Policies

Fair and Equal Pay Policy

Introduction

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.

Relevant Legislation

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.

Objectives

The Company’s objectives relating to equal pay are to:

Eliminate any unfair, unjust or unlawful practices that impact on pay;
Take appropriate remedial action;
Review other Company policies to ensure consistency with equal pay principles.

To achieve these objectives the Company will:

Implement regular equal pay reviews for all staff (including staff on maternity or sick leave);
Carry out job evaluation and regular equal pay audits
Provide training and guidance for staff involved in determining pay;
Inform staff of how these practices work and how their own pay is determined;
Respond to grievances on equal pay;
Monitor pay statistics regularly and gather other relevant information to assess the impact of this Policy.

Policy

The Company will:

Ensure that any differential in pay is due to a “material factor” such as length of service, skills and qualifications, performance and levels of responsibility;
Promote and achieve equality of opportunity for men and women;
Eliminate unlawful discrimination and harassment.

Responsibilities

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.

GDPR Policy

Basis of and scope of data storage

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).

How we obtain data:

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).

Data we hold consists of:

Contact information:

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.)

Payment information:

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.

Retention policy:

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:

- - These are generally kept for a number of years so that we can refer back to them if you send a follow up to our reply, after that they are deleted: At scheduled times throughout the year enquiries over the specified number of years old are removed. The number of years will depend on the type of enquiry and how it was submitted:
  - Any correspondence that may potentially relate to a financial transaction, currently active registration or client account, is treated the same as as tax records (tax records are legally required to be stored for a minimum of 6 years) and deleted after 7 years.
  - All other correspondence is deleted after 2 years.

Your rights

Right of access and rectification

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.

Right to erasure:

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.

Complaints, corrections or objections

If you have any questions or concerns about information, we hold about you, or need to correct inaccurate information, please contact our administration department

Policy Statement

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:

encouraging employees to seek work-life balance
considering requests for career breaks and sabbaticals
providing medical assistance to employees
encouraging employee fitness
promoting dignity at work
minimising the stressful impacts of work
managing sickness absence effectively.

Work-life Balance

All employees with at least 26 weeks’ continuous service are legally entitled to request flexible working if they have not made a similar request in the past 12 months. E.A.T.O.W will address all requests sympathetically and will try to meet all requests when the needs of the business allow.
Requests to work from home will be given careful consideration. A request will only be allowed if it will not have a negative impact on the smooth operation of the organisation. Employees must note that some jobs can never be successfully carried out from home.
Employees who are allowed to work from home will be expected to attend the workplace at least [number of times] per [week/month]. This will allow effective communication and ensure that the employee does not feel isolated from the work team.
Employees who work part time will be encouraged to attend team briefings. To achieve this, the timing of team briefings will vary to cover the different working patterns of employees.

Requests for Career Breaks and Sabbaticals

A career break is a period of time away from the workplace. This will be for a minimum of one year and a maximum of [number] years. During the period of a career break, the individual is not an employee of the organisation, but will be kept in touch with what is happening in the organisation through regular updates to facilitate a smooth return to work in the future.
A sabbatical can be for a maximum of [number] months. During the sabbatical an employee [will/will not] be expected to be doing work connected with the organisation. During the sabbatical the individual will remain an employee and continuity of service will continue to accrue. An employee is required to have at least [number] years’ service before requesting a sabbatical.
Requests for a career break or sabbatical must be made in writing to the line manager.
The organisation reserves the right to refuse a request for a career break or sabbatical. The reasons for a refusal will be confirmed in writing to the employee.

Providing Medical Assistance to Employees and Promoting Healthy Options

To promote the health of all employees E.AT.O.W will do the following.

Provide private health insurance for [all employees/employees in a specific grade]. Details of the scheme will be given to the employee in their contract of employment.
Promote healthy eating. There will always be healthy eating options in the staff restaurant, which is a subsidised facility. Staff lunches will always include healthy options.
Support employees trying to give up smoking. [Name of organisation] has access to specialist services who will provide advice and support to those who try to give up smoking. Details of this can be found on the company intranet.

Encouraging Employee Fitness

To promote exercise and fitness [name of organisation] will do the following.

Provide subsidised gym membership. Employees must apply to [job title] if they wish to take advantage of this opportunity. Employees must abide by the terms and conditions of the membership agreement.
Allow employees to use the company sport facilities. Employees must abide by the rules set by the Sports Manager or forfeit the right to use the facilities.
From time to time, events will be arranged for employees to participate in fitness activities. It is aimed to arrange at least one charity run each year, with similar events taking place throughout the year. Employees wishing to arrange an event should contact the HR Department.

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.

Any employee who is distressed by events at work and believes that their dignity has been violated or they have suffered harassment should talk to their line manager. This will be addressed in confidence.
If it is not appropriate to speak to the line manager employees should speak to a member of the HR department.
The organisation will add promptly to investigate any allegations of unacceptable behaviour in the workplace.
The organisation will support employees in getting over any distress that has been caused.
Employees who harass colleagues, or engage in otherwise upsetting behaviour, could be subject to disciplinary action.

Minimising the Stressful Impacts of Work

All jobs can have times when the work is particularly busy, or particularly demanding. E.A.T.O.W recognises this and will support employees by allowing regular breaks for the employee to rest from these demands.
Employees are not expected to be answering emails from home in the evenings. If employees find that they are regularly needing to work from home in the evenings, they must discuss this with their line manager to try to find a solution.
[E.A.T.O.W will always take steps to cover the absence of colleagues, without putting undue demands on other employees.
if employees are struggling to cope with the demands of their job, they should discuss this with their line manager or a member of the HR Department.

Managing Sickness Absence Effectively

Employees who are absent due to sickness must adhere to the Company Sickness Absence Procedure.
Employees should not return to work if medical advice is that they are not fit to work.
Employees who have been absent from work for a lengthy period of time will usually be expected to return to work on a phased return programme. This will be agreed between the employee and their line manager.
While an employee is on sickness absence leave their line manager will keep in touch. The purpose of this will be to ensure that key communications are sent to the employee, and to ensure that the employee still feels part of the work team.

Anti-Slavery Policy

This is the anti-slavery policy of E.A.T.O.W

1. POLICY STATEMENT

1.1 Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain. We are committed to acting ethically and with integrity in our business dealings and relationships and are committed to preventing modern slavery in our own business and to helping prevent modern slavery in our supply chains.
1.2 We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery. Under the Modern Slavery Act 2015, we are legally required to disclose the steps we take to tackle modern slavery. We expect the same high standards from all of our employees and suppliers.
1.3 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, suppliers, seconded workers, volunteers, and interns.
1.4 This policy does not form part of any E.A.T.O.W employee’s contract of employment and we may amend it at any time.

2. RESPONSIBILITY FOR THIS POLICY

2.1 The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.
2.2 The Legal and Human Resources departments have primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal procedures.
2.3 Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy. Guidance on the policy can be obtained from the Legal and Human Resources teams.

3. COMPLIANCE WITH THIS POLICY

3.1 The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy.
3.2 You must notify your manager (or your main point of contact at EATOW) as soon as possible if you believe or suspect that a breach of this policy has occurred, or may occur in the future.
3.3 You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains or any supplier tier at the earliest possible stage.

3.4 If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager (or your main point of contact at EATOW) as soon as possible.
3.5 If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chain constitute any of the various forms of modern slavery, you should raise it with your manager (or your main point of contact at EATOW).
3.6 We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment by EATOW as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Chief Human Resources Officer immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our grievance procedure.

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

5.1 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
5.2 We may terminate our relationship with other individuals and organisations working for us or on our behalf (including suppliers) if they breach this policy.

Code of ethics policy

Policy brief & purpose

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.

Scope

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.

Policy elements

What is meant by code of professional ethics?

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.

What is the purpose of a professional code of ethics?

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.

The components of our code of professional ethics:

We base our business code of ethics on common principles of ethics [Note: Modify this list based on your own organization’s values]:

Respect for others. Treat people as you want to be treated.
Integrity and honesty. Tell the truth and avoid any wrongdoing to the best of your ability.
Justice. Make sure you’re objective and fair and don’t disadvantage others.
Lawfulness. Know and follow the law – always.
Competence and accountability. Work hard and be responsible for your work.
Teamwork. Collaborate and ask for help.

Here’s a more detailed overview of our code:

Respect for others

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.

Integrity and honesty

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

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.

Justice

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.

Lawfulness

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.

Competence and accountability

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.

Teamwork

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;

Protect employees and clients from risk of infection of COVID-19
Provide employees and clients with COVID-19 Secure workplace and office
Provide employees and clients with a workplace and office where they feel comfortable and not at risk of infection

GOVERNMENT GUIDELINES

This policy is based on the government’s guidelines as set out in Working Safely During Coronavirus first published in May 2020

Carry out a Risk Assessment.
Develop cleaning, hand washing and hygiene procedures.
Help people work from home.
Maintain 2 m social distancing where possible.
Where people cannot be 2 m apart, manage transmission risk.

RISK ASSESMENT

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

Encourage people to follow the guidance on hand washing by placing signage in the cloakrooms.
Hand sanitiser is provided in the reception area as well as individuals are all provided with their own on each desk. Hand sanitizer to be provided in the kitchen, near the copiers, and in the meeting rooms.
Frequently cleaning and disinfecting objects and surfaces that are touched regularly
Enhanced cleaning in busy areas, such as kitchen, copiers
Provide protective equipment where necessary and appropriate

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.

Discuss home working arrangement with each employee to establish their requirements
Ensuring they have the right equipment
Making sure that there is adequate communication with all employees who are working at home
Considering their physical and mental well being

MAINTAIN 2 M SOCIAL DISTANCING WHERE POSSIBLE

Where possible and appropriate undertake as many tasks electronically as possible
Put up signage to remind people to observe the social distancing guidance
No sharing of work stations
Placing floor tape to remind people to keep a 2 m distance
Not having face to face work stations except for people of the same family or household
Arrange a one way traffic system through the office. Entrance to the office area through the double door and exit through the door at the translators area and then out into the lobby via the ‘library’ door
Increase in use of telephone and video meetings where appropriate

WHERE 2 M SOCIAL DISTANCING IS NOT POSSIBLE

Consider whether or not that activity is essential
If it is keeping activities as short as possible, involve as few people as possible
Consider the use of screens if necessary
Avoid face to face seating, use back to back or side by side if 2 m social distancing is not possible
Having flexible arrival and departure times; arrival between 7 and 10 am and departures between 3 and 7 pm
Having different teams come in on different days

EMERGENCY SITUATIONS

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

PROCEDURES

A: Persons who are or may be ill;

(Subject to GDPR provisions)

People who are ill, or suspect they may be or have been in contact with someone who is ill, may not come to the office until they have fully recovered or have undertaken the necessary periods of quarantine.
In respect of employees, normal absence procedures apply. Any employee who suspects they are ill should advise management immediately they suspect they are ill. This will enable management to advise other employees, implement quarantine if necessary, and to undertake santisation.
In respect of clients who appear to be ill, employees may respectfully advise the client that they are not comfortable meeting with them face to face and will continue to advise them by telephone or electronically.
Any employee who has been in contact with another employee or a client who appears to be ill must advise management immediately and take all measures to ensure they do not become ill, washing their hands, not touching their face. If necessary stay away from the office until they are certain that they are not ill.
Where an employee becomes ill at work, they must leave the office immediately and advise management that they have done so. Management to ensure that other employees are advised that an employee has gone home ill and that all precautions should be taken.
Any area where a potentially ill client or employee has been in the office must be fully sanitised.

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;

They should be formally asked to follow the policy or the guidelines
Where they continue to refuse they ought to be asked to provide a reason as to why they are not following the policy
If reasonably possible, that reason should be accommodated if feasible
Where it is not possible, that should be explained to the employee and they should be advised that further failure to follow the policy would result in discipline and for employees, further instances of failure to follow the policy or the government guidelines may result in disciplinary action being taken
Where it is not possible to accommodate the client’s reason for not following the policy, the employee dealing with that client may decline to continue to assist the client in any face to face situations, and may advise the client that further work will only be undertaken by telephone, or electronically.

FURTHER ACTIONS

Communicate this policy to all staff, publish on Website
Update related policies
Reconsider this policy every three months, next review by mid September 2020. Consider any updates to the Working Safely during Coronavirus as published in may 2020
Pandemic Response Team elective

Employee remote work policy template

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.

Policy brief & purpose

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.

Scope

This policy applies to employees whose primary work location is not at our offices.

Policy elements

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

Remote working agreement

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.]

Remote working that works

To ensure that employee performance will not suffer in remote work arrangements, we advise our remote employees to:

Choose a quiet and distraction-free working space.
Have an internet connection that’s adequate for their job.
Dedicate their full attention to their job duties during working hours.
Adhere to break and attendance schedules agreed upon with their manager.
Ensure their schedules overlap with those of their team members for as long as is necessary to complete their job duties effectively.

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.

Compliance with Policies

Our remote employees must follow our company’s policies like their office-based colleagues. Examples of policies that all employees should abide by are:

Attendance
Social media
Confidentiality
Data protection
Employee Code of Conduct
Anti-discrimination/ Equal opportunity
Dress code when meeting with customers or partners.

Compensation and benefits

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.

Equipment

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:

Keep their equipment password protected.
Store equipment in a safe and clean space when not in use.
Follow all data encryption, protection standards and settings.
Refrain from downloading suspicious, unauthorized or illegal software.

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.

We will:

promote responsibility for the environment within the organisation and communicate and implement this policy at all levels within the workforce;
reduce the use of energy, water and other resources;
minimise waste by reduction, re-use and recycling methods;
comply with all relevant environmental legislation/regulation;
ensure that our policies and services are developed in a way that is complimentary to this policy;
not prioritise funding needs ahead of sustainability requirements;
encourage all charities to commit to the sustainable development philosophy;
identify and provide appropriate training, advice and information for staff and encourage them to develop new ideas and initiatives;
provide appropriate resources to meet the commitments of this policy; and
promote and encourage involvement in local environmental initiatives/schemes.
This action plan is available to all staff on our intranet site and has been drawn to their attention. Senior

Management awareness will be raised by briefing at the Executive Group and Leadership Group forums.

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Key actions

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

Target: ongoing
Lead: Environmental Manager

Consider ISO 14001accreditation

Target: ongoing
Lead: Environmental Manager/Head of Business Enablement

Additional actions

We also responded to government targets by:

Establishing an Environmental Manager post.
Preparing and promoting an environmental policy and action plan.
Setting up Environmental Focus Groups encouraging staff to make suggestions and decisions on local site issues. (These groups were disbanded in May 2011)
Instigating building reports on Commission offices by the Carbon Trust and implemented as many of their recommendations as possible.
Arranging automatic shutdown of PC’s at an agreed time each evening.
Closely monitoring utilities consumption for each building, Commission travel and courier details,

keeping records as appropriate (start of an Environmental Management System).

Where appropriate, increasing recycling options and fitting time clocks on items of equipment which are not required to be powered up 24/07.
Using environmentally friendly products in kitchen areas.
Installing light sensors in the Taunton IT Suite, toilets and kitchen areas.

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:

provide equality, fairness and respect for all in our employment, whether temporary, part-time or full-time
not unlawfully discriminate because of the Equality Act 2010 protected characteristics of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race (including colour, nationality, and ethnic or national origin), religion or belief, sex and sexual orientation
oppose and avoid all forms of unlawful discrimination. This includes in pay and benefits, terms and conditions of employment, dealing with grievances and discipline, dismissal, redundancy, leave for parents, requests for flexible working, and selection for employment, promotion, training or other developmental opportunities

E.A.T.O.W commits to:

Encourage equality, diversity and inclusion in the workplace as they are good practice and make business sense
Create a working environment free of bullying, harassment, victimisation and unlawful discrimination, promoting dignity and respect for all, and where individual differences and the contributions of all staff are recognised and valued.

This commitment includes training managers and all other employees about their rights and responsibilities under the equality, diversity and inclusion policy. Responsibilities include staff conducting themselves to help the organisation provide equal opportunities in employment, and prevent bullying, harassment, victimisation and unlawful discrimination.

All staff should understand they, as well as their employer, can be held liable for acts of bullying, harassment, victimisation and unlawful discrimination, in the course of their employment, against fellow employees, customers, suppliers and the public
Take seriously complaints of bullying, harassment, victimisation and unlawful discrimination by fellow employees, customers, suppliers, visitors, the public and any others in the course of the organisation’s work activities.

Such acts will be dealt with as misconduct under the organisation’s grievance and/or disciplinary procedures, and appropriate action will be taken. Particularly serious complaints could amount to gross misconduct and lead to dismissal without notice.

Further, sexual harassment may amount to both an employment rights matter and a criminal matter, such as in sexual assault allegations. In addition, harassment under the Protection from Harassment Act 1997 – which is not limited to circumstances where harassment relates to a protected characteristic – is a criminal offence.
Make opportunities for training, development and progress available to all staff, who will be helped and encouraged to develop their full potential, so their talents and resources can be fully utilised to maximise the efficiency of the organisation.
Decisions concerning staff being based on merit (apart from in any necessary and limited exemptions and exceptions allowed under the Equality Act).
Review employment practices and procedures when necessary to ensure fairness, and also update them and the policy to take account of changes in the law.
Monitor the make-up of the workforce regarding information such as age, sex, ethnic background, sexual orientation, religion or belief, and disability in encouraging equality, diversity and inclusion, and in meeting the aims and commitments set out in the equality, diversity and inclusion policy.

Monitoring will also include assessing how the equality, diversity and inclusion policy, and any supporting action plan, are working in practice, reviewing them annually, and considering and taking action to address any issues.

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.

E.A.T.O.W

HEALTH AND SAFETY POLICY

STATEMENT OF GENERAL POLICY

E.A.T.O.W fully accepts the obligations placed upon it by the various Acts of Parliament covering health and safety. The Company requires its Chief Executive to ensure that the following policy is implemented and to report annually on its effectiveness.

MANAGEMENT ORGANISATION AND ARRANGEMENTS

Introduction

This policy has been prepared and published under the requirements of Health & Safety at Work legislation. The purpose of the policy is to establish general standards for health and safety at work and to distribute responsibility for their achievement to all managers, supervisors, and other employees through the normal line management processes.

MANAGEMENT RESPONSIBILITIES

Chief Executive

The Chief Executive has overall responsibility for the implementation of the Company’s policy. In particular he is responsible for ensuring that the policy is widely communicated and that its effectiveness is monitored.

Directors and Senior Managers

These managers are wholly accountable to the Chief Executive for the implementation and monitoring of the policy within the area of their specified responsibility.

Safety Officer

The Safety Officer is a nominated manager responsible for co-ordinating effective health and safety policies and controls across the organisation.

The Safety Officer is responsible for:

the production and maintenance of the Company’s policy and ensuring that Department Guidelines are consistent with policy;
its application;
monitoring and reporting on the effectiveness of the policy;
the provision of general advice about the implication of the law;
the identification of health and safety training needs. The safety officer also acts on behalf of the Chief Executive, as the Company’s formal link with the Health and Safety Executive, Environment Health Departments and other external agencies;
the production and maintenance of any health and safety documents or codes of practice as necessary for any relevant area of the Company services where this is required.

Responsibilities for Specific Workplaces

WORKPLACE

SENIOR MANAGER

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

HEALTH AND SAFETY MANAGEMENT PROCESS

E.A.T.O.W believes that consideration of the health, safety and welfare of staff is an integral part of the management process. The provision of the Health and Safety at Work etc Act, associated Codes of Practice and other relevant Directives will be adopted as required standards within the Company. Responsibility for health and safety matters shall be explicitly stated in management job descriptions.

The Company requires managers to approach health and safety in a systematic way, by identifying hazards and problems, planning improvements, taking executive action and monitoring results so that the majority of health and safety needs will be met from locally held budgets as part of day-to-day management, although many health and safety problems can be rectified at little additional cost.

For major additional expenditure, cases of need will be submitted by Directors to the Chief Executive.

If unpredictable health and safety issues arise during the year, the Chief Executive must assess the degree of risk, in deciding the necessary resources and actions to commit to addressing these issues.

HEALTH, SAFETY AND WELFARE GUIDELINES

It is the policy of E.A.T.O.W to require departmental managers to produce appropriate departmental health and safety policies or guidelines. These should embody the minimum standards for health and safety for the department and the work organised within it.

It shall be the responsibility of the manager to bring to the attention of all members of his or her staff, the provisions of the guidelines, and to consult with appropriate Health and Safety Representatives about the updating of these guidelines. Suggested model contents of a guideline are:

a clear statement of the role of the department;
regulations governing the work of the department;
clear reference to safe methods of working, for example nursing procedures, manufacturers’ manuals;
information about immediate matters of health and safety concern, such as fire drills, fire exits, first aid;
training standards;
the role and identity of the Health and Safety Representative;
names of specialist advisers who can be approached about the work of the department;
the manager responsible for organisation and control of work;
accident reporting procedures;
departmental safety rules;
fire procedures;
policies agreed by the Company.

IDENTIFICATION OF HEALTH AND SAFETY HAZARDS

ANNUAL AUDIT AND REGULAR RISK ASSESSMENTS

It is the policy of E.A.T.O.W to require a thorough examination of health and safety performance against established standards in each department, at least annually. The technique to be adopted for such examinations will be the ‘Safety Audit’. The Audit requires review of:

standards laid down in the policy;
departmental guidelines;
relevant regulations;
environmental factors;
staff attitudes;
staff instructions;
methods of work;
contingency plans;
recording and provision of information about accidents and hazards and the assessment of risk.

The information obtained by the Audit will be used to form the basis of the plan for the department for the following year.

The responsibility for ensuring that audit activity is carried out as part of this policy rests with the Chief Executive and will be carried out by the Safety Officer. Although the Audit remains a management responsibility, managers are required as part of this policy to seek the involvement of the appropriate Health and Safety Representative in the conduct of the Audit.

It is the management’s responsibility to ensure that any deficiencies highlighted in the Audit are dealt with as speedily as possible.

In addition to carrying out Safety Audits, it is the responsibility of the department manager to have checked, at least quarterly, all portable equipment, including electrical appliances, in their area, and to ensure that all problems are immediately dealt with.

Managers have a continual responsibility for the elimination of hazards in order to maintain a safe working environment and will also be expected to carry out regular risk assessments in line with the Health and Safety Executive Guidelines; that is follow the 5 steps:

Identify the hazards
Decide who might be harmed and how
Evaluate the Risks and decide on precautions
Record the findings and implement the precautions
Review the assessment and update when necessary

SAFETY REPRESENTATIVES

E.A.T.O.W will support Safety Representatives in carrying out their role and give all reasonable assistance. Safety Representatives will be encouraged to discuss specific health and safety issues with the relevant Head of Department. They may also formally report hazardous or unsafe circumstances to the Head of Department and will be formally notified of the remedial action taken or be given a reason why the action cannot be taken.

TRAINING

Health and Safety training shall be incorporated within annual training programmes, as part of the development of a systematic training plan. Health and Safety training needs will, therefore, be identified and planned for in the same manner as other training needs.

Four areas of need shall be given special priority:

training for managers, to equip them with an understanding of the manager’s responsibilities under this policy, and the role and purpose of safety representatives;
training for safety representatives to enable them to discharge their function;
training for all members of staff to acquaint them with the main provisions of the law and its practical implication, the main features of this policy and key safety rules;
induction and in-service training for staff at all levels to acquaint them fully with new requirements and hazards.

RECORDS, STATISTICS AND MONITORING

The Company will operate systems for recording, analysis and presentation of information about accidents, hazard situations and untoward occurrences. Advice on systems will be provided by the Safety Officer, in conjunction, where appropriate with specialist advisory bodies for example local Environmental Health Departments, and the responsibility for the operation of these systems rests with managers and supervisors at all levels. Information obtained from the analysis of accident statistics must be acted upon and, where necessary, bids for additional expenditure made to the Chief Executive.

REPORTS TO THE HEALTH AND SAFETY EXECUTIVE

The responsibility for meeting the requirements of the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1985 (RIDDOR) to the Health and Safety Executive, shall rest with the Chief Executive as delegated to the Safety Officer.

SPECIALIST ADVISORY BODIES

Certain bodies and the individual members of those bodies, have always had a Health and Safety role, most notably, the Health & Safety executive, or local Environmental Health Departments. If further specialist advice is required, this may be obtained by Managers from expert individuals or bodies outside the Company.

THE OCCUPATIONAL HEALTH SERVICE

It is the policy of the Company to obtain independent Occupational Health advice when required. Such services can include counselling on health and associated matters, investigation of hazards and accidents, environment studies, health interviews and employment medicals.

FIRST AID

It is the policy of the Company to make provision for First Aid and the training of ‘First Aiders’ in accordance with the First Aid Regulations (1982). The Safety Officer is responsible for ensuring the Regulations are implemented and for identifying training needs.

FIRE

The Chief Executive is responsible for ensuring that the staff receive adequate fire training, and that nominated fire officers are designated in all E.A.T.O.W premises. The Chief Executive delegates these responsibilities to the Directors.

In addition the Company will nominate a Fire Officer (this may be the Safety Officer or someone external to the Company) who will:

report and advise on the standard of fire safety in the Company’s premises and the standard of fire training of its staff;
undertake overall responsibility for fire training;
assist in the investigation of all fires in the Company’s premises and to submit reports of such incidents.

CONDEMNATION AND DISPOSAL OF EQUIPMENT

Procedures for the, condemnation and disposal of equipment are determined by the Chief Executive. Managers introducing new equipment should have such equipment checked initially by the Safety Officer.

FOOD HYGIENE

Those Managers who have responsibility for food acquisition, storage, processing and serving, and staff induction and hygiene training, are responsible for ensuring that these functions are undertaken to the necessary legal standards. Any suspected outbreak of food poisoning or other unexplained and possibly food related incidents must be reported to the Safety Officer.

LIFTING AND HANDLING

Managers are responsible for informing staff of safe lifting techniques. The Safety Officer will identify specific training needs and ensure training in lifting and handling is provided to staff who require it.

NON-SMOKING ON COMPANY PREMISES

E.A.T.O.W policy is that there will be no smoking in its buildings. The overall aim is to reduce smoking and so save life, reduce risk of fire, prevent unnecessary illness and chronic disability. The rules relating to smoking on Company premises are available from Head Office. These rules also extend to e-cigarettes / vaping.

CONTROL OF SUBSTANCES HAZARDOUS TO HEALTH

The Control of Substances Hazardous to Health Regulations (COSHH) require the Company to identify those substances which are in use and which are hazardous to health (as legally defined) and to assess the risk of those substances. The Company must also provide and use controls to prevent exposure to substances hazardous to health; maintain controls by monitoring exposure, or by health surveillance of employees; and provide information, instruction and training for employees on all these matters. The Safety Officer is responsible for implementing these Regulations.

COMPUTER INSTALLATIONS AND VISUAL DISPLAY UNITS

All new computer installations must adhere to the British Standard Specifications and comply with the Health and Safety (Display Screen Equipment) Regulations 1992. All new employees operating such equipment are expected to read the Health and Safety Executive guidance entitled ‘Working with Display Screen Equipment’. New employees who regularly use VDUs will be required to undergo sight screening.

CONTROL OF WORKING TIME

E.A.T.O.W is committed to the principles of the Working Time Regulations. No member of staff is expected to work more than 48 hours per week (including overtime) unless there are exceptional circumstances. Similarly all other requirements of the regulations e.g. in relation to breaks, night workers etc. will be complied with.

HEALTH AND SAFETY AND THE INDIVIDUAL EMPLOYEE

The Health and Safety at Work Act requires each employee ‘to take reasonable care for the Health and Safety of himself and of other persons who may be affected by their acts and omissions’ and co-operate with management to enable management to carry out their responsibilities under the Act. Employees have equal responsibility with the Company for Health and Safety at Work.

The refusal of any employee to meet their obligations will be regarded as a matter to be dealt with under the Disciplinary Procedure. In normal circumstances counselling of the employee should be sufficient. With a continuing problem, or where an employee leaves themself or other employees open to risk or injury, it may be necessary to implement the formal stages of the Disciplinary Procedure.

PEOPLE WORKING ON COMPANY PREMISES NOT EMPLOYED BY THE COMPANY

Persons working in E.A.T.O.W premises who are employed by other organisations are expected to follow Company Health and Safety Policies with regard to the safety of Company employees, their own personal safety (and that of other parties such as the general public if appropriate) and their method of work. This responsibility will be included in contracts or working arrangements.

VISITORS AND MEMBERS OF THE PUBLIC

The Company wishes to ensure that as far as is reasonably practicable, the Health, Safety and Welfare of visitors to Company establishments will be of the highest standard.

Any member of staff who notices persons acting in a way which would endanger other staff, should normally inform their Head of Department. If the danger is immediate, common sense must be used to give warning, call for assistance or give aid as necessary. It is equally important not to over-react to a situation.

CONTRACTORS

The Company wishes to ensure that as far as is reasonably practicable, the Health, Safety and Welfare of Contractors working in the Company’s establishments will be of the highest standards. In addition, Contractors and their employees have an obligation so far as is reasonably practicable to ensure all equipment, materials and premises under their control are safe and without risks to health.

Contractors must also observe the Company’s Fire Safety Procedures. These obligations will be drawn to the attention of the Contractors in the contract document issued to them. In addition a Company Manager will be identified in the contract as having authority to stop the work of Contractors who are placing themselves, other staff, or visitors at risk. Any member of staff who judges there is a risk where contractors are working, should inform their Manager immediately.

In tendering, Contractors will be asked to confirm they have a written Health, Safety and Welfare Policy. The Company’s Manager letting the Contract will be responsible for monitoring the Health and Safety performance of the Contractor and the Contractor’s performance will be a factor in deciding whether or not to invite the Contractor to tender again.

The Equality and

Human Rights Commission
Complaints Policy and Procedure

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.

What is a complaint?

A complaint is an expression of dissatisfaction, whether justified or not.

Our policy covers complaints about:

the standard of service you should expect from us
the behaviour of our staff in delivering that service
any action, or lack of action, by our staff or others engaged on Commission business

We refer to these complaints as “service complaints”.

Our complaints policy does not cover:

comments about our policies or policy decisions
dissatisfaction or complaints expressed with our policies or decisions about individual cases, funding, or requests for legal advice and assistance
matters that have already been fully investigated through this complaints procedure
anonymous complaints

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.

Our standards for handling complaints

We can receive complaints by letter or email, or alternatively if required by virtue of reasonable adjustments. We treat all complaints seriously.
You can expect to be treated with courtesy, respect and fairness at all times. We expect that you will also treat our staff dealing with your complaint with the same courtesy, respect and fairness.
We will treat your complaint in confidence within the Commission.
We will deal with your service complaint promptly. We will acknowledge receipt of a written complaint within five working days where we have a return address and you can expect to have a full reply within 20 working days. In a few cases we will not be able to send a full reply within 20 working days of receipt, for example if your complaint is very complex. If this happens, we will tell you the reason why and let you know when we will be able to reply in full, keeping you fully informed of progress.
You can find further information in our Annual Report and Accounts on the number and categories of service complaints, and the percentage of those upheld.
We will not treat you less favourably than anyone else because of your:
- sex or legal marital or same-sex partnership status: this includes family status, responsibility for dependants, and gender (including gender reassignment, whether proposed, commenced or completed)
- sexual orientation
- colour or race: this includes ethnic or national origin or nationality
- disability
- religious or political beliefs, or trade union affiliation
- any other unjustifiable factors, for example language difficulties, age, pregnancy and maternity.

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:

advice organisations

Continued…

professionals such as social workers, community psychiatric nurses, doctors or solicitors
family members or friends

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.

Confidentiality

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.

How to complain to us

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:

telephone (one of our officers will help you by writing out your complaint)
fax
asking a member of staff to help you in writing out your complaint

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

Service complaints procedure

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.

Stage 1

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.

Stage 2

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 you are still dissatisfied

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

Website http://www.ombudsman.org.uk/

Timescales

Our timescales for handling a complaint comply with guidance issued by the Public and Health Services Ombudsman.

Stage 1

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.

Stage 2

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.

Remedies

When we get things wrong we will act to:

accept responsibility and apologise
explain what went wrong and why, and
put things right by making any changes required
learn lessons from mistakes and change policies and practices where proportionate and sensible to do so

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

A full apology, explaining what happened and/or what went wrong. ( an apology is not an acceptance of liability under Section 2 of the Compensation Act 2006)
Remedial action, which may include reviewing or changing a decision on the service given to an individual complainant
Provide the service required in first instance (immediately, if appropriate)
Putting things right (for example a change of procedure to prevent future difficulties of a similar kind, either for the complainant or others)
Training or supervising staff; or a combination of both
Financial compensation

Compensation

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.

Vexatious and repetitive complaints, and unreasonable or abusive behaviour

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”.

We have a policy which sets out how we will respond to these situations.

Recording 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:

get things right in the future if we have not done so already
become more customer focused
be more open and accountable
act fairly and proportionately
seek continuous improvement

We will handle your information so that it is only processed and retained appropriately and legally, in line with data protection legislation.

Contacting us

All complaints and requests for review under our complaints procedure should be sent as follows:

By email: admin@eatow.co.uk

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

Reasonable adjustments and alternative formats

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 complaints@equalityhumanrights.com.

Comments and non-service complaints

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:

Vexatious Complaints, Unreasonable and Abusive Behaviour Policy

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:

applications for grants;
applications for legal assistance;
requests for enforcement action; or
requests for changes to our policies.

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.

Vexatious or repetitive complaints

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:

Could the complaint fairly be seen as obsessive?
Is the complaint harassing or causing distress to staff?
Does the complaint appear to be designed to cause disruption or annoyance?
Does the complaint lack any serious purpose or value?

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:

where the complaint requests information which has already been provided
where the nature and extent of the complainant’s correspondence with us suggests an obsessive approach to disclosure
where the tone adopted in correspondence by the complainant is confrontational and/or haranguing and demonstrates that the purpose is to argue and not really to obtain information
where the correspondence could reasonably be expected to have a negative effect on the health and well-being of our staff
where the complaint, viewed as a whole, appears to be intended simply to re-open issues which have been disputed several times before, and is, in effect, the pursuit of a complaint by alternative means
where responding to the complaint would likely entail substantial and disproportionate financial and administrative burdens for us
where it is not a one-off complaint, but a case of the same complaints having been made repeatedly, or where on repetition, the particulars of the complaints have been varied making it difficult to know exactly what the complainant is seeking and making it less likely that the request can be satisfied

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.

Unreasonable Behaviour

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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