Pepper company handbook update july 2015 by Jude Whitford

Company Handbook

Version 5 - March 2015 a

Our Vision/Commitments 1) Utilising and strengthening employeeâ&#x20AC;&#x2122;s capabilities to solve problems and contribute to business success through Investing in People for which we have accreditation. 2) Instilling a positive dedication to quality throughout the company to service the needs of the changing market place. 3) Improving the profitability of operation by establishing better client relationships, adding value to that relationship and developing a stronger position in the market. 4) Developing the management competencies required to meet the opportunities arising from the changing economic environment. 5) Taking advantage of technological developmentâ&#x20AC;&#x2122;s to improve the efficiency of our operations and our ability to respond to existing and potential customer needs.

Company Handbook

contents Induction checklist to detach and complete 3

Health And Safety Rules

COMPANY INFORMATION

Evacuation And Fire Policy And Procedure

Welcome From The Company Directors

Mission Statement

Company Structure

Three Decades Of Pepper

Environmental Policy

Quality Policy Statement

What Is Iso And Why Are We Audited?

Housekeeping 52 Lifting 53 Chemical Handling

CCTV 59

HR POLICIES APPENDIX

Alcohol & Drugs Policy

Equality and Diversity Policy

Business Goals

Anti-Harassment Policy

What Is FSC?

Anti-Bribery Policy

Data Protection Policy

Dignity at Work Policy

73 75

Corporate Social Responsibility

JOINING THE COMPANY

Disciplinary Policy

Your Employment

Computer And Email Use

Electronic Communications and Social Media Policy

Mobile Phone Use And Driving

Ethics Policy

Family Related Events Policy

Flexible Working Policy

Grievance Policy

Maternity Leave and Pay Policy

Performance Review Policy

100

Recruitment and Selection Policy

103

Redundancy Policy

105

Sickness Absence Policy

107

Stress At Work Policy

109

Whistle-blowing Policy

112

Working Time Policy

114

EMPLOYEEâ&#x20AC;&#x2122;S PERSONAL PROTECTIVE EQUIPMENT ISSUE RECORD SHEET

117 119 121

Smoking 27 Expenses 27 Holiday Entitlement

Medical Appointments

Sickness Procedure

Attendance Award Programme

Public Duties

Time Off For Family Emergency

Parental Leave

Maternity Leave

Capability Procedure

Disciplinary Procedure

Grievance Procedure

Termination Of Employment

EMPLOYEE UNIFORM ISSUE RECORD SHEET

Health And Safety At Work Policy

EMPLOYEE ACKNOWLEDGEMENT SLIP

Executive statement We are coming to the end of an investment programme which has positioned us at the cutting edge of technology. This financial year is one of consolidation and continuous improvement. The marketplace continues to be competitive but we see our move into complementary markets and our move to becoming a total solution provider and marketing support services is giving us the competitive edge. We need to be nimble and lean as a company and move quickly to the internal and external environment in which we operate. Our Business needs to focus on what our clients want now and in the future and it is our intention to build new revenues from online with a variety of strategies. Our overarching aim is growth and all efforts must be on achieving scale and increases in revenues.

Company Handbook

INDUCTION CHECKLIST Employeeâ&#x20AC;&#x2122;s Name Job Title

Start Date

Department

Person giving induction training The induction is to help a new employee settle down into the job as soon as possible. Induction should commence on the first day of employment and be completed as soon as practicable. All parts of the induction should be completed on the same day. GENERAL INFORMATION Explanation of induction

TICK

HEALTH AND SAFETY Fire procedures and drill

Job description and departmental info

First aid accident procedures

Company handbook

Personal protective equipment

PERSONNEL DETAILS

No smoking site

Employee records probation period

ISO 9001 & 14001

Principal statement returned

GENERAL

Hours of work, rest breaks

Training and education

Overtime/flexible working arrangements

Canteen/refreshment facilities

Timekeeping/clocking procedures

Transport and parking arrangements

Absence reporting

Risk assessments

Wages/payslip

Skills matrix

P45/NI and bank details

Appraisal

Bonuses, commission, allowances Pension scheme/medical insurance/ life cover

TICK

TOUR OF FACTORY

Holiday entitlement/requests Trade union Certificates for relevant qualifications

Cloakroom, lockers, exits, entrance, working areas, offices. Emergency exits, fire alarm points, extinguishers First aid room, canteen, notice boards

KEY PERSONNEL / CONTACT NAMES

Managing Director Jude Whitford Line Manager First Aiders Alan Mayall / Sandra Anderson / Dan Kittle Human Resources Jake Whitford Health and Safety Rep Jake Whitford / Tom Rayer (BPIF) Pay Roll Kerry Kyle

I have received the above induction training today from Jake Whitford

Employeeâ&#x20AC;&#x2122;s signature

Company Handbook

WELCOME MESSAGE FROM COMPANY DIRECTORS May we take this opportunity to welcome you to the company. We hope that your career with us will be both enjoyable and rewarding. It is our policy to communicate regularly with you on matters that are important to us all, such as product quality, production levels and information about your job and your terms and conditions of employment. This booklet describes our general working conditions and the rules of the company. If you need further information or help in any way, do not hesitate to ask your line manager.

Steve Whitf ord Chairman

Jake Whitf ord Director

“

Jude Whitford Managing Director

Seth Whitford Director

Saul Whitfor d Director

OUR MISSION STATEMENT To help our customers to communicate in print, adding value to their message through data processing & personalisation, delivered in an ethical and environmentally responsible way, backed up with ‘beyond expectation’ client service & support.

”

Web + Marketing Manager

Director of Online

Laser Operator

Data Specialists / Programmers

Data Processing Manager

Factory Manager Handbay Supervisor

Press Bindery Mailing Handbay Minders Operatives Operatives Operatives

Press Room Manager

Production Scheduler

Goods in/ Despatch

Production Director

Managing Director

Designers

Studio Manager

Pre-Press Operators

Pre-Press Manager

Chairman

COmPAnY struCture

Cleaner

Health & Safety /HR Admin

Reception

Accounts Admin

Finance Controller

Key Account Managers

Sales Team

Business Development Manager

Sales Director

Company Handbook

3GD Æ¥QRS BNLO@BS CHRB FNDR NM R@KD in the UK

1983

1982

Company founded by Steve Whitford

1984

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1986

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1989

1991

1995

1992

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1996

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1993

1995

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1993

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First brand New Heidelberg Press

First Chromalin machine

The Queen celebrates her Ruby Jubilee

Move to Langage purpose built factory 8000sq ft

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1988

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1986

Moved from buying type setting galleys of type to producing our own in house

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1985

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1984

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First year turnover Â£20,000

Computerised management Information system introduced

2004

2005

2007

2012

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2012

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2011

SG Anniversary Rebrand

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2011

2010

Awarded Environmental Printer of the Year BPIF (BAPC)

2008

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Twitter is created AX )@BJ #NQRDX

2006

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2008 Heidelberg XL105 B1 press installed

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2007

First digital colour press installed

2005

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2003

2002

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2001

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1998

1999

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First website launched @MC Æ¥QRS DL@HK RDMS

1997

Three decades of

Company Handbook

ENVIRONMENTAL POLICY STATEMENT “We aim to help our customers to communicate by harnessing emergent technology and adding value to their message through creativity and environmental sourcing, then delivering it through print & mailing media. We recognise that our processes impact on the environment and we are committed to reduce significant negative impacts where possible and also aim to improve the environment in which we live and work.” We have assessed our business activities and consider our main environmental issues to be: • The consumption of electricity

• Continually looking at material use and waste production in order to reduce its impact through using best available techniques where appropriate. • To reduce energy use through better management and monitoring. • Encouraging our customers to specify environmentally sensitive materials such as FSC, PEFC and other sustainably sourced paper and vegetable based inks • Using low solvent printing processes • Using processes, practices and materials to prevent pollution.

• Fluorinated gases

• The training and education of our staff and people working on behalf of the company to enable our environmental objectives to be achieved.

Pepper Communications Limited is Committed to:

• Continual improvement in all areas of our business

• Reducing Carbon as part of our formal system

We will manage our environmental commitment through our environmental management system, certificated to ISO14001, and by making the people who work for us aware of their impacts and responsibilities.

• Use of and storage of chemicals • Waste management

• Compliance with relevant legislation and other requirements (ISO 14001, FSC, PEFC) relating to our business activities.

Company Handbook

QUALITY POLICY STATEMENT Our Aim:

Our Customer Service standard:

At Pepper Communications Limited we value our customers and their loyalty very highly and we want their experience to be of a high standard of service each and every time they contact us.

• To deliver on time every time

Our aim is that, through knowledgeable and experienced staff, we will comply with requirements and surpass the expected service levels. This charter provides our policy for quality in customer services. It sets clear guidelines to enable everyone to measure that we are meeting our own high standards. Our Commitment: At Pepper Communications Limited we are committed to: • Being honest, ethical and professional at all times • Being helpful and courteous • Using our experience to offer advice on solving your problems

• To deliver the requested quantity (no shortages) • To always keep open the lines of communication • Complete all estimates within 24 hours • Answer the phone within 4 rings • Return all calls within 20 minutes • Check proofs before despatch • To have all the Customer Service teams working to a common method Our Production Quality Standard: • All work on triple coated silk and gloss to be produced at 175 screen or above if artwork is suitable • High resolution digital colour proofs matched to our presses

• Providing a value for money service

• Colour management system assured with tightly defined tolerances working to an ISO standard

• Producing a high-quality product

Our Service:

• Complying with the requirements of the ISO 9001, ISO14001 and ISO 12647-2 standards and maintaining our existing certifications, including the FSC & PEFC schemes.

We strive to ensure complete customer satisfaction and to continually improve the effectiveness of our operations. We welcome any comments to help us achieve this and we ask our customers to please contact us if there are any aspects of our service that are believed not to have been done well.

• To develop these commitments, we shall maintain measurable objectives for improvement.

I have prepared this statement as my commitment to running a Quality Assured Company, and I will expect that all persons carrying out work on behalf of Pepper Communications Limited to share these aims. This policy statement will be annually reviewed for ongoing suitability.

Company Handbook

WHAT IS ISO AND WHY ARE WE AUDITED? We at Pepper are committed to offering our customers the best quality and service within an environmentally sustainable framework. To demonstrate this we are independently audited by the British Standards Institute and are accredited to ISO9001:2008 (Quality Management) and ISO14001:2004 (Environmental Management). We also have ISO12647-2which is a Colour Management system which is independently audited by Mellow Colour. ISO stands for International Organisation for Standardisation. To fulfil their requirements we have documented all our procedures and policies into a binder which is held in the upstairs office. You are welcome to look at this at any time.

However, all the information you will need to know is within this booklet or on the ISO posters around the factory. The auditor is here for two days, twice a year and looks at all aspects of the business, he can pick on any process or anyone to ensure we are following the procedures set out. Don’t worry if he picks you! As you just answer any questions honestly and say exactly what you do, all our procedures reflect what we all do. They are not made up to look good!

To help you understand the approach to ISO 9001 the following illustration has been prepared.

To reach our business goals we must – as a continuous process: -

PLAN

Our work – listen to the Customers needs and wants. Do not accept work that we do not have the resources for.

Our work thoroughly – as though it were for ourselves. Adopt a first time fix policy. For example: measure twice – cut once!

CHECK

All of our work. Do not accept second best. Our workmanship must be first-class.

ACT

On, and report all problems. They will not be ignored. This is our route to improvement.

Company Handbook

BUSINESS GOALS Our 3 business goals, or objectives, defined by the Management Committee are: • ENSURE THAT WE ENJOY SECURE, PROFITABLE GROWTH • ALWAYS MEET OUR CUSTOMERS NEEDS AND EXPECTATIONS • IMPROVE THE QUALITY OF OUR WORKING PRACTICES

WHAT IS FSC AND PEFC What is the Forest Stewardship Council? Forests support up to 1.6 billion of the poorest people in the world. Sixty million indigenous people and countless species of plants and animals are wholly dependent on forests for their lives. Demand for forest products, such as timber and paper, continues to grow, putting increasing pressure on the world’s forests. Wood is a renewable resource; when forests are well-managed, with consideration for the environment, the wildlife and the people who live and work in them, harvesting timber can actually be an effective way of safeguarding the forests for future generations. Choosing products sourced from these well-managed forests and from recycled post-consumer waste allows businesses and consumers to support the world’s forests. How can you be sure that you are not supporting deforestation? Look out for the Forest Stewardship Council (FSC) logo on paper, timber and other forest products. FSC enables you to buy forest products of all kinds with confidence that you are not contributing to global forest destruction What is the Forest Stewardship Council? The Forest Stewardship Council (FSC) is an international, non-governmental organisation dedicated to promoting responsible management of the world’s forests. It was founded in 1993 in response to public concern about deforestation

and demand for a trustworthy wood-labelling scheme. FSC has developed a system of forest certification and product labelling that allows consumers to identify wood and wood-based products from well-managed forests. How can you be sure that the product really does come from an FSC certified forest? In addition to forest certification, the FSC system includes a certified chain of custody that tracks the timber through every stage in the supply chain from the forest to the final user. This is monitored through the invoicing process and the final label on the product has a code that confirms that the item is genuinely FSC. Codes can be verified by contacting FSC UK. What does the FSC logo mean? The Forest Stewardship Council (FSC) logo on a wood or wood based product is your assurance that it is made with, or contains, wood that comes from FSC certified forests, or from post-consumer waste. What makes FSC forests special? FSC certified forests must be managed to the highest environmental, social and economic standards. Trees that are harvested are replanted or allowed to regenerate naturally, but it does not stop there. The forests must also be managed with due respect for the environment, the wildlife and the people who live and work in them. This is what makes the FSC system unique and ensures that a forest is well-managed, from the protection of indigenous people’s rights to the methods of felling trees

Company Handbook What do the different labels mean? FSC Recycled –All the timber or fibre in the product is reclaimed material.

FSC Mix –The timber or fibre in the product is a mixture of some/all of the following:• Timber or fibre from and FSC-certified forest.• Post-consumer reclaimed timber or fibre.• Timber or fibre from other controlled sources Which products carry the label? The FSC® label is currently found on over 10,000 product lines in the UK alone. You can find it on garden furniture, decking, sheds, conservatories, tools, bird boxes and bird tables, kitchen, bathroom and general housewares, brushes, wallpaper, flooring, doors, shelves, furniture, toilet tissue, paper, books, pencils –in fact most things made from wood. It can also be found on other forest products such as venison, essential oils and latex for footballs and balloons.

Where can you buy FSC labelled products? Almost all the major DIY stores such as B&Q, Homebase and Focus DIY stock items. You can also find them in High Street stores such as Marks & Spencer, Sainsbury’s, John Lewis, The Body Shop, Tesco and Co-op. Why is the FSC trademark different from other forest certification schemes? There are a number of other forest certification around by they do not have the same strict environmental, social and economic standards or such rigorous chain of custody;tracking timber from the forest to the final user. Therefore the FSC is the only one endorsed by the major environmental charities. What should you do if you cannot find products with the FSC label? Although more and more products are becoming available all the time there are still gaps in the market. If you cannot find a product you should ask for it; the greater the demand, the bigger the supply. FSC UK also help with tracing items and there is a product search facility on the web site (www.fsc-uk.org).

Company Handbook

CORPORATE SOCIAL RESPONSIBILITY Introduction The policy of the Board of Directors of Pepper Communications Limited is that the company and all employees should act as good corporate citizens in the communities and environments that it operates. In order to achieve this, the Company and its employees will observe the following detailed policies General Pepper Communications Limited will observe the laws and regulations of the countries, in which it operates. In addition we will: • Contribute to economic, social and environmental progress to achieve sustainable development. • Respect the human rights of those affected by our activities. • Encourage human capital formation by providing training opportunities for employees. • Apply good corporate governance practices. • Promote employee awareness of and compliance with Company policies. • Refrain from discriminatory or disciplinary action against employees, who act as “whistle blowers” in good faith. • Encourage business partners including suppliers and sub-contractors to apply principles of corporate conduct compatible with the Guidelines. • Abstain from any improper involvement in political activities. Disclosure All disclosed information of both a financial and non-financial nature must be accurate and disclosure must be made on a timely basis. Employment and Industrial Relations • Respect the right of employees to be represented by trade unions or other representative organisations and engage in constructive negotiation to reach agreement on employment conditions.

• Not discriminate between employees or potential employees with disabilities or on grounds of age, race, colour, sex, religion, political belief, national extraction or social origin and to offer the same employment opportunities, training, career development and promotion prospects to all. • Promote consultation and co-operation between employers and employees and their representatives on matters of mutual concern. • Provide information to employees and their representatives on issues relevant to them as well as information on the performance of the company and the Group as a whole. • Take adequate steps to ensure occupational health and safety in their operations. Environment Pepper Communications Limited will take account of the need to protect the environment and promote public health and safety, and will endeavour to conduct business in order to promote sustainable development. In addition we try to: • Establish and maintain a system of environmental management, which collects and evaluates information on environmental, health and safety impacts of activities and then set and monitor targets for continuous improvement. • Maintain contingency plans for preventing, mitigating and controlling serious environmental and health damage including accidents and emergencies. • Recycle or re-use wherever possible waste from operations. If this is not possible then waste must be disposed of safely. • Ensure that the consumption of energy and other resources are minimised. • Develop processes that have no undue environmental impact, are safe to use and are efficient in their consumption of energy and natural resources. • Ensure that products conform to the legislative requirements.

Company Handbook • Provide training to employees in environmental health and safety matters including the handling of hazardous materials and the prevention of environmental accidents. Bribery No employee should directly or indirectly offer, promise, give or demand a bribe or other undue advantage to obtain or retain business or other improper advantage. All offers of bribes from third parties must be reported to the Managing Director Customers All Group companies should act in accordance with fair business, marketing and advertising practices and ensure the safety and quality of goods provided to customers. In addition they should: • Ensure that products meet all agreed and recognised required standards for quality. • Provide where requested accurate and clear information on content, storage and disposal. • Address and resolve customer complaints.

Competition Pepper Communications Limited will not enter into an anti-competitive agreement such as fixing prices or rigging bids. Pepper Communications Limited will comply with the relevant tax laws and pay the taxes on the due date.

JOINING THE COMPANY Handbook

Induction

This handbook contains our current policies, procedures and rules. It has been designed to help you understand how the Company is organised, what standards and procedures you are expected to follow and what you can expect from us in return. We hope this will help our employees to feel part of the team and be a gentle reminder as to the way our employees are expected to work.

Your induction programme is designed so that you fit in quickly and effectively. You will meet your new colleagues and you will receive information on the company, your terms and conditions of employment, company rules, and health, hygiene and safety.

This handbook is for guidance. If there is any discrepancy between your contract of employment and this handbook, you should assume that your contract of employment takes precedence.

Company Handbook

YOUR EMPLOYMENT Personnel Records

Hours of work

The Company shall hold a personnel file which contains all the relevant information regarding your employment including appraisal records, individual meetings and training and development that you have undertaken. Data must be kept within accordance to the Data Protection Act 1998.

Your normal working hours are those set out at the time of your engagement in your written principal statement. All employees should arrive at work in plenty of time to start work at their contracted time. If you are going to be late you should contact your Line Manager as soon as reasonably possible.

Personal problems

The Company reserves the right to request you to work reasonable overtime as circumstances demand. Staff may be requested to work on public holidays and will be entitled to relevant time off in lieu.

If you have any personal problems with which you believe the company may be able to help then you should approach your Line Manager. He or she may arrange for a personal discussion with the Human Resources officer which will be in absolute confidence. Change in personal circumstances To help us assist you it is essential that all information on your personnel files is up to date. Please inform Human resources of any changes in your personal circumstances, including address, telephone, name, next of kin. References Your employment is subject to the receipt of two satisfactory references. One should be from your most recent employer (or head teacher in the case of school leavers). If the Company does not receive satisfactory references, the offer of employment may be withdrawn or if the employee has already started, he/she may be dismissed depending upon the circumstances. Probationary period On joining the company you will serve a 12 week probationary period. During this time you will be making your own mind up about whether you wish to remain working for this company. Your Line Manager will be assessing your capabilities, attitude and potential. If you do not reach the standards required by the company your employment will be terminated at any time during the 12 week period, with the appropriate notice/pay in lieu or the probationary period may be extended beyond the 12 weeks.

Lunch and tea breaks are those notified to you on your engagement and must be taken at a time agreed with your Line Manager. Payment of wages Wages are paid at the end of each calendar month. Wages are paid by credit transfer directly into your bank or building society account. An itemised pay slip showing gross earnings, fixed and variable deductions and net wage will be given to you at the time of each wage statement. Your starting wage is stated in your principal statement. We will let you know of any subsequent changes to your wages, which are normally reviewed annually on April 1st. Clocking Procedure All production employees must clock in and out everyday using the Tharstern IDC system. All jobs completed must be recorded using the IDC system to record time allocated to each live job. Training of this procedure will be provided to ensure you are able to complete this process effectively. Overtime From time to time, you may be requested to work overtime, and you will be expected to co-operate with any reasonable request. All overtime must be authorised in advance by your Departmental Manager. No compensation is made for overtime not authorised in advance. All time sheets must be completed and handed to accounts by the penultimate Friday of the month. Overtime must be approved by your line manager or otherwise may not be granted.

Company Handbook Private Healthcare

Suggestion Scheme

All full-time staff will be eligible to join the company health scheme after your first 12 months employment; further details are available from Human Resources.

The Company welcome any ideas that lead to greater efficiency and productivity or ideas for the greater safety and well being of all employees.

Training Policy

You should write your idea and personal details in a letter addressed to the Production Director. If your idea is adopted by the Company you may receive a reward.

The Company believes that it’s most valuable resource is its employees. The continued success of the Company depends upon having highly motivated people with proper skills in the right job at the right time. We recognise the need to offer all employees a clear path of progression within the business, therefore, job descriptions and personal objectives will be reviewed on a regular basis. All staff involved in training other staff will be deemed competent themselves and it is expected that as part of your normal employment that you will help to train new employees. The individual ability and training needs of every employee will be identified through regular reviews. Training will be planned to meet these needs and the effectiveness of that training will be evaluated before deeming them competent to do the job. All persons who join the Company will receive systematic induction training, much of it on-the-job, designed to familiarise them with the Company and give them the necessary knowledge, skills and attitudes to begin their job. Staff promoted or transferred will be given appropriate training and the effectiveness of that training will be evaluated before or immediately upon taking up a new appointment. Staff will also be allowed and encouraged to attend external courses relevant to the development of their careers. An employee may be required to attend training courses normally at the employer’s expense. However, if the employee resigns from his/ her employment with the employer during the training course or within 6 months of completing any training course then the employer shall be entitled to deduct the cost of such course(s) in whole or in part by deduction from payment of the final salary and other emoluments due to the employee on termination of employment.

General Notice boards There are four notice boards located in the two canteens, next to the staff entrance and the factory floor. These should be checked regularly for relevant and important communication. Communications – the role of your Manager Perhaps the most important means of communications are the informal face-to face discussions that occur each day – about your job, your company and your benefits. Your prime source of information about your job or the company is your line manager. It is part of his/ her job to inform, answer questions and listen to constructive opinions, comments or suggestions. Personal Property The Company will not accept responsibility for loss of, or damage to your property whilst it is on Company premises. However if you lose or find any article please make sure you hand it in to the general office without delay. Confidentiality No employee shall disclose at any time during his/her employment or at any time after his/her employment has terminated disclose and trade secrets or other information of a confidential nature relating to the Employer or any of the Employers customers or clients except in the proper course of the Employee’s employment or as required by law. Employees must not remove any tangible items, which belong to the Employer or any document which may contain any confidential information from the Employers premises without proper advanced authorisation from a Director and completing an “Authorisation Form”, as per the Authorisation Policy.

Company Handbook Employees must upon request and, in any event, upon termination of the Employee’s employment return all documents and tangible items which belong to the Employer or which contain or refer to any confidential information. Other Employment You should not without prior written consent of the Employer (which shall not be unreasonably withheld), engage, whether directly or indirectly in any business or employment outside of the Employee’s hours of work for the Employer

Data Protection Principles The Act places an obligation on “data controllers”, such as the Company, to observe eight data protection principles. In summary these are that personal data must be: – processed fairly and lawfully; – processed for limited purposes and not in any manner incompatible with those purposes; – adequate, relevant and not excessive; – accurate;

Medical

– kept for no longer than is necessary;

The Employer reserves the right to request the Employee to undergo a medical, eyesight examination or audiometry testing (if required) conducted by a medical officer nominated by the Employer as and when the Employer deems necessary.

– processed in line with the rights given to individuals under the Act;

Data Protection Policy

All employees also have an obligation to comply with these principles where necessary.

The Data Protection Act 1998 (the “Act”) sets out the principles that the Company must follow when processing personal data about individuals, and also gives individuals certain rights in relation to personal data that is held about them. This Policy aims to: – assist the Company in meeting its obligations under the Act; – regulate the Company’s use of personal data relating to employees and others who work for the Company; and – ensure that employees and others working for the Company are aware of both their rights in relation to the personal data that the Company holds about them, and their responsibilities regarding personal data they may hold about other individuals working for the Company. For ease of reference, this policy refers to “employees’’, but it applies equally to individuals working for the Company in other capacities such as contractors, and agency workers where the Company holds data relating to them.

– kept secure; and – transferred only to those countries with adequate level of data protection.

What is Personal Data and Processing? Personal data includes information which relates to or identifies a living individual who can be identified from that data. The data protection principles apply to personal data which is either automatically processed (e.g. on a database) or which is held in a structured filing system which falls within the Act. There is a sub-category of personal data known as sensitive personal data. Personal data is sensitive if it relates to matters such as race or ethnic origin, trade union membership, health or any criminal offence or related proceedings. Sensitive personal data can only be processed under strict conditions, and will usually require the express consent of the person concerned. This Policy also explains the types of information the Company tends to hold which amounts to sensitive personal data. “Processing” is the term used in the Act to refer to a wide range of activities in relation to personal data including its collection, retention, use, disclosure, and final destruction or erasure.

Company Handbook What Types of Personal Data Does the Company Hold? The Company holds and processes certain data about you as part of its general employee records. Its records include; – name, address, phone numbers and other contact numbers; – date of birth, NI number, immigration status and marital status; – bank details; – CV’S details provided when you applied for your job, details of education, job history and experience (both within the Company and previously), qualifications, contracts of employment and offer letters; – emergency contact details; – full details of current and previous positions within the Company, details of compensation and benefits; – records relating to holiday and other leave; and – details of development needs and achievements, records and documentation relating to any appraisals, performance reviews, disciplinary matters concerning you or in relation to which you have been involved or grievances you have raised or which have been raised by others about you. Our systems will also collect and retain personal data; these might include our document management system, email system and internet portal. Obviously it is not possible to list every type of information which may be held by the Company about every employee. This list only contains examples of the usual types of general employee information the Company holds and is not exhaustive. Much of this information will amount to personal data for the purposes of the Act depending on the context in which it is held by us. Purpose of Processing General Employee Information The Company needs to collect and use personal data about employees for a variety of personnel, administration, employee, work and general business management purposes. These include administration of the payroll system,

the administration of employee benefits (such as bonuses, pensions, leave entitlements), facilitating the management of work and employees, carrying out appraisals performance reviews and salary reviews, disciplinary investigations and meetings, to operate and check compliance with the Company’s employment rules and policies, to operate the Company’s IT and communications systems such as the use of mobile phones, IT and laptops, and to check for unauthorised use of those systems (including, where appropriate, monitoring), and to comply with record keeping and other legal obligations including its obligation under the Act, for example searching and monitoring records in compliance with a data subject access request. Sensitive Personal Data As noted above, the Act also recognises a category of information known as sensitive personal data. The only information which the Company collects and processes which may amount to sensitive personal data is information relating to your health. In general, this information comprises records of sickness absences and medical certificates (including the Company’s Self Certified Sickness Form) and any medical reports which you have provided or have obtained by the Company with your consent. The purpose of obtaining and keeping this sort of information is to assess eligibility for or administer and pay benefits related to ill-health such as sick pay and private medical insurance. We may also use any medical reports we have obtained in order to assess or determine your fitness for employment, continued employment or a particular role or task, or to assess any risk to your health. The Company also needs this information to monitor and manage sickness absence, and to comply with obligations under Health and Safety legislation, including its obligations to protect your health and safety at work and the health and safety of others. Employee Database Some of the employee information described above is stored in a database and is controlled and accessed only by key individuals in Human resources and Finance. There are security measures in place, including the use of passwords and other access controls which will ensure the confidentiality of the information contained.

Company Handbook Personnel Files The remainder of the information described above is kept in the Company’s personnel files. These files are located in the Human resources department and access to these files is limited to key personnel within HR and Finance. Other staff such as your Manager will only be permitted to view or copy information on an individuals file if it is essential for them to carry out their duties of employment. Accurate and Up to Date Information The Company will take steps to ensure that the employee information and other personal data it holds is accurate and up-to-date. It is your obligation however to ensure that you notify the Company of any changes to your personal data, as set out above. The Company will also take steps to ensure that it does not keep any information about employees for longer than is necessary. It may, for example, keep details of employees for a reasonable time after they have left the Company’s employment. The Company needs to do this in order to ensure benefits have been properly administered, to give references if requested to do so, to ensure the Company’s tax obligations have been satisfied and to deal with tribunal or other court proceedings. Transfer of Personal Data to Others The Company may from time to time need to make employee personal data available to other members of the Company for the purpose set out in this policy. Likewise, the Company will also need to make employee information available to accountants, auditors, lawyers and other outside professional advisers, and to companies who provide products and services to the Company (such as IT suppliers, pension scheme, payroll service or medical benefit providers, other outsourcing providers)

Your Rights and Responsibilities under the Data Protection Act The Act gives employees (and anyone else about whom personal data is held) specific rights in relation to some of the information that is held about them. Under the Act you are able to; – obtain confirmation that the Company holds personal data about you, as well as a written description of the information, the purposes for which it is being used, the sources of the information (if available) and the details of any recipients; – make a written request to access the personal data which is held about you. It is important to note that this is not an absolute right to review all the information that is held about you, as there are various exceptions to this right. One of the most important exceptions is that you may not be able to access the information about you if this would reveal personal information about someone else. In addition the data may not be readily accessible, the information you seek may not amount to personal data under the Act or the data may not be held in a relevant filing system; and – ask, in certain circumstances, for the deletion or rectification of personal data which the Company holds about you which is not accurate. You’re Responsibilities As well as having rights under the Act, all employees must also comply with data protection principles set out above. Employees must also take steps to ensure that they follow the Company’s guidelines on data protection set out in this policy. Other People’s Personal Information It may be that as part of your job, you hold personal data about the Company’s employees or about other individuals or are asked to disclose it by others. For example, if you have any managerial responsibility for other employees you are likely to hold personal data about them. Even if you do not have direct involvement with personal data as part of your job, there may be times when you are asked by others to supply personal data. Therefore, all employees must follow the guidelines set out below.

Company Handbook Please note that the following guidelines apply equally to documents containing personal information which are kept in manual files, as well as information which is kept on a computer database or in any other electronic form.

– if you do need to send personal data to a third party, and have been authorized to do so, avoid sending personal data which is confidential by email or by fax unless you are sure that the link is secure and confidential.

– all personal information must be kept securely and should remain confidential.

– you should not keep personal data about people which is no longer needed or which is out of date or inaccurate. You should therefore review any personal data that you hold from time to time, bearing these principles in mind.

– if you receive a request from someone outside the Company to give them any personal data about an employee (or other individual) you should refer them to the HR department. The Company needs to verify the person making the request and has to balance various considerations when deciding whether and how to respond to such a request, including compliance to the Act. – in no circumstances should you give the information to the person requesting it without first referring the matter to the HR Manager and getting prior written approval. – you should be aware that it is a criminal offence under the Act if you deliberately or recklessly disclose personal data to someone outside the Company without the Company’s consent. – accessing, disclosing or otherwise using employee records or other employee data without authority will be treated as a serious disciplinary offence and may result in disciplinary action being taken in accordance with the Company’s disciplinary Rules and Procedure.

If you are unsure about the application of these guidelines to the information you hold as part of your job, you should contact your manager for further guidance. This Policy is provided by way of guidance only and does not form part of your contract of employment with the Company. However, any breach of this policy will be taken seriously and may result in disciplinary action. The Company may issue further guidance or amendments to this policy from time to time and/or in line with legal developments.

Company Handbook

COMPUTER AND EMAIL USE We do not wish to restrict in any way your use of our computer system – indeed we encourage it. However, we regard the integrity of our computer system as key to the success of our business. To avoid misunderstanding and confusion all employees must abide by the following policies. Breaches of this policy will be taken seriously and could amount to gross misconduct. You should direct any queries about this policy to a Director. Licensed software Only properly licensed software may be loaded onto our system. You are not allowed to use within the company any material that you either know, or suspect to be, in breach of copyright. In addition, you are not allowed to pass such material on to anyone else. It is important to bear in mind that breach of copyright for business purposes can be a criminal offence both by the company and by the individual concerned. No software may be loaded onto our system without first obtaining the express permission of a Director. Software includes business applications, shareware, entertainment software, games, screen-savers, and demonstration software. If you are unsure whether a piece of software requires a licence, please check. The copying of software media and manuals is also prohibited.

themselves. If a virus is suspected you should do nothing more until instructed. The matter must be reported immediately to the Production Director The most likely way that our computer system will be infected by a virus is by an external message. Any outside material must be properly virus checked before being loaded on to our computer system. Many viruses are now spread by email messages and use the address book of the recipient to pass it on to other people. Some of these viruses are activated when an attachment to the message is opened. Creators of these viruses frequently encourage the user to open the attachment simply by using a header such as “You must read this!” You should not open any attachment of this type and must generally be suspicious of any message that is received from an unknown source. In other words, only open mail when you know it is from a reliable source. If you receive email warnings about viruses please ignore the instructions they contain. In the majority of cases they are hoaxes and the instructions, if followed, will damage our computer system. Customer Procedures If you use a customer’s computer system you must observe the customer’s rules relating to their computers. In the absence of any such rules our rules should be followed.

Networks

Access

You are not allowed to make any change to the connection or configuration of your PC. None of our PC’s may be connected to a customer’s network without both permission from a Director and written permission from the customer concerned. In addition, none of our PC’s may be connected to a public network, e.g. internet, without permission

You are only allowed access to those parts of our computer system which you need in order to carry out your normal duties.

Disks You must not use disks from unknown sources or from home computers. All data disks must be virus checked before they may be used on our computer system. Viruses Generally, more damage to files is caused by inappropriate corrective action than by viruses

Inappropriate Material You must not view or download or pass on any pornographic material on our computer system or place obscene or offensive screen-savers on your PC. In line with the normal rules that apply to you as an employee, you are not allowed to send racist, sexist, blasphemous, defamatory, obscene, indecent or abusive messages on our computer system, either internally or externally. Do be careful and think carefully before sending any questionable messages that could reflect badly on us as a business.

Company Handbook Use of the internet at work

Data Protection

The primary reason for our providing you with access to the internet and/or email is to assist you in your work for us. You are allowed to send personal emails and access the internet in a similar way to the way that minor incidental personal telephone use is allowed. Such activity should not be excessive and must not affect your ability to work properly for us during normal working hours. You are not allowed to send unsolicited emails or email messages to multiple recipients or use email for personal gain.

If you have access to data about individuals you must bear in mind at all times the provisions of the Data Protection Act 1998.

You are also not allowed to use the companyâ&#x20AC;&#x2122;s internet access and email system to sign up for online shopping or internet membership schemes or chatrooms.

Backups Critical information should not be stored on the hard disk of your workstation in case it is lost, please use the office user drive located under the drive letter N:. Misuse Misuse of computers is a serious disciplinary offence. The following are examples of misuse: (a) Fraud and theft (b) System sabotage

Orders

You must not order anything on our behalf by email without proper authorisation. You should always bear in mind that an email from the company has the same legal effect as a letter from the company on the companyâ&#x20AC;&#x2122;s notepaper. This underlines the importance of being careful with what you say in an email in case it is misunderstood.

(d) Using unauthorised software

Confidentiality Before sending any confidential information by email consider carefully whether appropriate steps have been taken to maintain such confidentiality. Email is not inherently a more secure medium of communication than traditional means, and can be easily copied, forwarded and stored. Security Do not give internal passwords to anyone outside the company. In addition, you must not give any customer-related security information to anyone other than the customer unless specifically authorised in writing by the customer in advance. Records Keep proper records of our dealings with outsiders. It is always possible that what appears to be a relatively trivial point could be of immense significance later. It is not possible to foresee what will subsequently need to be checked so keep a complete record of all transactions.

(e) Obtaining unauthorised access (f) Using the system for unauthorised private work or game playing (g) breaches of the Data Protection Act 1998 (h) Sending abusive, rude or defamatory messages via email (i) Hacking or (j) Breach of the companyâ&#x20AC;&#x2122;s security procedures or this policy. This list is not exhaustive. Depending on the circumstances of each case, misuse of the computer system may be considered gross misconduct, punishable by dismissal without notice. Misuse amounting to criminal conduct may be reported by us to the Police. Breaches All breaches of computer security must be reported immediately. If you suspect that a fellow employee (of whatever seniority) is abusing the computer system you may speak in confidence to a Director. You are responsible for any actions that are taken against us by a third party arising from restricted and/or offensive material being displayed on or sent by you through our computer system.

Company Handbook Monitoring The company reserves the right to intercept and monitor your communications, including email, internet and telephone calls. This right to monitor may be exercised, for example, for the purpose of deciding whether communications are relevant to the business, for the purpose of preventing or detecting crime or to ensure the effective operation of the system.

In addition, the company reserves the right to monitor communications in order to determine the existence of facts, to detect unauthorised use of the system and to decide the standards which ought to be achieved by employees using the system.

MOBILE PHONE USE AND driving As part of our overall health and safety policy, Pepper Communications Limited is committed to reducing the risks which our staff face and create when using mobile phones in the workplace or when driving for work.

• All Managers and Senior Managers should lead by example and never make or receive a call on a mobile phone when driving. Managers should never expect staff to answer calls when they know they are driving.

We ask all our staff to play their part, whether they use a company vehicle, their own or a hire vehicle (this includes forklifts).

• Phones should be switched to voicemail, or switched off when driving, plan journeys so that they include safe rest stops, when messages can be checked and calls can be returned.

Staff driving for work must never make or receive calls on a mobile phone, whether hand-held or hands-free, while driving. Persistent failure to do so will be regarded as a serious matter. Staff must never make or receive a call whilst operating machinery. All Staff who drive for work need to know It is illegal to drive a vehicle or ride a motorbike while using a hand-held mobile phone or a similar device like a Blackberry. Hands-free phones can also be a distraction and you’ll risk prosecution for not having proper control of your vehicle when using one. If you are caught using a hand-held mobile phone or similar device while driving or riding, you’ll get an automatic fixed penalty notice three penalty points and a fine of £60. If your case goes to court, you may also face disqualification on top of a maximum fine of £1,000. Drivers of buses and goods vehicles face a maximum fine of £2,500.

• If while driving you pick up or use any type of phone that must be held- you will be breaking the law. This means you should not use your mobile phone, when you are stopped at traffic lights, queuing in traffic, to make or receive calls, to send or receive messages or to access the internet. • If you call someone on their mobile phone that turns out to be driving when they answer, say you will call them back and hang up. Using Mobile phone in the work place Office based use A certain etiquette relating to mobile use in the workplace is needed. Mobile phones can be a distraction and an irritation to others. • Personal mobile phones should be set to silent/vibrate in the work environment. • If it is necessary to make or answer a call then it should be done so in a private area.

If you reach six or more points within two years of passing your test, your license will be taken off you. You’ll need to resit your driving test to get your license back.

• When it is necessary to speak on the phone in the presence of others then do so in low tones.

• Never use a hand-held or hands-free phone while driving

• Don’t answer your mobile whilst in a meeting.

• Don’t interrupt colleagues by answering your mobile phone.

Company Handbook • Ensure that you choose a ringtone that isn’t likely to drive colleagues around the bend.

The vehicle must have a current MOT Certificate (if applicable), Insurance and Road Fund License.

• The only exception to the rule is work based Sales calls!

Mobile Phone

Shop Floor use Mobile phones + accessories including headphones impose a Health and Safety risk on the shop floor and should be kept in cars, bags or lockers. Staff are not permitted to make or receive calls whilst working on the shop floor, calls can be made in the canteen or outside the factory during break and lunch times only. All mobile phones should be kept on silent and preferably on voice-mail so that all messages and return calls can be dealt with during break times and away from the shop floor. The only exception is if prior agreement has been given by a line Manager for an expected emergency call. Mobile phones must NEVER be used whilst operating machinery or using chemicals and if they are seen lying around on machinery on the shop floor, they will be removed.

The use of a mobile phone while driving is illegal and prohibited. Refer to the Company Mobile phone policy for more details. Tiredness and Driving Employees must never attempt to drive if feeling drowsy or suffering from fatigue. Employees during their normal days work should rest before commencing a journey or stop for a break on route. Drink and Drugs Employees must never operate machinery or drive a company vehicle if they have been drinking alcohol or have taken drugs (illegal or prescribed) which affect concentration, induce drowsiness or otherwise affect a person’s ability to operate machinery or drive safely. Health

Failure to follow these rules will in effect be a breach of health and safety

Some forms of ill health affect a person’s ability to drive safely either for a temporary or longer term period even though they may be able to perform their work duties. In these instances the Company will assist to accommodate the problem.

Visitors and Telephone calls

Eye Tests

You must get permission before you receive visitors during working hours. You should seek your line manager’s agreement to make outgoing phone calls in cases of emergency. Please note: All calls made using the company telephone system may be recorded for training purposes.

It is recommended that all drivers have regular eye tests.

Driving on Company Business This policy applies to all staff, whether or not they are entitled to a Company Car. Health and Safety law requires employers to ensure so far as reasonably practicable the health, safety and well being of their employees and to safeguard others who may be at risk from their work activities. This includes when they are undertaking work related driving activities. The Company is constantly aware of the dangers surrounding any vehicle driver. Employees are required to comply with the following rules for their own safety and that of others. When using your own vehicle for work use, the vehicle must have insurance cover that covers ‘work use’. Privately owned vehicles must be road legal and safe for use as required under current Road Traffic Act requirements.

Adverse Weather Conditions Employees should assess the risk before setting out on journeys where there is a risk of adverse weather conditions, consider alternative forms of transport and obtain the appropriate authorisation from their line manager. Passengers The driver and passengers must wear seat belts at all times. Should a person be injured in an accident as a result of failing to wear a seat belt then it is likely that compensation could be refused or drastically reduced. Adherence to the Highway Code At all times employees are requested to comply with the Highway Code.

Company Handbook

SMOKING General Statement Pepper Communications Limited values it employees, consultants and contractors and wishes to promote their health, safety and well-being. Research indicates that smoking is a health hazard, both to smokers and to those subjected to smoke from others (passive smoking) and a possible safety risk due to the nature of our business. This policy applies to all staff including consultants, agency or temporary workers and any other third party working on Pepper Communications Limited premises or on behalf of Pepper Communications Limited The policy aims to establish a healthy and safe environment for all staff. It is based upon the general principle that the interests of both smokers and non-smokers will be respected. When these conflict, the preference of the nonsmoker will prevail in order to protect employees from the potentially adverse effects of passive smoking.

In order to provide a healthier work environment, Pepper Communications Limitedâ&#x20AC;&#x2122;s workplaces will be smoke free areas. This will apply regardless of whether all staff in a particular location are smokers and will include office staff. All areas of Pepper Communications Limited premises and workplace communal areas (including outside on the Companyâ&#x20AC;&#x2122;s premises), are designated as no-smoking areas. Staff that wish to smoke during their working day must only do so during their allocated breaks off the premises, clocking off and clocking back on when returning. Smoking or using e-cigarettes / vapourisers on site inside or outside is forbidden and will be treated as gross misconduct. Anyone found to be smoking on site will be suspended without pay pending investigation. Vehicles All vehicles used for work purposes including hired, privately owned and loaned vehicles, will be smoke free.

EXPENSES The Company will reimburse all reasonable travelling, hotel, entertainment and other out of pocket expenses which you may from time to time properly incur in the exercise of your duties provided that your expenses have been authorised and that there is evidence of expenditure as it may reasonably require.

All expenses must be recorded on the Companyâ&#x20AC;&#x2122;s Expense Claim Form with receipts attached and given to your Manager/Director at the end of the month to be duly checked and authorised. Expenses may not be paid unless the above procedure is followed. Any unusual or out of normal business hours claims must be pre-authorised.

Company Handbook

HOLIDAY ENTITLEMENT Holiday Year The Company holiday year runs from 1st January to 31st December. Holidays must be taken by arrangement with your appropriate Manager, as agreed in writing. No more than 10 working days may be taken at one time except with the written permission of a Director. The Company has the right to refuse holiday during certain periods e.g high production levels, insufficient staffing levels. All employees are required to take their full entitlement to paid holidays within each holiday year, and there is no statutory right to carry holiday entitlement into a succeeding holiday year unless with the written permission of a Director. No payment will be made in lieu of holiday entitlement not taken, other than on termination of employment. All employees accrue holiday during their 3 month probation period and are entitled to start booking holiday after successfully completing their 3 month probation period.

The Company also holds the right to nominate certain dates of closure or specific times, when employees will be expected to take annual leave. Should the Company require you to take some of your holiday entitlement at certain times then the correct notice will be given Annual Entitlement The basic entitlement shall be 23 days exclusive of bank and public holidays on days which the employee would normally work. The public/bank holidays each year that the Company will recognise are: New Years Day, Good Friday, Easter Monday, Early May BH, Spring BH, Summer BH, Christmas day and Boxing day. Annual holiday accrues at the rate of 1/12th of your contracted 5 weeks for each full calendar month of completed service. E.g. 23/12 = 1.91 days per month. In your first holiday year your entitlement will be proportionate to the amount of time left in the holiday year.

Holiday Pay

Part Time Staff

You will receive your normal pay for your holiday.

All holiday entitlement is calculated pro rata for part time employees.

Notice to Take Holiday You must give advance notice that you want to take holiday. This notice should be at least twice as long as the amount of holiday you want to take. For example, you should give two weeks’ notice for one week’s holiday. The Company has the right to refuse permission for your holiday even if the correct notice requirements have been met. With the correct notice the Company holds the right to shut the business down for certain periods, during which some or all employees will have to use their annual holiday entitlement.

Entitlement to Holiday on Termination of Employment Holiday entitlement for the current year will be calculated at 1/12th of the annual entitlement for each completed month of service up to the date of leaving. Termination pay will be adjusted to take account of the difference between holiday days accrued and taken since 1st January of the current year. During the notice period, any unused entitled holiday may only be taken at management’s discretion.

Company Handbook

MEDICAL APPOINTMENTS Where possible, appointments should be made in personal time or at the beginning or end of the working day. If a medical appointment is scheduled during working time the employee

shall inform his/her manager in advance of the date and time by production of an appointment card and endeavour to make up the time lost.

SICKNESS PROCEDURE If employees exhaust any paid Company Sick Pay in any 12 month period (such payment being in the Company’s absolute discretion), the Company shall not consider paying further Company sick pay in a subsequent 12 month period until the employee has returned to work for at least six consecutive months, without a period of sickness absence. Company sick pay may be withheld in the following circumstances: • The notification and certification requirements are not met. • Your Manager and Director are not reasonably satisfied with the reasons for your absence. • The Company has been advised by a Doctor or Occupational Health professional that you are fit for work.

Long Term Absence This is a period of absence which lasts longer than two calendar weeks. The company takes a sympathetic view about genuine ill health problems and will provide a supportive approach. We will monitor your absence and counsel you through a period of sickness absence. Telephone and home visits maybe arranged with prior consent. If it looks like absence will be for more than four weeks. Ultimately once all circumstances have been taken into account if absence does reach a problematic level the company may have no choice but to dismiss you. Before dismissal the company will comply with any applicable statutory dismissal procedure. Medical Examination

If any employee is away sick at the time in which he/she would have joined the scheme his/her membership will be deferred until he/she has returned to work for two consecutive weeks.

In the case of persistent or long term sickness absences, or at the point entitlement to be considered for payment of Company Sick Pay ceases, the Company will consult with you and reserves the right to require you to undergo a medical examination. The Company will pay the cost of any such examinations and any report produced in connection with the examination will be fully disclosed to the Company.

Short term absence

Return to work

Your line Manager will formally review your absence record if in any three month period there are three separate periods of absence (certificated or not), or if there is an unacceptable pattern of absence.

When you return to work your Line Manager will hold a discussion with you on the first day of your return to work or as soon as reasonably possible.

Payment of company sickness benefit will always be at management’s discretion Later Enrolment

Company Handbook Sickness Procedure All employees play an important role within the company and therefore your absence will be noticed. In fairness to the company and your colleagues, we require you to notify us by telephone should you be sick or absent. This will allow the company to make arrangements for your duties to be covered by other members of staff while you are away. 1. If you are taken ill at work, you should report to your Manager and obtain permission to leave work. Managers will ensure that arrangements have been made for you if you are unwell and shall arrange for you to be accompanied home or receive medical treatment where necessary. 2. In the event of absence for any reason the Employee (or someone on his/her behalf) must inform the Employer of the reason for the Employee’s absence as soon as possible before each day the Employee is due to commence his/her work unless covered by a fit note (formerly a sick note). 3. In respect of absence lasting 7or fewer calendar days the Employee is not required to produce a fit note (formerly a sick note) unless specifically so requested by the Employer, but complete a self certification forms on return to work from such absence. 4. In respect of absence lasting more than 7 calendar days the Employee must on the seventh calendar day of absence provide the Employer with a medical certificate stating the reason for absence and thereafter provide a like certificate each week to cover any subsequent period of absence. The Employer

reserves the right to ask the Employee at any stage of absence to produce a fit note (formerly a sick note) and/or to undergo a medical examination. 5. If the Employee resumes work after Sickness/ Injury absence of 6 days or less the Employee is required to complete and sign an “Absence Due to Personal Sickness or Injury” form on reporting back to work in the presence of a Manager. 6. If the Employee is absent from work on account of sickness or injury and provided that the Employee has followed the sickness reporting procedure he/she will be entitled to be paid statutory sick pay/Company sick pay. Company sick pay however is always paid at the discretion of the Manager. 7. If an employee falls sick whilst on holiday or immediately prior to his/her holiday the employee will still receive holiday pay for leave booked and not sick pay unless a medical certificate is provided and the correct procedures for reporting sickness are followed. The company reserves the right, at any time during a period of absence to obtain, with the employee’s permission, medical evidence, either from the employee’s own doctor or a doctor of the company’s choice that the state of incapacity continues. The company may require an employee to be examined by a doctor following a period of sick leave. If you do not notify the company of your absence in accordance with the company procedure and are unable to give a satisfactory explanation for your absence, the company reserves the right to withhold any sickness payments to you.

Company Handbook

Attendance Award Programme PURPOSE To reward employees with impeccable attendance records and incentivise those with poor attendance to improve and achieve zero absence. This makes you, your team, and ultimately the company more reliable to its customers. ELIGIBILITY All full time employees at Pepper who have a contract of employment and who achieve perfect attendance between January and December each year. RESPONSIBILITY The Attendance Award Programme is a Human Resources/Personnel department (H.R.) designed and implemented Employee Benefit. Attendance/Absence recording is an H.R. responsibility.

TWO OCCASIONS OF LATENESS WILL EQUATE TO ONE ABSENCE. Absences as detailed above can be converted into holiday to preserve your attendance award as part of the programme. Indicate if you wish to do this on a sickness form when you return to work after any absence within 1 week. Failure to do this may mean that the award cannot be paid. New employees joining the programme part way through the year will be paid pro rata in the first qualifying period. Only years in which you qualify are counted as cumulative and not years of service. The attendance award programme is cumulative and will increase with every successfully completed qualifying year in line with the following schedule:

It is a responsibility of all Managers, Supervisors and Leaders and Employees to support the Attendance Award Programme and objectives.

NO. OF AMOUNT PAYABLE QUALIFYING THROUGH PAYROLL YEARS SYSTEM in ÂŁâ&#x20AC;&#x2122;s

H.R. is responsible for generating communication and awards to achievers in January each year.

100

120

140

160

180 + 50 (5yr bonus)

200

220

A qualifying attendance year runs from January to December in line with the holiday year

240

An attendance award is payable in January with your normal monthly pay provided the following conditions are satisfied in the qualifying year:

260

280 + 100 (10yr bonus)

300

NO RECORDED ABSENCE

320

NO RECORDED SICKNESS

340

NO UNPAID LEAVE

360

380 + 150 (15yr bonus)

Attendance status will be featured in all appraisals. PROGRAMME An attendance award will be paid through the normal payroll system during the month following the qualifying date:-

Company Handbook FREQUENTLY ASKED QUESTIONS If I am absent for 1 day/shift do I get the award through this programme? No, but you can exchange an absence for holiday entitlement which would mean you would be entitled to the award. If I am absent for 3 days/shifts can I have a percentage of the award? No. The programme is designed to incentivise and reward those who achieve optimum attendance and therefore reliability. If I achieve the award for 2 years but in the third year have some absence what happens then? In year one you were paid £100, in year two £120 but in year three you will receive no award from the scheme. In the next complete year (January to December) that you have zero absence you will receive £140. Is the scheme retrospective? No. The attendance award programme is a new initiative with a start date of 01/03/03. It is effective from that date onwards. If I come into work and then fall ill and go home that day – therefore work for part of the day does that count as absence? Yes. That day would count under the programme as an absence day/shift (any holiday pay in this instance may be honoured under management discretion).

EXAMPLE QUALIFYING Service Years YEARS Year 1

Year 1 – No absence – Paid £100

Year 2 – Absences recorded – Paid £0

Year 2

Year 3 – No absence – Paid £120

Year 3

Year 4 – No absence – Paid £140

Year 5 – Absences recorded – Paid £0

Year 4

Year 6 – No absence – Paid £160

Year 5

Year 7 – No absence – Paid £180 + 50 = £230

Year 6

Year 8 – No absence – Paid £200

In this example in 8 years of service, 6 qualifying years have been achieved for the attendance award programme.

Company Handbook

PUBLIC DUTIES Employees who are required to take time off work to undertake jury service or to attend court as witnesses should show their Manager the notification of such requirement. The Company supports public service and will financially support you during this period. The court will send you a loss of earnings form which you

should complete and return to the court, with a copy to your Manager. You will be paid in full whilst carrying out your jury service but the loss of earnings payment which you are entitled to claim from the court will be deducted from your salary

TIME OFF TO DEAL WITH A FAMILY EMERGENCY All employees are entitled to reasonable time off work without pay, to deal with an emergency involving a dependant. For example, if a dependant falls ill or is injured, if care arrangements breakdown, or to arrange or attend a dependants funeral.

A dependent is defined as a spouse, civil partner, child or parent of the employee (not a Grandparent) or a person who lives in the same household as the employee (excluding tenants, lodgers, boarders and employees) and any person who reasonably relies on you for the provision of care.

PARENTAL LEAVE Employees who have been continuously employed by the Company for a minimum of one year are eligible to parental leave if they are responsible for a child under the age of 5, are responsible for a disabled child under the age of 18 or become the adoptive parents of a child (in which case parental leave can only be taken before the 5th anniversary of the placement or the childâ&#x20AC;&#x2122;s 18th birthday, whichever is the sooner).

You are entitled to a maximum of 13 weeks unpaid leave per child (pro rata for part time employees) for the purposes of caring for that child. This leave may be taken on application to your Line Manager and should be taken in blocks of 4 weeks leave a year. You will not be paid during your period of parental leave. In certain circumstances, other than when parental leave is requested immediately upon the birth or adoption of a child the Company reserves the right to postpone your request for parental leave if it considers that the operation of the business would otherwise be unduly disrupted.

Company Handbook

MATERNITY LEAVE Time off for antenatal care If you are pregnant, you are entitled to take time off during your normal working hours to receive antenatal care. This should be at times agreed with your supervisor or line manager and preferable at the start or end of your working day. Antenatal care includes appointments with your GP, hospital clinics and relaxation classes. You should advise your line manager that you will be absent as far in advance of your appointment as possible. You will be asked to produce your appointment card. There will be no deduction of salary for attendance at authorised antenatal appointments. Compulsory maternity leave (CML) All female employees regardless of their length of service must take the 2 weeks immediately following the birth of their child as leave. This is a legal requirement (if you work in a factory environment the period in which you are not allowed to work is extended to 4 weeks). Ordinary maternity leave (OML) All pregnant employees are entitled to take 52 weeks maternity leave, no matter how long they have been employed by us and no matter how many hours they work each week When does your maternity leave start? You can choose to start your maternity leave at any time after the start of the 11th week before the week in which your child is due, except in the following cases: (i) If you are absent because of an illness related to your pregnancy at any time after the start of the 6th week before your child is due, the company reserves the right to require you to start your maternity leave on the first day of that absence; (ii) If your child is born earlier than your planned date of starting maternity leave, then the maternity leave starts on the day the child is born. You should write as soon as possible to notify the company, enclosing form MAT B1, unless you have already handed this over by then.

Note that if your child is still born after the 24th week of pregnancy, you retain your maternity leave rights (and your right to statutory maternity pay (SMP), subject to the SMP rules stated below). Notification requirements At least 28 days before you start your maternity leave, you must give notice in writing addressed to your line manager. That notice must state: (i) That you are pregnant; (ii) The week in which your child is due (note that, for these purposes, a week begins on a Sunday); (iii) When you want your maternity leave to start. You should enclose a form MAT B1 signed by your GP or midwife with your letter, unless this has been given to the company earlier. If you are unable to give 28 days’ notice because you have to start your maternity leave sooner than you anticipated, provided that you give notice as soon as you can, you will not lose your right to take maternity leave. Returning from maternity leave (i) If you return to work at the end of your 52 week SML period, you need not formally notify us in advance of your return. (ii) You may wish to return to work before the end of your maternity leave period (MLP), but, if you choose to do so, you must give us 8 weeks advance warning of the date of your return. (iii) When returning to work after Ordinary Maternity Leave (the first 26 weeks of your statutory Maternity Leave), you have a right to return to the same job and the same terms and conditions as if you hadn’t been away. This also applies when you come back after additional Maternity Leave (the last 26 weeks of your Statutory Maternity Leave) but if it is not reasonable practical to return you to your original job (eg because it no longer exists) you do not have the same right. In that case you must be offered alternative work with terms and conditions as if you hadn’t been away.

Company Handbook (iv) If you decide not to return to work at the end of your MLP, you must notify your line manager at once in writing of your decision.

may, if you wish, receive pay in lieu, as long as you inform Human Resources within four weeks of your return to work.

Maternity Pay

Pension contributions

To qualify for SMP you must have been:

Your MLP will be treated as pensionable service and the company will therefore continue to make contributions on your behalf into the pension scheme based on the maternity pay you receive rather than your usual salary.

• Employed continuously for at least 26 weeks into the 15th week before the week your baby is due (the qualifying week) • Earning on average an amount which at least equals the lower earnings limit which applies on the Saturday at the end of your qualifying week The lower earnings limit is the amount you have to earn before you are treated as paying National Insurance contributions If you do not qualify for SMP, you may be entitled to claim maternity allowance. Your local Benefits Agency office will be able to advise you how to claim this. SMP is payable for a maximum of 39 weeks, for the first six weeks at 90% of your weekly earnings, followed by 33 weeks at either the statutory rate or at 90% of your weekly earnings, whichever is lower. You will be given a statement of your exact entitlement when you start your maternity leave. To claim SMP, you must give 28 days’ notice in writing of your absence on maternity grounds and you must give the original MAT B1 form, not a photocopy, to your line manager. You can only receive SMP once you have stopped work. Once you start your maternity leave, your maternity pay will be paid into your bank account on the same day that you would have received your salary, and will be subject to deductions for income tax and National Insurance. Contractual benefits You will continue to receive your contractual non remuneration benefits for the first 52 weeks of your MLP. Holidays While you are absent on ML, you will continue to accrue holiday entitlement in the usual way. You must take this additional holiday within 12 months of your return to work. Alternatively, you

Health and safety An employee should, at the earliest opportunity, discuss her pregnancy with her Line Manager or Human Resources Officer to enable Health and Safety to carry out a risk assessment and take account of any risks to the expectant mother and her unborn child in the workplace,. If you are employed in a job that has been identified as posing a risk to your health or that of your unborn child, you will be notified immediately and arrangements will be made to eliminate that risk. Employees will not be unreasonably requested by the Company to undertake work that would have taken place during the maternity leave period prior to departing on maternity leave. This will not, however, prevent employees from assisting in the planning of coverage of their work in advance of the maternity leave period. Paternity Leave Employees can choose to take either one or two consecutive weeks paid paternity leave (not odd days) if they: • Have or expect to have responsibility for the child’s upbringing or you are notified you are matched with your child • Are the biological father of the child or the other’s husband or partner and • Have worked continuously for the company for 26 weeks ending with the 15th week before the baby is due or the end of the week in which the birth is expected • Are the child’s adopter. Paternity leave must be completed: • Within 56 days of the actual date of birth or adoption of the child, or

Company Handbook • If the child is born early, within the period from the actual date of birth up to 56 days after the first day of the week in which the birth was expected. You must notify us in writing at least 15 weeks before the beginning of the week your baby is due or within 7 days of being matched with a child by an adoption agency. You must tell us whether you want one or two weeks OML and when you want it to start. Employees have the right to return to the same job after paternity leave. Most employees are entitled to Statutory Paternity Pay (SPP) from the company. The rate of SPP will be determined by Regulations. Employees may also qualify for Additional Paternity Leave. Find out what you are entitled to, by contacting the Human Resources office or view the www. direct.gov.uk website.

You will not qualify for Statutory Adoption Leave or Pay if you: • Arrange a private adoption • Become a special guardian • Adopt a stepchild • Have a child through surrogacy If you are adopting a child from overseas then different rules apply. Taking your adoption leave If you qualify, you have the right to 52 weeks of Statutory Adoption Leave. This is made up of 26 weeks of ordinary adoption leave followed by 26 weeks of additional adoption leave. You can start your leave either: • From the date the child starts living with you • Up to 14 days before the date you expect the child to start living with you Your leave can start on any day of the week.

To qualify for Statutory Adoption Leave, you must:

You need to tell your employer that you want to take Statutory Adoption Leave within seven days of being told that you have been matched with a child for adoption. If it is not possible to tell your employer within seven days, you must tell them as soon as possible.

• Be an employee

At the same time you must tell your employer:

• Be newly matched with a child by an adoption agency (‘matched’ means that the adoption agency gives you the details of the child they think is suitable for you to adopt)

• When you expect the child to be placed with you

• Have worked continuously for your current employer for at least 26 weeks before the beginning of the week when you are matched with a child

You can change your Statutory Adoption Leave start date so long as you give your employer at least 28 days’ notice.

The Company only recognises the statutory requirements for Paternity Leave and Pay. Adoption Leave and Pay

If you are adopting a child you are fostering, you must be matched for adoption by a recognised agency to be eligible for Statutory Adoption Leave or Pay. You must give your employer documentary proof to show that you have the right to paid Statutory Adoption Leave. This is usually a matching certificate from your adoption agency. The adoption agency must be recognised in the UK.

• When you want your Statutory Adoption Leave to start

Your employer should tell you within 28 days of receiving your notice, the date on which your Statutory Adoption Leave will end. This will be 52 weeks after it starts. You can return earlier than this as long as you give your employer eight weeks’ notice.

Company Handbook

CAPABILITY PROCEDURE You have a responsibility under your contract to perform to a satisfactory level. You will be given every help and encouragement to do so. However if your level of performance drops or becomes unsatisfactory the Company will address these concerns by following the Capability procedure. The purpose of this procedure is to ensure that the Company standards are maintained and to provide a fair and consistent method of dealing with any alleged failure to perform to the required standard. This procedure does not confer any contractual rights or obligations. The maintenance of good working practices does not necessarily require the use of formal procedures. In the majority of cases providing the right word, at the right time, in the right way is all that is required to remedy the situation, and therefore, informal counselling will often prove a more satisfactory method of dealing with failure to meet certain standards than the formal disciplinary procedure. The objective of any such action is to help the employee to improve. Any action taken under this procedure will be recorded and placed in the Company’s records. Issues arising under this procedure usually fall into two categories: Non-medical incapability – where you are medically fit but do not meet the required performance standards. Medical incapability – where you become unable to meet the required performance standards for medical reasons. Investigation No action will be taken before a proper investigation has been undertaken into the circumstances of your alleged poor performance. The purpose of the investigation is to consider any allegation that you are not performing to the required standard, whether the alleged shortcomings in your performance are due to non-medical or medical reasons and whether your performance is indicative of anything which is more properly dealt with under the Company disciplinary procedure. The investigation will usually be undertaken by your line manager who will look into all aspects

of your performance. You will be interviewed and advised of any shortcomings in your performance. You will be given an opportunity to reply and a note of your comments will be taken and retained. Wherever possible, the Company will take reasonable steps to keep any investigation confidential. However, you should be aware that confidentiality and anonymity are not and cannot be guaranteed. Time The Company will complete an investigation into any capability complaint and then hold any capability hearing within five working days of completing the investigation. Where this is not possible you will be kept informed of the state of the investigation. Capability hearings No capability warning will be imposed without a capability hearing. If the Company decide to hold a capability hearing, the Company will prepare a written statement setting out the matters to be discussed with you. The statement will identify the alleged characteristics or other matters giving rise to the capability hearing. It will identify the basis of the Company’s complaint and any supporting evidence the details of which will be supplied to you with the statement. The statement will be given or sent to you with an invitation to attend a capability hearing. You will be given 2 working days to consider your response to our statement of the matters to be discussed with you. The capability hearing will usually be chaired by a senior manager who may request the attendance of another member of the Company’s management team. The capability hearing will be in two parts. The first part of the hearing will be to determine whether you are not performing to the required standard and, if so, the reasons why. The second part of the hearing will be to decide what, if anything is to be done. Where there is a nonmedical incapability, the second part of the hearing will be to decide what, if anything, is to done. Where there is non-medical incapability, the second part of the hearing will follow part 3 of this procedure. Where there is a finding

Company Handbook of medical incapability, the second part of the hearing will follow part 4 of this procedure. If there is a disciplinary reason for your poor performance, the second part of the hearing will be conducted under part 5 of the company disciplinary procedure. You will be given an opportunity to state your case and to challenge the complaint and the company evidence. The Chairman of the hearing may decide the issue or adjourn the hearing for any reason. Where there is an adjournment, the Chairman will give the reason for the adjournment and fix a date and time for the hearing to resume. You will be informed in writing of the Chairman’s decision and of your right to appeal, within 5 working days of the hearing. Assistance In addition to counselling and warnings given under Parts 3 or 4, the Company will work with you to identify and help you overcome any shortcomings in your performance and may do so by agreeing remedial measures with you. These measures may include;– counselling – altering your working practices – training – advice and support – supervision – transferring you to other work These examples are not exhaustive or exclusive. Any scheme to help you overcome shortcomings in your performance will include a review date. The Company will make a written note of any discussion or scheme agreed with you. You will be provided with a copy of this note. A copy will be attached to your personnel file. Right to be accompanied You may wish to be accompanied at any stage in the capability procedure by a single companion of your choice who is either: (a) A fellow employee; or (b) A full time Officer of a Trade Union or a lay Trade Union Officer or work place representative provided that person has been certified by the Union as having experience of or training in acting as an employee’s companion at capability hearings.

A fellow employee who acts as your companion will be permitted reasonable paid time off for this purpose. A companion may address the Chairman, ask questions and be questioned. However, a companion will not be permitted to answer questions on your behalf. If you or your companion are unable to attend the capability hearing on the date proposed by the Company you may offer an alternative time and date which falls within five working days from the date originally proposed. The Company will consider reasonable requests for an alternative date. Appeals If you are dissatisfied with the outcome of any stage of the capability process you may appeal. Any appeal should be in writing and made within three working days to the meeting chairperson or HR Manager who will pass the matter up to an independent Director who will fix a time and date for the consideration of your appeal. Your appeal will be heard within a reasonable time of being lodged. Appeals will usually take the form of a re-hearing at which point you will have the right to be accompanied by a companion (see point 2.5 above.) On hearing your appeal the Director may: – confirm the original decision. – reverse the original decision. – change any course of action or time scale previously recommended. – reduce any steps taken under parts 3 or 4 of this policy. – increase any steps taken under parts 3 or 4 of this policy. The outcome of your appeal will be confirmed in writing within five working days of it being decided. Our decision on your appeal will be final. Disciplinary proceedings Failure to perform to any required standard may be a disciplinary, rather than a capability, issue. Any such cases will be dealt with under the Company disciplinary procedure. Procedures in cases of non medical incapability The following are examples of non-medical incapability:

Company Handbook – poor performance

– long term absence due to injury or sickness

– incompetence

– frequent short term absences due to minor ailments.

– unsuitability Where a capability hearing determines that you are not performing to the required standard and that the matter falls to be dealt with under this part of the procedure, the following steps will be taken: Stage 1 – Recorded counselling and first warning You will be given counselling about the standards required of you. A scheme of assistance may be agreed with you and a review date will be fixed. You will be warned that unless there is a satisfactory improvement in your performance your employment may be terminated. You will be advised of your right to appeal and a copy of the warning will be kept on your personnel file. Stage 2 – Final Warning A final warning may follow a single serious lapse in your performance but will usually only be given where you have not shown an acceptable improvement in your performance following recorded counselling and a first warning under stage 1 above. A scheme of assistance may be agreed with you and a review date will be fixed. You will be warned that unless there is a satisfactory improvement in your performance your employment will be terminated. You will be advised of your right to appeal and a copy of the warning will be kept on your personnel file. Stage 3 – Dismissal Dismissal may follow a single lapse in performance, but will usually only follow failure to show an acceptable improvement in your performance after recorded counselling and warnings under stages 1 and 2 above. Dismissal will be confirmed in writing stating the reason for dismissal, the date on which your employment will terminate and your entitlement if any to notice, pay in lieu and accrued holiday pay. This written confirmation will also advise you of your right of appeal. Part 4 – Procedures in cases of medical incapability Medical incapability may arise where you are unfit for work due to a physical or mental illness. The following are examples of medical incapability:

The following steps may be taken in any case under this part of the procedure: Step 1 – Monitoring All absences from work will be recorded and monitored. Step 2 – Medical examination The Company may require you to be examined by an independent medical practitioner of the Company’s choice. In this event, you agree to co-operate with such a request and to permit the medical practitioner to discuss with the Company the findings of the examination and the prognosis for your recovery. The findings of the medical practitioner will be taken into account when the Company consider the kind of action, if any, which we will take in respect of your absence from work. Step 3 – Further action The kind of action which the Company may take will be determined according to the circumstances of each case. This may include:– requiring you to undergo a further medical examination, the result of which we will take into account when the Company consider the kind of action, if any, which will be taken in respect of your absence. – giving you a warning or a series of warnings which may be verbal, first written or final written. Any warnings will identify a period over which your attendance will be monitored and a specified measure of improvement will be required of you and/or at the end of which you will be expected to have returned to work. Any such warning and its status will be confirmed in writing. – making changes to your working arrangements. – transferring you to other work. – Dismissal; the reason for dismissal and your right of appeal will be confirmed in writing. – make reasonable adjustments. Part 5 – Currency of warnings Subject to satisfactory performance, any formal warning given under Parts 3 and 4 of this procedure will be removed from our records after one year.

Company Handbook

DISCIPLINARY PROCEDURE The Company believes that clear, open and fair procedures for the resolution of problems are necessary both for the success of the Company and for the fair treatment of our employees. Any grievance or complaint can be discussed informally, or through the formal grievance procedure. Often raising issues promptly at the time in a sensible way helps to solve them and prevent further difficulties. This procedure may not be relevant within your first year of employment. Investigation Before any formal disciplinary action is taken, the relevant person will carry out a full investigation to establish the facts. The investigation will normally include a meeting with you. Before any meeting, you will be: – told in writing of the allegations/complaints against you, and the basis of those allegations; – given a reasonable opportunity to consider your response to that information; and, – offered the opportunity to be accompanied by a work colleague or a trade union representative You must take all reasonable steps to attend the meeting. At the meeting, you will be given a full opportunity to comment on the allegations, to put forward any defence or arguments you want, and to comment on what disciplinary sanction (if any) is appropriate. The Company reserves the right to suspend individuals for as short a period as possible during formal disciplinary action. Any suspension will be on a paid basis and does not mean that the issue has been prejudged. Informal Verbal Warning After establishing the facts, it may be considered that there is no need to resort to the formal procedure, and that it is sufficient to talk the matter over with you. A note of the informal warning may be kept on your personnel file; however, they are there for background and

would not normally be taken into account in the event of subsequent disciplinary procedures. The purpose of an informal warning is to provide an opportunity for improvement or for the matter to be corrected without the necessity for formal disciplinary procedures to be instigated. FORMAL DISCIPLINARY PROCESS Right to be accompanied You have the right to be accompanied at any investigation or disciplinary hearing by a single companion who is either: a work colleague; or, a trade union representative. Your representative has the right to explain and sum up your case, and to respond to any views expressed at the hearing. They may not answer questions on your behalf. If your representative cannot attend on the date set for the interview, the interview will be postponed for up to five days and may (at our discretion) be postponed for longer. Stage 1: Formal Verbal Warning A record will be kept of the fact that a verbal warning has been given. You will be advised that it is a ‘formal’ verbal warning. You will be informed of the steps, which must be taken to improve your conduct and, where appropriate, a time limit for improvement. It will be made clear that any further misconduct will result in further disciplinary action being taken. You will also be informed of your right of appeal. A note will be made of the verbal warning and the period after which it will expire (normally six months). This note will be placed on your personnel file. If conduct is sufficiently serious, stage 1 may be omitted and the Company may proceed straight to stage 2. Stage 2: Written Warning Where the matter is of a more serious nature, or where you have failed to meet the required standards after having received a formal verbal warning, you may be given a written warning.

Company Handbook This will state the nature of the complaint, the required standards that must be met and, where appropriate, a time limit for improvement. It will also state that further disciplinary action will follow if the required standards are not met or if there is further misconduct. You will be informed of your right of appeal, and how and where this should be made. A record of the warning and related discussions will then be placed on your personnel file. It will normally cease to have effect after 12 months. If conduct is sufficiently serious, stage 1 and stage 2 may be omitted and the Company may proceed straight to stage 3. Stage 3: Final Written Warning For more serious matters, or where you have failed to meet the required standards after being warned, you may be given a Final Written Warning. This will state the nature of the complaint, the required standards that must be met and, where appropriate, a time limit for improvement. It will also state that you will be dismissed if the standards are not met or if there is further misconduct. Again, you have the right to appeal. A record of the warning and a note of all related discussions will be placed on your personnel file. Again, a final written warning will normally cease to have effect after 12 months. Stage 4: Dismissal Where there has been gross misconduct (in which case, stages 1, 2 and 3 may be omitted) or where you have failed to meet the required standards after due warnings have been given, you may be dismissed. In extenuating circumstances we may apply another sanction such as disciplinary transfer, disciplinary suspension without pay or demotion. This will be confirmed in writing and will include details of the appeals procedure. In cases of gross misconduct, the dismissal will normally be without notice (or pay in lieu of notice).

Dismissal without Notice (‘Summary Dismissal’) The Company regards certain issues as serious enough to warrant ‘summary dismissal’ without prior warning. Matters that justify summary dismissal, include, but are not limited to: • Acts of dishonesty where your conduct affects your ability or suitability for continued employment with us; for example, theft, fraud or the deliberate falsification of records or expenses. • Serious insubordination or rudeness to customers or suppliers; • Deliberate damage to property; • A serious breach of Health & Safety policies; • physical violence or aggressive behaviour; • Indecent or immoral acts; • Being under the influence of, or possessing, alcohol or illegal drugs during employment hours; • Bringing the company into serious disrepute; • Any breaches of confidentiality requirements in your contract of employment, other than minor breaches. • Harassment or bullying, other than minor breaches. Except in the most serious cases of gross misconduct (see below), a full investigation will be held and, if necessary, you will be suspended pending the outcome of the investigation. In the event of gross misconduct, disciplinary action could take the form of a demotion, or a downgrading, with subsequent financial loss as well as loss of status, rather than a dismissal. This decision will be taken at our discretion. Other Disciplinary Matters Matters which may justify invoking the disciplinary procedure but which do not amount to gross misconduct include, but are not limited to, the following: • Refusal to obey a legitimate instruction; • Refusal to answer a question during the course of a properly constituted investigation; • Absence without permission, or persistent absence; • Poor timekeeping;

Company Handbook • Failure to report damage to our property;

RIGHT TO APPEAL

• Failure to carry out your duties adequately;

If you are not satisfied with a disciplinary decision, you may appeal, in writing, within five working days. Arrangements to hear the appeal will normally be made within five working days of receiving your written request. If the decision you are appealing against was a decision to dismiss you, the appeal may be heard after the dismissal has taken place.

• Breach of our policies and practices; • Continued poor work performance, or a persistent failure to keep up-to-date with technical developments; • Improper use of our equipment; • Harassment or bullying (not deemed serious enough for gross misconduct); • Actions bringing the Company into disrepute (not deemed serious enough for gross misconduct). What you can expect during the Disciplinary Process At each stage of the disciplinary process: • You will be told of the expected standard of performance of performance/behaviour, and the nature of the shortfall in expected standards will be identified; • You will be given the opportunity to reply to any allegations made against you, and to outline any mitigating circumstances you wish to be considered; • All the facts will then be considered. Occasionally you may be asked back for a further interview; • You will be told of the disciplinary sanction being imposed (although this may be done in writing). This will include details of any timescale within which improvement is to be achieved and the likely consequences if there is no improvement; and, • You will be advised of the right to appeal. Serious Gross Misconduct In the most serious cases of gross misconduct, for example where you are discovered in the process of a serious act of dishonesty, it is possible that you will be dismissed immediately without going through a formal suspension and investigative procedure.

All appeals must set out the grounds on which you are making the appeal. You will be invited to an appeal hearing, and you will be reminded of your right to be accompanied. The appeal hearing will reconsider the original decision. You will have an opportunity to put forward, should you wish to do so: (a) New evidence, which was not available during the first hearing; and/or, (b) Complaints of a flaw in the original decisionmaking process, such as a failure to follow procedures or a failure to give you a fair hearing. However, if there was no meeting before the disciplinary decision was first taken, then the appeal will be a full hearing of the matters in question. The outcome of the appeal will be confirmed to you in writing and will take one of three forms: (a) The original decision will be upheld, in which case any disciplinary sanction will be confirmed (b) The original decision will be overruled, in which case any disciplinary sanction will be rescinded (c) The original decision will be substantially confirmed but a less severe sanction will be substituted for that originally imposed (usually in cases of appeals based on extenuating circumstances). There is no further right of appeal.

If that happens, you will be written to within seven days, setting out the misconduct which led to your dismissal and what the basis was for the Company’s decision. You then have the right to appeal (see below).

Company Handbook

GRIEVANCE PROCEDURE If there is any matter relating to your work, or the people with whom you work, with which you are unhappy, you should use the following grievance procedure. At any formal meeting, you have the right to be accompanied by a single companion who is either: a) A work colleague; or, b) Trade union representative. Your representative has the right to explain and sum up your case, and to respond to any views expressed at the hearing. They may not answer questions on your behalf. If your representative cannot attend on the date we have set for the interview, we will always postpone the interview for up to five days and may (at our discretion) postpone it for longer. Stage 1 Discuss the matter informally with your manager. They may be able to resolve the matter to your satisfaction. Stage 2 Write to us setting out your grievance in full (please include copies of any relevant documents). We will invite you to a meeting to discuss the grievance, and will try to resolve matters to your satisfaction. It may be necessary for us to make enquiries with other people about your grievance, and possibly to have a second meeting with you. After the meeting, we will write to you with the outcome of your grievance. The letter will include a reminder of your right to appeal if you are not satisfied with the outcome.

Stage 3 If you wish to appeal, you should write to us within one week of receiving the stage 2 decisions. Your appeal letter should set out the reasons for your appeal. We will invite you to attend an appeal meeting with a more senior manager, when your grievance and your reasons for appealing will be discussed further. After the meeting, we will write to you with our final decision. There is no further appeal from this decision. After termination of employment If you wish to lodge a grievance after your employment has ended, we can either go through stages 2 and 3 above, or we can agree to deal with matters on the basis of a written grievance and response (without a meeting). We can discuss which option is easiest at the time. If you believe that you are being sexually or racially harassed or the victim of some other form of harassment or unlawful discrimination, you should report any incident(s) as per the AntiHarassment Policy which is on the Staff Notice Broad to the Human Resources Department who will investigate. Your report will be treated as confidential unless you agree otherwise.

Company Handbook

TERMINATION OF EMPLOYMENT Notice

Redundancy

If you wish to resign from the Company you must give your required contractual notice in writing to your Line Manager.

If the Company makes a position (s) redundant it will comply with all statutory obligations in terms of consultation and redundancy pay as detailed by employment legislation at the time. It will explore alternatives to limit job losses and will listen to employee’s suggestions during the consultation period.

Continuous employment Notice entitlement 1 to 11 years 12 years or more

1 week for each year 12 weeks

Office staff and key workers will be contracted to a monthly notice period relevant to their role as per their principal statement.

It will ensure fair, consistent and sympathetic process is applied in the selection of employees for redundancy.

Restrictive Covenants

Retirement

Should there be restrictive covenants within your contract you must remember to comply with these as the restrictions apply for a period following the termination of employment.

You are entitled to work beyond 65. If you wish to retire at 65 then please arrange a meeting with your H/R adviser.

Failure to do so could lead to legal action being taken against you.

HEALTH AND SAFETY AT WORK POLICY General Statement

Communication

Pepper Communications Limited is a responsible employer and takes its Health and Safety responsibilities seriously. For this reason we have formulated this policy to help us comply with our legal obligations to staff and visitors. It is the policy of the Company to safeguard the health, safety and welfare at work of all employees by means reasonably practicable and to progressively improve its health and safety performance.

The company will review this policy at least annually, revise it as often as is appropriate, and will keep staff informed of any changes that are made. Appropriate financial and physical resources will be provided to implement this policy.

Employees’ duties All employees have a duty to take reasonable steps to ensure that they do not place themselves or others at risk of harm. They are also expected to co-operate fully with us in complying with any procedures that we may introduce as a measure to protect the safety and well-being of our staff and visitors.

Policy • Safety Representatives have been appointed to carry out regular inspections in line with the Health and Safety Act. • The Company will carry out suitable and sufficient assessments to identify significant risks to the health and safety of its employees to which they are exposed whilst at work and to carry out preventative and protective measures to eliminate or reduce risk. This also applies to customers, visitors and contractors. • The Company will ensure that all employees are trained in health and safety matters relating to their workplace and provide information appropriate to their requirements.

Company Handbook • All Managers will ensure that health and safety regulations are adhered to at all times by their employees and correctly delegate responsibilities in their absence. • Individual employees have an obligation to accustom themselves with the Company Health and Safety Policy, to observe its regulations and co-operate in its implementation. • Expert advice will be obtained where necessary to determine the risks to health and safety within the establishment and the precautions required. • Duties and responsibilities for matters of health and safety are set out in our company handbook. A statement of the Company Policy regarding Health And Safety At Work The statement makes it clear that the company takes your health and safety seriously and will provide safe working conditions and adequate information and training etc. Although directors and managers of the company have prime responsibility for health and safety, the company realises that a healthy and accident free workplace cannot be achieved without the cooperation and active support of its employees. The company therefore has arrangements for consultation and for keeping you informed about matters of health and safety. Safe working is not optional: it is a condition of your employment that you will comply with safety signs, instructions and procedures. The organisation that exists for implementing the Health And Safety Policy

The financial cost of work related accidents and ill-health to victims, to us as an organisation and to society in general can be very significant. As a company and as individuals, we also have duties under a comprehensive range of health and safety laws. These laws require us to manage our activities so as to anticipate and prevent situation that might result in occupational injury or ill health. It is therefore in our best interests as an organisation and as individual employees to do what we can to achieve good health and safety performance. Good health and safety performance does not happen by chance. As with all of our business objectives, it has to be managed using a structured approach. Our health and safety management system identifies the structure. It is in three main parts as shown on next page. OUR POLICY (STATEMENT OF INTENT) What we intend to do This is a statement of our commitment to health and Safety. It sets the direction that the company and our employees will follow OUR ORGANISATION FOR IMPLEMENTING THE POLICY Who is responsible for ensuring that it is done? This states the general responsibilities of individuals and groups of individuals regarding health and Safety OUR ARRANGEMENTS FOR IMPLEMENTING THE POLICY How it gets done

The general health and safety responsibilities of key individuals and groups of employees are detailed in this section. You should make sure that you are aware of your own responsibilities. Additional specific duties may be delegated to you depending upon your job.

These are the procedures that exist for dealing with specific aspects of the management systems and for controlling specific risks

Why a Health And Safety Management System is important to us

We all have legal responsibilities for health and safety while we are at work. It is important that we are all aware of these responsibilities and that we work together to achieve a high standard of safety.

Injuries and ill-health from work activities can be a major cause of pain and suffering to the victims and their families and friends. As an employer we have a moral duty to do all that we reasonably can to prevent this.

Organisation Responsibilities General Responsibilities for Health And Safety

It is also important that all personnel know the lines of communication and levels of responsibility that exist to ensure that safety matters are dealt with efficiently.

Company Handbook Management Responsibilities

Employee Responsibilities

Responsibility for safety ultimately rests with the highest level of management.

All our employees have general duties under section 7 and 8 of the health and safety at work act. Act 1974 and other legal legislation.

The following section identifies: • The responsibility that we all have as employees, and • Those individuals with particular safety responsibilities Individuals who have been allocated specific health and safety responsibilities within our policy have been provided with individual folders detailing these responsibilities. In addition to monitoring their own areas of control, they are also required to monitor the performance and activities of subordinates to ensure acceptable standards are maintained. The individual’s responsibilities for health and safety should be read in conjunction with the relevant monitoring procedures that have been prepared to assist individuals in reviewing the success of measure taken.

We ALL have the legal responsibility: • To take reasonable care of our own safety and the safety of other persons who may be affected by what we do or fail to do at work. • To co-operate with each other so as to enable compliance with any imposed legal duty or requirement • Not to interfere with or misuse, intentionally or recklessly, anything provided in the interests of safety • To report hazardous shortcomings in health and safety arrangements. Family Members No children or family members are permitted on site, if a family member collects you from work, they must wait for you in the car until you are ready to leave work. No children under the age of 16 are permitted on site without prior authorisation from your manager.

HEALTH AND SAFETY RULES Introduction The following sections specify health and safety rules covering the main areas of our working environment. If you read, understand and follow the rules you will be helping to comply with your legal duty and will be contributing to the safe running of your workplace. It is not possible to have written for every aspect of health and safety at work and you should also work in accordance with the training that you have been given and follow instructions given by your line manager. In addition to the health and safety rules contained within this handbook, you should also refer to our safe working procedure manual which contains further information relating to workplace precautions to be followed.

If you do not understand what is expected of you or if you are unsure about our safety rules or safe working procedure, speak to your line manager as soon as possible. First Aid Pepper Communications Limited recognises its duty to ensure that every employee has reasonably quick access to first aid whilst at work To this end, the company will arrange for adequate number of persons to be trained in first aid: will provide appropriate first aid equipment and will inform employees of the arrangement for first aid. Our first aid boxes are sited in the following locations: Kitchen, Prepress, Print Factory, Mailing Factory. A list of all First Aiders and Emergency trained staff that have been appointed and trained is posted on the notice boards.

Company Handbook Accident Reporting It is the policy of the Company to record and investigate all accidents that result in injury or ill health. It is also our policy to record and investigate all accidents that might potentially have resulted in injury, ill health or damage to property, plant or equipment. All employees are required to co-operate in ensuring that the following procedures are adhered to: Reporting Injuries • If you are injured, you must initially report to a first aider (even if no treatment is necessary). Lists of first aiders are displayed at prominent positions in the workplace. You must provide the first aider with the information about yourself and about the circumstances of the accident. • In cases where it is recommended that you are sent for immediate hospital attendance, it is the responsibility of the first aider to ensure that your line manager is informed. In all other cases, where the injured person is sent home or returns to work, they must report to their line manager before doing so. • All injuries must be recorded, as soon as possible, in the accident book either by the inured person or by a responsible person on their behalf (preferably the First Aider) • A responsible person (preferably the First Aider) will ensure that an Injury Report (Form 1) is completed for every work-related injury that requires treatment. • A responsible person will ensure that a report and notification if made to the enforcing authority where required under the RIDDOR Regulations 1995 within the required time frame. • A full investigation will then be made by the Line Manager of the Department or section in which the accident occurred and an Accident Investigation Report (Form 2) will be completed. Reporting Near Miss Incidents • All near miss incidents must be reported immediately to your line manager. A near miss incident is defined as • Any unplanned event that resulted in damage to property

• Any unplanned event that might potentially have caused injury to yourself or others, or damage to property • A responsible person will complete a NearMiss Incident Report (Form 1A) for every incident in which there was damage to property, plant or equipment, or where there was clear potential for injury • A responsible person will ensure that a report and notification is made to the enforcing authority where required under the RIDDOR regulations 1995 within the required time frame.. • The line manager of the department or section in which the near miss incident occurred will carry out a full investigation and complete an Accident Investigation Report (Form 2 ) as soon as circumstances permit. Consultation The company acknowledge the importance of employee involvement in health and safety matters. The company will consult directly with employees on relevant health and safety matters, such as: • The introduction of any measure that will affect the health and safety of employees • The arrangements for appointing or nominating persons to assist us in complying with relevant legislation, and to assist in emergency procedures • The provision of relevant information as required under health and safety legislation • The planning and organisation of any relevant training required to be provided to employees under health and safety legislation • The health and safety consequences of introducing new technologies in the workplace It is the intention of the company to positively encourage the involvement of employees in such matters and to provide any facilities and assistance that might reasonably be required in order for this involvement to be effective. Methods of Consultation The company undertakes to consult directly with you and other employees on relevant health and safety matters.

Company Handbook Consultation will involve meetings between designated members of the management team together with all employees where such a meeting is appropriate and reasonably practicable. Where it is not reasonably practicable to consult with all employees at a single event, it will be necessary to arrange additional meetings.

Consultation events will be arranged as and when necessary for the consultation to be “in good time”, in respect of any of the matters for which consultation is relevant “in good time” means that consultation will take place sufficiently in advance of any relevant changes so that your views and input, if appropriate, be taken into account by the management team.

Frequency of Consultation

Raising Concerns About Health And Safety

The timing and frequency of consultation of events will depend on the nature of the matters about which the consultation relates.

Should you have any concerns regarding your health or safety at work, you are encouraged to report them to your line manager.

EVACUATION AND FIRE – POLICY AND PROCEDURE General Statement Pepper Communications Limited is a responsible employer and takes its fire safety duties seriously. For this reason we have formulated this policy to help us comply with our legal obligations to staff and visitors. These include the provision of a safe place of work where fire safety risks are minimised. Employees’ duties All employees have a duty to take reasonable steps to ensure that they do not place themselves or others at risk of harm. They are also expected to co-operate fully with us in complying with any procedures that we may introduce as a measure to protect the safety and well-being of our staff and visitors. Communication We will keep staff informed of any changes that are made to our fire safety procedures and fire risk assessment. We will also ensure that all visitors to our premises are briefed in the evacuation procedures and not left alone unless they are aware of, and familiar with, all available escape routes. Procedures We have introduced the following procedures in order to maintain high standards of fire safety • A fire risk assessment has been undertaken which will be reviewed annually. However, more frequent reviews will occur if there are changes that will impact on its effectiveness. These may include alterations to the premises or new work processes.

• The fire evacuation procedures will be practiced every 6 months. • Training will be provided as necessary to any staff given extra fire safety responsibilities, such as fire Marshalls. • Where possible responsible persons will be trained in the use of fire extinguishers • All new members of staff and temporary employees will be provided with induction training on how to raise the alarm and the available escape routes • All escape routes will be clearly signed and must be kept free from obstructions at all times • The fire alarm is a siren. When activated, all staff should leave the building immediately by the nearest exit. Do not stop to collect anything. • All fire-related equipment will be regularly serviced and maintained. If any employee notices defective or missing equipment, they must report it to a manager • Alarm systems will be tested regularly. This takes place on Friday mornings between 9.30 and 11 am • Any other safety systems will be checked regularly to ensure correct operation, where necessary, e.g. emergency lighting • This policy forms part of employees’ conditions of employment. Failure to comply may be treated as a disciplinary matter.

Company Handbook FIRE PREVENTION The company recognises the risk to which employees and others on our premises may be exposed in the event of fire; the risks can be reduced if you adopt the following precautions: Employees must ensure that they adhere to the following guidelines to reduce the risk of fire by: • Not bringing unnecessary potential sources of ignition into the workplace • Switch off all electrical equipment when leaving the office • Ensure that there are no trailing wires which can cause accidents or short circuits if suddenly pulled from their sockets • Use any heat/producing equipment as instructed • Not overloading electrical or mechanical equipment • Not smoking • Reducing flammable materials in the work room to a minimum required for the job (enough for half a shift/half a day) • Storing flammable materials in suitable cabinets or in separate fire resisting stores where appropriate • Keeping highly flammable substances in closed containers in suitable fire resisting cabinets, where it is necessary to store them in the work room • Ensuring adequate separation distance between flammable materials and any source of ignition (motors, heaters, lights etc) • Ensuring that flammable materials (liquids, gasses and solids) are stored, transported handled and used properly • Storing any oxidising materials well away from heat sources or flammable materials In the event of a fire starting (especially when the premises are unoccupied) you can help to prevent it from spreading by: • Closing doors and windows not required for ventilation • Not wedging open any self closing doors

You can help to ensure that people are able to escape in the event of a fire by: • Familiarising yourself with the fire alarm and evacuation procedures • Keeping fire exits routes clear • Keeping fire extinguishers and alarm points unobstructed Fire safety instructions for the company If you discover a fire 1. Sound the nearest Fire alarm immediately 2. Dial 999 to call the Fire Brigade 3. When the Fire Brigade replies, say distinctly:– “Fire at Pepper Communications Limited, Beechwood Way, Langage Science Park, Plymouth PL7 5HH 4. Attack the fire, if possible, with appliances provided but without taking personal risks. On Hearing the Fire Alarm 5. Immediately vacate the premises by the nearest available exit and proceed to the assembly point at:– Front Carpark 6. Close but do not lock all windows and doors behind you, do not stop to collect personal belongings, do not re-enter the building. Fire Marshalls/Managers Responsibilities Fire Marshalls and Managers have additional responsibilities in the event of a fire. All Fire Marshalls and Managers are aware of their duties and all staff must do as instructed by them in the event of an evacuation On hearing the alarm staff within your section under your responsibility will start to evacuate, if you see a disabled person in difficulty you should give assistance to leave the building. You will need to be extra vigilant to ensure staff follow instructions AND leave by the nearest exit. You should spend no longer than it is safe to do so carrying out a physical check (sweep) of your allotted area. Any area that is smoked logged should not be checked, but the location of the smoke logged area should be passed onto Fire Brigade. An office based Manager/Fire Marshall will bring the roll call register and visitor book to the fire assembly point. They will put on the high

Company Handbook visibility jacket to show they are in charge and run a roll call of the office staff. They will then report immediately to the Duty Fire Marshall/ Manager from the factory. Visitors/out of hours All staff who enter the building or stay on after 6.00pm have to ensure that the duty Fire Marshall/Manager is aware when you arrive and leave site so they have an up to date accurate account of ALL staff on the premises at all times. Anyone who returns to site MUST on their arrival report to the duty Fire Marshall/Manager (this includes everyone).

Fire extinguishers There are 5 main types of extinguisher detailed below, but not all of them may be provided in every building. You will only have extinguishers that are relevant to the type of fire risk present. Different types of extinguisher should be used for different types of fire and it is important that only the correct type is used. Symbols found on fire extinguishers and what they mean

All visitors must also be accounted for and the duty Fire Marshall/Manager will be responsible for checking the visitor’s book. Evacuation procedure An alarm will sound throughout the Company’s premises where an immediate evacuation of the building is necessary. Practice evacuation drills will be organised periodically by the Company so as to familiarise employees with the sound of the alarm and the evacuation procedures. Employees must never, however, assume that an alarm signals a drill only. Where an evacuation is necessary employees must:

Fire Marshall Function

• Leave the building immediately, but in an orderly manner, by the nearest available exit;

1) Help manage the fire safety arrangements within your area and report any deficiencies.

• Ensure any visitors leave the building;

2) Assist Managers to ensure staff and visitors know and understand the fire safety arrangements; part of your involvement is to ensure staff are so familiar with the procedures that it becomes second nature.

• Do not run; • Do not collect personal belongings • Gather at the assembly points and ensure you answer the roll call; • Do not return to the building until the all clear has been given and until instructed by a Fire Marshall/Manager Do not attempt to tackle a fire unless you have been trained to do so. If you do decide it is safe or necessary to actually fight a fire – do not take personal risks.. Even a small fire has the potential to generate large volumes of smoke and it is not Company policy for you to fight a fire, which could put lives at risk.

The main activities of a Fire Marshall are:

3) Help to manage and implement the Emergency evacuation procedures including those for any mobility impaired persons in your area. 4) Keep up to date with any changes in the procedures. 5) Review and update the effectiveness of the procedures by participating in regular testing and training. 6) Assist with any fire risk assessment process.

Company Handbook

HOUSEKEEPING The company recognises that poor housekeeping is one of the most common causes of accidents in the workplace. Please report all house keeping issues immediately. The risk of accidents and injuries can be reduced if you adopt the following precautions: • Check that your workplace is free from hazards at the beginning of each day • Put items away immediately after use • Clear up any spillages, etc. immediately • Do not place objects in, or allow them to protrude into walkways • Do not obstruct access to fire alarm, extinguishers or other emergency equipment • Do not obstruct access to electrical switches or panels • Ensure that waste materials are deposited in containers provided • Do not store articles or substances anywhere other than in designated storage areas • Ensure the workplace is tidy and that articles and substances have been put away at the end of each day / shift Maintenance Operations The company recognises that maintenance operations can present a serious health and safety hazard to those undertaking maintenance operations and to others in the vicinity. The risk of accidents and injuries can be reduced if you adopt the following precautions: • Ensure you are properly trained for the job • Do not try anything that you are not competent to do • Keep to planned work methods • Avoid using unauthorised work methods – they may create unforeseen risks

New plant, equipment and substances The company recognises that the introduction of new plant, equipment and substances may introduce new risks to the health and safety of employees. The risk of accidents and injuries can be reduced if you adopt the following precautions: • Do not bring equipment or substances onto the company premises unless authorised • Always read the data sheet, container labels and detailed health and safety information before using any new substance • Ensure you have been adequately trained in the correct use of new plant and equipment before you use it • Ensure you have been adequately trained in the correct use, handling disposal and storage of new substances. Manual Handling The Manual Handling Regulations require employers to: • Avoid the need for hazardous manual handling, so far as is reasonably practicable; • Assess the risk of injury from any hazardous manual handling that can’t be avoided; and • Reduce the risk of injury from hazardous manual handling, so far as is reasonably practicable. Employees have duties too. They should: • Follow appropriate systems of work laid down for their safety; • Make proper use of equipment provided for their safety; • Co-operate with their employer on health and safety matters;

• Find out if a permit to work is required

• Inform the employer if they identify hazardous handling activities;

• Ensure that machinery is securely isolated from all sources of energy

• Take care to ensure that their activities do not put others at risk.

• Use suitable personal protective equipment • Report any fault or hazard that you find

Company Handbook

lifting Good handling technique for lifting

• Don’t flex the back any further while lifting.

• Think before lifting/handling. Plan the lift. Can handling aids be used? Where is the load going to be placed? Will help be needed with the load? Remove obstructions such as discarded wrapping materials. For a long lift, consider resting the load midway on a table or bench to change grip.

This can happen if the legs begin to straighten before starting to raise the load.

• Avoid twisting the back or leaning sideways, especially while the back is bent. Shoulders should be kept level and facing in the same direction as the hips. Turning by moving the feet is better than twisting and lifting at the same time. • Keep the head up when handling. Look ahead, not down at the load, once it has been held securely. • Move smoothly. The load should not be jerked or snatched as this can make it harder to keep control and can increase the risk of injury. • Keep the load close to the waist. Keep the load close to the body for as long as possible while lifting. Keep the heaviest side of the load next to the body. If a close approach to the load is not possible, try to slide it towards the body before attempting to lift it. • Adopt a stable position. The feet should be apart with one leg slightly forward to maintain balance (alongside the load, if it is on the ground). The worker should be prepared to move their feet during the lift to maintain their stability. Avoid tight clothing or unsuitable footwear, which may make this difficult. • Get a good hold. Where possible the load should be hugged as close as possible to the body. This may be better than gripping it tightly with hands only. • Start in a good posture. At the start of the lift, slight bending of the back, hips and knees is preferable to fully flexing the back (stooping) or fully flexing the hips and knees (squatting).

• Don’t lift or handle more than can be easily managed. There is a difference between what people can lift and what they can safely lift. If in doubt, seek advice or get help. • Put down, and then adjust. If precise positioning of the load is necessary, put it down first, and then slide it into the desired position. Good handling technique for pushing and pulling Here are some practical points to remember when loads are pushed or pulled. • Handling devices. Aids such as pallet trucks and trolleys should have handle heights that are between the shoulder and waist. Devices should be well maintained with wheels that run smoothly (the law requires that equipment is maintained). When purchasing new trolleys etc, ensure they are of good quality with large diameter wheels made of suitable material and with castors, bearings etc which will last with minimum maintenance. Consultation with your employees and safety representatives will help, as they know what works and what doesn’t. Pull or push pallet trucks and trolleys please do not ride on these devices.

Company Handbook • Force. As a rough guide the amount of force that needs to be applied to move a load over a flat, level surface using a well-maintained handling aid is at least 2% of the load weight. For example, if the load weight is 400 kg, then the force needed to move the load is 8 kg. The force needed will be larger, perhaps a lot larger, if conditions are not perfect (eg wheels not in the right position or a device that is poorly maintained). The operator should try to push rather than pull when moving a load, provided they can see over it and control steering and stopping. • Slopes. Employees should enlist help from another worker whenever necessary if they have to negotiate a slope or ramp, as pushing and pulling forces can be very high. For example, if a load of 400 kg is moved up a slope of 1 in 12 (about 5o), the required force is over 30 kg even in ideal conditions good wheels and a smooth slope. This is above the guideline weight for men and well above the guideline weight for women. • Uneven surfaces. Moving an object over soft or uneven surfaces requires higher forces. On an uneven surface, the force needed to start the load moving could increase to 10% of the load weight, although this might be offset to some extent by using larger wheels. Soft ground may be even worse. • Stance and pace. To make it easier to push or pull, employees should keep their feet well away from the load and go no faster than walking speed. This will stop them becoming too tired too quickly. General Guidelines Women

Knuckle height

Mid lower leg height

5kg

20kg

10kg

25kg

15kg

3kg

7kg

13kg

10kg

16kg

7kg

13kg

20kg

10kg

3kg

7kg

10kg

5kg

Shoulder height Elbow height

Men 10kg

Shoulder height Elbow height

The company recognises that non-routine work, such as maintenance, cleaning, equipment installation and refurbishment can produce health and safety risks over and above those normally encountered in the workplace. To reduce these risks to the lowest level that is reasonably practicable, the company operates a Permit to Work System Permits to Work are formal written procedures designed to check that all eventualities have been considered when planning and organising non-routine activities, and are an important means of minimising any risks involved. Risk Assessments The company recognises that some of our working operations may, unless properly controlled, create risks to employees and others. `Risk assessments will be undertaken of the risk associated with our workplace and working operations Information will be provided to you about any risks to which you might be exposed, and the precautions that should be taken to avoid harm If you discover a hazard during working operations you should report the hazard to you line manager so that remedial action can be taken (PPE) Personal Protective Equipment What is PPE? PPE is all equipment which is intended to be worn or held by a person at work and which protects him against one or more risks to his health or safety’, eg safety helmets, gloves, eye protection, high visibility clothing, safety footwear and safety harnesses. – Safety Shoes

Knuckle height

– are to be worn at all time whilst on the factory floor.

Mid lower leg height

– Ear Caps and Ear plugs are available and staff are advised to wear them

Each box contains a guideline weight for lifting and lowering in that zone. As you can see, the guideline weights are reduced if handling is done with arms extended, or at high or low levels, as that is where injuries are most likely to occur.

Permit to Work

– Safety Glasses – these must be worn for your own protection whilst dealing with chemicals – the Company would not be liable for any injuries suffered if not worn as instructed. Goggles are also kept in the Personal Protective Equipment storeroom.

Company Handbook – Disposal rubber gloves are kept for your use when dealing with chemicals – again in the Personal Protective Equipment storeroom.

Safety signs and notices PROHIBITION (MUST NOT)

– Ear Defenders – MUST be worn at all times on entering the Compressor Room. – Masks are kept by each Printing Machine at the control end, in the Plate-room and also in the Personal Protective Equipment Storeroom and MUST be worn whilst dealing with chemicals. – Wipes are provided – again in storeroom. You are responsible for keeping your uniform clean and in good repair. If you lose or damage any items you may be liable for the cost of replacing them.

A sign prohibiting behaviour likely to increase or cause danger A ROUND SIGN WITH A WHITE BACKGROUND AND A RED BORDER AND DIAGONAL CROSS BAR. WARNING

On leaving the Company you will be required to return all PPE that you have been issued. Should you leave within 6 months of joining the Company the cost of your uniform will be deducted from any outstanding monies. Chemical Handling Various chemicals are used within the business for which COSHH data sheets are available in the first aid room and main office area. Only trained personnel may handle chemicals ensuring the correct protective clothing is used at all times and good ventilation is available.

A sign giving a warning of a hazard or danger TRIANGULAR WITH A YELLOW BACKGROUND, BLACK BORDER AND BLACK SYMBOL. MANDATORY (MUST BE DONE/WORN)

There are various spill kits located around the premises and if a spillage happens the spill kit absorbent pads and sand must be used to absorb the product. Under no circumstances can chemicals be washed down the drain or allowed to enter the natural water courses or sewers.

A sign prescribing specific behaviour ROUND WITH A BLUE BACKGROUND AND WHITE SYMBOL EMERGENCY ESCAPE OR FIRST AID SIGN

Waste must be treated as hazardous and removed by a specialist. All chemical spills must be dealt with by trained personnel and reported to the Departmental Manager Chemicals must be stored in specific chemical storage areas only. A sign giving information on emergency exits, first aid or rescue facilities (e.g. emergency escape route). SQUARE OR OBLONG WITH WHITE SYMBOLS ON A GREEN BACKGROUND

Company Handbook Training The company recognises that the adequate knowledge and skills are an essential element of safe working. The company will therefore ensure that all new employees (including temporary staff) complete an appropriate programme of health and safety induction training at the earliest reasonable opportunity. All employees will be provided with appropriate additional health and safety related training before they are exposed to new risks as a result of:

• Visitors must be advised of the risks to which they may be exposed whilst on site and the precautions they should take, including emergency arrangements and the location of the assembly points. • Visitors are required to make full use of any personal protective equipment that is necessary to secure their health and safety. • Visitors must be supervised whilst on company premises.

• Transfer to a new job /location or new responsibilities, or

• The person accompanying a visitor will ensure that the proper evacuation procedures are followed in the event of an emergency and that the visitor is accounted for.

• Before the introduction of new equipment or new technology or modification of existing equipment; or

• No children may enter the site without prior knowledge and approval from an authorised person and then be accompanied at all times

• Before the introduction of new systems of work or changes to the existing systems.

• Visitors must sign out before leaving the premises

Training will be repeated periodically when appropriate.

Waste Disposal

All employees will, from time to time require further health and safety training in addition to basic and site specific induction training, taking into account: • The present of planned job content/ responsibilities of individuals • The past health and safety performance of the individual • Statutory requirements for training, where applicable • The findings of risk assessments. Appropriate training programmes will be developed wherever health and safety related training is required. Visitors The company has a responsibility for the health and safety of visitors to our premises. All employees are required to cooperate in ensuring that the following rules are adhered to:

The company is committed to ensuring the health, safety and welfare of its employees and of others who may be affected by the waste materials, which result from our work. We will arrange for the disposal of all waste products regularly, safely and recycling initiatives will be taken, where reasonably practicable, in order to help protect the environment and make better use of resources. To ensure that the disposal of waste at the workplace is carried out safely and in accordance with the law, you are required to adopt the following precautions: • Use only designated receptacles for holding waste products • Do not put waste material in receptacles that have not been allocated for that specific purpose • Take note of any segregation requirements, e.g. for hazardous waste or recyclable materials • Do not overfill waste containers

• No visitor may be invited/allowed to enter the premises without approval.

• Inform your line manager when additional resources are required

• Upon arrival visitors must complete the visitor’s record book located at reception

• Ensure that any spillage of substances at the workplace is cleared in an approved manner and that any materials used for cleaning are properly disposed of

Company Handbook • Make a note of any special arrangements or precautions that will have to be taken by our authorised waste remover

• If your normal workplace is unsuitable for rest breaks or for eating meals, use the separate facilities that are provided

• Do not use disposal preparation equipment and machinery unless you are trained and authorised to do so

• Leave the facilities in a clean and tidy condition after use, dispose of waste materials in the bins provided

• Wear any personal protective equipment that is required for safe handling of waste products

• Do not use microwave or other cooking equipment unless you have been instructed in its safe use

Welfare Facilities The company is committed to providing a safe working environment and this includes the provision of suitable welfare facilities. All employees are required to co-operate in ensuring that the following procedures are adhered to:

• Do not place, or consume drinks near to any electrical equipment • Report any defects or problems to your line manager • Ensure that spillages of drinks etc. are cleaned up immediately

Washing and Sanitary Facilities

• Do not smoke

Only use facilities that you are authorised to use for the intended purpose

VDU User Eye Tests

• Hand basins should not be used for rinsing of mops or soiled rags, etc. • Leave the facilities in a clean and tidy condition after use • Report any defects or problems to your line manager • Ensure that spillages of water or other slip hazards are cleaned up immediately • Do not smoke in toilets or washrooms • Inform visitors and contractors of facilities which are available to them • Do not drink water (or make drinks) from taps that are not marked ‘drinking water’ Accommodation for Clothing • Use the accommodation provided • If your work might result in your work clothing becoming contaminated with hazardous materials, store it separately from your personal clothes.

The Company provides VDU equipment which complies with health and safety legislation. The relevant EU Directive on the use of VDU equipment contains the following points: • The screens should be the right size • The keyboard should be detachable from the screen. • The screen should have contrast and brightness controls. All users should find a setting that is most suited to them. It may be necessary to change this setting on occasion. • The VDUs should tilt and swivel. Users should adjust the angle of the screen and its distance away from them so that they can read it clearly. • Anti-static/anti-glare screens should be available for all VDU users.

Facilities for Rest and to Eat Meals

• All users should find the most comfortable position – normally arms should be bent at the elbows at an angle of 90 degrees with the forearms. Wrists and hands should be parallel to the work surface and the floor.

• Do not prepare or consume food in areas that might be contaminated with hazardous materials

• It is important that VDU users report any faults with flickering screens or unclear images to their line manager for correction.

• Do not prepare or consume food unless you have washed your hands

Company Handbook • Where ever possible screens should not be sited adjacent to a window. If this is unavoidable, the screen should be positioned at right angles to windows to reduce glare or reflection onto the screen. Any employee that is using display equipment within the business or for business purposes at home is entitled to a free eye examination and glasses for VDU use. Please contact the Human Resources department if you would like more information. Daily work routines In most cases, the general pattern of work allows for natural breaks and pauses. Whenever possible, jobs involving computers should be designed to consist of a mix of screen based and non-screen based work to prevent fatigue. Where computer work involves intensive use of the keyboard or mouse, changes should be made to include tasks which do not demand broadly similar use of the arms and hands. Similarly if the display screen work is visually demanding, alternative work activities should be of a different character. The nature and mix of demands of a particular job will determine how work patterns can best be structured to prevent fatigue.

An employee that believes their workload does not permit adequate changes to avoid long spells working at a computer must bring this to the attention of the Company. General points • Never place drinks near electrical equipment. • Do not cover or obstruct ventilation grilles. • If there are trailing wires near work stations please report them to your line manager who will ensure that the necessary action is taken. • Avoid rapid repetitive movements of the head or eyes. • Remember to blink regularly and to glance away from the screen to rest the eyes and to stop the surface of the eye from becoming dry. • Most jobs incorporate tasks which require the employee to move away from the keyboard and screen. Breaks should be taken away from the equipment to provide the opportunity to change posture and to rest both eyes and hands. • If the lighting around the equipment is too bright or too dim please report it.

Company Handbook

CCTV Purpose of CCTV

Evidence from CCTV footage

The organisation will not use CCTV for monitoring the work of employees or finding out whether or not they are complying with the organisation’s policies and procedures.

CCTV evidence may be used against an employee in disciplinary proceedings only where such evidence tends to show, in the reasonable belief of the employer, that he or she has been guilty of serious misconduct. The employee will be given a chance to see and respond to the images in these circumstances.

CCTV will be installed only if it is a necessary and proportionate way of dealing with a problem. The organisation will ensure that all cameras are set up in a way that ensures that there is minimal intrusion of staff privacy, and that any intrusion is fully justified. In areas of surveillance, signs will be displayed prominently to inform employees that CCTV is in use. Limits on use of CCTV CCTV will not be operated in toilets, private offices or changing rooms, unless this is necessary for the investigation of a serious crime or there are circumstances in which there is a serious risk to health and safety or to the operation of the employer’s business. CCTV will be used in this way only where it is a proportionate means of achieving the aim in the circumstances. Covert CCTV will only ever be set up for the investigation or detection of crime or serious misconduct. The use of covert CCTV will be justified only in circumstances where the investigator has a reasonable suspicion that the crime or serious misconduct is taking place and where CCTV use is likely to be a proportionate means of securing evidence.

Storage of CCTV footage Images from CCTV footage will be securely stored and only authorised personnel will have access to them. The images will be retained only long enough for an incident to come to light and any investigation to be conducted. Workers whose images are recorded have a right to view images of themselves and to be provided with a copy of the images. Workers making such a request should provide the organisation with a photograph or a description of themselves, together with the relevant time and date of the image, so that they may be easily identifiable. Workers will be allowed access to such images within 40 days of the request. The organisation will charge £10 per request for the images.

Company Handbook

HR Policies APPENDIX The Company holds an extensive list of HR Policies and procedures. The procedures and policies are regularly updated in line with legislation. To view the latest version of these policies please download the Company Handbook at: www.pepper.co.uk/HR/Pepper_Company_Handbook.pdf Alcohol & Drugs Policy ........................................... P62 Equality and Diversity Policy................................... P63 Anti-Harassment Policy........................................... P64 Anti-Bribery Policy ................................................ P66 Data Protection Policy............................................. P70 Dignity at Work Policy............................................. P73 Disciplinary Policy.................................................. P75 Electronic Communications and Social Media Policy........................................... P79 Ethics Policy............................................................ P86 Family Related Events Policy................................... P88 Flexible Working Policy........................................... P93 Grievance Policy...................................................... P95 Maternity Leave and Pay Policy............................... P96 Performance Review Policy..................................... P100 Recruitment and Selection Policy........................... P103 Redundancy Policy.................................................. P105 Sickness Absence Policy.......................................... P107 Stress At Work Policy............................................... P109 Whistleblowing Policy............................................ P112 Working Time Policy............................................... P114 Employee Acknowledgement Slip........................... P121

The password to access the digital company handbook is: teampepper

Company Handbook

DRUG AND ALCOHOL POLICY It is the responsibility of the Company to ensure, so far as reasonably practicable, the health, safety and well being of all employees. Employees who are under the influence of drugs and or alcohol whilst at work may adversely influence their own safety and that of their colleagues.

legal limit whilst driving a car and would strongly advise that no alcohol at all should be taken if driving.

The aim of the policy is to establish clear and comprehensive rules, which will apply to all employees. We aim to provide a supportive environment to those with a drug or alcohol related problem that are committed to changing their behaviour.

Confidentiality

Definition: Alcohol covers all alcoholic beverages. Drugs include all Class A,B and C substances, drugs which are only legally available on prescription and solvents which are misused. Rules The taking of alcohol and drugs is strictly prohibited before working hours where any functioning at work would be adversely affected and the taking of alcohol and drugs is strictly prohibited during working hours. Special Circumstances Where employees are entertaining clients or attend social functions outside of the normal working day, the Company accepts that moderate amounts of alcohol may be consumed. The Company insists that employees stay within the

Where employees are taking medication for a pre diagnosed condition, the type of drug and it possible contra indications must be reported by the employee to the Line Manager. An employee who has a drug or alcohol related problem may approach management in confidence, within the provisions of the law, and receive help and support. Any absence during a rehabilitation period will be treated as normal sickness. Disciplinary Action Any employee found to be smoking cigarettes, under the influence of drugs and or alcohol onsite during working hours will be suspended on full pay pending a disciplinary hearing which may resulting the employees dismissal for gross misconduct. Any employee found to be (using), in possession of, or dealing in, illegal substances (whether at work or otherwise) will be suspended on full pay pending a disciplinary hearing, which may result in the employeeâ&#x20AC;&#x2122;s dismissal for gross misconduct In all instances of this kind the employee will be reported immediately to the police.

Company Handbook

EQUAL OPPORTUNITIES POLICY STATEMENT It is the policy of Pepper Communications Limited to treat all employees and job applicants fairly and equally regardless of their sex, sexual orientation, marital status, race, colour, nationality, ethnic or national origin, religion, belief, age or disability. Furthermore the Company will ensure that no requirement or condition will be imposed without justification which could disadvantage individuals purely on any of the above grounds. The policy applies to recruitment and selection, terms and conditions of employment including pay, promotion, training, transfer and every other aspect of employment. The Company will regularly review its procedures and selection criteria to ensure that individuals are selected, promoted and otherwise treated according to their relevant individual abilities and merits. The Company is committed to the implementation of this policy and to a programme of action to ensure that the policy is, and continues to be, fully effective. The overall responsibility for the policy lies with Steve Whitford, Managing Director. However, all staff are required to comply with the policy and to act in accordance with its objectives so as to remove any barriers to equal opportunity. Any act of discrimination by employees or any failure to comply with the terms of the policy will result in disciplinary action. Specifically, discrimination is prohibited in the following circumstances. (a) Treating any individual on grounds of sex, colour, marital status, race, nationality, age or ethnic or national origin, religion, belief, sexual orientation, gender reassignment, disability or less favourably than others. (b) Expecting an individual, solely on the grounds stated above, to comply with requirement(s), for any reason whatsoever related to their employment, that are different to the requirements for others. (c) Imposing on an individual requirements that are, in effect, more onerous on that individual than they are on others. For example, this would include applying a condition (which is not warranted by the requirements of the

position) which makes it more difficult for members of a particular race or sex to comply than others not of that race or sex. (d) Victimisation of an employee (victimisation by treating any individual less favourably than another). (e) Harassment or bullying of an employee (which for the purposes of this policy, and the actions and sanctions applicable thereto, is regarded as discrimination). Unwanted conduct affecting the dignity of men and women in the workplace. It may be related to age, sex, race, disability, religion, belief, nationality or any personal characteristic of the individual, and may be persistent or an isolated incident. The key is that the actions or comments and actions are viewed as demeaning and unacceptable to the recipient (f) Any other act or omission of an act, which has the effect of disadvantaging an employee or applicant against another, or others, purely on the above grounds. Thus, in all disciplinary matters, as well as consideration for training, promotion, etc â&#x20AC;&#x201C; in other words, all instances where those in control of employees are required to make judgements between them â&#x20AC;&#x201C; it is essential that merit, experience, skills and temperament are Considered as objectively as possible. 1. The Company commits itself to the immediate investigation of any claims of discrimination on the above grounds and, where such is found to be the case, a requirement that the practice ceased forthwith, restitution of damage or loss (if necessary) and the investigation of any employee accused of discrimination. 2. Any employee (no matter what level) found guilty of discrimination will be instructed to desist forthwith. Since discrimination in its many forms is against the Companyâ&#x20AC;&#x2122;s policy, any employee offending will be dealt with under the disciplinary procedure. Unless assurances of future non discriminatory actions are forthcoming. An employee repeating any act of discrimination may be dismissed.

Company Handbook Complaints procedure 1. In the event that any employee feels that he or she has suffered discrimination in any way, the Company’s grievance procedure should be utilized. 2. If the complaint is against the employee’s own immediate or other superior, confidential application should be made to a senior manager. 3. In instances of sexual harassment, as far as possible, the anonymity of the complainant should be protected. 4. To make a complaint of discrimination, harassment, victimization, or unfair treatment, it will be necessary to have available;

(a) Details of what, when and where the occurrence took place (b) Any witness statements or names (c) Names of any others who have been treated in a similar way (d) Details of any former complaint made about the incident, date, where and to whom made; (e) A preference for a solution to the incident. Until a hearing is arranged, complainants should keep the matter confidential, other than possibly arranging for details of witnesses to be given to the manager responsible for the hearing.

ANTI-HARASSMENT POLICY Pepper Communications Limited is committed to providing a work environment free of unlawful harassment. Company policy prohibits discrimination because of sex, sexual orientation, marital status, race, colour, nationality, ethnic or national origin, religion, age, disability or union membership. Company policy also prohibits sexual harassment which is defined as a “conduct of sexual nature, or conduct based on affecting the dignity of women and men at work, including conduct of supervisors and colleagues which constitutes an intolerable violation of the dignity of workers or trainees”. All such harassment is unlawful and will be treated very seriously. Pepper Communications Limited anti-harassment policy applies to all persons involved in the operation of the Company and prohibits unlawful harassment by any employee of Pepper Communications Limited, including supervisors, manager and fellow employees.

c. Physical conduct such as assault, unwanted touching, blocking normal movement or interfering with work; d. Threats and demands to submit to sexual requests as a condition of continued employment, or to avoid some other loss, and offers of employment benefits in return for sexual favours; and e. Retaliation for having reported or threatened to report harassment. All new employees will be informed of the Company’s policy towards sexual harassment at induction training, when it will be stressed that all incidents of sexual harassment will be treated very seriously. The Company expects all Managers, Supervisors, and Employees to ensure that this policy and procedure is adhered to at all times. INFORMAL REMEDY:

a. Verbal conduct such as epithets, derogatory jokes or comment, slurs or unwanted sexual advances, invitations or comments;

Because what one employee may regard as acceptable behaviour may be totally unacceptable to another employee an informal method of dealing with alleged harassment may in the majority of cases prevent further unacceptable behaviour.

b. Visual conduct such as derogatory and/ or sexually oriented posters, photography, cartoons, drawings or gestures;

Employees who are victims of a one time or minor event that they view as sexual harassment in nature are advised to make it clear to

Prohibited unlawful harassment includes, but is not limited to, the following behaviour:

Company Handbook the harassing employee their behaviour is unacceptable and must stop. Whenever possible, confront the harasser and persuade them to stop. If an employee is unable to convey verbally that the behaviour must stop, then a written request (explaining the distress which the behaviour is causing) handed to the harasser may prove to be an effective remedy.

1.4 The employee against whom the complaint is directed will also have the right to be accompanied at the investigation by a colleague of his or her choice. The Senior Manager will ensure that the alleged harasser has every opportunity to defend or explain his or her actions, in accordance with the Companyâ&#x20AC;&#x2122;s disciplinary procedure.

FORMAL REMEDY:

1.5 The severity of the penalty imposed upon an employee found guilty of harassment will be consistent with those detailed in the disciplinary procedure (e.g. gross sexual harassment will normally result in summary dismissal.) Where a lesser penalty is appropriate (e.g. a written warning) this may be coupled with action to ensure that the victim is able to continue working without embarrassment or anxiety. The Company may order the transfer of the harasser to a different work area, or arrange for the amendment of working practices to minimise contact between the two employees. If the victim so wishes his or her own transfer will be arranged, subject to practical limitations. The result of the hearing will be confirmed in writing to both employees, but will be kept confidential.

If you believe that you have been unlawfully harassed, and an informal remedy is not appropriate for one reason or another, please provide a written complaint in confidence to your own (or any other Company Manager/ Supervisor, if your own Manager/Supervisor may be implicated) or Human Resources Department Representative of Pepper Communications Limited as soon as possible after the incident. Your complaints should include details of the incident or incidents, names of the individuals involved and names of any witnesses. Managers/ Supervisors will refer all harassment complaints to the Human Resources Department of Pepper Communications Limited who will immediately undertake effective, thorough and objective investigation of the harassment allegations so that complaints can be quickly and fairly resolved. All employees involved in the investigation are expected to respect the need for confidentiality. Failure to do so will be considered a disciplinary offence. PROCEDURE: 1.1 The Human Resources Department will appoint a Senior Manager (not involved in the complaint) to carry out the investigation. 1.2 Copies of statements made by witnesses will be made available to the alleged harasser and the complainant. Witnesses will be encouraged to appear at the complaint investigation if requested by either party. It is acknowledged that some witnesses may be reluctant to do so. In these circumstances the Senior Manager will, if necessary, adjourn the investigation to ask supplementary question of witnesses in private. 1.3 The complainant may, if he or she wishes, be accompanied by any colleague of his or her choice.

1.6 If the complainant or harasser is not satisfied about the way his or her complaint has been handled, he or she may ask for it to be reconsidered by another member of the Senior Management Team. 1.7 Requests for re-consideration of the complaint should be made within seven working days after the written decision is made know to the impacted employees. The decision of this second investigation will be sent, in writing, to both parties and will be final. 1.8 An employee who receives a warning or is dismissed for sexual harassment may appeal against the penalty in accordance with the Companyâ&#x20AC;&#x2122;s appeal procedure. Pepper Communications Limited will not retaliate against you for making a complaint in good faith and will not tolerate or permit retaliation by management, employees or fellow employees. However, if the complaint is made frivolously or maliciously, this will be the subject of disciplinary action.

Company Handbook

ANTI-CORRUPTION AND BRIBERY POLICY 1 Policy Statement

2 Who Is Covered By The Policy?

1.1 It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships wherever we operate and implementing and enforcing effective systems to counter bribery.

This policy applies to all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, homeworkers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or their employees, wherever located (collectively referred to as workers in this policy).

1.2 We will uphold all laws relevant to countering bribery and corruption in all the United Kingdom. However, we remain bound by the laws of the UK, including the Bribery Act 2010, in respect of our conduct both at home and abroad. 1.3 The purpose of this policy is to: (a) Set out our responsibilities, and of those working for us, in observing and upholding our position on bribery and corruption; and (b) Provide information and guidance to those working for us on how to recognise and deal with bribery and corruption issues. 1.4 Bribery and corruption are punishable for individuals by up to ten yearsâ&#x20AC;&#x2122; imprisonment and if we are found to have taken part in corruption we could face an unlimited fine, be excluded from tendering for public contracts and face damage to our reputation. We therefore take our legal responsibilities very seriously. 1.5 In this policy, third party means any individual or organisation you come into contact with during the course of your work for us, and includes actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies, including their advisors, representatives and officials, politicians and political parties.

3 What Is Bribery? A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage. Examples: Offering a bribe You offer a potential client tickets to a major sporting event, but only if they agree to do business with us. This would be an offence as you are making the offer to gain a commercial and contractual advantage. We may also be found to have committed an offence because the offer has been made to obtain business for us. It may also be an offence for the potential client to accept your offer. Receiving a bribe A supplier gives your nephew a job, but makes it clear that in return they expect you to use your influence in our organisation to ensure we continue to do business with them. It is an offence for a supplier to make such an offer. It would be an offence for you to accept the offer as you would be doing so to gain a personal advantage.

Company Handbook Bribing a foreign official

5 What Is Not Acceptable?

You arrange for the business to pay an additional payment to a foreign official to speed up an administrative process (SUCH AS CLEARING OUR GOODS THROUGH CUSTOMS)

It is not acceptable for you (or someone on your behalf) to:

The offence of bribing a foreign public official has been committed as soon as the offer is made. This is because it is made to gain a business advantage for us. We may also be found to have committed an offence. 4 Gifts And Hospitality 4.1 This policy does not prohibit normal and appropriate hospitality (given and received) to or from third parties. 4.2 The giving [OR RECEIPT] of gifts is not prohibited, if the following requirements are met: (a) It is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage, or in explicit or implicit exchange for favours or benefits; (b) It complies with local law; (c) It is given in our name, not in your name; (d) It does not include cash or a cash equivalent (such as gift certificates or vouchers); (e) It is appropriate in the circumstances. For example, in the UK it is customary for small gifts to be given at Christmas time; (f) Taking into account the reason for the gift, it is of an appropriate type and value and given at an appropriate time; (g) It is given openly, not secretly; and (h) gifts should not be offered to, or accepted from, government officials or representatives, or politicians or political parties, without the prior approval of your Manager. 4.3 We appreciate that the practice of giving business gifts varies between countries and regions and what may be normal and acceptable in one region may not be in another. The test to be applied is whether in all the circumstances the gift or hospitality is reasonable and justifiable. The intention behind the gift should always be considered.

(a) Give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given; (b) Give, promise to give, or offer, a payment, gift or hospitality to a government official, agent or representative to “facilitate” or expedite a routine procedure; (c) Accept payment from a third party that you know or suspect is offered with the expectation that it will obtain a business advantage for them; (d) Accept a gift or hospitality from a third party if you know or suspect that it is offered or provided with an expectation that a business advantage will be provided by us in return; (e) Threaten or retaliate against another worker who has refused to commit a bribery offence or who has raised concerns under this policy; or (f) Engage in any activity that might lead to a breach of this policy. 6 Facilitation Payments And Kickbacks 6.1 We do not make, and will not accept, facilitation payments or “kickbacks” of any kind. Facilitation payments are typically small, unofficial payments made to secure or expedite a routine government action by a government official. If you are asked to make a payment on our behalf, you should always be mindful of what the payment is for and whether the amount requested is proportionate to the goods or services provided. You should always ask for a receipt which details the reason for the payment. If you have any suspicions, concerns or queries regarding a payment, you should raise these with your Manager. 6.2 Kickbacks are typically payments made in return for a business favour or advantage. All workers must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us.

Company Handbook 7 Your Responsibilities

9 How To Raise A Concern

7.1 You must ensure that you read, understand and comply with this policy.

You are encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. If you are unsure whether a particular act constitutes bribery or corruption, or if you have any other queries, these should be raised with your Line Manager.

7.2 The prevention, detection and reporting of bribery and other forms of corruption are the responsibility of all those working for us or under our control. All workers are required to avoid any activity that might lead to, or suggest, a breach of this policy. 7.3 You must notify your Manager as soon as possible if you believe or suspect that a conflict with this policy has occurred, or may occur in the future. For example, if a client or potential client offers you something to gain a business advantage with us, or indicates to you that a gift or payment is required to secure their business. Further “red flags” that may indicate bribery or corruption are set out in the 13.4. 7.4 Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. 8 Record-Keeping 8.1 We must keep financial records and have appropriate internal controls in place which will evidence the business reason for making payments to third parties. 8.2 You must declare and keep a written record of all hospitality or gifts accepted or offered, which will be subject to managerial review. 8.3 You must ensure all expenses claims relating to hospitality, gifts or expenses incurred to third parties are submitted in accordance with our expenses policy and specifically record the reason for the expenditure. 8.4 All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, should be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off-book” to facilitate or conceal improper payments.

10 What To Do If You Are A Victim Of Bribery Or Corruption It is important that you tell your Manager as soon as possible if you are offered a bribe by a third party, are asked to make one, suspect that this may happen in the future, or believe that you are a victim of another form of unlawful activity. 11 Protection 11.1 Workers who refuse to accept or offer a bribe, or those who raise concerns or report another’s wrongdoing, are sometimes worried about possible repercussions. We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. 11.2 We are committed to ensuring no one suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or other corruption offence has taken place, or may take place in the future. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the compliance manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using our Grievance Procedure, which can be found in the Company handbook. 12 Who Is Responsible For The Policy? 12.1 The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

Company Handbook 13 Monitoring And Review 13.1 The Human Resources Manager and Board of Directors will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness. Any improvements identified will be made as soon as possible. Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective in countering bribery and corruption. 13.2 All workers are responsible for the success of this policy and should ensure they use it to disclose any suspected danger or wrongdoing. 13.3 Workers are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the compliance manager. 13.4 This policy does not form part of any employee’s contract of employment and it may be amended at any time. Potential risk scenarios: “red flags” The following is a list of possible red flags that may arise during the course of you working for us and which may raise concerns under various anti-bribery and anti-corruption laws. The list is not intended to be exhaustive and is for illustrative purposes only. If you encounter any of these red flags while working for us, you must report them promptly to your Manager: (a) You become aware that a third party engages in, or has been accused of engaging in, improper business practices; (b) You learn that a third party has a reputation for paying bribes, or requiring that bribes are paid to them, or has a reputation for having a “special relationship” with foreign government officials;

(c) A third party insists on receiving a commission or fee payment before committing to sign up to a contract with us, or carrying out a government function or process for us; (d) A third party requests payment in cash and/ or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made; (e) A third party requests that payment is made to a country or geographic location different from where the third party resides or conducts business; (f) A third party requests an unexpected additional fee or commission to “facilitate” a service; (g) A third party demands lavish entertainment or gifts before commencing or continuing contractual negotiations or provision of services; (h) A third party requests that a payment is made to “overlook” potential legal violations; (i) A third party requests that you provide employment or some other advantage to a friend or relative; (j) You receive an invoice from a third party that appears to be non-standard or customised; (k) A third party insists on the use of side letters or refuses to put terms agreed in writing; (l) You notice that we have been invoiced for a commission or fee payment that appears large given the service stated to have been provided; (m) A third party requests or requires the use of an agent, intermediary, consultant, distributor or supplier that is not typically used by or known to us; (n) You are offered an unusually generous gift or offered lavish hospitality by a third party.

Company Handbook

Data Protection Policy Purpose The aim of this Policy is to ensure that all personal information the Company holds about its employees is dealt with in a secure, confidential and accurate manner. The Company understands and endorses the requirements of the Data Protection Act 1998 (‘the Act’). It respects the right of its employees to privacy within the workplace and works to balance that with the need to ensure compliance with Company Rules and with the civil and criminal law. Access to any data held by the Company will be provided to the employee in compliance with the Act. This policy does not form part of any employee’s contract of employment and it may be amended at any time. Any breach of this policy will be taken seriously and may result in disciplinary action. Introduction The person with responsibility for this Policy is Jake Whitford and any queries should in the first instance be addressed to him. If you consider that the policy has not been followed in respect of personal data about yourself or others, you should raise the matter with your Manager. This Policy will be reviewed annually. Contents 1. Definition of data protection terms 2.Administration 3.My Personal data 3.1 Can I access the personal data held by the Company? 3.2 Can I request the Company to amend the Personal data held? 3.3 Is there any personal data that I am not eligible to access? 3.4 Can I prevent the Company Processing my Personal data? 4. W hat Sensitive data is the Company Processing? 5. W ill the Company disclose personal data to external organisations? 6. Monitoring 7. Providing information over the telephone

1. Definition of date protection terms 1.2 Data is information which is stored electronically, on a computer, or in certain paper-based filing system. 1.3 Data subjects for the purpose of this policy include all living individuals about whom we hold personal data. A data subject need not be a UK national or resident. All data subjects have legal rights in relation to their personal data. 1.4 Personal data means data relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal data can be factual (such as a name, address or date of birth) or it can be an opinion (such as a performance appraisal). 1.5 Data controllers are the people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed. They have a responsibility to establish practices and policies in line with the Act. We are the data controller of all personal data used in our business. 1.6 Data users include employees whose work involves using personal data. Data users have a duty to protect the information they handle by following our data protection and security policies at all times. 1.7 Processing is any activity that involves use of the data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties. 1.8 Sensitive personal data includes information about a person’s racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health or condition or sexual life, or about the commission of, or proceedings for, any offence committed or alleged to

Company Handbook have been committed by that person, the disposal of such proceedings or the sentence of any court in such proceedings. Sensitive personal data can only be processed under strict conditions, and will usually require the express consent of the person concerned. 2. Administration 2.1 The Company will ensure that all Data controllers and Data users are trained in compliance with the requirements of the Act and the Data will be: 2.1.1 Processed fairly and lawfully. 2.1.2 Processed for limited purposes and in an appropriate way. 2.1.3 Adequate, relevant and not excessive for the purpose. 2.1.4 Accurate. 2.1.5 Not kept for longer than necessary for the purpose. 2.1.6 Not transferred to people or organisations situated in countries without adequate protection. 2.2 The Company will ensure that all Personal data will be held in a secure centralised system and access will be restricted to Data controllers and Data users. 2.3. The Company have the following security procedures:

2.5 You will be asked annually to approve a list of your Personal data held by the Company. 3. My Personal data 3.1 Can I access the personal data held by the Company? You are entitled to have access to your records. Should you require such access you must place request it in writing to a Director together with a cheque for ÂŁ10 administration fee. Within 40 days you will be provided with access to all Personal data other than the exceptions listed in clause 3.3 below. 3.2 Can I request the Company to amend the personal data held? You can request the Company to update and/or amend any of your Personal data. This must be done in writing to a Director. However the Employer reserves the right to maintain the data complained of and includes a statement from the employee that he does not agree with the data. 3.3. Is there any Personal data that I am not eligible to access? The Act does not allow you access to the following data; 3.3.1 References written by the Company.

2.3.1 Entry controls. Any stranger seen in entrycontrolled areas should be reported. Secure lockable desks and cupboards.

3.3.2 Any data from which a third party can be identified, unless it is possible to remove the identifying elements.

2.3.2 Desks and cupboards should be kept locked if they hold confidential information of any kind. (Personal information is always considered confidential.)

3.3.3 Any data held for the purposes of management forecasting or planning if access to the same is likely to prejudice the conduct of the Companyâ&#x20AC;&#x2122;s business.

2.3.3 Methods of disposal. Paper documents should be shredded. Floppy disks and CD-ROMs should be physically destroyed when they are no longer required. 2.3.4 Equipment. Data users should ensure that individual monitors do not show confidential information to passers-by and that they log off from their PC when it is left unattended.

3.3.4 Any data prejudicing ongoing negotiations with you. . 3.3.5 Any data protected by legal professional privilege. 3.3.6 Any data regarding your health which an appropriate health professional considers likely to cause serious harm to your physical or mental health or of any other person.

2.4 The Company will carry out an annual audit of all Personal data to ensure it is accurate, up to date and relevant.

Company Handbook 3.4 Can I prevent the Company from Processing my Personal data? You have the right to prevent the Company Processing your Personal data: 3.4.1 For direct marketing purposes and 3.4.2 Where Processing is likely to cause damage or distress to you or someone else 4. What Sensitive Personal data is the Company Processing? The Processing of Sensitive Personal data is restricted by the Act. The Company will process data relating to sickness absence. By signing this document you give express consent to such processing of data which allows the Company to manage sickness absence. 5. Will the Company disclose Personal data to external organisations? The Company may from time to time use external bodies to process data, for example to outsource payroll or personnel functions. The Company will ensure that such bodies have in place sufficient security measures. 6. Monitoring 6.1 Email, phone internet and Social Media use (‘the Communications’). You are referred to the Electronic Information Policy for further information. If the Company reasonably suspects an employee is abusing the use of the Communications and/or it has been alleged that they have committed an act of misconduct or gross misconduct, they reserve the right to monitor all related Communications. . By signing this document you give express consent to such monitoring 6.2 CCTV cameras. The Company has CCTV cameras on site for security purposes . Insofar as this is considered “monitoring”, by signing this document you give express consent to the recording and storage of such data.

7 Providing information over the telephone Any member of staff dealing with telephone enquiries should be careful about disclosing any personal information held by the Company. In particular they should: 7.1 Check the caller’s identity to make sure that information is only given to a person who is entitled to it. 7.2 Suggest that the caller put their request in writing if they are not sure about the caller’s identity and where their identity cannot be checked. 7.3 Refer to their line Manager for assistance in difficult situations. No-one should be bullied into disclosing personal information.

Company Handbook

Dignity at Work Policy Policy statement Pepper Communications Ltd recognises the right of every employee to be treated with respect and dignity. The Company is committed to the development of positive policies for the elimination of harassment and bullying in the workplace.

employee explains to you that they find your behaviour upsetting you must take them seriously.

These guidelines have been drawn up with the objective of preventing harassment and/ or bullying in the workplace and are applicable to employees at every level. All employees are advised to consider this Policy in conjunction with the Company’s Equality & Diversity Policy.

Harassment can also mean:

Harassment is all unwanted conduct related to the ‘protected characteristics’ of sex, gender reassignment, race, disability, sexual orientation, religion or belief and age affecting the dignity of women and men at work. It can take many forms, e.g. • Displaying “off-colour” photographs in the workplace • Dubious jokes • Use of obscene language • Intentionally excluding a work colleague from conversation etc • “Accidental” trips, nudges and other physical contact • Actual assault. Harassment also includes the following: Harassment based on association. It is unlawful to discriminate against, or harass any individual for association with another individual who has a protected characteristic. Harassment based on perception. It is unlawful to discriminate against or harass any individual based on a perception that he or she has a protected characteristic. Harassment can be targeted at an individual or can be unintentional It is distinguished from mutually acceptable friendly or social behaviour, which may occur during contact between people at work. Harassment will be considered from the viewpoint of the person harassed. It is not relevant that the rest of the workforce would not find certain behaviour offensive or upsetting. “It was only a joke” is no excuse. If a fellow

Any of these forms of harassment will also amount to Discrimination and are covered by specific Regulations making it unlawful.

Bullying i.e. persistent, offensive, abusive, intimidating, malicious or insulting behaviour, abuse of power or unfair penal sanctions which makes the recipient feel upset, threatened, humiliated or vulnerable, which undermines their self confidence and which may cause them to suffer stress. Employers have as general duty to protect employees’ health and safety at work and failure to address a problem of bullying may contravene this legislation. Victimisation i.e. where an employee is subjected to a detriment , such as being denied a training opportunity or promotion, because he or she made or supported a complaint or raised a grievance under the Equality Act 2010, or because he or she is suspected of doing so. The Company has an obligation to provide an environment free of harassment. All employees have a responsibility to help to ensure that there is none. Any such conduct will not be condoned or tolerated in the workplace and will be dealt with under the disciplinary procedure and in severe cases will result in dismissal. Management have a particular duty to ensure that harassment, bullying and /or victimisation of any kind does not occur in work areas for which they are responsible. Any threat or insinuation made that an employee’s rejection of sexual advances will influence an employment decision affecting that person will be treated as a serious disciplinary offence. Complaints Procedure Employees who consider they are suffering from harassment, bullying and/or victimisation of any kind should ensure it is made clear to the alleged harasser that such behaviour is unwanted and unwelcome and in the complainant’s view constitutes harassment.

Company Handbook The grievance procedure may be used to deal with complaints of harassment, bullying and/ or victimisation. However, in the first instance, complaints should follow the steps set out in this policy wherever practicably possible.

both the complainant and the alleged harasser.

Employees who consider they are suffering from harassment and/or bullying are able to seek advice and support in total confidence from the a Director without obligation to take a complaint further.

If the investigation reveals that the complaint is valid, prompt action will be taken to stop the harassment immediately and prevent its recurrence.

If harassment continues in any form, a complaint under the existing procedure for dealing with grievances should be made. Where the grievance procedure is used, an opportunity will be afforded to the employee concerned to bring along a friend employed at the workplace or a union representative of their choice. In circumstances where a complaint of harassment, bullying and/or victimisation is made against the employeeâ&#x20AC;&#x2122;s immediate line Manager, the matter shall be referred to a more senior Manager in accordance with normal procedure. If the complaint is against a Director or Senior Manager, another Director will deal with the complaint. Investigations of complaints will be handled with sensitivity and with due respect for the rights of

Investigations and any subsequent disciplinary action will be carried out quickly, confidentially and carefully.

This action should not be to the detriment of the harassed person. It will be considered a disciplinary offence to victimise or retaliate against a person who is making a complaint of harassment or bullying or who is assisting in an investigation.

Company Handbook

Disciplinary Policy It is the policy of this Company to offer every advice and assistance to employees who do not meet the required standards of conduct or performance, for whatever reason. It is anticipated that the vast majority of problems can be overcome solely by discussion and by the voluntary agreement of employees to take appropriate remedial action. It is also recognised that occasionally it will be necessary to take disciplinary action against employees whose conduct or performance is unacceptable. Where such action has to be taken, it is appreciated that it should: • Be undertaken only in cases where good reason and clear evidence exists. • Be appropriate to the misdemeanour in question and to the degree of repetition of the misdemeanour. • Be demonstrably fair and consistent with previous actions in similar circumstances. • Take place where employees are made aware of the standards expected of them or rules with which they must comply in accordance with Company literature. • Allow employees the right to be accompanied by a colleague or trade union representative during any formal proceedings. • Allow employees the right of appeal against any disciplinary action. This procedure does not form part of any employee’s contract of employment. It may be amended at any time and the Company may depart from it depending on the circumstances of any case. The person with responsibility for this Policy is a Director and any queries should in the first instance be addressed to him. This Policy will be reviewed annually.

CONTENTS 1. Who is covered by the policy? 2. What is covered by the policy? 3. Procedure 3.1 Stage 1 - formal verbal warning. 3.2 Stage 2 - a written warning. 3.3 Stage 3 - final written warning. 3.4 Stage 4 – dismissal with notice. 3.5 Dismissal without notice. 3.6 Acts of gross misconduct. 4. Conduct of the proceedings? 4.1 Investigation. 4.2 Invitation to a disciplinary meeting. 4.3 The disciplinary meeting. 4.4 The outcome. 4.5 Appeals. 4.5.1 Against any verbal or written warnings. 4.5.2 Against dismissal with notice. 4.5.3 Against dismissal without notice. 4.5.4 Retaining warnings on record. 4.6 Suspension. 4.7 Trade union officials and disciplinary action. 4.8 Changes in rules or procedure. 1. Who is covered by the policy? The procedure applies to employees of the Company. 2. What is covered by the procedure? 2.1 This procedure is used to deal with misconduct. It does not apply to cases involving genuine sickness absence, proposed redundancies or poor performance. In those cases reference should be made to the appropriate policy or procedure in the Staff Handbook. 2.2 Minor conduct issues can often be resolved informally between the employee and their line Manager. These discussions should be held in private and without undue delay whenever there is cause for concern. Where appropriate, a note of any such informal discussions may be placed on the employees personnel file. In some cases an informal verbal warning may be given. Formal steps will be taken under this procedure if

Company Handbook the matter is not resolved, or if informal discussion is not appropriate (for example, because of the seriousness of the allegation). 2.3 If an employee has difficulty at any stage of the procedure because of his or her disability, he or she should discuss the situation with his or her line Manager as soon as possible. 3. Procedure 3.1 Stage 1 – A formal verbal warning A formal verbal warning will be given by the first line of management should an employee fail to meet the required standards of conduct or performance set by the Company (see Part 2 for the disciplinary meeting). The formal verbal warning should be recorded in writing and specify the period for which it will apply (for example 6 months). 3.2 Stage 2 – A written warning If, after a verbal warning, the employee’s conduct or performance does not improve and reach the required standard within a reasonable period of time, or he repeats the same or other misdemeanours, then he/she will be given a written warning by the department Manager. The warning should specify the period for which it will apply (for example 12 months) (see Part 2 for the disciplinary meeting). 3.3 Stage 3 – Final written warning If, after a written warning, the employee’s conduct or performance still does not improve and reach the required standard within a reasonable period of time, or he repeats the same or other misdemeanours, then he/she will be given a final written warning by the department Manager. (See Part 2 for the disciplinary meeting). The warning should specify the period for which it will apply (for example 12 months). 3.4 Stage 4 – Dismissal with notice If, after a final written warning, the employee’s conduct or performance still does not improve and reach the required standard within a reasonable period of time, or the same or other misdemeanours are repeated by him/ her, then he/she will be given notice of dismissal by the department Manager

or a director which will be confirmed in writing. Note: Should the circumstances be considered sufficiently serious, it may be necessary to disregard earlier or intermediate stages of the procedure. In such cases, the procedure will be invoked at whatever stage is judged appropriate to the misdemeanour currently under consideration (e.g. first or final written warning). 3.5 Dismissal without notice In some circumstances an employee may be dismissed without notice if (for example) it is established after investigation and hearing the employee’s version of the matter, that there has been an act of gross misconduct. 3.6 Acts of gross misconduct can include the following: • Theft from the Company or fellow employees • Fraud • Failure to carry out a reasonable and lawful direct instruction given by a superior during working hours

• Abuse of e-mail or internet facilities

• Breach of clocking rules

• Being under the influence of drink or drugs on Company premises (see drugs and alcohol policy)

• Deliberate damage to Company property or that of other employees

• Serious breach of safety rules involving potential loss of life or limb to any person

• Breach of the duty regarding nondisclosure of confidential information

• Flagrant or persistent failure to follow Company documentary procedures and regulations. This particularly applies to records of absence

• Assault, fighting, the threat of physical violence or dangerous horseplay

Company Handbook

• A conviction for a criminal offence or other acts committed outside the place of work when the offence has an adverse bearing on the employee’s suitability for the job or makes the employee unacceptable to other employees

This list of examples is not intended to be exhaustive. There may be other cases where a failure to comply with rules, or meet certain conditions and standards, will be considered by the Company as sufficient grounds for dismissal without notice. If the conclusion of an investigation is that there has been an act of gross misconduct, then the department Manager or a director shall immediately consult with the relevant director, before a written statement of the reasons for the dismissal without notice is given. 4 Conduct of the proceedings 4.1 Investigation: All necessary investigations will be carried out relating to the conduct or performance of any staff member and may include meetings with any appropriate individuals, in order for the Company to establish the facts involved in the case. 4.2 Invitation to a disciplinary meeting: The employee will be invited in writing to a disciplinary meeting. That invitation will include the following information: 1. That he/she has the right to be accompanied by a colleague or trade union official of his/her own choice;

2. Of the allegations brought against him/her and details of any investigations that support the allegation;

3. Any documentary evidence that has been produced during the investigation, including witness statements. In very rare circumstances the employer may withhold any documentary evidence where early disclosure could lead to endangerment of other parties;

4. That he/she will be given every opportunity to explain the

circumstances from his/her point of view and present any mitigating circumstances that may materially alter the Manager/supervisor’s view;

5. That the Manager/supervisor conducting the disciplinary interview will carefully consider any points made by the person being disciplined;

6. The time, date and location of the meeting. The date of the meeting will be set to allow sufficient time for the employee to consider the information provided in the invitation.

4.3 The disciplinary meeting: A note taker will be present at the meeting. Minutes will be produced and forwarded to the employee subsequent to the meeting. At the meeting the Manager will present the case to the employee, including any relevant evidence and will allow the employee to respond with their own evidence, question the evidence presented and call witness’s if appropriate. The Manager holding the meeting will then adjourn to consider the employee’s representations and will respond in writing with his decision. 4.4 The outcome: The Manager will communicate their decision in writing, which will contain the following information: 1. A summary of the employee’s representations and the Manager’s comments on each one. 2. A summary of any mitigation advanced by the employee and the Manager’s comments on the same. 3. The Manager’s decision as to any disciplinary action to be taken. 4. Where a warning is given, the employee will be informed: (i) That this is one of the stages (specify which one) of the formal procedure; (ii) Of the possible consequences in terms of the remaining procedural stages and ultimately dismissal (not applicable at dismissal stages) if there is any recurrence of the misdemeanour(s) which gave rise to the warning.

Company Handbook 5. The employee’s right to appeal against the disciplinary measure taken

considered appropriate, provided that period does not exceed 12 months in duration.

4.5 Appeals Note: The level of management to which appeals should be addressed will need to reflect individual organisational structures. Those hearing the appeal must not have had any previous involvement in the matter.

Where a formal verbal warning has been issued, a period of six months with no further offences will be regarded as a clean record for disciplinary purposes.

4.5.1 Against verbal or any written warning If an employee feels that any verbal or written warning is unjustified he/she may appeal within five working days to the level of management immediately above the Manager or supervisor who initially administered the warning in question, whose decision will be final. 4.5.2 Against dismissal with notice If an employee feels that dismissal is unjustified, he/she may appeal within five working days to the level of management immediately above the Manager who originally gave notice of dismissal to the managing director, whose decision will be final. 4.5.3 Against dismissal without notice If an employee feels that summary dismissal is unjustified, he/she may appeal within five working days to the level of management immediately above the Manager who originally implemented the decision to dismiss without notice to the managing director, whose decision will be final. Note: Pending the result of the appeal there will be no entitlement to pay. When an appeal results in the decision to dismiss being rescinded, the employee will receive full back pay for the period during which the appeal was pursued. In such a case his/her contract should be reinstated to the date of dismissal. Appeal hearings will take place as soon as possible. 4.5.4 Retaining warnings on record It is not intended to keep recorded warnings live for an indefinite period after the date on which they were given. Warnings will usually be live for 12 months, provided that the improvements sought are achieved within that time limit. If improvements made are not maintained and/ or further misdemeanours occur, new warnings may be issued. Any additional written warnings may be placed on record for whatever period is

Where any written warning has been issued, it will remain ‘live’ for a period not exceeding 12 months. There may be occasional very exceptional circumstances when the warning will exceed 12 months for instance if there are repeat offences each just outside the previous warning period. 4.6 Suspension It may sometimes be appropriate to suspend an employee whilst a process is ongoing. Such circumstances will include the likely intimidation of witnesses, or the likely continued disruption in the workplace. Instances of violence will lead to suspension for the duration of the process. Such suspension will be paid at basic rate and will not continue for any longer than is absolutely necessary. 4.7 Trade union officials and disciplinary action No disciplinary action beyond the first warning stage will be taken against an FOC or acting FOC until the circumstances of the case have been discussed with a full-time official of the union. The only exception to this will be precautionary suspension in the event of serious misconduct being investigated. 4.8 Changes in rules or procedure The Company’s rules and this procedure will be reviewed periodically in the light of any developments in employment legislation or industrial relations practice. Any amendments or additional rules imposing new obligations, which become necessary as a result of such developments, will not be introduced until all employees have been informed and given reasonable notice of the changes.

Company Handbook

Electronic Communications (EC) Policy and Social Media Policy Policy Statement This policy covers the handling, processing and use of all information held electronically, irrespective of the way in which it is held, including the use of emails the Internet, CCTV and mobile phones. The Company endorses their employees’ rights regarding privacy but must balance those rights with the Company’s need to prevent abuse of the electronic communications available to employees and this may from time to time require the monitoring of such communications. This monitoring will usually take the form of keeping track of the general EC traffic within the Company. 1. Management Responsibility Overall responsibility for the management and processing of information within the Company lies with Jake Whitford and changes to any access rights can only be made with their authority. In order that the policy continues to support business needs, a review will normally take place annually to keep abreast of legislation or where there is a significant change to the Company’s computer environment. 2. Individual Accountability As an employee you are personally accountable for your use of the Company’s EC facilities; access to information; changes that are made to a document or file and any authentication credentials (e.g. User name and password). You should not either use anyone else’s authentication credentials or disclose theirs. If you fail to carry out the requirements of this policy this could be deemed a disciplinary offence attract sanctions up to and including dismissal 3. Disciplinary Proceedings No information which is unlawful, defamatory, lewd, obscene or otherwise inappropriate, or likely to result in any form of liability on the part of the Company, is to be stored, sent, forwarded, downloaded, printed or otherwise dealt with, whilst using the Company’s systems. All information transmitted by the Company must reflect the standards, business practice and policies of the Company. Failure to abide

by all aspects of this policy may result in the instigation of formal disciplinary proceedings and in severe cases may lead to dismissal. 4. Administration Administrative procedures are the responsibility of Jake Whitford and as such, is accountable for any changes made to the software or data necessary to operate that system and the appropriateness of access controls. 5. N.B. Monitoring To allow the policing of this policy, the Company reserves the right to monitor employees’ use of electronic communications. Should an employee’s misuse give the Company reasonable cause for concern, the Company reserves the right to continuously monitor that employee’s use of all electronic media for a reasonable period of time. By signing this policy you accept these terms. 6. Reporting of misuse Should employees have any concerns about misuse of electronic information by others they should contact a Director and should any employee feel uncomfortable or harassed by receipt of electronic information from other employees, they should make a complaint using the Company’s Grievance Procedure. 7. Responsibility for the Policy The person responsible for this Policy is Jake Whitford who will undertake an annual review and update. Any queries regarding this policy should be addressed to him. EMAIL (a) Before You Send An Email Before you use the email facilities, you are reminded that it should be treated in the same way as written material; you should consider whether this is the most appropriate method of communication (for example, your message could be a formal instruction to a client/ customer; the most appropriate means of communication could be by way of letter). The transfer of confidential or commercially sensitive information is forbidden without prior consent from the relevant line Manager.

Company Handbook In addition, you should take care when drafting the content of the message; people often take an informal tone and write in a way they would not in a letter or memorandum. It is also important to remember that communicating by e-mail is fast and efficient. If this is abused or inappropriately used it can be a significant drain on resources. Remember that any email you send might be read by someone, other than the addressee, including your senior Manager. (b) Misuse Of The Email System The following are examples of misuse of the email system, which may result in disciplinary action up to and including summary dismissal for gross misconduct. This list is a guide only and not exhaustive: • Copyright infringement • Defamation • Harassment or discrimination • Offensive language • Downloading, accessing or distribution of pornography • Introduction of computer viruses • Confidentiality infringement • Excessive personal use • Any message that could result in bullying or harassment • Use of Company email accounts to conduct private correspondence of any sort (c) Exposure to liability and disciplinary action Employees should be aware that the transmission of material that they might not find offensive might be considered offensive by the person receiving said material. Such transmission (e.g. the sending of lewd pictures) may expose both the employee and the Company to claims of harassment. Consequently any such activity complained of will be dealt with under the disciplinary procedure and could lead to the perpetrator’s dismissal. (d) Private email accounts. Personal use is not permitted during working hours and may only be used during authorised rest breaks. It is vital that you are aware that any emails sent to fellow employees that are considered inappropriate could have repercussions within the workplace. Therefore, you should consider carefully what you choose to share via email communications even when using your own email accounts. The Company reserves the right to investigate your actions and

where appropriate, take disciplinary action if any communication sent or forwarded from you to another employee of the business is considered offensive or inappropriate, even if taking part in this action during your own private time. (e) Monitoring Should the Company have reasonable cause to believe that misuse of email is taking place, it reserves the right to continually monitor your use of email. Please see page 1 item 5 of this policy for further details THE INTERNET Before you use the Internet Before you use the Internet facilities, you should be aware that the Company classifies Internet usage into four specific headings: business use; personal use; active use and inappropriate use. (a) Business Use This includes any activity connected to the business including research, administration, development of professional knowledge and communication with clients, suppliers and customers. There is no restriction of business use. (b) Personal Use This includes personal banking, online email accounts, social networking sites, ordering personal goods and searching for information about holidays and car insurance or other jobs. [Personal use is not permitted during working hours and may only be used during authorised rest breaks] Excessive use during working is a disciplinary offence. (c) Active Use This includes downloading, playing games, private advertising and personal financial gain. Active use of the Internet is prohibited during working hours and will be a disciplinary offence. (d) Inappropriate Use This includes accessing pornographic, racist or illegal sites; it is unacceptable to download and disseminate such material by electronic means. Inappropriate use of the Internet is a disciplinary offence and could lead to dismissal. It may also be a criminal offence, and may therefore also be reported to the police. Exposure to Liability and Disciplinary Action Employees should be aware that the

Company Handbook transmission of material, which they might not find offensive, offends the person receiving said material. Such transmission (e.g. the sending of lewd pictures) may expose both the employee and the Company to claims of sexual or racial harassment. Consequently any such activity complained of will be dealt with under the disciplinary procedure and could lead to the perpetratorâ&#x20AC;&#x2122;s dismissal. Private use of Social Media Personal use is not permitted during working hours and may only be used during authorised rest breaks. The Company respects the right of all employees to a private life, however, it is important that you are aware that the posting of inappropriate comments on any social networking site could have repercussions within the workplace. Therefore, you should be careful not to identify your employer or work colleagues when making offensive or derogatory comments. If found to be taking part in such activity even whilst in your own private time, the Company reserves the right to investigate your actions and where appropriate, take disciplinary action.

Mobile Phone use at work Personal use is not permitted during working hours and may only be used during authorised rest breaks. This includes the use of the internet and email accounts via your mobile phone. Anyone found to be using their mobile phones outside of their normal break times will be dealt with under the Company disciplinary procedure. Monitoring Should the Company have reasonable cause to believe that misuse of the Internet is taking place, it reserves the right to continually monitor your use of email. Please see page 1 item 5 of this policy for further details.

Social Media Policy Purpose The Company recognise that the internet provides unique opportunities to participate in interactive discussions and share information on particular topics using a wide variety of social media, such as Facebook, Twitter, LinkedIn, blogs and wikis. However, employeesâ&#x20AC;&#x2122; use of social media can pose risks to our confidential and proprietary information, and reputation, and can jeopardise our compliance with legal obligations. To minimise these risks, to avoid loss of productivity and to ensure that our IT resources and communications systems are used only for appropriate business purposes, we expect employees to adhere to this policy. This policy does not form part of any employeeâ&#x20AC;&#x2122;s contract of employment and it may be amended at any time. Any breach of this policy will be taken seriously and may result in disciplinary action.

Introduction The person with responsibility for this Policy is Jake Whitford and any queries should in the first instance be addressed to him. This Policy will be reviewed annually. CONTENTS 1. Who is covered by the policy? 2. Scope of the policy 3. P ersonnel responsible for implementing the policy 4. Compliance with related policies and agreements 5. Personal use of social media 6. Monitoring 7. Business use of social media 8. Recruitment 9. Responsible use of social media

Company Handbook 1. Who is covered by the policy? 1.1 This policy covers all individuals working at all levels and grades, including senior Managers, officers, directors, employees, consultants, contractors, trainees, homeworkers, part-time and fixed-term employees, casual and agency staff [and volunteers] (collectively referred to as staff in this policy). 1.2 Third parties who have access to our electronic communication systems and equipment are also required to comply with this policy. 2. Scope of the policy 2.1 This policy deals with the use of all forms of social media, including Facebook, LinkedIn, Twitter, Wikipedia, all other social networking sites, and all other internet postings, including blogs. 2.2 It applies to the use of social media for both business and personal purposes, whether during office hours or otherwise. The policy applies regardless of whether the social media is accessed using our IT facilities and equipment or equipment belonging to members of staff. 2.3 Breach of this policy may result in disciplinary action up to and including dismissal. Disciplinary action may be taken regardless of whether the breach is committed during working hours, and regardless of whether our equipment or facilities are used for the purpose of committing the breach. Any member of staff suspected of committing a breach of this policy will be required to co-operate with our investigation, which may involve handing over relevant passwords and login details. 2.4 Staff may be required to remove internet postings which are deemed to constitute a breach of this policy. Failure to comply with such a request may in itself result in disciplinary action. 3. Personnel responsible for implementing the policy 3.1 All Managers have a specific responsibility for operating within the boundaries of this policy, ensuring that all staff understand the standards of behaviour expected of them and taking action when

behaviour falls below its requirements. Managers will be given training in order to do this. 3.2 All staff are responsible for the success of this policy and should ensure that they take the time to read and understand it. Any misuse of social media should be reported to (insert name). 4. Compliance with related policies and agreements 4.1 Social media should never be used in a way that breaches any of our other policies. If an internet post would breach any of our policies in another forum, it will also breach them in an online forum. For example, employees are prohibited from using social media to:

a) Breach our Electronic information and communications systems policy; b) Breach our obligations with respect to the rules of relevant regulatory bodies; c) Breach any obligations they may have relating to confidentiality; breach our Disciplinary Rules; d) Defame or disparage the organisation or its affiliates, customers, clients, business partners, suppliers, vendors or other stakeholders; e) Harass or bully other staff in any way OR breach our Anti-harassment and bullying policy; f) Unlawfully discriminate against other staff or third parties OR breach our Equal opportunities policy; g) Breach our Data protection policy (for example, never disclose personal information about a colleague online); h) Breach any other laws or ethical standards (for example, never use social media in a false or misleading way, such as by claiming to be someone other than yourself or by making misleading statements).

4.2 Staff should never provide references for other individuals on social or professional networking sites, as such references, positive and negative, can be attributed to the organisation and create legal liability for both the author of the reference and the organisation.

Company Handbook 4.3 Employees who breach any of the above policies will be subject to disciplinary action up to and including termination of employment. 5. Personal use of social media Personal use of social media is never permitted during working time or by means of our computers, networks and other IT resources and communications systems. 6. Monitoring 6.1 The contents of our IT resources and communications systems are our property. Therefore, staff should have no expectation of privacy in any message, files, data, document, facsimile, telephone conversation, social media post conversation or message, or any other kind of information or communications transmitted to, received or printed from, or stored or recorded on our electronic information and communications systems. 6.2 We reserve the right to monitor, intercept and review, without further notice, staff activities using our IT resources and communications systems, including but not limited to social media postings and activities, to ensure that our rules are being complied with and for legitimate business purposes and you consent to such monitoring by your acknowledgement of this policy and your use of such resources and systems. This might include, without limitation, the monitoring, interception, accessing, recording, disclosing, inspecting, reviewing, retrieving and printing of transactions, messages, communications, postings, log-ins, recordings and other uses of the systems as well as keystroke capturing and other network monitoring technologies. 6.3 We may store copies of such data or communications for a period of time after they are created, and may delete such copies from time to time without notice. 6.4 Do not use our IT resources and communications systems for any matter that you wish to be kept private or confidential from the organisation. For further information, please refer

to our Electronic information and communications systems policy. 7. Business use of social media 7.1 If your duties require you to speak on behalf of the organisation in a social media environment, you must still seek approval for such communication from your Manager, who may require you to undergo training before you do so and impose certain requirements and restrictions with regard to your activities. Likewise, if you are contacted for comments about the organisation for publication anywhere, including in any social media outlet, direct the inquiry to a Director and do not respond without written approval. 7.2 The use of social media for business purposes is subject to the remainder of this policy. 8. Recruitment We may use internet searches to perform due diligence on candidates in the course of recruitment. Where we do this, we will act in accordance with our data protection and equal opportunities obligations. 9. Responsible use of social media 9.1 The following sections of the policy provide staff with common-sense guidelines and recommendations for using social media responsibly and safely. 9.2 Protecting our business reputation: a) Staff must not post disparaging or defamatory statements about: (i) Our organisation; (ii) Our clients; (iii) Suppliers and vendors; and (iv) Other affiliates and stakeholders, but staff should also avoid social media communications that might be misconstrued in a way that could damage our business reputation, even indirectly.

b) Staff should make it clear in social media postings that they are speaking on their own behalf. Write in the first person and use a personal e-mail address when communicating via social media.

Company Handbook

c) S taff are personally responsible for what they communicate in social media. Remember that what you publish might be available to be read by the whole world (including the organisation itself, future employers and social acquaintances) for a long time. Keep this in mind before you post content.

9.3 Respecting intellectual property and confidential information:

a) Staff should not do anything to jeopardise our valuable trade secrets and other confidential information and intellectual property through the use of social media.

d) If you disclose your affiliation as an employee of our organisation, you must also state that your views do not represent those of your employer. For example, you could state, â&#x20AC;&#x153;the views in this posting do not represent the views of my employerâ&#x20AC;?. You should also ensure that your profile and any content you post are consistent with the professional image you present to clients and colleagues.

b) I n addition, staff should avoid misappropriating or infringing the intellectual property of other companies and individuals, which can create liability for the organisation, as well as the individual author.

c) Do not use our logos, brand names, slogans or other trademarks, or post any of our confidential or proprietary information without prior written permission.

d) You are not permitted to add business contacts made during the course of your employment to personal social networking accounts, such as Facebook accounts or LinkedIn accounts.

e) Avoid posting comments about sensitive business-related topics, such as our performance. Even if you make it clear that your views on such topics do not represent those of the organisation, your comments could still damage our reputation.

f) If you are uncertain or concerned about the appropriateness of any statement or posting, refrain from making the communication until you discuss it with your Manager.

g) If you see content in social media that disparages or reflects poorly on our organisation or our stakeholders, you should contact your Manager. All staff are responsible for protecting our business reputation.

9.4 Respecting colleagues, clients, partners and suppliers:

a) Do not post anything that your colleagues or our customers, clients, business partners, suppliers, vendors or other stakeholders would find offensive, including discriminatory comments, insults or obscenity.

b) D o not post anything related to your colleagues or our customers, clients, business partners, suppliers, vendors or other stakeholders without their written permission.

Company Handbook

Ethics Policy 1. Reporting of misuse 1.1 Pepper Communications Ltd (“the Company”) is committed to the practice of responsible corporate behaviour. 1.2 Through its business practices the Company seeks to protect and promote the human rights and basic freedoms of all its employees and agents. 1.3 Further the Company is committed to protecting the rights of all of those whose work contributes to the success of the Company, including those employees and agents of suppliers to the Company. 1.4 The Company is also committed to eliminating bribery and corruption. It is essential that all employees and persons associated with the Company adhere to this policy and abstain from giving or receiving bribes of any form. 1.5 This policy is non-exhaustive, and all aspects of the Company’s business should be considered in the spirit of this policy. 2. Human Rights 2.1 The Company is vehemently opposed to the use of slavery in all forms; cruel, inhuman or degrading punishments; and any attempt to control or reduce freedom of thought, conscience and religion. 2.2 The Company will ensure that all of its employees, agents and contractors are entitled to their human rights as set out in the Universal Declaration of Human Rights and the Human Rights Act 1998. 2.3 The Company will not enter into any business arrangement with any person, Company or organisation which fails to uphold the human rights of its workers or who breach the human rights of those affected by the organisation’s activities. 3. Workers’ Rights 3.1 The Company is committed to complying with all relevant employment legislation and regulations. The Company regards such regulations and legislation as the minimum rather than the recommended standard.

3.2 No worker should be discriminated against on the basis of age, gender, race, sexual orientation, religion or beliefs, gender reassignment, marital status or pregnancy. All workers should be treated equally. Workers with the same experience and qualifications should receive equal pay for equal work. 3.3 No worker should be prevented from joining or forming a staff association or trade union, nor should any worker suffer any detriment as a result of joining, or failing to join, any such organisation. 3.4 Workers should be aware of the terms and conditions of their employment or engagement from the outset. In particular workers must be made aware of the wage that they receive, when and how it is to be paid, the hours that they must work and any legal limit which exists for their protection and any overtime provisions. Workers should also be allowed such annual leave, sick leave, maternity / paternity leave and such other leave as is granted by legislation as a minimum. 3.5 The Company does not accept any corporal punishment, harassment in any form, or bullying in any form. 4. Environmental Issues 4.1 The Company is committed to keeping the environmental impact of its activities to a minimum and has established an Environmental Policy in order help achieve this aim. Copies of the Environmental Policy are available in the Company handbook. 4.2 As an absolute minimum, the Company will ensure that it meets all applicable environmental laws in whichever jurisdiction it may be operating. 5. Conflicts of Interest 5.1 The Company holds as fundamental to its success the trust and confidence of those with whom it deals, including clients, suppliers and employees. Conflicts of interest potentially undermine the relationship of the Company with its partners.

Company Handbook 5.2 In order to help preserve and strengthen these relationships the Company has developed a Corporate Hospitality and Gifts Policy, which provide rules and guidelines concerning the conduct of its officers and employees aimed at minimising the possibility of conflicts of interest and at avoiding risks associated with bribery and corruption. 5.3 All officers, employees and representatives of the Company are expected to act honestly and within the law. 6. Information and Confidentiality 6.1 Information received by employees, contractors or agents of the Company will not be used for any personal gain, nor will it be used for any purpose beyond that for which it was given. 6.2 The Company will at all times ensure that it complies with all applicable requirements of data protection legislation (including, but not limited to, the Data Protection Act 1998) in force from time to time. 7. Shareholders and Investors The Company, its officers, employees and representatives are committed to ensuring that no act or omission which is within their power and which would have the effect of deliberately, negligently or recklessly misleading the shareholders, creditors or other investors in the Company occurs. 8. Suppliers and Partners 8.1 The Company expects all suppliers and partners to work towards and uphold similar ethical and moral standards. 8.2 The Company will investigate the ethical record of potential new suppliers before entering into any agreement. Further, the Company reserves the right to request information from suppliers regarding the production and sources of goods supplied.

8.3 The Company reserves the right to withdraw from any agreement or other arrangement with any supplier or partner who is found to have acted in contravention of the spirit or principles of this Ethical Policy. 9. Bribery and Corruption 9.1 The Company is fundamentally opposed to any acts of bribery and to the making of facilitation payments as defined by the Bribery Act 2010. 9.2 Employees and any other persons associated with the Company such as agents, subsidiaries and business partners are not permitted to either offer or receive any type of bribe and/or facilitation payment. 9.3 All employees are encouraged to report any suspicion of corruption or bribery within the Company in accordance with the Whistle-blowing Policy. 9.4 Should any employee or associated person be in doubt when receiving or issuing gifts and hospitality, he/she must refer to a Director 9.5 The Company uses its reasonable endeavours to implement the guidance principles on bribery management that are published, from time to time, by Secretary of State in accordance with Section 9 of the Bribery Act 2010. 9.6 If an employee or associated person is found guilty of giving or receiving a bribe, he/she will be personally criminally liable and may be subject to disciplinary action. 9.7 Anyone found guilty of bribery, will be responsible for bearing any related remedial costs such as losses, court fees or expenses.

Company Handbook

Family Related Events Policy Policy Statement The Company recognises and endorses the need for employees to be able to find a work-life balance. The following documents take account of this need together with the Company’s need for a stable and effective workforce. These documents represent an understanding between the Company and its workforce that it will make every reasonable effort to ensure the needs of working parents are met, and in return those employees will honour their commitments to the Company and not abuse its trust. CONTENTS 1. Introduction 2. Paternity Leave 3. Parental Leave 4. Adoption Leave 5. Emergency Leave 6. Requests for Flexible Working (see separate policy) 7. Maternity Leave (see separate policy) 1. Introduction The person responsible for these policies is Jake Whitford. The policies will be reviewed annually. All Managers must familiarise themselves with these policies and refer any queries to a Director. Family-related rights of employees are enshrined in legislation. Managers must be aware of these rights and that failure to properly implement them may also amount to discrimination. Managers are required to ensure they are familiar with the Company’s Equal Opportunities and Discrimination Policies and consider them alongside these policies. The Company wishes to ensure that all employees are able to access these rights without hindrance. Therefore, Managers must understand that failure to implement these policies fairly could result in disciplinary measures being taken against them. Employees entitled to these rights must act responsibly in using them. Should it come to the Company’s attention that an employee is in any way abusing these rights, then disciplinary action will be taken up to and including dismissal.

Should any employee have any concerns about how they are being treated when asserting one of these rights they should initiate a grievance under the Company’s Grievance Procedure. 2. Paternity Leave Do I Qualify For Paternity Leave? You must: a) Have or expect to have responsibility for the child’s upbringing b) Be the biological father or the mother’s husband or partner c) You must also have worked continuously for the Company for 26 weeks prior to the 15th week before the Expected Week of Confinement (EWC). How Do I Notify My Employer?

a) You must write to your immediate supervisor by the 15th week before the EWC, telling them: b) The week the baby is due c) Whether you wish to take one or two weeks’ Ordinary Paternity leave or extended Additional Paternity Leave d) When you want your leave to start

On receipt of this letter you will: a) Be asked to complete a self-certificate confirming you are eligible for paternity leave b) Receive a letter confirming the dates you wish to take as leave. How Much Leave Can I Take? You can take one or two weeks’ Ordinary Paternity leave. If you take two weeks, they must be taken together and not as separate weeks. NB leave must be taken within 56 days of the birth. You can also take up to 26 weeks Additional Paternity Leave (see below) Do I Get Paid? You are required to provide a self-certificate as evidence of your entitlement to SPP and one will be provided when you notify us of your intention to take paternity leave. You will be paid Statutory Paternity Pay (SPP) whilst on leave provided that you have completed the self-certificate and returned it to us 28 days before the start of your leave.

Company Handbook Who pays me? Your employer who is able to recover most of the SPP in the same way that SMP is recovered from the Government will pay you. Can I Change The Dates Of My Leave? You can change your mind about the start of your leave so long as you give 28 days’ notice. This won’t always be practicable, particularly if you have only changed your mind because the baby has come late or early. In those cases, you must notify us as soon as possible. What About When I Return To Work? You are entitled to return to the same job after paternity leave. 3. Additional Paternity Leave Do I qualify for Additional Paternity Leave? You will qualify for additional paternity leave if you are: • the child’s father or • is married to, the partner of, or the civil partner of the child’s mother You must also have at least 26 weeks’ continuous employment with the employer, ending with the 15th week before the expected week of childbirth, and remain in continuous employment with the employer until the week before the first week of the additional paternity leave. You must have the main responsibility (apart from the child’s mother) for the child’s upbringing. When can Additional Paternity Leave be taken? The period lasts from 20 weeks after the child is born up to one year after the birth You can take between 2 and 26 weeks leave, depending on when the child’s mother’s period of maternity leave comes to an end. It must be taken as one continuous period, in multiples of complete weeks. In effect, you “take over” the rest of the mother’s maternity leave entitlement. How do I notify my employer? You tell your line Manager/HR at least 8 weeks before you wish to take your leave setting out:

a) When you want your leave to start. b) How much leave you wish to take and the date you want it to finish.

c) Provide evidence (e.g. your child’s birth certificate) of the age of the child and your relationship with it.

If possible you should put this in writing. You will then: • Be asked to complete a self-certificate confirming you are eligible for parental leave (and if necessary confirming how much parental leave you have taken with any previous employer). • Receive a letter confirming the dates you wish to take as leave. Am I entitled to be paid during Additional Paternity Leave? If there is any remaining SMP due (because the mother returned to work before the 39 weeks were up), then you can “take over” the remaining pay The same Paternity leave and pay procedure will apply if you were to adopt, in which case either the adoptive father or mother can take the Additional Paternity Leave Procedure Stage One You write to your Manager notifying them of your wish to take Additional Paternity Leave Stage Two Your Manager will ask you to complete a certificate confirming you are eligible for parental leave Stage Three Your request will be considered and you will either: (a) Receive a letter confirming your request (b) B e invited to a consultation meeting to discuss your request. This meeting will normally be held within three days of receipt of your request. The Company accepts your general right to Additional Paternity Leave but may wish to meet with you to satisfy itself as to your entitlement in specific circumstances You are reminded that the above procedures must be followed if you want to take paternity leave. Taking time off without proper notification

Company Handbook will be considered an unauthorised absence and may lead to disciplinary sanctions.

Can the Company refuse to allow me to take my leave?

NB Additional Paternity Leave is only available if you are taking over the rest of the child’s mother’s maternity leave. Otherwise your request for Additional Paternity Leave is not valid and such an attempt to take advantage of this right could lead to disciplinary action against you

• If you are taking leave straight after your baby is born or adopted then the Company will not resist your request. You must however have given the 21 days’ notice as set out above.

Equally, if you are concerned about the way your request is handled, you should initiate a grievance under the Grievance Procedure. 4. Parental Leave Do I qualify for parental leave? You must: a) Be the natural or adoptive parent of a child or

b) Have parental responsibility for the child

c) Have worked continuously for the Company for one year

d) H ave a child under 5 years old (or 18 if the child is disabled)

How do I notify my employer? You tell your Manager 21 days before you wish to take your leave setting out:

d) When you want your leave to start.

e) How much leave you wish to take and the date you want it to finish.

f) Provide evidence (e.g. your child’s birth certificate) of the age of the child and your relationship with it.

• However, for other periods of parental leave we will consider your request and if we consider that your request is too disruptive to our business we will ask that you postpone your leave for a maximum period of 6 months. • This decision will only be taken after full consultation with you and the reasons for our decision will be set out in writing to you no more than seven days after your request for leave. How much leave can I take? • You can take thirteen weeks in total (18 weeks if your child is disabled). • It must be taken within the first five years of the child’s life. • It can only be taken as a maximum of four weeks a year. Procedure Stage One You write to your Manager notifying them of your wish to take leave (see “How do I notify my employer” above) Stage Two Your Manager will ask you to complete a certificate confirming you are eligible for parental leave Stage Three Your request will be considered and you will either: (a) Receive a letter confirming your request (b) Be invited to a consultation meeting to discuss your request. This meeting will normally be held within three days of receipt of your request

Company Handbook Stage Four-consultation meeting This meeting will discuss: • Your reasons for requiring parental leave at this time. The Company accepts that you have a right to parental leave and the discussion is only to determine whether the Company needs to postpone your leave. • The Company’s reasons for requiring a postponement of your leave. • Your comments on the Company’s reasons. Stage Five-decision Within seven days of receipt of your request the Company will write to you either granting your request or postponing your leave with reasons. Stage Six – Appeal Should you wish to appeal the decision, you should write to the Company within five days of notification of the decision. You will be invited to an appeal meeting as soon as possible after your letter has been received. The meeting will consider: • The procedure followed by the Company in coming to its decision • The reasonableness of the reasons for the Company’s decision You will be notified by letter of the result of the appeal hearing. Do I get paid? o Parental Leave is unpaid. o Any Company pension is frozen during the period of your leave What about when I return to work? You are entitled to return to the same or similar job after parental leave. Your holiday entitlement under the Working Time Regulations will have continued to accrue. However you will not accrue any other holiday entitlement You are reminded that the above procedures must be followed if you want to take Parental Leave. Taking time off without proper notification will be considered an unauthorised absence and may lead to disciplinary sanctions.

You must tell us if you have taken any parental leave with any former employers. Misinforming us of the amount of parental leave you still have owing will be viewed as a very serious matter which may lead to dismissal for gross misconduct. Parental Leave is meant to be used to care for a child. If it comes to light that your leave was used for some other reason then you will be dealt with under the Company’s normal disciplinary procedures. Equally, if you are concerned about the way your request is handled, you should initiate a grievance under the Grievance Procedure. 5. Adoption Leave NOTE: Different rules may apply for babies adopted from abroad or for foster parents adopting a child placed in their care. Adoption leave and pay is not available in circumstances where a child is not newly matched for adoption, for example when a step-parent is adopting a partner’s children. Do I Qualify For Adoption Leave? You must: a) Be newly matched with a child for adoption by an approved adoption agency

b) H ave worked continuously for your employer for 26 weeks leading into the week in which you are notified of being matched with a child for adoption.

How Do I Notify My Employer? You must write to your Manager within 7 days of being notified by your adoption agency that you have been matched with a child for adoption. You must say:

a) When the child is expected to be placed with you

b) W hen you want your adoption leave to start.

On receipt of this letter you will: Receive a letter (the 28-day letter) confirming the dates you wish to take as leave and in particular, the date on which we expect you to return to

Company Handbook work if the full entitlements to adoption leave are taken. How Much Leave Can I Take? Ordinary Adoption Leave (OAL) You can take 26 weeks OAL . Additional Adoption Leave (AAL) You can then take a further 26 weeks AAL in addition to your OAL. When Will My Leave Start? No more than 14 days before the date of placement. Can I Change My Mind About The Start Date? Yes, so long as you give the Company 28 days notice, unless that is not reasonably practicable. The Company will respond by letter giving you the new date on which your adoption leave will end (the 28-day letter). What If The Adoption Falls Through? If the child’s placement ends during the adoption leave period, you can continue adoption leave for up to eight weeks after the end of the placement. When Should I Notify The Company Of My Return? You do not have to give any notification. The date of your return will be that set out in the 28day letter already sent to you by the Company. What If I Want To Postpone My Return To The Company? Adoption Leave cannot be extended but if you are sick at the end of your adoption leave then the normal sick rules apply and you must notify the Company in the usual way. What If I Wish To Return Early? 8 weeks notice is required to return to work early. What If I Fail To Return To The Company? If you decide you don’t want to return after your adoption leave, then you should give us termination notice in the usual way. How much notice will depend on how long you have worked for us. N.B If you fail to return on the date set out in the 28-day letter, and you have not notified us of any sickness, then the normal disciplinary procedures for unauthorised absence will apply.

Do I Get Paid? You will be paid Statutory Adoption Pay (SAP) provided that you have given 28 days’ notice to us of your intention to take leave and your requirement to be paid SAP. SAP will be paid for 39 weeks in total at a current rate Who Pays Me? Your employer who is able to recover most of the SAP in the same way that SMP is recovered from the Government will pay you. Can I Change The Dates Of My Leave? You can change your mind about the start of your leave so long as you give 28 days’ notice or if that is not reasonably practicable then as soon as possible. What Happens To My Work Benefits Whilst I Am On Leave? An employee who is due to have a child placed with them for adoption, is entitled to benefit from all their contractual terms and conditions except wages or salary - throughout their entire adoption leave period, i.e. during both OAL and AAL. Your pension continues to accrue during OML and AML. However, after 39 weeks in receipt of SMP the remaining 13 of AML weeks are without pay unless this is a contractual additional benefit in which case, the pension contributions continue to accrue. Benefits like Company cars and Health Insurance will continue during OML and AML. What About When I Return To Work? You are entitled to return to the same job after OAL. If you take AAL then you are entitled to return to the same job unless that is not reasonably practicable, in which case you will be offered a suitable alternative. You are reminded that the above procedures must be followed if you want to take adoption leave. Taking time off without proper notification will be considered an unauthorised absence and may lead to disciplinary sanctions. Equally, if you are concerned about the way your request is handled, you should initiate a grievance under the Grievance Procedure.

Company Handbook What are Keeping In Touch days ? An entitlement to “keep in touch days” (up to 10 in total) are so that where employees and employers agree, a woman on maternity/ adoption leave can go into work for a few days, without loosing her right to maternity / adoption leave or a week’s statutory pay. Will you keep in contact with me whilst in leave? An employer can make reasonable contact with their employees on maternity /adoption leave to help employers plan and ease the mother’s return to work. You are reminded that the above procedures must be followed if you want to take adoption leave. Taking time off without proper notification will be considered an unauthorised absence and may lead to disciplinary sanctions. Equally, if you are concerned about the way your request is handled, you should initiate a grievance under the Grievance Procedure 6. Emergency Leave Emergency leave (time off to care for dependants) deals with very specific situations arising out of a sudden and unexpected need to care for a dependant. It does not cover: a) Ordinary domestic emergencies (e.g. a boiler bursting).

b) Longer term care of dependants. c) E mergencies relating to nondependants (e.g. neighbours, friends, tenants).

d) Non-emergencies relating to dependants (e.g. husband needs collecting from hospital after an accident).

e) Any pre-arranged events (e.g. child’s visit to GP).

It does cover: a) E mergencies relating to dependants. Dependants are spouses, children, partners, parents and other people who live with you as part of the family (e.g. an elderly live-in relative/ a foster child). Occasionally someone else might also be a dependant.

b) A n emergency would mean any situation in which there is a breakdown of the normal care situation and you are needed to take care of the immediate situation and make arrangements for longer-term care. c) Funeral arrangements and attendance at funerals of relatives. d) Unforeseen events (e.g. child hurt at school, needs immediate visit to GP).

e) Other examples include: i) A n elderly neighbour falls and breaks her leg and you are the nearest person to deal with it. ii) Y our wife goes into labour. iii) C hildminder doesn’t turn up and you need to make alternative arrangements. By their very nature, these situations often mean that you are unable to notify the Company before having to take leave. However you are required to: • Notify the Company as soon as possible (e.g. by phone from the hospital). • Tell the Company when you expect to be able to return to work. • Take only a reasonable amount of time off. For guidance, it is expected that most situations would not need more than one day’s leave. Two days might sometimes be necessary but the Company is likely to consider any more than that to be an unreasonable amount of leave. • Attend a return to work interview. Notification: You must at the first available opportunity telephone your Manager to inform them of the reason for your absence. You must at the same time inform them when you expect to return to work. If you find you cannot return as expected, you must again telephone with your new expected return. If you expect to be away for more than one day, you must speak to your Manager and follow the usual procedure for absence notification.

Company Handbook You are reminded that the above procedure must be followed if you want to be protected whilst taking emergency leave. Taking time off without proper notification will be considered an unauthorised absence and may lead to disciplinary sanctions.

Abuse of this right is a breach of trust and therefore taken very seriously by the Company. It will be dealt with under the disciplinary procedure and if proved, it will result in disciplinary sanctions up to and including dismissal being taken against you.

Whilst the Company fully endorses your right to be protected in the case of true emergencies, abuses can occur. Therefore episodes of emergency leave will be noted on your file and the Company reserves the right to discuss with you any excessive or unusual patterns of emergency leave-taking.

Equally, if you are concerned about the way your leave is handled, you should initiate a grievance under the Grievance Procedure.

Flexible Working Policy The company understands and endorses the legislative requirements enabling employees to try to find a work life balance. The organisation believes that flexible working can increase staff motivation, promote work-life balance, reduce employee stress and improve performance and productivity. This policy only covers the procedure required under the Flexible Working Regulations. Employees are expected to follow this procedure and not to abuse the rights granted to them under these Regulations. Introduction This policy looks at an employee’s rights to make a request for more flexible working hours and the procedure to follow. The policy will cover: • Eligibility • Making an Application • Considering an Application • Reaching a decision • Appealing the decision • Exceptions to the procedure and withdrawals Managers should also read the company policies on Discrimination and Equal Opportunities in conjunction with this policy. The person responsible for this policy is Jake Whitford and it will be reviewed annually.

What flexible working pattern can I apply for? You can request to: a) Change the hours you work

b) Change the pattern of hours you work

c) Change the times when you are required to work

d A request to job share

e) Work from home (whether for part of the week or for all of the week)

Do I qualify for a new flexible working pattern? a) If you are an employee

b) If you have worked for the employer for 26 weeks continuously (or more) at the date of the application

Procedure Stage One Making the application You should write to your Manager to notify them of your wish to apply for a flexible working pattern. Your letter should state:

a) The date of the application

b) The flexible work pattern you are applying for

c) What date you wish the flexible working to become effective

Company Handbook

d) How the proposed change would affect the employer, if at all, and how such effects might be dealt with e) How in your opinion, any such effect might be dealt with

f) That the application is made under the statutory right to request a flexible working pattern

g) Whether a previous application has been made, who to and if so the date when it was made

If the application does not specify all information requested we would ask you to re-submit the application with the additional information required. The timetable for the procedure will run from the date we receive the information required. Stage Two Considering the application What does the employer do? a) W e will acknowledge receipt of the application in writing immediately, stating the date the application was received

b) We may be able to agree to your request without the need for a meeting in which case we will write to you accordingly

c) I f we need to discuss your request with you before making any decision, we will hold a meeting with you. At the meeting we will discuss: • The matters set out in your application

• Any concerns we may have as to the impact on the Company

• Any questions we need to clarify what you are asking for and why

You can bring along to the meeting a fellow employee as a companion

Stage Three The decision We will inform you of our decision in writing, which will be one of the following: i) Accepting the request If we accept your request you will receive a dated document setting out: a) A description of the new flexible working pattern

b) T he date the new working pattern commences

c) Confirmation that this is a permanent change or, if agreed, the date on which this working pattern will end and what will replace it

ii) Rejecting the request If we reject your request you will receive a dated document setting out: a) The grounds for refusing the application and reasons why. The explanation will include the key facts about why we are refusing your request and under which business ground it is rejected

Stage Four The appeal If you want to appeal the decision you need to put your appeal in writing within five days of the Company’s decision We will: a) Arrange an appeal meeting to take place. You may take a companion who works for the company along to the meeting

b) I nform you of the outcome of the appeal in writing within 14 days of the meeting

If the appeal is upheld, you will receive a dated document setting out: a) A description of the new flexible working pattern

b) Details of your right to appeal

b) T he date the new flexible working pattern commences

Company Handbook If the appeal is dismissed you will receive a dated document setting out: a) the grounds for the decision

2. We will consider your application withdrawn if: a) You decide to withdraw the application

b) You fail to attend to two meetings

c) You unreasonably refuse to provide the employer with the required information

b) an explanation as to why the grounds for refusal apply in the circumstances

The written notice of the appeal outcome is the employer’s final decision and is the end of the formal procedure. PLEASE NOTE 1. Will the change be permanent if accepted? Unless otherwise agreed in writing, any request that is made and accepted under the statutory right will be a permanent change to your terms and conditions of employment. You have no automatic right to change back to the previous working pattern.

In any of the above circumstances we will write to you confirming that your application is considered withdrawn You are reminded that the above procedures must be followed if you want to request flexible working. Taking time off without proper notification will be considered an unauthorised absence and may lead to disciplinary sanctions.

Grievance Procedure and Policy Purpose In order to ensure that employees have every opportunity to raise any grievances, which they may have arising out of their employment and to ensure that these grievances are properly heard and resolved, the employer has adopted this grievance procedure. Employees should not hesitate to use this procedure which has been adopted in recognition of the fact that, whilst the employer’s policies are designed to encourage good working relations, from to time there may be circumstances, due to pressure of work or otherwise, in which misunderstandings or grievances may arise concerning decisions of management or other specific situations. Redress of grievances may be sought orally or in writing in accordance with the following procedure. This procedure does not form part of any employee’s contract of employment. It may be amended at any time and the Company may depart from it depending on the circumstances of any case The person with responsibility for this Policy is Jake Whitford and any queries should in the first instance be addressed to him. This Policy will be reviewed annually.

Contents 1. Who is covered by this policy? 2. How to raise a grievance. 2.1 Stage 1 – Informal. 2.2 Stage 2 – Formal. 2.3 Stage 3 – Appeal. 1. Who is covered by the policy? The procedure applies to all employees regardless of length of service. It does not apply to agency workers or self-employed contractors. Grievances can arise for any number of reasons, including: • Harassment and bullying • Discrimination because of your race; sex; age; sexual orientation; transgender; marital status; pregnancy; religion or belief; disability • Failures to promote, train, implement pay rise 2. How to raise a Grievance. 2.1 Stage 1 - Informal A member of staff who feels that he or she has a question or grievance which concerns him or her personally and directly and which requires resolution should, in the first instance, discuss the matter with their immediate superior. The matter will then be discussed. Whilst most grievances, problems and other day-to-day issues can be resolved at this stage, the person dealing with the grievance will acquaint the

Company Handbook appropriate person of the circumstances if the matter proves not to be easy to resolve. 2.2 Stage 2 - Formal If, within seven working days of a matter having been raised at stage 1, it cannot be resolved informally or the employee considers that he or she has not been treated fairly or that the outcome is not satisfactory, then the employee may raise the matter in writing with the appropriate person, who will convene a meeting with the employee as soon as reasonably practicable. Following any necessary Investigation and discussions with appropriate individuals, a decision will be given, if reasonably practicable, within seven working days of the meeting, this decision will be communicated to the employee in writing.

2.3 Stage 3 - Appeal If the employee still considers that he/she has been unfairly treated or that the outcome is unsatisfactory, then he/she should, within seven days of receipt of the decision at stage 2, make an appeal in writing to the Managing Director. The case will then be reviewed in consultation with, if appropriate and practicable, the employee and other relevant employees. A meeting will be held with the employee within seven days, if reasonably practicable, of receipt of the appeal. Once a decision has been reached it will be communicated to the employee in writing within seven working days, if reasonably practicable, from the date of the appeal hearing. This decision will be final and recorded on the employeeâ&#x20AC;&#x2122;s personnel file. An employee has the right, at any stage of this grievance procedure, to be accompanied by a work colleague of his or her choice.

Maternity Leave and Pay Policy Purpose The Company understands and endorses its responsibilities to all of its employees who become pregnant and the contents of this Policy are intended to inform all staff as to the rights and obligations which attach to both employer and employee in regard to all maternity issues.

Pregnant employees have certain rights regarding: 1. Leave 2. Pay 3. Accrual of benefits 4. Returning to work 5. Requests for flexible working

This Maternity Policy is in place to offer assistance or support wherever possible during the employeeâ&#x20AC;&#x2122;s pregnancy and after the birth of her child. It helps to ensure that all employees (full time or part time) are aware of any benefits or entitlements that are available to pregnant employees and that the Company complies with written law.

This Policy deals with all these areas in turn.

Introduction The person with responsibility for this Policy is Jake Whitford and any queries should in the first instance be addressed to him.

All Managers should familiarise themselves with the contents of this Policy in order that they are fully aware of the procedures to be followed once notified of an employeeâ&#x20AC;&#x2122;s pregnancy. Managers should also read the Company policies on Discrimination and Equal Opportunities in conjunction with this Policy. Dealing with pregnancy-related issues can often lead the unwary into indirect discrimination. This Policy will be reviewed annually.

Company Handbook CONTENTS 1. Definitions 2. I’m pregnant – what do I do? 2.1 How to notify 2.2 How the Company will respond 3. How much maternity leave am I entitled to? 3.1 Ordinary Maternity Leave and Additional Maternity Leave (AML) 3.2 How is pregnancy related sickness dealt with? 3.3 What’s the earliest I can start my leave? 3.4 Can I change my mind about the start date? 3.5 W hen should I notify the Company of my return? 3.6 What if I want to postpone my return to the Company? 3.7 W hat if I wish to return early? 3.8 W hat if I fail to return to the Company? 4. What do I get paid? 4.1 Statutory Maternity Pay (SMP) 4.2 Maternity Allowance (MA) 4.3 How long am I paid for? 4.4 Can my employer recover SMP? 5. What happens to my work benefits whilst I am on leave? 5.1 Holidays 5.2 Salary 5.3 Pension 5.4 Other benefits 5.5 What benefits are retained during AML? 6. Returning to work 6.1 Will I get my old job back? 6.2 What if I decide not to come back? 6.3 What if I want to change my working hours? 7. Other queries 7.1 What happens if I suffer a stillbirth? 7.2 Are there any special Health and Safety concerns? 7.3 What about ante-natal care? 7.4 How do I keep in touch during my maternity leave? 8. Grievances

1. Definitions Statutory Maternity Pay (SMP) Statutory Maternity Pay (SMP) is payable to eligible employees who take maternity leave or leave employment because of pregnancy or childbirth. SMP, less tax and National Insurance Contributions, if applicable, will be paid on a monthly basis. SMP is payable only for complete weeks. 28 day letter The letter sent to you by the Company advising you of your expected return date. Expected Week of Childbirth (EWC) The Expected Week of Childbirth (EWC) is the week in which the baby is due to be born as certified by the employee’s doctor or midwife on the maternity certificate (MATB1). Qualifying Week (QW) The Qualifying Week (QW) is the 15th week before the Expected Week of Childbirth (EWC). MATB1 Certificate The MATB1 is the maternity benefit certificate given to a pregnant woman by the doctor or midwife. It states the Expected Week of Childbirth (EWC). Maternity Leave Maternity Leave is the period of time away from work due to maternity. Maternity Pay Period (MPP) The Maternity Pay Period (MPP) is the period during which SMP is payable to an eligible employee. It may start at any time from the 11th week before the EWC. Start of the MPP The MPP may start at any time from the start of the 11th week before the EWC at the employee’s discretion. The actual date of the MPP depends on when the employee starts her maternity leave. 2. I’m pregnant – what do I do? You are required to notify your line Manager as soon as possible after you have discovered you are pregnant.

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How to notify Write to your Manager stating:

a) That you are pregnant

b) The date of your EWC

c) When you wish to start your maternity leave

In order to qualify for leave, you must inform the Company at least 15 weeks before your EWC, otherwise you may lose your right to maternity leave. Should you not require leave, but only wish to receive maternity pay, then you must notify the Company 8 weeks before your EWC. 2.2 How the Company will respond Within 28 days of your letter, the Company will reply giving you details of your leave and pay entitlements and stating the date on which your maternity leave will end and you will be expected back at work. 3. How much maternity leave am I entitled to? 3.1 There are two types of leave – Ordinary Maternity Leave and Additional Maternity Leave, which add up to 52 weeks’ leave. It is also compulsory that all women take 2 weeks leave after the birth, or 4 weeks if you work in a factory. The Company will abide by its obligations in enforcing that requirement. 3.2 How is pregnancy-related sickness dealt with? Periods of pregnancy-related sickness absence shall be paid in accordance with our Sickness Absence Policy in the same manner as any other sickness absence. Periods of pregnancy-related sickness absence from the start of your pregnancy until the end of your maternity leave will be recorded separately from other sickness records and will be disregarded in any future employment-related decisions.

3.3 What’s the earliest I can start my leave? You can start your leave from 11 weeks before the EWC. If you are off sick for a pregnancy related reason in the 4 weeks before the EWC, your maternity leave will be automatically triggered, even though you may have wanted your leave to start later. 3.3 Can I change my mind about the start date? Yes, so long as you give the Company 28 days notice, unless that is not reasonably practicable, (for instance, you have given birth early or are too ill to inform us). The Company will respond by letter giving you the new date on which your maternity leave will end (the 28-day letter). 3.4 When should I notify the Company of my return? You do not have to give any notification. The date of your return will be that set out in the 28-day letter already sent to you by the Company. 3.5 What if I want to postpone my return to the Company? Maternity Leave cannot be extended but if you are sick at the end of your maternity leave then the normal sick rules apply and you must notify the Company in the usual way. 3.6 What if I wish to return early? You can do so, so long as you give us 8 weeks’ notice. 3.7 What if I fail to return to the Company? If you decide you don’t want to return after your maternity leave, then you should give us termination notice in the usual way. How much notice will depend on how long you have worked for us. N.B: If you fail to return on the date set out in the 28-day letter, and you have not notified us of any sickness, then the normal disciplinary procedures for unauthorised absence will apply. 4. What do I get paid? 4.1 Statutory Maternity Pay (SMP) Anyone is eligible for SMP who: • Has 26 weeks’ service at the 15th week before the EWC

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• Is earning above the Lower Earnings Limit (LEL) – check with HR for the current rates

• Has reached the 11th week before EWC or is confined by that date

• Has notified their employer of their pregnancy 28 days before EWC

Please note in particular that we may refuse to pay SMP if we are not notified in time. SMP is paid by your employer at 90% of your earnings for the first 6 weeks then 90% of earnings or current Statutory rate of Maternity Pay (whichever is lower) for another 33 weeks. 4.2 Maternity Allowance (MA) If you are not eligible for SMP you may be able to receive Maternity Allowance. This is not paid by your employer and you will have to contact the Benefits Agency for details. MA is paid at the same rate as SMP. 4.3

How long am I paid for? A maximum of 39 weeks as set out above.

5. What happens to my work benefits whilst I am on leave? 5.1 Holidays During your entire Maternity Leave period (52 weeks), all your holidays will continue accruing in the normal way. When holidays are taken should be discussed in advance of any leave periods to avoid confusion when returning, especially if that is in the following holiday year 5.2 Salary SMP or MA will take the place of your salary during your maternity leave. However you will retain the right to any pay increases awarded during your leave period. 5.3 Pension We will continue to make pension payments whilst you are receiving SMP. You may wish to discuss further with a Director whether you want to make your own “top-up” payments as well.

5.4 Other benefits Benefits like Company cars and Health Insurance will continue during your entire leave period. 6. Returning to work 6.1 Will I get my old job back? If you have taken only OML you are entitled to your old job back when you return, under the same terms and conditions. Any pay increases during your absence will be reflected in your pay. If you take AML, then you are entitled to go back to your own job unless it is not reasonably practicable, in which case a similar position will be offered to you. 6.2 What if I decide not to come back? You should give notice of termination in the normal way. How many weeks’ notice you should give will depend on your contract of employment. The minimum is one week’s notice for every year worked. 6.3 What if I want to change my working hours? The Company understands that the arrival of a child can necessitate changes to an employee’s working patterns. We will listen sympathetically to all requests for part-time or flexible working and will do our best to accommodate them. You are referred to the Company policy on flexible working with regard to the correct procedure. 7. Other queries 7.1 What happens if I suffer a stillbirth? If you unfortunately suffer a stillbirth after 24 weeks of pregnancy then you are automatically entitled to take maternity leave. 7.2 Are there any special Health and Safety concerns? As stated above, you will be subject to a compulsory 2 or 4 week maternity leave immediately after the birth. Your job may carry health and safety risks for a pregnant woman. Thus a risk assessment may be carried out and the Company will do its best to find you a suitable alternative job whilst you are pregnant.

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Company Handbook If you refuse to take this alternative, then we are not obliged to pay your salary. However, if there is no suitable alternative, you will be suspended on full pay until one can be found.

Shortly before you are due to return to work, the Company may invite you to have a discussion (whether in person or by telephone) about the arrangements for your return.

7.3 What about ante-natal care? You are entitled to time off to attend ante-natal care. You will be required to produce evidence of your attendance in order for your absences to be authorised.

8. Grievances The Company takes very seriously its commitment to equal opportunities and nondiscrimination. If you are concerned as to the way you are being treated by any employee or Manager and consider it is because of your pregnancy, you should make a formal grievance using the Companyâ&#x20AC;&#x2122;s Grievance Procedure.

7.4 How do I keep in touch during my maternity leave? The Company may make reasonable contact with you from time to time during your maternity leave. You may work (including attending training) for up to ten days during maternity leave without bringing your maternity leave or SMP to an end. The arrangements, including pay, would be set by agreement with your line Manager or the Human Resources Department. You are not obliged to undertake any such work during maternity leave. In any case, you must not work in the two weeks following birth.

Performance Review Policy and Procedure Purpose The Company is committed to the personal development of all its employees and expects a high standard of performance at all levels. However it recognises that sometimes performance can suffer for a variety of different reasons and therefore the following procedure has been developed in order to ascertain the reasons for poor performance and to help to correct them. PLEASE NOTE: Should the employeeâ&#x20AC;&#x2122;s poor performance be sufficiently serious, the Company reserves the right to omit the earlier stages in the Performance Review Procedure. This procedure does not form part of any employeeâ&#x20AC;&#x2122;s contract of employment. It may be amended at any time and the Company may depart from it depending on the circumstances of any case.

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The person with responsibility for this Policy is Jake Whitford and any queries should in the first instance be addressed to him. This Policy will be reviewed annually. Contents 1. Who is covered by the policy? 2. Procedure 2.1 Stage One. 2.2 Stage Two. 2.3 Stage Three. 2.4 Stage Four. 3. Conduct of the proceedings 3.1 The Review Meetings 3.2 Appeals 4. Trade Union officials and Performance Reviews 5. Changes in rules and procedure.

Company Handbook 1. Who is covered by the policy? The procedure applies to all employees regardless of length of service. It does not apply to agency workers or self-employed contractors. As stated above, the Company reserves the right to depart from the policy where appropriate 2. Procedure 2.1. Stage One Should there be concerns as to any employee’s performance an initial meeting will be held with that employee to discuss those concerns and to hear the employee’s views. The meeting will be conducted by your Manager. The employee is entitled to be accompanied to this meeting by a work colleague or Trade Union representative. Should the Company decide after this meeting that the employee’s performance needs to be addressed; a Performance Review Plan (PRP) will be drawn up with the employee, which will include relevant targets and set out a Review Period, which will be of a reasonable length of time for the employee to show improvement. Should the Company decide that the employee requires specific training or support, it will be incorporated into the PRP 2.2. Stage Two After the Review Period a Review Meeting will be held, conducted by your Manager. The employee’s progress during the Review Period will be assessed and the employee will be given the opportunity to comment. The employee is entitled to be accompanied to this meeting by a work colleague or Trade Union representative. Should the employee’s progress be unsatisfactory, a First Written Warning will be issued and a further Review Period set with relevant targets. The employee is entitled to appeal against the warning in writing within five working days of the date of the warning.

2.3 Stage Three After a further Review Period a Review Meeting will be held, conducted by your Manager. The employee’s progress during the Review Period will be assessed and the employee will be given the opportunity to make comments. The employee is entitled to be accompanied to this meeting by a work colleague or Trade Union representative. Should the employee’s progress still be unsatisfactory, a Final Written Warning will be issued and a further Review Period set with relevant targets. The employee is entitled to appeal against the warning in writing within five working days of the date of the warning. 2.4 Stage Four After the further Review Period a Review Meeting will be held, conducted by your Manager. The employee’s progress during the Review Period will be assessed and the employee will be given the opportunity to make comments. The employee is entitled to be accompanied at this meeting by a work colleague or Trade Union representative. Should the employee’s progress still be unsatisfactory, a decision to dismiss may be taken. The employee is entitled to appeal against the warning in writing within five working days of the date of the warning. 3. Conduct of the proceedings 3.1 The Review Meetings At or before the meeting the employee will be informed:

1. That he/she has the right to be represented by a colleague or Trade Union official of his/her own choice;

2. Of the failure(s) to meet required standards brought against him/her and details of any investigations that support the allegation;

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3. That he/she will be given every opportunity to explain the circumstances from his/her point of view and present any mitigating circumstances that may materially alter the Manager/supervisor’s view;

4. That the Manager/supervisor conducting the review will carefully consider any points made by the employee to ascertain whether they materially change the Company’s perceived view of the matter;

5. That if a warning is to be given, the improvements or standards of performance required be detailed, along with any time limits imposed; 6. That if the Company’s perceived view is not changed, the Manager/supervisor will confirm the outcome and the standards required;

7. That if there are any mitigating circumstances that do materially alter the position, the Manager/supervisor will confirm that the warning is not to be proceeded with;

8. That in the interests of natural justice the employee will be given an opportunity to appeal against any warning, or the procedure followed, if he/she feels it was unjust.

Where a warning is given, the employee will be informed:

1. That this is one of the stages (specify which one) of the formal procedure;

2. Of the possible consequences in terms of the remaining procedural stages and ultimately dismissal (not applicable at dismissal stages) if:

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a. There is any recurrence of the misdemeanour(s) which gave rise to the warning and/or;

b. The employee does not reach the required standard of conduct or performance within a reasonable time and maintain that standard thereafter. 3.2 Appeals When an appeal results in the decision to dismiss being rescinded, the employee will receive full back pay for the period during which the appeal was pursued. In such a case his/her contract should be reinstated to the date of dismissal. Appeal hearings will take place as soon as possible. The Company’s decision on any appeal is final. 4. Trade Union officials and Performance Reviews No disciplinary action beyond the first warning stage will be taken against an FOC or acting FOC until the circumstances of the case have been discussed with a full-time official of the Union. The only exception to this will be precautionary suspension in the event of serious misconduct being investigated. 5. Changes in rules or procedure The Company’s rules and this procedure will be reviewed periodically in the light of any developments in employment legislation or industrial relations practice. Any amendments or additional rules imposing new obligations, which become necessary as a result of such developments, will not be introduced until all employees have been informed and given reasonable notice of the changes.

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Recruitment and Selection Policy and Procedure Policy Statement The Company is committed to fair and equitable dealings with all candidates for posts and understands that ensuring the highest standards in recruitment will provide the best results both for employees and for the development and growth of the Company. Therefore it is policy that all recruitment and selection procedures will: • Be objective • Avoid discriminatory language or implications • Be open-minded • Concentrate on an individual’s skills, experience and qualifications This policy is the responsibility of Jake Whitford who will monitor its effectiveness and to whom any queries should be addressed. In general the Company will ensure that those undertaking recruitment will be properly trained in procedure and in legal requirements affecting recruitment practice, including discrimination law, Rehabilitation of Offenders, the recruitment of young people and immigration issues. It is a requirement that all recruitment takes place within the following procedural guidelines and any departure from these guidelines exposing the Company to legal claims and/or substandard appointments will be considered a disciplinary offence. Procedure Stage One – The Vacancy When a position falls vacant the appropriate management team will consider firstly whether this is an opportunity to make organisational changes. In any event the job description and person specification attached to that post will be scrutinised and updated and an objective selection criteria drawn up on the basis of these specifications. This and subsequent actions will be undertaken by a panel of no more than 3 (three) relevant recruiters, appointed in this initial stage.

Stage Two – The Advertisement Once the job description and person specification are completed, an advertisement will be placed in the appropriate media. Whilst working within appropriate parameters, the Company will ensure that this advert will appear in publications with the widest and most diverse readership to ensure all likely candidates are reached. The advert itself will be brief and state the main skills and experience required and will state that the Company is an Equal Opportunities Employer. Neutral language should be used. If a job title suggests a specific gender then it should be made clear that applications will be welcome from either sex. Nothing within an advert – including text or photos - should give the impression of a preference for a specific gender race, age or otherwise make it appear that applicants with a “protected characteristic” under the Equality Act 2010 need not apply An application form will be sent to each applicant. This form will be in a format scrutinised and approved by a Director and will avoid all discriminatory questions. Stage Three – Selection for Interview Each member of the panel will read the application forms separately and only after having made independent assessments will the panel meet to make its final choices for interview. For guidance: a) No assumptions should be made as to stereotypical requirements for a job – do not assume a woman is excluded from a job that involves heavy lifting.

b) Length of residence in the UK should not be taken into account unless essential.

c) A standard of spoken or written English that should be adequate to do the job. Higher requirements may be discriminatory.

d) Give proper consideration to those wanting to work part-time. Not to do so may be discriminatory.

e) Always consider what reasonable adjustments could be made so that a disabled candidate would be able to do

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Company Handbook the job. Also consider any reasonable adjustments that could be made so that a disabled candidate can attend an interview. When meeting to discuss final selection – panel members should check each others’ decision to ensure only fair and objective reasons are given for their choices. Stage Four – The Interview Interviews will always be before a panel of at least 2. An agreed set of questions must be put to each interviewee. These questions will be decided beforehand by the panel and will be fair and objective. Care must be taken not to ask questions that could indicate discrimination. Therefore women should not be asked about their children, their marital status, or their husband’s job. Interviewees from ethnic or religious minorities should not be asked where they are from or for details of their religious observance. An interview assessment sheet will be used to objectively score interviewees against the selection criteria. The interview will be concluded by telling the interviewee when they are likely to be given the panel’s decision. Stage Five – The Offer The panel will combine their scores to establish the most suitable candidate. The successful candidate will be offered the position by letter. It will be subject to any conditions that the Company may impose, such as satisfactory references. The offer letter will also contain a copy of the employer’s terms of employment and any ancillary documents. The candidate will be asked to sign the offer letter, indicating acceptance of the offer and receipt of the contractual documents. Disability Discrimination and Health Questionnaires It is unlawful to subject any candidate to a Health Questionnaire prior to an offer of the position. That offer can be subject to a Health Questionnaire if appropriate.

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Immigration and Race Discrimination The Company is aware of its duties under immigration legislation and recognises that unthinking observance of those duties could give rise to discrimination on the grounds of race. Therefore no assumptions are to be made as to the immigration status of any applicants and the following checks are to be made only after a decision on the successful candidate has been reached: • Prior to starting work, all new employees will be required to produce relevant documents establishing their right to work in the UK. • If no such document is produced, then the offer of employment will be withdrawn. Stage Six – Induction On starting his employment each new employee will undergo an induction procedure, which will include: • Introduction to Staff Handbook and delivery of individual copy • Introduction to Health and Safety Manual and delivery of individual copy • Explanation of the Company’s organisational structure • Discussion of any necessary initial training Unsuccessful Candidates The Company recognises that an objective and open process should include feedback to unsuccessful candidates if required. Panel members should be aware of this throughout the process and be prepared to provide constructive feedback. Any requests for feedback should be brought to the attention of a Director who will coordinate the panel’s response. Records All records produced during this process will be kept for a minimum of three months and a maximum of six months. Data Protection The Company recognises its responsibilities under the Data Protection Act to process data lawfully and will ensure all applicants are informed as to the processing of any personal data generated during this process.

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Redundancy Policy and Procedure Purpose Whilst it is the Company’s intention to develop and expand its business activities, circumstances may arise where changes in the market, technology, organisational requirements and the like, necessitate the need for redundancies. In order to minimise the impact of such reductions, the following procedure will be adopted wherever possible. It must, however, be recognised that where the needs of the business so dictate, the procedure will be adapted to the particular circumstances which prevail. Introduction The person with responsibility for this Policy is Jake Whitford and any queries should in the first instance be addressed to him. This Policy will be reviewed annually.

PROCEDURE 1. Stage One – Management Consideration Where the possibility of a reduction in the size of the workforce arises, management will enter into consultations with the Trade Union or any elected body with a view to establishing whether the proposed job losses can be achieved by means other than compulsory redundancies. Consideration will be given specifically to the following alternative options, subject to the Company’s immediate business considerations: (a) Imposing an immediate ban on further recruitment of new staff other than where this is essential and considering redeployment and/or retraining of surplus personnel.

(b) Restricting the use of subcontract labour and temporary and casual staff.

CONTENTS 1. Stage One – management (d) The implementation of temporary consideration lay-off, short-time working and/or job2. Stage Two – collective consultation sharing where appropriate. 3. Stage Three – initial announcement 4. Stage Four – provisional selection (e) Inviting applications for consideration 5. Stage Five – individual consultation for voluntary redundancy. 5.1 Individual meeting as to selection 2. Stage Two – Collective Consultation 5.2 Individual meeting as to final decision The Company: 6. Stage Six – suitable alternative employment a) Recognises its statutory obligation to 6.1 Consideration collectively consult with employee 6.2 Individual meeting representatives where it is proposed 6.3 New terms and conditions to dismiss as redundant 20 or more 7. Stage Seven – dismissal employees at one establishment within 8. Stage Eight – appeal a period of 90 days or less. 9. Redundancy payment b) Acknowledges the statutory requirements as to minimum periods of consultation.

c) In the relevant circumstances will ensure that adequate time and resources are given to allow employees to elect a sufficient number of employee representatives and will make every effort to ensure that the election is fair. Or In the relevant circumstances will ensure that adequate time and resources are given for effective consultation with any recognised Union.

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d) Acknowledges the need for individual consultation in addition to collective consultation.

3. Stage Three – Initial Announcement 3.1 Where, after due consideration of these other alternatives and any preliminary collective consultation, management considers that the need for redundancies still remains a general announcement will be made. This announcement will set out: (a) The reasons for considering possible redundancies

(b) The areas likely to be affected

(d) Any proposed draft selection matrices to be used

3.2 Employees will be asked to consider any alternatives to redundancy and present them either individually or through their representatives within a specific time period. 3.3 Individuals may be invited to a preliminary meeting with management to present their views on alternative to redundancy. 4. Stage Four – Provisional Selection If after consideration of the suggestions made by employees and/or the Union (if any) the Company decides that redundancies are still the most likely option, then a provisional selection for redundancy will be made. The scoring will be the prerogative of the management but the selection criteria used will be arrived at in consultation with any Trade Union or other employee representatives. This selection will be based on selection criteria to be decided as appropriate at the time but which are likely to include: skills; absences; disciplinary record; qualifications and will be subject always to the Company’s need to retain specific knowledge and skills and a balanced workforce. In certain circumstances (e.g. when there is a need for collective consultation) the scoring and criteria will be subject to consultation with the Union or other employee representatives.

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It should be stressed that the selection is provisional only and may be subject to change after individual consultations at Stage Five. 5. Stage Five – Individual Consultation 5.1 Individual meeting as to selection Management will then enter into immediate consultation on an individual basis with those employees provisionally selected for redundancy. All individuals provisionally selected will be given 2 days’ notice by letter of a meeting to discuss the basis of their provisional selection. They will be informed of their right to be accompanied by a Trade Union representative or work colleague of their choice. Any documentary information (e.g. their matrix scores) will be included in the letter. The meeting may adjourn in order to give the employee an opportunity to respond. Should the employee require more time a reasonable amount of time will be given. After hearing the employee’s response the Management will decide whether to confirm the individual’s role as redundant. 5.2 Individual meeting as to employer’s decision . This meeting is to inform the employee as to the Company’s decision. In the alternative, this stage may be carried out by written notification. The decision may be: a) Final; in that the individual is to be made redundant (subject to any suitable alternative employment offered at Stage Six)

b) P ostponed; in that further investigation needs to be undertaken given the individual’s representations

c) Cancelled; in that the individual s no longer at risk of redundancy

Company Handbook 6. Stage Six – Suitable Alternative Employment 6.1 Consideration Management will make every effort to seek alternative employment within the Company and, where this exists, to consider redundant employees for suitable vacancies. 6.2 Individual meeting If the Company considers there are suitable alternatives, a further meeting may take place to discuss these alternatives. Should the employee unreasonably refuse a suitable alternative, he will not be eligible for a redundancy payment. 6.3 New terms and conditions Where alternative vacancies are offered to redundant employees, new terms and conditions will be issued in line with the new job specification. Redundant employees who accept alternative employment with the Company will be entitled to a trial period in accordance with current legislation.

7. Stage Seven – No Suitable Alternatives If there are no suitable alternative positions then the employee’s redundancy is confirmed and details of the employee’s redundancy and notice pay and their right to appeal will be provided. (In certain circumstances where it is considered appropriate and employees may leave with payment in lieu of notice). 8. Stage Eight - Appeal If the employee elects to go to appeal, their case will be heard by a senior Manager who has not been involved in the earlier processes. 9. Redundancy payment Employees dismissed on the grounds of redundancy will be entitled to a statutory redundancy payment as set out in existing legislation. Currently, statutory redundancy payments are based on an employee’s age and length of service. All employees who receive redundancy payments will be given a written notification of the way in which their redundancy pay has been calculated.

Sickness Absence Policy Purpose The Employer understands and endorses its duties to ensure the health and well being of its employees and will act with due care when dealing with employees absences due to illhealth. In particular the employer takes notice of the provisions of the Equality Act.

Contents 1. Who is covered by the policy? 2. Procedure for short term sickness absence. 3. P rocedure for persistent short term absence. 4. Procedure for long-term sickness absence.

The Employee has a duty to comply with Company Rules regarding sickness absence and not to abuse the same.

1. Who is covered by the policy? The procedure applies to all employees regardless of length of service. It does not apply to agency workers or self-employed contractors.

This procedure does not form part of any employee’s contract of employment. It may be amended at any time and the Company may depart from it depending on the circumstances of any case. The person with responsibility for this Policy is Jake Whitford and any queries should in the first instance be addressed to him. This Policy will be reviewed annually.

2. Procedure for short-term sickness absence a) On going sick you must telephone your manager within half an hour of your start time to inform the Company of (i) the nature of your illness (ii) how long you are likely to be off.

b) If you are off sick for more than 7 days you must obtain a GP’s certificate and present it to your manager at the earliest opportunity.

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c) I f you are off sick for 7 days or less you must complete the Companyâ&#x20AC;&#x2122;s selfcertification form on your return.

d) On your return, a return to work interview will be conducted and a note made for retention on your file.

If you do not comply with the above requirements your absences will be unauthorised and will give rise to disciplinary action, which could lead to your dismissal.

Persistent and/or unreasonable short-term sickness absences will be dealt with as either a disciplinary matter or under the long-term sickness procedure as appropriate and could lead to your dismissal. 4. Procedure for long-term sickness absences a) On first going sick you must comply with 2a) to 2c) above.

3. Procedure for persistent short-term sickness absences a) O n each occasion when going off sick you must comply with 2a) to 2d) above.

b If your sickness absences are significantly worse than your colleagues, or if they show an underlying pattern (e.g. being grouped around weekends or bank holidays), then the following procedure will be followed:

c) Stage One - After initial assessment of the problem, your manager will conduct an interview with you to inform you of the Employerâ&#x20AC;&#x2122;s concerns and to hear your explanation. This is part of the investigative process and you will be informed that the conclusions of the investigation may include a decision to take disciplinary action.

d) Stage Two - If your manager decides that there appears to be an underlying medical problem, you will be invited to a further meeting to discuss this and will be asked to consent to a medical report on your condition being obtained. You may be accompanied at this meeting. Subsequent stages are as set out for long-term sickness.

If your manager decides that these absences are unacceptable, you will be invited to a further meeting and informed that you are receiving a formal warning. A review period will be set with targets with regard to sickness absences. The warning will confirm what further action will be taken should your record of absence not improve.

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b) T he Employer recognises that illness can sometimes mean that you need to take a substantial amount of time off work. However this can cause the Employer difficulties and it is important to ascertain how long you are likely to be off. Certain positions are more difficult to hold open than others and this will be taken into consideration when operating the following procedure.

c) Stage One - After a certain period of time, if there is no sign that you are able to return to work in an identifiable period, the Employer will write to invite you to attend an interview to discuss the situation. You are entitled to bring a companion to that meeting. You may be asked at the meeting to consent to the obtaining of a medical report on your condition and how it affects your ability to continue to do your job.

d) Stage Two - On receipt of the report, it will be discussed with you. You are entitled to be accompanied at this meeting.

The Employer must decide: i. Whether you are disabled as defined by the Equality Act

ii. Whether there are reasonable adjustments that can be made, or alternative work offered, which will enable you to return to work;

iii. T he impact of your continued absence on the Company. This will all be discussed with you at this meeting.

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e) S tage Three - You will be informed of the Employerâ&#x20AC;&#x2122;s decision by letter. This decision is likely to fall into one of the following categories: i. A review period during which an additional medical report may be obtained or

ii. No reasonable adjustments or alternative job can be found and your continued absence is causing difficulties, therefore a decision has been taken to dismiss you or

iii. It has been agreed with you that you will return to work within a certain period with/without reasonable adjustments or an offer of an alternative job being made.

Although every effort will be made by the Employer to ensure that you can return to work, your continued incapacity is likely after a full investigation to lead to your dismissal

Stress at Work Policy Purpose The Company are committed to protecting your health, safety and well-being and that of all those who work for us. We will endeavour to maintain a working environment in which everyone treats one another with dignity and respect and is able to co-operate with and trust their colleagues. The Company recognise that, whatever its source, stress is a health and safety issue in the workplace. We acknowledge the importance of a supportive environment and working culture and of identifying and reducing workplace stress. This policy does not form part of any employeeâ&#x20AC;&#x2122;s contract of employment and it may be amended at any time. Any breach of this policy will be taken seriously and may result in disciplinary action. Introduction The person with responsibility for this Policy is Jake Whitford and any queries should in the first instance be addressed to him. This Policy will be reviewed annually.

CONTENTS 1. What is stress? 2. Legal obligations 3. Who is covered by this policy? 4. Scope and purpose of the policy 5. P ersonnel responsible for implementation of the policy 6. Resolving cases of stress at work 7. Absence due to stress 8. Confidentiality 9. Protection for those reporting stress or assisting with an investigation 1. What is stress? 1.1. Stress is the adverse reaction experienced in response to excessive pressures or demands. Stress is not an illness but, sustained over a period of time, it can lead to mental and/or physical illness. 1.2. There is an important distinction between working under pressure and experiencing stress. Certain levels of pressure are acceptable and normal in every job. They can improve performance, enable individuals to meet their full potential and provide a sense of achievement and job satisfaction. However, when pressure becomes excessive it produces stress. 1.3. Pressures outside the workplace, whether the result of unexpected or traumatic events such as accidents, illness, bereavement, family breakdown or financial worries, can result in stress. They can also compound normal workplace pressures.

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Company Handbook 1.4. We recognise that what triggers stress and the capacity to deal with stress vary from person to person. Individuals react to similar situations in different ways. 2. Legal obligations 2.1. We have a legal duty to take reasonable care to ensure that your health is not put at risk by excessive pressures or demands arising from the way work is organised. 2.2. This policy takes account of our obligations under the Health and Safety at Work etc Act 1974, Management of Health and Safety at Work Regulations 1999, Employment Rights Act 1996, Protection from Harassment Act 1997, Working Time Regulations 1998 and Equality Act 2010. 3. Who is covered by the policy? 3.1. This policy covers all individuals working at all levels and grades, including senior Managers, officers, directors, employees, consultants, contractors, trainees, homeworkers, part-time and fixed-term employees, casual and agency staff [and volunteers] (collectively referred to as staff in this policy). 3.2. Third parties who enter the workplace (including customers and visitors) are also required to comply with this policy. 4. Scope and purpose of the policy 4.1. We are committed to identifying, tackling and preventing the causes of work-related stress and to providing appropriate support and consideration to staff suffering from stress, on a confidential basis where appropriate. 4.2.

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We are committed to: 4.2.1. Promoting a culture of open communication, participation and encouragement. Through training, effective planning and allocation of workloads and ensuring feedback is provided on performance, we want staff to develop their skills and confidence and to feel able to raise any concerns they have about their work or working environment. 4.2.2. U sing staff development, staff support systems and policies

reflecting current good practice to help staff understand and recognise the causes of stress and to address work-related stress and the impact of external stress at work.

4.2.3. Providing a workplace free from harassment, bullying and victimisation.

4.2.4. Addressing violence, aggression and other forms of inappropriate behaviour through disciplinary action.

4.2.5. Ensuring risk assessments include or specifically address workplace stress.

4.2.6. Maintaining an appraisal process to ensure the suitability of workloads, supported by a capability procedure.

4.2.7. Facilitating requests for flexible working where reasonably practicable [in accordance with our flexible working policy].

4.2.8. Following comprehensive change management procedures.

4.2.9. Providing support [services, such as occupational health,] for staff affected by or absent by reason of stress.

5. Personnel responsible for implementation of the policy 5.1. Recognition of stress as a genuine problem requires management support and action. Those working at management and supervisory level have a specific responsibility to:

5.1.1. Participate in the culture of open communication and encouragement, ensure that staff they manage receive training, effectively plan and allocate workloads and provide feedback on performance.

5.1.2. Monitor workloads and reallocate work where necessary.

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5.1.3. E nsure that staff they manage understand the standards of behaviour expected of them and others and act on behaviour that falls below those standards.

5.2. To facilitate this process, Managers are encouraged to seek advice on how to recognise stress in the staff they manage. 5.3. However, all members of staff are responsible for the success of this policy and must ensure that they: 5.3.1. F amiliarise themselves with the policy and act in accordance with its aims and objectives. 5.3.2. P lan and organise their work to meet personal and organisational objectives. 5.3.3. S peak to their Manager if they experience or are aware of a situation that may lead to a stress problem. 5.3.4. Co-operate with support, advice and guidance they may be offered by. 6. Resolving cases of stress at work 6.1. If you believe you are suffering from stress you should discuss this with your Manager in the first instance. 6.2. Once an issue affecting your health comes to the attention of your Manager, steps will be taken to address that issue. Those steps may include any of the following: 6.2.1. A workload review, reallocation of work, monitoring of future workload or possible redeployment. Our Capability Procedure may be applied. 6.2.2. W here appropriate, investigation under our Disciplinary and/or Grievance Procedures. 6.2.3. R eferral for medical advice AND/OR a medical report to be provided by the Occupational Health Department OR our medical advisers AND/OR the GP and any medical specialist treating the member of staff concerned. 6.3. If you are on sickness absence, discussion of an appropriate return to work programme. Our Sickness Absence Policy may be applied.

7. Absence due to stress If you are absent due to stress you should follow the sickness absence reporting procedure contained in (your contract AND/OR our Sickness Absence Policy). 8. Confidentiality 8.1. Confidentiality is an important part of this policy. Every member of staff is responsible for observing the high level of confidentiality that is required, whether they are suffering from stress, supporting a colleague who is suffering from stress or because they are otherwise involved in the operation of a policy or procedure dealing with stress. 8.2. Breach of confidentiality may give rise to disciplinary action. 8.3. However, there are occasions when matters reported by a member of staff suffering from stress may have to be put to third parties. For example, where duties need to be reallocated within a team or where, as the result of reported bullying or misconduct, a disciplinary investigation and/or proceedings take place. If this is the case, matters will be discussed with the member of staff concerned before any action is taken. 9. Protection for those reporting stress or assisting with an investigation 9.1. Staff who report that they are suffering from stress, who support a colleague in making such a report or who participate in any investigation connected with this policy in good faith will be protected from any form of intimidation or victimisation. 9.2. Any member of staff who considers that they have been subjected to any such intimidation or victimisation should seek support from their line Manager. They may alternatively or additionally raise a complaint in accordance with our Grievance Procedure. Any member of staff who is, after investigation, found to have acted in bad faith or to have provided false information will be subject to action under our Disciplinary Procedure.

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Whistle-blowing Policy and Procedure Purpose It is important to the business that any fraud, misconduct or other wrongdoing by workers or officers of the Company is reported and properly dealt with. The Company therefore encourages all individuals to raise any concerns that they may have about the conduct of others in the business or the way in which the business is run. This policy sets out the way in which individuals may raise any concerns, how those concerns will be dealt with and reassures the workers that they will suffer no detriment as a result of raising their concerns. This policy does not form part of any employee’s contract of employment and it may be amended at any time. Any breach of this policy will be taken seriously and may result in disciplinary action. Introduction The person with responsibility for this Policy is Jake Whitford and any queries should in the first instance be addressed to him. This Policy will be reviewed annually. CONTENTS 1. Who is covered by the policy? 2. What is whistle-blowing? 3. Raising a whistle-blowing concern 4. Confidentiality 5. External disclosures 6. Investigation and outcome 7. If you are not satisfied 8. Protection and support for whistle-blowers 9. Responsibility for the success of this policy 10. Contacts

These are referred to ‘Whistle-blowing’ and may include: a) a criminal offence; b) a miscarriage of justice; c) an act creating risk to health and safety; d) an act causing damage to the environment; e) a breach of any other legal obligation; f) concealment of any of the above;

2.2. A whistle-blower is someone who has a genuine concern in respect of any of the activities set out in 2.1. If you have a genuine concern that there is any wrongdoing in the Company you should report it under this policy. 2.3. This policy should not be used for complaints relating to your own personal circumstances, such as the way you have been treated at work, or alleged breaches of your contract of employment. In those cases you should use the Grievance Procedure. 2.4 The protection only extends to concerns which are raised in the public interest. 2.5 Changes made to the Whistle-blowing regulation in June 2013 removed the requirement for concerns only to be raised “in good faith”. However if you later bring a claim in the Employment Tribunal in relation to a concern which was not raised in good faith, the Tribunal has the power to reduce any compensation you may be awarded by up to 25%.

1. Who is covered by the policy? This policy covers all individuals working at all levels and grades, including senior Managers, officers, Directors, employees, consultants, contractors, trainees, homeworkers, part-time and fixed-term employees, casual and agency staff [and volunteers] (collectively referred to as staff in this policy).

3. Raising a whistle-blowing concern 3.1. We hope that in many cases you will be able to raise any concerns with your Line Manager. You may tell them in person or put the matter in writing if you prefer. They may be able to agree a way of resolving your concern quickly and effectively. In some cases they may refer the matter to the Whistle-blowing Officer.

2. What is whistle-blowing? 2.1 The Public Interest Disclosure Act 1998 amended the Employment Rights Act 1996 to provide protection for workers who raise legitimate concerns about suspected wrongdoing or dangers at work.

3.2. However, where the matter is more serious, or you feel that your Line Manager has not addressed your concern, or you prefer not to raise it with them for any reason, you should contact one of the following:

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(a) The Whistle-blowing Officer, (Insert name). (b) Our confidential [external] telephone hotline. (c) The Managing Director/CEO Contact details are set out at the end of this policy.

3.3. We will arrange a meeting with you as soon as possible to discuss your concern. You may bring a colleague or union representative to any meetings under this policy. Your companion must respect the confidentiality of your disclosure and any subsequent investigation. 3.4. We will take down a written summary of your concern and provide you with a copy after the meeting. We will also aim to give you an indication of how we propose to deal with the matter. 4. Confidentiality 4.1. We hope that staff will feel able to voice whistle-blowing concerns openly under this policy. However, if you want to raise your concern confidentially, we will make every effort to keep your identity secret. If it is necessary for anyone investigating your concern to know your identity, we will discuss this with you. 4.2. We do not encourage staff to make disclosures anonymously. Proper investigation may be more difficult or even impossible if we cannot obtain further information from you. It may also be more difficult to establish whether any allegations are made in the reasonable belief of the whistle-blower. Whistle-blowers who are concerned about possible reprisals if their identity is revealed should come forward to the Whistle-blowing Officer

body such as a regulator. It will very rarely if ever be appropriate to alert the media. We strongly encourage you to seek advice before reporting a concern to anyone external. The independent whistleblowing charity, Public Concern at Work, operates a confidential helpline. They also have a list of prescribed regulators for reporting certain types of concern. Their contact details are at the end of this policy. 5.3. Whistle-blowing concerns usually relate to the conduct of our staff, but they may sometimes relate to the actions of a third party, such as a customer, supplier or service provider. The law allows you to raise a concern with a third party, where you reasonably believe it relates mainly to their actions or something that is legally their responsibility. However, we encourage you to report such concerns internally first. You should contact your line Manager or the Company Managing Director and/CEO. 6. Investigation and outcome 6.1. Once you have raised a concern, we will carry out an initial assessment to determine the scope of any investigation. We will inform you of the outcome of our assessment. You may be required to attend additional meetings in order to provide further information. 6.2. In some cases we may appoint an investigator or team of investigators including staff with relevant experience of investigations or specialist knowledge of the subject matter. The investigator(s) may make recommendations for change to enable us to minimise the risk of future wrongdoing.

5. External disclosures 5.1. The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases you should not find it necessary to alert anyone externally.

6.3. We will aim to keep you informed of the progress of the investigation and its likely timescale. However, sometimes the need for confidentiality may prevent us giving you specific details of the investigation or any disciplinary action taken as a result. You should treat any information about the investigation as confidential.

5.2. The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external

6.4. If we conclude that a whistle-blower has made false allegations maliciously and with no belief in them , the whistle-

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Company Handbook blower may be subject to disciplinary action. 7. If you are not satisfied While we cannot always guarantee the outcome you are seeking, we will try to deal with your concern fairly and in an appropriate way. By using this policy you can help us to achieve this. If you are not satisfied with the procedure used please contact Jake Whitford. 8. Protection and support for whistle-blowers 8.1. It is understandable that whistle-blowers are sometimes worried about possible repercussions. We aim to encourage openness and will support staff who raise genuine concerns under this policy, even if they turn out to be mistaken. 8.2. Staff must not suffer any detrimental treatment as a result of raising a concern. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Whistle-blowing Officer immediately. If the matter is not remedied you should raise it formally using our

Grievance Procedure. 8.3. Staff must not threaten or retaliate against whistle-blowers in any way. Anyone involved in such conduct may be subject to disciplinary action up to and including dismissal. 9. Responsibility for the success of this policy All staff are responsible for the success of this policy and should ensure that they use it to disclose any suspected danger or wrongdoing. Staff are invited to comment on this policy and suggest ways in which it might be improved. Comments, suggestions and queries should be addressed to the Whistle-blowing Officer. 10. Contacts 1. Whistle-blowing Officer: (Jake Whitford). 2. Managing Director/CEO: (Jude Whitford).

Working Time Regulations Policy Purpose The Company endorses the need for ensuring the health and safety of its employees and other workers, in particular in relation to adequate rest and the prevention of overwork. It recognises that certain workers will have special rights in this regard. The Company itself needs a flexible workforce in the name of business efficacy and will strive to reach a balance between those competing needs within the remit of the Working Time Regulations. Introduction The person responsible for all aspects of this Policy is Jake Whitford and you should address any queries to him. This Policy will be reviewed annually.

CONTENTS 1. Who is covered by the policy? 2. How long is the average working week? 3. What are the annual leave entitlements? 4. What are the rest break entitlements? 5. Who is a night worker? 6. Records 7. Working elsewhere 8. Queries and concerns 1. Who is covered by the policy? This policy covers all individuals working at all levels and grades, including senior Managers, officers, directors, employees, consultants, contractors, trainees, homeworkers, part-time and fixed-term employees and casual (collectively referred to as staff in this policy). 2. How long is the average working week? 2.1. The working week is limited to 48 hours. 2.2. You can agree to work more than 48 hours, but you will have to sign an optout agreement with the Company. It is entirely voluntary and you can withdraw

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Company Handbook your opt-out if you give the Company 3 months’ notice. 2.3. Your hourly week is measured by taking an average over 17/26/52 weeks (depends on any collective Agreement with the GPMU or other workforce agreement). 2.4. Your hours will be measured by reference to (clock cards etc). Any falsification of these documents is a disciplinary offence. 3. What are the annual leave entitlements? 3.1. Under the WTR you are entitled to 28 days’ paid holiday, including bank holidays. 3.2. The WTR entitles you to start accruing your holiday in your first year of service at the rate of one-twelfth of your entitlement per month. 4. What are the rest break entitlements? 4.1. You are entitled to: a) 20 minutes’ break in every 6 hours worked. This break is unpaid. b) 11 hours rest in every 24 c) 24 hours rest each week (this can be extended to 48 hours every 2 weeks if preferred) 4.2.

If you are under 18 your entitlement is: a) 30 minutes every 4½ hours b) 12 hours rest in every 24 c) 48 hours every 7 days

5. Who is a night worker? 5.1. If you work between 11pm and 6 am, you are a night worker and entitled to work a maximum of 8 hours per 24.

5.2. You are also entitled to a free health assessment and if you have not been offered one you should approach the person named in this Policy. 6. Records 6.1. Records will be kept for two years showing: a) Those employees who have signed the 48 hour opt-out

b) The employee’s itemised pay statement will be used to establish that those employees without an opt-out are not working more that 48 hours per week. c) H ours worked nights and the offer of health assessments

6.2. Any falsification or failure to complete these documents will be a disciplinary offence. 7. Working elsewhere If you have a second job working elsewhere you may be working excessive hours and not receiving adequate rest breaks. The Company requires you to inform your line Manager of any other job with details of hours worked. If the Company considers that they will be in breach of the WTR as a result you will be required to curtail your second job in order to ensure compliance. 8. Queries and concerns If you have any queries or concerns about the Company’s compliance with the WTR, take it up with the person named in this Policy first. If you are still not satisfied, you should use the Company’s Grievance Procedure. Any such approach will be treated in confidence.

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EMPLOYEE’S PERSONAL PROTECTIVE EQUIPMENT ISSUE RECORD SHEET Name: Dept: Date: The Company has advised you of the following: 1. Fitted Safety Shoes – which are to be worn at all time whilst on the factory floor. 2. Ear Protection – All staff working within the factory area must wear ear protection at all times. This is provided by the company, the stock is regularly checked and re stocked as necessary. 3. Safety Glasses – safety glasses are available in the PPE Storage Room, these should be worn for your own protection whilst dealing with chemicals – the Company would not be liable for any injuries suffered if not worn as instructed. Goggles are also kept in the Personal Protective Equipment storeroom (this is located in the factory cleaning cupboard). 4. Disposal rubber gloves are kept for your use – again in the Personal Protective Equipment storeroom. 5. Masks and wipes are kept in the Personal Protective Equipment Storeroom and MUST be worn whilst dealing with chemicals. I also understand that if I were not to wear any of the above equipment the Company would not be responsible for any claims of liability if there was an injury resulting in them not being worn.

Employee Signature: Date:

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EMPLOYEE UNIFORM ISSUE RECORD SHEET Name: Dept: Date: 1. I undertake to wear the uniform in accordance with the Pepper Communications Limited Uniform Standards. 2. I understand it is my responsibility to keep the uniform clean and in good repair at my own expense. 3 If loss or damage to any item is due to my negligence, I understand that I may be liable for cost of replacement. 4 Should I leave within 6 months of issue of any uniform, I agree to have the amount deducted from any monies outstanding to me. The amount would depend on the cost of the item as listed below or at the actual cost at that moment in time. (0–6 months, 100% of cost: Polo Shirts £7.20 each, T-Shirts £4.25 each) 5 I undertake to wear safety shoes at all times whilst on the factory floor. 6 I also understand that if I were not to wear my safety shoes the Company would not be responsible for any claims of liability if there was an injury resulting in them not being worn. 7 The Company will undertake to replace uniform as and when required. Employee Signature: Date:

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Employee Acknowledgement Slip

I confirm that I have read all the policies and procedures contained within this company handbook, I understand the terms therein and consent to them:

Signed……………………………....................................... Print Name…………………………........................................................... Date………………………………......................................... Please return this acknowledgement slip to a Director / Line Manager within 7 days for retention on your personal file.

Pepper Communications Limited Beechwood Way Langage Science Park Plymouth PL7 5HH Tel: 0845 0 60 30 50 Fax: 0845 0 60 30 51 Email: hello@pepper.co.uk www.pepper.co.uk London | Bristol | Plymouth