Employee Handbook 2022

Page 1

Employee Handbook 2022


Contents I 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14.

II 1. 2. 3. 4. 5. 6. 7. 8. 9.

III 1. 2. 3. 4. 5. 6. 7. 8. 9. 10.

Section I Conditions of Employment Employment The Working Week Payment of Salaries and Wages Annual Holidays Illness and Injury Medical Examinations Time Off Training Policy Transfer Recognition of Trade Unions Redundancy Procedures Shortage of Work and Restricted Access to Work Pensions and Retirement Termination of Employment

5 6 7 8 9 10 11 11 11 12 12 12 12 13

Section II Family Friendly Policies Time Off for Antenatal Appointments Maternity Rights Adoption Leave Paternity Leave Parental Leave Shared Parental Leave Family Emergency and Care of Others Bereavement Leave Parental Bereavement Leave

15 15 16 16 16 17 17 18 18

Section III Personal Conduct and Dispute Resolution Procedures Personal Conduct Relationships at Work Policy Dispute Resolution in the Workplace Disciplinary Procedures for Addressing Misconduct Use of the Shortened Procedure Disciplinary Procedure for Addressing Performance Grievance Procedure Frustration of the Disciplinary Procedures Equal Opportunities Anti-harassment and Bullying Policy

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Contents IV 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. 24. 25. 26. 27.

Section IV General Terms and Company Policy Company Vehicles Driving Licence Accidents at Work Intranet, Notices and Noticeboards Personal and Company Property Handling Money Telephones Smoking Policy (Including E-Cigarettes) Alcohol and Drugs Machinery, Tools and Equipment Personnel Records Security Computer Equipment and Systems Social Media and Personal Internet Presence Data Protection Disclosure of Information Bribery Gifts Public Interest Disclosure - Whistleblowing Conflict of Interest Personal Appearance and Workwear Expense Claims Financial Conduct Authority Quality, Customer Service and Treating Customers Fairly Modern Slavery Discounts to Staff Electric/Hybrid Vehicle User Charge

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Contents V 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. 24. 25. 26. 27. 28. 29. 30. 31. 32. 33. 34.

Section V Health and Safety at Work Introduction Organisation Abrasive Wheels Access and Egress Accident Reporting Airbags Asbestos and Dust Contractors Control of Substances Hazardous to Health Detonators Display Screen Equipment (DSEs Electricity Environmental Fire First Aid Hand Tools Health and Hygiene Health Surveillance Highly Flammable Liquids (HFLs Horseplay Local Exhaust Ventilation (LEV Manual Handling Noise Occupational Driving Office Safety Personal Protective Equipment (PPE) Fuel Draining and Fuel Tanks Plant and Equipment Risk Assessment Valeting Vehicle Movement Hand-arm Vibration Welding Working At Height

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I

Section I Conditions of Employment

1. EMPLOYMENT I am pleased to welcome you to Cathedral Motor Company Limited (“the Company”) and wish you every success in your role. I hope your association with the Company will be a long, successful and happy one. This Handbook contains terms and conditions of employment, details of employee benefits and general Company rules which, together with your letter of appointment and/or individual Statement, form the basis of your Contract of Employment. In the event of a conflict between the terms in this Handbook and your letter of appointment and/or individual Statement, then the terms in your letter of appointment and/or individual Statement will prevail. You should study each section carefully to ensure that you are fully acquainted with both the benefits to which you are entitled and the rules governing your employment. If you are uncertain about any section of this Handbook, please contact your Department Manager. From time to time, changes to these conditions and rules may be necessary. You will be notified of any subsequent amendments or additions in writing. The Company is in the service/customer care business, and its success depends on all of us maintaining and improving standards of service, knowing that the quality of our service is the one thing that can distinguish us from our competitors. It is essential, therefore, that in whatever action you take on the Company’s behalf, you maintain the highest standard of courtesy and service towards our customers at all times. Our aim is total customer satisfaction. Please play your part to achieve that aim. It is intended that you should have every opportunity to use and develop your talents, to enjoy good companionship and feel a personal pride in sharing Company achievements. You are expected to make a full contribution by working well consistently and observing the policies, terms and conditions explained in this Handbook and your offer letter. When documents are referred to as part of your conditions, you can read them at any reasonable time on request to your Department Manager.

New Employees Prior to starting work, all new employees are required to complete and sign the Company’s employment application documents and an induction programme to ensure your health and safety whilst in our employment. You will also be required to bring relevant certificates (including driving licence and a mandate which will authorise the Company or a third party appointed by the Company to check your driving licence directly with the DVLA) for verification for any qualification claimed. Incorrect or misleading information provided on these forms can render the employee liable to dismissal. All offers of employment with this Company are subject to a probationary period and receiving a satisfactory reference through either an internal or third-party reference checking procedure. When reporting for work, new employees are required to produce their National Insurance number, P45 income tax form and banking details. In the absence of this form, income tax deductions will be made using an emergency code, with any overpayment being adjusted on receipt of the P45. No wages can be paid without an NI number. Before commencing employment, ALL persons will be required to prove their identity and their right to work in the UK.

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The Probationary Period The first 12 months of employment will be a probationary period. During this time, you will be given the opportunity to learn your new role and be provided with support and guidance to help you reach the standards of performance and competence expected by the Company. Please discuss with your supervisor any aspect of your work or operating procedures that requires further clarification. During the probationary period the Company may terminate your employment for any reason. The Company’s disciplinary procedure does not apply in any circumstance during your probationary period. Equal Opportunities Policy

It is Company Policy of engagement that solely objective standards and personal merit shall determine progression. No applicant or employee will be treated less favourably than another on grounds of sex, sexual orientation, age, disability, marital status, race, religion or belief, gender reassignment, maternity or pregnancy. Please act in the spirit of this policy.

2. THE WORKING WEEK Details of your basic working week, and the starting and finishing times, are set out in your offer letter and statement of terms and conditions. The hours of work may be varied to meet the needs of the business. You are expected to work that pattern of hours except when authorised to be absent for holidays, sickness etc. A high standard of punctuality is essential to maintain the service to customers. If you are late for any reason, or returning after absence, please report as soon as possible, in person, to your Department Manager. Salaries and wages are only paid for authorised hours worked and recorded. From time to time, you will be requested to work different hours and/ or overtime in order to meet specific production or customer requirements. Employees may also be required to participate in promotional launches, business development events or stocktaking exercises that may be undertaken outside of normal working hours and may be weekends or bank holidays. It is the intention of the Company to provide, where possible, reasonable notice for changes in hours of work including overtime working and the reasons for requesting the cooperation of the employees in meeting the needs of the job. In some departments, shifts or continual overtime are necessary, and your offer letter will tell you whether you are affected when you join. It will also state whether you are paid for overtime, the shift rates and/or premiums. Overtime working is subject to variation according to the circumstances prevailing. The Working Time Regulations place a maximum limit of 48 hours per week (averaged over a period of 17 weeks) that can be compulsorily worked at the Company’s request. However, if the employee wishes to work longer than 48 hours, they may do so, providing that they sign an individual voluntary agreement to opt out of this limit. The employee may cancel this agreement at any time and again be bound by the 48 hours statutory limit. Employees engaged in unmeasured work (i.e. not on time sheets) are required to keep a record of their hours worked. No employee will be expected to work excessive hours or to cooperate with unreasonable requests for overtime working. However, failure to cooperate, given the circumstances are reasonable, may be deemed to contravene the terms and conditions of employment with the Company. Employees and management having no overtime pay provisions may be required to work some unpaid additional hours in order to fulfil their responsibilities. Due to operating in the retail sector and in order to satisfy customer requirements you may be required to work weekends and on public holidays.

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3. PAYMENT OF SALARIES AND WAGES Your initial rate of pay, the intervals at which it will be paid, and whether any bonus or commission applies to you are explained in your letter of appointment and/or individual Statement of Terms and Conditions. Salaries and Wages are paid by bank transfer to a bank or building society account of your choice. You will be provided with access to receive your payslip electronically online. The Company reserves the right at any time to review, vary or withdraw any of its bonus or commission arrangements and will give you at least one month’s notice of any change. Any payments made under any bonus or commission arrangement will be at the sole discretion of the Company. The Company is required by law to make certain deductions from your pay, which includes National Insurance contributions and PAYE income tax. As a term of your employment, the Company has the right to make deductions from your wages/salary any sums, which you owe to the Company or as a result of the Company’s overpayment made because of (but not limited to): •

Unpaid private mileage or private mileage, which exceeds the agreed upper limit

Reimbursement to the Company in respect of outstanding monies owed for wage advances, loans, goods, materials and/or services received including company car scheme by you

Reimbursement of training costs if the employee terminates their employment before the expiry of the required service period agreed at the time of training

In the event of termination of your employment for any reason, payment for any holiday taken, in excess of your pro rata holiday entitlement for that annual leave year, will be deducted from final monies due

In circumstances where there has been, for any reason whatsoever, an overpayment of remuneration, expenses or other emoluments to you, or any other payment in excess of your contractual entitlement

The value of any fuel over and above the allocated allowance

To cover any monies owed to the Company in the event of theft or misappropriation by an employee of Company property or damage to Company property by an employee including to vehicles provided under any company car arrangements

To cover the cost of Company property including protective clothing that is lost or wilfully damaged during employment or not returned on leaving employment

In the event of termination of employment, an employee failing to give the correct notice may have a deduction made from any monies due, equal to the amount that would have been earned from the date of leaving until the end of the remaining unworked notice period

In the event of restricted access to work due to poor weather conditions, fuel shortages, pandemics etc., the Company reserves the right to make such absences unpaid and therefore deductible from salary payments

Monies paid under court order, i.e. wage arrestment (attachment of earnings), child support payments etc.

Motor-related fines incurred by the employee (or authorised family member) whilst in a Company vehicle and any unrecoverable insurance excess and uninsured losses as a result of the employee (or authorised family member) being involved in an accident.

This term of your employment is without any prejudice to any deductions that may have to be made from your pay in accordance with a statutory requirement or court order, or which are in respect of any other contractual arrangements or arrangements authorised by you for the payment of sums to the Company or third parties.

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4. ANNUAL HOLIDAYS Except where otherwise agreed by the Company, the following provisions on holiday entitlement will apply: The standard holiday entitlement for employees who are contracted to work for five days or more is 22 days paid holiday per holiday year. The holiday entitlement increases by one additional day to 23 days total, in the first full holiday year after completing 5 years’ service with the Company. Parttime employees are entitled to the same holiday benefits as full-time employees, on a pro-rata basis according to their hours/days of work. You will be entitled to one-twelfth of your annual holiday entitlement for each completed calendar month of service between your date of engagement and the following 31st December in your first year of service, rounded up to the nearest half-day. If you leave the Company for any reason, you will be entitled to payment in lieu of holidays earned but not taken, at the rate of one-twelfth of your holiday entitlement for each completed month of service in the year in which you leave. If you have already taken more than your paid holiday entitlement, a deduction will be made from your final wage or salary payment, amounting to the difference between paid holiday taken and your entitlement at the time of leaving. During any period of notice that you are not required to work and for which payment is made, the holiday entitlement relevant for such period is deemed to be included in the payment (i.e. you will not be paid twice for the same period of time). The holiday year starts 1st January and entitlement cannot be carried forward from one year to another, unless extraordinary circumstances exist (e.g. pandemic) and this must be approved by your Departmental Manager. Whilst aiming to meet everyone’s holiday requirements, it is not always possible due to the need to ensure that the Company is adequately staffed during the holiday period. Therefore, holidays may only be taken at times mutually convenient to your Department Manager and yourself. Holidays should be booked and approved via the online portal and it is recommended that you agree your holiday dates as far in advance as possible. The needs of the business may require that you take some part of your holiday entitlement at certain times of the year and the Company reserves the right to nominate those times and the right to direct employees to take holiday. In this regard, the Company is closed on Christmas Eve, therefore, if Christmas Eve is an employee’s normal working day, then it is mandatory that it must be taken as 1 day’s holiday from the employee’s annual holiday entitlement. No cash payments may be made in lieu of holidays not taken, unless you qualify on leaving the Company. If you become sick on the first day of your holiday, you must notify the Company on the first day on which the holiday would have become due and provide a medical statement to cover the entire period of sickness before the holiday can be postponed. The duration of the rearranged holiday will only be for the period covered by the medical certificate and must be subject to the needs of the business. Sickness commencing on the second or subsequent day of the holiday will not entitle the employee to postponement of the holiday. No more than 10 days’ holiday may be taken at any particular time. You will also be paid for the following statutory holidays. •

New Year’s Day

Good Friday

Easter Monday

Early May Holiday

Spring Holiday

Late Summer Holiday

Christmas Day

Boxing Day

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These may be varied by local agreement and other days substituted for them. You will also be paid for any other days declared as public holidays.

5. ILLNESS AND INJURY You must notify by telephone your Department Manager of your absence at least 30 minutes prior to your normal start time on the first day of illness. You will be required to state the reason for your absence and your expected return date. The call will be logged and the reason for absence noted. If you are not well enough to return to work on the date stated, then you should telephone again to advise your Department Manager of this. Messages left on ‘answer phone’ will not be accepted as proper notification. If your Department Manager is unavailable then you may notify another Line Manager on site. In no circumstances is a text message acceptable. Failure to do so may result in any sick pay being withheld. After one week, a Doctor’s Certificate is required from you. On your return to work you will be required to attend a return-to-work interview with your Department Manager and asked to complete a Company Self-Certification Certificate, and if your absence is longer than one week provide a Medical Certificate confirming your fitness to return to work. Your Department Manager will see all completed certificates and the document will be used to decide whether or not Company Sick Pay should be paid and/or Statutory Sick Pay is due. Medical Certificates are usually required every week, but once a month is acceptable in cases of serious illness. Failure to complete a Self-Certificate or providing false or inaccurate information on the certificate will be treated as a serious disciplinary offence. However, the Company may require a medical statement to cover any absence from work prior to Company sick pay being paid. Statutory Sick Pay will be paid directly to you by the Company for certified sickness through the normal pay arrangements, if you qualify, for up to a total of 28 weeks in a year. The Company has no contractual obligation to make any payment for periods of sickness. However, at the discretion of the Company, an allowance may be paid, equal to full basic pay, depending on the duration of your absence and for periods of sickness or injury absence that exceeds three working days. Company Sick Pay is only payable strictly at the Company’s discretion and the receipt of such a payment on any occasion shall not provide an entitlement to future payments. Sick Pay will be assessed on your basic salary and is calculated as a pro rata amount, taking into consideration the number of hours absent as a proportion of contracted weekly hours of work. Income tax, National Insurance, Pension Scheme contributions and all other agreed repayments are deductible from Company and Statutory Sick Pay. Where absence from work results from an accident/incident involving a third party, any payment of Company Sick Pay will need to be repaid to the Company in the event of a successful claim against the third party. The Company reserves the right to: •

Withhold payment of Sickness Pay should any employee behave in a manner likely to retard recovery, attempt to abuse the scheme in any way, or where it is evident that the illness or injury was the direct result of the employee’s own negligence or misconduct

To visit employees at home

Ask an employee drawing sick pay to attend a medical examination with a doctor or an occupational health practitioner nominated by the Company where additional medical evidence is felt necessary. The Company reserve the right to withhold the payment of sick pay until findings of the medical examination are available. The Company will be responsible for the costs relating to

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the medical examinations or reports. The opinion of the Company doctor or occupational health practitioner shall be final and conclusive •

To discipline and ultimately terminate the employment of an employee who has an unacceptable sickness record compared to the Company’s norm

Interview any employee on their return to work following an absence to establish the reasons for the absence and whether any further investigation is deemed necessary

Claim back from the employee the cost of sickness payments made, should the employee have successfully claimed or been awarded damages from a third party on account of such illness or injury.

To provide objectivity in managing short-term absences, the Company has introduced a formal absence monitoring system. The scheme ensures that all employees are treated fairly and consistently when dealing with absence from work and will differentiate genuine reasons for absence from more questionable absences by identifying frequent, short-term and unacceptable absence patterns. Every employee will have a return-to-work interview with his or her manager immediately following a period of absence. These discussions are not disciplinary interviews; they are designed to understand the facts surrounding the absence and will be used to complete the employee’s absence certification record and to provide advice on areas of concern and/or draw the employee’s attention to unacceptable trends and/ or review the need for job modifications and/or agree future actions. If disciplinary action is warranted as a result of the absence, then this will be dealt with separately using the Company’s disciplinary procedure. Each absence will generate absence points, which will accumulate over a rolling 52-week period using the following formula: •

P x P xT

P is the number of Periods of absence and T is the Total number of days absent

For example: •

5 incidents of a 1-day absence will generate an absence score of 5 x 5 x 5 = 125

1 incident of a 5-day absence will generate an absence score of 1 x 1 x 5 = 5

Whilst absence monitoring is a continuous process, the following ‘Trigger levels’ are set to identify when an employee’s absences have reached a level that require disciplinary action to be taken (and assume no existing warnings in effect). All actions will be consistent with the usual disciplinary rules and procedures. •

60 points Verbal Warning

150 points First Written Warning

350 points Final Written Warning

730 points Dismissal

Absences that will not attract a score under the scheme are: agreed holiday, authorised absences (e.g. jury service, TA, compassionate leave, specialist medical/antenatal appointments) and pregnancy-related illness. Continuous period of long-term sickness (longer than 14 days) will be scored as 1 incident of 15 days, regardless of its actual length.

6. MEDICAL EXAMINATIONS Employees joining the Company may be required to pass a medical examination by one of the Company’s Doctors or an occupational health practitioner before their appointment is confirmed. In addition, employees may be required to attend a medical examination by one of the Company’s Doctors or an occupational health practitioner at any time during their employment with the Company. This will be particularly necessary when the employee, as a result of his/her job, comes into regular contact with substances governed by C.O.S.H.H. The Company also reserves the right to test employees in order to detect the presence of alcohol and

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or non-prescribed drugs.

7. TIME OFF Staff may not leave their department without the prior permission of their immediate supervisor. Time off during working hours from your place of work is solely at management discretion. Leave of absence, without pay, will be granted for Jury and Witness Service, for certain Civil and Community duties and for service with the Armed Forces Reserve. Prior to committing yourself to any voluntary service, please check that the total time involved is compatible with your responsibilities at work. Application for time off should be made in writing to your Department Manager. The Company reserves the right to grant paid leave of absence at any time. Any grants or allowances will be offset against any Company payment and should be recovered by you.

8. TRAINING POLICY Our policy is to provide training at all levels to increase the efficiency of employees and thereby the Company, and to ensure job satisfaction and good career prospects for all our staff. Our objective is to achieve this by improving your working skills and developing your individual capabilities to the fullest extent. You will receive appropriate training to enable you to carry out your work efficiently and to keep you up-to-date with techniques and products, in conjunction with ‘on-the-job’ training within the Company. Should you identify a training need, please advise your Department Manager. Where the Company has paid course and examination fees, the Company reserves the right to claim full repayment from the employee should he/she resign from the Company within 6 months after the completion of the course, and 50% repayment should the employee resign within 12 months of the completion of the course. You may be required to attend courses run by outside organisations and colleges, which may occasionally necessitate time away from home. Reasonable expenses incurred will be reimbursed, providing prior authority has been gained from your Department Manager. Employees who do not attend a booked training course, without good reason, may be held personally liable for the wasted costs incurred. Such charges will be subject to the completion of a formal investigatory process. Employees who advise on and sell insurance and finance products are required by law to undertake appropriate training and pass assessments to demonstrate competence in selling such products and comply in accordance with the Company’s Financial Conduct Authority related approval. Your Department Manager will review your training needs regularly.

9. TRANSFER Occasionally, you may be required to work at another of the Company’s locations to meet special circumstances. You will be given as much notice as possible and reimbursed for any additional reasonable expenses incurred.

10. RECOGNITION OF TRADE UNIONS

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The Company does not have a recognition agreement with any trade union. Your employment is not bound by any trade union collective negotiation agreement, recommendations from national wage councils or other similar organisations. The Company recognises the right of an individual either to join or not to join a trade union.

11. REDUNDANCY PROCEDURES Subject to the maintenance of operational efficiency and continuing success of the Company, management will seek to avoid the need for compulsory redundancies by such means as: •

Restrictions on recruitment, reductions in overtime

Re-training or transfer to other work (including other locations)

Consider applications made for voluntary redundancy

If no volunteers are forthcoming, then selection for redundancy will then be based on performancerelated criteria relevant to the job category or functions and may include absence, disciplinary, sickness records, range of skills, productivity, flexibility and work attitude. The redundancy selection pool will be drawn from an individual site unless there is a well-established history of mobility between sites. In considering employees for redundancy, the Company will also consider: •

The needs of the business & employees available for re-deployment

To maintain a realistic balance of skills within the reduced workforce.

In the event of redundancy due to the needs of the business, reorganisation, etc. you will receive the Statutory Redundancy payments, if you qualify.

12. SHORTAGE OF WORK AND RESTRICTED ACCESS TO WORK If there is a shortage of work the utmost endeavour will be made to maintain continuity of employment by placing people on short time or suspending them from work without pay. Notice will be given for any such lay-off but this will not constitute termination of a Contract of Employment. This will be done in accordance with the provisions of current employment legislation. If the situation arises where an employee is able to work but is prevented from making the journey into work (e.g. bad weather, fuel shortage, vehicle problems, road or rail disruptions etc.), the Company reserves the right not to pay the employee for this time and to make any such deductions from salary until the situation is rectified. As an alternative, employees may choose to take time off as part of paid holiday entitlement. In the event that the business is instructed by Government or other statutory authority to cease working or restrict the work activities that it is able to perform due to national emergency or other reason (e.g. Covid pandemic) the Company reserves the right to lay off employees without pay. Subject to circumstances and where possible, the Company will seek to reduce the financial effect on employees created by such imposed closures, by claiming available grant or other payments that may be available.

13. PENSIONS AND RETIREMENT There is no default retirement age and any employee wishing to retire will be obliged to serve the Company with the period of notice required under their contract to terminate their employment.

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The Company is required to automatically enrol employees into a workplace pension scheme to help them to save for their retirement. You will be eligible to enrol into the pension scheme if: •

You earn over the minimum earnings threshold which is set annually by the Department for Work and Pensions (DWP)

Are aged 22 or over; and

Are under the state pension age.

You will be enrolled into the Company’s Auto Enrolment Pension Scheme after three months of joining the Company in accordance with the eligibility described above. This is a contributory pension scheme and requires both the employee and employer to contribute. The employee contributions will be deducted directly from your wages. The rate of contribution is 5% from the Employee and 3% from the Company; however, the contribution rates may escalate as set out by the government. If you decide that you do not want to join the pension scheme, you will be able to opt out within one month of your date of enrolment. In this case, any contributions that have already been taken from your pay will be returned to you and you will be treated as if you had never joined the pension scheme. Employees are strongly advised to take professional advice before deciding not to join this scheme; and should have an alternative retirement savings plan in place. Please be aware that the Company has no legal obligation to contribute to any other scheme. You can stop contributing at any time. In accordance with the pension scheme rules, if you do this, the contributions made by you and the Company up to that point will remain invested in your pension pot until you take your benefits. If you do not meet the joining criteria then you will not automatically become a member of the scheme, but you do have the right to elect to join our pension scheme if you want to. In this case, the same contribution rates and terms will be applicable. However, it should be noted that employees earning less than a minimum level set by the government may be entitled to join the scheme but not receive the employer’s contribution. Employees aged over 74 will not be entitled to join the scheme.

14. TERMINATION OF EMPLOYMENT Our aim is for your service with the Company to be long and successful. However, if you decide to leave you must give notice, in writing, to your Department Manager. After the first four weeks of service the following minimum periods apply, unless otherwise advised in your offer letter: •

Hourly paid and salaried staff – at least one month’s notice

If the Company gives you notice after four weeks’ or more service, the following minimum periods apply, unless otherwise advised in your offer letter, or in cases of serious misconduct: •

Less than two years’ service – one week

Over two years’ service – two weeks

There is then one additional week of notice for each year over two years of service up to a maximum of 12 weeks for 12 years’ service or more. When leaving the Company’s employment for whatever reasons, the Company reserves the rights to deduct from any sums owing to you any sums that you owe to the Company (and by signing these terms you consent to this deduction). The Company may, at its absolute discretion, require you not to attend your place of work for the duration of your notice period and may, at its discretion, relieve you of some or all of your contractual duties during that period. On termination of employment, the Company reserves the right to require employees to leave immediately and make a payment in lieu of notice. You will not for a period of one year after ceasing to be employed by the Company on your own behalf or on behalf of any person firm or Company directly or indirectly:

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Solicit or procure business from any person firm or Company which has at any time within two years immediately preceding such cessation been a customer of the Company

Sell products or services that compete with the Company’s business within a radius of 10 miles from any of the Company’s premises

Endeavour to entice away from the Company any employee of the Company

Employ any person who was an employee of the Company.

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II

Section 2 Family-Friendly Policies

1. TIME OFF FOR ANTENATAL APPOINTMENTS If you are pregnant, you may take reasonable paid time off during work hours for antenatal appointments. Please try to give us as much notice as possible of the appointment. We may ask you to provide a certificate or appointment card from the doctor, midwife or health visitor stating that you are pregnant. You make take unpaid time off to accompany a pregnant woman to up to two antenatal appointments lasting no more than 6.5 hours each if you have a “qualifying relationship” with the woman or the child. This means that either: •

You are the baby’s father or

You are the pregnant woman’s spouse, civil partner or cohabiting partner.

This also applies in the cases of assisted conception and surrogacy arrangements. Please give us as much notice of the appointment as possible. You must provide us with a signed statement providing the date and time of the appointment and confirming that you meet one of the eligibility criteria and the purpose of the time off is to accompany the pregnant woman to an antenatal appointment arranged by a registered medical practitioner, midwife or nurse.

2. MATERNITY RIGHTS The leave and payment provisions and right to return to work will mirror the statutory provisions provided for under the statutory maternity scheme. It is in your best interests to inform your Department Manager as soon as you are aware that you are expecting a baby. This is necessary to make sure that your working conditions and environment are assessed to ensure that there is no risk to you or the unborn child. Naturally, wherever possible, we will not divulge your condition other than to those employees who need to know. The timing of any general announcement remains at your discretion. All Employees will be eligible to take up to 26 weeks’ ordinary maternity leave (OML). The employee will be required to notify the Company of her pregnancy, the expected date of childbirth and the date on which she intends to start her ordinary maternity leave in or before the 15th week before the expected week of childbirth (EWC). OML can commence on or after the 11th week before the EWC (28 days’ notice of the expected leave date is required if reasonably practicable), on the day of childbirth or, if the employee is absent from work due to a wholly or partly pregnancy related reason, less than four weeks before the EWC. Employees shall not be permitted to work during their compulsory maternity leave, which is the twoweek period following the birth of their child. Subject to qualification, Employees will normally be entitled to receive Statutory Maternity Payments (SMP) for up to 39 weeks. The first six weeks are paid at the rate of 90% of average weekly pay and the balance is paid at the prescribed SMP rate. Employees have the right to return to their same job after taking OML. On return, their service will be continuous, seniority rights preserved and their terms and conditions of employment being no less favourable than those that would have applied had they not been absent.

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Following OML, all Employees are entitled to take up to a further 26-week period of additional maternity leave (AML). Employees that have taken AML (or an equivalent period of leave using a combination of other leave entitlements) have the right to return to work in the same job or, if that is not reasonably practicable, an alternative job that is suitable and appropriate. Should the employee wish to return to work early, i.e. before her full entitlement to maternity leave is exhausted, then eight weeks’ notice of the intended return date is required. During the periods of ordinary and additional maternity leave, the employee may work (or attend training course, etc.) for up to 10 days “keeping in touch days” without losing statutory payments or bringing the leave to an end. It should be noted that such days must be through joint agreement, may be taken at any point through the leave period (except during the mandatory leave period) and any days worked will not have the effect of extending the leave period. All the contractual benefits that the employee was receiving immediately before they began maternity leave will continue except remuneration (i.e. you will receive maternity pay instead of your usual salary and contractual allowances). During the period of maternity leave, the Company has the right to make reasonable contact with its employees.

3. ADOPTION LEAVE Will be available to employees (of either sex) who adopt a child. The leave and payment provisions and right to return to work will mirror the statutory provisions provided for under the statutory maternity scheme. To qualify, the employee must be able to provide evidence of entitlement (such as a matching certificate) and has continuous service for a period of not less than 26 weeks ending with the week in which notification of matching was provided by an adoption agency. The employee will be required to notify the Company of their intention to take adoption leave as early as is reasonably practicable. These provisions are complex in general and only a general outline is provided above. The Company will provide detailed and specific guidance on all aspects of this entitlement and qualifying conditions on request from the employee.

4. PATERNITY LEAVE Paternity Leave will be available in respect of children born or matched for adoption. Eligible employees will be entitled to take two weeks’ paid leave during the first eight weeks of the child’s life (or from joining the adopting family). Payment is at the prescribed statutory paternity payment rate, which is set by the government each year. To qualify, employees must have 26 weeks’ continuous service by the end of the 15th week before the start of the week when the baby is due or if adopting the end of the week you are notified you are matched with your child. You must provide a minimum of 28 days’ notice in requesting such leave and provide evidence of their entitlement to statutory paternity benefit. On request by an employee, the Company will provide detailed guidance on this entitlement.

5. PARENTAL LEAVE Employees (of either sex) who have had a baby or adopted a child and have completed one year’s qualifying service with the Company by the time they want to take their leave, have the right to take parental leave. This leave may be taken at any time to look after or make arrangements for the child’s welfare. Parental leave is unpaid. Employees will be entitled to take up to a maximum of 18 weeks for each child until the child’s 18th

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birthday. 21 days’ notice must be given of your intention to take parental leave. Normally, leave must be taken in multiples of one week (or multiples of one day for children with disability), up to a maximum of 4 weeks in any one year for each individual child. The Company has the right to postpone the leave for up to 6 months where the business would be particularly disrupted if the leave were taken, except on the occasion of the arrival of the baby or adopted child. At the end of the parental leave, providing the absence has been for a period of 4 weeks or less, employees are guaranteed the right to return to the same job. For leave periods longer than 4 weeks including employees who have taken parental leave following on from maternity leave have the right to return to a similar job that has the same or better terms.

6. SHARED PARENTAL LEAVE Shared Parental Leave is a right that is designed to give parents more flexibility in how to share the care of their child in the first year following birth or adoption. Eligible mothers, fathers, partners and adopters will be able to share a pot of leave, and can decide to be off work at the same time and/or taking it in turns to have periods of leave to look after the child. To qualify for Shared Parental Leave and Pay, a mother must be entitled to maternity or adoption leave, or statutory maternity or adoption pay or maternity allowance and must share the main responsibility for caring for the child with the child’s father or her partner. In addition, they will be required to follow a two-step process to establish eligibility.

Step 1 - Continuity test: A parent seeking to take Shared Parental Leave must have worked for the same employer for at least 26 weeks at the end of the 15th week before the week in which the child is due (or at the week in which an adopter was notified of having been matched with a child or adoption) and is still employed in the first week that Shared Parental Leave is to be taken. The other parent has to have worked for 26 weeks in the 66 weeks leading up to the due date and have earned above the maternity allowance threshold of £30 a week in 13 of the 66 weeks.

Step 2 - Individual eligibility for pay: To qualify for Shared Parental Pay, the parent must, as well as passing the continuity test, also have earned an average salary of the lower earnings limit or more (currently £123) for the 8 weeks prior to the 15th week before the EWC. It will be for the mother or adopter to continue on maternity leave or opt to take Shared Parental Leave. Shared Parental Leave may be taken at any time within the period that begins on the date the child is born or date of the placement and ends 52 weeks after that date. Leave must be taken in complete weeks and may be taken either in a continuous period, which the Company cannot refuse or in a discontinuous period, which can be refused.

7. FAMILY EMERGENCY & CARE OF OTHERS Occasional time off work to attend unforeseen family or domestic emergencies will be permitted. In such cases, you must notify the Company of the absence as soon as practically possible stating the reason for the absence and the time the absence is expected to last. Such absence is unpaid and intended to enable you to make alternative arrangements, arrange cover, etc. Absence from work to attend the sickness of a family member would normally be counted against annual holiday entitlement. To ensure that this time off is not misused, the Company reserves the right to request evidence of the requirement to take time off. Any abuse of this system will lead to disciplinary action.

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In exceptional circumstances and entirely at the discretion of the General Manager, you may be granted a period of leave, which may be paid or unpaid.

8. BEREAVEMENT LEAVE You will be granted up to three days’ leave, with pay, in the event of a death of a close relative, to help you to make arrangements and attend the funeral (i.e. mother, brother). The Company payment for up to three days’ leave is the same as that for Annual Holidays. Please advise your Department Manager if you need bereavement leave.

9. PARENTAL BEREAVEMENT LEAVE Parental bereavement leave is time off to deal with the death of a child, if they die under the age of 18 or are stillborn after 24 weeks’ pregnancy. Employees may take up two weeks’ paid leave of absence on the death of their child, adopted child, step child or child for whom they have direct parenting responsibility for. This statutory leave will apply to children who die under the age of 18 years and to stillbirths during pregnancy after 24 weeks. The payments will be made subject to eligibility and in accordance with the procedures and rates published by the UK Government. Any employee who experiences the death of a child or other dependant and wishes to seek support is encouraged to do so. The HR Department can direct employees seeking support to organisations that may be able to assist them or refer them to the Company’s occupational health providers.

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III

Section 3 Personal Conduct and Dispute Resolution Procedures

1. PERSONAL CONDUCT Employees must at all times carry out instructions and reasonable requests made directly by management or through their supervisors. If doubts are expressed as to the correctness of any instruction, the circumstances should be discussed through the established grievance procedure.

2. RELATIONSHIPS AT WORK POLICY 1. About this Policy 1.1 This policy governs personal relationships in the workplace. When we use the phrase “personal relationship” in this policy, we mean any emotional or romantic relationship that goes beyond the normally accepted boundaries of the professional sphere between colleagues. This will include formal, family relationships (for example, where people are married or living together). It will also include less formal situations (for example, where the parties consider that they are “seeing each other” or “going out together”). 1.2 This policy applies to all personal relationships between any member of staff, regardless of whether those involved work in the same team, department, division or office, or at the same site. 1.3 This definition is not intended to be exhaustive. Given the sensitive nature of personal relationships, all staff are required to use common sense in assessing whether or not this policy is relevant to them. If any person is unsure whether this policy applies to their circumstances, they should seek advice from the company’s HR department or a senior manager. 1.4 We respect the right of all our staff to a private life. We also understand that many people meet their partners at work and that personal relationships between staff are inevitable. For the avoidance of doubt, this policy is not intended to prohibit staff from having a personal relationship with a work colleague. It is intended to set out guidelines for their conduct within the workplace and to provide a framework for managers to deal sensitively, consistently and fairly with personal relationships that may affect the business. 1.5 This policy does not form part of any contract of employment or other contract to provide services, and we may amend it at any time. 2. Purpose of this Policy 2.1 In many cases, a personal relationship between staff will not interfere with work. However, sometimes a personal relationship will be or become problematic because it adversely impacts on other colleagues or negatively affects business efficiency. Personal relationships can be particularly problematic where they involve members of the same team or are between a supervisor or manager and subordinate. 2.2 This means that personal relationships are potentially a legitimate management concern. In issuing this policy, we seek to address the following, non-exhaustive, issues that may arise where there is a personal relationship: •

Lack of transparency in relation to workplace matters and potential for negative effect on general perception of fairness, objectivity and impartiality

Risks to the confidentiality of business information

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Legal risks regarding discrimination and harassment

Potential conflicts of interest of those involved in personal relationships

Actual or perceived bias regarding recruitment, promotion, annual leave allocation, appraisals, discipline and grievance and other operational matters where staff in a personal relationship are also in a direct reporting or subordinate relationship

Fear of favouritism by other colleagues

General adverse impact on team dynamics and reduction in team morale

Workplace disruption, impact on HR department or management resources and increased legal risks in the event of relationship breakdown.

3. Management Guidelines 3.1 Where a manager becomes aware that a member of their team is in a personal relationship with a colleague, they are required to treat this sensitively and, as far as possible, in confidence. 3.2 Most personal relationships should not have a significant impact on the workplace or efficiency of work. However, managers need to recognise their responsibility to all team members and to the needs of the business. 3.3 No action should be taken simply because a staff member is in a personal relationship with a colleague. Only if there is an issue or risk as outlined above should action be considered. 3.4 Managers will know that they must not discriminate against staff on various protected grounds. They should particularly consider the characteristics of sex, sexual orientation and age before taking any action as a result of a personal relationship. For example, it should not be assumed that the more junior person in a couple will be transferred out of a team, as this could be indirectly discriminatory. 3.5 Managers should be aware that conduct directed towards a colleague for personal reasons may be unwanted and that, in some circumstances, this could amount to unlawful harassment for which the employer could be liable. We will take any grievances (formal or informal) seriously and investigate these without delay. Managers should escalate any complaints of this nature to the HR department. 3.6 Any information regarding personal relationships is confidential and likely to be protected under data protection laws. Managers are reminded about their data protection obligations under the law, including ensuring the security of such information. 3.7 Managers are also reminded that we have a duty to protect the health and safety of our staff and that this includes mental health. If a manager has concerns regarding the health impact of a personal relationship on a member of staff they should bring this to the attention of the HR department without delay. 3.8 Given the highly sensitive nature of personal relationships, managers should seek the assistance of the HR department before dealing with any issues which may arise. They should also ensure that a note is taken of any meetings to discuss issues arising under this policy. 4. Conduct of those in personal relationships 4.1 Any members of staff who are in a personal relationship are expected to conduct themselves in a professional manner at work at all times in respect of such relationship. This means being considerate of the feelings of their other colleagues in their day-to-day dealings and being discrete in any discussions regarding their private life within the workplace. Public displays of affection are inappropriate in the work sphere. 4.2 Our equipment and resources are provided for work purposes only. Any inappropriate use in furtherance of a personal relationship will be treated as a disciplinary matter. 4.3 Our confidentiality rules continue to apply regardless of any personal relationship. Staff must ensure that they protect all confidential and commercially sensitive information from unauthorised disclosure. 4.4 As a matter of policy, colleagues who are in a personal relationship should not also be in manager/

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subordinate roles in the workplace. Where such a personal relationship arises, both parties are required to inform the HR department, in confidence, as soon as reasonably practicable. We will then liaise with those involved to agree a plan to minimise the impact of the personal relationship on the business. For example. This may involve changing line management responsibility or, where this is not feasible, transferring an affected employee to a different team or office. If this is not possible for operational reasons, then we will consider putting in place appropriate safeguards to ensure transparency and fairness. 4.5 Failure to disclose a personal relationship as required by this policy will be treated as a disciplinary matter and, subject to investigation, could result in disciplinary action, up to and including dismissal.

3. DISPUTE RESOLUTION IN THE WORKPLACE It is essential that the Company’s management and employees are aware of and have access to clear and established procedures to enable disputes in the workplace to be resolved in a fair and equitable manner. There are three specified procedures for resolving disputes within the Company. The first is the disciplinary procedure that is used to address alleged employee misconduct, the second is used to address shortcomings in performance (ability to perform the role), and the third specifies the procedure for employee grievances. The use of these procedures to resolve workplace disputes is a contractual requirement, and failure to use these internal procedures may preclude you from seeking an external remedy at a later date.

4. DISCIPLINARY PROCEDURES FOR ADDRESSING MISCONDUCT

All Disciplinary Procedures are non-contractual. The main purpose of the disciplinary procedure is to ensure that the employee whose actions or conduct fails to meet the required Company standard can be advised of what is required and given the opportunity to improve. Disciplinary action will be objective, consistent and fair and may be taken against an employee whose conduct or failings can be construed as being: •

Detrimental to the interests of the employer, its suppliers or customers

A hazard to the health, safety or security of themselves or others

Offensive to the employer, other employees, or customers of the Company.

When such instances arise, employees will be advised that they have failed to meet the requirements of their employment, and for minor breaches, this will be dealt with on an informal basis. Such advice will not constitute the initiation of the disciplinary procedures. However, if these minor breaches cannot be resolved informally or failings are not corrected, then this will require that the formal procedure be implemented. In such cases, should the employee be found to be in breach of the required standards, then one of a range of disciplinary sanctions may be applied. The sanction applied will be determined by the seriousness of the misconduct and the existence of previous “live” disciplinary warnings and will fall into one of the following categories.

Stage I - Recorded Verbal Warning Such a warning will be given in the event of a minor act of misconduct or breach of the terms and conditions of employment or some other minor failure to meet accepted standards.

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The employee will be informed of their failing, given advice regarding what corrective action is required and made aware that failure to adopt this advice will result in the next stage in the disciplinary procedure being applied. A record of the warning will be made on the employee’s personnel file and will remain in effect for a period of 12 months. Stage II - First Written Warning A written warning will be given where there has been a repeat of a previous failing or where the employee has failed to adopt the required corrective actions given at Stage I or where there has been a first but serious act of misconduct. The employee will be advised in writing of their failing, the corrective actions required and made aware that failure to adopt this advice will result in the next stage in the disciplinary procedure being applied. This warning will be placed on the employee’s personnel file and will remain in effect for a period of 12 months.

Stage III - Final Written Warning A final warning will be given where there has been a further repeat of a previous failing or where the employee has failed to adopt the required corrective actions given a Stage II or where there has been a first but particularly serious act of misconduct. The employee will be advised in writing of their failing, the details of the previous warnings issued (if applicable), the corrective actions required and made aware that failure to adopt this advice will result in the termination of their employment. This warning will be placed on the employee’s personnel file and will remain in effect for a period of 12 months. The employee will be required to sign the warning to acknowledge receipt.

Stage IV - Dismissal Dismissal will be considered where there has been a further repeat of a previous failing or where the employee has failed to adopt the required corrective actions given a Stage III or where there has been an incident of gross misconduct or gross negligence. The employee will be advised in writing the reasons for their dismissal. Dismissal as a result of consecutive disciplinary warnings will be subject to the statutory notice period. Dismissal as a result of gross misconduct/negligence is without notice.

5. USE OF THE SHORTENED PROCEDURE As stated above, the Company may instigate disciplinary action at the disciplinary level appropriate to the circumstances and may omit one or more stages of the disciplinary warning system. That is, if serious misconduct is proven, the Company may issue a final written warning without having need to first issue either a verbal or first written warning. In cases that are considered to be gross misconduct / negligence, then summary dismissal may be a first disciplinary sanction. Examples of gross misconduct warranting instant dismissal include: •

Conduct that is incompatible with the precepts of the organisation including the deliberate refusal to carry out reasonable, lawful and safe instructions

Dishonesty, theft, misappropriation or removing property from the Company, another employee, its suppliers or customers of the Company

Making a false statement to the Company, including those made at the time of engagement, entries in Company documents, records & accounts

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Accepting inducements from third parties in connection with the Company’s affairs, including wrongful disclosure of confidential Company information to a third party

Gross immoral behaviour, including the downloading and or viewing of pornographic images on the Company’s computer systems

Being unfit to carry out duties as a result of alcohol or non-prescribed drugs or in possession of unlawful drugs while on the Company’s premises or business or driving a Company vehicle

Alteration of a time card, recording another employee’s time or having your time recorded by someone else

Failure to notify the Company of any work accident, damage to property or fault that affects the safety of others, work equipment or vehicle

Gross negligence in carrying out duties instructions, wilfully ignoring responsibilities or instructions, thereby placing others in danger

Conducting acts of violence, including assault or threatening behaviour whilst on the Company’s premises or business

Conducting acts of vandalism and deliberate damage to property, equipment, products etc.

Any act deemed by the management to be seriously detrimental to the Company’s interests including discriminatory behaviour on grounds of age, sexuality, gender, race, religion or disability

Failure to follow safe working practices, thereby endangering yourself and others

Failure to follow both Company and statutory procedures in regard to money laundering (i.e. it is Company policy that you must not accept payments in cash in excess of £1,000)

Releasing a vehicle or part to a customer without the Company having received cleared funds whereby the Company incurs an unapproved cash debtor. Authority and approval must be sought prior to the release of any such vehicle or part from a Director of the business

Deliberately mis-selling a General Insurance product including, intentionally misleading a customer in the pursuit of General Insurance sales and/or encouraging a subordinate or fellow employee to mis-sell a General Insurance product.

The above list is not exhaustive.

6. DISCIPLINARY PROCEDURE FOR ADDRESSING PERFORMANCE All Disciplinary Procedures are non-contractual. It is essential that all employees are capable of fulfilling the position in which they are employed. If their capability is in question and normal counselling has failed then a strategy for improvement will be developed with the employee. This strategy will provide support, training and guidance (if appropriate) to overcome particular difficulties and consider whether there are any latent reasons for such difficulties (e.g. health, other personal reasons, workload, etc.) and will be conducted within a formal disciplinary procedure. This will provide a framework by which performance can be monitored, and if no improvement is forthcoming then steps can be taken towards implementing corrective actions. A reasonable and realistic time frame will be adopted. Where a manager is not satisfied with the individual’s ability to perform their duties, the following procedure will be adopted: Informal Warning Employees will be advised if they fail to meet the expected levels of performance and made aware of the required levels. In the first instance this will be dealt with on an informal basis. Such advice will not constitute the initiation of the formal disciplinary procedures for capability. However, if these failings continue then the formal capability warning procedure will be implemented.

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First Warning The elements described in the dispute resolution procedure (investigation, invitation, hearing, appeal) will be applied and used to draw the employee’s attention to their failure or shortcoming in their expected performance and review reasons to account for this performance. Advice will be given in writing on the improvement required, any support to be given and the period of time for achievement. The employee should also be made aware of the actions that will be taken if the required performance is not achieved. The manager will review the employee’s performance on a continuing basis throughout the specified time period and will provide appropriate counselling or training as is deemed necessary.

Final Warning If the employee has failed to reach the required standard at the end of the specified period, the same procedure will be used to again identify the failing and actions required. A final written warning will be issued that will state the specific reasons for the warning, the improvements expected of the employee and the time period allowed for this improvement. The manager will monitor the employee’s performance on a continuing basis providing appropriate counselling, training or advice. Dismissal or other Actions If, after having followed this procedure, the employee has still failed to reach or sustain the required standard of performance, disciplinary action will be taken. The range of actions available for consideration will include transferring the employee to a job within their level of ability, a reduction in wages, or their employment terminated. All actions are subject to the employee’s contractual terms of employment. The employee’s attention is to be drawn to both the Grievance and Appeals procedures. The employee can implement either or both of which, if they are dissatisfied with the actions being taken against them under the capability procedure.

7. GRIEVANCE PROCEDURE Nobody can work efficiently and enthusiastically if they feel they have a workplace grievance or an employment problem on their mind. In such circumstances you may wish to try to resolve these issues by discussion with the Company’s management. If you believe that your problem may be readily addressed locally or is of a nature that would be better addressed informally, then this should be discussed in the first instance with your immediate supervisor so the matter may be cleared up as quickly as possible. If the grievance cannot be resolved informally, or your grievance is with your immediate supervisor, another manager, or relates to a wider or more serious Company issue you should use the Company’s formal grievance procedure. The formal grievance procedure is set out below: Statement of Grievance The employee should set out in writing the basis of the grievance, with sufficient supporting information to enable the issues to be understood. The statement of grievance should be sent to the relevant manager who you believe will be able to deal with the matter. Your grievance may be passed onto a more appropriate person who is better qualified to deal with the issues being raised.

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Grievance Meeting The manager handling the matter will invite the employee to attend a meeting to discuss their grievance with a view to resolving the issues or collecting further information by which to arrive at a decision. The Company will inform the employee of its decision in response to the grievance raised and notify the employee of their right of appeal against the decision if dissatisfied with the outcome. Grievance Appeal In the event of the grievance not being resolved to the employee’s satisfaction, an appeal may be made to the next more senior level of management. The appeal must be made in writing, setting out the basis of the grievance and reasons for the appeal. The Company will invite the employee to a further hearing and provide an opportunity to discuss their grievance and objections to the original decision. After due consideration and further investigation if required, the employee will be informed of the Company’s decision regarding their appeal. In the unlikely event that the employee feels that the issues raised have not been properly addressed, or where the employee wishes to make a confidential protected disclosure (“whistle blowing”) a written submission may be made to the Company’s Managing Director who will review the situation with the employee. The actions taken by the Managing Director in relation to the grievance shall be final and binding on all parties. Employees may use the grievance procedure to draw the Company’s attention to issues at any point during their employment. Even after employment has ceased with the Company, this procedure may be used in an attempt to resolve problems. In such cases, where the issue is a relatively straightforward factual matter, for example, calculation of termination payments, payment of outstanding holiday entitlement, etc. It may be appropriate and acceptable to both parties to deal with the grievance as a written exercise without the need to meet, unless this would be appropriate. The disciplinary procedure is separate and distinct from the grievance procedure. Disciplinary procedures shall not be affected or interrupted by the employee invoking the grievance procedure. That is, the disciplinary action and appeal process will be allowed to take its course and any grievance will be dealt with afterwards.

8. FRUSTRATION OF THE DISCIPLINARY PROCEDURES On occasion, employees have been known to attempt to frustrate the disciplinary process by a variety of actions including non-cooperation, failure to attend meetings and sickness absence. Whilst each case will be dealt with on its merits, the following provisions are included to overcome frustration of the disciplinary process, notwithstanding the employee’s right to fairness and the rules of natural justice. The basis of the disciplinary procedures in the event of a perceived frustration will normally be to accord the employee the following: In the case of short-term sickness, consideration will be given to the postponement of the hearing, to provide a reasonable opportunity for the employee to regain health to state his or her own case. The period of time that it is considered reasonable to postpone the hearing will normally be up to 2 weeks. A judgement will be made at this time, whether it would be reasonable to grant a period of additional postponement. This will be made in knowledge of the known or expected length of absence. If the employee’s return is not expected in the short term, the employee will be invited to submit his or her representation to the hearing either in written form or through a representative (who is either their trade union representative or fellow employee) at the meeting. The representative will be provided with the same rights as the employee and able to present the facts of the defence, question witnesses and produce evidence to demonstrate the employee’s defence. If the employee declines to provide a written submission or present his case through a representative

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or the representative refuses to attend, the hearing may still go ahead, since the employee and his representative have been afforded the opportunity to make representations. In such an instance, should the decision go against the employee, the time limit in which to appeal the decision may be extended to afford a further opportunity for the employee to present his or her case.

9. EQUAL OPPORTUNITIES The Company is committed to promoting equal opportunities in employment. You and any job applicants will receive equal treatment regardless of age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation (“Protected Characteristics”). All managers must set an appropriate standard of behaviour, lead by example and ensure that those they manage adhere to the policy and promote our aims and objectives with regard to equal opportunities. All employees must not unlawfully discriminate against or harass other people including current and former employees, job applicants, clients, customers, suppliers or visitors. This applies in the workplace, outside the workplace (when dealing with customers, suppliers or other work-related contacts (or when wearing a work uniform), and on work-related trips or events including social events. The following forms of discrimination are prohibited under this policy and are unlawful: •

Direct discrimination: treating someone less favourably because of a Protected Characteristic. For example, rejecting a job applicant because of their religious views or because they might be gay.

Indirect discrimination: a provision, criterion or practice that applies to everyone but adversely affects people with a particular Protected Characteristic more than others, and is not justified. For example, requiring a job to be done full-time rather than part-time could adversely affect women because they generally have greater childcare commitments. Such a requirement may be discriminatory unless it can be justified.

The following terms may also be used in the context of discrimination

Harassment: this includes sexual harassment or other unwanted conduct related to a Protected Characteristic, which has the purpose or effect of violating someone’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment. Harassment is dealt with further in our Anti-harassment and Bullying Policy.

Victimisation: retaliation against someone who has complained or has supported someone else’s complaint about discrimination or harassment.

10. ANTI-HARASSMENT AND BULLYING POLICY Harassment is any unwanted physical, verbal or non-verbal conduct that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. A single incident can amount to harassment. It also includes treating someone less favourably because they have submitted or refused to submit to such behaviour in the past. Unlawful harassment may involve conduct of a sexual nature (sexual harassment), or it may be related to age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation. Harassment may include, for example: •

Unwanted physical conduct or “horseplay”, including touching, pinching, pushing and grabbing

Continued suggestions for social activity after it has been made clear that such suggestions are unwelcome

Sending or displaying material that is pornographic or that some people may find offensive

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(including emails, text messages, video clips and imaged sent by mobile phone or posted on the internet) •

Unwelcome sexual advances or suggestive behaviour (which the harasser may perceive as harmless)

Racist, sexist, homophobic or ageist jokes, or derogatory or stereotypical remarks about a particular ethnic or religious group or gender

Offensive emails, text messages or social media content.

Bullying is offensive, intimidating, malicious or insulting behaviour involving the misuse of power that can make a person feel vulnerable, upset, humiliated, undermined or threatened. Power does not always mean being in a position of authority, but can include both personal strength and the power to coerce through fear or intimidation. If you are being harassed or bullied, consider whether you feel able to raise the problem informally with the person responsible. You should explain clearly to them that their behaviour is not welcome or makes you uncomfortable. If this is too difficult or embarrassing, you should speak to your Group HR Manager who can provide confidential advice and assistance in resolving the issue formally or informally. If informal steps are not appropriate, or have been unsuccessful, you should follow the formal procedure set out above in the Grievance Procedure.

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IV

Section 4 General Terms and Company Policy

1. COMPANY VEHICLES No employee is permitted to drive on behalf of the Company any motor vehicle belonging to it or in its custody without prior authority being obtained from your Department Manager. Any unauthorised use of Company or customer vehicles may result in disciplinary action being taken. Any Company car, when provided, is done so, on the basis that it is required to enable you to carry out your job effectively. If this criterion should no longer apply, the Company reserves the right to withdraw the car without adjustment to your emoluments. Therefore, the private use of a Company car remains at the absolute discretion of the Company. The vehicle, when available for private use, may only be driven by the Employee and their spouse provided that they have completed a Spouse’s Driver Form and their use is then authorised in writing by a director. The employee will be responsible for the security of the vehicle at all times, and equipment belonging to the Company should be removed or secured when leaving the vehicle. Personal property will be deemed to be the sole responsibility of the driver. Any Company car used by you should always be kept in a clean and tidy condition, ready for sale or demonstration at any time. It is the driver’s responsibility to ensure that oil and water levels are checked regularly and that any routine maintenance or warranty repairs are completed promptly. Failure to maintain your Company car may result in the benefit being withdrawn and may result in disciplinary action being taken. If you are involved in an accident while driving a Company vehicle or in its custody and it is concluded by the Company or the investigating authorities to have been caused by your negligence, in addition to disciplinary action you may be liable to reimburse to the Company the cost associated with repairing the vehicle or any insurance excess, up to a maximum of £1,000. Should you be involved in an accident, the following procedure must be adhered to: •

Note date and time of accident

Note place of accident, weather conditions and visibility

Note condition of driving surface

Note full details of others involved – name, address, vehicle owner (where different from driver), vehicle make, colour, registration number and the name of the Insurance Company

Note full name and addresses of any witnesses together with Police Officers’ names and numbers (if in attendance)

Do not admit liability under any circumstances and no statement should be made verbally or in writing to the police at the time of the accident (you have a legal right not to make any such statement). The only information you should impart is your name and address together with details of the Company

Note carefully statements of others

Note carefully extent of all damage and any injuries

Sketch map showing position of vehicle(s) immediately before and after the accident, skid marks, road width, etc.

Take breakdown recovery action as appropriate ideally to a Company location

Report the incident to the Finance Director and complete an accident report form.

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You must not use your own vehicle on Company business. Company vehicles must not be used for motor sport of any kind nor for hire or reward. Payment of any fine or penalty for parking or other motoring offence is your personal responsibility. The first occasion that you delay or fail to settle a parking surcharge or fine, the Company will pay the sum due to the authorities and then deduct the amount from the next payment of expenses or salary due to you (to which deduction you will have agreed to by signing these terms and conditions). Employees under the age of 25 will not be insured under the Company’s insurance policy for driving vehicles with an engine capacity of 1.6 litres or above for social and domestic purposes. Your Department Manager will give further details regarding use and insurance cover of Company cars to you. It is a further condition of your employment that you accept your Department Manager as the sole arbiter of driving ability, and the Company reserve the right to withdraw the use of vehicle without notice.

2. DRIVING LICENCES Employees who are required to drive a vehicle on behalf of the Company must hold a current driving licence appropriate for this purpose. The Company also reserves the right to conduct eyesight tests for employees who are required to drive vehicles on behalf of the Company. It is the employee’s responsibility to immediately notify the Company of any changes to their licence or driving capacity including penalty points added. Employees who lose their licence for any reason must not drive any Company vehicle either on or off the Company’s premises. Where it is an express or implied condition of your employment that you hold a current driving licence, the Company reserves the right – after consideration of the circumstances – to terminate your employment if your licence is withdrawn or suspended by the Licensing Authorities or is lapsed by you. A photocopy of your driving licence will be held on file and the Company will regularly check employees’ driving licences for validity and endorsements directly with the DVLA. All employees are required to cooperate with this process. It is your responsibility to inform your Department Manager of any endorsements that may occur.

3. ACCIDENTS AT WORK It is a legal requirement that all accidents, however minor, are recorded – this can be done via the online portal or the Accident Report Book. Therefore, you must report any accident or incident where injury is sustained (or could have been sustained), to your Department Manager. In this way you will be assisting the Company in ensuring that the safety of your working environment is continually monitored. Any queries should be directed to your immediate manager.

4. INTRANET, NOTICES & NOTICEBOARDS We acknowledge the need for good communication processes. Please visit the notices on the Intranet and also the information on your noticeboards, which are provided to display Company and other authorised communications; employees should regularly inspect these boards and read the displayed notices. Employees must not remove, destroy or deface any notice, bulletin or other information posted by, or with the authority of the Company. Employees wishing to use the noticeboards must get prior approval from their supervisor. The misuse of the notice boards will lead to appropriate disciplinary action. All users are given secured access to the Intranet system whilst on the Company’s network, on the

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strict basis that the information contained is for internal use only and must not be communicated to external parties or used for commercial or personal benefit. It must not be abused; the Company may withdraw permission for it at any time and may further restrict access at its discretion. The information available to all staff published on the Company Intranet is confidential and should be treated as such.

5. PERSONAL AND COMPANY PROPERTY The Company cannot accept liability for the loss of an employee’s personal property, including tools, left on the Company premises. Similarly, any vehicles, motorbikes or pedal cycles parked on Company premises are left entirely at their owners’ risk. Employees are reminded that any tools brought onto site remain their responsibility and you are strongly recommended to keep such tools in secured lockers and that they are not insured. All Company equipment and property should be handled with care and protected or stored when not in use. Company equipment including computers, tools, etc. should not be taken off the Company premises. All equipment on loan from the Company must be returned on termination of employment. The parking of private vehicles on Company premises is totally at Company discretion and there is no contractual entitlement to on-site parking. Vehicles can only be parked in those areas set aside for this purpose. The Company does not accept liability for any damage or loss, where cars are parked on site but incidents should be reported. There is a maximum speed limit of 5mph in force on all sites. Employees in breach of these rules will be asked to find alternative parking arrangements.

6. HANDLING MONEY The Money Laundering Regulations 2003 are aimed at eliminating the practice of cash payments in legitimate business transactions being used to launder money obtained from criminal activity. Penalties for breach of these Regulations may lead to an individual criminal penalty of up to two years’ imprisonment and/or a fine, with HMRC also having the power to apply civil penalties of up to £5,000 for each failure to comply. In order to protect both the Company and its employees from infringing these Regulations, our policy for cash transactions is as follows: •

Cash payment in excess of £1,000 for a single transaction will not be accepted from customers.

Please note that £1,000 is the total transaction limit and not just an individual payment. For example, a customer could not come in over 4 days paying £500 per day (i.e. £2,000 cash) for a vehicle part payment. The £1,000 amount is the total for that whole vehicle transaction. All staff must adhere to this rule without exception. Any member of staff responsible for accepting or allowing payments of over £1,000 from a customer in cash (whether as one payment, or multiple smaller ones, which total over £1,000) will be deemed guilty of misconduct and subject to disciplinary action. The Company does not accept cheques as a method of payment from retail customers, and this includes banker’s drafts. The only acceptable methods of payment are cash, direct bank transfer, and credit/debit card (when validated by chip & pin PDQ machine). Employees must ensure that they receive payment in full for all goods before they are handed over to the customer. Service collect and deliver must be paid via credit/debit card over the phone before the customer’s vehicle is returned to them. Cash or other payments received from customers outside normal office hours must be securely deposited in the dealership safe and must not be taken off the premises under any circumstances. A pre-printed voucher must support all petty cash expenditure. The Line Manager and the employee who has spent the money should sign the voucher and provide a description of the expenditure. Wherever practicable, this should be attached to a receipt. The Company operates strict cash handling procedures. Cash taken to the bank must be taken directly

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to the bank and deposited immediately. Other duties or errands must only be conducted after the banking has been completed. One person may take banking up to the value of £6,000 and amounts from £6,000 to £12,000 require two persons to accompany the money. A security company must be used to move amounts of money greater than £12,000. As the Company incurs charges for all cheque and card transactions, employees are strictly prohibited from drawing cash from Company tills against personal cheques or debit/credit card and must not use the Company’s resources for their own personal banking needs. Failure to comply with the above terms will be considered to be gross misconduct.

7. TELEPHONES Employees are reminded that the Company telephones are provided for business use and should only be used for private purposes in cases of emergency. Telephone calls made on the Company’s telephone system may be recorded and used for either disciplinary or training purposes. The Company reserves the right to claim back from the employee the costs incurred through private calls. Employees are not permitted to text, make or receive private mobile phone calls during their working hours as this creates unnecessary distraction and disruption to the working day. Private telephone calls should be made during recognised work breaks. Private incoming calls of an urgent and important nature should be directed through the Company’s switchboard. The use and recharging of mobile phones in the workshop areas is expressly prohibited on the grounds of safety. Drivers of Company vehicles are reminded that the use of mobile telephones whilst driving is illegal unless using a hands-free or similar adaptor. Even with such equipment, it is recommended that the driver find a safe place to stop and park the vehicle before making or receiving telephone calls.

8. SMOKING POLICY (INCLUDING E-CIGARETTES) Smoking is not permitted in any work area including offices, toilets and vehicles belonging to the Company or its customers. Smoking is only permitted outside the building in the designated smoking areas. Cigarettes should be disposed of safely in the receptacles provided, that is not stubbed out and left on the floor. Employees are not permitted to leave their workstation outside their normal authorised break periods to smoke. Any employee failing to adhere to this policy will be subject to disciplinary action, which could result in their dismissal.

9. ALCOHOL & DRUGS Employees are expressly prohibited from consuming alcohol or non-prescribed drugs on the Company’s premises or attending work while under their influence. Being under the influence of or in possession of these substances while on the Company’s premises or business is deemed to be gross misconduct, and the employee will be subject to summary dismissal. The Company reserves the right to test any employee suspected of being under the influence of drink or drugs. Employees in receipt of prescribed medicines to treat medical conditions must check with their GP that there are no side effects caused that may be deleterious to their safety (e.g. drowsiness, inability to concentrate, loss of balance etc.) whilst at work.

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10. MACHINERY, TOOLS AND EQUIPMENT Employees are normally expected to provide themselves with tools, which are customary to their crafts. At the discretion of the Company, advances, to be repaid, may be made for the purchase of some tools. Any other tools and equipment are the property of the Company, and must not be taken from the premises. Machinery, tools or equipment that appear to be faulty should be turned off immediately, isolated from the power supply and reported immediately to a supervisor. Before leaving work, every person involved must ensure that tools and equipment etc. are deposited and secured in the assigned place and that their immediate place of work, machine or equipment are left safe. For health and safety reasons, work equipment may not be used out of hours. Under no circumstances may the Company’s work equipment be taken off the site for private use. Employees leaving the Company must surrender all tools and equipment that have been supplied by the Company. Employees losing or damaging tools and equipment may be held responsible for the cost of replacements.

11. PERSONNEL RECORDS Employees must inform the person who maintains the personnel files of any change of address or other personal details, so that records can be kept up to date. Incorrect records can result in serious delay should it become necessary to notify your family in case of sickness or accident. The Company will need to collect and process employees’ personal data. This will include personal details, education/training records, employment information, financial details, driving licence details and performance records to enable it to fulfil its contractual and statutory obligations in regard to employment, administration, payroll & performance management. Only the information required to enable these functions to operate is obtained and processed; and without it the Company would not be able to meet its obligations. The Company does not require your express consent to enable it to process this type of information, as this is a statutory requirement and/or considered to be in the best interests of the data subject. The General Data Protection Regulations (GDPR) regulate the collection, processing and sharing of personal data in any format (hard copy and digital) by the Company. ‘Personal data’ is defined as any information relating to a living individual, and ‘processing’ is any activity carried out involving personal data, including its holding and storing. Information may be passed between relevant departments within the Company and it may also be passed to external organisations by reason of statutory or regulatory obligation (e.g. HMRC, RIDDOR, court order), or where it is necessary for legitimate interests of the Company (e.g. business service providers, legal advisors) or where it is necessary to protect the vital interests of the employee or others (e.g. to ensure their safety and well-being). In doing so there shall be a lawful reason and proportionate delivery of information for the service provided and this shall not be to the detriment of interests or rights of individuals. The Company may also use automated recording systems, such as telephone, email, internet browsing history, CCTV, premises entry/ time keeping, and/or vehicle tracking to collect and store information that may capture data about the employee. This data is used for staff/ Company security, identify staff training needs, maintain brand standards and resolve disputes. The Company may also undertake mystery shops (which may involve video/audio capture), monitor live calls and use the data collected for training and performance management purposes. Some types of information or personal data, such as that relating to health, disability, biometrics (including fingerprint readers), equality monitoring, criminal history, background checks (including taking up previous employment references) is categorised as being “sensitive or special” in nature. If this type of personal information data needs to be collected/ processed, then the employee will be advised of this need, the purpose for which the information is required and asked to provide their explicit consent for that information to be collected/ processed.

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All persons have the right to request to inspect the data that the Company holds about them and they also have the right to request that any inaccurate information being held is corrected and in some cases, they may request the information be erased, although this will be subject to the purpose for which it is being used. The Company is committed to the correct, lawful and fair handling of all personal data, respecting the legal rights, privacy and trust of all individuals with whom it deals. A more detailed Personal Data Policy is available.

12. SECURITY All visitors and contractors who go beyond the normal public areas must first report to reception, be accompanied by a member of staff in these areas and ensure that they have been signed in and out of the premises using the visitors’ book. This employee will be responsible for ensuring their visitors’ health and safety whilst on the Company premises and their safe evacuation from the premises, in the event of an emergency. The Company reserves the right to request any employee entering or leaving the Company’s premise to show to a member of management the contents of any parcel, bag, or article of clothing carried or worn by them. The Company also reserves the right to request to search any vehicle in the Employees’ charge whilst on Company property. Employees being searched will have the right to have another member of staff present at the time. Employees’ failure to cooperate with a reasonable request may result in disciplinary action being taken, and if theft or other criminal activity is suspected then the matter will also be handed over to the police. Key holders to the premises shall only access the premises outside of normal business hours for legitimate business reasons. All key holders must ensure that they know how to disarm and reset the security systems correctly and, where applicable, should advise the alarm monitoring company in advance. The Company’s premises are alarmed and monitored by closed circuit television surveillance. Where an act of dishonesty is suspected, the Company reserves the right to use the data collected by these security systems as evidence to instigate or support disciplinary action.

13. COMPUTER EQUIPMENT & SYSTEMS The Company recognises that use of computers and the internet has many benefits for the Company and its employees. The internet and email make communication more efficient and effective. Therefore, employees are expected to use the internet as outlined in this policy. Unacceptable usage of the internet can place the Company and others at risk. The following terms have been established for using Company PCs in an appropriate, ethical and professional manner. The Company’s internet and email access may not be used for transmitting, retrieving or storing of any communications of a defamatory, discriminatory or harassing nature or materials that are obscene or pornographic. No messages with derogatory or inflammatory remarks about an individual’s race, age, disability, religion, national origin, physical attributes or sexual preference shall be transmitted. Disparaging, abusive, profane, or offensive language; materials that would adversely or negatively reflect upon the Company or be contrary to its best interests; and any illegal activities – including piracy, cracking, extortion, blackmail, copyright infringement, and unauthorised access to any computers on the Internet or email are forbidden. Copyrighted materials belonging to entities other than the Company may not be transmitted by employees on the Company’s network. All employees obtaining access to other companies’ or individuals’ material must respect all copyrights and may not copy, retrieve, modify or forward

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copyrighted materials, except with permission or as a single copy to reference only. If you find something on the Internet that may be interesting to others, do not copy it to a network drive. Instead, give the URL (uniform resource locator or “address”) to the person who may be interested in the information and have that person look at it on his/her own. Do not use the system in a way that disrupts its use by others. This includes excessive downloading, sending or receiving many large files and “spamming” (sending email messages to thousands of users). The use of portable electronic media like CD/DVD, memory cards or USB drives is not permitted without approval of the Group IT Manager. Each employee is responsible for the content of all text, audio or images that he/she places or sends over the Company’s Internet and email system. Email is not guaranteed to be private or confidential. All electronic communications are the Company’s property. Therefore, the Company reserves the right to examine, monitor and regulate email messages, directories and files, as well as Internet usage. No employee should use the Company’s email or the internet for personal reasons during business hours. The employee’s Company email address should only be used in relation to Company business. It should not be used as a personal email account. The Company reserve the right to suspend an employee’s access to its IT systems and/or divert emails should the employee be unable to perform their role due to absence from work or suspension. Occasional internet use for personal reasons during approved breaks or lunch is acceptable subject to the approval of your manager. Internal and external email messages are considered business records and may be subject to discovery in the event of litigation. Be aware of this possibility when sending email within and outside the Company. Employees are not allowed to access at any time: •

File-sharing websites

Music/video file-sharing websites

Torrent websites

Instant messaging anyone for anything other than business is forbidden. This includes Skype, Zoom, Microsoft Teams etc. The downloading of software should be done only with the approval of the Group IT Manager. No employee has software installation permission. If you are presented with a message box asking for permission to download software or an “Active-X” control, click the red X in the top-right corner of the message box and/or exit the website immediately. Do not click the “OK” or “Cancel” buttons in a message box, as malicious website programmers have been known to covertly change what these buttons do. Employees are not permitted to store or record passwords anywhere in their work area. Employees are also not permitted to share passwords. Employees are permitted to store passwords on their PCs in a password-protected Excel file. The password used to access the network is not to be recorded anywhere. The Company uses Google Drive for the storage of any work data. Any work files and folders should be placed in Google Drive, where it will be automatically backed up using the Google Drive cloud functionality. Files and folders should not be stored on the PC ‘desktop’, or anywhere else on the PC. Any problems with Google Drive should be reported to the Group IT Manager. Company PCs are not to be used for the storage of any personal data. This includes photographs, music and videos. Employees are not permitted to use their personal computer, tablets or smartphones on the Arbury Motor Group network, without the permission of the Group IT Manager. This includes connecting to the Arbury Wi-Fi broadcasts. Though, personal smartphones may connect to the Arbury Customer WiFi broadcasts during normal daily work breaks (e.g. lunchtimes).

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All Company-supplied technology, including computer systems and company-related work records, belong to the Company and not the employee. Insurance of equipment issued for use outside the Company’s premises is the responsibility of the Company, however, employees are responsible for the use, transportation and secure storage of this equipment and must exercise due care. This type of equipment is a high-risk theft target, especially when left in vehicles or unattended in premises, even for a short time. Employees should take all practical measures to ensure security. Employees will also be responsible for keeping the equipment in a clean and undamaged condition. The Company monitors usage patterns daily for its email and Internet communications. Although, with approval, employees are encouraged to explore the vast resources available on the internet during work breaks, they should use discretion in the sites that are accessed. Employees are required to close their browser as soon as they have finished using a website. Leaving your browser opened and minimised will influence your daily usage patterns in a negative manner. Since all the computer systems and software, as well as the email and Internet connection, are Company owned, all terms of use are in effect at all times. Each employee is responsible for reporting any suspected violations of this IT usage policy, as detailed above, to the Group IT Manager immediately. Example, if you are on the receiving end or know of an inappropriate email, it is your responsibility to report this email. Any employee who abuses the privilege of the Company’s facilitated access to email or the internet may be denied access and be subject to the Company’s disciplinary policy. Employees are not permitted to take any Company computer equipment home, without the permission of the Group IT Manager. This includes laptops, PCs and tablets.

14. SOCIAL MEDIA & PERSONAL INTERNET PRESENCE The use of online forums and social networking sites (e.g. Facebook, Twitter, YouTube etc.) has become a significant part of everyday life. It must be recognised that the Internet and social media are powerful mediums; however, sometimes their use can have a negative impact. If an employee’s personal internet presence does not make any reference to the Company and the Company cannot be identified, then the content is unlikely to be of concern. If employment by the Company is referred to or can be identified then the information posted would need to comply with the following conditions: •

Any posts where the Company is brought into disrepute may constitute misconduct or gross misconduct and disciplinary action will be applied.

Under no circumstances should an employee disclose confidential information through an internet posting relating to their employment at the Company.

Under no circumstances can Company logos, Franchise logos or any copyright material obtained from employment by the Company be used on any personal posts.

If you make any of the posts from your personal user name on any of the Company’s Social Media sites then you agree to be bound by the additional terms included in the Arbury Social Networking User Policy.

Posting should not be used to abuse other employees, customers or business partners (e.g. franchisors or suppliers). The feelings of others should be respected at all times and any incident that may be deemed to be online bullying or harassment will be dealt with in the same way as other such instances.

Employees should obtain permission from individuals before posting contact details or pictures. An individual’s privacy should be respected.

Care should be taken to avoid using language, usernames or nicknames that could be deemed as offensive to others.

If information is discovered on any site that raises a concern with regard to the Company or any of its employees or a conflict of interest then employees should bring it to the attention of their Line Manager.

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If approached by a media contact about content on a site relating to the Company, employees should advise their Line Manager before taking any action.

Any misuse of social networking or the internet by employees that has a negative impact on the Company, its employees, customers or business partners (e.g. franchisors or suppliers) may be regarded as a disciplinary offence and the Company will take seriously any occasions where the services are used inappropriately. In addition, viewing and updating personal social networking sites should not take place during normal work times.

15. DATA PROTECTION

The General Date Protection regulations 2018 (“GDPR”) defines UK law on the processing of personal data. It is the main piece of legislation that governs the protection of personal data in the UK. In line with GDPR, all employees have a responsibility for how personal data is collected, stored and handled appropriately. When processing personal data, employees must ensure the following standards are met: •

Only information that is necessarily required for the performance of a legitimate business purpose shall be collected.

Personal data is not shared informally or disclosed to unauthorised personnel within the Company or externally. If such data is required to be shared with external organisations there shall be a legitimate reason for doing so and a data sharing agreement shall be in place.

Personal and sensitive information relating to customers and employees including deal files and personnel files must not be left on display unsupervised. Hard copy documents should be kept in secure cabinets when not in use.

Personal sensitive and confidential data must be password-protected when it is stored or when it is being transferred electronically to third-party companies. The password is to be supplied by a separate email or other means.

Computer screens are locked when left unattended.

Strong passwords are used and not given out unless to authorised personnel.

Data to be regularly reviewed and updated if out of date. Consideration of whether data is no longer needed and if required disposed or and deleted properly.

The Company has a Data Protection Policy in place, which sets out the responsibilities and practices in place in relation to GDPR. Breach of this data handling legislation may result in disciplinary action being taken and possibly criminal prosecution.

16. DISCLOSURE OF INFORMATION During your employment you may be trusted with confidential information about the Company. It is a condition of employment that you do not disclose information to anyone inside or outside the Company, whether for gain or not, without the permission of the Company. This applies during and after your employment and with no limit of time but does not apply to information that is or comes into the public domain otherwise than through your unauthorised disclosure. Such information will include but shall not be limited to: •

The business methods and information of the Company including but without limitation: prices charged, discounts given to customers or obtained from suppliers, developments, marketing and advertising programmes, costings, budgets, turnover, sales targets and other financial information

Lists and or particulars of the Company’s suppliers and customers and the individual contacts at such suppliers and customers

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Details and terms of the Company’s agreements with suppliers and customers

Know-how employed by the Company or its suppliers

Confidential details of the structure of the Company, details of business developments prior, current or future.

This applies whether or not in the case of documents they are or were marked confidential These restrictions shall not apply so as to prevent you from using your own personal skills in any business in which you may lawfully be engaged after termination of your employment.

17. BRIBERY The Bribery Act 2010 is concerned with bribery. The word “Bribe” is very widely drawn in the Act and effectively covers any action involving the giving or receiving of a financial or other advantage which: •

Encourages the recipient to perform their functions or activities improperly, or

Rewards the recipient for having already done so.

Any act of hospitality, gift or inducement given or received is therefore covered. One person’s hospitality or gift could be seen as another person’s bribe. The Act does not, however, intend to prevent genuine hospitality, gifts or similar business expenditure that is reasonable, proportionate and for legitimate and ethical business practice. The Company’s policy on gifts (set out in paragraph 3.19 below) set out acceptable parameters in which to operate. Each employee is, however, required to take extra vigilance given this new legislation and ensure that: •

The Company’s policies are rigidly applied

They individually are comfortable that their own actions could not be misinterpreted.

Decisions as to what is acceptable may not always be easy. If in doubt, the matter should be referred to the Finance Director at Head Office. It is a condition of employment that employees will not offer, promise, give, request, agree to receive, or accept any bribes: •

In the course of their employment

When conducting Company business

When representing the Company in any capacity.

A bribe means a financial payment or other form of reward or advantage, whether direct or indirect, that is intended to induce or influence, or has the effect of inducing or influencing, an individual, company or public body to perform their functions, including business and public duties, improperly. For the avoidance of doubt, improper performance includes: •

Not acting in good faith

Not acting impartially

Not acting in accordance with a position of trust.

All employees must comply with the applicable bribery and corruption laws. As part of this duty, you must report any suspicious conduct that may amount to a bribe being offered, promised, given, requested or accepted (either involving you or another employee or person acting for, or on behalf of, the Company) immediately to the Finance Director at Head Office in accordance with the Company’s anti-bribery policy. If you are suspected of bribery, the Company is entitled to suspend your employment while carrying

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out its investigations. Further, the Company is entitled to terminate your employment for Gross Misconduct if it is found that you are guilty of an act of bribery.

18. GIFTS Employees who receive or are offered gifts from clients, public officials, suppliers or other business contacts should be referred to a Director of the Company. In this context, gifts include any form of hospitality offered (excluding working business lunches) – examples would be attendance at a sporting event or tickets to a concert. If, in the opinion of the Director, the gift or hospitality might constitute a bribe or other inducement, the employee will be asked to return the gift or decline the hospitality with a suitable letter explaining the Company’s policy and asking that it be respected in the future. In cases where the employee’s Director agrees that the gift or hospitality was offered to the employee as a token of gratitude for work carried out to a particularly high standard or for an exceptional level of service given, the employee may, at the Director’s discretion, be permitted to retain the gift or accept the hospitality. This policy does not apply to promotional gifts, that is items such as stationery or pens that bear the logo or company name of another organisation, provided that these have no significant value. Employees or associated persons providing gifts to suppliers, clients or other business contacts may be authorised provided that: •

The gifts are no more than £100 per annum to any one supplier/business contact

The gifts are authorised in accordance with the Company’s expense procedures or normal purchase invoice processing procedures.

19. PUBLIC INTEREST DISCLOSURE - WHISTLEBLOWING The Company has a duty to conduct its affairs in a responsible way with due care for our employees, and it is aware of its obligations in common with all other organisations and individuals to comply with the law. In the event that an employee becomes aware of any information that tends to show that the Company is failing to conduct its affairs in accordance with its obligations, they are encouraged to disclose that information internally in confidence to a Director of the Company. The employee should make their disclosure without fear of detriment as the Public Interest Disclosure Act 1998 affords protection to employees who make certain disclosures in the public interest.

20. CONFLICT OF INTEREST There is no intention to interfere with your personal interests or activities, but even the most conscientious need to guard against situations where their interests conflict with those of the Company. You are not permitted, therefore, to engage in any activity, or to receive any sort of benefit for acting in a manner that would conflict with the interests of the Company. For example, you are not to engage in the buying and selling or servicing of motor vehicles for private gain outside your employment. Nor are you permitted to advise companies on finance, vehicle management, to write software relating to vehicle management, or to advise outside bodies on location of new vehicles and vehicle disposals. To this end, the Company’s policy is that employees will not be permitted to undertake business activities or other work where the Company considers that this is incompatible with its interests and, in

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any event, unless employees have obtained the prior written authorisation from a Director. If you have any doubt, please discuss the matter with your Head of Business.

21. PERSONAL APPEARANCE AND WORKWEAR You will be issued with any protective clothing that is essential for your safety at work. Under the Health and Safety at Work Act, staff have an obligation to work safely, and to meet this safety requirement you are required to wear substantial and stout shoes. (Further guidance is given under the ‘Health and Safety’ Section). Increasingly, the image presented by customer-facing staff is critical. As with all service industries, the personal appearance of our staff needs to be at the highest standard. As such, when you are issued ties or neck scarves then you will be expected to wear them when you are representing the Company. In the absence of any formal uniform provided by the Company, we need to ensure a standard of dress that will be acceptable to the majority of our customers and that will be practical for staff to wear, therefore the following should be used as a guide: •

Standard of dress for all customer-facing staff must be deemed acceptable and appropriate by the local management. This means that the dress for all employees will be deemed appropriate for their job and will meet normal, conservative, levels of decency – e.g., revealing or see-through materials will not be acceptable.

Where no uniform is provided, a common standard e.g. white shirt/blouse, grey trousers/skirt will be required for all customer-facing staff.

Where standard of dress is not obviously a Company uniform, employees should be readily identifiable by name badges etc.

All workwear should be clean and in good repair.

Tattoos, generally, should be concealed for customer-facing staff, but can be dependent on ambient temperature. Again, the discretion of local management applies.

Strict religious or strict ethnic dress requirements can be accommodated provided they meet Health, Safety and Hygiene requirements and are compatible with the Company standards.

22. EXPENSE CLAIMS Any legitimate reasonable expenses incurred will be reimbursed, provided all details are entered correctly on the Company’s expense claim form, are accompanied by the appropriate receipts and are prior authorised by your General Manager.

23. FINANCIAL CONDUCT AUTHORITY The Company recommends, provides advice and sells a range of insurance products and services to our customers (e.g. Extended warranties etc). In doing so it is legally bound to comply with the requirements of the Financial Conduct Authority (FCA). Broadly, the FCA is all about ensuring sound auditable business practices to ensure that the “Customer is Treated Fairly” – see below. It is Company policy that only staff who are appropriately trained and expressly authorised can recommend, dispense advice or sell insurance products or service to our customers. All other staff are strictly forbidden from this activity.

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24. QUALITY, CUSTOMER SERVICE AND TREATING CUSTOMERS FAIRLY The nature of our business is that of a service provider in a very competitive industry, and our reputation is determined by the impression we create. The quality of our customer service is of the utmost importance to the Company. Therefore, all employees must be aware of the required quality standards, follow all quality assurance procedures and work at all times to meet or exceed the expected standards. To ensure that the fair treatment of customers is promoted within the Company, the Directors and Management will enforce the following principles throughout the business. We will: •

Ensure that consumers can be confident that they are dealing with a Company where the fair treatment of customers is central to our corporate culture

The products and services that we market and sell are designed to meet the needs of identified consumer groups and are targeted accordingly

That all our consumers are provided with clear information and kept appropriately informed before, during and after the point of sale

That where consumers receive advice, the advice is suitable and takes account of their circumstances

That all our consumers are provided with products that perform as we have led them to expect, and the associated service is of an acceptable standard and as they have been led to expect

That our consumers do not face unreasonable post-sale barriers to change products, switch provider, submit a claim or make a complaint.

All employees must abide by the Company’s complaints procedure. Any complaint received by an employee from a customer must be acted on promptly, whether this has been received orally or in writing. In many minor cases, these can be dealt with by the department staff. However, the Department Manager must be aware of a complaint on the day of receipt and in their absence the Operations Manager. If a complaint cannot be resolved on the day, then the Operations Manager must be made advised. If the Department Manager cannot reach a resolution with the complainant, then the complaint must be escalated to the Operations Manager and then a Director for final conclusion. In the case of a Regulated Insurance or Consumer Credit Complaint then this must be referred to the Operations Manager and FCA Compliance Manager on the day of receipt, whether the complaint is considered to be eligible or not. To ensure that we are treating the customer/complainant fairly, the person who provided the advice on the product must not be responsible for dealing with the complaint. The FCA Compliance Manager is responsible for ensuring all timescales and record-keeping requirements are met in accordance with the Company’s FCA Manual.

25. MODERN SLAVERY Modern slavery is a crime and a violation of 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. The Company has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our business or in any of our supply chains. 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 the Company or under our control. The Company has an

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Anti-slavery and Human Trafficking Policy, which sets out the responsibilities and practices in place. All employees are required to avoid any activity that might lead to, or suggest, a breach of our Anti-slavery and Human Trafficking Policy, which is available from your Line Manager. You must notify a Director as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future.

26. DISCOUNTS TO STAFF Subject to availability, you may obtain discounts on items purchased from the Company. Brief details are given below and further information may be obtained from a Director. You may purchase up to two (new or used) cars a year for use by you or the immediate members of your family. •

New Cars (subject to availability) – As per the terms and conditions of the manufacturer’s Dealer Employee Car Scheme or cost price to the Company plus £100. Your Sales manager will give you full details of ‘cost to the Company’ prices, which take account of the initial preparation and servicing costs.

Used Cars – Trade price including preparation costs plus £100.

Workshop Labour, Parts and Accessories – All vehicles in Company workshops, for any reason, require a job card authorised by the service manager. Parts, oils and consumables will be booked to the job card in the normal manner. Labour will be charged at £25/hour and parts at cost plus 50%. MOT tests a maximum of 3 in any 12-month period.

Prior approval must be gained from a Director before taking advantage of any of the above benefits.

27. ELECTRIC/HYBRID VEHICLE USER CHARGE: In the interest of fairness to all employees across the business, we are going to introduce a nominal charge to all those drivers who drive an electric/hybrid vehicle given the additional benefit of being able to charge your car at work, which will reflect the change in pricing we are now seeing. The charge will work in the following way: •

Those driving an electric vehicle will have a £50 charge monthly in arrears.

Those who are driving a hybrid vehicle will have a £25 charge monthly in arrears.

The Accountant and Dealer Principal at each site will be responsible for reconciling this information monthly and communicating this to each relevant individual.

We will not be removing EV/hybrid vehicles from the P11D banding we are using to calculate company car tax payable, so there will be no change in any tax codes to reflect this price change.

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V

Section 5 Health & Safety at Work

1. INTRODUCTION It is Company policy that Health & Safety is a primary management responsibility. To whatever extent any individual is responsible for any aspect of our business, he or she is equally responsible for the health and safety of themselves, their colleagues and any others who may be affected by their actions or their failure to follow safe systems of work. All employees must familiarise themselves with the Company Health and Safety Policy Statement.

Health and Safety Policy Our policy is to provide and maintain safe and healthy working conditions, equipment and systems of work for all our employees and to provide such information training and supervision as they need for this purpose. We also accept our responsibility for the health, safety and welfare of other people who may be affected by our activities.

Employer’s Responsibilities 1.

Provide and maintain safe premises, plant and equipment and methods of work.

2.

The organisation will comply with all statutory requirements and expect employees, visits and contractors to do the same.

3.

The organisation considers failure to comply with the Health & Safety at Work Act 1974, associated Regulations, Codes of Practice and Guidance Notes to be an important breach of the contract of employment and will act accordingly.

4.

Take measures to prevent fires and explosions and provide and maintain adequate fire prevention equipment and safe means of escape from the premises.

Employees Employees have a duty to cooperate in the operation of this policy and must: 1.

Conform to the Company Health & Safety Policy and follow guidelines issued

2.

Not misuse equipment or plant in such a way as to endanger themselves or others

3.

Report to the employer immediately if they detect anything that could compromise Health & Safety

4.

Work safely and efficiently at all times

5.

Use the protective equipment provided

6.

Report incidents that have or may lead to injury or damage.

This Policy will be kept up-to-date to take account of changes within the business and any relevant legislation. Failure to comply with the requirements of the Health and Safety Policy, prescribed safe systems of work or any health and safety instruction, will be considered serious and shall be subject to normal disciplinary proceedings.

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All employees have a legal obligation to bring to the attention of management any health or safety issue that they believe may cause or contribute to injury or ill health. All employees must read this booklet carefully and must bring to the attention of their Line Manager any queries that may arise. Management will do all that is reasonably practicable to provide a safe and healthy working environment, and will in accordance with its duties under the Health and Safety at Work Act 1974 (HASAWA) provide: •

Plant and systems of work, which are safe

Arrangements to ensure the safe handling, storage and transportation of articles and substances

Information, instruction, training and supervision necessary to ensure health and safety

A well-maintained workplace with safe access and egress

A working environment free of noxious substances supported by adequate welfare facilities.

Management will endeavour, where practicable, to be proactive in its approach to health and safety, consulting the workforce in accordance with its “working together” strategy. As part of this policy and in accordance with statutory duties, emphasis will be placed upon risk assessment, particularly in respect of: •

The Health & Safety at Work Act 1974 (“HASAWA”)

The Management of Health and Safety at Work Regulations

The Manual Handling Regulations

The Display Screen Equipment Regulations

The Personal Protective Equipment Regulations

The Provision and Use of Work Equipment Regulations

The Control of Substances Hazardous to Health Regulations.

It is accepted that risk assessment is a management responsibility; such a strategy can, however, only be successful if all members of staff cooperate fully at every stage. Management will expect all employees to comply with their statutory duties, namely: HASAWA S.7 All employees are to take reasonable care for their own health and safety and anyone else (including members of the public) who may be affected by their acts or omissions. HASAWA S.8 Not to intentionally or recklessly interfere with or misuse anything, which is provided in respect of health and safety. HASAWA SS. 36.37 Every individual, cooperate officer and manager must cooperate with their employer to enable them to perform and comply with any statutory duty placed upon them. All Personal Protective Equipment (PPE) issued for use in identified operations must be used on every occasion that the process is undertaken. Defects in PPE must be reported as soon as they occur. Any employee finding a shortfall in health and safety arrangements likely to lead to a hazardous situation must report it immediately. Failure to comply with any of the above duties can render employees to disciplinary and/or prosecution action.

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2. ORGANISATION The Company wishes to involve every employee in the establishment and practice of safe systems of work. Any individual who wishes to progress any health and safety issue should do so via their Line Manager.

3. ABRASIVE WHEELS Abrasive wheels are potentially dangerous due to their high speed of rotation and the resultant possibility of break-up under centrifugal stress. Due to its low cost but high risk, the standard practice is to replace the whole abrasive wheel unit rather than to try and replace the worn abrasive wheel. Indeed, no one may mount (change) any abrasive wheel unless they have been formally trained and are in possession of a valid certificate. When using an abrasive wheel: Do not wear any loose clothing when operating Do not use any machine you are unfamiliar with Do not grind any material that clogs the wheel Do not grind on the side of straight wheels Do not wear gloves – they may get caught up Do not exert undue pressure when grinding Do wear goggles or visor when grinding Do wear hearing protection Do ensure all guards are fitted Do adjust tool rest as close as possible to the face of the wheel Do dress (clean and square) the cutting face regularly with the tool provided.

4. ACCESS AND EGRESS Many accidents are caused through trips, slips and falls due to work areas and traffic routes being obstructed. It is essential that ways in and around the workplace be kept clear at all times. This is particularly important in respect of fire escape routes. Do not block fire doors or escape routes Do not haphazardly discard tools or equipment Do not leave air or lubricating lines lying around Do not leave drawers, cupboards and filing cabinets open Do maintain a tidy workspace Do dispose of waste into proper receptacles Do clean spillages promptly Do warn others of temporary hazards such as wet floors Do route trailing leads sensibly or protect with cable covers.

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5. ACCIDENT REPORTING All accidents, no matter how minor, must be reported as soon as possible following their occurrence. All workplaces are equipped with first-aid equipment, an accident book and trained first aid assistants. It is particularly important that any accident that requires treatment by a doctor or hospital be thoroughly investigated and the circumstances are accurately recorded. Anyone suffering from ill health symptoms, that do they believe may be work-related, should report the circumstances to their Line Manager. Do not work with open wounds Do not assume that minor injuries will be all right Do report all accidents, including those that do not result in injury Do fill in the accident book Do cover all open wounds, scratches etc. when treating others who are bleeding to avoid crossinfection Do report any accident that is serious or prevents you from carrying out your normal work for 7 days or more – this must be reported to the HSE under RIDDOR.

6. AIRBAGS Airbags contain a small amount of explosive and other materials that may cause respiratory problems if inhaled. Airbags are only likely to cause a problem if they are accidentally punctured or ignited following deployment. Technicians must not work with airbags unless they have first read and understood the manufacturer’s safety data sheet, available from their Line Manager. Do not puncture inflated airbags Do not smoke whilst working on airbags Do not weld near inflated airbags Do not put vehicles withairbags into drying ovens Do read the safety data sheet Do wear eye protection Do store inflated airbags in marked metal containers.

7. ASBESTOS AND DUST Asbestos may be found in the fabric of buildings, such as in roof sheets, wallboards, pipework and lagging. Vehicle parts in older vehicles such as brake shoes and pads or clutch linings may also contain asbestos material. Inhalation of asbestos fibres or dust can cause serious respiratory diseases. Ensure any person or contractor is provided with a copy of the Asbestos Survey Report before starting any work that may disturb asbestos containing materials. Do not cut, drill or grind any asbestos product Do not use airlines to blow clean hubs or clutch housings as they can remove this section Do report any suspicious building materials that are not marked

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Do wear a respirator when working with asbestos products Do damp down hubs and housings using a proprietary spray can product Do return asbestos products in original packaging, clearly marked Do wrap all contaminated rags and materials in sealed polythene, before disposal in accordance with environmental standards by specialist contractors.

8. CONTRACTORS Contractors are any company or any individual who is engaged by or on behalf of the Company to carry out works or services on our property. Employees must not engage in any hazardous activity, which may endanger contractors, unless they first bring the nature of the hazard to the contractor’s notice e.g. fuel drainage, paint spraying, running vehicles without extraction equipment. Furthermore, employees are not to enter any area allocated to contractors without the prior permission of their Line Manager. Do not expose contractors to any of the hazards of our trade Do not assist contractors in their work Do not allow contractors to use any Company equipment Do obey any notices or instructions that are posted Do report any dangerous activity you observe.

9. CONTROL OF SUBSTANCES HAZARDOUS TO HEALTH COSHH is concerned with the exposure by inhalation – physical contact or ingestion of any substance, which may cause harm to any individual whom, may be exposed. A wide range of harmful substances exists in the workplace, ranging from photocopier toner to acids, oils and paint fumes. COSHH is not just concerned with the user, but with anyone else who may come into contact, perhaps via storage, spillage or disposal. Known hazardous substances will be clearly marked with a symbol and should only be used in accordance with printed instructions. Unmarked substances and containers should be treated as suspect until information is made available. Do not use any hazardous substance unless you have read and understood the safety data sheet Do not dispose of any hazardous substance into skips or bins not provided for hazardous waste disposal or drains Do not decant hazardous substances into unmarked containers Do read the label Do read manufacturer’s safety data sheets Do follow precautions precisely Do dispose of hazardous substances safely.

10. DETONATORS Detonation devices are typically found in seatbelt mechanisms to assist with automatic activation. Care should be exercised when handling or storing such devices. Do not use sources of heat near detonators Do store detonators in clearly marked metal containers

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Do wear eye protection when handling detonators.

11. DISPLAY SCREEN EQUIPMENT (DSES) Intensive users of DSE equipment may be entitled to free eyesight testing and assistance with the provision of corrective spectacles. Users will be subject to a written risk assessment to identify any potential hazards created by their work activity, workstation or working environment. Line Managers will arrange awareness training. Do not work for prolonged periods at a keyboard or screen without regular breaks in activity Do not work in unduly cramped or restricted conditions Do report any signs or symptoms of ill health, such as stress, eyestrain or pain in the upper limbs Do arrange your workstation to best suit your needs based on correct settings as covered by DSE training.

12. ELECTRICITY Electricity is a common cause of fire and injury in every type of workplace. It is particularly dangerous because it cannot be seen or detected by the normal senses. Where possible, the use of mains voltage equipment (240 volt) should be avoided and substituted by reduced voltage equipment (110/25 volts) or battery-operated tools. All portable electrical equipment should be visually checked before use, paying special attention to the plug, leads and casing. Any defects must be reported immediately. Only qualified electricians are allowed to repair faulty electrical equipment. The use of “block” type adapters should be discouraged. Where extension leads are required, they should be of the flat multi-outlet type, correctly fused. All Workshop mains appliances should be protected by circuit breakers and RCDs, especially where wet conditions apply, e.g. power washers, vacuum cleaners etc. Do not use 240-volt equipment if an alternative is available Do not use any faulty or damaged electrical equipment Do report any faults immediately and withdraw equipment from use Do ensure that workshop and valet bay power supplies are circuit breaker protected.

13. ENVIRONMENTAL It is an offence to knowingly cause or permit the discharge of any substance, which may pollute the air, land or water. In practice, this will mean strict control of all waste such as oil, filters, paints, acids etc. Other activities must also be carefully controlled e.g. paint spraying may only be conducted inside spray booths. Vehicle washdown may only be conducted where the wastewater is discharged into the foul sewer with local authority consent. Under no circumstances is waste oil or coolant from vehicles to be discharged into normal drains. All spillages are to be contained and soaked up using absorbent material. The contaminated absorbent is to be treated as ‘controlled waste’. Do not store scrap batteries outside or near drains Do not spray any paint outside of spray booths Do not pour any detergents, oils, antifreeze or acids into any drain or watercourse Do identify controlled waste containers and systems

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Do know where spillage control material is located.

14. FIRE Fire is a major cause of loss of life and destruction. The main causes of fire at work are carelessly discarded smoking materials, electrical faults and arson. Fire prevention relies upon good housekeeping, control of sources of ignition e.g. naked flame, welding etc. and the maintenance and efficient use of firefighting equipment. Line Managers will arrange training in fire awareness and the practical use of extinguishers. Do not smoke, weld or grind near any flammable materials Do not interfere with firefighting equipment Do not use extinguishers containing water on electrical fires Do observe good housekeeping practices Do ensure all smoking materials are correctly extinguished Do find out what the fire alarm sounds like Do keep fire escape routes clear Do find out how to use firefighting equipment know which type is most suitable for different types of fire.

15. FIRST AID All dealerships will provide readily accessible first aid equipment on open display. Signs will be displayed showing the names and locations of trained first aiders and appointed persons. All employees are encouraged to volunteer to act as first aiders; training will be provided during normal working hours. Any employees suffering from injury or ill health at work should seek the assistance of a trained first aider. Do not remove or interfere with any first-aid equipment Do seek treatment for all injuries Do find out the location of your department’s first-aid cover and equipment.

16. HAND TOOLS Hand tools must be maintained in good condition and only be used for the purpose for which they were designed. Do not use poor-grade hand tools, which may break, bend or chip. Always use a ring spanner where circumstances permit and avoid the use of adjustable spanners. Be especially careful of the condition of chisel heads and hammer faces and discard, any which may result in flying splinters. Do not use low-grade hand tools Do not use defective hand tools Do use the right tool for the job Do protect your eyes from flying particles.

17. HEALTH AND HYGIENE

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Many illnesses and diseases are caused through cross-infection. It is essential to have good hygiene practice whilst at work. Full use should be made of barrier creams, both before and after work. Hands should be thoroughly washed before eating and before and after visiting the toilet. Food and drink should not be consumed in any work area where it may be contaminated by harmful substances. Overalls and workwear should be regularly laundered and changed if contaminated by harmful substances Do not expose your skin to harmful substances Do not eat or drink where there is danger of contamination Do use barrier cream or gloves (nitrile) but not both Do wash hands before eating and drinking Do change overalls and workwear regularly.

18. HEALTH SURVEILLANCE All employees involved in potentially hazardous activities will be subject to regular health surveillance under Group arrangements. Typically, this will include: Some DSE users – Eyesight testing Workshop technicians – Dermatitis checks, ARC technicians – Dermatitis checks, lung function testing, audiometry, urinary, blood and HAVS Any employee who believes they are suffering from any work-related ill health effect should report it to their Line Manager. Management will then seek advice from the Group Medical Advisers. Employees can obtain advice on any employment health issue from the Employment Medical Advisory Service (EMAS). Contact details are published on notice “Health and Safety at Work. The Law, What You Should Know”. Do not expose yourself or others to any hazardous substances Do follow safe systems of work described on risk assessments Do use PPE where prescribed Do report any ill health symptoms immediately they occur.

19. HIGHLY FLAMMABLE LIQUIDS (HFLS) HFLs are any liquids, which give off a flammable vapour at less than 32 degrees centigrade. HFLs are particularly dangerous as many of the vapours are heavier than air and gather in pockets. There are strict legal limits on the quantity of HFLs, which may be kept in any workroom. Up to 50 litres may be stored in closed containers inside a marked fireproof cupboard or room. HFLs should be strictly segregated from heat and sources of ignition. Do not smoke, use naked flame, weld or grind near HFLs Do not store HFLs in open containers, always replace the lid or cap firmly Do return HFLs to store when not in use Do use a proprietary fuel retriever to drain fuel tanks Do clean up spillages as they occur and dispose of contaminated materials safely Do store LPG containers safely outside in an upright position. Cylinders should be chained to walls.

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Employees must not indulge in horseplay or practical jokes whilst at work. ‘Initiation ceremonies’ have no place in the work environment and indulgence in such practices will be treated as a serious breach of discipline.

21. LOCAL EXHAUST VENTILATION (LEV) LEV is any powered system that is designed to remove harmful dust, vapour or fume away from the breathing zones of any operator e.g. welding, sanding, spraying, vehicle exhausts. Inhalation of these harmful substances can cause a range of respiratory diseases, some of which may/can cause permanent damage. All employees are to use LEV where it is provided. LEV is not to be relied upon as fool-proof protection. Do not run vehicles unless an extraction hose is attached Do not weld, power sand, spray or mix paints or solvents without LEV Do not rely solely on LEV for protection, use a respirator as well Do not leave lids off paint cans or solvent containers when not in use Do check LEV systems for suction rate Do use air-extracted tools Do report any defects immediately.

22. MANUAL HANDLING Manual handling is any activity that may involve lifting, lowering, pushing or pulling. When activities involve stretching, twisting or repetitive movement the likelihood of musculo-skeletal injury increases. Weight is only one factor, although the heavier an object, the greater likelihood of injury. No employee is to handle any load that they believe is beyond their own personal capability. Employees are to make full use of mechanical handling equipment such as trolleys, barrows, jacks, axle stands etc. Where possible, loads should be broken down and made more manageable. If in any doubt, seek assistance. Personnel with a history of any injury, which may be adversely affected by manual handling, should take greater care and may wish to make management aware of their condition to allow special arrangements to be made. Manual handling training will be arranged by Line Managers. A careful assessment of each load should be made before handling, giving consideration to size, shape, packaging, contents etc. Do not handle any load that is beyond your own capability Do not bend your back when lifting or lowering Do not ascend/descend steps or ladders with both hands full Do use mechanical handling equipment Do break loads down Do seek help Do assess loads for hazards.

23. NOISE

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Ear damage caused by exposure to noise at work is permanent and incurable. Hearing loss is usually gradual due to prolonged exposure to noise, although hearing damage can also be caused immediately by sudden, extremely loud noises. Exposure to noise can also cause tinnitus, which is a sensation of noise in the ears, such as ringing or buzzing. Tinnitus may occur in combination with hearing loss. The Control of Noise at Work Regulations 2005 imposes limits on noise exposure. The Company has taken the following actions to reduce the risks from noise exposure to the lowest practical level: •

Identified the noise hazards in the workplace and has sought to eliminate/reduce noise levels from as many fixed sources as is practically possible.

Due to the varying work types the noise level does vary from day to day. It has been found that the general level of noise in most areas is within acceptable limits. However, there can be short periods of time when high noise levels are experienced, for example when air tools are being used, engines revved etc.

Based on the noise levels recorded, the workplaces with higher levels of noise have been designated into one of two categories:

Those workplaces that have noise levels in excess of 80dB(A) have been designated as “Hearing Protection Advisory Areas” and display signage indicating this designation. In these areas noise levels are such that hearing protection is not mandatory but is recommended. Hearing protection devices are provided for use.

Those workplaces that have noise levels in excess of 85dB(A) have been designated as “Hearing Protection Mandatory Areas” and display signage indicating this designation. In these areas noise levels are such that hearing protection is required to be worn at all times.

In addition to the general noise levels experienced in work areas, certain isolated work tasks and/ or work equipment may produce short term local peaks of noise. For example, the use of a handheld air tool or a revving engine. Therefore, when using a tool or undertaking a work task that is anticipated as generating high levels of noise (however short), hearing protection should be worn whilst this work activity is being conducted.

In addition, the noise producer should advise the other persons in the locality that they are about to produce high levels of noise and provide them with the opportunity to wear their own hearing protection equipment.

The Company has signed the areas where hearing protection is advised or is mandatory. In addition, fixed plant and tools that produce excessive noise levels have also been marked with either the noise level or a mandatory hearing protection sign.

In this document, the Company has informed employees of the health risks from excessive noise, and through one-to-one training will demonstrate the use of hearing protection equipment.

Each employee exposed to high levels of noise will be issued with appropriate hearing protection equipment and provided training in its use. The wearing of such equipment in high-risk areas/work activities is a mandatory requirement.

In addition, those persons who may be potentially exposed to noise are required to participate in the health surveillance programme.

In practice, the noisier work areas and work processes are located in bodyshops, workshops and other production areas that use mechanical equipment. Work areas, power tools or other work equipment that have high levels of noise will display noise warning notices or mandatory hearing protection signs. All employees must take care to follow guidance given by management to control exposure to noise and must use hearing protection equipment provided as directed.

24. OCCUPATIONAL DRIVING

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Only persons holding a valid UK driving licence may drive vehicles on behalf of the business either on public roads or around the site. The Company expects all persons involved in driving or managing those involved in driving vehicles on behalf of the business to do so within the law and to act safely and responsibly at all times. The Highway Code requires all drivers to be familiar with laws and rules of the road and safe driving. Drivers should also be aware that the main causes of road crashes are due to bad driving and that poor driving, poor health, fatigue and distractions dramatically increase the risk of having an accident. Drivers must also be aware that road traffic accidents tend to result in far more serious injury to themselves and others than would normally be expected in other workplace accidents in our industry. Due to the diverse nature of the driving activities performed by the business, the driver must be aware of their responsibility for ensuring that all control procedures specified are followed, and operate in the knowledge that as a driver/ passenger they have an absolute delegated authority to decline to drive a vehicle or to be driven by a customer or otherwise undertake a driving task that they feel is unreasonable, they are not qualified to perform or otherwise would compromise their safety or that of other road users. All drivers must actively participate in any driver assessments and driving safety training given and they should familiarise themselves with the Company’s risk assessments and safe systems of working. Drivers should bring their manager’s attention to any driving activity, lack of training, vehicle, delivery schedule or work request given that they feel may be unreasonable or otherwise may unduly compromise their safety. Any defects found on a vehicle must be reported immediately.

25. OFFICE SAFETY Although most office-based activities offer a relatively safe environment, accidents still happen. Most office accidents are related to slips, trips and falls, manual handling or electrical contact. Prompt reporting of faulty equipment and the maintenance of a tidy work area will go a long way in the prevention of office accidents. Do not use faulty electric appliances, overload sockets or use block type adapters Do not allow telephone or computer leads to trail dangerously over walkways Do not obstruct corridors or fire escape routes Do not leave desk drawers open or leave keys in locks Do not put too much weight in upper drawers of filing cabinets or open more than one drawer at once Do not handle any load that is beyond your own capability Do report faulty equipment immediately Do switch off any electrical equipment, including the photocopier before attempting to clear paper jams etc. Do find out how to deal with electric shock Do clean up spillages quickly Do replace or repair torn floor coverings, especially on stair treads Do supervise visitors and contractors and acquaint them with emergency procedures Do find out the location of first aid equipment and assistants Do bend your knees and keep a straight back when lifting or lowering loads.

26. PERSONAL PROTECTIVE EQUIPMENT (PPE)

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It is an offence to knowingly cause or permit the discharge of any substance, which may pollute the air, land or water. In practice, this will mean strict control of all waste such as oil, filters, paints, acids etc. Other activities must also be carefully controlled e.g. paint spraying may only be conducted inside spray booths. Vehicle washdown may only be conducted where the wastewater is discharged into the foul sewer with local authority consent. Under no circumstances is waste oil or coolant from vehicles to be discharged into normal drains. All spillages are to be contained and soaked up using absorbent material. The contaminated absorbent is to be treated as ‘controlled waste’. Do not store scrap batteries outside or near drains Do not spray any paint outside of spray booths Do not pour any detergents, oils, antifreeze or acids into any drain or watercourse Do identify controlled waste containers and systems Do know where spillage control material is located.

27. FUEL DRAINING AND FUEL TANKS There is a particularly high level of danger associated with the recovery of fuel from fuel systems and repairs to fuel tanks and lines. Fuel retrieval is only to be carried out in a well-ventilated area (outside if possible), using a proprietary fuel retriever, which recovers both the petrol and vapour from the system. There should be a dedicated bay with barriers and warning signs should be clearly displayed to alert personnel of the danger of fire or explosion. Suitable fire extinguishers and spillage control material must be readily available. Fuel lines should be clamped or plugged when disconnected to prevent leakage. Welding should not be carried out on fuel tanks unless they have been flushed out and vented. Repairs to fuel tanks will be subject to strict managerial control. Do not drain petrol into open containers Do not allow any sources of ignition in the area Do not use or recharge mobile phones in the workshop area at any time Do not weld near fuel tanks or lines Do use a fuel retriever Do have a suitable extinguisher at hand (dry powder or foam) Do ensure good ventilation Do dispose of contaminated spillage material safely.

28. PLANT & EQUIPMENT Much of the plant and equipment in use in the workplace is subject to regular preventative maintenance and statutory insurance inspection. Users of equipment are obliged to visually inspect all equipment before use and report any defects as they occur. Employees are not to use or operate any equipment that they are unfamiliar with. All vehicle lifts, axle stands and other load-bearing equipment must be clearly marked with their safe working load (SWL). Do not operate equipment that you have not been trained to use Do not remove or interfere with any safety devices, guards, pins or chocks Do not clean or service any moving equipment

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Do operate equipment in accordance with manufacturer’s instructions Do report defects as they occur.

29. RISK ASSESSMENT All activities, which may present significant risks, are subject to written risk assessment. Risk assessments will be carried out by line management and nominated safety representatives. Risk assessments will identify and quantify risks and describe the control measures that will form the safe system of work. Once issued, the described safe system of work is to be employed each time that particular task is carried out. Copies of risk assessments are available from Line Managers and will form part of induction training. Do not carry out activities that may result in significant harm unless you have read and understood the written risk assessment and you are competent to undertake the task Do always follow the described safe system of work Do bring to the attention of management any activity, which you believe to be hazardous or inadequately controlled by the current work methods.

30. VALETING Valeting will typically include the external and internal cleaning and preparation of vehicles. Hazards will include the use of main voltage, high-pressure washers, vacuum cleaners and various chemical preparations. Mains voltage equipment must be protected by a circuit breaker or RCD. Eye protection must always be worn when pressure washing or using chemicals. Read the warnings and instructions on chemical preparations and follow the manufacturer’s instructions carefully. Do not allow wet waste into drains or watercourses Do not use unprotected electrical supplies Do not use chemical sprays, polishes or cleaners unless you have read and understood the safety data sheet Do wear eye protection and waterproof outer clothing when pressure washing Do open doors and sunroofs when using chemicals (particularly sprays), inside vehicles. Additional PPE (respirators) may be required when applying interior Supaguard or other similar stain resistant chemicals.

31. VEHICLE MOVEMENT Great care must be exercised when moving vehicles around the workplace. Vehicle movement must always be conducted in a responsible manner at a safe speed. Where vision is restricted, assistance should be provided to give guidance, particularly when driving over open vehicle pits. Use of the horn at entrances and exits should be exercised and access to transporter loading and offloading areas should be restricted. Do not drive any vehicle unless you hold a current driving licence for that class of vehicle Do not leave keys in unattended vehicles or on desktops or unlocked drawers Do drive slowly and cautiously

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Do get assistance when reversing, especially over pits or on and off lifts Do control transporter loading and offloading and post warning cones or signs Do check customer driving licences through the DVLA website before allowing test-drives and explain the use of all controls.

32. HAND-ARM VIBRATION Hand-arm vibration is vibration transmitted into your body, for example, when you use powered handheld work equipment. Too much exposure vibration can cause injuries to your nerves, blood vessels muscles and joints of the hand, wrist and arm, resulting in conditions such as vibration white finger and carpel tunnel syndrome. Persons who are regularly exposed to high levels of vibration (or relatively low levels of vibration for long periods of time) may develop adverse health effects. Employees who use powered hand tools for significant periods of their working day should be aware of this issue, the actions that can be taken to avoid such injury and the medical symptoms to look for. For most employees the times that hand-held tools are operated are well within the safe limits. However, the Company will provide you with guidance on safe trigger times and you should consider these when using tools for extended periods. Your employer will have in place controls to assess vibration risk and minimise any risks identified to an acceptable level. You, as the user, should be familiar with all local control procedures, participate in any health surveillance exercises being carried out and also operate your own controls. •

Think about the job – can it be done without the need for hand-held power tools?

Always use the right tool for the job (this will enable you to do the job more quickly and with reduced vibration).

Use low-vibration tools.

Make sure all cutting blades are sharp so they remain efficient.

Check tools before using them to make sure they have been properly maintained and do not demonstrate excessive vibration (due to wear or faults).

Take defective tools out of service and send for immediate repair.

Do not exceed the recommended air pressure for the tool, regularly oil tools.

Reduce the amount of time you use a tool in one go, try and fit in other jobs between uses or split long jobs over shifts (e.g. start it at the end of one day and finish the next).

Familiarise yourself with the symptoms of HAVS. Report any symptoms that you detect.

Avoid gripping or forcing a tool or work piece more than you have to.

Store tools so handle do not get very cold before next use.

Participate in the Company’s health surveillance programme. It is designed to maintain your health.

Encourage circulation by: •

Keeping warm and dry

Giving up or cutting down on smoking

Massaging or exercising your fingers during work tasks.

33. WELDING

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The main hazards associated with welding are fire, explosion, electric shock and burns. Only trained welders may operate welding equipment. A dry powder or CO2 fire extinguisher must be located nearby Gas welding sets must be fitted with blow-back arrestors, and operators should check that they are within their certified period of use as well as the condition of hoses and fittings before use. Electric welding sets should be checked for the condition of leads and clamps. Welders should be familiar with the first aid treatment of burns and resuscitation techniques. Do not weld near flammable or explosive materials Do not trail electric leads through water or under sharp metal edges Do not repair hoses with ‘jubilee clips’ Do ensure adequate ventilation and use fume extraction equipment when welding in confined spaces Do find out how to treat burns and how to resuscitate Do check that a serviceable fire extinguisher is fitted to the welding set Do segregate gas bottles by type and store upright and chained to wall to avoid damage to control valves.

34. WORKING AT HEIGHT Working at height should be avoided wherever possible, as falls from height account for more cases of serious injury and death than almost any other cause at work. Working at any height where a fall could result in significant injury, or a falling object could injure someone below, is subject to written risk assessment and managerial control. Typical activities will include gaining access to high storage, changing bulbs and lamps, hanging flags or flyers inside and outside showrooms and all roof work. Consideration should be given to the use of contractors for activities involving working at height. Only employees who are trained and authorised can use proprietary access equipment such as industrial ladders and steps or FLTs fitted with a purpose designed lifting platform to gain access to high places. Employees are not to work from ladders and are to have both hands free when ascending or descending. Ropes should be used to raise and lower equipment. Ladders should either be tied to structures for stability or be supported by another person. Fixed barriers should protect personnel working on areas where a fall could result or wear a safety harness securely fastened to a firm anchorage. The open sides of any high work area (including storage floors) should be protected with fixed-edge toe boards of at least 150mm (6 inches) in height. Where personnel below may be at risk, the area must be designated and signed as a “Danger Area” and access should be restricted, careful consideration should be given to the wearing of safety helmets. Particular consideration should be given to the weather when personnel are working at height outside e.g. wind and rain. Do not carry equipment when climbing ladders Do not site access equipment on unstable or sloping ground Do not work near unprotected edges Do carry out a risk assessment before working at height Do get assistance (never work alone) Do carefully inspect all ladders and access equipment for defect or damage before and after use Do site access equipment on firm level ground

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Do read manufacturer’s instructions carefully Do erect ladders at an angle of 75 degrees (1 foot out for every 4 feet up) Do tie ladders to structure or have a colleague support them Do report any fear of heights to your Line Manager.

Every member of staff must read and note the contents of this handbook and, after resolving any queries, will be asked to sign that its contents have been understood.

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