Alan Nuttall Partnership Limited Policies

THE ALAN NUTTALL PARTNERSHIP LTD PRIVACY POLICY – WEBSITE
The contents of this website are the copyright of The Alan Nuttall Partnership Ltd unless otherwise indicated.

Disclaimer

The contents of this website are for information only and neither the author(s) nor The Alan Nuttall Partnership Ltd shall accept any responsibility for loss or damage caused as a result of reading or subsequent use of these pages. Whilst every care has been taken in the compilation of the content of these pages, The Alan Nuttall Partnership Ltd disclaims any warranty or representation, express or implied about its accuracy, completeness or appropriateness for a particular purpose. These pages are hosted and reside on a server run by The Alan Nuttall Partnership Ltd. Any views expressed in these pages are not necessarily those of The Alan Nuttall Partnership Ltd or its business partners. If you find anything that causes concern please let us know.

Data Protection and Privacy statement

We regard your privacy as important and comply with the General Data Protection Regulation (GDPR) (EU) 2016/679. We will only use any personal information you send us for the purposes for which you provide it, or where allowed by law. We will only hold your information for as long as necessary for these purposes and will not pass it to any other parties unless this is made clear by you. All Partnership members who have access to your personal data or are associated with the handling of that data are obliged to respect the confidentiality of your personal data.

Links disclaimer

We include links from our website to other websites which we believe will support your understanding of our web pages.
Many of the links from our site lead to sites maintained by other organisations or individuals. The Alan Nuttall Partnership Ltd is not responsible for the content or reliability of linked websites and does not necessarily endorse the expressed views or content within them. Listing of other websites on The Alan Nuttall Partnership Ltd website shall not be taken as endorsement of any kind. No responsibility is assumed by The Alan Nuttall Partnership Ltd for the content of the other websites. We will not be able to deal with any queries arising from these external websites – please contact the provider of the website in question.

Broken links

We cannot guarantee that links will work all of the time and we have no control over availability of linked pages.
If your browser reports that it cannot contact the site, there is probably a fault at the linked website and it may be worth trying again later. However, if you receive a Document Not Found (error 404) message, then our link is incorrect, therefore please contact us so that we can correct it.
If you would like us to link to your site, or another site you find useful, contact us with the URL and we will consider adding a link. Please suggest where in our site you think the link should be from.

Links to this Site

You are welcome to make a link to any page on our site if you think it is useful.
However, you must acknowledge our copyright if you copy any text or graphics from our pages onto your own, or include any graphics on our site within your pages. You must comply with the points made in our re-use notice.

Any telephone calls in relation to the contents of this website may be recorded for training and monitoring purposes and information from these recordings may be shared between The Alan Nuttall Partnership Ltd divisions where legally permitted.

This policy is the operational policy for The Alan Nuttall Partnership Ltd and its website. We are committed to protecting your privacy, and at the same time we endeavor to use any data we collect from you to provide the best possible service.

Google Analytics

We use this to understand how the website is being used in order to improve the user experience. User data is anonymous.

COOKIES

Providing visitors with anonymous access

You can access our website home page and browse our site without disclosing your personal data.
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We use cookies on the website to track visitor behavior and store certain site preferences. If you prefer not to allow the use of cookies, you can change the configuration of your browser to either warn you when you receive a cookie, or to automatically reject them. You may find, however, that disabling cookies means certain areas of the site do not function correctly. If you would like to find out more about cookies, including how to control or delete them, then we recommend you visit http://www.aboutcookies.org for detailed guidance.

What are cookies?

Cookies are very small text files that are stored on your computer when you visit some websites. They are used by most websites to tailor information and marketing messages to better suit your needs, as well as to store login or personal information for your convenience. On Behalf of the Board of Directors as a collective
Darren Emms
Secretary
The Alan Nuttall Partnership Ltd
Effective from June, 2015.

THE ALAN NUTTALL PARTNERSHIP LTD PRIVACY POLICY STATEMENT – RECRUITMENT

Introduction

Any information received from you by the Company will be used for recruitment purposes only. It will be treated in the utmost confidence in accordance with the Company HR General Data Protection Regulations Policy.

Type of Data Collected

The Company will need to collect a range of information about you during the recruitment process including:

• Your name and contact details
• Your qualifications, experience skills and employment history
• Whether you have the right to work in the UK
• Your current salary and benefits
• Whether you have a disability for which we need to make reasonable adjustments during our recruitment procedure.

The data will be collected from your CV and covering letter, application form, exam certificates, passport or other identity documents. The information will be stored securely on our internal IT systems and in paper form within the HR Department.

How the data collected from you will be used

During the recruitment process your information will be confidentially shared internally with any Partnership members who are directly involved in the recruitment process for the position for which you have applied, this may include Directors, Managers, Supervisors and the HR Team. It will also be used where you may be considered for other suitable vacancies within the Company. The Company may also obtain information and share your information with former employers in order to obtain references, confirm qualifications and other appropriate information.
Your data will be used to comply with legal obligations, for example checking your right to work within the UK before employment commences.
Your data will be held to fulfil legitimate business interests, including being able to manage the recruitment process, assess your suitability for the role and decide whether to employ you. Your data will also be retained to defend the Company against any legal claims.
The Company will not share your data with any other third parties or transfer it outside of the European Economic Area.

Data Storage and Retention

If your application is unsuccessful, the Company will keep your information on file for 6 months after notification of outcome. If you wish your data to be kept for a longer period in order to be considered for any future suitable vacancies that arise for a total period of 12 months, you should put your request to us in writing to us. You are free to withdraw this consent at any time.

Your Rights and Obligations

Under the General Data Protection Laws you have the right to:

• Request a copy of the information that we hold about you.
• Ask the Company to amend incorrect or out-of-date data.
• Ask for the Company to erase or stop processing your data if it is no longer necessary for it to be held for its’ original purpose.
• Object to the Company processing your data where we are relying on legitimate interests as the legal basis for processing.
• Complain to the Information Commissioner’s Office if you believe that the Company has breached your data protection rights.

Automated Decision Making

We do not base our recruitment decisions on automated decision making.

Changes to Privacy Policy

The Policy will be reviewed on a regular basis.

Please contact the HR Manager if you have any questions concerning this Privacy Policy Statement.

On Behalf of the Board of Directors as a collective
Darren Emms
Secretary
The Alan Nuttall Partnership Ltd
Effective from June, 2015.

THE ALAN NUTTALL PARTNERSHIP LTDMODERN SLAVERY POLICY STATEMENT MODERN SLAVERY ACT 2015 STATEMENT FOR FINANCIAL YEAR 2018

Introduction

The Alan Nuttall Partnership Ltd is committed to preventing slavery and human trafficking throughout our business and those associated with our business. Modern slavery encompasses slavery, servitude, human trafficking and forced labour. The Alan Nuttall Partnership Ltd has a zero tolerance approach to any form of modern slavery.

This is not a standalone issue but one which forms part of our approach to ensure we treat people with dignity and respect, that we source goods and services responsibly, that we promote and strive for transparency and that we conduct our business with the highest regard to ethical and environmental standards. We are committed to ensuring that all our Partnership members abide by the highest professional and ethical standards. As a commitment to eradicate modern slavery, this statement sets out the steps that The Alan Nuttall Partnership Ltd has taken and is continuing to take to ensure that modern slavery or human trafficking is not taking place within our business or our supply chain.

COMPANY STRUCTURE

The Alan Nuttall Partnership Ltd is a successful shop fitting, interior solutions and foodservice equipment business operating through three divisions; Store Fitting, Project Solutions and Foodservice Solutions. Manufacturing facilities are based at Hinckley, Leicestershire and Dudley, West Midlands.

OUR POLICIES

We operate a number of internal policies to ensure that we are conducting business in an ethical and transparent manner, these include;

• Modern Slavery and Anti-trafficking Policy which sets out our stance on modern slavery and explains how partners can identify instances and where they can go for help.
• Human Rights Policy demonstrates our respect for all fundamental human rights provisions in line with the United Nationals Universal Declaration of Human Rights.
• Anti-Bribery and Corruption Policy sets out the Partnership’s requirements and restrictions in relation to bribery and corruption.
• Ethical Guidelines Policy setting out our stance in respect of objectivity, confidentiality, conduct, conflicts of interests and independence.
• Anti-Harassment & Bullying Policy outlining the Partnership’s stance on bullying and harassment both in and out of the workplace.
• Equal Opportunities Policy promoting equality of opportunity for all.
• Whistleblowing Policy – operates so that all Partnership members know they can raise concerns about how colleagues are being treated or practices within our business or supply chain without fear of reprisals.

OUR SUPPLY CHAIN

It is likely our supply chain may employ individuals from outside of the EU and we will review our supply chain to understand if they are taking any appropriate measures to ensure eligibility to work in the UK and that there are appropriate welfare arrangements on site. The Alan Nuttall Partnership Ltd intends to conduct regular audits and have minimum standards that must be met.

SUPPLIER ADHERENCE TO OUR VALUES AND ETHICS

We have zero tolerance to modern slavery and human trafficking. To ensure all those in our supply chains and contractors comply with our values, we have put together a supplier compliance team which consists of representatives from the following departments;

• A Board Director
• Compliance/QSHE
• Human Resources
• Procurement/Supply Chain
• Sales/Commercial.

DUE DILIGENCE PROCESSES

As part of our initiative to identify and mitigate risk we are putting in place systems to;

• Identify and assess potential risk areas in our supply chain.
• Mitigate the risk of slavery and human trafficking occurring in our supply chains.
• Monitor potential risks in our supply chains.
• Protect whistleblowers.

TRAINING

To ensure a high level of understanding of the risks of modern slavery and human trafficking in our supply chains and our business, we are putting in place a training programme for all our Partnership members.

STATEMENT

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our slavery and human trafficking statement for the financial year ending 31st December 2018.

On Behalf of the Board of Directors as a collective
Darren Emms
Secretary
The Alan Nuttall Partnership Ltd
Effective from June, 2015.

THE ALAN NUTTALL PARTNERSHIP LTD
EQUAL OPPORTUNITIES POLICY

1. Policy statement

1.1 The Alan Nuttall Partnership Ltd is committed to promoting equality of opportunity for all Partnership members and job applicants. We aim to create a working environment in which all individuals are able to make best use of their skills, free from discrimination or harassment, and in which all decisions are based on merit.
1.2 We do not discriminate against Partnership members on the basis of age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation (protected characteristics).
1.3 The principles of non-discrimination and equality of opportunity also apply to the way in which Partnership members treat visitors, clients, customers, suppliers and former Partnership members.
1.4 All Partnership members have a duty to act in accordance with this policy and treat other Partnership members with dignity at all times, and not to discriminate against or harass other Partnership members, regardless of their status.
1.5 This policy does not form part of any Partnership members contract of employment and may be amended at any time.

2. Who is covered by the policy?

This policy covers all Partnership members working at all levels and grades, and also including for non-Partnership members such as consultants, contractors, volunteers, and agency staff. To provide for clarity in this policy, the above will collectively be referred to as “staff”.

3. Who is responsible for this policy?

3.1 The Board of Directors have overall responsibility for the effective operation of this policy. Day-to-day application and use of this policy is the responsibility of the HR Director who will advise the Company Secretary and the Board of Directors for annual review.
3.2 All Managers must set an appropriate standard of behaviour and leading by example to ensure that those they manage adhere to the policy and promote our aims and objectives with regard to equal opportunities. Managers will be given appropriate training on equal opportunities awareness and equal opportunities recruitment and selection best practice.

4. Scope and purpose of the policy

4.1 This policy applies to all aspects of our relationship with Partnership members and to relations between Partnership members at all levels. This includes job advertisements, recruitment and selection, training and development, opportunities for promotion, conditions of service, pay and benefits, conduct at work, disciplinary and grievance procedures, and termination of employment.
4.2 We will take appropriate steps to accommodate the requirements of different religions, cultures, and domestic responsibilities.

5. Forms of discrimination

5.1 Discrimination by or against a Partnership member is generally prohibited unless there is a specific legal exemption. Discrimination may be direct or indirect and it may occur intentionally or unintentionally.
5.2 Direct discrimination occurs where someone is treated less favourably because of one or more of the protected characteristics set out above. For example, rejecting an applicant on the grounds of their race because they would not “fit in” would be direct discrimination.
5.3 Indirect discrimination occurs where someone is disadvantaged by an unjustified provision, criterion or practice that also puts other people with the same protected characteristic at a particular disadvantage.
For example, a requirement to work full time puts women at a particular disadvantage because they generally have greater childcare commitments than men. Such a requirement will need to be objectively justified. 5.4 Harassment related to any of the protected characteristics is prohibited. Harassment is unwanted conduct that has the purpose or effect of violating someone’s dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. Harassment is dealt with further in our Anti-harassment and Bullying Policy.
5.5 Victimisation is also prohibited. This is less favourable treatment of someone who has complained or given information about discrimination or harassment, or supported someone else’s complaint.

6. Recruitment and selection

6.1 We aim to ensure that no job applicant suffers discrimination because of any of the protected characteristics above. Our recruitment procedures are reviewed regularly to ensure that individuals are treated on the basis of their relevant merits and abilities. Job selection criteria are regularly reviewed to ensure that they are relevant to the job and are not disproportionate. Shortlisting of applicants should be done by more than one person wherever possible.
6.2 Job advertisements should avoid stereotyping or using wording that may discourage groups with a particular protected characteristic from applying.
6.3 Applicants should not be asked about health or disability before a job offer is made. There are limited exceptions which should only be used with Human Resources approval. For example:
a) Questions necessary to establish if an applicant can perform an intrinsic part of the job (subject to any reasonable adjustments).
b) Questions to establish if an applicant is fit to attend an assessment or any reasonable adjustments that may be needed at interview or assessment.
c) Positive action to recruit disabled persons.
d) Equal opportunities monitoring (which will not form part of the decision-making process).
6.4 Applicants should not be asked about past or current pregnancy or future intentions related to pregnancy. Applicants should not be asked about matters concerning age, race, religion or belief, sexual orientation,
or gender reassignment without the approval of Human Resources (who should first consider whether such matters are relevant and may lawfully be taken into account).
6.5 We are required by law to ensure that all Partnership members are entitled to work in the UK. Assumptions about immigration status should not be made based on appearance or apparent nationality. All prospective employees, regardless of nationality, must be able to produce original documents (such as a passport) before employment starts, to satisfy current immigration legislation. The list of acceptable documents is available from Human Resources.

7. Staff training and promotion and conditions of service

7.1 Staff training needs will be identified through regular Performance and Development reviews. All staff will be given appropriate access to training to enable them to progress within the organisation and all promotion decisions will be made on the basis of merit.
7.2 Our conditions of service, benefits and facilities are reviewed regularly to ensure that they are available to all staff and provide access to them and ensure that there are no unlawful obstacles to accessing them.

8. Termination of employment

8.1 We will ensure that redundancy criteria and procedures are fair and objective and are not directly or indirectly discriminatory.
8.2 We will also ensure that disciplinary procedures and penalties are applied without discrimination, whether they result in disciplinary warnings, dismissal or other disciplinary action.

9. Disability discrimination

9.1 If you are disabled or become disabled, we encourage you to tell us about your condition so that we can support you as appropriate.
9.2 If you experience difficulties at work because of your disability, you may wish to contact your Line Manager or the Human Resources Department to discuss any reasonable adjustments that would help overcome or minimise the difficulty. Your Line Manager or The Human Resources Department may wish to consult with you and your medical adviser(s) about possible adjustments. We will consider the matter carefully and try to accommodate your needs within reason. If we consider a particular adjustment would not be reasonable we will explain our reasons and try to find an alternative solution where possible.
9.3 We will monitor the physical features of our premises to consider whether they place disabled workers, job applicants or service users at a substantial disadvantage compared to other staff. Where reasonable, we will take steps to improve access for disabled staff and service users.

10. Fixed-term Partnership members and agency workers

We monitor our use of fixed-term Partnership members and agency workers, and their conditions of service, to ensure that they are being offered appropriate access to benefits, training, promotion and permanent employment opportunities.

11. Part-time work

We monitor the conditions of service of part-time Partnership members and their progression to ensure that they are being offered appropriate access to benefits and training and promotion opportunities. We will ensure requests to alter working hours are dealt with appropriately under our Flexible Working Policy.

12. Breaches of this policy

12.1 If you believe that you may have been discriminated against you are encouraged to raise the matter through our Grievance Procedure. If you believe that you may have been subject to harassment you are encouraged to raise the matter through our Anti-harassment Policy. If you are uncertain which applies or need advice on how to proceed you should speak to the HR Department.
12.2 Allegations regarding potential breaches of this policy will be treated in confidence and investigated in accordance with the relevant procedure. Staff who make such allegations in good faith will not be victimised or treated less favourably as a result. False allegations which are found to have been made in bad faith will, however, be dealt with under our Disciplinary Procedure.
12.3 Any member of staff who is found to have committed an act of discrimination or harassment will be subject to disciplinary action. Such behaviour may constitute gross misconduct and, as such, may result in summary dismissal. We take a strict approach to serious breaches of this policy.

13. Monitoring and review of the policy

This policy is reviewed annually by the Company Secretary and the Board of Directors. Recommendations for change should be reported to the HR Department for tabling to the Board.

On Behalf of the Board of Directors as a collective
Darren Emms
Secretary
The Alan Nuttall Partnership Ltd
Effective from June, 2015.

THE ALAN NUTTALL PARTNERSHIP LTD ENVIRONMENTAL POLICY STATEMENT

This Policy, which continues to apply to all Nuttall locations and work activities, was originally formulated and continues to demonstrate that the Company, Directors, Partners and Contractors recognise their duties and responsibilities to all aspects of the business, which could have an impact on the environment.

The Alan Nuttall Partnership Ltd, through its Directors and Management structure, recognises and fully accepts responsibility for the activities of the company and are committed to ensure that the best environmental practice is followed wherever possible through our commitment to our certified ISO 14001 systems. The environment and the prevention of pollution in all its forms is considered to be of equal importance to all other business activities and as such the Company will ensure that adequate arrangements are available to ensure that the policy statement and its associated procedures are implemented throughout the company for the protection of the environment.

All Managers have a Duty of Care associated to all activities under their control. All staff are expected to comply with this policy, company procedures and their statutory duties in the implementation of their daily activities.

This policy will be implemented and monitored by:

• Active co‐operation of all of the Company’s Partners through the identification, evaluation and control of our activities so as to eliminate or reduce the risk of adverse environmental impacts.
• Ensuring that Directors, Managers, Supervisors, Partners and Contractors are made aware of their responsibilities for the environment and that they are given such information, instruction, training and supervision to enable them to carry out their duties effectively.

Procedures and arrangements will be established to ensure that the Company’s activities are safe and without adverse risk to the environment, which will include but is not limited to the following:

• Setting and reviewing of appropriate environmental objectives and key performance indicators.
• Continuously monitoring the Company’s environmental performance by use of Management review systems and procedures.
• Complying with all applicable legislation, regulatory statutory requirements, Pollution Prevention Guidelines as appropriate for any specific client requirements or other requirements that may be relevant.
• Committing to continually improving the Company’s procedures and, in doing so, the environment in which we operate.
• Committing to the prevention of pollution in all the Organisations activities.
• Training all Partners to ensure competence in the environmental matters appropriate to their role.
• Conserving resources by the efficient consumption of energy and materials.
• Implementing waste minimisation programmes where required.
• Co‐operating and communicating openly with our clients, public, relevant neighbours, government, regulatory authorities and all other interested parties towards the shared goal of protecting the environment.
• Regular audit and monitoring to ensure compliance to this Policy, to the principles of BS EN ISO 14001:2015 and to the identification of areas for continuing improvement.

This Policy Statement will be reviewed annually to ensure its continuing compliance to current legislation and business requirements. It is the duty of Senior Management to communicate the policy to all staff under their control.

On Behalf of the Board of Directors as a collective
Darren Emms
Secretary
The Alan Nuttall Partnership Ltd
Effective from June, 2015.

THE ALAN NUTTALL PARTNERSHIP LTD ANTI-BRIBERY & CORRUPTION POLICY

CHAIRMAN OF THE BOARD OF TRUSTEES COMMITMENT

Here at The Alan Nuttall Partnership Ltd, we are committed to observing the laws and regulations that govern our operations, regardless of where in the world those operations take place. The Management of The Alan Nuttall Partnership Ltd wants to ensure we do not engage in or facilitate any form of bribery or corruption. This policy explains our individual responsibilities in ensuring that the Company complies with anti-bribery and anti-corruption laws around the world, as well as ensuring that third parties we engage on our behalf do the same.

The aim of this policy is to:

• Set out the expected standards of behaviour in relation to bribery and corruption;
• Provide guidance and parameters on the giving and receiving of gifts and hospitality;
• Provide guidance and parameters on how to report suspected bribery or corruption or suspicious behaviour.

Alan D Nuttall
Chairman

POLICY

The Alan Nuttall Partnership Ltd – (referred to as ‘The Company’)
1. Standards of Conduct
It is The Company’s policy to prohibit all forms of corruption amongst our Partnership members, suppliers and any associated parties acting on our behalf.

You must never:

• Offer or pay bribes;
• Solicit or receive bribes; or
• Make payments to or offer gifts to any public official in order to obtain a business advantage

A bribe is the offering or, giving of a financial or other non-financial advantage to another person in order to improperly influence their views or actions. It also covers requesting, agreeing to receive or receiving a financial or other non-financial advantage to influence improperly your views or actions. The law defines improper performance as breach of trust, lack of impartiality or performance in bad faith.

Bribery of foreign public officials (in order to obtain or retain business or an advantage in doing business) as well as companies and private individuals are all equally prohibited under the laws of many countries and under this policy. The law is intentionally drafted to cover a wide range of behaviour. This policy cannot cover every possible situation that may arise when conducting business activities around the world. Each Partnership member must use their common sense in identifying activity that may violate this policy. The policy is intended to help you make the right choices when you are called upon to do so. However, when in doubt guidance should be sought from The Company Secretary.

2. Hospitality, Gifts and the Company’s Gift Register

Gifts and hospitality come in many different guises and this policy is not able to provide an exhaustive list, however, the below sets out some rules that must always be followed and also acts as a guide to help you make the right decision where the proposed gift/hospitality is not mentioned expressly below. Even where you follow these rules, you must still complete The Company’s Gift Register as described below, as this is required for all gifts and offers of gifts. Whenever you make or receive an offer of hospitality or a gift, even where you decline the offer, you must make sure it is logged on The Company’s Gift Register. To do this, you need to complete the correct form, which must be signed by your Line Manager and promptly logged with The Company Secretary. Your Line Manager’s permission must be received before any hospitality event is accepted. Bona fide hospitality and promotional, or other business expenditure which seeks to improve the image of a commercial organisation, better to present products and services or establish cordial relations is recognised as an established and important part of doing business and it is not the intention of the Act to criminalise such behaviour. When accepting or giving a gift or hospitality, you should consider the intention that accompanies it. If this is, or could be, construed as influencing improper behaviour, then it is likely to amount to a bribe. It has become commonplace for suppliers to offer free places, accommodation and/or travel to Partnership members at conferences, where the intention is that they will meet with a number of potential suppliers of products or services. These events are sometimes known as ‘reverse sourcing events’. Whilst these events do not cause a problem in themselves, Line Managers should carefully consider the implication and impression of allowing a supplier (current or potential) to fund a Partnership member’s attendance at such an event.

RECEIVING GIFTS/SAMPLES

1. Never accept or offer monetary gifts.
2. Never give the impression that the award of business is conditional upon gifts or hospitality. Nor should The Company’s Partnership members ever ask or encourage a third party to provide a gift or hospitality to them.
3. Gifts received from suppliers must never be accepted on a personal basis and must instead be placed in a raffle for charity, other than:

• Low value items such as pens, calendars, mugs and diaries that carry a company logo, which can be retained by Partnership members; or
• Low value gifts where receipt is a local/cultural tradition and it would be impolite to decline (e.g. China), which can be retained by Partnership members provided they are pre-approved by Line Managers.

4. All gifts must be delivered to a work location. Gifts must never be received at home/alternative addresses.
5. Samples received from suppliers will not become the personal property of any individual, unless purchased through a properly organised sample sale. Samples may be removed for evaluation as part of a Partnership member’s role (and returned at the end of the evaluation), but only where Line Manager’s approval is obtained through the existing samples logging system.

GIVING GIFTS

1. Never offer or give a gift to a public official, including foreign public officials.
2. Never make a cash payment to a public official other than in an official capacity.

HOSPITALITY

For certain roles it is appropriate to have dinner with a supplier (e.g. when on a foreign trip or at an exhibition). Meals and entertainment (including sporting/music events) are acceptable provided:

• They are incidental to a business-related event(s);
• Reasonable in value;
• given in good faith;
• permitted under local laws and customs;
• offered infrequently; and
• Line Manager consent is obtained prior to the activity and a form submitted to The Company Secretary.

Gifts of hospitality should always be avoided whilst a tendering process is underway or a contract or engagement is being negotiated. Occasionally, you should seek to settle the bill so as to avoid any misunderstandings and demonstrate transparency. This should be settled through The Company’s Expenses Policy, and when more than one Partnership member is involved and The Company is paying, the most senior Partnership member must pay. The Expenses Policy should be observed at all times when paying for hospitality.

3. Facilitation Payments

Facilitation payments are generally small unofficial payments made to facilitate or speed up the performance of a routine or necessary action. These are regarded as bribes under UK law, regardless of whether they may be part of the ‘way of doing business’ in a particular country. As a representative of The Company, you must not make a facilitation payment.

4. Intermediaries/Associated Parties

The Company’s standard procurement Terms and Conditions already include appropriate references to compliance with Bribery and Corruption legislation. When using third party contracts it must be ensured that the third party agrees to the same compliance causes being incorporated into that contract. The Procurement Team or Company Secretary can help you with this drafting. You should be alive to our suppliers ‘influencing’ local officials with routine tasks such as customs clearance, duty preference documents or favourable treatment of the import/export of raw materials. Where a party refuses to sign a contract containing this provision or asks for it to be removed from the Standard Terms and Conditions, the refusal must be escalated to The Company Secretary, who will assess the impact of the supplier’s refusal and decide on an appropriate next step. Any known bribery in the supply chain should immediately be confidentially reported to The Company Secretary or any of the other reporting mechanisms below.

5. Board Endorsement and Reporting of Concerns

The Company’s Board of Directors will not criticise Management for any loss of business resulting from adherence to this policy. No Partnership member or contractor will suffer as a consequence of bringing to the attention of the Board or Senior Management, in good faith, a known or suspected breach of this policy nor will any Partnership member or contractor suffer any adverse employment or contract decision for abiding by this policy. If you are aware of or suspect that bribery or corruption is taking place within The Company or you have a genuine concern about inappropriate commercial conduct, you have a number of routes available to you to escalate your concerns. You should choose the most appropriate route to report your concerns. These include;

• Your Line Manager;
• Your Line Manager’s Manager;
• The HR Department;
• The Company Secretary;
• Concerns surrounding inappropriate conduct in matters of bribery and corruption, financial reporting, acts of dishonesty or any other malpractices will be investigated and dealt with in line with the Whistleblowing Policy, and/or Disciplinary Policy.

Line Managers have a responsibility to escalate claims or concerns of the nature outlined above.

6. Accountability and Compliance

All suspected breaches of this policy will be fully investigated. This may lead to disciplinary action being taken up to and including summary dismissal.

7. Guidance and Training

Training is an important part of the implementation of The Company’s Anti-bribery Policy and procedures. Training will be available to all Partnership members wishing to attend however, it will be mandatory for all Partnership members in the following groups:

• Executive and Management teams;
• Procurement Team:
• Any other Partnership member considered to fall into high risk groups by the Company Secretary from time to time.

8. Monitoring and Review

The Company Board will monitor this policy at least annually and through periodic review of Internal Audit findings. This policy will be reviewed every three years by The Company Secretary, or sooner where the Board so requires, where there is a change in law or practice or where the Group’s risk profile significantly changes, for example where it moves into other geographies or markets, or materially alters its sourcing model.

On Behalf of the Board of Directors as a collective
Darren Emms
Secretary
The Alan Nuttall Partnership Ltd
Effective from 1st June, 2015.