twentysix london handbook by test26

twentysix London Staff Handbook CONTENTS

WELCOME TO THE MEDIA SQUARE GROUP OF COMPANIES GROUP MISSION STATEMENT INTRODUCTION SECTION 1 – GENERAL Equal Opportunities Training Union Membership Corporate Social Responsibility Statement SECTION 2 – POLICY OVERVIEW Health & Safety Alcohol & Illegal Substances Environmental Statement Hygiene & Housekeeping Quality Smoking Policy Internet Company Vehicle Drivers International Assignments and Transfers SECTION 3 – PERSONAL BENEFITS Salaries Pension Incentive Schemes Retirement Lateness / Absenteeism SECTION 4 - COMPANY FACILITIES Clothing & Equipment Personal Correspondence & Telephone Calls Company Mobile Phones Communications Catering Facilities SECTION 5 – POLICIES & PROCEDURES Harassment Harassment Procedures Grievance Introduction Grievance Procedure Disciplinary Rules Serious Misconduct Disciplinary Procedure Absence Procedure 1

twentysix London Staff Handbook Unsatisfactory Work Performance Procedure Redundancy Whistle Blowing Policy & Procedure SECTION 6 – ABSENCE AND SICKNESS Maternity Leave Paternity Leave Parental Leave Adoption Leave Time Off for Dependants Bereavement Leave Jury Service and Other Public Duties Flexible Working Sickness Holiday SECTION 7 – COMPANY RULES Changes in Personal Details Personnel Records Travel Expenses Other Employment Private Trading Personal Property Company Property Security Procedures Private Vehicles Personal Behaviour Betting & Gambling Raffles Collections, Sponsorships, Flag Days General Health Statements to the Media APPENDICES 1. 2. 3. 4. 5. 6. 7.

Corporate Social Responsibility Health & Safety Environmental Policy Driver Handbook Retirement Procedure Persistent Absence - Guidelines for Managers Flexible Working

FORMS Computer User Self - Assessment Checklist Personal Details Form Flexible Working Application Form 2

twentysix London Staff Handbook

Request for Paternity Leave Request for Parental Leave Return to Work Discussion Form Please note that the details in this handbook are correct at time of issue, they are, however, subject to change. The Group Human Resources will confirm the latest version.

twentysix London Staff Handbook

Dear Employee, People are the heartbeat of our organisation and the way in which we interact with employees is key to its continuing success. I am delighted therefore to share the contents of this handbook with you as it is your essential guide to working for twentysix London, part of the Media Square group of companies. We provide equal opportunities and are committed to the principle of equality regardless of race, creed, colour, nationality, religion/belief, sex, sexual orientation, disability or age. We will apply employment policies, which are fair, equitable and consistent with the skills and abilities of our employees and the needs of the business. We look to your support in implementing these policies to ensure that all employees are accorded equal opportunity for recruitment, training and promotion and, in all jobs of like work, on equal terms and conditions of employment. We will not condone any discriminatory act or attitude in the conduct of our business with the public or our employees. Acts of harassment or discrimination on the grounds of race, religion, belief, gender, sexual orientation, disability or age are disciplinary offences. We ask that you study carefully the contents of this employee handbook as, in addition to setting out our rules and regulations, it also contains a great deal of helpful information. If you feel any of the documentation needs to be improved please let us have your thoughts. We reserve the right to amend this handbook as and when appropriate. The handbook will be updated regularly to reflect any changes in legislation or company policies and you will be notified of any changes as appropriate. For the avoidance of any doubt, the definitive version will be available from Group Human Resources.

Gail Dudleston Managing Director

ABOUT MEDIA SQUARE PLC An AIM-quoted marketing services and marketing communications group, Media Square is a community of highly entrepreneurial businesses stretching across Europe, the Far East, Africa and America. We are committed to realising profit through the talent of our people. Our aim is to nurture excellence within the companies we own, encouraging a culture of collaboration within the group and maximising commercial opportunities with new and existing clients. Through a series of acquisitions, we have grown to become the fifth largest UK-based quoted marketing company, servicing more than 2,500 clients and employing 1,800 people worldwide. Our rapidly maturing business is one of the largest and best resourced of its type based in the UK today. 4

twentysix London Staff Handbook INTRODUCTION The Company will work in partnership with you and your colleagues to ensure that:-

our working environment is safe and agreeable;

everyone is kept informed regularly of progress and developments within the Company;

our organisation is staffed with individuals who have the required ability, knowledge, and aptitude for their work;

individuals are encouraged to develop their skills and participate in training so that they can make the most of any opportunities for promotion as they arise;

everyone works together to ensure the continuing improvement of the Company in terms of general business and production methods, quality, facilities, employee benefits and profitability

JOINING OUR ORGANISATION Job Description You may be provided with a job description for the position to which you have been appointed but amendments may be made to your job description from time to time in relation to our changing needs and your own ability. You may be required to carry out any other duties within your capacity which the Company may reasonably require. Performance and Review Our policy is to monitor your work performance on a continuous basis so that we can capitalise on your strengths, help you overcome any possible weaknesses and provide challenging development opportunities to enhance your skills and career prospects. Job Flexibility It is an express condition of employment that you are prepared, whenever necessary, to transfer to alternative departments or duties within our business. During holiday periods, etc. it may be necessary for you to take over some duties normally performed by colleagues. This flexibility is essential as the type and volume of work is always subject to change, and it allows us to operate efficiently and gain maximum potential. You may be required to work at any other premises occupied by the Company (or any customer or client of the Company) within the United Kingdom as directed by the Company and be expected to perform all reasonable tasks assigned to you which you are competent to perform. This includes compliance with all directions given to you by your line manager and to observe all the rules and regulations from time to time laid down by the Company in relation to those tasks, such as manning levels, flexible working practices and allocation of tasks. You will be provided with such training as considered necessary to enable you to comply with this flexible working policy and to ensure all Health & Safety requirements are met. The payment structure in place recognises and rewards skill acquisition and multi-skilling. 5

twentysix London Staff Handbook Mobility Although you are usually employed at one particular site it is also a condition of your employment that you are prepared, whenever applicable, to travel as required by the needs of our business. This may include travel outside the UK. The mobility is essential to the smooth running of our business. Right to Hold Personal Data As part of your Terms and Conditions of Employment, you give the Company permission to collect, retain and process information about you, such as age, gender and ethnic origin. The Company will hold and use this information so that we can monitor our compliance with the law and best practice in terms, in particular, of equal opportunity and non-discrimination.

twentysix London Staff Handbook SECTION 1 – GENERAL 1 2 3 4

Equal Opportunities In Employment Training Union Membership Corporate Social Responsibility Statement

EQUAL OPPORTUNITIES IN EMPLOYMENT

The Company is committed to the fair treatment of its employees, job applicants, purchasers of the Company’s goods or users of its services, and will not unlawfully discriminate on the grounds of race, colour, ethnic or national origins, gender, religion, creed or belief, sexual orientation, marital status, responsibilities for dependants, age, physical or mental disability or offending background. The Company actively promotes equal opportunity for all with the right mix of talent, skills and potential and welcomes applications from a wide range of candidates, including those with criminal records. The Company selects all candidates for interview based on their skills, qualifications and experience. The aim of this policy is: To ensure that all purchasers of the Company’s goods or users of its services, job applicants and employees will receive equal treatment. To prevent bullying and harassment in the workplace specifically addressed at sexual and racial harassment, harassment on the grounds of religion, creed or belief, age, disability, sexual orientation or marital status. 2.

TRAINING

At the commencement of your employment you will receive on-the-job training specific to your role, and as your employment progresses your skills may be extended to encompass new job activities within the business. The Company recognises its employees as its most valuable asset and is committed to the development of all its employees in line with the business needs. 3.

UNION MEMBERSHIP

Every employee shall have the following rights:to be a member of such trade union as he/she may choose; not to be a member of a trade union or other organisation of workers, or to refuse to be a member of any particular trade union or other organisation of workers; where he/she is a member of a trade union, at any appropriate time to take part in the activities of the trade union (including any activities as or with a view to becoming an official of the trade union) and to seek or accept appointment or election and (if appointed or elected) to hold office as such an official. -

Any activities as a union official will not normally be carried out during Company time, but if, with management approval they are, they will be unpaid. 7

twentysix London Staff Handbook The Company does not recognise a trade union for the purposes of collective bargaining. 4

CORPORATE SOCIAL RESPONSIBILITY STATEMENT

The management of the Media Square group of companies regard corporate social responsibility as a mutual objective for all stakeholders. The objective of the policy with regard to corporate social responsibility is to provide a reference point to guide stakeholders, including all employees, on the elements that drive the conduct of Company business and relationships in the world in which we operate. The Company recognises its corporate social responsibility commitments and this is reflected in our:-

Standards of business conduct. ( Code of Ethics ) Health and Safety. Employees. Customers. Environment. Suppliers. Community.

Heads of Department are responsible to the Managing Director for carrying out the corporate social responsibility policy within the framework of the policy. All Department Heads and Supervisors are to ensure that arrangements for corporate social responsibility within departments are up to date and accurately reflect company procedures. The full policy is attached as Appendix 1.

twentysix London Staff Handbook SECTION 2 – POLICY OVERVIEW 1. 2. 3. 4. 5. 6. 7. 8. 9.

Health and Safety Alcohol & Illegal Substances Environmental Statement Hygiene & Housekeeping Quality Smoking Policy Internet Company Vehicle Drivers International Assignments and Transfers

HEALTH AND SAFETY The Health and Safety at Work Act 1974, requires Employers to prepare and, as often as may be appropriate, revise their written statement of general policy with respect to the health and safety at work of their employees, together with the organisation and arrangement in force at the time for carrying out the policy, and to bring the statement, and any revisions, to the notice of all employees. The managing director of your company and management of the Media Square group of companies regard the promotion of health and safety measures as a mutual and essential objective for management and employees alike, at all levels. It is company policy to do all that is reasonable and practicable in securing the health and safety of employees and to protect all other persons such as customers, contractors, visitors and members of the public, in so far as they come into contact with the Company’s activities and premises. This document sets out the main principles to be applied in all the Company’s establishments. a) b) c) d) e) f) g) h) i)

Duties of Employers Duties of Employees Risk Assessments Health And Safety Personnel Health And Safety Training Fire Action First Aid VDU Users Consultation With Employees

Duties of Employers

Executive Responsibility Individual operating company managing directors have overall responsibility for health and safety for all premises. They are fully committed to fulfil the requirements of this policy document, the Health and Safety at Work Act 1974 and other relevant legislation. They have special responsibility to ensure that resources are available to implement and maintain this policy. They will ensure that everyone co-operates with them and their senior management in maintaining a safe place of work.

twentysix London Staff Handbook The managing director will periodically review the effectiveness of this policy and the personnel to whom operational responsibility for health and safety have been assigned. All directors have operational responsibilities for health and safety throughout their business, and are accountable to the managing director for the compliance and effectiveness of this policy. The Company will ensure that specific company insurance policies remain current: in particular Employers Liability, Fire and Security Risk, Plant and Engineering Services, and Public/Product Liability. The Company will also: -

Ensure that fire-fighting equipment is available and properly serviced on a regular basis. Compile emergency procedures and ensure that all employees are instructed in these procedures. Ensure that fire drills are carried out at regular intervals. Ensure that the fire authorities have site plans and have immediate access to locked areas.

The Media Squareâ&#x20AC;&#x2122;s Director of Employee Services is responsible for supervising the implementation of this policy, in conjunction with local managers. They are responsible for ensuring that the health and safety arrangements are put in place. Other duties include audit, review and monitoring the performance of, and providing consultancy on, the implementation of this policy. A report will be given to the managing director on a regular basis, following the meetings. Managers and Supervisors Departmental Managers and Supervisors are responsible to their Director for day to day compliance with this Policy throughout their particular areas. General health and safety duties apply to all managers and supervisors such as: -

Actively encourage the awareness and compliance with this policy. Ensure that all new employees attend a formal health and safety induction. Ensure risk assessments are carried out on a regular basis. Conduct safety audits and safety tours to regularly inspect the departments and working areas in their control and rectify any infringement as a matter of priority. Ensure that employees receive sufficient information, instruction and training to carry out work safely. Any change in the process must be brought to the immediate attention of all employees. Provide the correct tools and equipment for each work activity and ensure they are used only for the purpose intended and regularly checked and maintained. Carry out workplace assessment and inspections (Housekeeping) on a quarterly basis paying particular attention to â&#x20AC;&#x153;non-genericâ&#x20AC;? risks. Take remedial action concerning adverse working conditions whenever these are found to exist. All matters of concern that cannot be resolved by individuals are referred to the Local Site Manager and/or Director of Employee Services. Provide written job instructions, warning notices and signs as necessary. Give all employees proper instruction on safety rules and practices, and ensure that all rules are adhered to. Ensure that all temporary, contracted employees and visitors are well acquainted with appropriate health and safety information. Investigate, report and record all accidents and near misses, however slight. 10

twentysix London Staff Handbook MANAGERS TRAINING RESPONSIBILITIES It is the manager’s / supervisor’s responsibility to ensure that safety training, whether general or specific to tasks or individuals, is recorded accessibly in the appropriate employee file. Managers must ensure new employee induction includes details of the health and safety policy and all local rules, including fire precautions. This will also apply when employees are transferred from one job to another or from one location to another. It is the manager’s responsibility to ensure that each employee is competent to perform his or her work safely, and has received individual safety instruction associated with the work. The training or the arrangements for training of employees operating machinery is part of the manager’s responsibility. -

Duties of Employees

Each employee has a duty under the Health and Safety at work Act 1974, to care for his/her own safety and the safety of others, and to co-operate with the company to ensure a safe place of work. Employees are therefore expected to: -

Conform to Company safety rules and procedures, jointly agreed on their behalf. Use and properly maintain all safety devices and personal protective equipment provided, and to report any defects. Ensure that all office equipment is safe to use and that there is safe access to all parts of the office premises. Maintain the highest standards of housekeeping, ensuring that all electrical equipment is correctly connected and arranged in such a manner to eliminate any hazard. Learn to recognise hazards and report them promptly to managers or supervisors. Report to management any accident, incident or near miss, whether it be of personal injury or property damage. Assist in the investigation of accidents with the objective of introducing measures to prevent recurrence. When working on, or visiting client’s premises, employees shall take note of the clients’ Fire, Safety and Emergency procedures, and comply with them fully. Thoroughly read all safety documentation issued by the Company and comply with its requirements. If the employee is in any doubt as to their safe working duties, and or responsibilities, they must initially discuss the matter with their supervisor and management thereafter. Be aware of the location of the First Aiders, Fire Escape Routes and Fire Fighting Equipment. Understand the Company fire evacuation and emergency procedures and participate with their organisation. Make a positive contribution to the health and safety performance of the Company to ensure a safe and healthy working environment. Risk Assessments

All risks are assessed by the Health and Safety Department or nominated competent person and all actions to eliminate or reduce the risks are put in place. Assessments are continually reviewed and monitored. 11

twentysix London Staff Handbook d)

Health and Safety Personnel

The managing director has overall responsibility for health and safety, he/she will normally appoint a competent person to oversee health and safety on a day to day basis The following employee positions are responsible for health and safety:Director of Employee Services (Media Square Group) Operating Company CEO or Managing Director Or alternative locally appointed representative. Please see your HASAW poster for details of the appointed person in your organisation. e)

Health and Safety Training

All employees will receive health and safety induction training within the first month of employment. Refresher training on job specific tasks will take place as deemed necessary taking into account the results of risk assessments and current legislation. f)

Fire Action

In the event of a fire the alarm will sound and you must leave the building immediately by the nearest safe exit and report to the designated assembly point and wait for the incident controller to instruct you what to do. Please ensure that you are familiar with your local evacuation procedures and alarms. If you discover a fire: - Immediately operate the nearest fire alarm call point. - Attack the fire, if possible, with the appliances provided but without taking personal risks. On hearing the fire alarm: - Leave the building and report to the person in charge of assembly point. - The fire precautions officer, the deputy, or nominated person for the affected floor or department will take charge of any evacuation and ensure that no one is left in the area. - Use the nearest available exit. - Do not stop to collect personal belongings. - Do not re-enter the building. When dealing with a fire: - If a personâ&#x20AC;&#x2122;s clothing is on fire, wrap a blanket closely round them and lay them on the ground to prevent flames reaching their head. - If electrical appliances are involved, switch off the current before dealing with the fire. - Shut the doors and, if possible, the windows of the room in which the fire is discovered. It is in your own interests: - To familiarise yourself with this procedure, to know what to do in the event of a fire and how to use the fire appliances. - To make yourself familiar with all the means of escape in case of fire and to avoid any obstruction of staircases, landings and other escape routes at all times. 12

twentysix London Staff Handbook g) First Aid First aid is available through your line manager in the event of an accident. A qualified first aider will treat you and enter the details in the accident book in line with RIDDOR 95. All accidents must be reported. h)

Working with VDUs

Introduction

Visual display units (VDUs) are a common feature in our workplace. The Health & Safety (Display Screen Equipment) Regulations 1992 require employers to assess the health and safety risks of computer users at their workplace and where risks are found, to take appropriate remedial action. To encourage the prevention of problems, the following provides a guide to employees who work with VDUs and will: Answer some common questions about VDUs and healthy Suggest some simple adjustments that can be made to your workstation and screen to make them more comfortable and easy to use. ii.

Your Health & VDUs – Your Questions Answered

Am I at risk? VDU’s are blamed – often wrongly – for a wide range of health problems. In most cases, the problems do not arise from the VDUs themselves, but from the way in which they are used. The problems can be avoided altogether by the way you use your equipment and workstation, together with good workplace and job design. Can work with VDU’s affect eyesight? There is no evidence that VDU’s cause permanent damage to eyes, but intensive VDU work can make users with pre-existing problems more aware of them. This (together with other working conditions) can cause fatigue and discomfort, even to healthy eyes. Uncorrected vision defects can make work at VDUs more stressful or tiring than it should be, and correcting defects can improve comfort. Visually related problems can also be due to a badly positioned VDU or poor lighting. Drifting or flickering images can also be very tiring. I wear contact lenses. Does this cause any special problems if I work with a VDU? Users of contact lenses find any dry environment uncomfortable and the heat generated by VDUs tends to make the atmosphere drier. You may find that it helps to use tear substitute drops or alternatively, wear your glasses when using a VDU. Are aches and pains caused by a VDU? Some users may experience aches and pains in their hands, wrists, arms, neck, shoulders or back, especially after long periods of uninterrupted VDU work. Usually problems of this nature can be prevented through good workstation design and regular breaks. If problems persist, you should alert your manager.

twentysix London Staff Handbook Do VDUs give out harmful radiation? No, the Health & Safety Executive’s advice is that there is no evidence of significant radiation from VDUs and no hazard to employees. What should I do if I am pregnant? There is no evidence that work at VDUs creates a significant risk either to a pregnant woman or her baby. However, as pregnancy progresses, women may find it of particular value to pay attention to seating position and breaks, to ensure comfort. iii.

Adjusting your workstation to suit you.

What can I do to help myself? You should make full use of the adjustment facilities for your VDU and work environment to get the best from them and avoid health problems. Here are some tips: Comfortable Keyboard Operation Good positioning of wrists, arms and shoulders is very important in preventing fatigue and discomfort in the back and upper limbs. A comfortable keying position can be achieved by ensuring: Shoulders are in a relaxed position, not hunched up. Upper arms are held in roughly vertical position, parallel to the side of the body without extending forwards unduly or protruding outwards at the elbow. Forearms are held roughly horizontal, with wrists extending straight when fingers are on the home row of keys. If your desk height is fixed, it’s important to adjust your seat height to achieve optimum positioning. If the chair height has to be raised to the extent that your feet are no longer firmly planted on the floor, a footrest may be needed. Good keying technique is also important. While keying, try to ensure that the wrists are held straight without twisting to the side or bending upwards, and fingers are not overly extended. Use all you fingers and maintain a light touch on the keys: wrists should not be rested on the desk surface whilst keying. If you find this a problem then a wrist support may be needed. Good Posture Having adopted a good keying position, it’s time to consider the body posture overall. The following steps are important: Place your feet firmly on the floor (or foot rest) so that the front edge of your seat supports, but does not cut into, the underside of our knee. Adjust the height and angle of your chair to give firm support to the middle and lower back. Adopt a comfortable “straight on” position in relation to the screen, avoiding twists in the neck, body and legs. Position your screen at a comfortable viewing distance (50 to 70cms on average) and a suitable height so that the top of the screen is just below your horizontal line of sight. Any document holder should be a similar distance and in the same plane as the screen.

twentysix London Staff Handbook Place frequently used items like telephones within easy reach to minimise repetitive movement. Allocate a desk area for work which is not screen based, moving your chair to it (rather than easing over) and readjusting chair height if appropriate. Optimal Viewing Conditions Some users may occasionally experience temporary visual fatigue, leading to a range of symptoms such as red or sore eyes and headaches from using VDUs. Keeping visual fatigue to a minimum means optimising viewing conditions. Although individual needs and environment will vary, it is worth observing these guidelines where possible: The length of your screen should be orientated in line with the overhead lighting tubes. The surface of your screen should not face the window over your shoulder. Don’t place your screen with a window directly behind it when the exterior view is mostly of sky. Adjust the brightness or contrast controls to give comfortable viewing in different lighting conditions. Use blinds carefully, covering just enough window to relieve any discomfort and retracting when not strictly necessary (except the south elevation which should always be partially closed: failure to do this causes solar gain which can upset the air conditioning) Keep your screen free of dust and fingerprints. Good Working Practices No matter how good your posture, staying in one position for long periods is likely to cause discomfort. And however good the viewing conditions, visual fatigue is an inevitable side effect of concentrating hard on a finite area. Allow your body and eye muscles to stretch by: Varying work patterns where possible, to include tasks that are VDU based and tasks which are not. Varying your posture occasionally. Glancing away from the screen as often as feasible. Getting up, moving around. Taking your lunch break outside your immediate working environment. A “working with VDU’s” self assessment form is included in the forms section of this handbook (Form 1) Eyesight Defects. All employees who regularly use VDUs or display screen equipment (DSE) as part of their work are entitled to a full eye examination and eyesight test by a qualified Optometrist / Ophthalmic Medical Practitioner on request. Though the VDU does not in itself cause vision defects, users will be made more aware of existing defects. “Special corrective appliances” (normally spectacles) will be prescribed to correct vision defects at the viewing distance specifically for display screen / VDU work. Those who need special corrective appliances may include users who already use spectacles or contact lenses or others who have uncorrected vision defects. What should I do if I have any problems? Please report to your manager or your local Human Resources contact any symptoms that may be related to VDU work as soon as possible. 15

twentysix London Staff Handbook i) Consultation with Employees If you have any concerns on health and safety then raise them through your line manager. You may also approach the nominated health and safety persons at any time. For full details refer to the Health & Safety Policy attached as Appendix 2. 2.

ALCOHOL & ILLEGAL SUBSTANCES

It is the policy of the Company and its employees to provide a safe place of work, to undertake activities in a safe manner thereby not endangering others and providing such facilities and provisions to enhance the well-being of the workforce at the work place. It follows therefore, that employees who are under the influence of drugs and/or alcohol whilst at work, are directly failing in their duty of care to themselves and others at work. The Companyâ&#x20AC;&#x2122;s policy is to employ a workforce free from the illegal use of drugs either at or away from work and the influence of alcohol whilst on the job. If you are found to be in violation of this policy you will be liable to disciplinary action, which may include termination of employment, even for the first offence. It is the policy of the Company that you will not use illegal drugs or abuse legal substances or report for work while under the influence of the same. The only circumstances in which alcohol may be permitted on Company premises is in special pre authorised circumstances e.g. work related celebration and then only in minimal quantities. The bringing of any illegal or unlawful drugs or controlled substances onto the Companyâ&#x20AC;&#x2122;s premises or property, having possession of, being under the influence of, engaging in the current use, selling, attempting to sell or transfer whilst on Company business or at any time during the hours between the beginning and ending of the working day, whether on duty or not, is misconduct and you may be subject to disciplinary action or termination of employment, even for the first offence. The Company reserves the right to request you undergo professional medical screening for the abuse of drugs and/or alcohol. The use of prescribed and over-the-counter drugs which may adversely affect your performance or behaviour must be reported to your line manager upon reporting for duty so that in the event of a reaction the medication may be taken into account. Abuse of over-the-counter or prescribed drugs is prohibited. However, the company recognises alcohol and substance dependency as illnesses which are treatable and will assist where an employee with an alcohol or drug problem seeks help, advice, and treatment. Employees who suspect that they have an alcohol or drug problem, even in its early stages, will be encouraged to seek diagnosis and treatment, and no employee with an alcohol or substance abuse / drug problem will have their employment jeopardised by their request for treatment. Any records concerning an employeeâ&#x20AC;&#x2122;s alcohol or substance dependency or treatment will be treated with due confidentiality. Employees will be allowed reasonable time off for treatment recommended or endorsed by the company's health advisor.

twentysix London Staff Handbook The disciplinary or persistent absence procedures, as appropriate, will be used: for acts of gross misconduct, even where related to dependency where a dependent, or apparently dependent employee's refusal to seek diagnosis, or undertake or adhere to treatment or behavioural regimes leads to attendance, performance or misconduct problems where abuse does not stem from dependency, and results in attendance or conduct problems.

ENVIRONMENTAL STATEMENT

The Company Environmental Policy sets out all matters relating to the environment. The Company believes that concern for the environment is a fundamental part of its business strategy. All aspects of the Companyâ&#x20AC;&#x2122;s operations, from accounting and purchasing to product design, manufacturing, selling, marketing and distribution, will have an impact on the environment. The Company is committed to reducing any adverse impact by implementing a policy on control of pollution and care for the local environment. The Companyâ&#x20AC;&#x2122;s Environmental Policy is included as Appendix 3. 4.

HYGIENE & HOUSEKEEPING

In all our premises and facilities hygiene and housekeeping must be maintained in accordance with our health and safety policy. 5.

QUALITY

Our Quality Policy at Media Square is to provide our clients with a service which exactly meets their requirements in terms of creativity, timeliness, flexibility, accuracy and consistency. We have this policy because we recognise that our business depends on client satisfaction. We ensure client satisfaction by: -

Continual improvement of our people, systems, products and services Developing a customer friendly culture, through an emphasis on: - Training - Teamwork - Continuous improvement

Each one of us has a role to play in doing our best to establish client requirements and meet them in a timely and efficient way, and to achieve this we should all make adherence to our Quality Policy an integral part of our working life. Continual improvement will be achieved by free involvement of relevant people in respect of client complaints to make sure that we learn as much as possible from these occurrences in order that we may prevent them happening again.

twentysix London Staff Handbook 6. SMOKING POLICY The Company has a duty to ensure, as far as practicable, the health and safety and welfare of its employees. The Company is of the view that to allow smoking on its premises or in company motor cars or other vehicles being used on Company business is inconsistent with this duty. Employees who smoke endanger themselves and others who do not smoke through passive smoking. Smoking also has an effect on the Companyâ&#x20AC;&#x2122;s business as it increases absenteeism on the grounds of ill health, and also increases the potential of a fire. You are therefore forbidden from smoking on the Companyâ&#x20AC;&#x2122;s premises, including motor vehicles and in any other vehicle being used on Company business. Any employee who is in breach of this requirement is liable to disciplinary action. Visitors too should be asked not to smoke on the Companyâ&#x20AC;&#x2122;s premises including in any Company motor vehicles and in any other vehicle being used on Company business. Where smoking is permitted outside the building it should be away from all doors and windows. When smoking in designated areas ensure cigarettes are extinguished and discarded of properly. 7. a) b) c) d) e) f) a)

EMAIL, THE INTERNET AND IT Background Email Minimising the Potential Risk Appropriate use of the Internet and web browsing The Do's and Don'ts Appropriate use of web based Email services - The Do's and Don'ts Other Internet Services Background

This policy defines the rules concerning your access to and use of Company computers (including associated software, files and data), Email and the internet. The creation of this policy is necessary to ensure that the Company and its employees do not commit any criminal offences or breach any laws including data protection legislation. Persistent or flagrant breach of this policy may result in disciplinary action. Key Principles: -

The Company expects all employees to act responsibly with regards to the use and access to the Internet and Email.

Internet access is primarily provided for business purposes i.e. access to client web sites, research, or any other aspect that may assist the user in carrying out their work. Email is primarily for use in communicating with business contacts.

Reasonable personal use of the Internet is allowed, subject to the requirements and guidelines below, and to such extent that the personal use does not interfere with job performance.

twentysix London Staff Handbook The user, not the Company, is responsible for websites that they visit and the Email that they send and forward. -

Users should be aware that the Company reserves the right to access Email communications for business reasons. The Company also has the facilities to record website access and though it does not expect to use this facility to monitor access, it reserves the right to do so. The user should be aware that the information may be used when reviewing a user’s conduct. In the event that users are found to have accessed a website that may constitute breaking the law they may be reported to the relevant authorities.

All information must respect the privacy of individuals and comply with the Data Protection Act.

The Company respects the privacy of user’s emails. At times it may be necessary to access an email of an absent user for business purposes, this will be arranged through the IT department providing that a request is made at director or manager level. The requester must agree that reasonable care will be taken to ensure that only business related emails are read. However users must be aware there is still a risk that personal emails may be opened inadvertently and users should make receivers of emails aware of this. Business email must always take priority over personal email, however users should take the same precautions when sending and receiving either type of communication. The use of Email carries risks including: -

lost productivity due to excessive time spent online; system overload due to the size of attachments and the volume of Emails; opportunity for wrongful or accidental disclosure of trade secrets and confidential information; sabotage; remarks (even remarks which may not appear to be derogatory or abusive) can amount to harassment under the Sex or Race Discrimination Actions, Race Relations Act, Age Discrimination Regulations regardless of the sender’s intent. The Company can become vicariously liable for harassment unless it takes all reasonably practicable steps to prevent the harassment. The Company must supervise and deal with problems as they arise. Emails may be stored and may be read during audits by the Company. When using Email the use of the “delete” will not erase the Email from all locations in the Company’s I.T. systems which may be accessed at any time by the Company; the viewing and transmission of pornography by you can create an uncomfortable working environment and is unacceptable in all circumstances. This can lead to the Company being liable for harassment, if someone is subject to this discomfort. You as well as the Company can be directly liable for any damages arising from defamation. Defamation occurs when derogatory remarks are made verbally (slander) or in writing (libel); risk of copyright infringement if you download copyright articles from the internet; risk of virus transmission from the downloading of software and executable files; inadvertent formation of contracts; unauthorised access, hacking, viruses, theft and the destruction or alteration of vital data; accidental or intentional disclosure of confidential information; and negligent advice.

Minimising the Potential Risk

Business Email

The sending of obscene attachments to Emails constitutes gross misconduct for which you may be 19

twentysix London Staff Handbook summarily dismissed. - The publication of any libellous message by the sending of an Email or publication on the Internet constitutes gross misconduct for which you may be summarily dismissed. - You should take care with the content of Emails to avoid liability for defamation and must not make derogatory remarks about another person or organisation. - Highly confidential information should not be sent externally without the Company’s authority. - Email messages addressed outside of the Company are not secure, and therefore must not be used to convey sensitive, classified or confidential information. - Harassment can take place by Email, including racial and sexual discrimination. You must not send Emails containing innuendoes or sexual references which could be interpreted as intimidating, hostile or humiliating. - You should remember that material sent by you has the Company’s address on it and you should not send anything to which the Company would object. - Email may be monitored to check compliance with this policy. Personal Email The Company’s I.T. systems are primarily provided for business use. Private use should be kept to a minimum. Where private Emails are sent they should be clearly marked as private/personal Abuse of this could result in disciplinary action. The Company may from time to time intercept all communications to record and/or monitor the use of its I.T. systems to ensure compliance with this policy. d)

Internet

The Internet can have many benefits to our organisation because of the wealth of information and communication resources. However, there are also costs and potential risks if the Internet is not used properly. Use of the internet for personal purposes is discouraged during working hours. The Company may from time to time intercept all communications to record and/or monitor the use of its I.T. systems to ensure compliance with this policy. Minimising the potential risks of the Internet - You should not download obscene material or material that is likely to cause offence. - Any audio material should not be used in a manner that interferes with the work of those around you. - The downloading and/or circulation of pornography, inappropriate images, sounds, messages or non-work related data constitutes gross misconduct. “Surfing” the internet for pornography will constitute gross misconduct. - At no time during personal browsing should any Company details be entered into any site/facility on the Internet. Such details include identifications (company name, address, company Email address, phone/fax numbers, etc.) - Persistent or flagrant breach of this policy is a disciplinary matter and will be dealt with accordingly and may result in your dismissal. - If users, whilst browsing the Internet find themselves in any situation they consider to be suspicious, they should contact the I.T. department for help and clarification. e)

Computer systems

You are responsible for safeguarding your own passwords. The following are regarded as serious 20

twentysix London Staff Handbook breaches of discipline which may result in disciplinary action or dismissal: deliberately introducing a virus into the computer system or accidentally introducing a virus through usage of media which have not been checked and authorised by the Company every time before use of them in the Company’s I.T. network.; - accessing or attempting to access any area of or data on the computer system and modifying programs or data without the prior authorization from the relevant manager; - using or divulging information relating to the computer system including passwords or access codes; - loading software onto the Company’s machines without prior authorisation; - downloading software or data from the internet without prior authorisation from the I.T. Manager; - creating directories on the public computer drives without authorisation from the I.T. Manager; - copying or creating data or programs for personal use; - using privately acquired media (disks, CD’s, etc.,) on the Company machines without prior authorisation; - collecting and processing personal data on the computer and not having it registered with the Information Commissioner; and - installing, copying, distributing or using proprietary software in violation of copyright or any licensing agreement (i.e. infringing copyright laws) 8.

COMPANY VEHICLE DRIVERS

Company vehicle drivers must comply with all requirements laid down in the Drivers Handbook, attached as Appendix 4. The Company will invoke the Disciplinary Procedure against anyone contravening any of the policies and procedures detailed above, as set out in Section 5 of this employee handbook. 9.

INTERNATIONAL ASSIGNMENTS AND TRANSFERS

Media Square’s strategy is to build a world class international marketing and communications group that is capable of meeting the sophisticated demands of clients, both domestically and internationally. By creating a global centre of excellence in all disciplines we can produce the best results for our clients. Given the nature of the Group’s spread of expertise across all disciplines and territories, the Group does not anticipate the need to staff positions with non-national employees. However, in the event that non-national employees with relevant technical expertise and/or specific business knowledge are requested to transfer their skills to a Group company in a different country or location, the following policy should be used as a guideline to handling international assignments. Purpose This policy outlines the basic principles which will govern the transfer and assignment of Media Square group employees between international offices. Its aims are threefold: To establish compensation principles that are deemed to be fair and reasonable. To ensure consistent treatment of international expatriates within the group business units. To control costs through the effective management of all elements of the international assignment.

twentysix London Staff Handbook However, the company realises that different locations and personal circumstances will have an impact on the overall arrangements. To this purpose, whilst assignments should be structured in accordance with these principles, the Company may apply some flexibility where appropriate. Scope of Assignment The following business reasons will determine an international assignment: -

To set up a new business. To develop an existing business. To share skills, knowledge, technology and to train others. To apply specific client or market knowledge to an associated office. To manage a specific project.

Definitions “Home Country” – the employee’s country of origin, or from where they are transferring. “Host Country” – the country to which the employee is transferring “Cost of living differential” – the term used in relation to the measurement of differences in the cost of shopping basket comparisons between home and host countries. Differences may be “positive” (ie host country prices are higher) or “negative” (ie lower). Basic Principles -

Assignment terms and conditions will not become effective until a valid visa / work permit has been issued and immigration clearance given. The transfer must be for a business purpose (see “Scope of Assignment”). Employees requesting a transfer for personal reasons (personal transfer) will not normally be provided with assistance in transferring, with the possible exception of the host company sponsoring a visa / work permit application. The home and host countries will have absolute discretion to determine and mutually agree whether the move is driven primarily by business or personal request and any provisions set out in relation to short, medium and long term business transfers will only apply to moves that are purely business driven. The terms and conditions of each assignment will be reviewed on an annual basis to reflect any personal changes and market/business considerations. Should a temporary assignment turn into an indefinite transfer, the home country employment agreement will be terminated and a host country employment agreement will be issued. All terms and conditions, including pay and benefits, will accord with the host country practice and any assignment allowances, where applicable, will end. Where applicable, the cost of living comparisons will only be made where the cost of living is higher in the host country. As outlined above, this provision will not apply to personal transfers. After an initial settling in period, it is assumed that the employee will adopt local spending and shopping habits/consumption patterns. Rates of exchange will be based on the rate of exchange at the start of the transfer and will be adjusted if and when the rates fluctuate by more or less than 10 per cent. No expatriate bonuses will be made ie an incentive paid to encourage the employee to take up the assignment. Except for personal transfers, employees will receive a free one hour tax consultation via an approved tax accountant, where taxes are due in both countries. This will enable the employee 22

twentysix London Staff Handbook to understand the personal tax implications of the assignment. The cost of any further consultations will be met by the employee. Pay and benefits should be viewed as a whole package and considered in the context of the “host” normal provision. The Company will not always be able to provide like-for-like employee benefits. Assignments that are likely to be for a 1 to 2 year duration will be based on the assumption that the employee will be returning to the home location at the end of the assignment. Consideration will therefore be given to repatriation and suitable alternative employment. The company will seek to preserve the long term pension and social security position of the employee in their home country wherever possible. Although every effort will be made by the Company to find suitable alternative employment for the employee at the end of the assignment, this cannot be guaranteed. The Company accepts that the employee may wish to remain in the “host” country on a long term basis and to this end, will support employees in making the appropriate applications for citizenship where longer terms prospects of employment exist. However, the employee must accept that at the end of the assignment period, their pay and benefits package will be reviewed, all expatriate / transfer related benefits will cease and their legal employment relationship will transfer to the host country/company. Although the Company will retain a flexible approach to the management of international transfers to be able to respond to business critical situations, assignments should follow these principles and guidelines as closely as possible to ensure fair and consistent treatment of employees across the Group. It is noted that “expatriate” employees often share experiences and the Group supports a policy of transparency in general. However, employees must understand the overall nature of expatriate packages are determined by individual circumstances and that no package is therefore identical. Therefore, any exceptions must be clearly justifiable and understood by the relevant employee. This provides a general guideline for the treatment of international assignments. No agreements should be entered into without the involvement of your local or Group Human Resources contact in order to ascertain the full implications, cost and otherwise, relating to the transfer.

twentysix London Staff Handbook SECTION 3 – PERSONAL EMPLOYMENT MATTERS 1. 2. 3. 4. 5. 6

SALARIES PENSION INCENTIVE SCHEMES RETIREMENT LATENESS/ABSENTEEISM WORKING TIME REGULATIONS

SALARIES

Payment The pay month is the calendar month. Basic salaries are paid in arrears by the date stated in your contract of employment. However, should that day fall on a Saturday, Sunday or public holiday, the transfer will take place on the last preceding working day. You will receive a payslip showing how the total amount of your pay has been calculated. It will also show the deductions which have been made and the reasons for them, e.g. Income Tax, National Insurance. Any pay queries that you may have should be raised with your Finance Department or managing director. Overpayments If you are overpaid for any reason, the total amount of the overpayment will normally be deducted from your next payment but if this would cause hardship, arrangements may be made for the overpayment to be recovered over a longer period. Income Tax and National Insurance At the end of each tax year you will be given a form P60 showing the total pay you have received during that year and the amount of deductions for Income Tax and National Insurance. You may also be given a form P11D showing non-salary benefits. You should keep these documents in a safe place as you may need to produce them if making enquiries with the Inland Revenue or Department of Work and Pensions, or if completing a self-assessment form. The law does not allow us to issue duplicate copies. Changes to Personal Details Any changes to your personal details, address, bank details etc should be notified to your usual payroll contact on the “Personal Details Form” included in the Forms section – Form 2. 2.

PENSION

You are entitled to join a pension scheme upon commencing your employment. The Company may or may not make contributions to this pension, depending on your length of service and the scheme that is in place at the relevant time. Details of the relevant scheme are available from HR or the finance department. 24

twentysix London Staff Handbook 3.

RETIREMENT

The Company’s normal retirement age is 65 and it is our policy for employees to retire at the end of the month in which their qualifying birthday falls. The Company will follow the retirement procedure introduced as a result of the Age Discrimination legislation which includes the right for all employees to request to continue to work beyond their normal retirement age. Any extension of employment will be at the total discretion of the individual operating company. A copy of the retirement procedure is attached at Appendix 5. 4.

LATENESS/ABSENTEEISM

You must attend for work punctually at the specified time(s) and you are required to comply strictly with any time recording procedures relating to your work. All absences must be notified in accordance with the sickness reporting procedures laid down in this Employee Handbook – Section 5. You may be asked to keep a record of your working hours whilst employed on Company business. In instances where weekly time sheets may be issued – it is advisable that you keep your recorded hours up to date on a daily basis. It is imperative that all time sheets are accurately completed – if you have any queries then please talk to your Line Manager for clarification. Lateness or absence without sufficient reason or which is excessive may result in disciplinary action and/or loss of appropriate payment. 5.

WORKING TIME REGULATIONS

The Working Time Regulations 1998 provide rights and obligations relating to work and rest. The principle provisions are as follows: -

A limit on average weekly working time to 48 hours, although individuals can choose to be excluded from this (opt out) a limit on night workers average normal daily working time to 8 hours a requirement to offer health assessments to night workers minimum daily and weekly rest periods rest breaks at work paid annual leave.

The regulations also give employees aged between 16 and 18 additional rights relating to: - Health assessments for night work - Minimum daily and weekly rest periods - Rest breaks at work The regulations apply to all employees on a permanent or fixed term contract who are on the Company payroll and also to individuals providing on-going freelance or agency work if they are being paid directly by an employer and to trainees who are engaged on work experience. The regulations do not apply to the self employed. Working Time Limits and Rest Breaks 25

twentysix London Staff Handbook Employees: - should not work more than an average of 48 hours per week over a 17 week reference period. - are entitled to a rest period of 11 consecutive hours between each working day (12 hours for adolescents) and not less than 24 hours in each 7 day period (48 for adolescents). The weekly rest period may be averaged over a two week period (but not for adolescents). - are entitled to an uninterrupted break of 20 minutes when daily working time is more than 6 hours (30 minutes for adolescents working for more than 4.5 hours per day) - are entitled to at least 4 weeks paid leave each year (including public holidays). In the majority of cases employees will be invited to “opt out” of the regulations, in which case, no records of the working hours need to be kept. Employees who choose not to “opt out” must provide their manager, on a weekly basis, adequate records indicating the weekly hours worked. Failure, on behalf of the employee, to co-operate with the provision of this information, may result in disciplinary action being taken. Employees, who have “opted out” may elect to “opt in” to the regulations at any time, by giving the Company at least 3 months notice in writing.

twentysix London Staff Handbook SECTION 4 - COMPANY FACILITIES 1. 2. 3 4

PERSONAL CORRESPONDENCE AND TELEPHONE CALLS COMPANY MOBILE PHONES COMMUNICATIONS CATERING FACILITIES

PERSONAL CORRESPONDENCE AND TELEPHONE CALLS

The Company address should not be used for correspondence of a personal nature as responsibility for delivery cannot be accepted and all correspondence is liable to be opened as part of the Company mail. Outgoing personal mail may be sent through reception but must be already stamped. All employees should seek permission from their Line Manager before making personal use of the telephone; permission will not be unreasonably withheld. Use should be restricted to emergency calls only. Additionally, employees are asked to restrict incoming messages to genuine emergencies only. The use of personal mobile telephones is only permitted on a minimal basis on Company premises or in Company time unless specifically authorised by the management. 2.

COMPANY MOBILE PHONES

Mobile phones are issued to Company employees only on the basis of need. Payment will be made for mobile phones only if they have been issued by the Company and not for any other reason. Company mobile phones are primarily for business calls, private calls should be kept to a minimum. The Company may ask you for reimbursement if you make excessive private calls. Any employee, contractor or agent of Media Square or associated company, whilst driving a motor vehicle, is expressly prohibited from making or receiving, telephone calls, text or photo messages using a hand held mobile, whilst the vehicle is in motion. Additionally any drivers who have satellite navigation system in their vehicles should not programme these while the vehicle is in motion. Drivers should pull over in a safe place to enter instructions. In order to ensure compliance with this requirement, employees should ensure that their hand held mobile phones are switched off when engaging in driving activities. Drivers still risk prosecution when using hands-free phone kits if it is deemed that use of the mobile phone causes them to drive in a careless or reckless manner. Minimise the risk of taking calls on hands-free mobile phones whilst driving by using voicemail or call divert and take regular stops to check messages. Should a call need to be taken, and it is not possible to pull over and stop safely, keep the conversation to a minimum and end the call quickly. If you need to make outgoing calls, stop and find a safe place to park before making them. In addition, you should not attempt to speak to fellow employees if you know they are driving. Failure to comply with this policy will be treated as a disciplinary matter. Employees driving in the course of their duties should refer to the mobile phones use section of the driversâ&#x20AC;&#x2122; handbook.

twentysix London Staff Handbook 3. COMMUNICATIONS a)

Briefings

From time to time you will be briefed on important issues concerning your company or employment related matters including information on trading results during the previous period and other company matters of interest to employees. b)

Notice Boards

There are notice boards situated throughout the Companyâ&#x20AC;&#x2122;s premises. Employees should check their nearest one on a regular basis and read any new notice as this is how the Company announces new appointments, changes in policies and procedures as well as items of general interest. Employees must not post their own notices without the prior permission of the most senior on-site employee. C)

Circle and Circle Online

Circle is issued quarterly and Circle Online is produced bi monthly. D)

Annual and Interim Reports

These are available and are issued to staff directly. 4.

CATERING FACILITIES

Catering facilities appropriate to the size of business and the number of employees are provided; this may include smoking and non smoking canteen facilities, along with drinks machines and filtered water where appropriate.

twentysix London Staff Handbook SECTION 5 – POLICIES & PROCEDURES 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12

HARASSMENT HARASSMENT PROCEDURES GRIEVANCE INTRODUCTION GRIEVANCE PROCEDURE DISCIPLINARY RULES SERIOUS MISCONDUCT DISCIPLINARY PROCEDURE ABSENCE PROCEDURE UNSATISFACTORY WORK PERFORMANCE PROCEDURE REDUNDANCY WHISTLE BLOWING POLICY & PROCEDURE SHARE DEALING

HARASSMENT

a) b) c)

What is harassment? Examples of harassment Enforcement of this policy

What is Harassment?

Harassment is particular behaviour by one person which another person finds unacceptable or unwelcome or is unwanted conduct that has the purpose or effect of violating another person’s dignity, or creating an intimidating, hostile, degrading, humiliating or offensive environment for him / her. (b) Examples of Harassment -

physical contact verbal or non verbal conduct victimisation including but not limited to unjustified criticism that occurs on more than one occasion, punishment imposed without reasonable justification and changes in the duties or responsibilities of the employee to the employee’s detriment without reasonable justification name calling abusive language mockery jokes bullying or intimidation of a general nature or that specifically is targeted at someone because of their religion, creed or belief, gender, age, sexual orientation, disability or ethnic origin

These examples are not exclusive or exhaustive and conduct of a similar nature may be dealt with under this procedure. (c) Enforcement of this Policy The Company will treat all allegations of harassment seriously.

twentysix London Staff Handbook Acts of discrimination or harassment on grounds of race, colour, ethnic or national origin, religious belief, gender, marital status, sexual orientation, age or disability by employees of the company will result in disciplinary action being taken against the perpetrator. This includes misuse of Email. The policy applies to all who are employed in the company. You have a personal responsibility and duty to ensure the practical application of this policy and to help promote a working environment consistent with a policy of equal opportunity for all employees. You have a responsibility to ensure that you do not discriminate against or harass fellow employees, customers or suppliers during the course of your employment. You should report any discriminatory action or act of harassment of which you are aware to the Company. Consistent application of this policy will assist in the creation of the right environment for its success and it is for each employee to make his or her own contribution to ensure that this success is maintained. The management is responsible for the implementation of this policy and ensuring compliance with it. This policy will be monitored by the Company to judge its effectiveness. If changes are required the Company will implement them. 2.

HARASSMENT PROCEDURES

a) b) c)

Right to Representation Informal Procedure Formal Procedure

Right to Representation

At all formal stages of the procedure the individual has the right to be accompanied by either: -

A fellow colleague of their choice. A full-time officer employed by a trade union; or a lay union officer or workplace representative, so long as they have been reasonably certified by their union as having experience of, or as having received training in, acting as a workerâ&#x20AC;&#x2122;s companion at formal proceedings.

Employees are encouraged to report any harassment to a senior manager. a)

Informal Procedure

Under the informal procedure an employee may approach the person responsible for the harassment either directly or in writing. If an approach is made directly the employee should be accompanied by an independent representative of the Company. The employee should explain the conduct which he/she considers to be harassment, ask the person responsible to stop the conduct and explain that if the conduct is repeated the matter will be dealt with as a formal complaint. The senior manager to whom the matter is referred will ensure that a written record of any action taken, pursuant to this informal procedure is kept.

twentysix London Staff Handbook b) Formal Procedure Employees who believe that they have been subjected to harassment may also make a formal complaint about such conduct either after or instead of using the informal procedure. The complaint may initially be made orally, but must be confirmed in writing as soon as reasonably practicable. As far as is reasonably possible, the complaint should contain: -

clear specific allegations about a named person or persons dates/times of the alleged actions names of witnesses direct quotes of offensive remarks any documentary evidence a brief description of the circumstances giving rise to the complaint an explanation of why the employee considers the conduct to amount to harassment.

The employee concerned should present their complaint to a Senior Manager. All complaints will be investigated as quickly as possible by a member of the Management Team. Wherever possible, complaints will be dealt with on a confidential basis. At the conclusion of the investigation the Senior Manager or Managing Director will determine whether the complaint is well founded and sufficiently serious and, if so, it will become a disciplinary matter and will be dealt with in accordance with the Companyâ&#x20AC;&#x2122;s disciplinary procedure. The Senior Manager / Managing Director will ensure that the complainant is properly advised as to the outcome of the investigation. Where it is found that an employee has abused the Harassment Policy and has made a deliberately false or malicious allegation, he/she may be liable to disciplinary action. 3.

GRIEVANCE INTRODUCTION

a) b)

Introduction Right to Representation

Introduction

While it is the duty of all parties to ensure good working relationships, it is recognised that from time to time grievances will occur. It is believed by all concerned that grievances are best solved quickly, fairly, and as close to the source of the problem as possible, and handled in ways appropriate to the nature of the problem. It is the aim of this procedure to allow individuals to be able to raise issues with management about their employment, or about the Company, or other employeesâ&#x20AC;&#x2122; actions which affect them directly

twentysix London Staff Handbook b) Right to Representation At all formal stages of the procedure the individual has the right to be accompanied by: -

A fellow colleague of their choice.

A full-time officer employed by a trade union; or a lay union officer or workplace representative, as long as they have been reasonably certified by their union as having experience of, or as having received training in, acting as a worker’s companion at formal proceedings.

GRIEVANCE PROCEDURE

Informal Formal

Informal

In the first instance the individual should discuss the grievance with their immediate line manager. It is hoped that by dealing with grievances at the informal level initially, there will be a speedy resolution of the matter, without recourse to the formal process. If the grievance remains unresolved then the formal procedure will be adopted. b)

Formal

Stage 1 – The individual must put the grievance in writing and send it to their immediate line manager. Where the grievance is against the line manager the matter should be raised with the next manager in the line of command. The manager shall invite the individual to attend a formal hearing as soon as convenient, to discuss the grievance, reminding the individual of their rights to be accompanied by a representative of their choice (as described under “Right to Representation”). The manager will respond to the grievance as soon as possible. Where there may be a delay in responding to the grievance the manager will provide the individual with an explanation as to why, and indicate when they are likely to receive a response. Stage 2 - If the matter is not resolved at Stage 1, the individual is entitled to appeal and raise the matter in writing with a more senior manager (who will be detailed at stage 1). A further hearing will be arranged following receipt of written grievance. The individual will be reminded of their rights to be accompanied by a representative at the hearing. The manager will respond to the grievance normally within 5 working days. Where there may be a delay in responding to the grievance the manager will provide the individual with an explanation as to why, and indicate when they are likely to receive a response. Stage 3 - Failing settlement at stage 2, the individual can raise the grievance in writing with a Higher Management Official (HMO). A further hearing will be arranged as soon as is convenient, with the individual having the same rights of accompaniment. 32

twentysix London Staff Handbook The HMO will endeavour to provide a decision on the grievance within 5 working days, however, where this is not possible, will provide the individual with an explanation as to why, and indicate when they are likely to receive a response. If during the course of a disciplinary procedure an individual raises a grievance about the behaviour of another individual or a manager, depending on the circumstances it may be appropriate to suspend the disciplinary procedure for a period until the grievance has been considered. 5.

DISCIPLINARY RULES

You will be issued with the disciplinary rules specific to your organisation with your contract of employment. These should be read in conjunction with the rules below. The following rules provide a code designed to protect the interests of our employees, the public and the Company, and ensure that set standards of behaviour at work are adhered to. a) -

General Rules / Guidance on Expected Behaviour at Work Employees are required to report punctually for work at the times stated in their Contract of Employment for normal hours of work or as stated by their immediate superior for other work times such as overtime. Persistent lateness will result in the Disciplinary Procedure being invoked which could ultimately lead to dismissal. Employees are required to maintain sanitary conditions in washrooms and toilets, and also to keep their work area clean and tidy at all times. Visitors not related to the business of the Company should not be brought into the premises, without the permission of a Director. Private correspondence, private telephone calls including those received or made from mobile telephones, are only permitted on a minimal basis on Company premises or in Company time unless specifically authorised by the management. However, where a very urgent telephone call has to be made, and time to seek permission is not practical, this must be reported to the line manager as soon as possible. Collections are not permitted on the Company premises without the prior authorisation of management.

This list is not exhaustive and will not prevent disciplinary action (including dismissals for repeated breaches) being taken for any other breaches of appropriate behaviour and/or standards. Depending on the seriousness of the breach of the rules, the matters may be dealt with either informally or formally, whichever is appropriate and at the Companyâ&#x20AC;&#x2122;s discretion. Employees are also referred to the Company Rules as set out in Section 7. 6.

SERIOUS MISCONDUCT

The following are examples of serious misconduct, any of which, if proved, could result in summary dismissal or the imposition of other penalties without the operation of the standard warning procedure:-

Unauthorised use or possession of company property, or of the property of a third party, while acting or purporting to act on behalf of the Company; or theft of the property of any fellow employee. Assault on any person, while acting or purporting to act on behalf of the Company or assault on 33

twentysix London Staff Handbook any fellow employee. For the avoidance of doubt assault includes harassment or bullying of any kind. - A criminal offence, for which an employee is convicted, which detracts from the employee’s ability to carry out his or her duties or where the penalty imposed by a court of law for any offence makes it impossible or impracticable to continue in employment. This could include driving offences where the employee is disqualified from driving. - Refusal to comply with a proper instruction, or insulting behaviour towards a line manager or member of management. - Misbehaviour constituting gross misconduct at work or at Company social events, such as drunkenness, acting under the influence of illegal substances and indecency. - Fraud or dishonesty in such matters as completing expenses forms, car mileage log sheets, purchase orders or time sheets. - Unauthorised absence or persistent poor time-keeping. - Serious negligence or deliberate misuse of Company equipment or property, whether or not resulting in damage or injury; or giving advice without due care. - Unauthorised use of Company vehicles or other Company equipment or property. - Unauthorised use of IT systems including internet, internal and external Email, and use of Company equipment to access, download or transmit unauthorised software. - Disclosing confidential information to a person or body outside the Company or to a person or body within the Company who is not entitled to disclosure of that confidential information. - Undertaking paid work in competition with the Company. - Having and failing to disclose to the appropriate manager any financial, personal or family interest in business matters, including transactions, contracts or appointments, or in any other organisations which might affect or reasonably appear to affect any employee’s judgement when carrying out their duties. - Swiping/clocking ‘in’ or ‘out’ for another employee. - Not observing the terms of the Company’s safety policy (published on all notice boards). Employees are required to follow safe, normal working procedures and may only use equipment which they are authorised to use. - Smoking on Company premises, except in designated smoking areas. - Being in possession of alcohol or any illegal substance while on Company premises. - Criminal acts indicating a breach of the Company’s disciplinary rules or where the act, though not occurring in the course of carrying out your duties, nevertheless affects or casts doubt on the individual’s ability or suitability for continued employment with the Company or otherwise damages the interests or reputation of the Company. - Deception (e.g. making untrue statements to the Company on employment application forms, falsifying references, documents relating to sickness/absence; falsifying time records and/or expenses). - Unauthorised and improper use of the Company’s computerised records, or any attempt to access such information which is not directly related to your own work area as this is strictly forbidden (e.g. fraud and theft, system sabotage, introduction of viruses and time bombs, using unauthorised software, hacking, illegal copying of proprietary software, sending abusive, rude or defamatory messages via email). Misuse amounting to criminal conduct may be reported to the police. - Negligence e.g. breach of the Company’s health and safety regulations likely to cause injury to people or damage to equipment.

7. a)

DISCIPLINARY PROCEDURE Introduction 34

twentysix London Staff Handbook b) Timescales c) Right to Representation d) STAGE 1 - Informal Action e) STAGE 2 - Formal Interview Procedure f) Right of Appeal a)

Introduction

From time-to-time individuals may not conform to expected standards of conduct and this procedure provides a framework within which disciplinary matters can be systematically and fairly reviewed and provides for consistency and equitable treatment. The procedure will allow individuals to be made aware of any shortcomings in their overall conduct and of the possible remedies before any formal action is taken. The intention of the procedure is to provide an opportunity for an employee accused of misconduct to explain the reasons or refute the allegations. This disciplinary procedure is not appropriate for dealing with cases of poor work performance or sickness absence where there is no alleged misconduct. These will be handled separately under the Company's other procedures. Nor will it be applicable to any case where an incident may result in the Health and Safety at Work Act and/or safety rules being contravened except where there is alleged personal misconduct. b)

Timescales

Although some timescales are included in the formal disciplinary procedure it is recognised that it may not always be possible to keep to them. Nevertheless, the principle will still be applied that each stage of the procedure should be followed as quickly as possible. c)

Right to Representation

At all formal stages of the procedure the individual has the right to be accompanied by either: -

A fellow employee of their choice.

A full-time officer employed by a trade union; or a lay union officer or workplace representative, so long as they have been reasonably certified by their union as having experience of, or as having received training in, acting as a workerâ&#x20AC;&#x2122;s companion at formal proceedings.

The representative will have no legal right to answer questions on the employeeâ&#x20AC;&#x2122;s behalf but will have the right to address the hearing and ask questions of the disciplinary officer. d)

STAGE 1 - Informal Action

Although managers have the right to invoke the formal procedure at any time as part of the normal relationship between employees and their managers, employees may have drawn to their attention defects in their conduct which, in themselves, would not warrant formal disciplinary action. Such issues should be handled through an informal discussion between the manager and the individual and initially be dealt with by counselling and consideration given to training and other forms of support for the individual. If that proves unsuccessful, the formal procedures can be invoked. 35

twentysix London Staff Handbook If the actions from the initial informal discussions prove unsuccessful then the line manager may, if they feel it appropriate, continue with the informal route, and have further informal discussions with the individual, and continue to provide support over a defined review period. It is hoped that the informal procedure, having open and honest discussions, and providing support where appropriate, will resolve most situations quickly, without the need for recourse to formal procedures. e)

STAGE 2 - Formal Interview Procedure

Initial Investigation Where misconduct is suspected, or the actions described in (d) above have not resulted in an improvement in conduct, an investigation into the circumstances shall be undertaken by the immediate line manager. The detail and length of investigation will very much depend on the nature and seriousness of the alleged misconduct. However, it may involve taking witness statements, taking photographs of damage caused and / or obtaining physical evidence etc. If unsure how to approach the investigation, managers should approach the HR department who will provide assistance and guidance throughout the process, and ensure that a thorough investigation is conducted. Should the investigation reveal that the misconduct or breach is serious enough that if proven it could result in a dismissal, the disciplinary hearing must be conducted by a director or HR representative who has the power to dismiss, should the allegation be proven and warrant such a penalty. If the line manager is satisfied that the individual’s alleged actions warrant convening a formal hearing, they shall inform the employee of the allegations and arrange a disciplinary hearing, giving at least 2 working day’s notice. The employee will be told of their right to have present at the disciplinary interview a representative of his or her choice, as set out in Section 5.7 (c). The nature of the allegations and the time and date of the formal interview will be confirmed in writing to the employee as soon as possible and the disciplinary interview will take place within two working days. The employee must take all reasonable steps to attend the meeting. In exceptional circumstances the meeting may be conducted “in absentia”. Immediate Suspension from Duty Only in exceptional circumstances where the Company considers that the allegations are incompatible with the employee remaining at work or further investigations may be necessary, the employee may be suspended immediately pending a formal disciplinary interview. The decision to suspend will be taken after consultation by the line manager, with the HR Manager or appropriate Director. 36

twentysix London Staff Handbook Normally the period of suspension will not exceed two weeks and the employee will continue to be paid throughout the period of suspension. It should be noted that where suspension is used, it does not imply that the alleged misconduct is proven, and is not considered to be disciplinary action. Disciplinary Interview Disciplinary interviews will either be conducted by the line manager in conjunction with the HR Representative, appropriate director or other nominated company representative. At the formal disciplinary interview the allegations will be explained to the employee and they will be given an opportunity to answer fully the allegations made against them. The Manager conducting the disciplinary interview will consider the situation in the light of all the information available, including statements of witnesses, relevant documentary and other evidence, and evidence of mitigating circumstances, and shall make a decision on the case, or conduct further investigations as appropriate. The permitted penalties which can be awarded are given in the section Permitted Penalties Within The Formal Procedure (see (iv) below). Where a penalty is awarded the employee shall be notified in writing of the penalty and the reasons for which it was imposed as soon as possible after the disciplinary interview. At the same time they shall be informed of the right of appeal and to whom such an appeal should be made. Permitted Penalties Within The Formal Procedure a.

Formal Oral Warning – mainly used when informal procedures have been exhausted, or for first offences which are too serious for the informal process but not serious enough to warrant a formal written warning. Warnings will be issued to the employee specifying the breach of conduct and stating what the penalty may be if a further breach occurs. A brief note of the oral warning will be kept on the individual’s personnel file, but will be expunged after six months satisfactory conduct. The individual will be informed that this constitutes the first stage of formal disciplinary action

Written warning to final written warning – depending on the seriousness of the offence. Warnings will be issued in writing to the employee specifying the breach of conduct and stating what the penalty may be if a further breach occurs. A copy of the letter will be kept in the employee's personnel record for a period not exceeding one year unless otherwise stated or during that year a further written warning is given, in which case the warnings will be retained for a further period not exceeding one year. The objective of the warning process is to bring the misconduct to the individual’s attention, in order to give them the opportunity to bring about the desired improvement in their conduct. This may result in a number of written warnings being given before reaching a decision to dismiss, however, this process very much depends on the seriousness of the misconduct in 37

twentysix London Staff Handbook question and does not remove the right to issue a final written warning from the outset, or immediate dismissal if deemed necessary. After a final written warning, a further breach will result in dismissal. c.

Transfer to another post at the same or lower grade at the same location, which may lead to a reduction in remuneration.

Dismissal with notice (paid) or instant dismissal (unpaid), depending on the seriousness of the offence.

In the case of subsequent action involving the formal procedure, evidence of disciplinary actions can be used during the period it is retained on the employee's personal record. f)

Right of Appeal

An appeal against a decision and/or penalty (referred to in Permitted Penalties within the Formal Procedure) must be in writing by the appellant or their representative on the appellant's behalf, within five working days of the receipt of the confirmatory letter. The appeal will be heard by a Higher Management Official (HMO) who will have the power to revoke, confirm or vary the decision and/or penalty previously imposed in accordance with the permitted penalties set out in Permitted Penalties within the Formal Procedure). This is a non compensatory process, however, the HMO shall also have the power to settle any issue of payment or compensation covering the period from the time that the penalty was imposed in the case of dismissal and re-instatement or transfer to another post resulting in a reduction of remuneration. At the appeal the appellant will have the right to attend and be accompanied. Should new evidence arise during the appeal the individual or their representative will be given the opportunity to comment before any action is taken. It may be appropriate to adjourn the appeal to investigate or consider such issues further. The management official who made the decision following the formal interview shall also attend. The result of the appeal will be notified in writing to the appellant and their representative by the HMO as soon as possible after the appeal hearing, together with an explanation of their reasons for the decision. The decision of the HMO is final. There is no further right of internal appeal.

ABSENCE PROCEDURE

The policy relating to this procedure can be found in Section 6 â&#x20AC;&#x201C; Absence and Sickness. a) b) c) d)

Introduction Exceptions Investigation of Excessive/Persistant Sickness/Absence Procedures for Dealing with Excessive Sickness/Absence 38

twentysix London Staff Handbook e) Appeal Procedure f) Procedure for Dealing with Long Term Illness a)

Introduction

The contract of employment between the Company and employees is subject, among other things, to satisfactory work performance and regular attendance. The Company as a good employer has a concern for the health and welfare of its employees. This procedure has been designed to assist managers in dealing with cases where levels of sickness absence, whether short-term or long-term, give significant concern. They are not intended to displace normal welfare arrangements or the guidance set out in the Company's Absence Policy. The procedure is not intended to be punitive. Its focus is not the genuineness of the employee's sicknesses, but the business impact of unsatisfactory attendance. As such its key purpose is to seek satisfactory attendance, but also to provide for dismissal where this is not achieved. The procedure takes into account the appropriate ACAS Code of Practice and the various procedural requirements established by tribunals. They also take account of the implications of the Disability Discrimination Act 1995 and the Access to Health Records Act 1990 At all formal stages of the procedure the individual has the right to be accompanied by a fellow colleague of their choice, being a fellow employee or a full-time officer employed by a trade union; or a lay union officer or workplace representative, so long as they have been reasonably certified by their union as having experience of, or as having received training in, acting as a workerâ&#x20AC;&#x2122;s companion at formal proceedings b)

Exceptions

Deliberate abuse of the sick pay scheme, unauthorised absence from work and dishonest completion of sickness self-certification forms will be dealt with in accordance with the disciplinary procedure. c)

Investigation of Excessive/Persistent Sickness/Absence

Initial steps to deal with what is judged to be an abnormal level of sickness absence should be carried out in accordance with the managerâ&#x20AC;&#x2122;s guidance notes accompanying this procedure. Included as Appendix 6. The investigation will be in the context of a welfare discussion, and the assumption will be that the absences are for genuine medical reasons unless there is specific evidence to the contrary. Opportunity will be given for the individual to explain the level of absence and every effort will be made to ascertain the reasons for the absence and to assist the individual in improving their record. If, following this discussion, absences continue at an unacceptable level, then further steps may be necessary which, ultimately, could lead to dismissal. The absence from work through sickness procedure should only be followed in cases where monitoring and counselling support have failed to result in improved attendance and satisfactory performance at work. The procedure should not be instigated until a full investigation of the absence and any related factors has taken place.

twentysix London Staff Handbook Particular care should be taken where the nature of the absence or illness could be described as a disability under the Disability Discrimination Act 1995. If you are in any doubt please consult the HR Department for advice. It may be necessary to seek specialist support and advice or arrange for a referral to the Company's Occupational Health Advisory Service / doctor prior to any further action being taken. d)

Action Triggers

Where an employee has four weeks of absence in a rolling twelve month period - in one or more episodes- which are apparently owing to a single underlying cause, it will normally be appropriate to seek further medical information, with a view to considering the implications for employment under a Long-term Incapacity Review â&#x20AC;&#x201C; Section g. An adjustment to benefits etc. may also be appropriate. Where an employee has three episodes of absence in a twelve week rolling period this will normally lead to their being counselled about the company's absence policy, and the possibility of action under the excessive sickness absence procedure if their inability to attend recurs frequently. Where an employee, counselled in the last year about absence, again meets the 'three episodes in twelve weeks' trigger this will normally lead to action under the excessive sickness absence procedure. No other action triggers will be used unless agreed by Group HR. e)

Procedures for dealing with excessive sickness absence

Stage 1 - Informal Action

If following the initial sickness discussion, the level of absences continues to be unsatisfactory, the individual will be interviewed again (normally not less than three months after the initial discussion), but this really depends on the level and frequency of the absences. He/she will be given every opportunity to explain any underlying reasons for their absence within the context of this discussion. In all cases the employee should be warned of the likely consequences, including the possibility of dismissal if there is no improvement in attendance and told what improvement is expected and by when. The manager will confirm any agreed course of action to the individual in writing as soon as possible after the discussion. ii)

Stage 2 - Formal Interview Procedure

Should there be insufficient improvement in the individual's attendance record over the set review period; they may be asked to attend a formal interview. At least two working days' notice will be given, confirmed in writing setting out the points to be discussed and detailing their rights of representation. At the formal interview, all aspects of the individual's attendance record will be examined, including any mitigating factors. The outcome of the interview will be confirmed in writing by the manager as soon as possible after the interview. It may contain a firm decision in relation to the individual's future or it may result in a further period of review. Courses of action may include the following:-

Deferment for a given period to seek further medical advice and/or to give renewed opportunity for an improvement in the attendance record; 40

twentysix London Staff Handbook - Withholding an increment or a reduced performance bonus on the grounds of unsatisfactory service, with a view to granting once reached the required standard; - Transfer to a post in the same or lower grade, which may lead to a reduction in remuneration, in another section or department where this will materially assist the individual; - Dismissal with notice. e. At the same time, the individual will be notified of their right of appeal (see paragraph (f) below) and to whom such appeal should be made. If the decision is to allow a further review period, a further formal interview will be convened as soon as possible after the review period has finished, but not before its expiry. Again this should be confirmed in writing at least two days before the interview. The whole aim of this procedure is to try and give the individual the opportunity to improve their attendance. If by setting further review periods and providing relevant support the line manager feels this can be achieved, then they are free to continue with review periods until they feel necessary. f)

Appeal Procedure

An appeal against a decision and/or penalty must be in writing by the appellant or their representative on the appellant's behalf, within five working days of the receipt of the confirmatory letter. The appeal will be heard by a Higher Management Official (HMO) who will have the power to revoke, confirm or vary the decision previously confirmed. At the appeal the appellant will have the right to attend and be accompanied by his or her representative. The manager who made the decision following the formal interview shall also attend. The result of the appeal will be notified in writing to the appellant and their representative by the HMO as soon as possible after the hearing. g)

Procedure For Dealing With Long Term Illness

Adjustment to the current role which facilitates return (e.g. change to working hours or equipment or working practices);

Redeployment to alternative work if the individual's health or condition will not allow them to return to their normal job;

iii

Deferment for a defined period (not normally more than 3 months) to allow a further assessment to be made

Dismissal with notice because suitable work is not available.

(NB: The latter two decisions should only be initiated following careful consideration of the circumstances and full discussion with your HR Department) Care must be taken to ensure that all the options have been fully explored and discussed with the individual. Appropriate medical advice must be sought in conjunction with the individual and their representative before any final decision is taken Employees are expected to co-operate fully with the Companyâ&#x20AC;&#x2122;s request for medical information. 41

twentysix London Staff Handbook An appeal can be made against the decision of the manager holding the counselling interview on the basis set out in paragraphs (e) above. 9.

UNSATISFACTORY WORK PERFORMANCE PROCEDURE

a. b. c. d. e. f. g.

Introduction Right to Representation Investigation of Unsatisfactory Work Performance Stage 1 – Informal Action Stage 2 – Formal Action Stage 3 Appeal Procedure

Introduction

The contract of employment between the Company and employees is subject, among other things, to satisfactory work performance. This procedure is intended to apply where it is alleged that a employee’s work performance has consistently fallen short of the standards expected through an apparent inability to perform the work required. If there is evidence of deliberate or wilful neglect of work it will be dealt with in accordance with of the disciplinary procedures. These notes take into account the appropriate ACAS Code of Practice and the various procedural requirements established by tribunals. b)

Right to Representation

You have the right to be accompanied to formal interviews by either: -

Fellow worker, i.e., another of the Company’s workers.

A full-time officer employed by a trade union; or a lay trade union officer or workplace representative, so long as they have been reasonably certified by their union as having experience of, or as having received training in, acting as a worker’s companion at formal proceedings. The representative will have no legal right to answer questions on your behalf but will have the right to address the hearing and ask questions of the interviewer.

Investigation of Unsatisfactory Work Performance

When a line manager is concerned that an individual is not performing their duties satisfactorily, all reasonable steps should be taken to identify the extent of the performance issue. The manager should be able to demonstrate that the individual has not performed parts of their job, has failed to work in accordance with specific guidelines / QA work instructions or has performed at a standard below that which could be reasonably expected in terms of quality and quantity for the post in question.

twentysix London Staff Handbook If unsure how to approach the investigation, managers should approach the HR department who will provide assistance and guidance throughout the process, and ensure that a thorough investigation in conducted. The investigation may reveal that there are other reasons for the performance issue not directly related to the individual's competence. These could include ill-health or difficult personal circumstances. Such cases should be referred to HR and appropriate action taken to support or manage the areas of concern raised. d)

Stage 1 - Informal Action

Ideally managers should deal with individual performance issues as they arise so as to nip them in the bud before they develop into major issues, and without recourse to the formal procedures. The manager should have an informal meeting with the individual concerned, highlighting the shortcomings in their performance and identifying areas for improvement. Where appropriate a review period will be agreed during which performance in specified areas will be monitored. It should be made clear to the individual that the consequences of continued poor performance may include further action being taken against them. Use of Review Periods Review periods should be used where the line manager feels that the individual would benefit from additional time to prove him or herself after discussing the performance levels required, or after a suitable period of supervision or training. During review periods regular discussions will take place between the line manager and the individual on their progress and performance. During the review period the line manager should be prepared to keep the individual informed and be available to discuss specific queries relating to their work performance. They will offer full guidance on how performance can be improved to achieve the required standard and objectives set. This is in addition to the general management responsibilities of providing training, supervision, and where appropriate, adequate assistance to enable employees to perform effectively. The manager should make notes of any discussions on work performance and place them on the individuals file. e)

Stage 2 - Formal Action

Where informal action does not result in an improvement in performance, further action will be taken in accordance with the Company's formal procedure. If necessary further investigations will be conducted into the areas of poor performance, and presented to the individual at any formal hearings.

twentysix London Staff Handbook At least two working days' prior notice will be given of the formal interview. This will be confirmed in writing, setting out the points to be discussed and the individualâ&#x20AC;&#x2122;s rights of representation. The Company reserves the right to leave out any or all of the stages of the disciplinary procedure when it considers it appropriate. At the interview the manager will consider any informal action that has already been taken and will examine performance issues previously raised in detail with the individual and their representative. The objective will be to decide on a course of action which will assist the individual to reach the standards of performance required. Such action could include: -

a further review of performance over a defined period, normally no less than one month, with additional training or supervision if necessary;

a formal oral warning about future performance, specifying areas for improvement. A brief note of the oral warning will be kept on the individualâ&#x20AC;&#x2122;s personal file, but will be expunged after six months satisfactory performance.

a formal written warning specifying area for improvement. Written warnings are kept on file for 12 months unless otherwise specified.

The outcome of the interview will be confirmed in writing as soon as possible after the interview, indicating areas of improvement and specific actions. At the same time, the individual will be notified of their right of appeal and to whom such appeal should be made. If the decision is to allow a further review period, a second formal interview will be convened as soon as possible after the review period has finished, but not before its expiry. Again this should be confirmed in writing at least two working days before the interview. Should this course of action fail to achieve the desired and specified improvement the manager may hold a further formal hearing using the same procedure. Further courses of action may then include: -

a further review of performance over a defined period, normally no less than one month, providing further training and support over and above that already provided;

a formal written warning or second written warning about future performance, specifying areas for improvement, and providing training and support where appropriate.

Any written warning will be placed on the individual's personal file and retained for a period not exceeding one year, unless during that year a further written warning is given, in which case the warnings will be retained for a further period not exceeding one year. The outcome of the interview will be confirmed in writing as soon as possible after the interview, indicating areas of improvement and specific actions. At the same time, the individual will be notified of their right of appeal (see paragraph (g) Appeal Procedure) and to whom such appeal should be made. f)

Stage 3

Should the warning process fail to achieve the desired and specified improvement the manager may hold a further formal hearing using the same procedure. Further courses of action may then include: 44

twentysix London Staff Handbook - Transfer to another post on the same grade or salary. - Transfer to another post on a lower grade, which may lead to a reduction in remuneration. - Transfer to another work location. - Dismissal with or without notice. Prior to dismissing on the grounds of poor performance the manager should consider whether there is any suitable alternative employment available with the Company. This is particularly important where the individual has been promoted to a position which they are not capable of performing effectively. Consideration should also be given to length of service with the Company. The manager's decision should be confirmed in writing to the individual as soon as possible after the formal interview. At the same time, the individual will be notified of their right of appeal (see paragraph (g) Appeal Procedure) and to whom such appeal should be made. g)

Appeal Procedure

An appeal against the facts presented and/or the course of action determined, must be made in writing by the appellant or their representative on the appellant's behalf, within five working days of the receipt of the confirmatory letter. The appeal will be heard by a Higher Management Official (HMO) who will have the power to revoke, confirm or vary the outcome previously confirmed. The HMO will be specified in any correspondence to you. At the appeal the appellant will have the right to attend and be accompanied by his or her representative (see section (b) Right to Representation). The manager who made the decision following the formal interview shall also attend. The result of the appeal will be notified in writing to the appellant and their representative by the HMO as soon as possible after the appeal hearing. The decision of the HMO is final. There is no further right of internal appeal.

twentysix London Staff Handbook 10. REDUNDANCY a) b) c) d) e)

Introduction Consultation Selection for Redundancy Redeployment Right of Appeal

a) Introduction The Company recognises that security of employment is an important factor to everyone and endeavours to provide continued employment. Circumstances may arise, however, where, inevitably, certain jobs are no longer needed. b) Consultation The Company will consult fully with all affected employees before dismissal on the grounds of redundancy takes effect. Consultation will continue for as long as it is meaningful. c) Selection for redundancy The factors taken into account when selecting employees for redundancy will be notified to you at the time. Voluntary redundancies will be invited only where this can be done without prejudice to the Company in terms of its future requirement for employees and skills, and where such invitation is made the Company shall be able to decline all or any volunteers. If you are selected for redundancy you be invited to a meeting to discuss the next steps. You have the right to be accompanied at this meeting by a fellow employee of your choice or by a trade union officer. The representative will have no legal right to answer questions on your behalf but will have the right to address the dismissing manager and ask questions of him/her. d) Redeployment & Retraining The Company will offer alternative employment wherever suitable work is available. It may, however, be necessary for you to move your home in order to take such work (subject to the Company provision of appropriate relocation support). A position may also be offered, which, in the opinion of the Company, the employee would be capable of fulfilling after suitable additional training. Where a suitable alternative post cannot be found the Company will try to give as much warning as possible. e) Right of appeal You have the right to appeal in writing against the decision to dismiss on the grounds of redundancy. The appeal will be heard by a Higher Management Official (HMO). You will have the right to attend and to be accompanied by your chosen representative. The result of the appeal will be notified in writing to you and your representative by the HMO as soon as possible after the appeal hearing, together with an explanation of the reasons for their decision. The decision of the HMO is final. There is no further right of internal appeal.

twentysix London Staff Handbook 11 WHISTLEBLOWING POLICY & PROCEDURE a) b) c) d) e) f)

General Statement Scope of Policy Procedure Confidentiality/Anonymity Disciplinary Action Protection

General Statement

Media Square is committed to ensuring that the manner in which we operate and conduct our business is to the highest standard. We recognise, however, that there may be occasions when employees have genuine concerns about the actions of their colleagues, managers or the operating company within which they work. The purpose of this Policy is to provide a framework for individuals to raise such concerns without fear of adverse repercussion. b)

Scope Of The Policy

Employees should invoke the Whistleblowing Policy where they have genuine concerns about any of the following: c)

a criminal offence; the breach of a legal obligation; a miscarriage of justice; a danger to the health or safety of any individual; damage to the environment; or deliberate covering up of information tending to show any of the above five matters. Procedure

Where an employee has a genuine concern about any of the above, the issue should normally be raised with his/her immediate line manager. If the employee feels unable to do so, the concern should be raised with a more senior manager (typically a Director of the operating company within which the employee works). If the employee feels unable to raise the issue with anyone involved in the operating company within which he/she works, the matter may be raised by phone or by writing to the Director of Employee Services, Media Square or a prescribed person. The issue will be investigated as quickly as possible and the outcome communicated to the employee. d)

Confidentiality/Anonymity

Any concern raised under this Policy will be treated in confidence as far as is possible, subject to the need to ensure a full investigation of the issue. 47

twentysix London Staff Handbook A complainant may wish to remain anonymous and the Group will ensure the individualâ&#x20AC;&#x2122;s anonymity wherever possible and as far as is reasonably practicable. Ultimately, however, the Group reserves the right to investigate any complaint raised under this Policy in the most appropriate manner to ensure that all aspects are fully and rigorously followed up. Where circumstances arise which mean that a full and thorough investigation cannot be conducted without revealing the identity of the complainant, this will be discussed with the individual concerned prior to any further action being taken. e)

Disciplinary Action

Where an investigation confirms that there has been wrongdoing/malpractice, appropriate action will be taken which may include summary dismissal and/or reporting the matter to the police/other statutory bodies. The objective of this Policy is to provide a process to encourage individuals to raise genuine concerns. It may be, however, that the complainant has been involved in wrongdoing. In such a situation, he/she would have to answer for his/her actions and should not expect immunity from disciplinary/criminal proceedings. In such circumstances, however, the fact that he/she raised the concern would be taken into account. Where it is found that an employee has abused the Whistle-blowing Policy and has made a deliberately false or malicious allegation, he/she may be liable to disciplinary action, which may result in dismissal. f)

Protection

The Group will take all reasonable steps to ensure that any employee who raises a concern under this Policy is not victimised or suffers any detriment. Should an employee believe that they have been victimised or suffered a detriment or believe that their complaint has not been fully investigated, they should immediately contact the Director of Employee Services, Media Square. 12

SHARE DEALING

Things You NEED to Know About Buying or Selling Media Square Shares As you are aware the Group is quoted on the London Stock Exchange where its shares are traded on the Alternative Investment Market (AIM). This quoted status brings with it a detailed and complex set of rules and legislation governing how the Group conducts its business. The vast majority of these rules and laws will never have any material impact on how each of us completes their normal work however there is a particular law which affects all of us in our daily business ... INSIDER TRADING. It is a criminal offence for any individual to use confidential, inside information about the Group to gain an unfair advantage, compared to the general public, when buying or selling shares in the Group. The offence extends to disclosing confidential information about the Group to others, who in turn, gain an unfair advantage, compared to the general public, when buying or selling shares in the Group.

twentysix London Staff Handbook The rules are fairly simple, particularly for senior employees. If you believe you are in possession of specific information which could affect the share price either positively or negatively (e.g. new contracts, loss of contracts, in talks regarding acquisitions or disposals, etc) and which is not in the public domain, then this information should not be disseminated to anyone, including the spouse and family, outside the company and the person in possession of the information should not themselves deal in the shares of Media Square. Only once the information has become public knowledge should that individual then discuss that information. In addition to these specific matters there are periods during the year which are considered sensitive by the Stock Exchange and during these periods it is prohibited for employees to buy or sell shares in the Group. Such periods are known as CLOSE PERIODS and run for a period of two months before the Group reports it's final and interim results to the Stock Exchange. These reports are themselves normally made two to three months after the year and half year-end. This means that within the periods April - June and August - October there will be two month periods which will be Close Periods. If any employee of the Group is considering buying or selling shares in the Group then they are required to obtain the written authority of the Group Finance Director using the standard authority request form is included in the Forms section â&#x20AC;&#x201C; Form 3. Failure to comply with this procedure would be a breach of the employee's terms and conditions of employment and potentially a disciplinary matter. If you have any questions please contact the Group Finance Director before taking any action.

twentysix London Staff Handbook SECTION 6 â&#x20AC;&#x201C; ABSENCE AND SICKNESS 1. 2. 3. 4. 5. 6. 7. 8. 9. 10.

MATERNITY PATERNITY LEAVE PARENTAL LEAVE ADOPTION LEAVE TIME OFF FOR DEPENDANTS BEREAVEMENT LEAVE JURY SERVICE AND OTHER PUBLIC DUTIES FLEXIBLE WORKING SICKNESS HOLIDAYS

MATERNITY

The Company provides maternity benefits in line with the current statutory provisions. If you become pregnant you must notify your Line Manager at an early stage so that your entitlements and obligations can be explained to you. Introduction The procedures relating to maternity are quite complicated and can be confusing. Failure to follow the proper procedures may result in the loss or reduction of benefits. Please discuss your particular circumstances with your relevant HR contact. Statutory Maternity Pay In order to qualify for Statutory Maternity Pay, you must comply with the following conditions: You must have at least 26 weeks continuous employment with the Company up to and into the 15th week before your expected week of childbirth (i.e. the week in which your baby is due) You must give written notice to your Line Manager / HR contact at least 28 days before absence begins that you will be absent from work because of impending childbirth, and the date you intend to start your leave. You must produce medical evidence stating the expected week of childbirth within 3 weeks of the date from which the maternity pay period will commence. This will normally be on form MATB1 (Maternity Certificate) but other medical evidence, provided it shows the date the baby is due, may be accepted. Payments cannot be made until this evidence has been received. You must still be pregnant or have had your baby by the 11th week before the expected week of childbirth. You must have stopped work because of your pregnancy. Calculation of Statutory Maternity Pay The method of calculating Statutory Maternity Pay (SMP) is complicated and the amount you receive will depend on the length of time you have been with the Company, if you meet certain service criteria, and your current salary. SMP is paid for a maximum period of 39 weeks, starting at a higher rate (for 6 weeks) then reducing to the lower rate (for 33 weeks). It is calculated as follows: -

90% of your average earnings for the first 6 weeks, 50

twentysix London Staff Handbook then up to 33 weeks at the lower rate (see http://www.dti.gov.uk/employment/employmentlegislation/employment-guidance/page34244.html#Statutory for current rates) The entitlement to SMP is separate to entitlement to maternity leave Please note the Statutory Maternity Pay period cannot commence earlier than the 11th week before the expected week of childbirth. PREGNANCY RELATED ILLNESS If the Sunday of the 4th week before the Expected Week of Childbirth (EWC) has passed and you are sick with a pregnancy related illness, then your maternity leave automatically starts, and your Statutory Maternity Pay starts on the Sunday following the commencement of the absence. Maternity Leave You will be entitled to 26 weeks maternity leave irrespective of your length of service and hours of work. This general entitlement is referred to as Ordinary Maternity Leave. Ordinary Maternity Leave (Maximum 26 weeks) In order to benefit from Ordinary Maternity Leave, the following conditions apply: You must give written notice to your Line Manager / HR contact no later than the end of the 15th week before the expected week of childbirth, and at least 28 days before absence begins, that you will be absent from work because of impending childbirth, and the date you intend to start your leave. HR will respond, within 28 days, confirming the date on which you will be expected to return to work if you take your full entitlement to maternity leave. a)

Your 26 weeks leave may not normally commence until the 11th week before your expected week of childbirth.

Should you wish to change the start date for Ordinary Maternity Leave, you must notify the Company by the earlier of 28 days before the original start date or 28 days before the new start date.

You must provide a medical certificate (MATB1), stating your expected week of childbirth. If, as may be the case, the certificate is not available in time to be given with the notice, the notice should not be delayed because the certificate can always be produced later.

If you intend returning before the end of the 26 weeks Ordinary Maternity Leave, you should inform HR of your intention to resume work at least 8 weeks before you return. You may not return within 2 weeks of childbirth.

You do not have to give the Company advance notice if you intend to return to work immediately after the end of your 26 weeks Ordinary Maternity Leave period.

Although you are not obliged to, we would very much appreciate you notifying us as soon as you have made a decision regarding your return date.

twentysix London Staff Handbook Additional Maternity Leave (A Further 26 weeks) With effect from April 2007 all employees are entitled to Additional Maternity Leave. In order to benefit from Additional Maternity Leave, the following conditions apply: a.

You must give written notice to your Line Manager / HR contact no later than the end of the 15th week before the expected week of childbirth and at least 28 days before absence begins that you will be absent from work because of impending childbirth, and the date you intend to start your leave. HR will respond, within 28 days, confirming the date on which you will be expected to return to work if you take your full entitlement to maternity leave.

Your leave may not normally commence until the 11th week before your expected week of childbirth.

You must provide a medical certificate (MATB1), stating your expected week of childbirth. If, as may be the case, the certificate is not available in time to be given with the notice, the notification should not be delayed because the certificate can always be produced later.

You should notify HR of your intention to resume work at least 8 weeks before you return, if you intend to return to work before the end of your Additional Maternity Leave period. (If sufficient notice is not given, the Company may postpone your return date). You may not return to work within 2 weeks of childbirth.

The maximum amount of Leave is calculated as 26 weeks starting from the end of the last week of ordinary maternity leave. The week runs from Sunday to Saturday. At the latest, therefore, you must return to work on the first working day after the end of the 52 weeks from the commencement of ordinary maternity leave.

You do not have to give the Company notice if you intend to return to work immediately following the end of your Additional Maternity Leave period. Although you are not obliged to, we would very much appreciate you notifying us as soon as you have made a decision on your return date. Further information including details of the current rate of SMP can be found on: http://www.dti.gov.uk/employment/employment-legislation/employmentguidance/page34244.html#Statutory Keep In Touch Days With effect from April 2007, â&#x20AC;&#x153;Keep in touch daysâ&#x20AC;? have been introduced whereby an employee can work for up to 10 days during the maternity leave period without the statutory maternity leave period being deemed to have ended and without impact on statutory maternity pay. Use of Keeping in Touch days should be agreed prior to maternity leave commencing which should also include confirmation of how the employee will be remunerated for these days. The company is not obliged to offer them nor are employees obliged to take them up. Employees cannot be penalised for refusing to take up a Keeping in Touch day.

Holiday Entitlement 52

twentysix London Staff Handbook You will continue to accrue holiday entitlement during your period of Ordinary Maternity Leave. You will need to agree with your manager and the HR Department whether you take the holiday entitlement following your Maternity Leave or receive payment in lieu, or a combination of the two. This will depend on how much holiday you have already taken during the year, and business needs. Contract of Employment and Terms and Conditions The contract of employment continues throughout Ordinary and Additional Maternity Leave unless either party (i.e. either you or the Company), expressly ends it or it expires. Terms and conditions of employment are affected during Maternity Leave, for example, Pension, Private Medical insurance, etc. For further details and to discuss your options regarding these aspects, contact your local HR Representative. Continuity of Employment Absence due to maternity leave will be counted in calculating length of service for Notice Rights and possible Redundancy Payments. Maternity Leave will not break continuity of employment. Time off for Antenatal Care All pregnant employees are entitled to paid time off for antenatal care. Except in the case of your first appointment, you will need to be able to show your manager a medical certificate confirming that you are pregnant and written evidence showing that an appointment has been made, if requested.

Return to work on a Part Time Basis or Request for more Flexible Working There is no specific right for a woman to change her contractual working conditions, including hours of work, on return to work following maternity leave, however, the Company has a statutory obligation to consider such requests. The Company will, therefore, give careful consideration to any request to work on a part-time basis. In any such situation, the Company must take business needs into account. Given that requests to return on a part-time basis require detailed and careful consideration, these should be made as soon as possible. The full policy is included as Appendix 7 and an application form is included within the Forms section â&#x20AC;&#x201C; Form 4

PATERNITY LEAVE

The Company provides paternity benefits in line with the current statutory provisions. If you wish to take a period of paternity leave please contact your Line Manager as soon as possible so that your entitlement can be explained to you. Fathers of new born or newly adopted children, subject to certain eligibility criteria, are entitled to 2 weeks statutory paternity leave. The qualifying period for eligibility is the same as the criteria for qualifying for Statutory Maternity Pay and is paid at the same rate as Statutory Maternity Pay (SMP). Employees wishing to take paternity leave should complete the appropriate application form, included in the Forms section â&#x20AC;&#x201C; Form 5 and return it to their manager. 3.

PARENTAL LEAVE 53

twentysix London Staff Handbook The Company provides parental benefits in line with the current statutory provisions. You should discuss your needs with your Line Manager, who will identify your entitlements and look at the proposed leave periods dependant upon your child’s/children’s particular circumstances and the operational aspects of the business. Qualifying Conditions Parental Leave applies to both mothers and fathers, including both natural and adoptive parents. The following qualifying conditions apply: a)

You must have at least one year’s continuous service with the Company.

You must be a parent named on the birth certificate or have (or expect to have) parental responsibility for the child.

The child must be under 5 years old (or under 18 in the case of a disabled child).

In the case of adoption, you must have adopted, on or after 15th December 1999, a child under the age of 18.

Parental Leave must be to care for a child.

Main Entitlements a) The maximum Leave a qualifying employee can take is 13 weeks per qualifying child. (18 weeks for a disabled child) b)

Both parents can take Parental Leave.

The right to take Leave exists up to the child’s 5th birthday.

Parents of a disabled child can use their leave over a longer period (up to the child’s 18th birthday).

The employee remains an employee whilst on Leave.

The employee has the right to return to the same job.

Taking Leave a) Leave can only be taken in blocks or multiples of one week (or individual days for a disabled child) b)

Employees must give a minimum of 21 days notice, giving the dates when the leave will start and finish. A form is provided – included in the Forms section – Form 6.

Employees can take a maximum of 4 weeks leave in any one year in respect of any individual child. (A year is calculated either from when the child is born, or when the employee has completed a year’s service, whichever is later).

twentysix London Staff Handbook d) Leave can be postponed by the Company for up to 6 months where the business would be unduly disrupted. Leave cannot be postponed where the employee gives notice to take it immediately after the time the child is born or is placed with the family for adoption. Any questions regarding Parental Leave should be referred to the HR Department. 4.

ADOPTION LEAVE

The Company provides adoption benefits in line with the current statutory provisions. If you are matched or adopted, you should notify your Line Manager as soon as possible, preferably within seven days so that your entitlements can be explained to you. Full details are available on request from your Line Manager, HR department or http://www.dti.gov.uk/employment/workandfamilies/adoption-leave/page16608.html 5.

TIME OFF FOR DEPENDANTS

The Employee Relations Act 1999 contains a range of family friendly measures designed to help parents, or those employees who have or may have to care for dependants. All employees have the right to take a reasonable amount of time off work to deal with an emergency involving a dependant. It should be noted that time off to care for dependants is generally unpaid. An employee is entitled to take reasonable time off work during working hours in order to take action, which is necessary, as follows: -

To provide assistance on an occasion when a dependant falls ill, gives birth or is injured in some way.

To make arrangements for the provision of care for a dependant who is ill or injured.

In consequence of the death of a dependant.

To deal with an incident which involves a child of the employee, and which occurs unexpectedly.

A dependant is generally defined as the employeeâ&#x20AC;&#x2122;s wife, husband, child or parent or someone living in the same household (but not as a tenant, lodger or boarder). In the case of illness, injury or where care arrangements break down, a dependant includes someone who reasonably relies on the employee for assistance (whether because you have primary care responsibility or you are the only person who can help in a serious emergency situation). In the event that time off is required: 1. 2.

The employee must inform his / her manager of the reason for his / her absence as soon as reasonably practicable, and state the potential amount of time he / she will be absent. If the absence lasts for more than one day, ongoing communication between the individual and their manager during the absence, should be jointly agreed. 55

twentysix London Staff Handbook 3. A return to work discussion should take place upon the employee’s return. 4. The manager is responsible for notifying the local Payroll Officer (Financial Controller) of the total period of absence, via the return to work discussion form. The Payroll Officer will then action any necessary pay adjustments. Time off is normally unpaid, however exceptions in extreme cases may be agreed, at the Company’s discretion. 6.

BEREAVEMENT LEAVE

After one year's service, on the death of a relative the following guidelines for paid leave of absence will be applied at your director's discretion: 5 days

Spouse/Partner Child Parent

3 days

Sibling Parent In-law

The granting of paid leave of absence on the death of persons not mentioned above will be entirely at the Company’s discretion. 7.

JURY SERVICE AND OTHER PUBLIC DUTIES

Time off for jury service and other public duties will be granted in accordance with statute and any associated code of practice. Any request beyond these obligations, such as membership of the T.A.V.R. will be dealt with at the discretion of the Company, on the basis of individual merit from employees with more than 6 months’ consecutive service. In all cases, you must produce documentary evidence of the need for any period of absence. If you are required to serve as a juror, you must notify your Line Manager as soon as possible of the period and dates that you expect to be absent from work. If you are not required at Court during any part of your period of jury service you must attend work wherever this is possible. You are not entitled to paid time off for jury service and therefore you should claim the maximum permissible compensation for loss of earnings, subsistence and travel allowance. The Company may, if appropriate ‘make-up’ the differences to your normal basic pay, at its discretion. 8.

FLEXIBLE WORKING

All employees with children under the age of 6 (or eighteen if the child is disabled) are entitled to request a more flexible working arrangement. This entitlement is merely to request a change, it is not an entitlement to have your hours or work changed. If you believe you may be eligible and are interested in requesting a more flexible working arrangement please inform your Line Manager. A copy of the policy is attached as Appendix 7 and an application form is included in the section Forms – Form 4. With effect from April 2007, this entitlement will extend to the carers of adults.

twentysix London Staff Handbook 9. SICKNESS a) b) c) d) e)

Introduction Reporting Sickness Returning to Work Sick Pay Summary

Introduction

The Company is committed to creating a healthy environment at work, where employees feel they can give their best. If you are off work due to sickness, we will work closely with you to assist you back to full health to enable your return to work. We are committed to supporting you as much as possible, as well as meeting the ongoing needs of the business. It is important you follow the Companyâ&#x20AC;&#x2122;s sickness procedure to make sure your line manager understands your personal situation, so as to be able to provide assistance where appropriate. This policy outlines what actions you need to take when you are absent from work. If you are unsure about any of this policy please ask your line manager. Failure to follow the correct procedure could result in disciplinary action. b)

Reporting Sickness

On the first day you are sick you must contact your line manager by telephone. You will need to explain that you will not be coming to work and indicate when you think you will be returning. Text messaging or leaving voicemail messages outside of normal working hours is not acceptable. To give your line manager as much time as possible to re-arrange work, please ring by your normal starting time or by 9.15am at the latest if you are office based, and if you work shifts you should phone at least 45 minutes before the start of your shift. If you cannot speak to your line manager directly please make arrangements to ensure they are informed. When phoning in, you will be required to supply the following information: -

The nature and extent of your illness The anticipated length of your absence Provide details of any business-related matters, which may be affected by your absence, in order that alternative arrangements can be made.

You will need to keep in regular contact with your line manager whilst you are off sick. If you are unwell for a significant period of time, someone from the Company may visit you at home to see how you are and if there is any support the Company can offer you to aid your recovery. You may also be contacted by an Occupational Health Advisor. Appropriate sickness certificates must be provided to your line manager, these being -

A self certificate up to the first 7 calendar days (obtained from payroll department or your line manager). This can be completed on your return to work.

A valid doctorâ&#x20AC;&#x2122;s certificate for absences exceeding 7 calendar days. This should be provided as 57

twentysix London Staff Handbook early in your absence as possible. If you have been off sick for a period in excess of seven consecutive days (including non-working days), a Doctor’s certificate covering the whole period of your absence is required. If your absence continues you must provide a new certificate as soon as the previous one expires. If your incapacity extends to more than seven days you are required to notify us of your continued incapacity once a week thereafter, unless otherwise agreed. Where sickness absence commences on a working day prior to authorised leave, and prevents an employee taking leave, this may be regarded as a period of sickness (rather than annual leave). A medical certificate will be required. Sickness whilst on leave will otherwise be regarded as annual leave. It is important that we are satisfied that you are fit to be at work and able to carry out your duties. Getting medical advice helps us to do this. If you feel you are able to return to work undertaking certain duties or hours rather than your normal job, please speak to your line manager, to see whether this can be accommodated. We may require you to obtain a doctors certificate to confirm that you are able to undertake light duties. If you have been suffering from an infectious or contagious disease or illness such as rubella or hepatitis you must not report for work without clearance from your own doctor. c)

Returning To Work

On your return to work you will have an informal Return to Work Interview with your line manager, to ensure you are fit to return and also to submit the appropriate paperwork as detailed below. All absences will be treated as genuine, unless there is evidence to the contrary. A return to work discussion form is available and included in the Forms section – Form 7. In circumstances of a longer term health issue being identified, your manager will work with you to provide suitable support and / or adjustments to your duties. Should the interview reveal problems with excessive absence and/or abuse of the sickness absence scheme, further action may be taken in accordance with the absence or disciplinary procedures as appropriate. d)

Sick Pay

Provided you comply with current Company procedure, and supply the correct sickness certificates, we provide an additional sickness benefit for all staff, subject to the conditions detailed below. This means that, if you are ill and cannot come to work, you may be eligible to receive your normal basic salary and other contractual benefits for a certain number of days per year. Period of Employment

Amount of sickness benefit

Less than 1 year’s service: 1-3 year’s service: 5-7 year’s service: 7 years and over:

Statutory Sick Pay only 1 month’s absence paid at full pay 2 months’ absence paid at full pay 3 months’ absence paid at full pay 58

twentysix London Staff Handbook Where the company makes a payment for a period of sickness more than that to which the employee is entitled under the above rules, either because we have not been informed of the sickness absence or because your sickness absence records are not available in time to make the appropriate adjustments in the month to which the adjustment relates, the company reserves the right to deduct any overpayment you receive from any amount subsequently due to you. If you are off work due to illness for longer than the company sickness benefit provides, then you will receive only SSP for the remainder of your sickness absence. Any extension of sick pay entitlement is made solely at your Managing Director’s discretion. If you are ever suspended from work, pending a disciplinary investigation, then the sickness policy will still apply to sickness absence during the period of that suspension. Statutory Sick Pay (SSP) rates will apply, with the Company making up the difference between SSP and your basic pay for those with sickness entitlement. Current SSP rates can be found at: www.inlandrevenue.gov.uk/cbr-ssp/section1/102.htm All sick pay will be paid at your normal rates less all National Insurance benefits. (Where a married woman has elected not to pay full contributions the deduction will be made at the current minimum benefit rate). Please remember misuse of the sick pay scheme – e.g. working for another employer whilst claiming sick pay from the Company, by falsely stating you are ill – could lead to suspension of sick pay and / or more serious action. Sickness includes injury and other disability, but unless the company decides otherwise, it excludes any recurring injury or other disability due to active participation in sport (especially as a profession), any injury or disability arising from other paid employment or any case where you’re proven to be negligent. In some circumstances the Company may require you to attend a medical examination. If you are absent due to an accident which appears to be caused by the actions of a third party from whom damages may be recovered, you may not be eligible for sick pay. You should inform your line manager of the situation immediately. Depending on the circumstances, the company will advance you an amount not exceeding the sick pay which you would have been eligible to receive. This advance will be subject to your agreement to refund the Company an appropriate amount in line with any damages you receive. When a refund is made, the corresponding period of absence won’t be recorded as sickness. You will also be expected to co-operate with the Company regarding the potential recovery of these monies. Failure to adhere to the above rules may result in action under the company's disciplinary procedure and may result in the loss of eligibility for sick pay. e)

Summary

Please remember that it is your responsibility to make sure you understand the Company sickness procedure so you know what to do when you’re ill. If you have any queries or are unclear about anything, speak to your line manager. 59

twentysix London Staff Handbook 10. HOLIDAYS The Companyâ&#x20AC;&#x2122;s holiday year runs from 1 March to 28 (29) February and holiday entitlements are detailed in each employeeâ&#x20AC;&#x2122;s Contract of Employment. Holidays accrue pro-rata on a daily basis. During the first and last year of your employment you will be entitled to a pro rata proportion of your full entitlement. Additionally, on termination, you will be paid for any accrued holidays not taken. The Company may recover from you a sum in respect of any holiday you may have taken in excess of your accrued entitlement and may deduct this sum from any sums due to you from the Company as at the date of termination of your employment. You will be expected to retain up to 3 days of your annual holiday entitlement per year to be taken between Christmas and New Year. Holiday dates must be approved by appropriate Line Management at least two weeks in advance. Approval will be subject to the demands of the business and the Company reserves the right to refuse to grant a request for holiday or require you to take your holidays on dates on which your place of employment is closed.

twentysix London Staff Handbook SECTION 7 â&#x20AC;&#x201C; COMPANY RULES 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. 13. 14.

CHANGES IN PERSONAL DETAILS PERSONNEL RECORDS TRAVEL EXPENSES OTHER EMPLOYMENT PRIVATE TRADING PERSONAL PROPERTY COMPANY PROPERTY SECURITY PROCEDURES PERSONAL BEHAVIOUR BETTING AND GAMBLING RAFFLES COLLECTIONS SPONSORSHIP FLAG DAYS GENERAL HEALTH

CHANGES IN PERSONAL DETAILS

You should notify your local payroll contact in writing of any change of name, address, telephone number, next of kin, bank details, etc., so that we can maintain accurate information on our records and make contact with you in an emergency, if necessary, outside of normal working hours. 2.

PERSONNEL RECORDS

During your employment the Company will need to hold certain information about you, for example your address and salary details on computer. The Company will take all reasonable steps to ensure that this information is kept confidential. Some limited information may be given to third parties for research or statistical purposes, subject to the Data Protection Act. Personal information will not be passed onto third parties unless authorised by the employee in advance, unless required to do so by law. You have a right to request a copy of the information which is held under the terms of the Data Protection Act. 3.

TRAVEL

The Company reserves the right to request you to travel anywhere within the United Kingdom or overseas, as may be necessary and reasonable, e.g. site visits, training issues, etc. The Company would not expect an employee to unreasonably refuse. Appropriate travel insurance is provided by the Company. 4.

EXPENSES

The Company will reimburse all reasonable travel, accommodation, entertainment and other out-ofpocket expenses which you may from time to time incur in properly carrying out your duties, provided that they are authorised by your Line Manager in accordance with Company policy. You must submit receipts or some other proof of payment with your expenses claim otherwise the Company reserves the right to withhold payment. 61

twentysix London Staff Handbook 5.

OTHER EMPLOYMENT

During your employment with the Company, you must not, without the Company’s prior agreement, be involved either directly or indirectly in any other business or undertaking or any other regular work. Should you wish to accept an outside appointment or take up additional employment you must obtain the consent of your Director. Should you receive consent to take up secondary employment you must undertake to provide such information as is necessary to enable the Company to comply with its obligations under the Working Time Regulations 1998. 6.

PRIVATE TRADING

Private trading on Company premises e.g. sale of duty free goods or other items, and personal use of the Company’s equipment is strictly prohibited. Anyone found contravening this prohibition will be subject to disciplinary action. 7.

PERSONAL PROPERTY

The Company accepts no liability for any personal property which is lost, damaged, or stolen on Company premises. You should, however, report any such loss or damage to your immediate Superior who will investigate matters on your behalf. 8.

COMPANY PROPERTY

If requested by the Company during your employment, or following the termination of your employment, you must immediately return all property belonging to the Company which is in your possession custody or control, including, but not limited to, clothing and equipment, any documents, confidential information and copies of such documents. Failure to return such items will result in the cost of the items being deducted from any monies outstanding to you. 9.

SECURITY PROCEDURES

The Company requires a secure environment in which to carry out its business. It is of the utmost importance that the Company’s employees, customers, premises, intellectual property, confidential information, and all other company property are kept secure at all times and that the interests of the business are safeguarded. You are expected to assist the Company to achieve this. If you see any person acting suspiciously on Company premises you should report this to an appropriate person. The Company may invite the police to search its premises and to investigate any employee whom it suspects may be guilty of theft of Company’s property or who may have committed any other criminal offence on its premises. To safeguard premises and property the Company reserves the right to search all employees and visitors: -

parcels, bags, containers or other property in your possession while leaving or entering the premises 62

twentysix London Staff Handbook - Vehicles in which you are travelling when you enter or leave the premises. - Anyone is entitled to ask for another person to be in attendance while a search is being carried out. If an employee is suspected of theft and refuses to allow a search to take place the employee will be detained and the police called. Please note that anyone found in possession of the Company’s products or other property who does not have authority to take them off the premises will be subject to gross misconduct action. If you do need to take Company property off the premises you should obtain written permission describing the property that you are authorised to remove, from your immediate Superior, before you leave the premises.

10. PERSONAL BEHAVIOUR Employees must always behave sensibly and safely and not endanger any other employee whilst at work e.g. through horseplay, practical jokes, rowdyism, violence, etc. 11. BETTING AND GAMBLING Betting and gambling on the Company’s premises are strictly forbidden. 12. RAFFLES Organising or selling tickets for lotteries or raffles is strictly prohibited unless authorised in advance by the Department Manager. 13. COLLECTIONS SPONSORSHIP FLAG DAYS All collections, sponsorships and Flag Day appeals must be authorised in advance by the Department Manager. 14. GENERAL HEALTH In addition to medical reports requested under the Company Sickness Rules, you could be requested, at the Company’s expense, to undergo medical examinations, in connection with your employment, e.g. hearing tests, eyesight tests, etc. 15 STATEMENTS TO THE MEDIA Your operating company will have guidelines on who can comment to the media. The general rule is that authorised spokespeople will be directors of the company. No comment should ever be given regarding other operating companies or about Media Square plc. All enquiries not relating to your company should be immediately referred to Media Square’s head of communications. Anyone contravening any of the above rules will be subject to disciplinary action in accordance with the Company’s Disciplinary Procedure set out in Section 5. 63

twentysix London Staff Handbook

Appendices

twentysix London Staff Handbook Appendix 1

CORPORATE SOCIAL RESPONSIBILITY

POLICY

Media Square

twentysix London Staff Handbook

CONTENTS

POLICY STATEMENT BY THE MANAGING DIRECTOR…………………3

CODE OF ETHICS……………………………………………………………….4

HEALTH AND SAFETY…………………………………………………………7 HUMAN RESOURCES…………………………………………………………..8

ENVIRONMENT…………………………………………………………………10 SUPPLIERS……………………………………………………………………….11

COMMUNITY……………………………………………………………………12

twentysix London Staff Handbook

MANAGING DIRECTORS POLICY STATEMENT ON CORPORATE SOCIAL RESPONSIBILITY Media Square Executive Management regard the promotion of Corporate Social Responsibility as a mutual objective for all stakeholders of Media Square. The objective of the Company’s policy with regard to corporate social responsibility is to provide a reference point to guide stakeholders, including all employees, on the elements that drive the conduct of the business and relationships in the world in which we operate. Media Square recognises its corporate social responsibility commitments and this is reflected in our:•

Standards of business conduct. ( Code of Ethics )

•

Health and Safety.

•

Employees.

•

Customers.

•

Environment.

•

Suppliers.

•

Community.

The Executive Management direct that Heads of Department are responsible to the Managing Director for carrying out the corporate social responsibility policy within the framework of the policy. All Department Heads and Supervisors are to ensure that arrangements for corporate social responsibility within departments are up to date and accurately reflect company procedures.

CODE OF ETHICS We are committed to ensuring that our business is conducted in all respects according to rigorous ethical, professional and legal standards. Adherence to the law and regulations, and the application of common sense, logic and the basic standards of behaviour expected in the society we live, should guide each employee in determining the correct course of action that supports these standards in their daily working lives. The standards of business conduct for Media Square, provide employees with guidance on their personal conduct. A guiding principle should be that neither the Company’s overall integrity nor its reputation would be damaged if full details of the business practice or transaction were publicly disclosed.

twentysix London Staff Handbook Standards Conflicts of Interest All employees should avoid situations where personal interests could conflict, or appear to conflict, with the interests of the business. Our reputation depends not only on our high quality services and products but also in the manner in which we conduct our relationships with suppliers, government officials, organisations and others outside the Company. Each employee must ensure that his/her conduct does not provide, or give the appearance of providing, him/her with personal gain at the expense of the company or any external business contact. Making or receiving illegal payments or inducements, such as bribes, are contrary to the policy of Media Square and the funds and resources of the company shall not be used directly or indirectly for any such purpose. Compliance with Laws, Rules and Regulations Media Square and their employees must obey the laws, rules and regulations of each country they operate in. If there is any doubt, guidance should be sought from the line manager who will decide whether to obtain specific legal advice. Employees who are involved in the preparation of any information that will be included in any public communication to shareholders or investors in any document or report that will be filed with the London Stock Exchange or the UK Listing Authority must ensure that such information is full, fair, timely and understandable. Protection of Confidential Information No employee shall without proper authority access, modify, divulge or make use of any trade secrets, confidential commercial company information for any purpose other than legitimately carrying out his or her duties. The obligation of confidentiality extends after employees cease working for Media Square and covers disclosure to others. Protection and proper use of company assets Our assets provide us with the foundation to provide our services and products worldwide. Each employee is responsible for the protection and wise stewardship of our assets. This includes being responsible for the establishment of, and adherence to procedures that ensure our assets are not put in jeopardy or used wastefully. Whether it is responsibility, for example, efficient plant and office maintenance, energy conservation, security, protection of information or effective control procedures ( including personal expenses ), every employee must seek to use all our resources with efficiency, honesty and the highest standards of care. All employees are prohibited from taking for themselves business opportunities that arise through the use of Media Square corporate, property, information or position. This includes obtaining personal gain or competing with the company. Relationships with customers and suppliers Each employee has the responsibility to ensure there are no compromises in delivering the highest standard of services and products and that every aspect of our operations which impacts upon quality promotes and reflects these standards. No one should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information or misrepresentation of material facts. 68

twentysix London Staff Handbook The giving and receiving of gifts, entertainments and gratuities between employees and suppliers or other outside business acquaintances represents a source of potential conflict of interests. Any significant gift likely to be deemed as influential upon decision making is unacceptable. Our Employees As employees we should treat each other with respect, courtesy and decency. Disparagement, harassment or negative comments regarding fellow employees or business contacts are inconsistent with these standards and every employee should refrain from, and should discourage, such behaviour. Media Square are committed to offering equal employment opportunity, including access to training, development and promotion opportunities, based upon the position and each employeeâ&#x20AC;&#x2122;s abilities, performance and commitment to these standards. Specifically, it is contrary to these standards for there to be any discrimination that contradicts Media Squareâ&#x20AC;&#x2122;s Human Resources Policy. Each employee is to ensure that his/her conduct does not place their personal safety or the safety of others in jeopardy. This requires an active participation in maintaining a safe working environment and includes observance of established safety procedures and making recommendations for changes when they are required. In all circumstances, including when travelling on company business, each employee is to conduct himself/herself in a professional, mature and responsible manner at all times. Compliance with this code and reporting of any unethical behaviour All employees are expected to comply with the company standards of business conduct policy, failure to do so will result in disciplinary action being taken which, in the case of serious breaches, could lead to dismissal. Media Square must be made aware of any failure to adhere to the standards. The details of any concern should be reported honestly, accurately and without malice. We will respect the wishes of staff raising concerns if they ask for confidentiality, but Media Square may need to act to protect its employees, clients and business. In the first instance, any concerns should be raised with the individualâ&#x20AC;&#x2122;s line manager, director in charge or any other senior person within Media Square with whom the employee feels comfortable. They will either act on the information or pass it to the relevant person who can deal with it. If the matter is not dealt with in a manner the employee feels is appropriate, or it is not possible to discuss the matter with the line manager for any reason, the matter should be reported to the Director of Employee Services. Employees should be satisfied that, in making a disclosure, they are acting in good faith and genuinely believe that the information and allegations are substantially true. Media Square will respect the wishes of employees raising concerns if they ask for confidentiality but Media Square may need to act to protect its employees, clients and businesses. Appropriate steps will be taken to ensure that the working environment and/or working relationship are not prejudiced as a result of the disclosure. Any person who acts or attempts to act in a prejudicial way towards a whistleblower will be subject to the disciplinary procedures at Media Square. Scope Every employee and director of the company is expected to comply with these standards and to behave in a mature, professional and responsible manner. Responsibilities 69

twentysix London Staff Handbook The Managing Director is the sponsor of the standards of Business Conduct Policy. Department Heads are responsible for implementing, promoting and monitoring compliance with the policy in all their business areas.

twentysix London Staff Handbook

HEALTH AND SAFETY Health and Safety Policy Media Square health and safety systems are based on HSG 65 – Successful Health and Safety Management – which is an HSE document. The message it conveys is that companies need to manage health and safety with the same degree of expertise and to the same standards as other core business activities, if they are effectively to control risks and prevent harm to people. Media Square comply with this approach and this ensures a continually improving health and safety performance. Media Square ensure that compliance with health and safety legislation is the minimum standard we work to. However we endeavour to raise our standards to achieve industry best practice standards. Each business area working with the group health and safety manager is responsible for identifying health and safety risks associated with its activities, and for developing, implementing and maintaining management standards leading to continual improvement in our health and safety performance. The group health and safety manager is responsible for establishing safety objectives and monitoring safety performance in each business area including auditing with an associated programme of risk improvements. The framework for health and safety at Media Square is the ‘stand alone’ health and safety policy document. Scope The policy statement applies to every business within Media Square. The health and safety committees comprise of both workers and directors for each area of the business. The committees are responsible for raising, discussing and agreeing objectives and standards for health and safety. Responsibilities Business heads are responsible to the Managing Director for health and safety within their business areas. The group health and safety manager is responsible for the group health and safety policy and overall monitoring of health and safety issues, reporting to the Managing Director and to the board at least annually.

twentysix London Staff Handbook HUMAN RESOURCES Human Resources Policy Media Squareâ&#x20AC;&#x2122;s aim is to deliver a competitive and fair employment environment and the opportunity to develop and advance personally and as a company. This is achieved by the following standards: Equal Employment Opportunity Media Square supports the principle of equal employment opportunity and is opposed to all forms of unlawful discrimination on the grounds of sex, race, nationality, ethnic or national origin, religion, marital status, sexual orientation, disability or age. Media Square companies will conduct their businesses in a way that seeks to ensure individuals are treated equally and fairly and that all employment, training and career development decisions are made on a job based criteria. All personnel are expected to comply with this policy and are required not to discriminate, harass or victimise others. A breach of this policy will lead to disciplinary action, which could include dismissal. The framework for human resources is the company handbook. Recruitment and Development Media Square aims to appoint the best person for the job. All appointments should be based on individual performance and job based criteria. Media Square policy is to encourage employees to manage their own careers and ensures this by providing appropriate job training, and where appropriate, aiming to fill vacancies with existing staff who are suitably qualified and experienced. Communication Media Square policy is to communicate with employees to ensure understanding of the businesses and the impact business decisions have on employees and to obtain feedback and ideas of employees to improve the operation of the business. Redundancy Media Square will manage restructuring by detailed planning, consultation with individuals or elected employee representatives, as appropriate, prior to implementation of redundancies and where job losses are unavoidable, seeking alternative opportunities to minimise the personal impact as far as possible. Scope The policy statement applies to all staff. Responsibilities The local company Managing Director is the sponsor of the company Human Resources Policy within each individual company location. All managers reporting to him have a responsibility to monitor the implementation of the policies and report back where necessary 72

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ENVIRONMENT Environmental Policy Our objective is to endeavour to reduce/minimise our impact on the environment through a commitment to pollution control, continual improvement and compliance with environmental legislation and regulations. Each business area working with the group Environmental manager is responsible for identifying any adverse environmental impact associated with its activities, products and services and to control them by developing, implementing and maintaining management systems which are consistent with this policy and which reflect the environmental circumstances of the business and the needs of their customers. The group environmental manager will set targets, monitor performance and carry out environmental audits. This will ensure that through the efficient use of resources a reduction in any adverse environmental impacts will be achieved whilst also positively influencing business performance. The framework for environmental issues at Media Square is the â&#x20AC;&#x2DC;stand aloneâ&#x20AC;&#x2122; Environmental policy. Scope The policy statement applies to all staff. Responsibilities The Managing Director is the sponsor of the environmental programme. The Group Environmental Manager reports to him and to the board at least annually on the environmental programme. The Group Environmental Manager is responsible for overall monitoring of the environmental programme. SUPPLIERS Company Ethical Trading Policy Media Square regards suppliers as partners and works with them to help us achieve our policy aspirations in the delivery of our products and services by ensuring that the welfare of workers and labour conditions within our supply chain meet or exceed recognised standards. Each business area is responsible for ensuring all those affected by their supply chain are producing goods and services which adequately meet recognised minimum requirements for worker welfare and conditions of employment. This will be achieved by the Group Hygiene and Product Safety Manager carrying out an audit programme as per the BRC/IOP technical standard of all the approved suppliers. Suppliers who are unable to meet all of the requirements after an initial audit will be given the opportunity to comply, within a set period of time the areas that need improving. 73

twentysix London Staff Handbook An action plan will be given to the supplierâ&#x20AC;&#x2122;s management team for them to address. If Media Square has reason to believe that the supplier is not making sufficient progress, then this could lead to the supplier being removed from the approved suppliers list. Media Square reserve the right to cease a relationship with a supplier if it is found that unacceptable practices are being employed such as the use of child labour, forced or bonded labour as well as physical abuse or discipline and extreme forms of intimidation. Scope The policy applies to all staff in the company. Responsibilities Overall company ethical trading issues are the responsibility of the Managing Director supported by the business heads who are responsible for implementing and monitoring ethical trading policies in the business.

COMMUNITY Community Investment Policy Media Square is committed to being a responsible corporate citizen through support for appropriate projects, organisations and charities. Media Square sponsor projects within registered local charities such as healthcare, education, disability, children etc. All employees are encouraged to act as responsible and responsive citizens of their communities and to support projects, organisations and services that work towards the common good and improvement of their community and society. Scope The policy statement applies to all staff. Responsibilities The Managing Director and the Director of Employee Services oversee corporate sponsorship and charitable giving.

twentysix London Staff Handbook Appendix 2

Health & Safety Policy

twentysix London Staff Handbook Company Policy for Health and Safety At Work This document contains the policy statement and general policy of the company with respect to health and safety. It is the responsibility of management to know and understand its contents so that they may implement company policy. The Health and Safety at Work Act 1974, requires Employers to prepare and, as often may be appropriate, revise their written statement of general policy with respect to the health and safety at work of their employees, together with the organisation and arrangement in force at the time for carrying out the policy, and to bring the statement, and any revisions, to the notice of all employees. General Policy Statement The Executive Directors and Management of Media Square and associated companies regard the promotion of health and safety measures as a mutual and essential objective for management and employees alike, at all levels. It is therefore, Company Policy to do all that is reasonable and practicable in securing the health and safety of employees and to protect all other persons such as customers, contractors, visitors and members of the public, in so far as they come into contact with the Company’s activities and premises. This document sets out the main principles to be applied in all the Company’s establishments. Policy Objectives In pursuance of this Policy, the Company acknowledges its objectives and responsibilities to: Provide and maintain a safe and healthy work environment for every employee, contractor and temporary employee. Secure the safe and efficient operation of Company activities by the prevention of accidents and damage to property taking into account all Statutory requirements and approved Codes of Practices. Inform employees of safety regulations applicable to them, and to provide training and instruction to enable employees at all levels to perform their work safely. In particular, employees will be required to comply with their obligations within this policy and contribute positively to their own health and safety at work as well as others. Maintain constant and continuing interest in health and safety matters applicable to the Company’s activities, in particular, by consulting and involving employees wherever possible. Encourage the participation of the individual operating Company Safety Committees and to cooperate fully in the appointment of safety representatives, providing sufficient facilities and training to carry out this task. Make available and supervise the use of all necessary safety devices, documentation and protective equipment, which are considered reasonable in securing personal safety. Monitor safety performance with regard to this policy by carrying out Management Safety Tours and Safety Committee Inspections. Provide any medical, welfare, safety services and advice that are necessary to implement this Policy. Having defined the Company’s responsibilities and objectives, it is also important to recognise that all employees have a statutory obligation and responsibility to co-operate in the maintenance of healthy and safe working conditions. -

twentysix London Staff Handbook Compliance with the Health and Safety Policy is a legal duty. Non compliance with this Policy renders the Company, Directors and or employees answerable to the authorities and or to a Court of law It cannot be stressed enough therefore, that the Company Health and Safety Policy has to be a meaningful document, and one that must be fully implemented. Organisation and Responsibilities for Health and Safety Executive Responsibility The Media Square CEO has overall responsibility for Health and Safety for all premises. He is fully committed to fulfil the requirements of this Policy document, the Health and Safety Work Act 1974 and other relevant legislation. He has special responsibility to ensure that resources are available to implement and maintain this Policy. He will ensure that everyone co-operates with him and his senior Management in maintaining a safe place of work. The Media Square CEO in conjunction with the Director of Employee Services will periodically review the effectiveness of this Policy and the personnel to whom operational responsibility for health and safety have been assigned. All individual operating company Managing Directors / CEOâ&#x20AC;&#x2122;s have the operational responsibilities for health and safety throughout their business, and are accountable to the Media Square CEO for the compliance and effectiveness of this Policy. The Director of Employee Services together with the Group Finance Director has the primary and supportive responsibility to the Media Square CEO for the allocation and budgeting of financial resources to health and safety. They will ensure that specific Company insurance policies remain current: in particular Employers Liability, Fire and Security Risk, Plant and Engineering Services, and Public/Product Liability. The Director of Employee Services is also responsible for advising the Media Square CEO and or the Group Financial Director of any financial implication for work considered necessary in the interest of health and safety. Other responsibilities are: -

Ensuring that fire-fighting equipment is available and properly serviced on a regular basis. Compile emergency procedures and ensure that all employees are instructed in these procedures. Ensure that fire drills are carried out at regular intervals. Ensure that the fire authorities have site plans and have immediate access to locked areas.

The Director of Employee Services is responsible for supervising the implementation of this Policy, in conjunction with local operating company management. They are responsible for ensuring that the local health and safety committee has been organised. Other duties include audit, review and monitoring the performance of, and providing consultancy on, the implementation of this Policy. A report will be given to the Media Square CEO on a regular basis, following the meetings.

twentysix London Staff Handbook Managers and Supervisors Departmental Managers and Supervisors are responsible to their Managing Director / CEO for the day to day compliance of this Policy throughout their particular areas. General health and safety duties apply to all Managers and Supervisors such as: -

Actively encourage the awareness and compliance with this Policy. Ensure that all new employees attend a formal health and safety induction. Ensure that all new employees are provided with a copy of the Health and Safety Policy and any relevant safety code of practice documents. Ensure risk assessments are carried out on a regular basis. Regularly inspect the departments and working areas in their control and rectify any infringement as a matter of priority. Ensure that employees receive sufficient information, instruction and training to carry out work safely. Any change in the process must be brought to the immediate attention of all employees. Provide the correct tools and equipment for each work activity and ensure they are used only for the purpose intended and regularly checked and maintained. Carry out workplace assessment and inspections (Housekeeping) on a quarterly basis paying particular attention to “non-generic” risks. Take remedial action concerning adverse working conditions whenever these are found to exist. All matters of concern that cannot be resolved by individuals are referred to the Director of Employee Services. Provide written job instructions, warning notices and signs as necessary. Ensure that protective clothing is always worn and special safety equipment is always used when conditions and operations demand. Include health and safety matters on the agenda of departmental meetings at least once a quarter, and ensure that there is a report back on matters raised. Give all employees proper instruction on safety rules and practices, and ensure that all rules are adhered to. Ensure that all temporary, contracted staff and visitors are well acquainted with appropriate health and safety information. Investigate, report and record all accidents and near misses, however slight.

MANAGERS TRAINING RESPONSIBILITIES It is the Manager’s / Supervisor’s responsibility to ensure that safety training, whether general or specific to tasks or individuals, is recorded in the appropriate employee file. Managers must ensure new employee induction includes details of the health and safety policy and all local rules, including fire precautions. This will also apply when employees are transferred from one job to another or from one location to another. It is the Manager’s responsibility to ensure that each employee is competent to perform his or her work safely, and has received individual safety instruction associated with the work. The training or the arrangements for training of employees operating machinery is part of the Manager’s responsibility.

twentysix London Staff Handbook Employees Responsibilities Each employee has a duty under the Health and Safety at work Act 1974, to care for his/her own safety and the safety of others, and to co-operate with the company to ensure a safe place of work. Employees are therefore expected to: -

Conform to Company safety rules and procedures, jointly agreed on their behalf. Nominate representatives for site safety committees. Use and properly maintain all safety devices and personnel protective equipment provided, and to report any defects. Ensure that all office equipment is safe to use and that there is safe access to all parts of the office premises. Maintain the highest standards of housekeeping, ensuring that all electrical equipment is correctly connected and arranged in such a manner to eliminate any hazard. Learn to recognise hazards and report them promptly to Managers or Supervisors. Report to management any accident, incident or near miss, whether it be of personal injury or property damage. Assist in the investigation of accidents with the objective of introducing measures to prevent recurrence. When working on, or visiting clientâ&#x20AC;&#x2122;s premises, employees shall take note of the clientsâ&#x20AC;&#x2122; Fire, Safety and Emergency procedures, and comply with them fully. Thoroughly read all safety documentation issued by the Company and comply with its requirements. If the employee is in any doubt as to their safe working duties, and or responsibilities, they must initially discuss the matter with their supervisor and management thereafter. Be aware of the location of the First Aiders, Fire Escape Routes and Fire Fighting Equipment. Understand the Company fire evacuation and emergency procedures and participate with their organisation. Make a positive contribution to the health and safety performance of the Company to ensure a safe and healthy working environment.

Obligations to Employees with Special Needs The Disabled Persons (Employment) Act 1995 makes it unlawful to discriminate against disabled people in the area of employment, the provision of goods and services and facilities, and the buying/renting of land or property and also in the areas of education and transport. Our Company will: -

Give disabled people full and fair consideration for all employment vacancies Make reasonable adjustments to the workplace to accommodate disabled employees Contact disabled employees at least once a year to ensure that they have all they need to achieve their full potential If employees become disabled, ensure that they are not discriminated against Take action to ensure that all employees develop sensitive awareness of disability, enabling these commitments to work. Each year, review these commitments and: Assess achievements Plan ways to improve Inform all employees of progress made and future plans 79

twentysix London Staff Handbook Areas of Health and Safety Risk Assessments To comply with the Management Health and Safety at Work Regulations 1992, all Managers must make a risk assessment of their work activities. (See “Generic Risk Assessment”). The risk assessment is made in order to identify protective and preventative measures – significant findings must be recorded. Arrangements have to be made for the planning, organisation, control, monitoring and review of the preventative and protective measures – these must also be recorded. Ensure that employees receive appropriate health surveillance, where this is shown to be necessary by the risk assessment. Set up emergency procedures. Only allow persons with sufficient health and safety instruction to have access to restricted areas. Provide employees with sufficient information, instruction and training relating to their work activities and health and safety practices. Provide temporary workers with sufficient health and safety information and if required, the nature of any health surveillance needs. Ensure that temporary workers have the skills needed to be able to carry out the work safely. Provide relevant health and safety information to the employer of any outside contractor, and also provide the contractor with adequate instruction and information. Liaise with the Health and Safety Specialists and other professionals to ensure compliance with health and safety law. EMPLOYEES DUTIES The Management of Health and Safety at Work Regulations oblige employees to: -

Use any equipment provided in the interests of safety. Follow health and safety instructions. Report anything they consider to be a serious danger. Report any shortcomings in the protection arrangements for health and safety.

Manual Handling Operations To comply with the Manual Handling Operations Regulations 1992 Media Square will, in so far as is reasonably practicable, secure the health and safety of all employees by means of consultation with workers and their representatives: -

Carry out an initial assessment of manual handling operations throughout the company to identify activities involving risk. 80

twentysix London Staff Handbook Endeavour to eliminate risk in manual handling activities wherever practicable by:o removing the need for the operation o automating or mechanising the operation Where onerous manual handling activities cannot be eliminated, appoint suitably qualified assessors to carry out a detailed assessment of the potentially risky manual handling operations, considering in each case, the task, the load, the working environment and the individual capability. Put in place a system of measures to reduce the risks associated with remaining operations based upon the results of the assessment, concentrating upon changes to the task, the load and working environment. Wherever possible, ensure that loads including those loads delivered from outside the company are marked with sufficient information to facilitate safe handling. Provide general training on principles of manual handling for all employees engaged in such activities, outlining the risks to health and how they may be avoided. Provide specific training on manual handing where the assessment indicates it is necessary. Ensure that allocation of manual handling operations takes account of the individual circumstances of the worker concerned. Review the assessments should the conditions change.

HEALTH PROBLEMS ARISING FROM MANUAL HANDLING Where an employee raises a matter related to health and safety in relation to manual handling of loads, the company will: -

Take all the necessary steps to investigate the circumstances.

Take corrective measures where appropriate.

Advise the employee of actions taken.

Where a problem arises involving the manual handling of a load, the employee must adopt the following procedures and inform the department Supervisor/Manager immediately.

INFORMATION AND TRAINING The Company will give sufficient information, instruction and training as is necessary to ensure the health and safety of workers carrying out manual handling of loads. This provision will also apply to those persons not in direct employment, such as temporary staff. Self employed contractors and contractors working for another employer, will be reminded of their responsibilities under the Regulations and given sufficient information about the loads to enable them to meet their responsibilities. Personal Protective Equipment (PPE) All personal protective equipment issued by the company will be assessed for its potential impact on manual handling operations. During the process of assessment, the equipment will be reviewed to ensure that it is fit for the workplace. 81

twentysix London Staff Handbook Particular consideration will be given to the features that may influence grip on the load, damage due to loads or their contents, reduced communication, reduced visibility and the risk of tripping or slipping. Employees will be reminded to report any incidents where PPE appear to impair their ability to handle loads, and of their duty to report any damaged or ill fitting items. The management will undertake to replace all damaged equipment immediately it is reported.

Hearing Conservation The Noise at Work Regulations 1989 are designed to protect workers and principally require that employers prevent damage to the hearing of workers from exposure to excessive noise in the workplace. All Managers should assess the noise levels to which their employees are exposed, where they believe exposure reaches or exceeds the action levels defined in the Regulations. EMPLOYEE DUTIES Employees must co-operate with the noise assessment. Use and take care of silencers, enclosures or refuges, which are provided. Use and take care of the personal protective equipment, which is provided. Report any defects in equipment or problems in its use.

Electrical Safety The Electricity at Work Regulations 1989: To comply with legislation, the company will ensure the provision of safe electrical systems and equipment and to provide adequate maintenance to assure its continued safety. This will require attention to be focused on the following: -

The fixed electrical supply system. All fixed electrical plans installed on Company premises. All portable and transportable electrical equipment on Company premises irrespective of the ownership of the equipment, the method by which it was brought onto site or its source. All systems of work involved in the installation, commissioning, operation, testing, maintenance and finally the de-commissioning and disposal of electrical system, plan and equipment must be safe and without risk to the health of the company workforce, the general public and all visitors. The Company will provide adequate information, instruction, training and supervision as is necessary to ensure the safety of all persons involved with or near electricity. To ensure that workers are competent. To employ only competent and qualified third parties such as contractors and advisers and to provide them with a safe place of work. The Company will maintain safe conditions and provide a safe environment within the workplace. To provide personal protective equipment where necessary to prevent injury from electric shock or burns. A code of safe practices is established and enforced. This shall include the instruction to avoid â&#x20AC;&#x153;liveâ&#x20AC;? working whenever practical. 82

twentysix London Staff Handbook Electrical devices used in the area are regularly inspected. Inspections and corrective action shall be documented. Safe access or work clearance is maintained around all electrical panels, switches and controllers. Safety practice and procedure manuals are available at all times.

twentysix London Staff Handbook EMPLOYEES DUTIES Each employee is responsible for following electrical safety practices and procedures: -

Not to interfere with any electrical equipment, unless they are competent and authorised to do so. To report all unsafe conditions and faults immediately they are observed and to switch off the electrical system or equipment concerned, where this action will prevent danger and providing that such action will not create a further hazard. Not to undertake unauthorised temporary repairs in order to continue a work process. To only use equipment that is known to be within its current safety test certification period and is marked to that effect. To assist Management by adhering to the health and safety guidelines at all times, so as to ensure a safe working environment for everyone to enjoy.

Control of Substances Hazardous to Health (COSHH) The Control of Substances Hazardous to Health Regulations 1994 apply to our working environment. We recognise that some substances have the potential to cause ill-health and we will introduce measures to identify what substances our employees use or are exposed to in the course of their work. Whenever we can, we will discontinue the use of harmful substances (so long as this can be done without serious detriment to our business). These substances will be sent for disposal and no more obtained. Where a harmful substance is being used, we will replace it with a suitable and less hazardous substance wherever possible. Substances that we must use will be assessed and control measures introduced to prevent risk to our employees or others affected by our business operations. Where reasonably practicable, these measures will not involve personal protective equipment (PPE). We will assess the use of all new substances introduced into the workplace. At least once a year, we will make an inventory of all substances present on site and review our control measures, to ensure that the management controls are still appropriate and effective. Where PPE must be used, employees will be provided with the appropriate equipment, which will be maintained, repaired and tested as required by each class of protection. Information, instruction and training will be provided for all employees who may be exposed to hazardous substances. The necessary information and training will also be provided for any nonemployees working on site who may be exposed to hazardous substances. EMPLOYEE DUTIES Employees must co-operate with management to fulfil the requirements under health and safety law. Employees must not interfere with any controls, which are installed in order to prevent exposure to substances. 84

twentysix London Staff Handbook COSHH regulations place a duty on employees to use any controls that are supplied to control exposure, and to report any defects therein.

Display Screen Equipment The Health and Safety (Display Screen Equipment) Regulations 1992 are directed at the protection of employees who habitually use display screen equipment as a significant part of their normal work. To comply with these regulations, the Company will: -

Analyse all workstations to assess risks to User health and safety, and reduce those identified to the lowest extent reasonably practicable. Ensure that all workstations comply with the Regulations. Plan User activity so that work at the display screen is periodically interrupted by breaks or changes of activity. Pay for eye/sight testing if an employee requests it before the employee becomes a User and/or at regular intervals thereafter, or if the employee experiences visual difficulties related to display screen work. Pay for any special corrective appliance, which may consequently be prescribed by an Optometrist/Ophthalmic Optician or suitable qualified Medical Practitioner for specific VDU use only. Provide health and safety information and training to all Users of VDU and Laptops (including temporary or contracted employees) as appropriate. Provide a Laptop User Policy, which restricts the use of laptops to 1 hour without a break or change in activity.

EMPLOYEE DUTIES Individual users have a part to play in reducing or minimising visual, musculo-skeletal or stress-related risks by: -

Correct and timely detection and recognition of hazards and risks and understanding how health problems may be manifested. Consciously adopting a comfortable posture when working and recognising the importance of postural change. Using adjustment mechanisms on equipment (particularly furniture) to reduce stress and fatigue. Using and arranging workstation components to facilitate good posture prevent over-reaching and avoiding screen glare and reflection. Ensuring that screens are cleaned regularly and equipment is properly maintained. Co-operating with measures introduced by the employer to ensure breaks in screen related work (to undertake other activities or take schedule rest breaks). Informing their Manager of problems relating to workstations and any symptoms of ill health suffered which they believe may be related to display screen equipment work.

LAPTOPS / PORTABLES The use of laptops without adequate breaks or changes in activity puts Users at risk of developing musculo-skeletal strains, pains and possibly longer term problems, including chronic upper limb disorders. The likelihood of experiencing these is related mainly to the frequency, duration, intensity 85

twentysix London Staff Handbook and pace of spells of continuous use, allied to other factors such as the amount of discretion the person has over the extent and methods of display screen use. If a portable is in use for prolonged periods the following should be considered: Do not use a portable longer than 1 hour without a break or change in activity. Use of a docking device, a full size keyboard and mouse. Eyesight Test for Display Screen Equipment Users Under the Display Screen Equipment Regulations, employees defined as display screen equipment users must be provided with an eyesight test upon request. Such a request may be made before commencing work as a user. These tests are designed to determine if the user requires special corrective lenses to enable the screen to be viewed comfortably at the normal viewing distance. The test to be carried out is a VDU eyesight test as carried out by an optician. If special corrective lenses are required, these must be provided by the Company without cost to the employee. Where the employee wishes to have special frames or other more expensive corrective appliances the Company is only liable for the basic cost. Retesting will normally be permitted once every two years. If an employee wishes a test at a shorter interval they must obtain authorisation from the local Managing Director / CEO. Normally only basic lenses and frames will be provided, where an employee requests special more expensive frames or lenses these will be provided by the Company only where there is a special optical/medical reason confirmed by the Optician / Company Doctor. In any other circumstance the employee will be requested to pay the additional cost.

twentysix London Staff Handbook Fire Since the introduction of the Fire Precautions (workplace) Regulations 1997, with the exception of businesses whose activities are covered by a fire certificate, employers have been required to conduct a fire risk assessment. Failure to comply with the Regulations constitutes a criminal offence. Environmental layout, route or exit changes or improvements which might affect the terms of the Certificate or Risk Assessment must be notified to the Fire Authority who must be consulted prior to activating any new plan. The Fire Authority may choose to inspect the Company’s premises at any time to ensure that we: -

Display the fire Certificate or Risk Assessment as appropriate. Have efficient Fire Alarm systems. Regularly test and practice evacuation procedures. Keep records of the testing in the general register of appliances. Have an appropriate Fire Exit signs/smoking policy. Provide on-site well maintained fire fighting equipment and extinguishers. Maintain statutory storage provisions for flammable substances. Provide employees training. Provide and maintain visible notices and instructions of the evacuation procedure.

EMPLOYEES DUTIES Employees have obligations to be aware of: -

Action to be taken upon discovering a fire. Action to be taken upon hearing an alarm. Method of raising the alarm and calling the Fire Brigade Location and use of Fire Extinguishers. Escape routes. Actions to be taken during evacuation of the Building and knowledge of Assembly points.

First Aid The Health and Safety (First Aid) Regulations imposes duties on the Company to provide facilities and equipment that enables first aid to be rendered to employees if they are injured or become ill at work. The Company will ensure that it meets the statutory requirements by: -

Providing an adequate number of first aiders in all the Company’s premises. Ensuring that all first aiders in the Company’s premises are trained and aware of their responsibilities. Ensuring that the names, location and telephone numbers of trained first aiders are well displayed throughout the Company, i.e.: by First Aid Boxes, notice boards and Reception. Ensuring that First aid rooms are fully equipped and readily available at all times. Ensuring that First Aid boxes are also provided and maintained fully equipped.

twentysix London Staff Handbook EMPLOYEES DUTIES Employees trained as First Aiders must ensure that they attend regular refresher training and maintain current certification. First aiders must only render treatment in which they have been fully trained. In the event they render first aid, they are expected to act prudently and exercise reasonable care. All employees must be familiar with the procedure for dealing with an accident or illness. In the event of accidents at work, this must be recorded as soon as possible on Accident Forms. If any accident causes loss of life, serious injury or dangerous occurrence, this must be reported immediately to senior Management. Any fatal, major injury or over 3 days lost time accident, and any notifiable dangerous occurrence, must be reported to the Health and Safety Executive, in accordance with the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995. The Director of Employee Services must be informed of any such reports and copies of correspondence should be forwarded accordingly. Occupational Ill-Health The Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR) require us to report certain diseases to our enforcing authority. Supervisors will provide their staff with information on any occupational diseases associated with their work activity, where relevant. Any employee who notices any of the symptoms of, or is diagnosed by a doctor as having, any relevant occupational disease must report this to their supervisor, local health and safety representative / Managing Director / CEO and the Director of Employee Services as soon as possible. We will take all reasonably practicable measures to prevent out employees from contracting any occupational disease. If an occupational disease is contracted, wherever possible we will take steps to protect the employee against further exposure while keeping them in their normal job. If this is not possible, we will try and offer the employee suitable alternative work. In some cases, we may have to suspend employees to protect their health. This will only be done after all other alternatives have been considered but are not reasonably practicable. Not reporting an occupational disease associated with your work activity is a disciplinary offence. Managers and supervisors must report any occurrences of occupational diseases to the local health and safety representative / Managing Director / CEO and the Director of Employee Services. The local health and safety representative / Managing Director / CEO will report all cases of reportable diseases to the enforcing authority. 88

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Visitors The Health and Safety at Work Act 1974, Management Of Health and Safety at Work Regulations 1992 and Occupier’s Liability Act 1957 apply to visitors on our premises. Our policy regarding the control of visitors on our premises is as follows: -

We must be aware that the visitor is on our premises.

Our Visitors’ Rules follow this section and should be explained to our visitors on their arrival.

As far as possible, an employee will accompany visitors. Visitors will not be permitted to wander freely around working areas. This is important for safety and security reasons.

Should a fire occur, the person who is accompanying the visitor will take him/her to the fire assembly point.

Should an incident occur involving the visitor which results in injury, this will be recorded on an Accident Form and a thorough investigation carried out as soon as possible.

If the injury is of serious nature or is fatal, the incident must be reported to the enforcing authority and the company’s accident reporting system must be followed.

All visitors must: -

Follow the fire procedures displayed on the premises Adhere to “no smoking” controls Either be accompanied or authorised to enter the premises Remain within authorised areas and must not enter any restricted areas unless accompanied Not take anything from the premises without permission Report all incidents and/or injuries to the host Where appropriate, wear protective clothing, which will be supplied when necessary

twentysix London Staff Handbook Young Persons We will carry out a suitable and sufficient risk assessment for all work involving young persons (16 to 18 years old) prior to their employment, and will communicate the result of this to them on their commencement of work. Risk assessments for work involving young persons will be modified with the following considerations relating to their: Physical and psychological capacity to carry out the work effectively Potential exposure to toxic or harmful substances or agents (including radiation) Inexperience in the recognition of potentially hazardous situations, or lack of training Potential exposure to extremes of heat or cold, noise or vibration Where young persons or school age children (on work or other experience schemes) may be exposed to risk, their parent or guardian will be advised of the identified risks.

Pregnant Workers The Management of Health and Safety at Work (Amendment) Regulations 1994 and the Maternity (Compulsory Leave) Regulations 1994 apply to any of our employees who are pregnant, breast feeding or who have given birth within the last six months. The Workplace (Health, Safety and Welfare) Regulations 1992 require us to provide rest facilities for new or expectant mothers. We will extend existing risk assessments to cover new and expectant mothers. These will be recorded and female workers informed of any additional risks they may face if they become pregnant or are breast-feeding. We recognise the extra vulnerability of pregnant and nursing mothers and additional risk assessments will be made when a woman notifies her manager that she is pregnant. Any additional measures agreed will be applied for six months after the birth. We are only required by law to take extra precautions for pregnant or nursing mothers if we are notified of their conditions. If pregnant employees do not provide confirmation from their medical practitioner, we will request medical confirmation. Our display screen equipment workstations, e.g. computer terminals, are properly assessed and controlled and there is no additional risk to pregnant women or nursing mothers. Additional risks to pregnant women and nursing mothers will be minimised. As required by law, if additional risks to pregnant women and nursing mothers cannot reasonably be reduced, we will find alternative work (with no loss of terms or conditions), or authorise paid leave if alternative work is not available.

twentysix London Staff Handbook Work Equipment The Provision and Use of Work Equipment Regulations 1998 apply to the functioning and safety of our work equipment. Where reasonable, we will adapt the work equipment, or its use, to those employees with disabilities, as long as this creates no additional hazards. In order to minimise the risk of injury from work equipment, we will put in place arrangements for the assessment of risks and then create appropriate control measures to minimise the risks identified. These measures will include the following arrangements and procedures: -

A full assessment of all new or secondhand equipment purchased. All equipment purchased will comply with any relevant product safety standards. All hired or rented equipment will be required to comply with the Regulations, and will include the provision of comprehensible information on safe use. Inspection of the equipment and testing where necessary. A log for all equipment that could give rise to serious injury. Adequate and identifiable means of isolation, where appropriate. The provision of suitable and effective safety devices. The provision of suitable and effective controls. Suitable and readily comprehensible signs and warnings Suitable general, task and emergency lighting. Suitable training.

These arrangements will be reviewed at least annually and on any significant change in the type, nature or use of equipment. In departments or areas where the workforce has employees whose English is poor, the information will be provided in appropriate languages, either written or spoken. EMPLOYEES DUTIES Employees are reminded that they have a legal obligation under the Management of Health and Safety at Work Regulations 1992 to inform their manager of situations where they see serious and imminent danger to health and safety, or any matters where they see shortcoming in our arrangements for health and safety protection. The Indoor Environment The Workplace (Health, Safety and Welfare) Regulations 1992 govern the health and safety of our indoor, working environment. Where reasonable, we will adapt the premises and facilities to those employees with disabilities. It is our policy to provide a working environment that is both comfortable and that maximises the effectiveness of employees. In order to achieve this, we will put in place arrangements for the assessment of risks from the working environment and provide, maintain and monitor appropriate control measures to minimise the risks identified. 91

twentysix London Staff Handbook EMPLOYEES DUTIES Employees are reminded that they have a legal obligation under regulation 12(2) of the Management of Health and Safety at Work regulations 1992 to inform their manager of situations where they see serious imminent danger to health and safety, or any matters where they see a shortcoming in our arrangements for managing health and safety.

Mobile/Peripatetic Workers The Health and Safety at Work, etc. Act 1974; the Management of Health and Safety at Work Regulations 1992, and the Workplace (Health, Safety and Welfare) Regulations 1992 apply to our employees who visit other premises in the course of their work (peripatetic workers). We recognise that this work is carried out in places that are not under our direct control. We will provide additional measures, such as information, instruction and training, to ensure their safety on the premises of others. Where any of our employees are on other premises for anything other than short periods, we will ensure that those in control of the premises are aware of the proposed activities of our employees, by means of a risk assessment. ARRANGEMENTS AND PROCEDURES FOR PERIPATETIC WORKERS None of our peripatetic workers will be expected to work on the premises of others without being advised of the hazards they may face and how to deal with them. We will require all clients to provide our employees with written information on emergency procedures, when appropriate. Clients will be asked to make available their first-aid arrangements, sanitary and washing facilities, and their facilities for rest, eating meals, and where available, their catering arrangements. When clients do not wish to make any of their facilities available, our employees will be given sufficient time to locate local alternatives for breaks and sanitary facilities. EMPLOYEE DUTIES Employees on clientâ&#x20AC;&#x2122;s premises must conform to all their arrangements for fire, security and liaison, such as signing the visitorsâ&#x20AC;&#x2122; book, observing no smoking areas and reporting to named managers before starting or leaving work or moving to a different area.

Temporary Workers The Health and Safety at Work Act 1974 and the Management of Health and Safety at Work Regulations 1992 apply to the health and safety of temporary workers employed by our business.

twentysix London Staff Handbook Except where the temporary worker is retained for short periods (e.g. one day or less), they will be given information on the risks to their health and safety, including an induction covering the hazards of our business, emergency procedures and the management controls for those risks. Temporary employees will be exposed to the complete range of risks to which other employees are exposed. They will also be unfamiliar with many of the procedures and will need extra supervision for a period after their induction. Where the temporary worker is retained only for short periods they will be given information on emergency procedures, and will be continually supervised. ARRANGEMENTS AND PROCEDURES FOR TEMPORARY WORKERS Agencies of temporary staff will be required to provide evidence that they have a safety policy as a matter of contract between our business and the agency. The policy must include a statement that their workers will comply with our safety procedures whilst on our site. Agencies of temporary staff will be required to provide evidence of employerâ&#x20AC;&#x2122;s liability insurance. We will provide the agency with details of risks from our activities to the health and safety of personnel supplied by them. All agency or other temporary workers will be assigned to the supervision of a management member of the permanent staff. Where personal protective equipment (PPE) is required and agreed with agency, it will be provided at no less a standard than for permanent employees. Where there is no agreement, the agency will be required to provide staff who bring their own PPE. This will apply, for example, to staff using display screen equipment bringing their own glasses if they need visual aids, or maintenance operatives bringing their own safety boots if they are working in the warehouse. We will provide extra supervision for all work experience employees. We will carry out extra risk assessments for all work experience employees who are under the age of eighteen. Shiftworkers The Health and Safety at Work Act 1974 and the Management of Health and Safety at Work Regulations 1992 apply to the safety of shiftworkers on our premises. Staff who work during the night may experience fatigue or disorientation. We will provide them with training on how to avoid and deal with fatigue. Wherever possible, working at night will be voluntary. If pregnant workers or new mothers do not choose to work at night, they do not have to: we will provide them with alternative work, where necessary. 93

twentysix London Staff Handbook Adequate first-aid cover will be provided at all times for shiftworkers. Staff who word alone must follow the systems set up for reporting regularly to a designated person. If the work activity is anything other than low risk, lone working will not be permitted and adequate supervision will be provided. Contractors The Health and Safety at Work Act 1974 and the Management of Health and Safety at Work Regulations 1992 impose duties to safeguard the health and safety of those who are not in our employment, but who may be affected by our business activities. These duties also apply to a contractor on the premises, in respect of safeguarding our employees from his activities. We will endeavour to employ only competent contractors, who will be selected according to our specifications. One of our main duties is to ensure adequate co-operation between the business and the contractor. No contract will commence or continue unless a Manager has been placed in charge of liaison with the contractor. In addition, the Construction (Design and Management) Regulations 1994 may apply to the activities of some contractors. We will obtain competent advice on how to meet the requirements of the Regulations.

Accident Reporting It is our policy to report all accidents, industrial diseases and dangerous occurrences to comply with the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995. We will also record all injuries on Accident Forms, as required by the Social Security (Claims and Payments) Regulations 1979 The details of our enforcing authorities for notifying accidents and dangerous occurrences are recorded at each individual site. Employees must report all injuries to their manager immediately after treatment. The Accident Form must be fully completed for all injuries incurred at work, however minor. If, because of their injury, employees are incapable of making an immediate entry, then that entry must be made by their manager, the first-aider, the appointed person, or a nominated person. Following any accident of any severity that requires treatment, the employeeâ&#x20AC;&#x2122;s manager will notify the local health and safety representative / Managing Director / CEO, who will: -

Complete an accident investigation report Notify the enforcing authority if the accident is reportable Notify the Occupational Health Unit (if appropriate)

twentysix London Staff Handbook Following any accident of any severity that requires treatment, the employee’s manager will take statements and retain any other documents related to the accident, such as containers (with contents listed), equipment logs, environmental or process recordings, etc. If the injury is of a serious nature or if there is any doubt, the injured person will be sent to the nearest hospital for treatment. Although it is not our legal duty, we will notify the enforcing authority of injuries to non-employees, e.g. contractors, if the injury takes place on our premises and we become aware of it. Accidents and injuries that are reportable to the enforcing authority will also be reported to our employer’s liability insurer. ACCIDENT INVESTIGATION It is our Policy to investigate: -

All accidents resulting in any reportable injury or losses of any assets All accidents, however minor All near-misses

Employees should be aware that Local Authority Health and Safety Enforcement Officers can enter our premises without an appointment, at any reasonable time, to ascertain if the requirements of the law are being met. If they have reason to believe that a situation exists or may arise in, which there is potential for serious injury or death, they may enter work premises at any time. We will extend to them full co-operation. We will co-operate with our insurers, in order to reduce our premium as far as we can. If the insurers have any advice on reducing risk, we will follow that advice where reasonably practicable.

CHILD VISITORS Media Square make every effort to ensure the safety of all who visit our premises, the presence of children (under 16’s) present additional concerns. The dangers facing a child in the office are exaggerated by factors such as their size and inexperience, therefore it is essential that children are exposed to workplace dangers only when no alternatives can be found, for the minimum amount of time, and that a parent or guardian take full responsibility for their care and safety at all times. The Health and Safety at Work Act 1974, Management of Health and Safety at Work Regulations 1992 and Occupiers’ Liability Act 1957 apply to all visitors on our premises. Our policy regarding children visiting our sites is as follows: -

Children must be accompanied at all times by an employee parent or guardian. Children must be fully supervised at all times by an employee parent or guardian. Employees must have the full permission of line Management prior to bringing children onto sites. 95

twentysix London Staff Handbook Employees must take full responsibility for the care and safety of children visiting sites at all times. Contractor and Temporary employees are not permitted to bring children to site. Children visiting the sites must enter and be signed in, via usual Site Security protocols. Should a fire occur, the parent or guardian of the child must take him/her to the fire assembly point. Should an incident occur involving a child which results in injury, the parent or guardian must ensure that this is recorded on an Accident Form and a thorough investigation carried out as soon as possible. If the injury is of a serious nature or is fatal the incident must be reported to the enforcing authority and the Companyâ&#x20AC;&#x2122;s accident reporting system must be followed. Health & Safety Committees REGULATIONS The Safety Representatives and Safety Committees Regulations 1977. Management of Health and Safety at Work Regulations 1992, Health and Safety (consultation with employees) Regulations (1996) encourages employeeâ&#x20AC;&#x2122;s participation in maintaining health and safety in the workplace. Membership of the Committee shall consist of senior Management and employee nominated Safety Representatives, together with Managers to provide technical information, guidance and expertise. Meetings will be held regularly, and will be structured to cover the following objectives: -

To generally promote co-operation between all employees in formulating instigating, developing and executing measures to ensure health and safety at work. To study accidents/dangerous occurrences, industrial disease cases, statistics and trends with a view to reporting on some with recommendations for remedial action. To examine safety audit, inspection and survey reports and to recommend remedial action. To consider the impact of new legislation and information made available by the Health and Safety Executive and other related bodies. To assist in the development of safe working practices. To make recommendations on health and safety improvements and to monitor the effectiveness of safety training, communication and health and safety awareness in the Company.

Smoking, Drugs and Alcohol Smoking In the interest of the health of the workforce, the Company has declared a rule of no smoking in all areas where working activities are taking place. Smoking is only permitted in certain designated areas external to the building. Drugs and Alcohol Introduction of illegal drugs or controlled substances onto Company premises is forbidden. Additionally, no employee may work while under the influence of alcohol, drugs or a controlled substance. Violation of the policy may result in immediate involuntary termination. Employees using 96

twentysix London Staff Handbook prescription medications should be aware of side effects (drowsiness, dizziness etc). Employees using such medications should inform their supervisors of any side effects that may affect their safety. (NOTE: the Company has a commitment to respect employee confidentiality. Managers and Supervisors need only know about potential side effects, which may affect employee safety and measures to be taken to protect the employee).

twentysix London Staff Handbook Health and Safety Roles and Responsibilities All Management personnel have general responsibilities towards safety, which include, but are not limited to: -

Training employees in the safety and health aspects of their jobs. Informing employees of the nature and hazards of the materials they work with. Ensuring the periodic safety inspections are conducted in their respective areas. Ensuring that safety violations in their areas are corrected. Investigating accidents and near misses, and reporting them. Ensuring that maintenance and control inspections are carried out regularly and documented.

Ensuring that safety and health instructions and training are documented. Employee Duties It is the responsibility of all employees to: -

Comply with all safety rules and regulations which provide for their safety Report potential safety hazards to their supervisors so that appropriate corrective action can be taken.

Safety Violations Each employee is expected to comply with all safety rules and practices as defined throughout the Company premises. Failure to wear appropriate safety equipment or any other violation of safety measures is a serious matter. Therefore, it a verbal warning is not sufficient to correct the situation, the employee may be dismissed for the remainder of the day / shift â&#x20AC;&#x201C; without pay. If the returning employee continues to violate safety practices, the Supervisor may resort to more formal corrective action, up to and including involuntary termination.

twentysix London Staff Handbook Appendix 3

ENVIRONMENTAL POLICY

twentysix London Staff Handbook

CONTENTS

INTRODUCTION PART 1 - GENERAL POLICY STATEMENT PART 2 - ORGANISATION AND RESPONSIBILITIES ORGANISATIONAL CHART PART 3 - GENERAL ARRANGEMENTS FOR PROTECTION OF THE ENVIRONMENT

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INTRODUCTION 1. The Environmental Protection Act of 1990 requires employers to ensure, as far as it is reasonably practicable, that all members of the Company operate in an environmentally responsible manner, with particular interest in minimising hazardous emissions to atmosphere and contamination of local land, sea and air. 2. This Environmental Policy Document comprises of three parts. These are:a) PART 1 - Policy Statement. b) PART 2 - Organisation and Responsibilities. c) PART 3 - General Arrangements.

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PART 1 - GENERAL POLICY STATEMENT

1. Media Square CEO and individual operating Company Managing Directors / CEOâ&#x20AC;&#x2122;s, regard the promotion of environmental measures as a mutual objective for all personnel employed in this Company. 2. It is, therefore, policy that this Company operates in an environmentally responsible manner, with particular interest in minimising hazardous emissions to the atmosphere and contamination of local land, sea and air. 3. Employees have a legal duty to co-operate in the execution of this policy; the guidelines for which are:a) They should not misuse anything provided in the interests of protecting the environment. b) They should do all that is reasonably practicable to prevent contravention of the Environmental Protection Act 1990. c) They should report incidents which have led, or may lead, to damage of the environment. d) The must comply with the Company Environmental Procedures which are brought to their attention. e) They must be prepared to assist in the investigation of any acts of non-compliance of the Environmental Protection Act 1990. 4. Heads of Departments are responsible to the Managing Director / CEO for carrying out the environmental policy. Within the framework of the policy all Department Heads and Supervisors are to ensure that arrangements for protection of the environment within departments are up to date, documented and accurately reflect Company Procedures.

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PART 2 - ORGANISATION AND RESPONSIBILITIES SECTION 1. Managing Director. 2. Director of Safety. 3. Department Head. 4. Managers/Supervisors. 5. Health and Safety Manager. 6. Group Safety Assistant 7. Safety Representatives. 8. Specialist Personnel. 9. Organisation Chart. Managing Director 2.1

The ultimate responsibility for all environmental matters within each operating company area lies with the Managing Director / CEO.

Department Head 2.2

Each Department Head is responsible for ensuring environmental requirements are being met within their area of responsibility. They are to:2.2.1

View accident reports, with environmental effects, and progress action where appropriate.

2.2.2

Instigate safety monitoring.

2.2.3

In the case of any new operations, processes or machinery being introduced, they will ensure all necessary precautions are covered.

2.2.4

Instigate COSHH assessments.

2.2.5

Ensure accident details, with environmental effects, are provided as soon as possible.

2.2.6

Initiate, and review any environmental procedures thought necessary.

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Managers/Supervisors 2.3

Supervisors are responsible for applying the company environmental procedures. Also:2.3.1

Assist the Health and Safety Manager to investigate all accident reports, with environmental effects, to determine their cause and initiate remedial action, if required.

2.3.2

Instruct all new employees in all relevant aspects of protecting the environment.

Health and Safety Management 2.4

Locally appointed Health and Safety representatives act as the safety advisor, and have the duty of assisting supervisors and employees in meeting their various responsibilities for the environment. The Health and Safety Representatives are also responsible for:2.4.1

Organising and managing the various levels of environmental inspections (e.g. Audits - Sampling) carried out within the company.

2.4.2

Investigating accidents, with environmental effects, and near-miss incidents, instigating remedial procedures if required.

2.4.3

Identifying potential sources of danger to persons and property; proposing remedial actions.

2.4.4

Ensuring compliance with legislation and other standards, bringing them to the attention of the Management.

2.4.5

Participate in safety training.

2.4.6

Provide an information service for the organisation i.e. periodicals, information sheets, videos, visits etc.

2.4.7

Liaise with Health and Safety authorities as necessary, e.g. Health & Safety Executive.

2.4.8

Oversee the upkeep of all safety records, documents etc.

2.4.9

Carry out the duties of COSHH arranging assessments, checking action as a result of the assessment, Local Exhaust Ventilation inspection etc.

2.4.10 Where appropriate, liaise with the Noise Competent Officer. Ensure Noise Assessments are completed.

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Specialist Personnel 2.5.1

Fire Officer. The Fire Officer will provide advice and training in all matters relating to fire safety.

2.5.2

COSHH Officer. The Health and Safety Manager will act as COSHH Officer, ensuring assessments are made of all hazardous substances and co-ordinating results.

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PART 3 - GENERAL ARRANGEMENTS FOR PROTECTION OF THE ENVIRONMENT

CONTENTS SECTION 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12.

Pollution Prevention and Control. Ground Level Air Pollution. Protecting the Ozone Layer. Global Warming Energy Efficiency. Water Pollution. Noise. Consumption of Resources. Hazardous Materials Management. Recycling. Waste Disposal and Litter. Petrol, Oil and Lubricants. Estate Management.

Pollution Prevention and Control 3.1

All members of the company are to assist with the compliance of the Environmental Protection Act by ensuring that they:3.1.1

Prevent pollution at source.

3.1.2

Minimise the risk of harm to human health and the environment.

3.1.3

Encourage and apply the most advanced technical solutions available, whilst recognising the integrated nature of the environment and the need to achieve the best practicable option as a whole.

3.1.4

Apply a 'common sense' approach by assessing the levels of pollutant which local environment can tolerate without significant damage, in order to focus protection on the most vulnerable environments.

3.1.5

Ensure that any pollution is reported, as soon as possible, and all practicable measures are taken to control the pollution.

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Ground Level Air Pollution 3.2

All members of the company are to assist with the compliance of the Clear Air Acts of 1993 by helping to:3.2.1

Minimise the emission of smoke, fumes, dust and toxic gases into the environment.

3.2.2

Limit the discharge of dark smoke (that is defined as darker than shade two on a Ringelmann Chart) into the environment.

3.2.3

Limit any open burning.

3.2.4

Reduce vehicle emissions by:a)

Avoiding over-revving of engines.

The avoidance of engine idling of unnecessarily long periods.

Not speeding at any time.

Protecting the Ozone Layer 3.3

All members of the company are to assist with the compliance of the Montreal Protocol by ensuring that they:3.3.1

Minimise the use of CFC's and other listed substances on the Montreal Protocol list.

3.3.2

Never vent Protocol substances to the atmosphere.

3.3.3

Modify equipment to permit alternatives to be introduced.

3.3.4

Reduce CFC's usage whenever possible.

Global Warming - Energy Efficiency 3.4

All members of the company are to conserve energy by ensuring the following:3.4.1

All plant and machinery is switched off when not in use.

3.4.2

All computers are switched off when not in use.

3.4.3

All lights are switched off when offices are vacated - even for a few minutes.

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Water Pollution 3.5 3.5.1

All members of the company are to protect water supplies by the following :Never put any of the following items into the sewage system or down any drain:a) b) c) d) e) f) g) h) i) j) k)

Food waste. Textiles. Razors. Cooking oils and fats. Medicines Paints. Solvents. Plant sprays. Waste oils. Electralites/Acids. Coolants.

Noise 3.6

All company members are to comply with the reduction of noise by the following:3.6.1

No over-revving of engines.

3.6.2

Ensuring all engines and exhaust systems are maintained in good condition and comply with current regulations.

3.6.3

Ear protection is available and used when necessary.

Consumption of Resources 3.7

All Company members are to cut consumption of resources by:3.7.1

Phoning as opposed to writing.

3.7.2

Circulate documents rather than photocopy.

3.7.3

Photocopy both sides of paper.

3.7.4

Prune distribution lists.

3.7.5

Refrain from copying responses to letters.

3.7.6

Use minimum protective packaging.

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Hazardous Material Management 3.8

All members of the company are to conform to COSHH regulations by the following. 3.9.1

Read and adhere to relevant safety data sheets.

3.9.2

Wear protective clothing.

3.9.3

Minimise usage.

3.9.4

Strictly control all COSHH substances.

Recycling 3.9

All company members are to comply with the recycling policy by:3.9.1

Using the containers for paper.

3.9.2

Using aluminium containers for cans.

Waste Disposal and Litter 3.10

All company members are to ensure the following:3.10.1

All areas are free from litter at all times.

3.10.2

Any controlled waste is back loaded through the correct channels.

Petrol, Oils and Lubricants 3.11

All company members are to ensure that pollution by POL is kept to a minimum by:3.11.1

Ensuring correct procedures are used with using POL.

3.11.2

Using drip trays to contain any spillage.

3.11.3

Ensuring any spillage is cleaned up immediately.

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Estate Management 3.12

All company are to assist with the compliance of the Policy of Estate Management by:3.12.1

Protecting and conserving wildlife.

3.12.2

Protecting and conserving plants and trees.

3.12.3

Conserving the landscape.

3.12.4

Minimising the effect on the local population.

3.12.5

Conserving buildings and ancient monuments.

3.12.6

Preventing contamination of the land.

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Appendix 5

Retirement Policy

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RETIREMENT PROCEDURE Following the introduction of age discrimination legislation effective from 1 October 2006, the Company proposes to introduce the following retirement policy: Notification At least 6 months, and subject to a maximum 12 months, before retirement, the Company will write to the member of staff advising that: - their employment is due to end, by reason of retirement, on the normal retirement date. - they have a right to apply to continue to work beyond the normal retirement date, and confirm the procedure for so doing. Request to Stay On To request an extension of employment, the employee must put their request in writing at least 3 months, and subject to a maximum of 6 months, before the normal retirement date. The letter should include: - confirmation that the request is being made under paragraph 5 of schedule 6 of the Employment Equality (Age) Regulations 2006 - a suggested period of extension (ie to a specified date on indefinitely). Consideration of Request If the Company can agree the request without any further information or discussion with the employee then this should be confirmed in writing. If more information is required, the Company should arrange to meet with the employee within a reasonable period of time. This will be a formal meeting and the employee has the right to be accompanied to this meeting by a fellow worker. Within a reasonable time of the meeting the Company should notify the employee of its decision. If the request is refused the employee must be given the right to appeal. The employer does not have to give a reason for rejecting the request to continue. Appeal The employee can appeal the decision within a reasonable time of receiving the decision. The appeal must be in writing setting out the grounds of the appeal. The outcome of the appeal should also be notified in writing.

If the request is granted and a new, fixed, retirement date is agreed and is within 6 months, then no further action is required and the employee will be dismissed on the grounds of retirement on the agreed date. Where a new date has not been fixed, or the new date is more than 6 months in advance then procedure must be complied with again. Please note that it will be unlawful age discrimination to terminate an employeeâ&#x20AC;&#x2122;s contract prior to age 65. - 112 -

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Appendix 6

PERSISTENT ABSENCE PROCEDURE GUIDELINES FOR MANAGERS

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Persistent Absence Procedure – Guidelines For Managers Managers' Key Responsibilities These are: • to maintain effective absence records • to enforce notification etc. rules • to conduct return work discussions after any absence by a member of their team, complete the 'return to work form', copy it as required and retain their copy in a secure place • to instigate action as prompted by any episode of absence: counselling, gaining better medical information; Long-term Incapacity Review; action under the persistent absence or disciplinary procedures • where action would normally be triggered, but is not taken, to record the rationale for this • to refer to HR cases where the level of absence in a year suggests that adjustments should be considered to leave, bonus, etc. Records Absence records are to be maintained, using the Absence Recording Form. All data relating to an employee's health is 'sensitive data' under the Data Protection Act 1998. As such it is vital that due security is taken and confidentiality observed concerning such information. In particular: All original documentation to be held in Human Resources. All copies of employee documentation must be held in a locked and secure place within the department. During absence • Where there is no initial contact from the employee you have a duty to investigate their absence, to ensure their safety. • When the employee contacts you, remind him or her when they should next contact you in accordance with the policy, or give any 'reasonable instructions' concerning a 'maintaining contact' regime. (Calling in every day would not, in typical circumstances be reasonable). • Where appropriate, you may wait until the return to work discussion to decide whether or not to authorise absence (e.g. where absence is for domestic reasons). • Once advised that absence will exceed one week, despatch a self certification form to the employee for completion and return to you (or identify to whom). • Where medical certificates are not provided promptly contact the employee, remind them of their obligations and 'stay on the case'. • Where rules are not adhered to, remind the employee of them (during or on return from sick leave, as appropriate) and that non adherence is a potential disciplinary matter. • Communications must be between the employer and employee. Discussions via third parties (parent/partners etc.) are inappropriate except in rare cases, or over trivial matters. • Refer to HR concerning the gaining of further medical information when: advised that an absence will exceed four weeks a medical certificate states stress, anxiety or depression as the reason for absence certified sickness occurs during a disciplinary investigation or procedure • Refer to HR before requiring a doctor's certificate for absences of less than one week, or certification of fitness to return to work.

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Return To Work Discussion These must be held in all cases, irrespective of concerns about or confidence of the genuineness of the illness. They are intended to ensure that the company meets its obligations towards employees, as well as vice versa. Before undertaking the discussion brief yourself on the employee's absence record and whether counselling or other action has been taken concerning absence. The return to work discussion should cover the items on the form which should be completed at or immediately on conclusion of the discussion. The original should be forwarded to HR, a copy retained by the manager, and supplied on request to the employee. The return to work discussion will normally be the occasion to identify whether action is to be taken: • to seek further information on the employee's health • to take disciplinary action concerning misconduct • to counsel the employee about his or her absence level/pattern, and the company's policy on absence • to take action under the Persistent Absence Procedure. Wherever possible the discussion should be held face to face, and must always be in private. Where undertaken by phone it must NOT be undertaken whilst driving. The discussion does not constitute any level of formal procedure, but may on occasions be the forum for counselling (which may alternatively take place as a follow up discussion if appropriate). Action Triggers Where an employee has four weeks of absence in a rolling twelve month period - in one or more episodes- which are apparently owing to a single underlying cause, it will normally be appropriate to seek further medical information, with a view to considering the implications for employment under a Long-term Incapacity Review. (An adjustment to benefits etc. may also be appropriate.) Where an employee has three episodes of absence in a twelve week rolling period this will normally lead to their being counselled about the company's ill health and attendance policy, and the possibility of action under the persistent absence procedure if their inability to attend recurs frequently. Where an employee, counselled in the last year about absence, again meets the 'three episodes in twelve weeks' trigger this will normally lead to action under the persistent absence procedure. No other action triggers are to be used unless agreed by HR.

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Absence and bonus/benefits/appraisal Where absence in a year exceeds four weeks it may be appropriate to modify certain benefits - HR should be consulted before any action is taken. Note that: • performance ratings will normally be based upon performance for the period in attendance, and applied as if the employee had been present all year • whilst it may be possible to adjust bonus/ incentive payments, it should not be automatically assumed that an employee's absence has resulted in lack of performance or attainment of goals. • where possible performance should be assessed against goals and objectives for the bonus period, and the impact of the period of absence assessed within that context • merit review should therefore be applied in line with the above and the ratings awarded. If absence is due to a disability or a pregnancy related illness other arrangements may be appropriate, HR will advise. These notes supplement the Procedure, with which managers should familiarise themselves before using. General • The procedure should be treated with similar gravity to the use of the disciplinary procedure as it may ultimately lead to dismissal. • The procedure, however, carries no stigma or suggestion of blame. • When used, it must be strictly adhered to. • Where, at the end of a warning period, satisfactory attendance has been achieved, an informal meeting should be held to advise the employee of this, to remind them that absence will continue to be monitored. Where considered appropriate they may be counselled that, if the procedure needs to be instigated again, it may commence at an advanced stage • Whatever level the interview is held under, less severe warnings etc. than that indicated by the level may be given. Calling to interview Whilst the interview may be initially notified or arranged by phone, a written notification must be given at least 2 days before the interview. It will: • describe the attendance failure that is the reason for the hearing • attach any relevant information (e.g. counselling record) • specify the level of procedure under which the interview is to be held. If any level of procedure is to be missedout, the reason for this should be discussed first with HR • enclose a copy of the procedure (unless previously provided) • remind the employee of his or her right to be accompanied • where the outcome may be dismissal, (typically where the employee is under a Final Attendance Warning) include the phrase(s) "[As you are under a Final Attendance Warning,]" "the interview may result in your dismissal."

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At Interview Ensure you do the following. • Make and retain hand written notes of the interview, including start, finish and any adjournment times. If a third party is included to make notes, check and record that this is acceptable to the employee. • Check the position on accompaniment: if the employee is not accompanied ensure this is not through misunderstanding or last minute problems. • Explain the purpose of the interview, explaining the shortfall between the employee's attendance and the required standard. • Allow the employee to ask questions and explain any relevant factors, including any mitigating circumstances. The companion should normally be permitted to participate fully. In the event of a disruptive approach advise the companion that they may contribute when invited (only), and then invite their contribution at appropriate times. • Adjourn if you consider any investigation is required - reconvening at a later date where necessary. • Adjourn at the employee's request. • (Always) adjourn when all the appropriate ground has been covered, to reach your conclusion. If, owing to mitigating circumstances no further action is to be taken, ensure that you record the reason. • Offer the employee and companion a private room during adjournments. • Reconvene to: advise the employee of the decision you have reached explain the meaning of warnings, where given explain the right to appeal - including timescales. Warnings and dismissal Warnings must be in accordance with the procedure: • Formal verbal warnings are to be recorded on the employee's file. This may be done by retention of the interview note, or a separate file note. • Written warnings should be confirmed in writing within two working days, including the information required within the policy Dismissal under this procedure will always be with notice or pay in lieu.

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Appendix 7

FLEXIBLE WORKING PROCEDURES

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Flexible Working - Procedure Overview The Employment Act 2002 (effective from 1st April 2003) and the Work and Families Act 2006 (effective 1 April 2007) provides eligible employees with the right to request a flexible working pattern and places on employers an obligation to consider any request fairly and reasonably. The legislation does not provide:• An automatic right to work a flexible pattern • A right to switch back to full-time hours without the employer's consent at a later date • The necessity to ignore the commercial or economic circumstances within the workplace Acceptance or rejection of any request has to be considered purely on business or commercial grounds. Within the legislative framework, a set timetable coupled with: • face-to-face meetings • formal representation / accompaniment rights is created. A right of action to a tribunal now exists where an application is refused unfairly. If an application is fairly refused on business grounds, no further application may be made within twelve months. The Flexible Working legislation requires the following elements:• either - a child under the age of 6 or • a child with disabilities under the age of eighteen, or • effective 1 April 2007, to be a Carer of certain adults (definition of “Carer” and potential types of care are included at the end of this document). In addition: - for applications in relation to childcare: • the application must be made no later than 2 weeks before the qualifying birthday • the employee must have responsibility for the child's upbringing - for all applications the employee must: • have 26 weeks service at the time of the application • not have made another application within the preceding 12 months The legislative process builds in statutory time limits for an employer to consider an application and also builds in a formal internal appeal process. Where line management are in a position to accept an application on the basis of the employee's written proposals, it would not be necessary to have face-to-face meetings. However, where further discussion / clarification is required it is essential that face-to-face meetings take place and that the legally-prescribed timetables are recognised.

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The process flow is shown below

Employee makes written application to immediate manager

28 days

Seek further info from employee Manager considers application and consults with Unit Head

Manager arranges meeting with employee to discuss application

14 days

Employee withdraws application or accepts managerâ&#x20AC;&#x2122;s modifications

14 days

Reject or seek modified proposal

Manager advises employee in writing of decision and reasons for rejection

Employee provides written appeal with detailed supporting points

Accept proposal Manager advisers HR of effective date and new work pattern

Accept proposal

2nd-Line Manager or Director considers appeal submission

Accept appeal 14 days

HR arrange for salary change sign-offs and for payroll & HR system input

Accept appeal

14 days

Reject/seek modifications 2nd-Line Manager or Director arranges meeting with employee to discuss resubmission

Reject appeal 2nd Line Manager or Director advises employee in writing of decision and reasons for rejection

Manager monitors progress and arranges for any follow-up reviews

HR representative provides advice and guidance

As the intention is to provide a loose and flexible framework for the application process, it is not the intention to impose compulsory HR representation (as with the more formal grievance and disciplinary processes.) HR and senior management would always remain fully available to provide advice and guidance on issues relating to either the law or relating to consistency of treatment. Considering an Application The company's internal framework seeks to match the legislative requirements - except for the need for a face-toface meeting when line management are in a position to accept the employee's submission without any modifications. Consideration of any application should be based on the circumstances of each individual case. It is recognised that some consistent principles can be followed; however, the operational issues may be different and may depend very much on the unique nature of the individual's own duties or the unique set of customer demands relating to their current work. The immediate manager should assess the suitability of the application and provide their comments and recommendations on the application form for the higher level manager / Director or Managing Director to sign-off.

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Meeting the Employee Where management are considering seeking modifications to, or clarification of, the proposal, a face-to-face meeting has to be arranged within 28 days of the initial request. While it is ideal that this meeting is between the employee and their immediate manager, the employee has a statutory right to be accompanied by a fellow employee. The work colleague may ask questions but may not answer any questions on the applicant's behalf. At the meeting, both employee and manager should feel free to openly discuss any concerns that they have; the object of any meeting is to seek a consensus agreement that both sides find workable. Manager's Decision It is not essential that a decision is made at the time of the meeting and further guidance either from HR or from higher management may be sought at this stage. A decision must be made (and provided in writing) within 14 days of the meeting with the employee. It is perfectly in order to maintain a telephone or e-mail dialogue during the period of consideration and it is not necessary to re-convene the meeting for any additional clarification (particularly in the case of an employee currently on maternity leave). Any agreed changes should be notified to local HR / Office Manager who will then arrange for:• formal sign-off of the salary change • written confirmation of the change of hours and salary • payroll and HR system changes Where the manager either rejects the proposal or seeks major modifications, they must:• provide detailed written reasons to the employee (detailed in the application form.) • provide HR with a copy of the decision and any necessary working papers Applications may only be refused, for justifiable business reasons, on the following grounds: • Burden of additional costs • Detrimental effect on ability to meet customer demand • Inability to re-organise work among existing staff • Inability to recruit additional staff • Detrimental impact on quality • Detrimental impact on performance • Insufficiency of work during the periods the employee proposes to work • Planned structural changes

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Employee Appeals If the employee appeals against the proposal being rejected or modified, this should be made in writing accompanied by a detailed set of reasons to support their proposal - it may be that the initial submission was workable but did not have the necessary supporting information. The appeal be:• • •

should be considered by either the next level of management or by a Director. The resubmission may accepted at this stage referred back to the immediate manager for further dialogue put forward for consideration at a further meeting with the employee.

Any further meeting must take place within 14 days of the initial written appeal. Once again, the employee may be accompanied by a work colleague. Any points put forward by the employee should be considered at this stage; similarly, the higher level manager / Director should openly discuss the commercial and operational considerations which currently apply to the role or which may affect the role in the foreseeable future. If the resubmission is accepted, the employee should be informed in writing and local HR / Office Manager should be advised in order to deal with the contractual or payroll issues. Should a re-submission either be rejected or major modifications required, the employee should be given the necessary written reasons and HR provided with the necessary working papers. No further right of consideration exists although the employee does have a right to take any application where a rejection is unfair to a tribunal. Carers For the purpose of this legislation, Carers are employees who care, or expect to be caring, for a: • Spouse • Partner • civil partner • relative, or • someone who lives at the same address Relatives include blood relatives, in-laws, step-relatives, half-blood relatives plus adoptive relationships. The adult concerned will have to be in need of care for the employee to be eligible to make a request for flexible working. There is no particular level of care required in order to show a need for care but types of care may include: -

Help with personal care (e.g. dressing, bathing, toileting) Help with mobility (e.g. walking, getting in and out of bed) Nursing tasks (e.g. daily blood checking, changing dressings) Giving / supervising medicines Escorting to hospital appointments (e.g. GP, hospital, chiropodist) Supervision of the person being looked after Emotional support - 123 -

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Keeping the care recipient company Practical household tasks (e.g. preparing meals, shopping, domestic chores) Help with financial matters or paperwork

This list is not exhaustive. Please refer to your local HR representative, the Director of Employee Services - Media Square plc or the Group Human Resources Manager - Media Square plc if you have any questions or require further guidance on this matter.

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FORMS

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COMPUTER USER SELF – ASSESSMENT CHECKLIST Please complete and return to your Office Manager, Health & Safety Representative or Human Resources Representative. Nature of the Job How much time do you spend on the computer? Posture and Furniture Adjustability Do you get aches, pains or sensory loss (“tingling” or “pins and needles”) in neck, back, shoulder or upper limbs?

Is the workstation arranged to meet your needs?

Is there anything to prevent you from sitting comfortably and easily changing posture?

Do you use a wrist support when using the keyboard or mouse?

Is your chair adjusted to enable you to find a comfortable position?

Are your feet resting flat on the floor or do you need a footrest?

Are your keyboard and screen adjusted to allow you to type in a comfortable position?

Have you got a document holder? Is it located so that you are comfortable using it?

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Visual Factors Do you have problems with your vision (eg headaches, focusing difficulties, ete discomfort, difficulties reading the screen or the documents you are reading from)?

Is there a reflection or glare on the screen from windows or lights?

Are the keyboard symbols legible?

Have you had an eye test since joining the Company? If so, when?

General Safety Are there any electrical hazards eg worn or improperly connected cords around your workstation?

Are there any trip hazards eg trailing cables around your workstation?

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PERSONAL DETAILS FORM Name Dr / Mr / Mrs/ Miss / Ms / Other

Employee No: Surname:

First Name

Known as:

I am

A new joiner Notifying a change of address Notifying a change of bank details Notifying a change of other personal details

Address: Date of Birth: Marital Status National Insurance Number: Home Telephone No Mobile No: Bank Account Details: (original form with signature to be forwarded to HR) Bank Name and Address Sort Code: Account No: Building Society Reference No:: Account Name: Emergency Contact Details: Name & Address: Relationship Daytime Telephone No: Mobile No: Children Name:

Date of Birth:

Name:

Date of Birth:

Name:

Date of Birth:

Name:

Date of Birth:

Signed:

Date:

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FLEXIBLE WORKING APPLICATION The following form should be completed by the employee as fully as is possible; where it is necessary to provide any additional information, please use a separate sheet. As the company may need to make arrangements to hire additional staff or to re-arrange duties within the team, it is helpful that as much notice as possible is provided to enable the necessary work to be reallocated - failure to provide sufficient notice may lead to an application being turned down. Part One - Employee and Manager Comments 1. Personal Details Name

Department

Date of Application Requested commencement Date

2. Details of Application a. Please state the domestic circumstances relating to the application - e.g. expected birth of 2nd child on 24th July, eldest child starts school on 3rd September, Carer responsibilities

b. Please state the expected duration of the flexible arrangement (the changes will be considered to be a permanent arrangement unless otherwise agreed) - please note that the company is not obliged to reinstate the previous arrangement at a later date

c. Please provide details of your current work pattern - e.g. all-day Monday-Friday, full-day Mon-Tue plus am Wed

d. Please describe the amended pattern that you would like to work Day

Start Time

Finish Time

Lunch Period (mins)

Total Time Worked(Hrs and Mins)

Mon Tue Wed Thu Fri

Weekly Total

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3. Impact of the new working pattern a. Please provide an assessment of how your proposed pattern will affect both your department / team and any of your colleagues

b. Please provide your suggestions as to how your department / team and colleagues could accommodate the suggested work pattern - please illustrate what work / responsibilities should be retained by you and what work / responsibilities should be reallocated

4. Line Manager Assessment a. Please provide an assessment of the impact of the proposal on the work of the department / team

b. Please provide your recommendations as to whether the proposal should be accepted, modified or rejected. Where the proposal should be modified, please state what modifications are proposed and the reasons for the amendments. Where the proposal is to be rejected, please state the business or operational considerations to be applied

Line Manager Name and Signature

Date

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Part 2 - Business Unit, HR and Payroll Authorisation 5. 2nd Line manager or Director Comments Please provide any necessary comments or recommendations (e.g. suggested modifications or initial review date.) Once completed, please sign and return a paper copy of the form to your local Human Resources contact / Office Manager

Signed

Date

Part three - for HR / Office Management Input only Revised Salary

Effective Date of Change

Authoriser

Date

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REQUEST FOR PATERNITY LEAVE

Name: Employee No: National Insurance No:

The baby is due on: Or, if the baby has been born, the actual date of birth: I would like to start my SPP and / or paternity leave on: I want to be away from work for one / two* weeks (*delete as appropriate)

You must be able to tick all three boxes below to get Statutory Paternity Pay. I declare that: I am − The baby’s biological father − Married to the mother or − Living with the mother in an enduring family relationship but am not an immediate relative I have responsibility for the child’s upbringing

I will take time off work to support the mother or care for the child

I understand that my salary will be adjusted in accordance with the above request Signed:

Date:

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REQUEST FOR PARENTAL LEAVE

Name : …………………………………………. Date:…………………………………………… Department:…………………………………….

Child’s Name:…………………………………. Child’s Date of Birth:………………………….. Child’s Name:…………………………………. Child’s Date of Birth:………………………….. Please note the following request for unpaid parental leave for a period of ……… weeks. From ……………..……… to ……………….. . I require this time to look after the above child/children due to the following circumstances: ……………………………………………………………………………………… ……………………………………………………………………………………… ……………………………………………………………………………………… ……………………………………………………………………………………… This request gives the required 21 days notice. Signed …………………………………….

Authorised by: Line Manager ……………………………. Department Manager …………………….. HR Manager ………………………………

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RETURN TO WORK DISCUSSION FORM • Where insufficient room for input, continue over page • Original form to be supplied to HR, manager to retain a copy and copy to employee if requested. Employee name (insert): Date of discussion (insert): Period of absence (insert): from

to:

No. of working days:

Employee's given reason for absence (explore as appropriate and record):

Does employee believe it likely to recur (explore as appropriate and record):

Is paid absence authorised? (tick one box and insert reason where applicable) YES: by reason of sickness YES: for another reason (insert) NO: for the following reason (insert) Is employee fully fit to work? YES/NO (delete as applicable). If 'no', record any arrangements agreed for light duties/ reduced hours etc. and (where appropriate) any steps to be taken to gain further information on the state of health

Has all appropriate documentation (e.g. self certification) been completed? YES/NO (delete as applicable). If 'no', record any outstanding actions to be taken (insert):

Were rules on notification etc. adhered to? YES/NO (delete as applicable). If 'no', record reason and action taken (e.g. reminder, advice that disciplinary action to be taken):

Were any developments in the business/team during employee's absence communicated? YES/NO (delete as applicable). If 'yes', record briefly, what: Was the employee in excess of any action trigger: YES/NO (delete as applicable). If 'yes': • record fully below the action taken. (e.g. counselling, action to gain more health information, advice that action under the persistent absence procedure was to taken) or, • where no action to be taken, record fully below, why. (continue over page where necessary)

Signed (manager)

date:

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