Business Ethics Policy
1. Business Ethics Statement
There are certain foundations which good organisations have to anchor themselves to if they want their business to be both profitable and sustainable. These foundations relate to how we do business and the values that we associate with work, whether in the office, with clients or with our suppliers.
- Openness, Honesty and Integrity
- Respectfulness of others
- Respectfulness of our operating environment
- Protect our organisation
3. What these Mean in Practice
When we talk about openness, honesty and integrity, we mean that we ask questions if we don’t know the answers, we are not frightened to say what we are thinking, that we tell it like it is, and that we value our personal and business reputations within and outside the organisation through our relationships with others.
When we talk about fairness, we mean that we avoid or disclose and manage conflicts of interest in relationships both internally (for example during recruitment) and externally (for example in the way that we discuss our dealings with clients). It also means that we act with impartiality, making sound judgements on the basis of the facts available to us at the time. We do not allow personal relationships to shade our views or influence our decisions.
When we talk about respect for others, we mean that we show mutual respect for others, irrespective of their personal characteristics. We show concern and demonstrate courtesy and responsiveness to the needs of our colleagues.
When we talk about respect for our operating environment, we mean that we recognise the importance of the respective governments, cultures and laws of the lands in which we operate, and that we meet the regulations and procedures we are required to follow in each of those territories or jurisdictions.
When we talk about professionalism, we mean that we inspire confidence and trust in our abilities and performance through our actions and behaviours. We understand that we work in a competitive environment, but we do not engage in anti-competitive practices, we do not participate in bribery or corruption, we do not make false promises, and we maintain accurate books and records.
When we say we protect our organisation, we mean that we do not make reckless decisions that put the organisation at risk, we protect our information and assets, we safeguard quality, and recognise our duty to safeguard the best interests of our customers, both now and in future. We also mean that we will protect our employees, partners, and suppliers from illegal or damaging actions by others.
4. How We Apply These Values
Throughout the Handbook, you will see a variety of policies relating to equal opportunities, harassment and bullying, sickness, maternity and paternity, flexible working, data protection and information security, health, safety and the environment.
The Handbook also contains information on how to raise concerns (through the Whistleblowing Policy) and the actions we will take to address any matters (through Discipline or Grievance Policies).
Asking Questions and Raising ConcernsIf you are in any doubt about these values, about any course of action, or if you have a concern that someone is behaving in a manner which does not reflect these values, you should discuss the matter with you manager, with the Managing Director, or with the Independent HR Consultant. Further details can be found in the whistleblowing policy.
Equal Opportunities Policy
1. Equal opportunities statement
We Are Creation 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. This policy covers all employees, officers, consultants, contractors, casual workers and agency workers.
2.3. This policy does not form part of any employee’s contract of employment and we may amend it at any time.
3. Who is responsible for this policy?
3.1. Our board of directors (the board) has overall responsibility for the effective operation of this policy and for ensuring compliance with discrimination law.
3.2. All managers must set an appropriate standard of behaviour, lead by example and ensure that those they manage adhere to the policy and promote our aims and objectives with regard to equal opportunities. Managers will be given appropriate training on equal opportunities awareness and equal opportunities recruitment and selection best practice.
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:
- 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.
- 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.
- Harassment: this includes sexual harassment and other unwanted conduct related to a Protected Characteristic, which has the purpose or effect of violating someone’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. Harassment is dealt with further in our Anti-harassment and Bullying Policy.
- Victimisation: retaliation against someone who has complained or has supported someone else’s complaint about discrimination or harassment.
- 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.
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 and with the involvement of the Human Resources Department, where possible. Our recruitment procedures should be reviewed regularly to ensure that individuals are treated on the basis of their relevant merits and abilities.
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. We take steps to ensure that our vacancies are advertised to a diverse labour market.
5.4. 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.
5.5. Job applicants should not be asked about health or disability before a job offer is made. There are limited exceptions which should only be used with the approval of a Director. For example:
- Questions necessary to establish if an applicant can perform an intrinsic part of the job (subject to any reasonable adjustments).
- Questions to establish if an applicant is fit to attend an assessment or any reasonable adjustments that may be needed at interview or assessment
- Positive action to recruit disabled persons.
- Equal opportunities monitoring (which will not form part of the selection or decision-making process).
Where necessary, job offers can be made conditional on a satisfactory medical.
5.6. We are required by law to ensure that all employees are entitled to work in the UK. Assumptions about immigration status should not be made based on appearance or apparent nationality. All prospective employees, regardless of nationality, must be able to produce original documents (such as a passport) before employment starts, to satisfy current immigration legislation. The list of acceptable documents is available from UK Visas and Immigration.
5.7. To ensure that this policy is operating effectively, and to identify groups that may be underrepresented or disadvantaged in our organisation, we monitor applicants’ ethnic group, gender, disability, sexual orientation, religion and age as part of the recruitment procedure. Provision of this information is voluntary, and it will not adversely affect an individual’s chances of recruitment or any other decision related to their employment. The information is removed from applications before shortlisting and kept in an anonymised format solely for the purposes stated in this policy. Analysing this data helps us take appropriate steps to avoid discrimination and improve equality and diversity.
6. Training and promotion and conditions of service
6.1. Training needs will be identified through regular appraisals. You will be given appropriate access to training to enable you to progress within the organisation and all promotion decisions will be made on the basis of merit.
6.2. Our conditions of service, benefits and facilities are reviewed regularly to ensure that they are available to all of you who should have access to them and that there are no unlawful obstacles to accessing them.
7. Termination of employment
7.1. We will ensure that redundancy criteria and procedures are fair and objective and are not directly or indirectly discriminatory.
7.2. We will also ensure that disciplinary procedures and penalties are applied without discrimination, whether they result in disciplinary warnings, dismissal or other disciplinary action.
8.1. If you are disabled or become disabled, we encourage you to tell us about your condition so that we can support you as appropriate.
8.2. If you experience difficulties at work because of your disability, you may wish to contact a Director to discuss any reasonable adjustments that would help overcome or minimise the difficulty. Your Director may wish to consult with you and your medical adviser about possible adjustments. We will consider the matter carefully and try to accommodate your needs within reason. If we consider a particular adjustment would not be reasonable we will explain our reasons and try to find an alternative solution where possible.
8.3. We will monitor the physical features of our premises to consider whether they might place anyone with a disability at a substantial disadvantage. Where necessary, we will take reasonable steps to improve access.
9. Part-time and fixed-term work
Part-time and fixed-term staff should be treated the same as comparable full-time or permanent staff and enjoy no less favourable terms and conditions (on a pro-rata basis where appropriate), unless different treatment is justified.
10. Breaches of this policy
10.1. 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.
10.2. If you believe that you have suffered discrimination you can raise the matter through our Grievance Procedure or through our Anti-harassment and Bullying Policy as appropriate. Complaints will be treated in confidence and investigated as appropriate.
10.3. There must be no victimisation or retaliation against staff who complain about discrimination. However, making a false allegation deliberately and in bad faith will be treated as misconduct and dealt with under our Disciplinary Procedure.
1. Modern Slavery Statement
We Are Creation will not directly or knowingly through the supply chain in any activity that might be interpreted or considered to be modern slavery.
Modern slavery is a term that covers a wide variety of activities. The UK Legislation passed in 2015 requires all companies with a turnover in excess of £36m to take reasonable steps to investigate and act upon modern slavery within its supply chain. As such, this piece of legislation has a cascading effect.
In particular, organisations engaged in the supply chain of these organisations (including We Are Creation and our suppliers) must be able to demonstrate that we do not either directly, or through the supply chain:
- Employ or engage any person in slavery or servitude;
- Engage a worker in forced or compulsory labour;
- Arrange or facilitate travel for the purposes of exploitation;
- Engage in force, threats or deception; and/or
- Aid, abet, counsel or procure an offence under the Modern Slavery Act.
3. What these Mean in Practice
We treat our employees fairly and reasonably, allowing employees to receive a fair day’s pay in return for a fair day’s work, knowing that they chose to work for us, and that they are not exploited or threatened.
When we engage with suppliers we do so having established whether they are a fair supplier, and one that complies with the same standards expected of us. In particular, we recognise that a breach of these rules within our supply chain has the potential to cause serious harm to our reputation and the reputation of our customer.
4. How We Apply These Values
Our suppliers are an extension of our own service offering and as such, they are important partners, providing both solutions and risks. We expect our suppliers to welcome the opportunity to work with us and to benefit from the opportunities we present, but we also expect them to declare any risks that may be inherent in their solutions.
An important part of this is the supplier audit and approval process. We expect all of our suppliers to go through a process of supplier audit and approval and to work with us in the same open and professional way that we seek to deal with them.
1. Supplier relationships statement
In the eyes of our customers, we are who we work with, their standards are our standards and their failings are our failures.
Both Company legislation and the demands of society are requiring larger businesses to adopt a more demanding approach to procurement of goods and services and this is producing a cascading effect on their wider supply chain.
As an organisation We Are Creation relies on the re-assurances provided by our suppliers to meet the increasingly demanding and challenging needs of our customers.
Some of our high-profile customers are introducing penalty clauses associated with reputational damage they suffer as a consequence of our activities. This means that as an organisation we have to adopt a robust approach to supplier approval.
We have an obligation to protect our own business, and the business of our customers by meeting the standards and expectations placed on them and us, and through our supply chain. We expect our suppliers to understand and to support us in the fulfilment of this obligation.
The standards cover four areas but are topped and tailed with process to ensure internal and cascading compliance, assigned individuals responsible for ensuring compliance, processes for ensuring that this information is communicated effectively, and mechanisms for addressing any failings.
The four areas are:
- Human Resources;
- Health and Safety;
- Business Ethics; and
- The Environment.
3. What these mean in practice
For Human Resources, it means that organisations have considered, and where appropriate, adopted standards in relation to:
- Modern Slavery;
- Freedom of association and/or collective bargaining;
- Living accommodation or other benefits;
- Children or young workers;
- Regular Employment;
- Discipline and Grievance;
- Homeworkers or smallholders; and
- Human Rights.
For Health and Safety, it means that organisations have, and can provide evidence they have:
- A written policy statement;
- Considered significant risks;
- Established emergency procedures;
- Implemented training;
- Identified hazardous materials;
- Established health surveillance (where appropriate); and
- Implemented adequate housekeeping, hygiene and welfare arrangements.
For Business Ethics, it means organisations have, and can provide evidence they:
- Considered business risks;
- Implemented processes around fair competition;
- Protect confidentiality; and
- Prevent Bribery and Corruption.
For the Environment, it means organisations have, and can provide evidence they have:
- A written policy statement;
- Considered biodiversity, emissions, energy, climate change, pollution, raw material selection, renewable energy, water, and waste;
- Identified the impact of their activities; and
- Are actively seeking to reduce their impact on the environment.
4. Systems and processes
Each of these standards should be evaluated individually, but it is equally important that suppliers can evidence that they have:
- Processes to ensure internal compliance;
- Processes to ensure that their suppliers meet similar standards;
- Assigned individuals responsible for on-going compliance;
- Processes for ensuring that this information is communicated effectively, and
- Mechanisms for addressing any failings, such as a Whistleblowing or raising concerns policy, or some other mechanism.
As a part of the review exercise, suppliers must also declare any sanctions that they have received as a consequence of non-compliance with any of these standards and the actions that they have taken to address them.
Data protection policy
1. Policy statement
1.1. Everyone has rights with regard to how their personal information is handled. During the course of our activities we will collect, store and process personal information about our staff, customers, suppliers and other third parties. We recognise the need to collect, process, store and destroy information in an appropriate and lawful manner.
1.2. Any breach of this policy will be taken seriously and may result in disciplinary action.
2. About this policy
2.1. The types of information that we may be required to handle include details of current, past and prospective employees, suppliers, customers, and others that we communicate with. The information is subject to certain legal safeguards specified in the Data Protection Act 2018 (the Act) and other regulations. The Act imposes restrictions on how we may use that information.
2.2. This policy does not form part of any employee’s contract of employment and may be amended at any time.
2.3. The Data Protection Officer is responsible for overseeing data protection strategy and implementation to ensure compliance with data requirements, including ensuring compliance with the Act and with this policy. That post is held by Alex Miller. Any questions or concerns about the operation of this policy should be referred in the first instance to the Data Protection Officer.
2.4. If you consider that the policy has not been followed in respect of personal data about yourself or others, you should raise the matter with your line manager or the Data Protection Officer.
3. Definition of data protection terms
3.1. Personal data means any information relating to an identifiable person who can be directly or indirectly identified by reference to an identifier.
3.2. This definition provides for a wide range of personal identifiers to constitute personal data, including name, identification number, location data or online identifier, reflecting changes in technology and the way organisations collect information about people.
3.3. The GDPR applies to both automated personal data and to manual filing systems where personal data are accessible according to specific criteria. This could include chronologically ordered sets of manual records containing personal data.
3.4. Personal data that has been pseudonymised – e.g. key-coded – can fall within the scope of the GDPR depending on how difficult it is to attribute the pseudonym to a particular individual.
3.5. Special category (sensitive) personal data includes information about an individual’s: race; ethnic origin; politics; religion; trade union membership; genetics; biometrics (where used for ID purposes); health; sex life; or sexual orientation. We Are Creation will not hold sensitive personal data unless it specifically relates to an individual’s ability to perform a role.
3.6. Sensitive personal data can only be processed under strict conditions and will usually require the express consent of the person concerned.
4. Data protection principles
4.1. Anyone processing personal data must comply with the six enforceable principles of good practice. These provide that personal data must be:
- processed lawfully, fairly and in a transparent manner in relation to individuals;
- collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving, historical research or statistical purposes shall not be considered to be incompatible with the initial purposes;
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
- kept in a form which permits identification of Individuals for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
4.2. We Are Creation, as the controller, shall be responsible for, and must be able to demonstrate, compliance with the principles
5. Fair and lawful processing
5.1. The Act is intended not to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the individual. The Individual must be told who the data controller is (in this case We Are Creation, who the data controller’s representative is (in this case the Data Protection Officer), the purpose for which the data is to be processed, and the identities of anyone to whom the data may be disclosed or transferred.
5.2. For personal data to be processed lawfully, at least one of specified condition must be met. These may include, among other things, contract (for example the payment of salaries), legal obligations (for example the payment of income tax and national insurance payments), to protect your vital interests (for example your next of kin or certain medical information relating to allergies), to meet our legitimate interests (for example holding information about your knowledge, skills and experience so that we can ensure that the assignments we give to you are within your capabilities).
5.3. Examples of when special category (sensitive) personal data of staff is likely to be processed are set out below:
- information about an employee’s physical or mental health or condition in order to monitor sick leave and take decisions as to the employee’s fitness for work;
- the employee’s racial or ethnic origin or religious or similar information in order to monitor compliance with equal opportunities legislation;
- in order to comply with legal requirements and obligations to third parties.
6. Processing for limited purposes
Personal data will only be processed for the specific purposes notified to the Individual when the data was first collected or for any other purposes specifically permitted by the Act. This means that personal data will not be collected for one purpose and then used for another. If it becomes necessary to change the purpose for which the data is processed, the Individual will be informed of the new purpose before any processing occurs.
7. Adequate, relevant and limited processing
Personal data will only be collected to the extent that it is required for the specific purpose notified to the Individual. Any data which is not necessary for that purpose will not be collected in the first place.
8. Accurate and up to date data
Personal data will be accurate and kept up to date. Information which is incorrect, or misleading is not accurate, and steps will therefore be taken to check the accuracy of any personal data at the point of collection and at regular intervals afterwards. Inaccurate or out-of-date data will be destroyed.
9. Data retention
Personal data will not be kept longer than is necessary for the purpose. This means that data will be destroyed or erased from our systems when it is no longer required. For guidance on how long certain data is likely to be kept before being destroyed, contact the Data Protection Officer.
10. Data security
10.1. We will ensure that appropriate security measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.
10.2. The Act requires us to put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. Personal data may only be transferred to a third-party data processor if he agrees to comply with those procedures and policies, or if he puts in place adequate measures himself.
10.3. Maintaining data security means guaranteeing the confidentiality, integrity and availability of the personal data, defined as follows:
- Confidentiality means that only people who are authorised to use the data can access it.
- Integrity means that personal data should be accurate and suitable for the purpose for which it is processed.
- Availability means that authorised users should be able to access the data if they need it for authorised purposes. Personal data should therefore be stored on our central computer system instead of individual PCs.
10.4. Security procedures include:
- Entry controls. Any stranger seen in entry-controlled areas should be reported.
- Secure lockable desks and cupboards. Desks and cupboards should be kept locked if they hold confidential information of any kind. (Personal information is always considered confidential.)
- Methods of disposal. Paper documents should be shredded. Floppy disks and CD-ROMs should be physically destroyed when they are no longer required.
- Equipment. Data users should ensure that individual monitors do not show confidential information to passers-by and that they log off from their PC when it is left unattended.
11. Subject access requests
A formal request from an Individual for information that we hold about them must be made in writing. Any member of staff who receives a written request should forward it to the Data Protection Officer immediately.
12. Providing information to third parties
Any member of staff dealing with enquiries from third parties should be careful about disclosing any personal information held by us. In particular, they should:
- they are legally entitled to receive the information they have requested.
- Suggest that the third party put their request in writing so the third party’s identity and entitlement to the information may be verified.
- Refer to the Data Protection Officer for assistance in difficult situations.
- Where providing information to a third party, do so in accordance with the eight data protection principles.
Health and safety policy
1. About the policy
1.1. We are committed to ensuring that the management and operation of health and safety is not only effective but is also continually improving. This statement of intent demonstrates a commitment to comply with all relevant legal and other requirements to which We Are Creation subscribes.
1.2. This document will be reviewed annually, or in light of inadequacies, changes to Legislation or ‘best practice’, requirements of other bodies (including professional bodies, landlord, customers and awarding bodies), changes within the We Are Creation or incidents that may have occurred.
1.3. We Are Creation recognises its responsibilities and is committed to comply with the Health and Safety at Work etc. Act 1974 to ensure so far as it is reasonably practicable, the health, safety and welfare of its employees, others who may be affected by We Are Creation’s activities and users of its manufactured products and premises.
1.4. The Director accepts this duty and attaches the greatest importance to these matters, considering that safety is a management responsibility at least equal to that of any other function. The management commits to provide adequate financial and physical resources for health and safety.
1.5. The Director is committed to ensuring that all We Are Creation activities comply (or exceed) current applicable legislation and are continuously improving. In addition, the Director will keep up to date with changes to industry best practice and manufacturers’ recommendations through their extensive contacts within the industry. To help achieve this, We Are Creation will allocate the necessary resources and enlists the support of employees upon whom duties are also imposed by the Health and Safety at Work etc. Act 1974.
1.6. The Director believes that given the co-operation of the employees, it is possible to conduct operations in such a way that injury to employees and loss or damage to property can be eliminated.
1.7. To achieve this, We Are Creation will continue to: make available safety training, instruction, information and supervision; participate in joint consultation; provide adequate control of the health and safety risks arising from work activities; provide safe plant and equipment and ensure safe handling and use of substances where applicable. to ensuring the health and safety of staff and anyone affected by our business activities, and to providing a safe and suitable environment for all those attending our premises.
1.8. This policy does not form part of any employee’s contract of employment and we may amend it at any time. We will continue to review this policy to ensure it is achieving its aims.
2. Your responsibilities
2.1. All staff share responsibility for achieving safe working conditions. You must take care of your own health and safety and that of others, observe applicable safety rules and follow instructions for the safe use of equipment.
2.2. You should report any health and safety concerns immediately to your line manager.
2.3. You must co-operate with managers on health and safety matters, including the investigation of any incident.
2.4. Failure to comply with this policy may be treated as misconduct and dealt with under our Disciplinary Procedure.
3. Information and consultation
3.1. We will inform and consult directly with all staff regarding health and safety matters.
3.2. We will ensure any health and safety representatives receive the appropriate training to carry out their functions effectively.
4.1. We will ensure that you are given adequate training and supervision to perform your work competently and safely.
4.2. Staff will be given a health and safety induction and provided with appropriate safety training.
5.1. You must use equipment in accordance with any instructions given to you. Any equipment fault or damage must immediately be reported to your line manager.
5.2. No member of staff should attempt to repair equipment unless trained to do so.
6. Accidents and first aid
6.1. Details of first aid facilities and the names of trained first aiders are displayed on the notice boards.
6.2. All accidents and injuries at work, however minor, should be reported to the Managing Director and recorded in the Accident Book.
6.3. The Managing Director is responsible for investigating any injuries or work-related disease, preparing and keeping accident records, and for submitting reports to the relevant authorities if required under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR).
7. Fire Safety
7.1. All staff should familiarise themselves with the fire safety instructions, which are displayed on notice boards and near fire exits in the workplace.
7.2. If you hear a fire alarm, leave the building immediately by the nearest fire exit and go to the fire assembly point shown on the fire safety notices. Do not stop to collect belongings. Do not re-enter the building until told to do so.
7.3. If you discover a fire do not attempt to tackle it unless it is safe, and you have been trained or feel competent to do so. You should operate the nearest fire alarm and, if you have sufficient time, call reception and report the location of the fire.
7.4. Nominated individuals will be trained in the correct use of fire extinguishers.
7.5. You should notify your manager if there is anything (for example, impaired mobility) that might impede your evacuation in the event of a fire. A personal evacuation plan will be drawn up and brought to the attention of colleagues working in your vicinity.
7.6. Fire drills will be held at least every 12 months and must be taken seriously.
7.7. The Managing Director is responsible for ensuring fire risk assessments are undertaken and implemented, and for ensuring regular checks of fire extinguishers, fire alarms, escape routes and emergency lighting.
8. Risk assessments and measures to control risk
8.1. We carry out general workplace risk assessments periodically. The purpose is to assess the risks to health and safety of employees, visitors and other third parties as a result of our activities, and to identify any measures that need to be taken to control those risks.
8.2. Measures will be taken to avoid or reduce the need to lift or carry items which could cause injury (manual handling) and to provide training on manual handling as necessary.
8.3. The use of hazardous substances at work will be avoided wherever possible and less hazardous alternatives will be used where available. Training on the control of substances hazardous to health (COSHH) will be provided where it is deemed necessary.
9. Computers and display screen equipment
9.1. If you use a computer screen or other display screen equipment (DSE) habitually as a significant part of your work:
- You should try and organise your activity so that you take frequent short breaks from looking at the screen.
- You are entitled to a workstation assessment.
- You are entitled to an eyesight test by an optician at our expense.
9.2. You should contact your line manager to request a workstation assessment or an eye test. Eye tests should be repeated at regular intervals as advised by the optician, usually every two years. However, if you develop eye problems which may be caused by DSE work (such as headaches, eyestrain, or difficulty focusing) you can request a further eye test at any time.
9.3. We will not normally pay for glasses or contact lenses, unless your vision cannot be corrected by normal glasses or contact lenses and you need special glasses designed for the display screen distance. In such cases we will pay the cost of basic corrective appliances only.
10. Policy statement
10.1. We are committed to minimising our environmental impact across all aspects of our operations. This means that we consider the environmental implications of our business and manage our business in an environmentally responsible way. In doing so, we can remain compliant with the law, improve cost control, conserve raw materials and energy, and support the sustainability of our business and the communities in which we operate.
10.2. This policy sets out our arrangements in relation to:
- our legal obligations;
- our business decisions and the effect they have on the local and wider community;
- raw material and energy conservation; and
- through the efficiency of our operations.
10.3. We will continue to review this policy to ensure it is achieving its aims.
11. Responsibility for environmental matters
11.1. Our board of directors (the board) has overall responsibility for health and safety and the operation of this policy. Alex Miller has day-to-day responsibility for environmental matters.
12. Your responsibilities
12.1. All staff share responsibility for their impact on the environment and the communities in which we, as an individual, as an organisation, and throughout our supply chain operate.
12.2. You should report any environmental concerns immediately to your line manager at your earliest opportunity.
12.3. You must co-operate with managers on environmental matters, including any appropriate investigations.
12.4. You must take reasonable steps to remain up to date with current thinking in so far as how current trends in environmental performance and management affect your role.
12.5. This policy does not form part of any employee’s contract of employment. However, failure to comply with this policy may be treated as misconduct and dealt with under our Disciplinary Procedure.
13. Our Legal Operations
13.1. We are committed to ensuring that we fulfil our own legal obligations relating to the environment. Specifically, these relate to:
- the selection of raw materials, particularly when products are sourced from overseas;
- the handling (including the collection, disposal, and treatment) of waste;
- steps to minimise waste and the prevention of litter;
- nature conservation.
14. Our Business Decisions
14.1. We work closely with our clients and suppliers to select the most effective source of materials, based on product design, sourcing, and manufacture.
14.2. Where it is appropriate to do so, we work with our suppliers and provide drawings in a manner that enables them to most effectively construct and configure production processes to minimise environmental impact.
14.3. We work with our clients on design and sourcing decisions, maximising where possible the sourcing of products from UK operations for UK markets, reducing carbon footprints, and supporting UK operations.
14.4. We will not knowingly engage with organisations that have a poor record when it comes to environmental performance or pollution.
15. Raw Material and Energy Conservation
15.1. We work hard to provide a balance between high quality, fit for use products, and the environmental costs and impact of their production.
15.2. In the way that we carry out our work, we adopt a sensible and sensitive approach to the environment, minimising the use of resources where possible.
15.3. In our print products, we ensure that our suppliers:
- Use modern technology to reduce set up time, costs and wastage.
- Commit to minimise any waste that they produce and ensure that waste generated from their operations is disposed of responsibly and recycled where possible.
- Use vegetable-based inks to provide a sustainable approach to the environment.
- Utilise the most efficient production processes to reduce waste, for example through the avoidance of ink cartridges.
- Use recycled and Forestry Stewardship Council (FSC) certified paper, and support other environmental programmes, where possible.
- Operate an Environment Management System such as ISO 14001 to ensure that these commitments are embedded in their day to day operations.
15.4. In our non-print products, we ensure that our suppliers:
- Use modern technology to reduce set up time, costs and wastage.
- Understand the environmental risks and hazards posed by their operations and address those risks accordingly.
- Conform with appropriate national guidelines relating to the use of materials, processes and operations.
16. Operational Efficiency
16.1. We work hard to provide a balance between high quality, fit for use products, and the environmental costs and impact of their production.
16.2. In the way that we carry out our work, we adopt a sensible and sensitive approach to the environment, minimising the use of resources where possible.
17. Continuous Improvement
17.1. We will review this policy from time to time to ensure that it remains relevant and reflect current practice in environmental management in so far as it relates to our industry, and the industries of our clients and suppliers.
17.2. We will set performance targets and measure performance against those targets as far as possible to ensure that we are effectively managing our impact on the environment, not least in relation to energy use.
17.3. All employees will be encouraged to participate and engage in environmental matters.