Fair and Equal Pay Policy
E.A.T.O.W (“the Company”) is committed to the principle of equal pay for like work, work of equal value and work rated as equivalent for all its employees and understands that equal pay between men and women is a legal right under both UK and European law.
This policy does not form part of any employee’s contract of employment and the Company may amend it at any time.
Equal Pay Statement
The Company supports the principle of equality of opportunity for all staff. It recognises the importance of, and is committed to, providing a fair, objective and transparent pay system which is free from gender bias. As good business practice and in the interests of equity and fairness the company is committed to taking action to ensure that it provides equal pay for men and women for like work, work of equal value and work rated as equivalent.
Pay, therefore, includes access to, and level of benefits under, occupational pension schemes, contractual and discretionary bonuses and sick pay as well as any other additional benefits.
The relevant legislation concerning equal pay is: Equal Pay Act 1970, Equal Pay (Amendment) Regulations 1983, Pensions Act 1995, Sex Discrimination (Public Authorities) (Statutory Duties) (Scotland) Order 2007 and the Equality Act 2010. The rights under this legislation apply to all employees of the Company whether full or part-time, on temporary, fixed-term or permanent contracts.
The Company’s objectives relating to equal pay are to:
To achieve these objectives the Company will:
The Company will:
Decisions on initial placing of new staff on incremental salary scales will be taken by one of the Company Partners.
This policy will be reviewed on an annual basis.
We store and process data only as agreed by the client or as required in order to perform services requested by the client. We regard all details we do store as confidential.
We do not engage in any profiling activities.
We never share data with 3rd parties (e.g. for advertising, marketing, data analysis or similar).
Data we hold will consist solely of information that you provide to us (e.g. contact details you enter on forms or correspondence), or is determined through your direct interaction with our website (e.g. your IP address).
Your name. Company name (if applicable). Postal address. Country. Email addresses (if applicable). Telephone number (if applicable).
This is used so that we can contact you when needed (e.g. to send invoices, certificates you have requested, communicate information affecting your account or our service to you, etc.)
Payee name. Billing contact details (if applicable). Card type (e.g. Amex, Visa) (card payments only). Last 4 digits of payment card (card payments only). Date and amount of payments.
This data is kept purely to allow cross-checking in the event of accounting imbalance, customer payment enquiries or investigation by tax authorities (i.e. mandatory accounting requirements).
Information you supply relating to works you have lodged with us (i.e. copyright ownership and work titles).
Enquiries we have received via email, web-form or post.
We may also store your IP address for security reasons and to enable us to investigate technical problems if you experience a fault whilst using our site.
We retain personal data that you supply for as long as you are a client with an active account, and for as long as we are legally required to do so (e.g. by tax and accounting regulations).
Where data may exist on back-ups, these are regularly changed and expired files (etc.) are securely disposed of when backup media is expired or replaced.
General enquiries via web-form, email or post:
If you are a client and have need to check any information we hold about you, or need to correct inaccurate information, please contact our administration department.
For security reasons we will need to ensure that you are the account holder (and may ask you to provide proof of your identity) before we can release any information.
If you decide that you no longer need our services and want the data we hold to be deleted, you may cancel your account at any time and we will remove your data once we are legally able to do so.
(Note: for VAT invoices, and other financial records, there is a minimum retention period of 6 years specified under Paragraph 6, Schedule 11 of VAT Act 1994 and HMRC Notice 700/21 (December 2007), point 2.4. ).
If you are not a client, but have contacted us via email/letter, and want any emails, letters, or form submissions enquiries you have made erased please contact our administration team and we will be happy to arrange that.
Please note: for security reasons you must contact us from the address you want removed and we may ask you to prove your identity (i.e. you cannot delete someone else’s data without their consent).
If you take no action, your data will be securely disposed of automatically in due course as part of our routine maintenance activities.
If you have any questions or concerns about information, we hold about you, or need to correct inaccurate information, please contact our administration department
E.A.T.O.W is committed to ensuring the wellbeing of all employees. It is recognised that work has an impact on the mental and physical health of employees, and E.A.T.O.W is committed to making that a positive commitment.
Effective employee wellbeing will be achieved by:
Requests for Career Breaks and Sabbaticals
Providing Medical Assistance to Employees and Promoting Healthy Options
To promote the health of all employees E.AT.O.W will do the following.
Encouraging Employee Fitness
To promote exercise and fitness [name of organisation] will do the following.
Promoting Dignity at Work
E.A.T.OW believes that all employees should be able to work without fear of being harassed or distressed by their colleagues, customers or other contacts in the workplace.
Minimising the Stressful Impacts of Work
Managing Sickness Absence Effectively
This is the anti-slavery policy of E.A.T.O.W
1. POLICY STATEMENT
2. RESPONSIBILITY FOR THIS POLICY
3. COMPLIANCE WITH THIS POLICY
4. COMMUNICATION AND AWARENESS OF THIS POLICY
4.1 Guidance on this policy forms part of the induction process for all individuals who work for us and will be provided otherwise as necessary.
5. BREACHES OF THIS POLICY
Our professional code of ethics policy aims to give our employees guidelines on our business ethics and stance on various controversial matters. We trust you to use your better judgment, but we want to provide you with a concrete guide you can fall back on if you’re unsure about how you should act (e.g. in cases of conflict of interest). We will also use this policy to outline the consequences of violating our business code of ethics.
This policy applies to everyone we employ or have business relations with. This includes individual people such as employees, interns, volunteers, but also business entities, such as vendors, enterprise customers or venture capital companies.
Note that our code of ethics is slightly different than our code of conduct. Code of conduct may include elements such as dress code and social media use, whilst our code of professional ethics refers to legally or morally charged issues. Still, these two codes do overlap.
First, let’s define professional ethics: they are a set of principles that guide the behavior of people in a business context. They are essential to maintaining the legality of business and a healthy workplace.
So what is a code of ethics? Our code of ethics definition refers to the standards that apply to a specific setting – in this case, our own organization.
Having our business ethics in writing doesn’t mean that we don’t trust our employees. We strive to hire ethical people who have their own personal standards, so we expect that a written code won’t be necessary most of the time.
But, it can still be helpful. You may find yourself in a situation where you’re not sure how you should act. Life is full of grey areas where right and wrong aren’t so apparent. Some professional ethics also correspond to laws that you absolutely must know to do your job properly, so we will mention them in our code of ethics.
Additionally, every organization makes bad hires every once in a while. We also can’t predict how people are going to behave. When an employee behaves, or intents to behave, in a way that’s against our professional ethics, or applicable laws, we will have clear guidelines on what disciplinary actions we will consider.
For these reasons, we advise you to read this document carefully and consult with your manager or HR, if you have doubts or questions.
We base our business code of ethics on common principles of ethics [Note: Modify this list based on your own organization’s values]:
Here’s a more detailed overview of our code:
It’s mandatory to respect everyone you interact with. Be kind, polite and understanding. You must respect others’ personal space, opinions and privacy. Any kind of violence is strictly prohibited and will result in immediate termination. You’re also not allowed to harass or victimize others.
What constitutes harassment or victimization? To answer this, we have a policy on harassment and a more specific policy on sexual harassment you can take a look at. As a general rule, try to put yourself in someone else’s place. How would you feel if someone behaved a specific way to you? If the answer is “I wouldn’t like it much” or “I would never let them behave like that to me”, then we don’t tolerate this behavior no matter the person it comes from.
If someone, be it customer, colleague or stakeholder, is offensive, demeaning or threatening toward you or someone you know, report them immediately to HR or your manager. You can also report rudeness and dismissiveness if they become excessive or frequent.
First, always keep in mind our organization’s mission. We all work together to achieve specific outcomes. Your behavior should contribute to our goals, whether financial or organizational.
Be honest and transparent when you act in ways that impact other people (e.g. taking strategic decisions or deciding on layoffs). We don’t tolerate malicious, deceitful or petty conduct. Lies and cheating are huge red flags and, if you’re discovered, you may face progressive discipline or immediate termination depending on the damage you did.
Stealing from the company or other people is illegal. If you’re caught, you will face repercussions depending on the severity of your actions. For example, if you steal office supplies, you may receive a reprimand or demotion (at a minimum), while if you steal money or data (e.g. engaging in fraud or embezzlement), you will get fired and face legal consequences. The decision is at HR’s discretion on a case-by-case basis.
Conflict of interest may occur whenever your interest in a particular subject leads you to actions, activities or relationships that undermine our company. This includes situations like using your position’s authority for your own personal gain or exploiting company resources to support a personal money-making business. Even when you seemingly act to the company’s advantage, you may actually disadvantage it. For example, if an employee uses dubious methods to get competitor intel and raise their sales record, their action will have a positive impact on the company’s revenue, but it will put us at a legal risk and promote unhealthy business practices.
If it turns out you have created a conflict of interest for yourself, you will be terminated. If the conflict of interest was involuntary (e.g. buying stocks from a company without knowing they’re a competitor), we will take actions to rectify the situation. If you repeat the offence, you may be terminated.
Don’t act in a way that exploits others, their hard work or their mistakes. Give everyone equal opportunity and speak up when someone else doesn’t.
Be objective when making decisions that can impact other people, including when you’re deciding to hire, promote or fire someone. Be sure that you can justify any decision with written records or examples. Seek and use the most objective methods in any case; for example, when interviewing candidates, ask the same interview questions to all of them and avoid judging non-job-related criteria, like dress, appearance, etc.
When exercising authority, be fair. Don’t show favoritism toward specific employees and be transparent when you decide to praise or reward an employee. You’re also obliged to follow our employment of relatives which forbids you from having a reporting relationship with a relative.
If you need to discipline an employee, be sure to have prepared a case that you can present to HR. You must not retaliate against employees or applicants (such as in cases when they’ve filed complaints) as this is forbidden by law.
Be just toward customers or vendors, too. If you think our company was in the wrong in a specific instance, don’t try to cover it up or accuse the other side. Discuss with your manager to find solutions that can benefit both sides.
You are obliged to follow all laws which apply to our organization. Depending on your role and profession, there might be various laws you need to observe. For example, accountants and medical professionals have their own legal restrictions and they must be fully aware of them.
When you’re preparing contracts, clauses, disclaimers or online copy that may be governed by law (such as consent forms), please ask verification from [our legal counsel] before finalizing anything.
You’re also covered by our confidentiality and data protection policy. You must not expose, disclose or endanger information of customers, employees, stakeholders or our business.
Following laws regarding fraud, bribery, corruption and any kind of assault is a given. You are also obliged to follow laws on child labor and avoid doing business with unlawful organizations.
If you’re not sure what the law is in a specific instance, don’t hesitate to ask HR or our legal counsel.
We all need to put a healthy amount of effort in our work. Not just because we’re all responsible for the organization’s success, but also because slacking off affects our colleagues. Incomplete or slow working might hinder other people’s work or cause them to shoulder the burden themselves. This comes in direct conflict with our respect and integrity principles.
We also expect you to take up opportunities for learning and development, either on-the-job or via educational material or training. If you are unsure how you can achieve this, have an open discussion with your manager.
Also, take responsibility for your actions. We all make mistakes or need to make tough decisions and it’s important we own up to them. Failing to be accountable on a regular basis or in important situations (e.g. a crucial mistake in our financial records) will result in termination. If you take responsibility and come up with ways to fix your mistakes where possible, you will be in a far better position.
Working well with others is a virtue, rather than an obligation. You will certainly get to work autonomously and be focused on your own projects and responsibilities. But, you should also be ready to collaborate with and help others.
Be generous with your expertise and knowledge. Be open to learning and evolving. If days go by without you consulting or brainstorming with anyone, you are missing out on opportunities for excellence. Instead, work with others and don’t hesitate to ask for help when you need it.
COVID-19 Health and Safety Policy Update June 2020
ADDENDUM TO ANNEX L HEALTH AND SAFETY AT WORK POLICY
COVID-19 Health and Safety Policy Update June 2020
As a result of the COVID-19 outbreak this addendum has been drafted as a supplement to the Health and Safety at Work Policy.
AIM OF THIS POLICY
To put in place additional measures to;
This policy is based on the government’s guidelines as set out in Working Safely During Coronavirus first published in May 2020
A Risk Assessment will be done to asses the risks and to put in place measures to eliminate or mitigate those risks.
CLEANING, HANDWASHING AND HYGIENE PROCEDURES
WORKING FROM HOME
Where possible enabling employees to work form home, taking into account, the requirements of the business, safety of personal data and employee well being.
MAINTAIN 2 M SOCIAL DISTANCING WHERE POSSIBLE
WHERE 2 M SOCIAL DISTANCING IS NOT POSSIBLE
There may be emergency situations such as fire, evacuation or injury, where it would not be necessary to observe social distancing or where it is unsafe to do so. Once the emergency is over, people involved should wash or sanitise their hands
A: Persons who are or may be ill;
(Subject to GDPR provisions)
B: In compliance with the governments track and trace policy, anyone who exhibits symptoms of coronavirus (a new cough, a fever or loss of smell or taste) should contact the NHS to book in a COVID-19 test. If the test is returned positive the individual must inform management who will work to identify any colleagues or clients who have come into contact with the individual who has tested positive. Anyone who has come into contact with a confirmed case will be required to self isolate for two weeks.
FAILURE TO COMPLY WITH THIS POLICY
Clients and Employees
Where a client or an employee fails to follow this policy or the government guidelines;
This Employee remote work policy template is ready to be tailored to your company’s needs and should be considered a starting point for setting up your employment policies.
Our Employee remote work policy outlines our guidelines for employees who work from a location other than our offices. We want to ensure that both employees and our company will benefit from these arrangements.
This policy applies to employees whose primary work location is not at our offices.
Remote working is a permanent or temporary agreement between employees and managers to work from a non-office location for more than [three days.]
Working from home for a maximum of [two days] or working from home certain days a week on a recurring basis are situations covered by our remote work policy
Employees may work remotely on a permanent or temporary basis.
Permanent remote work employees should indicate their primary working address in a remote working agreement. This contract will also outline their responsibilities as remote employees.
Office-based employees may also work remotely for a maximum of [two consecutive weeks] per year if [they want to visit family/ their birthplace.] Eligible employees are those who have been employed by our company for at least [a year.] Employees who are new parents or suffer from short-term/long-term disability may agree to longer periods of remote working with their manager and HR.
Office-based employees may also revert to permanent remote working in cases of relocation. HR will assess their eligibility on a case-by-case basis.
Employees who want to work remotely must submit a request by [asking HR for a form/ through our HRIS.]
To ensure that employee performance will not suffer in remote work arrangements, we advise our remote employees to:
Team members and managers should determine long-term and short-term goals. They should frequently meet (either online or in-person when possible) to discuss progress and results.
Our remote employees must follow our company’s policies like their office-based colleagues. Examples of policies that all employees should abide by are:
Compensation is determined by job role. Health insurance, PTO and other individual or group benefits are not altered by a remote working agreement.
Remote employees will also receive [£100] per month as a remote-working allowance to cover office-related costs (e.g. electricity and rent.) Occasionally, we may pay for our remote employees to visit our offices.
We will provide our remote employees with equipment that is essential to their job duties, like laptops, headsets and cell phones (when applicable.) We will install VPN and company-required software when employees receive their equipment. We will not provide secondary equipment (e.g. printers and screens.)
Equipment that we provide is company property. Employees must keep it safe and avoid any misuse. Specifically, employees must:
HR will discuss insurance needs with employees. Employees may have to take up homeowner’s insurance to cover the cost of company equipment. HR may reimburse a portion of the coverage when applicable.
Disclaimer: This policy template is meant to provide general guidelines and should be used as a reference. It may not take into account all relevant local, state or federal laws and is not a legal document. Neither the author nor Workable will assume any legal liability that may arise from the use of this policy.
Environmental & Sustainability Policy
We are committed to sustainable development (meeting the needs of the present without compromising the ability of future generations to meet their own needs) as a guiding principle within our work. Concern for the environment is an integral and fundamental part of this commitment. Our aim is to reduce the impact on the environment from our operations.
Our environmental/sustainability action plan
In our role as a regulator, we aim to promote good governance in charities as well as dealing with aspects of poor practice. Through our work with charities, we are in a position to promote the wider sustainability agenda. A number of the charities we regulate are themselves established to promote sustainability.
We have a small team engaged in the work of charities operating internationally. Whilst this is funded primarily to focus on issues of terrorism that could inadvertently be supported by charities it can also work alongside those seeking to promote sustainability in the poorest countries of the world.
We will assess the environmental impacts of our operations and set objectives and targets in order to improve our environmental performance. We will regularly review these targets.
Management awareness will be raised by briefing at the Executive Group and Leadership Group forums.
2 of 2
Ensure continued roll out of electronic records document management system and online services initiatives to reduce need for paper
Target: Systems fully operational by January 2008 (complete)
Lead: Head of Business Enablement
Create an Environmental Management System
Target: Ongoing – baseline detail available from March 2008 Lead: Environmental Manager
Reinforce Senior Management Commitment
Target: Policy approved in March 2008
Lead: Environmental Manager/Head of Business Enablement
Improve Environmental awareness amongst staff and promote green housekeeping issues
Target: Ongoing – Focus Groups created and meetings held since March 2008
Lead: Environmental Manager
Review Policy and Action Plan
Lead: Environmental Manager
Consider ISO 14001accreditation
Lead: Environmental Manager/Head of Business Enablement
We also responded to government targets by:
keeping records as appropriate (start of an Environmental Management System).
Equality, Diversity & Inclusion Policy
E.A.T.O.W is committed to encouraging equality, diversity and inclusion among our workforce, and eliminating unlawful discrimination.
The aim is for our workforce to be truly representative of all sections of society and our customers, and for each employee to feel respected and able to give their best.
The organisation – in providing goods and/or services and/or facilities – is also committed against unlawful discrimination of customers or the public.
The policy’s purpose is to:
E.A.T.O.W commits to:
The equality, diversity and inclusion policy is fully supported by senior management and has been agreed with trade unions and/or employee representatives.
Details of the organisation’s grievance and disciplinary policies and procedures can be found at https://eatow.co.uk/privacy-policy/ This includes with whom an employee should raise a grievance – usually their line manager.
Use of the organisation’s grievance and/or disciplinary procedures does not affect an employee’s right to make a claim to an employment tribunal within three months of the alleged discrimination.
ACCOUNTABLE TO THESENIOR MANAGER FORHEALTH AND SAFETY INTHEIR DEPARTMENTS
Client Services Department
Director of Client Services
All Department Managers are accountable to the Director for their respective areas
The Equality and Human Rights Commission is committed to providing a high quality, transparent and accessible service to everyone we deal with. In order to do this we need you to tell us when we get things wrong. We want to help resolve your complaint as quickly as possible.
We handle any expression of dissatisfaction with our service which calls for a response as a complaint. We listen to your complaints, treat them seriously, and learn from them so that we can continuously improve our service.
A complaint is an expression of dissatisfaction, whether justified or not.
Our policy covers complaints about:
We refer to these complaints as “service complaints”.
Our complaints policy does not cover:
We refer to these types of comments or complaints as’non-service complaints’. These are handled differently, as set out in the ‘Comments and Non-service complaints’ section on page 12.
Third Party Reporting
Complainants may wish to have a third party act on their behalf. A third party is any person or organisation acting on behalf of or making enquiries for the complainant. For example, third parties may include:
Where a third party is helping a complainant with a particular complaint, we need written consent to that effect. Where we have this authority, we will endeavour to take all possible steps to keep the third party informed of progress on the complaint.
We do not need written consent if a MP or elected Councillor is helping a constituent with a complaint, and we can disclose information to them in response to their enquiries.
Also, some lawyers and attorneys are legally empowered in certain circumstances to act on behalf of a complainant, and consent to disclose information is not required.
All complaints received will be dealt with confidentially and in accordance with the requirements of the Data Protection Act 1998, subject to the need to disclose information as required by statutory authorities, and/or as a result of statutory, legal or parliamentary obligations placed on the Commission.
If you wish to make a complaint, you can do so by email or letter.
If you are disabled, and need a reasonable adjustment to ensure you can register your complaint, you can contact us alternatively by:
Our contact details are in the Contacting Us section below. If you require different adjustments, let us know and we will try and put those arrangements in place where we can.
How we will respond to your complaint
We have a two-stage service complaints handling procedure, explained above. At each stage it will help us to resolve your complaint quickly if you can give us as much clarity and detail as possible, including providing any documents and correspondence and stating that you are making a complaint. If we do not have all the details required to deal with the complaint, we may contact you and ask you for further information.
Our Correspondence Unit is responsible for managing the handling of service complaints including notifying you of the outcome.
This is the first opportunity for us to resolve your dissatisfaction. We expect the majority of complaints to be resolved at this stage. On receipt of your complaint we will contact a senior officer from the most appropriate directorate and ask them to respond to your complaint. This includes any service complaints about our former services where we still retain relevant information.
If you are dissatisfied with the response at stage 1, you may request a review. This will be carried out by a responsible Director (or Deputy Director). Your request together with all subsequent correspondence relating to it should be sent to our Correspondence Unit, who will forward your request to the relevant Director to be reviewed.
If having followed the two internal stages of our service complaints procedure you remain dissatisfied, you can ask to have your complaint reviewed by the Parliamentary and Health Service Ombudsman (the Ombudsman) who is independent of the Commission. The Ombudsman will assess whether there is evidence of service failure or maladministration on our part. You have a maximum of 28 days from the date of the Commission’s final response to register a complaint with the Ombudsman.
You can only refer your complaint to the Ombudsman through your Member of Parliament (MP). You should contact your MP and ask them to refer your complaint to the Ombudsman. The Ombudsman can carry out independent investigations into complaints about government departments, agencies and some public bodies which include the Equality and Human Rights Commission.
You can contact the Parliamentary and Health Service Ombudsman as follows:
By post: Millbank Tower, Millbank, London SW1P 4QP
Telephone or fax: 020 7217 4000
Textphone (Minicom): 0300 061 4298
Our timescales for handling a complaint comply with guidance issued by the Public and Health Services Ombudsman.
We will acknowledge complaints within 5 working days of receiving each complaint. We will send a full response within 20 working days of receiving each complaint.
If you make a complaint in person to a member of our staff (at an event or meeting), we will record your complaint in writing within 3 working days, and acknowledge it within 5 working days thereafter. We will then deal with your complaint in accordance with our policy for written complaints.
We will acknowledge complaints within 5 working days of receiving each complaint. We will send a full response within 20 working days of receiving each complaint.
Extending time limits
We aim to complete our investigation into all complaints received about our service within the timescales set out above. However, in a limited number of cases – for example, if a complaint is very complex or requires further breakdown, it may be necessary to extend the time limit to ensure we have all the information necessary to deal with it. If this is the case we will keep you informed of progress with the investigation, the reasons for the delay, and inform you of next steps.
When we get things wrong we will act to:
The action we take to put matters right (i.e. redress) in response to a service complaint can include any combination of the remedies set out in the list below. The general principle we follow is that complainants should, so far as possible, be put in the position they would have been in, had things not gone wrong.
The remedy applied needs to be proportionate and appropriate to the failure in service, and take into account what redress people seek when they complain. An apology is generally the most appropriate action, but other action may also be necessary in some circumstances.
List of remedies
In the majority of cases, remedies other than financial compensation will satisfy the complainant. Financial compensation is a final option, and will only apply in cases where the loss or suffering is considered to warrant such a payment i.e. in cases of actual direct or indirect financial loss.
In circumstances where it is decided that our action or lack of action has resulted in maladministration, if the complainant has suffered direct or indirect financial loss, compensation may be payable. In determining this, we will have regard to the Parliamentary and Health Service Ombudsman’s (PHSO) published “Principles for Remedy”.
Where it is decided, following investigation of a complaint, that a complainant has suffered an injustice and or hardship resulting in direct or indirect financial loss due to maladministration, we will determine whether compensation is an appropriate remedy by looking at all the evidence, including how much the complainant can demonstrate they have lost, or what extra costs they have incurred as a result of our maladministration.
The reason for our decision will be recorded by the decision maker and included in our response.
All complaints will be dealt with in accordance with this policy. However, unreasonable or abusive complaint behaviour does happen from time to time, and vexatious and repetitive complaints are an increasing problem for public sector bodies. Difficulties in handling such situations can place strain on time and resources and can be stressful for staff who have to deal with these complex and challenging issues.
The Parliamentary and Health Service Commissioner defines unreasonably persistent complainants as “those who, because of the frequency or nature of their contact with an authority, hinder the authority’s consideration of their or other people’s, complaints”.
Complaint details, outcomes and actions taken are recorded by us and used for service improvement. We record all complaints we receive and collate data from them to help us understand what types of problems are most prevalent, and how well we are doing to resolve them.
We value your feedback and expect to use it to help us to:
We will handle your information so that it is only processed and retained appropriately and legally, in line with data protection legislation.
All complaints and requests for review under our complaints procedure should be sent as follows:
By email: email@example.com
If you are unable to contact us in writing as above, and require a reasonable adjustment because you are a disabled person, you may contact us as follows:
Telephone: 0161 829 8327
Fax: 0161 829 8110
The Commission is committed to equal opportunities and our aim is to make our corporate complaints policy easy to use and accessible to all of our customers. We will take reasonable steps to accommodate any reasonable adjustments you may have to enable you to access this policy or receive responses to complaints in other formats, and provide such assistance as you may reasonably require.
This policy is also available in Welsh.
If you would like the policy or a response to a complaint in another format (such as Braille, audio CD, BSL video, large print or Easy Read) please contact firstname.lastname@example.org.
Quality of service is an important measure for us of our effectiveness. Learning from complaints, including non-service complaints (complaints not covered by this policy), is a powerful way of helping continuous improvement at the Commission and enable us to better deliver to our values and standards. All non-service complaints will be looked at by a responsible manager from the appropriate team, and a response, if required, sent to you directly within 20 working days where possible. Non-service complaints should be sent to the Correspondence Unit.
As well as learning from your complaints we are also interested in ideas you may have on how we might do things better. We would also like you to tell us when we do things well.
Your comments will be passed on to the relevant team and we will use them to help improve our service and the way we do things. You can make your comments by contacting any members of our staff, or you can e-mail the Correspondence Unit.
Addendum to the Complaints Policy and Procedure:
This policy is integrated with other existing Commission policies. It does not address issues of health and safety directly, which are dealt with elsewhere.
This policy deals with service complaints which Commission staff consider vexatious or repetitive, and behaviour which we deem as unreasonable. It has been developed taking into account the Information Commissioner’s (ICO) guidance under the Freedom of information Act 2000.
Some complaints may relate to our final decisions on matters such as:
There are separate Commission procedures addressing such matters. Where those procedures have been exhausted, any subsequent complaints which are deemed to be vexatious or repetitive will also be dealt with in accordance with this policy.
We sometimes receive complaints which can be deemed ‘vexatious’ or ‘repetitive’. Some of these complaints can be costly to handle; or responding to them may be a disproportionate use of our staff’s time.
Deciding whether a complaint is vexatious requires us in each case to take into account the context and history of the complaint. We will consider whether the complaint is likely to cause unjustified distress, disruption or irritation. In particular, we will consider the following issues:
The concern we will address is whether a complaint is vexatious in terms of the effect of the request on us and not whether the applicant is personally vexatious.
By its ordinary meaning, the term ‘vexatious’ refers to activity that “is likely to cause distress or irritation, literally to vex a person to whom it is directed”.
For a complaint to be vexatious, we will consider whether there is a proper or justified cause for it. We will not only examine the complaint itself, but also its context and history. That context may include other complaints made by the applicant to us (whether complied with or refused), the number and subject matter of the complaints, as well as the history of other dealings between the complainant and ourselves. The effect a complaint will have may be determined as much, or indeed more, by that context as by the complaint itself.
We will take into consideration the following factors (which are not an exhaustive list) when determining whether a complaint is vexatious:
No single one of the above factors would lead to a finding, by itself, that a complaint was vexatious. However, based on the strength of the various factors, taken together with the history and context of a complaint, a complaint may be deemed vexatious by the Commission.
It is important of course that all complaints from a single source should not be deemed vexatious just because some may have been so previously. This is particularly the case if, on the face of it, the complaint seems to be specific, stand alone and straight forward. However, it is entirely appropriate and necessary, when considering whether a complaint is vexatious, to view that complaint in context – if, say, the complaint is part of a wider grievance against the Commission and is, for example, inextricably linked to an individual’s quest to hold the Commission to account for perceived shortcomings.
Complaints can sometimes become a vehicle for individuals to try to reopen previous issues. Although we recognise that people are not always satisfied with the responses they receive, the raising of complaints is not a panacea for problems that have not been resolved through other channels. Continued complaints after the underlying complaint has been addressed, go beyond the reasonable pursuit of resolution.
The Commission understands that people may act out of character in times of distress or due to frustration. We do not view behaviour as unreasonable just because a complainant is forceful or determined. Commission staff make reasonable allowances for complainants’ behaviour.
However, sometimes the situation between a complaint and the Commission staff can escalate and the behaviour of the complainant becomes unacceptable, for example becoming abusive, aggressive or threatening. Such abusive, aggressive, threatening or vexatious complaints are in the very small minority but we sometimes find ourselves in the position where we need to restrict or bring to an end communication and access to our premises or staff.
Our staff have the right to undertake their work free from abuse, threats and harassment, or vexatious and repetitive complaints. We expect our staff to be treated with courtesy and respect. The Commission has a duty to protect the welfare and safety of staff and considers that violence, threats or abuse towards staff is unacceptable. Staff are also expected to treat complainants with courtesy, respect and fairness.
Complainants who harass, or have been abusive, aggressive or threatening on one or more occasions towards our staff – or their families or associates – directly or indirectly, will be considered unreasonable.
Any threats or acts of violence will cause direct contact with the complainant to be discontinued. Violence includes behaviour or language (written, oral, or in tone or otherwise) that may cause staff to feel afraid, threatened or abused. Examples of unacceptable behaviour includes but not exclusively threats, verbal abuse, derogatory remarks, rudeness, racist, sexist, homophobic, transphobic, disablist or other harassment based on personal characteristic or obscene remarks, repeatedly demanding disciplinary action be taken against staff, and where complainants are known to have recorded meetings or telephone conversations without consent.
We also consider that inflammatory statements and unsubstantiated allegations can amount to abusive behaviour.
Furthermore, Commission staff will bring to an end phone calls if the caller is considered aggressive, abusive or threatening. The complainant will first be told that we consider their language offensive or their behaviour unacceptable, and will be asked to stop using such language or behaviour.
If an officer considers behaviour to be unreasonable they are advised in the first instance to refer it to their manager who may seek advice and guidance before determining future contact with the complainant, be that by telephone, in person, or electronically.
Where complaints are deemed vexatious, the complainant will be notified in writing that no further correspondence will be entered into on the matter in question. The Commission will initially keep one form of contact open so that there is not a ‘blanket ban’ on contact for any individual.
Where unreasonable or abusive behaviour is determined, the complainant will be notified in writing that no further contact will be undertaken, and this will apply to all Commission contacts. A copy of this policy will be included and, if and where appropriate, a no-contact period specified. If further contact is necessary, the complainant will be informed that it will be made through a Director or their nominated officer/s. A decision to restrict contact will be reconsidered if the complainant subsequently demonstrates more reasonable behaviour.
If you disagree with a decision made by the Commission to regard your behaviour as unreasonable, you can challenge it. Please refer to our Complaints Policy.
All incidents of harassment or aggression will be documented and referred to senior staff. In appropriate circumstances these matters may be referred to the police and the Commission may consider taking appropriate legal action against the complainant, if necessary, without prior
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