason should be explained and agreed by a Director prior to any claim.
10. Submission or Authorisation
All expense claims MUST be:
Submitted by the person making the claim and signed by their line manager by the 8th of the month.
Accompanied by all relevant VAT receipts and copies kept and numbered accordingly.
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Authorised by a Director in advance of any expenditure being incurred where it is expected to be in
excess of £500.
By submitting and authorising the claim, the claimant and the line manager accepts that the
expenditure is:
• Necessary
• Solely for business purposes
• Reasonable and represents value for money, and
• Meets the company’s expenses policy.
All claims should be correctly and fully completed.
Sole accountability for validating the expense claims and checking that all claims are in line with the
policy rests with the claimant and the authorised signatory. Any exceptions to the policy must be
authorised at Director level.
Expenses will be reimbursed by the Finance Department direct to the individuals bank account by the
end of the month.
Employee Loan Policy
1. Purpose
This policy outlines the guidelines and procedures for granting loans to employees of
Dunton. The aim is to provide financial assistance to employees while ensuring
responsible lending practices that align with the company’s financial policies.
2. Scope
This policy applies to all full-time and part-time employees who have completed their
probation period at Dunton. This policy does not form part of any contract of
employment or other contract to provide services, and we may amend it at any time.
3. Policy Guidelines
3.1 Eligibility
• All full-time and part-time employees who have successfully completed their
probation period are eligible to apply for a loan.
• The employee must have a valid reason for the loan, such as medical
expenses, educational expenses, or unforeseen emergencies.
3.2 Loan Amount
• The maximum loan amount an employee can request is 1.5 times their net
monthly salary.
• The net salary is defined as the employee’s monthly salary after all deductions
(taxes, national insurance, etc.).
3.3 Application Process
• Employees must submit a loan application form to the Human Resources (HR)
department, detailing the reason for the loan and the amount requested.
• The application must be supported by necessary documentation (e.g., medical
bills, tuition fees, etc.).
3.4 Approval Process
• The HR department will review the application and verify the employee’s
eligibility and the documentation provided.
• The application will then be forwarded to the Finance department for budget
review and approval.
• Final approval must be obtained from the HR Director and the Chief Financial
Officer (CFO).
3.5 Repayment Terms
• Loan repayment will be through automatic payroll deductions.
• The repayment period will be mutually agreed upon between the employee and
the HR department.
• The repayment amount will be deducted from the employee’s monthly salary.
3.6 Interest Rates
• The loan will be interest-free.
3.7 Conditions and Restrictions
• An employee cannot apply for a new loan until the existing loan is fully repaid.
• If an employee resigns or is terminated, the outstanding loan balance will be
deducted from their final salary.
• The company reserves the right to deny a loan application based on financial
constraints or if the loan purpose does not meet the policy criteria.
3.8 Confidentiality
• All loan applications and related documentation will be treated with the highest
level of confidentiality.
Policy Review
This policy will be reviewed annually and updated as necessary.
Implementation
The HR and Finance departments are responsible for implementing and monitoring
compliance with this policy.
Contact
For questions or further information regarding this policy, please contact the HR
department at samual.gellion@duntonenvironmental.co.uk.
Approval and Effective Date:
This policy is approved by James Hill, CSO and Neil Roe, CEO, and is effective from
01/07/2024:
Signatures:
Neil Roe, CEO,
…………………………………………………….
James Hill, CSO
…………………………………………………….
Equal Opportunities Policy
1. Equal opportunities statement
Dunton is committed to promoting equal opportunities in employment. You and any
job applicants will receive equal treatment regardless of age, disability, gender
reassignment, marital or civil partner status, pregnancy or maternity, race, colour,
nationality, ethnic or national origin, religion or belief, sex or sexual orientation
(Protected Characteristics).
2. About this policy
2.1 This policy sets out our approach to equal opportunities and the avoidance of
discrimination at work. It applies to all aspects of employment with us,
including recruitment, pay and conditions, training, appraisals, promotion,
conduct at work, disciplinary and grievance procedures, and termination of
employment.
2.2 Dunton is responsible for this policy and any necessary training on equal
opportunities.
2.3 This Policy applies to all employees, apprentices, consultants, officers,
contractors, interns, volunteers, job applicants, and agency and casual
workers.
2.4 This policy does not form part of any employee’s contract of employment, and
we may amend it at any time.
3. Equality and Diversity
3.1 ‘Equality’ requires us, and you, to treat everyone equally and fairly, with equal
opportunities and rights.
3.2 ‘Diversity’ recognises that this world is full of differences. We should note,
value and positively embrace these differences. It is important for differences
to be recognised. But it is equally important that, whilst recognising them,
each and every person does so positively, with the importance of equality at
the forefront of their minds.
4. Discrimination
4.1 You must not unlawfully discriminate against or harass other people including
current and former employees, job applicants, clients, customers, suppliers
and visitors. This applies in the workplace, outside the workplace (when
dealing with customers, suppliers or other work-related contacts), and on
work-related trips or events including social events.
4.2 The following forms of discrimination are prohibited under this policy and are
unlawful:
4.2.1 Direct discrimination: treating someone less favourably because
of a Protected Characteristic. For example, rejecting a job applicant
because of their religious views or because they might be gay.
4.2.2 Indirect discrimination: a provision, criterion or practice that
applies to everyone but adversely affects people with a particular
Protected Characteristic more than others and is not justified. For
example, requiring a job to be done full-time rather than part-time
would adversely affect women because they generally have greater
childcare commitments than men. Such a requirement would be
discriminatory unless it can be justified.
4.2.3 Harassment: this includes sexual harassment and other unwanted
conduct related to a Protected Characteristic, which has the
purpose or effect of violating someone’s dignity or creating an
intimidating, hostile, degrading, humiliating or offensive environment
for them. Harassment is dealt with further in our Anti-Bullying and
Harassment Policy.
4.2.4 Victimisation: retaliation against someone who has complained or
has supported someone else’s complaint about discrimination or
harassment.
4.2.5 Disability discrimination: this includes direct and indirect
discrimination, any unjustified less favourable treatment because of
the effects of a disability, and failure to make reasonable
adjustments to alleviate disadvantages caused by a disability.
4.3 There are other actions which can be unlawful under equal opportunities
legislation which apply specifically to disability:
4.3.1 Failure to make reasonable adjustments to minimize certain
disadvantages suffered by a disabled employee (or job applicant).
4.3.2 Treating someone less favorably because of something arising from
their disability (rather than the disability itself) without a good reason
which justifies that treatment.
5. Recruitment and selection
5.1 Recruitment, promotion and other selection exercises such as redundancy
selection will be conducted on the basis of merit, against objective criteria that
avoid discrimination. Shortlisting should be done by more than one person if
possible.
5.2 Vacancies should generally be advertised to a diverse section of the labour
market. Advertisements should avoid stereotyping or using wording that may
discourage particular groups from applying.
5.3 Job applicants should not be asked questions which might suggest an
intention to discriminate on grounds of a Protected Characteristic. For
example, applicants should not be asked whether they are pregnant or
planning to have children.
5.4 Job applicants should not be asked about health or disability before a job offer
is made, except in the very limited circumstances allowed by law: for example,
to check that the applicant could perform an intrinsic part of the job (taking
account of any reasonable adjustments), or to see if any adjustments might
be needed at interview because of a disability. Where necessary, job offers
can be made conditional on a satisfactory medical check. Health or disability
questions may be included in equal opportunities monitoring forms, which
must not be used for selection or decision-making purposes.
5.5 In line with VINCI Group, we are committed to ensuring everyone is treated
with dignity, prohibiting discrimination on any grounds. Group companies
apply a proactive equal opportunities policy focused on gender equality, and
employment of the disabled, people of diverse background and seniors. VINCI
encourages the implementation of this policy and ensure these principles are
applied by management. For more information, please refer to VINCI’s Code
of Ethics and Conduct.
6. Disabilities
If you are disabled or become disabled, we encourage you to tell us about your
condition so that we can consider what reasonable adjustments or support may be
appropriate.
7. Part-time and fixed-term work
Part-time and fixed-term employees should be treated the same as comparable full-
time or permanent employees and enjoy no less favourable terms and conditions (on
a pro-rata basis where appropriate), unless different treatment is justified.
8. Breaches of this policy
8.1 We take a strict approach to breaches of this policy, which will be dealt with in
accordance with our Disciplinary Procedure. Serious cases of deliberate
discrimination may amount to gross misconduct resulting in dismissal.
8.2 If you believe that you have suffered discrimination you can raise the matter
through our Grievance Procedure or Anti-Bullying and Harassment Policy.
Complaints will be treated in confidence and investigated as appropriate.
8.3 You must not be victimised or retaliated against for complaining about
discrimination. However, making a false allegation deliberately and in bad
faith will be treated as misconduct and dealt with under our Disciplinary
Procedure.
Flexible Working Policy
1. About this policy
1.1 This flexible working policy gives eligible employees an opportunity to request
a change to their working pattern.
1.2 We will deal with flexible working requests in a reasonable manner and within
a reasonable time. In any event the time between making a request and
notifying you of a final decision (including the outcome of any appeal) will be
less than two months unless we have agreed a longer period with you.
1.3 This policy does not form part of any employee’s contract of employment, and
we may amend it at any time.
Eligibility
To be eligible to make a flexible working request, you must:
(a) be an employee
(b) not have made two flexible working requests during the last 12
months which includes requests that
(c) Have been withdrawn; and
(d) Not make a request to work flexibility if a request you made
previously has not been concluded.
2. What is a flexible working request?
A flexible working request under this policy means a request to do any or all of the
following:
(a) to reduce or vary your working hours;
(b) to reduce or vary the days or times you work;
(c) to work from a different location (for example, from home).
Making a flexible working request
Your flexible working request should be submitted to Human Resources in writing
and dated. It should:
(a) state that it is a flexible working request.
(b) explain the change being requested and propose a start date; and
(c) state whether you have made any previous flexible working requests.
3. Meeting
3.1 We will arrange a meeting at a convenient time and place to discuss your
request. You may be accompanied at the meeting by a colleague of your
choice or a trade union representative. They will be entitled to speak and
confer privately with you but may not answer questions on your behalf.
3.2 We may decide to grant your request in full without a meeting, in which case
we will write to you with our decision.
4. Decision
4.1 We will inform you in writing of our decision as soon as possible after the
meeting.
4.2 If your request is accepted, we will write to you with details of the new working
arrangements and the date on which they will commence. You will be asked to
sign and return a copy of the letter.
4.3 If we cannot immediately accept your request we may require you to
undertake a trial period before reaching a final decision on your request.
4.4 Unless otherwise agreed, changes to your terms of employment will be
permanent.
4.5 We may reject your request for one or more of the following business
reasons:
(a) the burden of additional costs;
(b) detrimental effect on ability to meet customer demand;
(c) inability to reorganise work among existing staff;
(d) inability to recruit additional staff;
(e) detrimental impact on quality;
(f) detrimental impact on performance;
(g) insufficiency of work during the periods that you propose to work; or
(h) planned structural changes.
4.6 If we are unable to agree to your request, we will write to tell you which of
those reasons applies in your case. We will also set out the appeal procedure.
1. Appeal
1.1 You may appeal in writing within 14 days of receiving our written decision. This
includes a decision following a trial period.
1.2 Your appeal must be dated and must set out the grounds on which you are
appealing.
1.3 We will hold a meeting with you to discuss your appeal. You may bring a
colleague to the meeting.
1.4 We will tell you in writing of our final decision as soon as possible after the
appeal meeting, including reasons. There is no further right of appeal.
Grievance Procedure
1. About this procedure
1.1 Most grievances can be resolved quickly and informally through discussion
with your line manager or Human Resources. If this does not resolve the
problem, you should initiate the formal procedure set out below.
1.2 This procedure applies to all employees regardless of length of service. It
does not apply to agency workers or self-employed contractors.
1.3 This procedure does not form part of any employee’s contract of employment.
It may be amended at any time, and we may depart from it depending on the
circumstances of any case.
2. Step 1: written grievance
2.1 You should put your grievance in writing and submit it to your line manager. If
your grievance concerns your line manager, you may submit it to Human
Resources.
2.2 The written grievance should set out the nature of the complaint, including any
relevant facts, dates, and names of individuals involved so that we can
investigate it.
3. Step 2: meeting
3.1 We will arrange a grievance meeting, normally within one week of receiving
your written grievance. You should make every effort to attend.
3.2 You may bring a companion to the grievance meeting if you make a
reasonable request in advance and tell us the name of your chosen
companion. The companion may be either a trade union representative or a
colleague, who will be allowed reasonable paid time off from duties to act as
your companion.
3.3 If you or your companion cannot attend at the time specified you should let us
know as soon as possible and we will try, within reason, to agree an
alternative time.
3.4 We may adjourn the meeting if we need to carry out further investigations,
after which the meeting will usually be reconvened.
3.5 We will write to you, usually within one week of the last grievance meeting, to
confirm our decision and notify you of any further action that we intend to take
to resolve the grievance. We will also advise you of your right of appeal.
4. Step 3: appeals
4.1 If the grievance has not been resolved to your satisfaction you may appeal in
writing to The Chief Strategy Officer, HR Director stating your full grounds of
appeal, within one week of the date on which the decision was sent or given
to you.
4.2 We will hold an appeal meeting, normally within two weeks of receiving the
appeal. This will be dealt with impartially by a manager who has not
previously been involved in the case. You will have a right to bring a
companion (see paragraph 3.2).
4.3 We will confirm our final decision in writing, usually within one week of the
appeal hearing. There is no further right of appeal.
Holidays Policy
1. About this policy
1.1 This policy sets out our arrangements for staff wishing to take holidays (also
known as annual leave).
1.2 This policy covers all employees at all levels and grades, including full-time,
part-time, permanent and fixed-term employees, managers, directors,
trainees, and homeworkers.
1.3 This policy does not form part of any employee’s contract of employment, and
we may amend it at any time. We may also vary the policy as appropriate in
any case.
2. Your holiday entitlement
2.1 The company’s holiday year runs from 1 April to 31 March. If your employment
starts or finishes part way through the holiday year, your holiday entitlement
during that year shall be calculated on a pro-rata basis rounded up to the
nearest half day.
2.2 Unless otherwise set out in your employment contract, you are entitled to 23
days’ paid holiday in each holiday year, or the pro rata equivalent if you work
part time. In addition, you are entitled to take the usual public holidays in
England and Wales or days in lieu where we require staff to work on a public
holiday. In addition, upon completion of 3 complete years of service from the
start of your employment, your holiday entitlement will increase by 1 day
(calculated on a pro rata basis) with effect from the following holiday year,
upon completion of 4 complete years of service from the start of your
employment it will increase by a further 1 day (calculated on a pro rata basis)
with effect from the following holiday year and upon completion of 5 complete
years of service from the start of your employment it will increase by a further
3 days (calculated on a pro rata basis) with effect from the following holiday
year, until your holiday entitlement is equal to a full-time equivalent
entitlement of 28 days’ holiday.
2.3 Except as set out in this policy, holiday entitlement must be taken during the
holiday year in which it accrues.
2.4 Unused holiday can only be carried over to another holiday year:
2.4.1 in cases involving sickness absence, as set out in paragraph 5;
2.4.2 in cases of maternity, paternity, adoption, parental or shared
parental leave, as set out in paragraph 6;
2.4.3 if otherwise required by law.
2.4.4 If approved by the departmental director, the HR Director and the
CEO in advance.
3. Taking holiday
3.1 All leave must be pre-authorised by the Line Manager and Department
Director and if the request is for more than 10 consecutive working days,
additional approval is required by the Director-HR Director-CEO. You must not
make travel bookings until approval has been given. Taking leave without
authorisation or following a declined request is not allowed, and may be
considered as gross misconduct and will be dealt with in accordance with the
Companies Policy.
3.2 The purpose of this policy is to ensure continuity of operations during staff
leave and clear communication of intended leave so it can be coordinated
with due consideration of operational needs and other staff that may already
be booked on leave during the same period.
3.3 We may require you to take (or not to take) holiday on particular dates,
including when the business is closed, particularly Christmas, (we will ask you
to use a minimum of 3 days, up to 8 days of your holiday entitlement, which
will be deducted from your leave) or during your notice period.
4. Sickness during periods of holiday
4.1 If you are sick or injured during a holiday period and would have been
incapable of work, you may choose to treat the period of incapacity as sick
leave and reclaim the affected days of holiday.
4.2 Employees already on sick leave before a pre-arranged period of holiday may
choose to cancel any days of holiday that coincide with the period of
incapacity and treat them as sick leave.
4.3 Dishonest claims or other abuse of this policy will be treated as misconduct
under our disciplinary procedure.
5. Long-term sickness absence and holiday entitlement
5.1 Holiday entitlement continues to accrue during periods of sick leave.
5.2 If you are on a period of sick leave which spans two holiday years, or if you
return to work after sick leave so close to the end of the holiday year that you
cannot reasonably take your remaining holiday, you may carry over unused
holiday to the following leave year.
5.3 Any holiday that is carried over under this rule but is not taken within 18
months of the end of the holiday year in which it accrued will be lost.
5.4 Alternatively, you can choose to take your paid holiday during your sick leave,
in which case you will be paid at your normal rate.
6. Family leave and holiday entitlement
6.1 Holiday entitlement continues to accrue during periods of maternity, paternity,
adoption, parental or shared parental leave (referred to collectively in this
policy as family leave).
6.2 If you are planning a period of family leave that is likely to last beyond the end
of the holiday year, you should discuss your holiday plans with your manager
in good time before starting your family leave. Any holiday entitlement for the
year that cannot reasonably be taken before starting your family leave can be
carried over to the next holiday year.
6.3 For the avoidance of doubt this covers your full holiday entitlement.
6.4 Any holiday carried over should be taken immediately before returning to work
or within three months of returning to work after the family leave.
7. Arrangements on termination
7.1 On termination of employment, you may be required to use any remaining
holiday entitlement during your notice period. Alternatively, you will be paid in
lieu of any accrued but untaken holiday entitlement for the current holiday
year to date, plus any holiday permitted to be carried over from previous years
under this policy or as required by law. You are entitled to be paid at a rate of
1/260th of your full-time equivalent basic salary for each day of untaken
entitlement.
IT and Communications Systems Policy
1. About this policy
1.1 Our IT and communications systems are intended to promote effective
communication and working practices. This policy outlines the standards you
must observe when using these systems, when we will monitor their use, and
the action we will take if you breach these standards.
1.2 Human Resources has overall responsibility for this policy, including keeping it
under review.
1.3 This policy will also be reviewed by the Digital Systems Integration Manager.
1.4 This policy is in compliance with SFIT.
1.5 Breach of this policy may be dealt with under our Disciplinary Procedure and,
in serious cases, may be treated as gross misconduct leading to summary
dismissal.
1.6 This policy does not form part of any employee’s contract of employment and
we may amend it at any time.
2. Equipment security and passwords
2.1 You are responsible for the security of the equipment allocated to or used by
you, and you must not allow it to be used by anyone other than in accordance
with this policy. You should use passwords on all IT equipment, particularly
items that you take out of the office. You should keep your passwords
confidential and change them regularly.
2.2 You must only log on to our systems using your own username and password.
You must not use another person’s username and password or allow anyone
else to log on using your username and password.
2.3 If you are away from your desk, you should log out or lock your computer. You
must log out and shut down your computer at the end of each working day.
3. Systems and data security
3.1 You should not delete, destroy or modify existing systems, programs,
information or data (except as authorised in the proper performance of your
duties).
3.2 You must not download or install software from external sources without
authorisation from the Digital Systems Integration Manager. Downloading
unauthorised software may interfere with our systems and may introduce
viruses or other malware.
3.3 You must not attach any device or equipment including mobile phones, tablet
computers or USB storage devices to our systems without authorisation from
IT.
3.4 We monitor all e-mails passing through our system for viruses. You should
exercise particular caution when opening unsolicited e-mails from unknown
sources. If an e-mail looks suspicious do not reply to it, open any attachments
or click any links in it.
3.5 Inform the Digital Systems Integration Manager immediately if you suspect
your computer may have a virus.
4. Mandatory Training
4.1 All staff who are issued with a company laptop and online account must
complete mandatory online courses during their employment. For all new
starters, you must complete these courses on your start date unless you are
unable to do so. In this circumstance, you must complete these courses either
by the end of your first week of employment or the nearest possible date.
4.2 These courses are mandatory and include:
4.2.1 Cyber Security
4.2.2 Human Rights
4.2.3 Anti-Corruption
4.2.4 Conflict of Interest.
4.3 Throughout the course of your employment, these courses may need to be re-
completed, or new mandatory courses will be released from SFIT. In these
circumstances, Human Resources will communicate with you which new or
outstanding courses must be completed.
4.4 Failure to complete these courses will result in your account being locked and
inaccessible. In this circumstance, SFIT will reactivate your account
temporarily for the completion of the mandatory courses.
5. E-mail
5.1 Dunton adopts a standard signature which all staff members with corporate
email accounts must use. Updated versions of this signature will be
communicated by the Digital Systems Integration Manager.
5.2 Adopt a professional tone and observe appropriate etiquette when
communicating with third parties by e-mail.
5.3 Remember that e-mails can be used in legal proceedings and that even
deleted e-mails may remain on the system and be capable of being retrieved.
5.4 You must not send abusive, obscene, discriminatory, racist, harassing,
derogatory, defamatory, pornographic or otherwise inappropriate e-mails.
5.5 You should not:
5.5.1 send or forward private e-mails at work which you would not want a
third party to read;
5.5.2 send or forward chain mail, junk mail, cartoons, jokes or gossip;
5.5.3 contribute to system congestion by sending trivial messages or
unnecessarily copying or forwarding e-mails to others who do not
have a real need to receive them; or
5.5.4 send messages from another person’s e-mail address (unless
authorised) or under an assumed name.
5.6 Do not use your own personal e-mail account to send or receive e-mail for the
purposes of our business. Only use the e-mail account we have provided for
you.
6. Using the internet
6.1 Internet access is provided solely for business purposes. Occasional personal
use may be permitted as set out in paragraph 7
6.2 You should not access any web page or download any image or other file
from the internet which could be regarded as illegal, offensive, in bad taste or
immoral. Even web content that is legal in the UK may be in sufficient bad
taste to fall within this prohibition. As a general rule, if any person (whether
intended to view the page or not) might be offended by the contents of a
page, or if the fact that our software has accessed the page or file might be a
source of embarrassment if made public, then viewing it will be a breach of
this policy.
6.3 We may block or restrict access to some websites at our discretion.
7. Personal use of our systems
7.1 We permit the incidental use of our systems to send personal e-mail, browse
the internet and make personal telephone calls subject to certain conditions.
Personal use is a privilege and not a right. It must not be overused or abused.
We may withdraw permission for it at any time or restrict access at our
discretion.
7.2 Personal use must meet the following conditions:
7.2.1 it must be minimal and take place exclusively outside of normal
working hours (that is, during your lunch break, and before or after
work);
7.2.2 personal e-mails should be labelled “personal” in the subject
header;
7.2.3 it must not affect your work or interfere with the business;
7.2.4 it must not commit us to any marginal costs; and
7.2.5 it must comply with our policies including the Equal Opportunities
Policy, Anti-harassment, Anti-Bullying Policy, Data Protection Policy
and Disciplinary Procedure.
8. Monitoring
8.1 Our systems enable us to monitor telephone, e-mail, voicemail, internet and
other communications. For business reasons, and in order to carry out legal
obligations in our role as an employer, your use of our systems including the
telephone and computer systems (including any personal use) may be
continually monitored by automated software or otherwise.
8.2 We reserve the right to retrieve the contents of e-mail messages or check
internet usage (including pages visited and searches made) as reasonably
necessary in the interests of the business, including for the following purposes
(this list is not exhaustive):
8.2.1 to monitor whether the use of the e-mail system or the internet is
legitimate and in accordance with this policy;
8.2.2 to find lost messages or to retrieve messages lost due to computer
failure;
8.2.3 to assist in the investigation of alleged wrongdoing; or
8.2.4 to comply with any legal obligation.
8.2.5 to access any leaver’s emails, usually by the leaver’s line manager,
and approved by the DPO. This will access right will be subject to
limited access (not more than 60 days) and must not be used by
those granted access to view personal emails.
9. Prohibited use of our systems
9.1 Misuse or excessive personal use of our telephone or e-mail system or
inappropriate internet use will be dealt with under our Disciplinary Procedure.
Misuse of the internet can in some cases be a criminal offence.
9.2 Creating, viewing, accessing, transmitting or downloading any of the following
material will usually amount to gross misconduct (this list is not exhaustive):
9.2.1 pornographic material (that is, writing, pictures, films and video clips
of a sexually explicit or arousing nature);
9.2.2 offensive, obscene, or criminal material or material which is liable to
cause embarrassment to us or to our clients;
9.2.3 a false and defamatory statement about any person or organisation;
9.2.4 material which is discriminatory, offensive, derogatory or may cause
embarrassment to others (including material which breaches our
Equal Opportunities Policy or our Anti-harassment and Bullying
Policy);
9.2.5 confidential information about us or any of our staff or clients
(except as authorised in the proper performance of your duties);
9.2.6 unauthorised software;
9.2.7 any other statement which is likely to create any criminal or civil
liability (for you or us); or
9.2.8 music or video files or other material in breach of copyright.
Maternity Policy
1. About this policy
1.1 This policy outlines the statutory rights and responsibilities of employees who
are pregnant or have recently given birth and sets out the arrangements for
pregnancy-related sickness, health and safety, and maternity leave.
1.2 Arrangements for time off for antenatal care and to accompany a pregnant
woman to antenatal appointments are set out in our Time off for Antenatal
Appointments Policy.
1.3 In some cases, you and your spouse or partner may be eligible to opt into the
shared parental leave (SPL) scheme which gives you more flexibility to share
the leave and pay available in the first year. You will need to give us at least
eight weeks’ notice to opt into SPL, and you must remain on maternity leave
until at least two weeks after birth. For information about SPL, see our Shared
Parental Leave (Birth) Policy.
1.4 This policy only applies to employees and does not apply to agency workers
or self-employed contractors. This policy does not form part of any employee’s
contract of employment, and we may amend it at any time.
1.5 Under The Maternity Leave, Adoption Leave and Shared Parental Leave
(Amendment) Regulations 2024, pregnant workers who have informed us of
their pregnancy after 6th April 2024, will also be automatically entitled to be
given a suitable alternative role if made redundant.
1.6 If a miscarriage occurs before the 24th week of pregnancy, the protection
stated above (1.5), will continue for a period of two weeks. If a miscarriage
occurs after the 24th week, then the rules that apply in a maternity leave
situation will apply.
2. Entitlement to maternity leave
All employees are entitled to up to 52 weeks’ maternity leave, consisting of 26
weeks’ ordinary maternity leave (OML) and 26 weeks’ additional maternity leave
(AML).
3. Notification
3.1 Please inform us as soon as possible that you are pregnant. This is important
as there may be health and safety considerations.
3.2 Before the end of the fifteenth week before the week that you expect to give
birth (Qualifying Week), or as soon as reasonably practical afterwards, you
must tell us:
3.2.1 the week in which your doctor or midwife expects you to give birth
(Expected Week of Childbirth); and
3.2.2 the date on which you would like to start your maternity leave
(Intended Start Date).
3.3 We will write to you within 28 days to tell you the date we will expect you to
return to work if you take your full maternity leave entitlement (Expected
Return Date).
3.4 Once you receive a certificate from a doctor or midwife confirming your
Expected Week of Childbirth (MATB1), you must provide us with a copy.
4. Starting maternity leave
4.1 The earliest you can start maternity leave is 11 weeks before the Expected
Week of Childbirth (unless your child is born prematurely before that date).
4.2 If you want to change your Intended Start Date, please tell us in writing. You
should give us as much notice as you can, but wherever possible you must
tell us at least 28 days before the original Intended Start Date (or the new
start date if you are bringing the date forward). We will then write to you within
28 days to tell you your new expected return date.
4.3 Your maternity leave should normally start on the Intended Start Date.
However, it may start earlier if you give birth before your Intended Start Date,
or if you are absent for a pregnancy-related reason in the last four weeks
before your Expected Week of Childbirth. In either of those cases, maternity
leave will start on the following day.
4.4 Shortly before your maternity leave is due to start we will discuss with you the
arrangements for covering your work and the opportunities for you to remain
in contact, should you wish to do so, during your leave. Unless you request
otherwise, you will remain on circulation lists for internal news, job vacancies,
training and work-related social events.
4.5 The law says that we cannot allow you to work during the two weeks following
childbirth.
5. Maternity pay
5.1 Statutory maternity pay (SMP) is payable for up to 39 weeks provided you
have at least 26 weeks’ continuous employment with us at the end of the
Qualifying Week and your average earnings are not less than the lower
earnings limit set by the government each tax year. The first six weeks SMP
are paid at 90% of your average earnings and the remaining 33 weeks are at
a rate set by the government each year.
5.2 You will qualify for company maternity pay if you have been continuously
employed during the 26 week period ending with the Qualifying Week and
have not received any company maternity pay from our employment during
the 12 month period ending with the Qualifying Week. This is paid at the rate
of your normal basic salary during maternity leave for up to 14 weeks and
includes any SMP that may be due for that period.
6. During maternity leave
6.1 With the exception of terms relating to pay, your terms and conditions of
employment remain in force during OML and AML.
6.2 Holiday entitlement will continue to accrue during maternity leave. If your
maternity leave will continue into the next holiday year, any holiday
entitlement that cannot reasonably be taken before starting your maternity
leave can be carried over and must be taken within three months of returning
to work unless your manager agrees otherwise. Please discuss your holiday
plans with your manager in good time before starting your maternity leave. All
holiday dates are subject to approval by your manager.
6.3 If you are a member of the pension scheme, we shall make employer pension
contributions during OML and any period of paid AML, based on your normal
salary, in accordance with the pension scheme rules. Any employee
contributions you make will be based on the amount of any maternity pay you
are receiving, unless you inform Payroll that you wish to make up any
shortfall.
7. Keeping in touch
7.1 We may make reasonable contact with you from time to time during your
maternity leave although we will keep this to a minimum. This may include
contacting you to discuss arrangements for your return to work.
7.2 You may work (including attending training) on up to ten “keeping-in-touch”
days during your maternity leave. This is not compulsory and must be
discussed and agreed with your line manager.
7.3 You will be paid at your normal basic rate of pay for time spent working on a
keeping-in-touch day and this will be inclusive of any maternity pay
entitlement.
8. Returning to work
8.1 You must return to work on the Expected Return Date unless you tell us
otherwise. If you wish to return to work earlier than the Expected Return Date,
you must give us eight weeks’ prior notice of the date. It is helpful if you give
this notice in writing. You may be able to return later than the Expected Return
Date if you request annual leave or parental leave, which will be at our
discretion.
8.2 You are normally entitled to return to work in the position you held before
starting maternity leave, and on the same terms of employment. However, if
you have taken AML and it is not reasonably practicable for us to allow you to
return into the same position, we may give you another suitable and
appropriate job on terms and conditions that are not less favourable.
8.3 As per the Maternity Leave, Adoption Leave and Shared Parental Leave
(Amendment) Regulations 2024, in the case of redundancy, employees on
maternity leave are statutorily entitled to be automatically given a suitable
alternative role over other employees.
8.4 The protection stated above (clause 8.3) will continue for a period of 18
months from either the first day of the estimated week of childbirth, or the date
of birth (if communicated to the employer before the end of the maternity
period).
8.5 If you want to change your hours or other working arrangements on return
from maternity leave you should make a request under our Flexible Working
Policy. It is helpful if such requests are made as early as possible.
8.6 If you decide you do not want to return to work, you should give notice of
resignation in accordance with your contract.
Menopause Policy
1. Policy Statement
Dunton is committed to providing an inclusive and supportive working environment
for all its employees. This policy sets out our guidelines and approach for providing
support to employees experiencing menopause, and to continue working
comfortably and productively.
The policy is intended as a support guide for all workers. All stakeholders agree
to work proactively to make adjustments where necessary to support women
experiencing the menopause and to ensure the workplace does not make their
symptoms worse.
2. Purpose
This policy applies to all employees of Dunton, regardless of their position or status
within the organization. It recognizes that menopause can affect individuals in
different ways and aims to provide appropriate support for those experiencing
menopausal symptoms.
It should be noted that people from the non-binary, transgender and intersex
communities may also experience menopausal systems. Due to a variety of
factors, the experience of the menopause may differ for those among these
communities. Although the policy refers to women, please consider that ‘people
who menstruate’ also require consideration.
It is imperative that employees who require additional support during this time are
treated with understanding, dignity and respect.
3. Objectives
3.1 To raise awareness and understanding of menopause and its impact on
employees, both management and non-management.
3.2 To create a supportive work environment where women can feel confident in
raising issues about their symptoms and seek reasonable adjustments and
additional support at work.
3.3 To provide guidance and support to employees and managers on managing
menopause-related issues in the workplace.
3.4 To reduce the stigma and ensure an open and respectful dialogue about
menopause.
4. Definitions
4.1 Perimenopause
The perimenopause is the period in a woman’s life when she starts to experience
hormonal fluctuations and changes to her periods. The average time for a woman to
be perimenopausal is between four to five years. During this time, periods may
become increasingly heavy and irregular, it is therefore important for a woman
experiencing symptoms to be close to toilet facilities. For some women, symptoms
during this time can be worse than the actual menopause.
4.2 Menopause
The menopause is a natural part of every woman’s life, marking the end of her
reproductive cycle. A woman is described as being menopausal once experiencing
12 months without periods and when the ovaries are no longer responsive.
Menopause typically occurs in women between the ages of 45 and 55 years old.
The average age for a woman to reach the menopause in the UK is 51.
4.3 Post Menopausal
The time after menopause has occurred, starting when a woman has not had a period
for 12 consecutive months. The average time for women experiencing symptoms of
the menopause is five years, but many women experience symptoms for up to ten
years, with some women experiencing symptoms for the rest of their lives.
Postmenopausal women have an increased risk of heart disease, diabetes and
osteoporosis and managers should be aware of this.
5. Workplace Support
5.1 The policy recognises that there are many workplace factors which can make
working life more difficult for women experiencing the menopause and which
may make symptoms worse. It recognises that menopause is a personal
experience, therefore individual adjustments and support may be needed. Line
managers should seek to provide appropriate support and adjustments when
needed to help women deal with issues arising from the menopause.
5.2 It is recognised that employees have a responsibility for their health, safety and
welfare but that workplace demands can complicate this. Simple changes to
someone’s role or working environment can help ensure the menopause does
not become a barrier to performance. Employees can expect such things as:
5.2.1 Flexible Working Arrangements including, but not limited to
flexible working hours or remote working arrangements.
5.2.2 Physical Workplace Adjustments, including the provision of fans
or temperature control, rest areas or private spaces, and availability
of sanitary products in lavatories.
5.2.3 Workload Management: Adjustments to workload or duties may be
considered to accommodate employees experiencing severe
symptoms.
5.2.4 Wellbeing facilities such as our Employee Assistance Programme
which provides free, confidential 24/7 calling services.
5.3 Risk Assessments
Risk assessments should consider the specific needs of menopausal women and
ensure that the working environment will not make their symptoms worse. Often,
making simple changes to the working environment can help to alleviate the impact of
some symptoms.
A risk assessment should look at issues such as:
a) Temperature and ventilation
b) The materials used in any uniform or corporate clothing.
c) Access to toilet facilities and access to cold water.
6. Responsibilities and Support
Management will take responsibility to ensure awareness and understanding of our
menopause policy, ensuring that staff foster an inclusive and supportive workplace
environment. Management will identify any extra support a person experiencing
menopause may benefit from.
All employees are to take an active role in managing their health and wellbeing. You
must communicate with your manager, Health and Safety, or HR if you need any
further support or adjustments.
Exclusionary or discriminatory practices will not be tolerated, and for more details
see our grievance and disciplinary procedure.
7. Training and Awareness
We will provide regular training for managers and employees on menopause
awareness and the support strategies we offer.
8. Confidentiality
All discussions and disclosures about menopause will be treated with the utmost
confidentiality. Information will only be shared with relevant parties on a need-to-
know basis and with the consent of the employee.
Modern Slavery Policy
Purpose
This policy outlines Dunton’s commitment to preventing modern slavery, human
trafficking, forced labour, and related human rights violations in our operations and
supply chains. We align our approach with the VINCI Group’s principles and ethical
standards. For more information, please refer to VINCI’s Modern Slavery and Human
Trafficking Statement.
Scope
This policy applies to all employees, contractors, suppliers, and business partners
engaged in Dunton’s operations in compliance with the Modern Slavery Act 2015.
1. Commitment
1.1. Dunton is committed to:
1.1.1. Prohibiting forced labour, human trafficking, and any form of
exploitation.
1.1.2. Ensuring fair recruitment practices, including prohibiting recruitment
fees for workers.
1.1.3. Respecting workers’ rights to freedom of movement and prohibiting the
withholding of personal documents.
1.1.4. Adhering to fair wages, safe working conditions, and reasonable
working hours.
1.1.5. Preventing child labour and ensuring compliance with minimum age
regulations.
1.1.6. Providing grievance mechanisms for workers to report any concerns
related to labour practices.
2. Due Diligence and Risk Management
2.1. To mitigate the risk of modern slavery, Dunton will:
2.1.1. Conduct due diligence on suppliers and subcontractors to ensure
compliance with ethical labour standards as per the Modern Slavery Act
2015.
2.1.2. Include contractual clauses prohibiting modern slavery in supplier
agreements.
2.1.3. Perform regular audits and site inspections where necessary.
2.1.4. Require training for relevant employees on identifying and preventing
modern slavery.
3. Reporting and Whistleblowing
Employees and stakeholders are encouraged to report any suspected cases of
modern slavery through our confidential reporting channels. No retaliation will be
taken against individuals who report in good faith. For more details on
whistleblowing, please refer to our Whistleblowing Policy.
4. Compliance and Continuous Improvement
4.1. As part of our commitment to compliance, we will:
4.1.1. Review and update this policy periodically to align with evolving legal
requirements and industry best practices.
4.1.2. Where necessary, collaborate with industry groups, NGOs, and
governmental bodies to enhance our approach to preventing modern
slavery.
Accountability
Failure to comply with this policy may result in disciplinary action, contract
termination, or legal proceedings where applicable.
Neonatal Care Policy
1. About this Policy
1.1 This policy outlines the statutory rights and responsibilities of employees with
parental or other personal relationships with a child who is to receive or has
received neonatal care.
1.2 This policy outlines the arrangements for those eligible to take Neonatal Care
Leave (NCL) and Neonatal Care Pay (NCP). The policy ensures that parents
whose newborns require neonatal care receive appropriate support through
leave and pay provisions.
1.3 This policy only applies to employees and does not apply to agency workers
or self-employed contractors. This policy does not form part of any employee’s
contract of employment, and we may amend it at any time.
1.4 The Neonatal Care (Leave and Pay) Act 2023 provides employees with a new
statutory right entitling them to take a period of leave of absence when their
baby requires neonatal care. This law will be enforced as of 1st April 2025.
2. Eligibility
2.1 To be eligible to receive neonatal leave, the following must apply:
2.1.1 You must be an employee with a parental or significant personal
relationship to a child receiving neonatal care.
2.1.2 The baby is under 28 days old when the care begins.
2.1.3 The neonatal care continues without interruption for a period of at least 7
days beginning with the day after the day on which the care starts.
2.1.4 The baby is born on or after 6th April 2025.
2.2 Neonatal Care Leave (NCL)
2.2.1 The total amount of statutory neonatal leave for eligible employees is
capped at a maximum of 12 weeks.
2.2.2 Leave must be taken in a continuous block of one or more weeks.
2.2.3 The total amount as set out in clause 2.2.1 must be used within 68 weeks
of the birth.
2.2.4 This leave is in addition to other parental leave entitlements such as
maternity, paternity, adoption, parental leave, shared parental leave, and
parental bereavement leave.
3. Neonatal Care Pay (NC)
3.1 Statutory Neonatal Care Pay (NCP) is payable during neo-natal leave
provided you have at least 26 weeks’ continuous employment ending with the
beginning of care.
3.2 The rate of NCP is set by the government each tax year.
4. Leave Commencement and Notice Requirements
4.1 To be entitled to take neonatal care leave, an employee must give the
required notice of their intention to take the leave. The notice should specify:
4.1.1 the date of birth,
4.1.2 the date the child’s neonatal care starts (and, if applicable, when it ended),
4.1.3 the date on which the employee intends to start the period of leave, and
4.1.4 the number of weeks.
4.2 Where it is not reasonably practical to give the appropriate period of notice,
the employee must give notice as soon as is reasonably practicable. Both
parties may agree to waive the notice requirements for entitlement to pay.
5. During Neonatal Leave
5.1 An employee’s period of neonatal care leave begins on the date specified in
the notice in a case where—
5.1.1 the employee notifies their employer of their intention to begin neonatal
care leave on the same day as notice is given to their employer, and they
are already at work on that day.
5.1.2 the employee’s period of neonatal care leave begins on the day after that
day.
5.1.3 In a case where the employee and employer mutually agree to waive the
requirement to give notice in accordance, the employee’s period of
neonatal care leave begins on a day mutually agreed with the employer.
5.2 An employee who takes neonatal care leave is, during any period of leave
entitled to –
5.2.1 the benefit of all the terms and conditions of employment which would
have applied if the employee had not been absent on leave (subject only
to the exception in terms and conditions about remuneration); and
5.2.2 are bound by any obligations arising under those terms and conditions,
subject only to the exception in terms and conditions about remuneration.
6. Returning to Work
6.1 You are normally entitled to return to work in the position you held before
starting neo-natal leave, and on the same terms of employment. However, if
you have taken NCL and it is not reasonably practicable for us to allow you to
return into the same position, we may give you another suitable and
appropriate job on terms and conditions that are not less favourable.
6.2 If you want to change your hours or other working arrangements on return
from NCL you should make a request under our Flexible Working Policy. It is
helpful if such requests are made as early as possible.
6.3 If you decide you do not want to return to work, you should give notice of
resignation in accordance with your contract.
Parental Bereavement Leave Policy
1. About this policy
1.1 This policy sets out the arrangements for parental bereavement leave, which
is a type of compassionate leave intended to help employees deal with the
death of a child or a stillbirth after at least 24 weeks of pregnancy.
1.2 For compassionate leave in other circumstances, please see our
Compassionate Leave Policy.
1.3 This policy does not form part of any employee’s contract of employment and
we may amend it at any time.
2. Entitlement to parental bereavement leave
2.1 You may be entitled to parental bereavement leave if your child or a child in
your care has died or been stillborn after 24 weeks of pregnancy.
2.2 Parental bereavement leave can be one week, two consecutive weeks, or two
separate weeks. It can be taken at any time during the first 56 weeks after the
child’s death.
2.3 Further unpaid compassionate leave may be available under our
Compassionate Leave Policy at our discretion. Please speak to your manager
if you require further time off in addition to parental bereavement leave.
3. Parental bereavement pay
3.1 You may qualify for statutory parental bereavement pay (SPBP) during
parental bereavement leave if:
3.1.1 you have at least 26 weeks’ continuous employment ending on the
Saturday before the child died; and
3.1.2 you earn at least the lower earnings limit for class 1 national
insurance contributions.
3.2 SPBP is only payable in respect of whole weeks of leave, at the same rate as
statutory paternity pay. The rate is set by the government each tax year.
4. Leave in the first eight weeks
4.1 In the first eight weeks after a child has died, there is no need to give advance
notice to take parental bereavement leave. Please notify your line manager as
soon as you can on the day you want your leave to start, preferably before the
time you would normally start work, where possible. Someone can do this on
your behalf if necessary.
4.2 If you have already started work, then your parental bereavement leave
period will start on the following day. We would usually allow you to take the
rest of the day off as compassionate leave.
4.3 You can cancel any planned parental bereavement leave in the first eight
weeks by telling us at any time before the leave starts, and no later than the
time you would normally start work on the first day of the leave period. You
cannot cancel leave once it has started.
5. Leave after more than eight weeks
5.1 To take parental bereavement leave more than eight weeks after the child has
died, please give your line manager at least a week’s written notice.
5.2 Parental bereavement leave can be cancelled with a week’s written notice,
and can be re-booked by giving a week’s written notice.
6. Written confirmation
We will ask you to confirm the following information in writing within 28 days of
starting any period of parental bereavement leave:
6.1.1 your name;
6.1.2 the date the child died or was stillborn;
6.1.3 the dates of paid or unpaid parental bereavement leave taken; and
6.1.4 your relationship to the child.
Parental Leave Policy
1. About this policy
1.1 This policy summarises the statutory right of employees with at least one
year’s continuous service to take up to 18 weeks’ unpaid parental leave in
respect of each child.
1.2 This policy does not form part of any employee’s contract of employment and
we may amend it at any time.
2. Entitlement to parental leave
2.1 To be eligible for parental leave, you must:
2.1.1 have at least one year’s continuous employment with us;
2.1.2 have or expect to have responsibility for a child; and
2.1.3 be taking the leave to spend time with or otherwise care for the
child.
2.2 You have responsibility for a child if you are the biological or adoptive parent
or have legal parental responsibility in some other way, for example under a
court order.
2.3 Eligible employees are entitled to take up to 18 weeks’ parental leave in
relation to each child.
2.4 You must tell us of any parental leave you have taken while working for
another employer as this counts towards your 18-week entitlement.
3. Taking parental leave
3.1 In most cases, parental leave can only be taken in blocks of a week or a
whole number of weeks, and you may not take more than four weeks’ parental
leave a year in relation to each child. Parental leave can be taken up to the
child’s 18th birthday.
3.2 Special rules apply where your child is disabled, which for these purposes
means entitled to a disability living allowance, armed forces independence
allowance or personal independence payment. You can take parental leave in
respect of that child in blocks of less than one week. However, there is still a
limit of 4 weeks a year for each child and 18 weeks in total for each child.
4. Notification requirements
4.1 You must notify your line manager of your intention to take parental leave at
least 21 days in advance. It would be helpful if you can give this notice in
writing. Your notification should include the start and end dates of the
requested period of leave.
4.2 If you wish to start parental leave immediately on the birth of a child, you must
give notice at least 21 days before the expected week of childbirth.
4.3 If you wish to start parental leave immediately on having a child placed with
you for adoption, you should give notice at least 21 days before the expected
week of placement, or if this is not possible, give as much notice as you can.
5. Evidence of entitlement
We may ask to see evidence of:
5.1.1 your responsibility or expected responsibility for the child such as
birth certificate, adoption or matching certificate, parental
responsibility agreement or court order.
5.1.2 the child’s date of birth or date of adoption placement.
6. Our right to postpone parental leave
6.1 Although we will try to accommodate your request for parental leave, we may
postpone your requested leave where it would unduly disrupt our business
(for example, if it would leave us short-staffed or unable to complete work on
time).
6.2 We will discuss alternative dates with you and notify you in writing of the
reason for postponement and the new start and end dates, within seven days
of receiving your request for parental leave.
6.3 We cannot postpone parental leave if you have requested it to start
immediately on the birth or adoption of a child.
6.4 We cannot postpone parental leave for more than six months, or beyond the
child’s 18th birthday (if sooner).
7. Terms and conditions during parental leave
7.1 Parental leave is unpaid. You will not be entitled to employer pension
contributions in respect of the period of leave.
7.2 Your employment contract will remain in force, and holiday entitlement will
continue to accrue. You will remain bound by your duties of good faith and
confidentiality, and any contractual restrictions on accepting gifts and benefits,
or working for another business.
Paternity Policy
1. About this policy
1.1 This policy outlines when an employee may be entitled to paternity leave and
paternity pay and sets out the arrangements for taking it.
1.2 This policy does not form part of any employee’s contract of employment, and
we may amend it at any time.
1.3 You may be entitled to time off to accompany your partner to antenatal
appointments or to attend adoption appointments. For more information see
the Time off for Antenatal Appointments Policy or the Time off for Adoption
Appointments Policy.
1.4 In some cases, you and your partner may be eligible to opt into the Shared
Parental Leave (SPL) scheme which gives you more flexibility to share the
leave and pay available in the first year. This is in addition to your right to
paternity leave. For information about SPL, see our Shared Parental Leave
(Birth) and Shared Parental Leave (Adoption) Policies.
Entitlement to paternity leave
1.5 Paternity leave is available on the birth of a child if you have been
continuously employed by us for at least 26 weeks ending with the 15th week
before the expected week of childbirth and:
(a) you are the biological father and will have some responsibility for the child’s
upbringing; or
(b) you are the partner (spouse, civil partner or cohabiting partner) of the mother,
and will have the main responsibility (with the mother) for the child’s
upbringing; or
(c) the child is born to a surrogate mother where you are, or your partner is, one
of the child’s biological parents, and you expect to obtain a parental order
giving you and your partner legal responsibility for the child.
1.6 Paternity leave is also available where a child is placed with you for adoption
by an adoption agency, provided you meet the same continuous employment
criteria. If eligible, one parent can take adoption leave, while the other parent
(of any gender) can take paternity leave.
1.7 If eligible, you are also entitled to paternity leave in the event of stillbirth (after
24 weeks) or neonatal loss (if the child is born alive but does not survive).
Additional leave may be available under the Neonatal Care (Leave and Pay)
Act 2023 for extended hospital care.
2. Taking paternity leave
2.1 Paternity leave is up to two weeks’ leave taken within the first 52 weeks after
birth or adoption placement. You may choose to take:
(a) A single period of one or two weeks; or
(b) Two separate one-week periods at different times within the first 52 weeks.
2.2 To take paternity leave, you must provide written notice at least 28 days
before each period of leave you wish to take. If your plans change, you can
update your leave dates with at least 28 days’ notice before the earlier of the
original or new leave start date. You must confirm your entitlement by
providing:
(i) The expected week of childbirth (or adoption placement date);
(ii) Your relationship to the child (father, spouse, civil partner, partner, or
intended parent through surrogacy); and
(iii) Confirmation that the leave is to care for the child or support the child’s
mother or adopter.
3. Paternity pay
3.1 You are entitled to Statutory Paternity Pay (SPP) if you:
(a) Have at least 26 weeks’ continuous employment ending with the 15th week
before birth/adoption; and
(b) Earn above the government-set Lower Earnings Limit.
3.2 The rate of SPP is set by the government each tax year.
4. Enhanced Paternity Pay:
4.1 If you have been continuously employed for at least 12 months at the time of
the qualifying week, you may be eligible for enhanced paternity pay:
4.1.1 Week 1: Paid at your normal basic salary.
4.1.2 Paid at Statutory Paternity Pay (SPP)
4.2 To receive enhanced paternity pay, you must confirm in writing that you intend
to return to work for at least six months after paternity leave. If you decide not
to return, you may be required to repay the enhanced portion (but not SPP).
This agreement must be confirmed in writing before leave starts.
5. During paternity leave
5.1 All the usual terms and conditions of your employment remain in force during
paternity leave, except for salary.
5.2 Holiday Entitlement: Continues to accrue. If paternity leave crosses into a new
holiday year, untaken leave may be carried over, subject to managerial
approval.
5.3 Pension Contributions: Employer contributions will continue based on normal
salary. Employee contributions will be based on actual earnings unless a
request is made to maintain full contributions.
5.4 If the child dies or is stillborn, paternity leave may still be taken. Additional
leave may be available under the Parental Bereavement Leave Policy.
6. Review and Amendments
This policy will be reviewed regularly to ensure it remains in line with UK
legislation and best practices. Any amendments will be communicated
accordingly. For more details, refer to the Shared Parental Leave (SPL) Policy
or consult HR.
Recruitment Policy
1. About this Policy
This Recruitment Policy outlines the process for hiring new employees, ensuring a
fair, transparent, and efficient approach that complies with UK employment laws and
promotes equal opportunities for all candidates.
2. Scope
This policy applies to all recruitment activities within the organisation, covering
internal and external hiring processes.
3. Principles
Equal Opportunities: The organisation is committed to promoting equality and
diversity in recruitment. All candidates will be treated fairly and without discrimination
based on age, disability, gender reassignment, marriage or civil partnership,
pregnancy and maternity, race, religion or belief, sex, or sexual orientation, in
compliance with the Equality Act 2010.
Transparency and Fairness: Recruitment decisions will be based solely on merit,
skills, experience, and qualifications relevant to the job.
Confidentiality: Candidate information will be handled with the highest level of
confidentiality and in accordance with data protection laws (UK GDPR and the Data
Protection Act 2018).
4. Recruitment Process
Stage 1: Authority to Recruit
At the start of the recruitment process, an Authority to Recruit form must be signed
by the CEO. This form is distributed by HR and requires the hiring manager to fill in
details about the role. The form must also be signed by a director before it is
submitted to the CEO for final approval.
Stage 2: Job Advertisement and Application
Job vacancies will be advertised internally and externally to ensure a wide pool of
applicants.
Job descriptions and person specifications will outline the essential and desirable
criteria for the role.
Applicants will submit their CVs via internal or external sources for HR and the hiring
manager to shortlist.
Stage 2: Pre-Screen Interview
Purpose: To assess candidates’ suitability for the role based on their qualifications,
experience, and initial alignment with the job requirements.
Format: Pre-screen interviews will be conducted via Microsoft Teams (video call).
Participants: The hiring manager and an HR representative will be present.
Process:
The HR representative will ensure the interview adheres to equality and non-
discrimination principles.
Standardised questions will be prepared to assess key competencies and ensure
consistency across all candidates.
Notes will be taken to document the discussion.
Stage 3: Secondary Interview (Formal Face-to-Face)
Purpose: To conduct a deeper assessment of the shortlisted candidates’ suitability
for the role, including their technical skills, experience, and cultural fit within the
organisation.
Participants: The hiring manager and a director will conduct the interview. The
director’s involvement is mandatory.
Process:
Interviews will take place at Head Office
The hiring manager will lead the discussion, with input from the director.
Questions will explore the candidate’s qualifications, experience, problem-solving
abilities, and alignment with organisational values.
Notes and evaluation forms will be completed to ensure consistency and fairness.
Stage 4: Decision-Making and Offer
Assessment: Candidates will be evaluated based on their performance in both
interview stages. A scoring matrix may be used to compare candidates objectively.
Decision: The hiring manager and director will jointly decide on the most suitable
candidate, ensuring the decision is free from bias.
ITR: Before an offer is made, an Intent to Recruit form must be signed by the CEO.
This form is distributed by HR and requires the hiring manager to confirm who they
intend to hire. The form must also be signed by a director before it is submitted to the
CEO for final approval.
Offer: HR will issue a conditional offer of employment, subject to satisfactory
references and any necessary background checks.
Feedback: Unsuccessful candidates will be notified promptly with a standard regret
for employment letter.
5. Recruitment Agents
In certain cases, the organisation may choose to utilise recruitment agents for
specific roles. When doing so, the following guidelines apply:
Only recruitment agents with whom the organisation has entered into a formal
contract may be engaged.
Alternatively, recruitment agents willing to provide their services at a fee of 12.5% or
less of the successful candidate’s first-year salary may also be considered.
All engagements with recruitment agents must be approved by HR and adhere to
this policy’s principles of fairness and transparency.
6. Compliance with UK Employment Law
All stages of the recruitment process will comply with the Equality Act 2010, ensuring
fair treatment of all candidates. For more details, please refer to our Equal
Opportunities Policy.
Reasonable adjustments will be made for candidates with disabilities to support their
participation in the process.
Recruitment records will be retained for a specified period in line with data protection
laws and for the purpose of responding to any claims or queries.
Policy Review This Recruitment Policy will be reviewed annually or as required to
ensure compliance with legislative changes and best practices.
Shared Parental Leave (Adoption) Policy
1. About this policy
1.1 This policy outlines the arrangements for shared parental leave and pay in
relation to the adoption of a child. If you or your partner are pregnant or have
given birth please see the Shared Parental Leave (Birth) Policy instead.
1.2 This policy applies to employees. It does not apply to agency workers or self-
employed contractors.
1.3 This policy does not form part of any employee’s contract of employment and
we may amend it at any time.
2. Frequently used terms
The definitions in this paragraph apply in this policy.
“Partner” your spouse, civil partner or someone living with
you in an enduring family relationship at the time
the child is placed for adoption, but not your
sibling, child, parent, grandparent, grandchild,
aunt, uncle, niece or nephew.
“Qualifying Week” the week the adoption agency notifies you that
you have been matched with a child for adoption.
3. What is shared parental leave?
3.1 Shared parental leave (SPL) is a form of leave that may be available where a
child is placed with you and/or your partner for adoption on or after 5 April
2015.
3.2 It gives you and your partner more flexibility in how to share the care of your
child in the first year after birth than simply taking maternity and paternity
leave. Assuming you are both eligible, you will be able to choose how to split
the available leave between you, and can decide to be off work at the same
time or at different times. You may be able to take leave in more than one
block.
4. Entitlement
4.1 You may be entitled to SPL if an adoption agency has placed a child with you
and/or your partner for adoption, or where a child is placed with you and/or
your partner as foster parents under a “fostering for adoption” or “concurrent
planning” scheme. You must intend to share the main responsibility for the
care of the child with your partner.
4.2 The following conditions must be fulfilled:
4.2.1 you must have at least 26 weeks continuous employment with us by
the end of the Qualifying Week, and still be employed by us in the
week before the leave is to be taken;
4.2.2 your partner must have worked (in an employed or self-employed
capacity) in at least 26 of the 66 weeks before the Qualifying Week
and had average weekly earnings of at least £30 during 13 of those
weeks; and
4.2.3 you and your partner must give the necessary statutory notices and
declarations as summarised below, including notice to end adoption
leave or statutory adoption pay (SAP).
4.3 Either you or your partner must qualify for statutory adoption leave and/or
SAP and must take at least two weeks of adoption leave and/or pay.
4.4 If your partner is taking adoption leave and/or claiming SAP, you may be
entitled to two weeks’ paternity leave and pay (see our Paternity Leave
Policy). You should consider using this before taking SPL. Paternity leave is
additional to any SPL entitlement you may have, but you will lose any untaken
paternity leave entitlement once you start a period of SPL.
4.5 The total amount of SPL available is 52 weeks, less the weeks of adoption
leave taken by either you or partner (or the weeks in which your partner has
been in receipt of SAP if they were not entitled to adoption leave).
5. Opting in to shared parental leave and pay
Not less than eight weeks before the date you intend your SPL to start, you must
give us a written opt-in notice which includes:
5.1.1 your name and your partner’s name;
5.1.2 if you are taking adoption leave, your adoption leave start and end
dates;
5.1.3 if you are not taking adoption leave, your partner’s adoption leave
start and end dates, or if your partner is not entitled to adoption
leave, the start and end dates of their SAP;
5.1.4 the total SPL available, which is 52 weeks minus the number of
weeks’ adoption leave or SAP taken or to be taken by you or your
partner;
5.1.5 how many weeks of the available SPL will be allocated to you and
how many to your partner (you can change the allocation by giving
us a further written notice, and you do not have to use your full
allocation);
5.1.6 if you are claiming statutory shared parental pay (ShPP), the total
ShPP available, which is 39 weeks minus the number of weeks of
SAP taken or to be taken);
5.1.7 how many weeks of the available ShPP will be allocated to you and
how many to your partner (you can change the allocation by giving
us a further written notice, and you do not have to use your full
allocation);
5.1.8 an indication of the pattern of leave you are thinking of taking,
including suggested start and end dates for each period of leave
(see paragraph 9 and paragraph 10 for information on taking leave).
This indication will not be binding at this stage, but please give as
much information as you can about your future intentions; and
5.1.9 declarations by you and your partner that you both meet the
statutory conditions to enable you to take SPL and ShPP.
6. Ending your adoption leave
6.1 If you are taking or intend to take adoption leave and want to opt into the SPL
scheme, you must give us at least eight weeks’ written notice to end your
adoption leave (a curtailment notice). The notice must state the date your
adoption leave will end. You can give the notice before or after adoption leave
starts, but you must take at least two weeks’ adoption leave.
6.2 You must also give us, at the same time as the curtailment notice, a notice to
opt into the SPL scheme (see paragraph 5) or a written declaration that your
partner has given their employer an opt-in notice and that you have given the
necessary declarations in that notice.
6.3 If your partner is eligible to take SPL from their employer they cannot start it
until you have given us your curtailment notice.
6.4 The curtailment notice is binding on you and cannot usually be revoked. You
can only revoke a curtailment notice if your adoption leave has not yet ended
and one of the following applies:
6.4.1 if you realise that neither you nor your partner are in fact eligible for
SPL or ShPP, in which case you can revoke the curtailment notice
in writing up to eight weeks after it was given;
6.4.2 if your partner has died.
6.5 Once you have revoked a curtailment notice you will be unable to opt back in
to the SPL scheme.
7. Ending your partner’s adoption leave or pay
If your partner is taking adoption leave or claiming SAP from their employer, you will
only be able to take SPL once your partner has either:
7.1.1 returned to work;
7.1.2 given their employer a curtailment notice to end adoption leave; or
7.1.3 given their employer a curtailment notice to end SAP (if they are
entitled to SAP but not adoption leave).
8. Evidence of entitlement
You must provide on request:
8.1.1 One or more documents from the adoption agency showing the
agency’s name and address and the expected placement date; and
8.1.2 The name and address of your partner’s employer (or a declaration
that they have no employer).
9. Booking your SPL dates
9.1 Having opted into the SPL system, you must book your leave by giving us a
period of leave notice. This may be given at the same time as the opt-in notice
or later, provided it is at least eight weeks before the start of SPL.
9.2 The period of leave notice can either give the dates you want to take SPL or, if
the child has not been placed with you yet, it can state the number of days
after the placement that you want the SPL to start and end. This may be
particularly useful if you intend to take paternity leave starting on the date of
placement and wish to take SPL straight afterwards.
9.3 Leave must be taken in blocks of at least one week.
9.4 If your period of leave notice gives dates for a single continuous block of SPL
you will be entitled to take the leave set out in the notice.
9.5 If your period of leave notice requests split periods of SPL, with periods of
work in between, we will consider your request as set out in paragraph 10,
below.
9.6 You can give up to three period of leave notices. This may enable you to take
up to three separate blocks of SPL (although if you give a notice to vary or
cancel a period of leave this will in most cases count as a further period of
leave notice; see paragraph 11).
10. Procedure for requesting split periods of SPL
10.1 In general, a period of leave notice should set out a single continuous block of
leave. We may be willing to consider a period of leave notice where the SPL is
split into shorter periods with periods of work in between. It is best to discuss
this with your manager and HR in good time before formally submitting your
period of leave notice. This will give us more time to consider the request and
hopefully agree a pattern of leave with you from the start.
10.2 If you want to request split periods of SPL, you must set out the requested
pattern of leave in your period of leave notice. We will either agree to the
request or start a two-week discussion period. At the end of that period, we
will confirm any agreed arrangements in writing. If we have not reached
agreement, you will be entitled to take the full amount of requested SPL as
one continuous block, starting on the start date given in your notice (for
example, if you requested three separate periods of four weeks each, they will
be combined into one 12-week period of leave). Alternatively, you may:
10.2.1 choose a new start date (which must be at least eight weeks after
your original period of leave notice was given), and tell us within five
days of the end of the two-week discussion period; or
10.2.2 withdraw your period of leave notice within two days of the end of
the two-week discussion period (in which case it will not be counted
and you may submit a new one if you choose).
11. Changing the dates or cancelling your SPL
11.1 You can cancel a period of leave by notifying us in writing at least eight weeks
before the start date in the period of leave notice.
11.2 You can change the start date for a period of leave by notifying us in writing at
least eight weeks before the original start date or the new start date,
whichever is earlier.
11.3 You can change the end date for a period of leave by notifying us in writing at
least eight weeks before the original end date or the new end date, whichever
is earlier.
11.4 You can combine discontinuous periods of leave into a single continuous
period of leave. Since this will involve a change to the start date or end date of
a period of leave, see paragraph 11.2 and paragraph 11.3 above which set out
how much notice is required.
11.5 You can request that a continuous period of leave be split into two or more
discontinuous periods of leave, with periods of work in between. Since this will
involve a change to the start date or end date, see paragraph 11.2 and
paragraph 11.3 above which set out how much notice is required for the
request. We do not have to grant your request but will consider it as set out in
paragraph 10.
11.6 A notice to change or cancel a period of leave will count as one of your three
period of leave notices, unless:
11.6.1 the variation is a result of the child being placed with you earlier or
later than the expected placement date;
11.6.2 you are cancelling a request for discontinuous leave within two days
of the end of the two-week discussion period under paragraph 10.2.
11.6.3 the variation is at our request; or
11.6.4 we agree otherwise.
12. Shared parental pay
12.1 You may be able to claim Statutory Shared Parental Pay (ShPP) of up to 39
weeks (less any weeks of SAP claimed by you or your partner) provided you
have at least 26 weeks’ continuous employment with us at the end of the
Qualifying Week and your average earnings are not less than the lower
earnings limit set by the government each tax year. ShPP is paid at a rate set
by the government each year.
12.2 You should tell us in your period of leave notice(s) whether you intend to claim
ShPP during your leave (and if applicable, for what period). If it is not in your
period of leave notice you can tell us in writing, at least eight weeks before
you want ShPP to start.
13. Other terms during shared parental leave
13.1 Your terms and conditions of employment remain in force during SPL, except
for the terms relating to pay.
13.2 Holiday entitlement will continue to accrue at the rate provided under your
contract. If your SPL will continue into the next holiday year, any holiday
entitlement that cannot reasonably be taken before starting your leave can be
carried over and must be taken within three months of returning to work
unless your manager agrees otherwise. Please discuss your holiday plans
with your manager in good time before starting SPL. All holiday dates are
subject to approval by your manager.
13.3 If you are a member of the pension scheme, we will make employer pension
contributions during any period of paid SPL, based on your normal salary, in
accordance with the pension scheme rules. Any employee contributions you
make will be based on the amount of any shared parental pay you are
receiving, unless you inform Payroll that you wish to make up any shortfall.
14. Keeping in touch
14.1 We may make reasonable contact with you from time to time during your SPL
although we will keep this to a minimum. This may include contacting you to
discuss arrangements for your return to work.
14.2 You may ask or be asked to work (including attending training) on up to 20
“keeping-in-touch” days (KIT days) during your SPL. This is in addition to any
KIT days that you may have taken during adoption leave. KIT days are not
compulsory and must be discussed and agreed with your line manager.
14.3 You will be paid at your normal basic rate of pay for time spent working on a
KIT Day and this will be inclusive of any shared parental pay entitlement.
15. Returning to work
15.1 If you want to end a period of SPL early, you must give us eight weeks’ written
notice of the new return date. If you have already given us three period of
leave notices you will not be able to end your SPL early without our
agreement.
15.2 If you want to extend your SPL, assuming you still have unused SPL
entitlement remaining, you must give us a written notice at least eight weeks
before the date you were due to return to work. If you have already given us
three period of leave notices you will not be able to extend your SPL without
our agreement. You may instead be able to request annual leave or ordinary
parental leave (see our Parental Leave Policy), subject to the needs of our
business.
15.3 You are normally entitled to return to work in the position you held before
starting SPL, and on the same terms of employment. However, if it is not
reasonably practicable for us to allow you to return into the same position, we
will as per The Maternity Leave, Adoption Leave and Shared Parental Leave
(Amendment) Regulations 2024 arrange another suitable and appropriate job
on terms and conditions that are not less favourable, but only in the following
circumstance:
15.3.1 if your SPL is less than 6 weeks in duration, or 18 months from the
child’s date of birth when more than 6 weeks consecutive SPL has
been taken.
15.4 If you want to change your hours or other working arrangements on return
from SPL you should make a request under our Flexible Working Policy. It is
helpful if such requests are made as early as possible.
15.5 If you decide you do not want to return to work you should give notice of
resignation in accordance with your contract.
Shared Parental Leave (Birth) Policy
1. About this policy
1.1 This policy outlines the arrangements for shared parental leave and pay in
relation to the birth of a child. If you are adopting a child please see the
Shared Parental Leave (Adoption) Policy instead.
1.2 This policy applies to employees. It does not apply to agency workers or self-
employed contractors.
1.3 This policy does not form part of any employee’s contract of employment and
we may amend it at any time.
2. Frequently used terms
The definitions in this paragraph apply in this policy.
“Expected week of childbirth
(EWC)”
the week, beginning on a Sunday, in which the
doctor or midwife expects your child to be born.
“Parent” One of two people who will share the main
responsibility for the child’s upbringing (and who
may be either the mother, the father, or the
mother’s partner if not the father).
“Partner” your spouse, civil partner or someone living with
you in an enduring family relationship, but not
your sibling, child, parent, grandparent,
grandchild, aunt, uncle, niece or nephew.
“Qualifying Week” the fifteenth week before the EWC.
3. What is shared parental leave?
3.1 Shared parental leave (SPL) is a form of leave that may be available if your
child is expected to be born on or after 5 April 2015.
3.2 It gives you and your partner more flexibility in how to share the care of your
child in the first year after birth than simply taking maternity and paternity
leave. Assuming you are both eligible, you will be able to choose how to split
the available leave between you, and can decide to be off work at the same
time or at different times. You may be able to take leave in more than one
block.
4. Entitlement to SPL
4.1 You are entitled to SPL in relation to the birth of a child if:
4.1.1 you are the child’s mother, and share the main responsibility for the
care of the child with the child’s father or with your partner;
4.1.2 you are the child’s father and share the main responsibility for the
care of the child with the child’s mother; or
4.1.3 you are the mother’s partner and share the main responsibility for
the care of the child with the mother (where the child’s father does
not share the main responsibility with the mother).
4.2 The following conditions must also be fulfilled:
4.2.1 you must have at least 26 weeks continuous employment with us by
the end of the Qualifying Week, and still be employed by us in the
week before the leave is to be taken;
4.2.2 the other parent must have worked (in an employed or self-
employed capacity) in at least 26 of the 66 weeks before the EWC
and had average weekly earnings of at least £30 during 13 of those
weeks; and
4.2.3 you and the other parent must give the necessary statutory notices
and declarations as summarised below, including notice to end any
maternity leave, statutory maternity pay (SMP) or maternity
allowance (MA) periods.
4.3 The total amount of SPL available is 52 weeks, less the weeks spent by the
child’s mother on maternity leave (or the weeks in which the mother has been
in receipt of SMP or MA if she is not entitled to maternity leave).
4.4 If you are the mother you cannot start SPL until after the compulsory maternity
leave period, which lasts until two weeks after birth.
4.5 If you are the child’s father or the mother’s partner, you should consider using
your two weeks’ paternity leave before taking SPL. Once you start SPL you
will lose any untaken paternity leave entitlement. SPL entitlement is additional
to your paternity leave entitlement.
5. Opting in to shared parental leave and pay
Not less than eight weeks before the date you intend your SPL to start, you must
give us a written opt-in notice giving:
5.1.1 your name and the name of the other parent;
5.1.2 if you are the child’s mother, the start and end dates of your
maternity leave;
5.1.3 if you are the child’s father or the mother’s partner, the start and end
dates of the mother’s maternity leave, or if she is not entitled to
maternity leave, the start and end dates of any SMP or MA period;
5.1.4 the total SPL available, which is 52 weeks minus the number of
weeks’ maternity leave, SMP or MA period taken or to be taken;
5.1.5 how many weeks of the available SPL will be allocated to you and
how many to the other parent (you can change the allocation by
giving us a further written notice, and you do not have to use your
full allocation);
5.1.6 if you are claiming statutory shared parental pay (ShPP), the total
ShPP available, which is 39 weeks minus the number of weeks of
the SMP or MA period taken or to be taken);
5.1.7 how many weeks of available ShPP will be allocated to you and
how much to the other parent. (You can change the allocation by
giving us a further written notice, and you do not have to use your
full allocation);
5.1.8 an indication of the pattern of leave you are thinking of taking,
including suggested start and end dates for each period of leave
(see paragraph 9 and paragraph 10 for information on taking leave).
This indication will not be binding at this stage, but please give as
much information as you can about your future intentions; and
5.1.9 declarations by you and the other parent that you both meet the
statutory conditions to enable you to take SPL and ShPP.
6. Ending your maternity leave
6.1 If you are the child’s mother and want to opt into the SPL scheme, you must
give us at least eight weeks’ written notice to end your maternity leave (a
curtailment notice) before you can take SPL. The notice must state the date
your maternity leave will end. You can give the notice before or after you give
birth, but you cannot end your maternity leave until at least two weeks after
birth.
6.2 You must also give us, at the same time as the curtailment notice, a notice to
opt into the SPL scheme (see paragraph 5) or a written declaration that the
other parent has given their employer an opt-in notice and that you have given
the necessary declarations in that notice.
6.3 The other parent may be eligible to take SPL from their employer before your
maternity leave ends, provided you have given the curtailment notice.
6.4 The curtailment notice is binding and cannot usually be revoked. You can only
revoke a curtailment notice if maternity leave has not yet ended and one of
the following applies:
6.4.1 if you realise that neither you nor the other parent are in fact eligible
for SPL or ShPP, in which case you can revoke the curtailment
notice in writing up to eight weeks after it was given;
6.4.2 if you gave the curtailment notice before giving birth, you can
revoke it in writing up to eight weeks after it was given, or up to six
weeks after birth, whichever is later; or
6.4.3 if the other parent has died.
6.5 Once you have revoked a curtailment notice you will be unable to opt back
into the SPL scheme, unless paragraph 6.4.2 applies.
7. Ending your partner’s maternity leave or pay
If you are not the mother, but the mother is still on maternity leave or claiming SMP
or MA, you will only be able to take SPL once she has either:
7.1.1 returned to work;
7.1.2 given her employer a curtailment notice to end her maternity leave;
7.1.3 given her employer a curtailment notice to end her SMP (if she is
entitled to SMP but not maternity leave); or
7.1.4 given the benefits office a curtailment notice to end her MA (if she is
not entitled to maternity leave or SMP).
8. Evidence of entitlement
You must also provide on request:
8.1.1 A copy of the birth certificate (or if you have not yet obtained a birth
certificate, a signed declaration of the child’s date and place of
birth); and
8.1.2 The name and address of the other parent’s employer (or a
declaration that they have no employer).
9. Booking your SPL dates
9.1 Having opted into the SPL system, you must book your leave by giving us a
period of leave notice. This may be given at the same time as the opt-in notice
or later, provided it is at least eight weeks before the start of SPL.
9.2 The period of leave notice can either give the dates you want to take leave or,
if the child has not been born yet, it can state the number of days after birth
that you want the leave to start and end. This may be particularly useful if you
intend to take paternity leave starting on the date of birth and wish to take SPL
straight afterwards.
9.3 Leave must be taken in blocks of at least one week.
9.4 If your period of leave notice gives a single continuous block of SPL you will
be entitled to take the leave set out in the notice.
9.5 If your period of leave notice requests split periods of SPL, with periods of
work in between, we will consider your request as set out in paragraph 10,
below.
9.6 You can give up to three period of leave notices. This may enable you to take
up to three separate blocks of SPL (although if you give a notice to vary or
cancel a period of leave this will in most cases count as a further period of
leave notice; see paragraph 11) .
10. Procedure for requesting split periods of SPL
10.1 In general, a period of leave notice should set out a single continuous block of
leave. We may be willing to consider a period of leave notice where the SPL is
split into shorter periods with periods of work in between. It is best to discuss
this with your manager and HR in good time before formally submitting your
period of leave notice. This will give us more time to consider the request and
hopefully agree a pattern of leave with you from the start.
10.2 If you want to request split periods of SPL, you must set out the requested
pattern of leave in your period of leave notice. We will either agree to the
request or start a two-week discussion period. At the end of that period, we
will confirm any agreed arrangements in writing. If we have not reached
agreement, you will be entitled to take the full amount of requested SPL as
one continuous block, starting on the start date given in your notice (for
example, if you requested three separate periods of four weeks each, they will
be combined into one 12-week period of leave). Alternatively, you may:
10.2.1 choose a new start date (which must be at least eight weeks after
your original period of leave notice was given), and tell us within five
days of the end of the two-week discussion period; or
10.2.2 withdraw your period of leave notice within two days of the end of
the two-week discussion period (in which case the notice will not be
counted and you may submit a new one if you choose).
11. Changing the dates or cancelling your SPL
11.1 You can cancel a period of leave by notifying us in writing at least eight weeks
before the start date in the period of leave notice.
11.2 You can change the start date for a period of leave by notifying us in writing at
least eight weeks before the original start date or the new start date,
whichever is earlier.
11.3 You can change the end date for a period of leave by notifying us in writing at
least eight weeks before the original end date or the new end date, whichever
is earlier.
11.4 You can combine discontinuous periods of leave into a single continuous
period of leave. Since this will involve a change to the start date or end date of
a period of leave, see paragraph 11.2 and paragraph 11.3 above which set out
how much notice is required.
11.5 You can request that a continuous period of leave be split into two or more
discontinuous periods of leave, with periods of work in between. Since this will
involve a change to the start date or end date, see paragraph 11.2 and
paragraph 11.3 above which set out how much notice is required for the
request. We do not have to grant your request but will consider it as set out in
paragraph 10.
11.6 A notice to change or cancel a period of leave will count as one of your three
period of leave notices, unless:
11.6.1 it is a result of your child being born earlier or later than the EWC;
11.6.2 you are cancelling a request for discontinuous leave within two days
of the end of the two-week discussion period under paragraph 10.2.
11.6.3 it is at our request; or
11.6.4 we agree otherwise.
12. Premature birth
Where the child is born early (before the beginning of the EWC), you may be able to
start SPL in the eight weeks following birth even though you cannot give eight weeks
notice. The following rules apply:
12.1.1 If you have given a period of leave notice to start SPL on a set date
in the eight weeks following the EWC, but your child is born early,
you can move the SPL start date forward by the same number of
days, provided you notify us in writing of the change as soon as you
can. (If your period of leave notice already contained a start date
which was a set number of days after birth, rather than a set date,
then no notice of change is necessary.)
12.1.2 If your child is born more than eight weeks early and you want to
take SPL in the eight weeks following birth, please submit your opt-
in notice and your period of leave notice as soon as you can.
13. Shared parental pay
13.1 You may be able to claim Statutory Shared Parental Pay (ShPP) of up to 39
weeks (less any weeks of SMP or MA claimed by you or your partner) if you
have at least 26 weeks’ continuous employment with us at the end of the
Qualifying Week and your average earnings are not less than the lower
earnings limit set by the government each tax year. ShPP is paid by
employers at a rate set by the government each year.
13.2 You should tell us in your period of leave notice(s) whether you intend to claim
ShPP during your leave (and if applicable, for what period). If it is not in your
period of leave notice you can tell us in writing, at least eight weeks before
you want ShPP to start.
14. Other terms during shared parental leave
14.1 Your terms and conditions of employment remain in force during SPL, except
for the terms relating to pay.
14.2 Holiday entitlement will continue to accrue at the rate provided under your
contract. If your SPL will continue into the next holiday year, any holiday
entitlement that cannot reasonably be taken before starting your leave can be
carried over and must be taken within three months of returning to work
unless your manager agrees otherwise. Please discuss your holiday plans
with your manager in good time before starting SPL. All holiday dates are
subject to approval by your manager.
14.3 If you are a member of the pension scheme, we will make employer pension
contributions during any period of paid SPL, based on your normal salary, in
accordance with the pension scheme rules. Any employee contributions you
make will be based on the amount of any shared parental pay you are
receiving, unless you inform Payroll that you wish to make up any shortfall.
15. Keeping in touch
15.1 We may make reasonable contact with you from time to time during your SPL
although we will keep this to a minimum. This may include contacting you to
discuss arrangements for your return to work.
15.2 You may ask or be asked to work (including attending training) on up to 20
“keeping-in-touch” days (KIT days) during your SPL. This is in addition to any
KIT days that you may have taken during maternity leave. KIT days are not
compulsory and must be discussed and agreed with your line manager.
15.3 You will be paid at your normal basic rate of pay for time spent working on a
KIT day and this will be inclusive of any shared parental pay entitlement.
16. Returning to work
16.1 If you want to end a period of SPL early, you must give us eight weeks’ written
notice of the new return date. If have already given us three period of leave
notices you will not be able to end your SPL early without our agreement.
16.2 If you want to extend your SPL, assuming you still have unused SPL
entitlement remaining, you must give us a written period of leave notice at
least eight weeks before the date you were due to return to work. If you have
already given us three period of leave notices you will not be able to extend
your SPL without our agreement. You may instead be able to request annual
leave or ordinary parental leave (see our Parental Leave Policy), subject to
the needs of the business.
16.3 You are normally entitled to return to work in the position you held before
starting SPL, and on the same terms of employment. However, if it is not
reasonably practicable for us to allow you to return into the same position, we
will as per The Maternity Leave, Adoption Leave and Shared Parental Leave
(Amendment) Regulations 2024 arrange another suitable and appropriate job
on terms and conditions that are not less favourable, but only in the following
circumstance:
16.3.1 if your SPL is less than 6 weeks in duration, or 18 months from the
child’s date of birth when more than 6 weeks consecutive SPL has
been taken.
16.4 If you want to change your hours or other working arrangements on return
from SPL you should make a request under our Flexible Working Policy. It is
helpful if such requests are made as early as possible.
16.5 If you decide you do not want to return to work you should give notice of
resignation in accordance with your contract.
Sickness and Absence Policy
1. About this policy
1.1 This policy sets out our arrangements for sick pay and for reporting and
managing sickness absence.
1.2 Abuse of sickness absence, including failing to report absence or falsely
claiming sick pay will be treated as misconduct under our Disciplinary
Procedure.
1.3 This policy does not form part of any employee’s contract of employment, and
we may amend it at any time.
2. Reporting when you are sick
If you cannot attend work because you are sick or injured, you should telephone
your manager as early as possible and no later than 30 minutes after the time
when you are normally expected to start work.
3. Evidence of incapacity
3.1 You must complete a self-certification form for sickness absence of up to seven
calendar days.
3.2 For absence of more than a week you must obtain a certificate from your doctor
stating that you are not fit for work, giving the reason. You must also complete
a self-certification form to cover the first seven days. If absence continues
beyond the expiry of a certificate, a further certificate must be provided.
3.3 If your doctor provides a certificate stating that you “may be fit for work” you
must inform your manager immediately. We will hold a discussion with you
about how to facilitate your return to work, taking account of your doctor’s
advice. If appropriate measures cannot be taken, you will remain on sick leave
and we will set a date for review.
4. Statutory sick pay and Company sick pay
4.1 You may be entitled to Statutory Sick Pay (SSP) if you satisfy the relevant
statutory requirements. Qualifying days for Monday to Friday, or as set out in
your employment contract. The rate of SSP is set by the government in April
each year. No SSP is payable for the first three consecutive days of absence.
It starts on the fourth day of absence and may be payable for up to 28 weeks
4.2 You will qualify for Company sick pay provided you comply with this policy and
any further requirements set out in your contract. This does not affect any
entitlement you may have to receive SSP for the same periods of sickness
absence, although any sick pay you receive from the Company shall be
inclusive of any SSP due to you.
4.3 Company sick pay is equal to your full basic salary for up to 2 weeks’ absence.
5. Return-to-work interviews
After a period of sick leave your manager may hold a return-to-work interview
with you. The purposes may include:
5.1.1 ensuring you are fit for work and agreeing any actions necessary to
facilitate your return.
5.1.2 confirming you have submitted the necessary certificates.
5.1.3 updating you on anything that may have happened during your
absence.
5.1.4 raising any other concerns regarding your absence record or your
return to work.
6. Managing long-term or persistent absence
6.1 The following paragraphs set out our procedure for dealing with long-term
absence or where your level or frequency of short-term absence has given us
cause for concern. The purpose of the procedure is to investigate and discuss
the reasons for your absence, whether it is likely to continue or recur, and
whether there are any measures that could improve your health and/or
attendance. We may decide that medical evidence, or further medical evidence,
is required before deciding on a course of action.
6.2 We will notify you in writing of the time, date and place of any meeting, and why
it is being held. We will usually give you a week’s notice of the meeting.
6.3 Meetings will be conducted by your line manager.
6.4 You may bring a companion to any meeting or appeal meeting under this
procedure. Your companion may be either a trade union representative or a
colleague, who will be allowed reasonable paid time off from duties to act as
your companion.
6.5 If you or your companion cannot attend at the time specified you should let us
know as soon as possible and we will try, within reason, to agree an alternative
time.
6.6 If you have a disability, we will consider whether reasonable adjustments may
need to be made to the sickness absence meetings procedure, or to your role
or working arrangements.
7. Medical examinations
7.1 We may ask you to consent to a medical examination by a doctor or
occupational health professional or other specialist nominated by us (at our
expense).
7.2 You will be asked to agree that any medical report produced may be disclosed
to us and that we may discuss the contents of the report with the specialist and
with our advisers. All medical reports will be kept confidential and held in
accordance with our Data Protection Policy.
8. Initial sickness absence meeting
8.1 The purposes of a sickness absence meeting or meetings will be to discuss the
reasons for your absence, how long it is likely to continue, whether it is likely to
recur, whether to obtain a medical report, and whether there are any measures
that could improve your health and/or attendance.
8.2 In cases of long-term absence, we may seek to agree a return-to-work
programme, possibly on a phased basis.
8.3 In cases of short-term, intermittent absence, we may set a target for improved
attendance within a certain timescale.
9. If matters do not improve
If, after a reasonable time, you have not been able to return to work or if your
attendance has not improved within the agreed timescale, we will hold a further
meeting or meetings. We will seek to establish whether the situation is likely to
change, and may consider redeployment opportunities at that stage. If it is
considered unlikely that you will return to work or that your attendance will
improve within a short time, we may give you a written warning that you are at
risk of dismissal. We may also set a further date for review.
10. Final sickness absence meeting
Where you have been warned that you are at risk of dismissal, and the situation
has not changed significantly, we will hold a meeting to consider the possible
termination of your employment. Before we make a decision, we will consider
any matters you wish to raise and whether there have been any changes since
the last meeting.
11. Appeals
11.1 You may appeal against the outcome of any stage of this procedure. If you wish
to appeal you should set out your appeal in writing to James Hill, (CSO, HR
Director) stating your grounds of appeal, within one week of the date on which
the decision was sent or given to you.
11.2 If you are appealing against a decision to dismiss you, we will hold an appeal
meeting, normally within two weeks of receiving the appeal. This will be dealt
with impartially and, where possible, by a more senior manager who has not
previously been involved in the case.
11.3 We will confirm our final decision in writing, usually within one week of the
appeal hearing. There is no further right of appeal.
11.4 The date that any dismissal takes effect will not be delayed pending the
outcome of an appeal. However, if the appeal is successful, the decision to
dismiss will be revoked with no loss of continuity or pay.
Smoking Policy
1. About this policy
1.1 We are committed to protecting your health, safety and welfare and that of all
those who work for us by providing a safe place of work and protecting all
workers, service users, customers and visitors from exposure to smoke.
1.2 All of our workplaces (including our vehicles) are smoke-free in accordance
with the Health Act 2006 and associated regulations. All staff and visitors have
the right to a smoke-free environment.
1.3 This policy does not form part of any employee’s contract of employment, and
it may be amended at any time.
1.4 If you wish to suggest improvements to the policy or experience particular
difficulty complying with it you should discuss the situation with your line
manager, Health Safety and Human Resources.
2. Where is smoking banned?
2.1 Smoking is not permitted anywhere in our workplace. The ban applies to
anything that can be smoked and includes, but is not limited to, cigarettes,
electronic cigarettes, pipes (including water pipes such as shisha and hookah
pipes), cigars and herbal cigarettes.
2.2 No-smoking signs are displayed at the entrances to our workplace.
2.3 Anyone using our vehicles, whether as a driver or passenger, must ensure the
vehicles remain smoke-free. Any of our vehicles that are used primarily for
private purposes are excluded from the smoking ban.
3. Where is smoking permitted?
You may only smoke outside in designated areas during breaks. When smoking
outside, you must dispose of cigarette butts and other litter appropriately in the
receptacles provided.
4. Breaches of the policy
4.1 Breaches of this policy by any employee will be dealt with under our
Disciplinary Procedure and, in serious cases, may be treated as gross
misconduct leading to summary dismissal.
4.2 Smoking in smoke-free premises or vehicles is also a criminal offence and
may result in a fixed penalty fine and/or prosecution.
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Social Media Policy
1. About this policy
1.1 This policy is in place to minimise the risks to our business through use of social
media.
1.2 This policy deals with the use of all forms of social media, including Facebook,
LinkedIn, Twitter, Google+, Wikipedia, Instagram and all other social networking
sites, internet postings and blogs. It applies to use of social media for business
purposes as well as personal use that may affect our business in any way.
1.3 This policy does not form part of any employee’s contract of employment, and we
may amend it at any time.
2. Personal use of social media
Occasional personal use of social media during working hours is permitted so long as it
does not involve unprofessional or inappropriate content, does not interfere with your
employment responsibilities or productivity and complies with this policy.
3. Prohibited use
3.1 You must avoid making any social media communications that could damage our
business interests or reputation, even indirectly.
3.2 You must not use social media to defame or disparage us, our staff or any third
party; to harass, bully or unlawfully discriminate against staff or third parties; to
make false or misleading statements; or to impersonate colleagues or third parties.
3.3 You must not express opinions on our behalf via social media, unless expressly
authorised to do so by your manager. You may be required to undergo training in
order to obtain such authorisation.
3.4 You must not post comments about sensitive business-related topics, such as our
performance, or do anything to jeopardise our trade secrets, confidential information
and intellectual property. You must not include our logos or other trademarks in any
social media posting or in your profile on any social media.
3.5 The contact details of business contacts made during the course of your
employment are our confidential information. On termination of employment you
must provide us with a copy of all such information, delete all such information from
your personal social networking accounts and destroy any further copies of such
information that you may have.
3.6 Any misuse of social media should be reported to IT.
4. Guidelines for responsible use of social media
4.1 You should make it clear in social media postings, or in your personal profile, that
you are speaking on your own behalf. Write in the first person and use a personal e-
mail address.
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4.2 Be respectful to others when making any statement on social media and be aware
that you are personally responsible for all communications which will be published
on the internet for anyone to see.
4.3 If you disclose your affiliation with us on your profile or in any social media postings,
you must state that your views do not represent those of your employer (unless you
have been authorised to speak on our behalf as set out in paragraph 3.3). You
should also ensure that your profile and any content you post are consistent with
the professional image you present to clients and colleagues.
4.4 If you are uncertain or concerned about the appropriateness of any statement or
posting, refrain from posting it until you have discussed it with your manager.
4.5 If you see social media content that disparages or reflects poorly on us, you should
contact your line manager.
5. Breach of this policy
5.1 Breach of this policy may result in disciplinary action up to and including dismissal.
Any member of staff suspected of committing a breach of this policy will be required
to co-operate with our investigation.
5.2 You may be required to remove any social media content that we consider to
constitute a breach of this policy. Failure to comply with such a request may in itself
result in disciplinary action.
Time off for Adoption Appointments Policy
1. About this policy
1.1 This policy outlines the statutory right to take time off to attend adoption
appointments.
1.2 This policy applies to employees and agency workers. It does not apply to self-
employed contractors.
1.3 If you are an agency worker, the rights set out in this policy only apply to you
once you have worked in the same role with us for at least 12 continuous weeks
(which may include more than one assignment). For these purposes we will
ignore any breaks due to holiday or other leave to which you are entitled, breaks
due to industrial action, breaks of up to 28 weeks in cases of sickness or jury
service, and breaks of up to six weeks for any other reason. We will treat breaks
due to pregnancy or childbirth up to 26 weeks after birth, and any statutory
maternity, paternity or adoption leave, as time worked.
1.4 This policy does not form part of any employee’s contract of employment and
we may amend it at any time.
2. Time off for an adoption appointment
2.1 An adoption appointment is an appointment arranged by an adoption agency
(or at the agency’s request) for you to have contact with a child who is to be
placed with you for adoption, or for any other purpose related to the adoption.
2.2 You may take time off to attend an adoption appointment once the agency has
notified you that a child is to be placed with you for adoption but before the child
is actually placed with you.
3. If you are adopting a child with another person
3.1 Where you and your partner are adopting a child, you must decide between you
who will be treated as the primary adopter and who will be treated as the
secondary adopter for the purposes of time off. You must tell us your decision
the first time you request time off for an adoption appointment. This will affect
how much time you can take off.
3.2 You would usually choose to be the primary adopter if you intend to take
adoption leave when the child is placed with you. You would not be able to take
paternity leave if you have elected to be the primary adopter.
3.3 You would usually choose to be the secondary adopter if you intend to take
paternity leave when the child is placed with you, although you may be able to
take adoption leave if your partner is not taking it.
4. If you are adopting a child alone
If you are adopting a child alone, you are treated as the primary adopter.
5. If you are adopting more than one child
If the agency is placing more than one child with you as part of the same
arrangement, this is treated as one adoption and will not increase the number
of appointments you can take time off to attend. Any time off under this policy
must be taken before the first child is placed with you.
6. Amount of time off
6.1 If you are adopting on your own or have elected to be the primary adopter, you
may take paid time off to attend an adoption appointment on up to five
occasions in relation to any particular adoption.
6.2 If you are the secondary adopter, you may take unpaid time off to attend an
adoption appointment on up to two occasions only.
6.3 You must not take more than six and a half hours off for each appointment,
including travel and waiting time.
7. How to book time off
7.1 Please give us as much notice of the appointment as possible. You must
provide your manager with a signed statement or an email confirming:
7.1.1 The date and time of the appointment.
7.1.2 That the appointment has been arranged or requested by the
adoption agency.
7.1.3 Whether you are adopting a child alone or jointly with another person.
7.1.4 If you are adopting with another person, whether you are electing to
take paid or unpaid time off.
7.2 If you are an agency worker you may have to notify your agency as well. You
should check with the agency.
7.3 We may sometimes ask you to try and rearrange an appointment where it is
reasonable to do so. In exceptional circumstances we reserve the right to refuse
a request for a particular appointment but we will not do so without good reason.
Time off for Antenatal Appointments Policy
1. About this policy
1.1 This policy outlines the statutory right to take time off to attend antenatal
appointments.
1.2 This policy applies to employees and agency workers. It does not apply to self-
employed contractors.
1.3 If you are an agency worker, the rights set out in this policy only apply to you
once you have worked in the same role with us for at least 12 continuous weeks
(which may include more than one assignment). For these purposes we will
ignore any breaks due to holiday or other leave to which you are entitled, breaks
due to industrial action, breaks of up to 28 weeks in cases of sickness or jury
service, and breaks of up to six weeks for any other reason. We will treat breaks
due to pregnancy or childbirth up to 26 weeks after birth, and any statutory
maternity, paternity or adoption leave, as time worked.
1.4 This policy does not form part of any employee’s contract of employment, and
we may amend it at any time.
2. Time off if you are pregnant
If you are pregnant, you may take reasonable paid time off during working hours
for antenatal appointments. You should try to give us as much notice as
possible of the appointment. Unless it is your first appointment, we may ask to
see a certificate confirming your pregnancy and an appointment card.
3. Time off for accompanying a pregnant woman: eligibility
You may take unpaid time off to accompany a pregnant woman to an antenatal
appointment if you have a “qualifying relationship” with the woman or the child.
This means that either:
3.1.1 you are the baby’s father.
3.1.2 you are the pregnant woman’s spouse, civil partner or cohabiting
partner; or
3.1.3 she has undergone assisted conception and at that time you were
her wife or civil partner or gave the required legal notices to be
treated in law as the second female parent; or
3.1.4 you are one of the intended parents in a surrogacy arrangement and
expect to obtain a parental order in respect of the child.
4. Time off for accompanying a pregnant woman: how to book time off
Please give us as much notice of the appointment as possible. You must
provide us with a signed statement providing the date and time of the
appointment and confirming:
4.1.1 that you meet one of the eligibility criteria in paragraph 3;
4.1.2 that the purpose of the time off is to accompany the pregnant woman
to an antenatal appointment; and
4.1.3 that the appointment has been made on the advice of a registered
medical practitioner, registered midwife or registered nurse.
5. Time off for accompanying a pregnant woman: amount of time off
5.1 You may take time off to accompany a pregnant woman to up to two antenatal
appointments in relation to each pregnancy.
5.2 You must not take more than six and a half hours off for each appointment,
including travel and waiting time.
5.3 Time off to attend these appointments is unpaid.
5.4 If you wish to take time off to attend further antenatal appointments, you should
request annual leave.
Time off for Dependants’ Policy
1. About this policy
1.1 The law recognises that there may be occasions when you need to take time
off work to deal with unexpected events involving one of your dependants.
1.2 This time off for dependants’ policy gives all employees the right to take a
reasonable amount of unpaid time off work to deal with certain situations
affecting their dependants.
1.3 There may be occasions when you will need to take time off work to provide or
arrange care for a dependant with a long care need. For more information see
our Carer’s Leave Policy.
1.4 No-one who takes time off in accordance with this policy will be subjected to
any detriment.
1.5 This policy does not form part of any employee’s contract of employment and
we may amend it at any time.
2. Reasonable unpaid time off
2.1 You have a right to take a reasonable amount of unpaid time off work when it
is necessary to:
2.1.1 provide assistance when a dependant falls ill, gives birth, is injured
or assaulted.
2.1.2 make longer-term care arrangements for a dependant who is ill or
injured;
2.1.3 take action required in consequence of the death of a dependant.
2.1.4 deal with the unexpected disruption, termination or breakdown of
arrangements for the care of a dependant (such as a child-minder
falling ill); and/or
2.1.5 deal with an unexpected incident involving your child while a school
or another educational establishment is responsible for them.
2.2 A dependant for the purposes of this policy is:
2.2.1 an employee’s spouse, civil partner, parent or child;
2.2.2 a person who lives in the same household as the employee, but who
is not their tenant, lodger, boarder or employee; or
2.2.3 anyone else who reasonably relies on the employee to provide
assistance, make arrangements or take action of the kind referred to
in paragraph 2.1.
2.3 This policy applies to time off to take action which is necessary because of an
immediate or unexpected crisis. This policy does not apply where you need to
take planned time off or provide longer-term care for a dependant. If this is the
case, you should take advice from your line manager.
2.4 Whether action is considered necessary will depend on the circumstances,
including nature of the problem, the closeness of the relationship between you
and the dependant, and whether anyone else is available to assist. Action is
unlikely to be considered necessary if you knew of a problem in advance but
did not try to make alternative care arrangements.
2.5 Reasonable time off in relation to a particular problem will not normally be more
than one day. However, we will always consider each set of circumstances on
their facts.
3. Exercising the right to time off
3.1 You will only be entitled to time off under this policy if, as soon as is reasonably
practicable, you tell your line manager:
3.1.1 the reason for your absence; and
3.1.2 how long you expect to be away from work.
3.2 If you fail to notify us as set out above, you may be subject to disciplinary
proceedings under our Disciplinary Procedure for taking unauthorised time off.
3.3 We may in some cases ask you to provide evidence for your reasons for taking
the time off, either in advance or on your return to work. Suspected abuse of
this policy will be dealt with as a disciplinary issue under our Disciplinary
Procedure.
Time off for Public Duties Policy
1. About this policy
1.1 We wish to enable employees to perform any public duties that they may be
committed to undertake and so will give them time off to do so where it does
not conflict with the operational needs of our business. We are not legally
obliged to grant paid leave for these purposes. The circumstances in which
we are prepared to do so are set out below.
1.2 This policy does not form part of any employee’s contract of employment and
we may amend it at any time.
2. Jury service
2.1 You should tell your line manager as soon as you are summoned for jury
service and provide a copy of your summons if requested.
2.2 Depending on the demands of our business we may request that you apply to
be excused from or defer your jury service.
2.3 We are not required by law to pay you while you are absent on jury service.
You will be advised at court of the expenses and loss of earnings that you can
claim.
3. Voluntary public duties
3.1 Employees are entitled to a reasonable amount of unpaid time off work to
carry out certain public duties, including duties as a tribunal member,
magistrate, local councillor, member of an NHS Trust, prison visitor, police
station lay visitor or school governor.
3.2 If you are unsure whether a public service that you perform is covered by this
policy you should speak to Human Resources.
3.3 As soon as you are aware that you will require time off for performance of a
public service you should notify your line manager in writing, providing full
details of the time off that is being requested and the reasons for your
request. In order that arrangements can be made to cover your duties in your
absence you should make your request in good time.
3.4 Each request for time off will be considered on its merits taking account of all
the circumstances, including how much time is reasonably required for the
activity, how much time you have already taken, and how your absence will
affect the business.
4. Reserve forces duties
4.1 We are aware that employees who are members of the Reserve Forces (the
Territorial Army, Royal Navy Reserve, Royal Marines Reserve or Royal
Auxiliary Air Force) may be called-up at any time to be deployed on full-time
operations and are expected to attend regular training.
4.2 We are under no obligation to offer leave (either paid or unpaid) for reservists
to undertake training and you should use existing holiday entitlement to meet
training commitments.
4.3 If we receive notice that you have been called-up for active service we may
apply to an adjudication officer for the notice to be deferred or revoked if your
absence would cause serious harm to our business (which could not be
prevented by the grant of financial assistance).
4.4 Once your military service has ended you may submit a written application for
reinstatement to your employment. This should be made by the third Monday
following the end of your military service and you should notify us of the date
on which you will be available to restart work.
4.5 If it is not reasonable and practicable to reinstate you into your former
employment we will offer you the most favourable alternative on the most
favourable terms and conditions which are reasonable and practicable.
Company Vehicle Policy
1. Purpose
1.1. This policy establishes guidelines for the use, maintenance, and allocation of
company vehicles and vehicle allowances, ensuring fairness, cost-effectiveness,
and adherence to legal requirements.
1.2. Company owned vehicles are defined as a Benefit in Kind (BIK) by the HMRC
when given to an employee. BIK tax rates are based on CO₂ emissions, fuel
type, and the vehicle’s list price. Employees should refer to the latest HMRC
guidance or consult Payroll for current tax rates.
1.3. Allowances are benefits paid monthly with salary and are subject to applicable
taxes. Employees allocated an allowance must provide proof of vehicle
ownership and comprehensive business-use insurance.
2. Eligibility for Company Vehicles or Allowance
2.1. Employees receiving a company vehicle or car allowance must hold a valid UK
driver’s license. Employees must inform the company immediately if their driving
license is suspended, revoked, or otherwise invalid.
2.2. If the employee loses his/her driving licence due to a motoring offence, no
monetary allowance will be paid in lieu of the provision of a Company car. The
company has the right to remove the use of a Company car or allowance if
necessary.
2.3. The company has the right to inspect driving licenses of staff and other
Company car drivers on a regular basis. Licence checks will be carried out
periodically by the company.
2.4. Employees who do not hold a valid UK driver’s license and whose
circumstances make a vehicle unnecessary may be eligible for a travel
allowance. Eligibility for the travel allowance will be assessed based on the
employee’s role and the need for regular travel.
2.5. Company vehicles or allowances are provided based on the employee’s role, job
requirements, and salary banding. Employees eligible for a company vehicle or
allowance include:
2.5.1. Executives and senior managers.
2.5.2. Employees requiring regular travel for business purposes.
2.5.3. Employees whose job descriptions necessitate frequent travel or client visits.
3. Vehicle Banding and Allowance Allocation
3.1. Company vehicle eligibility and allowances are determined by a tiered banding
system based on role and responsibilities.
3.2. The specific vehicle banding structure, corresponding allowances, and eligible
car types are maintained as an internal HR record. Employees may contact HR
for further information regarding their eligibility and options under this policy.
3.3. Employees opting for a company vehicle instead of an allowance will receive an
equivalent vehicle within their designated band, as determined by the company.
4. Vehicle Usage Guidelines
4.1. Company vehicles are intended primarily for business use. Limited personal use
is permitted, subject to applicable tax implications. Employees allocated a
company van must declare any personal use on their P11D. Employees with
electric or ultra-low-emission vehicles may be eligible for reduced BIK tax rates.
4.2. A company car may be driven by the employee and, with written approval, their
spouse, civil partner, partner, or immediate family members living in the same
household. Approval requires submitting their names, driving records, and other
relevant details, along with a signed declaration and valid driving licence. The
company does not cover provisional licence holders.
4.3. Employees must ensure vehicles are available for business use during working
hours.
5. Overseas Travel (applicable to company car and van drivers only):
5.1. Employees must get written approval from HR (email is acceptable) before
taking a company car overseas for business or personal use. For trips of two or
more weeks, at least one month’s notice is required. If a short, unplanned trip
arises, the employee must inform the CEO as soon as possible.
6. Company Vehicle Restrictions (applicable to company car and van drivers
only)
6.1. The company vehicle must not be used for:
6.1.1. Any business purposes outside of company-related work.
6.1.2. Transporting goods or passengers for hire or reward.
6.1.3. Racing, rally driving, or any competitive events.
6.1.4. Towing, unless the vehicle is designed for it.
6.2. The company may update its vehicle policies or withdraw the benefit at any time.
Employees eligible for a company vehicle will be informed of the maximum lease
value and the make, model, and colour provided to ensure suitability for
business use.
6.3. During the lease period, the company covers MOT, licensing, insurance,
maintenance, repairs, and servicing, except when damage is due to the
employee’s negligence. There is no automatic right to a replacement vehicle if
the company decides it is no longer needed.
6.4. The company retains all registration documents and ensures MOT, road tax, and
servicing are up to date. MOT and service appointments will be scheduled by the
fleet manager, but employees must track service dates based on the vehicle
logbook and mileage.
7. Maintenance and Upkeep:
7.1. Employees are responsible for ensuring company vehicles are clean, well-
maintained and meet all safety standards. Routine servicing and repairs must be
conducted as per manufacturer guidelines.
8. Fuel and Expense Reimbursement
8.1. Fuel cards will only be provided for commercial vehicles (vans). Employees must
submit monthly logs for reimbursement of business travel in personal vehicles.
8.2. Mileage rates for personal vehicles used for business purposes will be
reimbursed based on government guidelines and our expenses policy. For EVs
and plug-in hybrids, employees using home or public charging must submit
itemized receipts for reimbursement at HMRC-approved rates.
8.3. For more information, contact CFO, Victoria Allen,
(victoria.allen@duntonenvironmental.co.uk).
9. Insurance and Liability
9.1. All company vehicles will be insured under the company’s fleet insurance policy.
9.2. Employees using their own vehicles for business purposes must provide proof of
comprehensive insurance coverage that includes business use. Employees must
provide proof of insurance annually, and the company reserves the right to audit
policies at any time.
9.3. The employee will be responsible for any income tax and National Insurance
liability as assessed by HM Revenue & Customs in respect of the use of the
vehicle.
9.4. When any manufacture’s cover expires, the company will also arrange to provide
and pay for emergency breakdown/roadside assistance cover through a
motoring organisation selected by the company.
10. Damage and Accidents
10.1. Employees are responsible for any damage caused by negligence or wilful
default. They must pay the insurance excess for any accident, regardless of
fault, and the company may deduct repair or excess costs from wages with prior
notice. Employees at fault in an accident must complete a ROSPA Driver
Development Course, with a day’s pay deducted.
10.2. Employees cannot alter or install accessories (e.g., radios, tow bars).Personal
items left in the vehicle are at the employee’s own risk.
10.2.1. Employees must immediately report any of the following to the
company:
10.2.2. Vehicle defects, damage, theft, or loss.
10.2.3. Any road traffic accident, regardless of third-party involvement.
10.2.4. Traffic offences, licence endorsements, or disqualifications.
10.2.5. Any event making them ineligible to drive.
10.2.6. Theft or loss of the vehicle or serious accidents must also be reported
to the police.
10.3. Employees involved in an accident must gather key details, including:
10.3.1. Other parties’ details (name, contact, vehicle, employer if applicable).
10.3.2. Insurance details (company, policy number).
10.3.3. Witness details and police officer’s information.
10.3.4. Call emergency services if needed. Never admit liability at the scene.
10.4. Employees must provide a detailed written report, including date, time,
location, visibility, estimated speeds, statements made, and a diagram of the
accident.
10.5. Employees must always follow traffic laws, speed limits, parking regulations,
and ensure they are fit to drive.
11. Returning a Company Vehicle
11.1. Employees must return the company vehicle and keys to Head Office in the
following situations:
11.1.1. When their employment ends.
11.1.2. If they lose or no longer hold a valid driver’s license.
11.1.3. During any extended leave granted by the company.
11.1.4. If convicted of a careless, reckless, or dangerous driving offence (at the
company’s discretion).
11.1.5. If involved in an excessive number of accidents (as determined by the
company).
11.1.6. If they violate this policy or fail to use the vehicle responsibly.
11.1.7. If penalty points on their driving license result in an unacceptable
insurance cost increase.
11.2. If a vehicle is not returned when required, the company may deduct the
vehicle’s value from any outstanding pay, as outlined in the employee’s contract.
12. Vehicle Checks
12.1. Employees must ensure their vehicles are roadworthy by checking:
12.1.1. Tyres (tread and pressure).
12.1.2. Lights, brakes, oil, water coolant, fuel, screen wash, and battery.
12.1.3. Compliance with road traffic laws and insurance conditions.
13. Company Inspections:
13.1. Monthly checks will be carried out on company vehicles to ensure
compliance.
13.2. Logs will be maintained from vehicle issuance to collection.
13.3. Cash allowance vehicles will be subject to random checks.
14. Vehicle Tracking
14.1. The company may install satellite tracking systems in all company vehicles to
monitor location, distance, speed, and driving habits. Employees will be informed
if a monitoring device is installed and its purpose. Disabling monitoring is strictly
prohibited and will result in disciplinary action.
14.2. Tracking is used to:
14.2.1. Ensure compliance with Working Time Regulations 1998.
14.2.2. Promote safe driving and accident prevention.
14.2.3. Enhance performance, productivity, and customer service.
14.2.4. Improve fuel efficiency and fleet management.
14.2.5. Ensure lone driver safety in emergencies.
14.3. In some cases, legal obligations require permanent monitoring (e.g.,
tachographs in lorries). Data from monitoring may be used in disciplinary actions
if company policies are breached.
15. Fines
15.1. Employees are responsible for paying fines incurred for motoring offences,
such as speeding or parking violations.
15.2. Employees must provide their driving license for inspection upon request.
15.3. Failure to follow these rules or misuse of the vehicle may result in:
15.3.1. Withdrawal of vehicle privileges.
15.3.2. Disciplinary action, up to and including dismissal for serious breaches,
such as gross misconduct.
16. Driving and Mobile Phones
16.1. Employees are strictly prohibited from using hand-held phones or
smartwatches while driving. This includes:
16.1.1. Making or receiving calls.
16.1.2. Sending or reading messages, emails, or accessing the internet.
16.1.3. Using such devices at traffic lights, during traffic jams, or when the
engine is running.
17. Hands-Free Devices
17.1. Hands-free calls should only be made when necessary and safe. Even with
hands-free equipment, limit calls to essential matters.
17.2. Violation of this policy may lead to disciplinary action, including dismissal for
gross misconduct due to health and safety risks.
18. Health and Safety
18.1. Employees must not drive under the influence of alcohol, drugs, or any
substances that impair their ability to drive. This includes:
18.1.1. Being unfit to drive due to prescribed or over-the-counter medications.
18.1.2. Having alcohol or drug levels in the blood that exceed legal limits, even
if driving seems unaffected.
18.2. If you are taking medications that may cause drowsiness or affect your ability
to drive, inform your line manager or HR before driving.
18.3. Employees must notify the company of any medical condition that must be
reported to the DVLA.
18.4. To reduce accident risks:
18.4.1. Take regular breaks while driving.
18.4.2. Reverse Park your vehicle where possible to allow for a swift exit in
case of an emergency.
19. Non-Compliance
Failure to adhere to this policy may result in suspension or withdrawal of vehicle
privileges or allowances, and disciplinary action, up to and including termination of
employment.
—————————————————————————————————————-
———–
I (INSERT NAME) acknowledge receipt of this Company Vehicle policy and agree to
adhere to it.
Print Name……………………………………………………………………………..
Signed……………………………………………………………………………………..
Date………………………………………………………………………………………….
Whistleblowing Policy
1. About this policy
1.1 We are committed to conducting our business with honesty and integrity and
we expect all staff to maintain high standards. Any suspected wrongdoing
should be reported as soon as possible.
1.2 This policy covers all employees, officers, consultants, contractors, casual
workers and agency workers.
1.3 This policy does not form part of any employee’s contract of employment, and
we may amend it at any time.
2. What is whistleblowing?
Whistleblowing is the reporting of suspected wrongdoing or dangers in relation to our
activities. This includes bribery, facilitation of tax evasion, fraud or other criminal
activity, miscarriages of justice, health and safety risks, damage to the environment
and any breach of legal or professional obligations.
3. How to raise a concern
3.1 We hope that in many cases you will be able to raise any concerns with senior
management. However, where you prefer not to raise it with your manager for
any reason, you should contact either your Whistleblowing Officer, Human
Resources or Health and Safety. Contact details are at the end of this policy.
3.2 We will arrange a meeting with you as soon as possible to discuss your
concern. You may bring a colleague or union representative to any meetings
under this policy. Your companion must respect the confidentiality of your
disclosure and any subsequent investigation.
4. Confidentiality
We hope that staff will feel able to voice whistleblowing concerns openly under this
policy. Completely anonymous disclosures are difficult to investigate. If you want to
raise your concern confidentially, we will make every effort to keep your identity
secret and only reveal it where necessary to those involved in investigating your
concern.
5. Group Reporting
5.1 As a part of VINCI Group, we are obliged to inform all employees how to raise
an internal alert as per VINCI’s whistleblowing procedure. This allows a
concerned natural person to inform the Group of any proven or probable
infringement of applicable legal provisions and/ or rules set out by the Group.
5.2 An internal alert can relate to:
5.2.1 an infringement of VINCI Group’s Code of Ethics and Conduct or
Anti – Corruption Code of Conduct.
5.2.2 A proven or probable infringement on VINCI Group’s Guide on
Human rights.
5.2.3 A proven or probable infringement on VINCI Group’s Essential and
Fundamental Actions Concerning Occupational Health and Safety.
5.2.4 A proven or probable infringement of the VINCI Group’s
environmental commitments or serious impact on the environment.
5.2.5 A crime or other offence.
5.2.6 A threat or harm to the public interest.
5.3 On an employee’s induction, we will direct you to where you can access the
entity’s system. All employee’s will be able to access the Group’s
Whistleblowing platform. We will also provide further training to make staff
familiar with Group’s policies, procedure’s and systems in Whistleblowing.
6. External disclosures
6.1 The aim of this policy is to provide an internal mechanism for reporting,
investigating, and remedying any wrongdoing in the workplace. In most cases
you should not find it necessary to alert anyone externally.
6.2 The law recognises that in some circumstances it may be appropriate for you
to report your concerns to an external body such as a regulator. We strongly
encourage you to seek advice before reporting a concern to anyone external.
Protect operates a confidential helpline. Their contact details are at the end of
this policy.
7. Protection and support for whistle-blowers
7.1 We aim to encourage openness and will support whistle-blowers who raise
genuine concerns under this policy, even if they turn out to be mistaken.
7.2 Whistle-blowers must not suffer any detrimental treatment as a result of
raising a genuine concern. If you believe that you have suffered any such
treatment, you should inform Human Resources immediately. If the matter is
not remedied, you should raise it formally using our Grievance Procedure.
7.3 You must not threaten or retaliate against whistle-blowers in any way. If you
are involved in such conduct, you may be subject to disciplinary action.
7.4 However, if we conclude that a whistle-blower has made false allegations
maliciously, the whistle-blower may be subject to disciplinary action.
7.5 Protect operates a confidential helpline. Their contact details are at the end of
this policy.
8. Contacts
| Whistleblowing Officer | CEO
Neil Roe 07814 979 368 Neil.roe@duntonenvironmental.co.uk |
| Human Resources | James Hill, CSO, HR Director:
07814 977 461, james.hill@duntonenvironmental.co.uk Samuel Gellion, HR Assistant: 0121 356 4360/ samuel.gellion@duntonenvironmental.co.uk |
| Health and Safety | Christopher Gellion, Non-Executive Director (Dunton):
07487 763 779, Chris.Gellion@duntonenvironmental.co.uk Elizabeth Brittle, H&S Manager: 07977 143668, Elizabeth.Brittle@duntonenvironmental.co.uk |
| VINCI Group Reporting (Via Dunton website) | https://duntonenvironmental.com/business- ethics/
David Maltman, Menard Group Hse Coordinator David.maltman@vinci- construction.com |
| Protect
(Independent whistleblowing charity) |
Helpline: 020 3117 2520
E-mail: whistle@pcaw.co.uk Website: https://protect-advice.org.uk/ |
