Resources & Downloads

Equal Opportunities Policy

It is the policy of Starfish 9 Limited to ensure that no job applicant, member of staff or trainee receives less favourable treatment on the grounds of sex, race, marital status, disability, age, part-time or fixed-term contract status, sexual orientation or religion, or is disadvantaged by conditions or requirements that cannot be shown to be justifiable. In making this statement we would also like to confirm that we are committed not only to our legal obligations under equal opportunities legislation but also in the development and support of a positive culture that supports compliance throughout all aspects of our operations. It is also the policy of Starfish 9 Limited to make every effort wherever it is reasonably practicable, to retain the services of any currently employed staff member who for any reason suffers an illness, personal hardship or disability. Furthermore, we shall also ensure access and use of the facilities we provide shall take into account the needs and expectations of the staff we employ or require to gain access such that their personal capability or disability shall in no way preclude them or compromise their personal safety or dignity. In making this policy, Starfish 9 Limited confirm it shall be actively applied throughout all aspects of its operations as it develops and as such it shall be subject to our own internal monitoring arrangements, the outcome of which shall, based on a reasonable written request to the Managing Director, may also be made available to any external / 3rd Party interest.

Starfish 9 Ltd Equal Opportunities Policy-2019 (Last Review Jan 2019- Next Planned Review Jan 2020)

Corporate and Social Responsibility Policy

We define our CSR as the integration of business operations and values, whereby the interests of all stakeholders including investors, customers, employees, the community and the environment are reflected in the company's policies and actions.

Commitment

We are committed to:

• Continuous improvement in our Corporate and Social Responsibility (CSR) strategy;
• Encouraging our business partners to strive for matching performance;
• Acting in a socially responsible way;
• Continually improving our performance and meeting all relevant legislation;
• Encouraging our staff to be mindful of the effect of their actions on any natural resource.

Purpose and Aims

The purpose of the policy is to make clear to all stakeholders what we mean by CSR and how we propose to work towards achieving it. The CSR policy applies throughout all of the departments within our company and to our supply chain and governs our approach to all our activities.

In implementing this policy we aim to:

• Be responsible;
• Be an exemplar of good practice.

Standards of business conduct

• We recognize that good CSR embraces all aspects of sustainable development and the way we affect people through our business operations;
• We will assess which social issues are of most relevance to the contract and decide at what stage in the procurement lifecycle this social policy could most effectively and legally be included;
• We shall operate in a way that safeguards against unfair business practices;
• We believe that a responsible approach to developing relationships between companies and the communities they serve, global or local, is a vital part of delivering business success;
• When carrying out our business, in consultation with our customers, we will determine the environmental, social and economic issues;
• Our contracts will clearly set out the agreed terms, conditions and the basis for our relationship;
• We will continually review our policies and business practices to encourage engagement with small and medium enterprises and to promote the development of the regional supply chain.

Corporate Governance

• We will share and declare information on personal and corporate conflicts of interest and seek guidance from higher authority before acting;
• We are committed to ensuring that our business is conducted in all respects according to rigorous ethical, professional and legal standards;
• All the laws that regulate and apply will be complied with;
• We endeavour to ensure that stakeholders have confidence in the decision­making and management processes of the procurement service, by the conduct and professionalism of all staff. We do this by continually training and developing our staff;
• All groups and individuals with whom we have a business relationship will be treated in a fair, open and respectful manner;
• The competition will be reasonable and based upon the quality, value and integrity of the products and services being supplied;
• Feedback on performance will be actively sought, and we will continually review all activities to ensure best practice is observed at all times;
• We will allow our customers and vendors to give feedback on our performance and ensure that all customer comments are analysed, responded to and where appropriate, acted upon;
• An Action Plan will be developed to ensure continuous improvement is achieved.

Environment

• Our objective is to endeavour to reduce our impact on the environment through a commitment to continual improvement;
• We will continue to work with our vendors to reduce their impact on the environment;
• We do assess production, use and disposal associated with the main goods we use;
• Our customers will be informed of the key issues involved in procurement so they can make informed purchases to reduce their impact on the environment;
• We will ensure that paper products used come from forests independently certified as well-managed according to the standards of the Forest Stewardship Council (FSC), or from recycled materials. All virgin paper products have been banned throughout the Company, environmental alternatives are used.

Human Rights

• We aim to support and respect the protection of internationally proclaimed human rights;
• Vendors are actively encouraged to observe international human rights norms within their work.

Equality and Diversity

• We aim to eliminate discrimination on any grounds and promote equality of opportunity in the supply chain;
• We will ensure that our customers and vendors are able to work together in confidence and be treated with respect by each party;
• Our range of contracts will take account of the needs of a diverse customer base.

Sustainability

A Sustainable Procurement Policy will be maintained that will set out the principles, policies and procedures on which sustainable business activity within the Company will be based upon:

• The policy will act as a prompt to staff to consider sustainability as a factor in all purchasing decisions;
• We seek to minimise the adverse environmental effects of people travelling to and from our offices.

Impact On Society

• We will take steps to understand how we can most effectively support the needs of the local community and implement initiatives accordingly;
• Our impact on the local and wider community will be understood and nurtured;
• Dialogue with local communities shall be encouraged for mutual benefit.

Ethics and Ethical Trading

We actively encourage the use of sustainable practices in the maintenance of the Company grounds and premises.

Vendors (Suppliers)

• Vendors will be worked with to help us achieve our policy aspirations in the delivery of our products and services;
• We shall encourage vendors to adopt responsible business policies and practices for mutual benefit;
• Vendors are regarded as partners and we will work with them to help us achieve our policy aspirations in the delivery of our products and services;
• A documented environmental and social assessment will be undertaken for every new contracted vendor;
• We are committed to ensuring that the welfare of workers and labour conditions within our supply chain meet or exceed recognised standards;
• Where necessary, we will exert procurement pressure to ensure that all of our vendors behave in a socially responsible way. This includes environmentally- friendly products and making sure that workers are treated properly;
• Where appropriate, our tender specifications include questions to reflect our desire for sustainable procurement;
• We hold regular meetings with vendors to support these ideas;

• We will continue to work with vendors to:

• Promote more environmentally friendly products and promote these to our customers;
• Reduce the amount of packaging and transit where possible;
• Implement schemes to take-back, recover, reuse and recycle products at the end of their life/use.

Starfish 9 CSR Policy- Jan 19
(Last Review Jan 2019- Next Planned Review- Jan 2020)

Customer Care Policy

Our TEAM will strive at all times to deliver Best Value Services to the highest quality standards which fully satisfy our customer's needs. To do this we must ensure our standards of customer care are shaped and designed with their continued involvement. We have a focused Customer Care Plan, the objective of which is to improve our customer satisfaction through understanding their changing needs and what really matters to them and deliver service excellence consistently across our business. The Starfish 9 Customer Care Plan Objectives for providing excellent customer care are that:

• We will listen to and engage with our customers and develop our service to meet those needs;
• We will treat our customers with respect and integrity, ensuring our people are responsible, accountable and customer-focused in everything they do;
• We will offer a choice of access to our services and commit to clear and consistent standards of service delivery;
• We will ensure that customer information is accurate, available and transparent.

We will engage with all our employees to ensure that they:

• Have the opportunity to influence the range of services we provide;
• Can take an active role in setting the standards of delivery;
• Are able to influence the design of service delivery mechanisms to ensure all customers have equal access to consistent services;
• Play an on-going role in helping to develop our organisation's culture of excellent customer service.

Starfish 9 Ltd. Customer Care Policy- Jan 19
(Last Review Jan 2019- Next Planned Review Jan 2020)

Ethical Policy

Starfish 9 Limited recognises the importance of operating to a set of core values in the way that it carries out its business with its customers and supply chain organisations. These core values seek to establish, protect and increase the trust and confidence of individuals and organisations with whom we interact thereby enhancing our reputation and our successful business dealings. Company procedures and the approach to business arising from this policy are to be applied by all of our employees in the course of their work activities, as well as across those of our suppliers and sub-contractors. To achieve these aims Starfish 9 requires all employees;

• To apply high ethical standards in their relationships with customers, suppliers, sub­contractors, competitors and the local community at all times;
• To ensure that all advertising, marketing and promotional documentation we issue avoids false statements, concealment and exaggeration;
• Not to give or receive monies or gifts of significant value intended as an inducement or bribe;
• To report any offer of monies or gifts of significant value to your line manager;
• To maintain and protect the confidentiality of information provided by customers and suppliers as if it were our own information;
• To develop good working relationships with our suppliers and sub-contractors based on fair working practices, not making unreasonable demands and arranging prompt payment as agreed in the Terms and Conditions of the contractual relationships;
• To maintain a fair and neutral business relationship with our competitors;
• Not to discuss confidential information with our competitors;
• Not to malign the competition through misrepresentation, false statements or innuendo;
• To respect the local traditions and culture within the region in which we are operating;
• To comply with all laws and local regulations within the region in which we are operating.

To support these aims the Company will endeavour to;

• Ensure adequate resources are available to implement the requirements of this policy;
• Make this statement available to all who are affected by it, or required to support it;
• Review and update this policy through regular management review meetings.

The cooperation and involvement of all our employees, at all levels of responsibility, is essential in the effective implementation of this policy.

Starfish 9 Ltd Ethical Policy-2019
(Last Review Jan 2019- Next Planned Review Jan 2020)

Sustainability Policy

Starfish 9 Ltd considers the Environment, Social and Economic factors to be the three or our largest impact areas. To us, Sustainability is about integrating short-term and long-term aspects

Environment

Where possible, we will supply and source our materials from renewable/ reclaimable sources. We will keep water usage and disposal to a minimum. We will treat any spillage in line with current waste regulations and contain correctly to prevent/ minimise any impact on biodiversity. We aim to operate fuel and omission efficient plant and vehicles. We hold a valid SEPA Waste Management License and ensure that our waste is monitored. We work with waste companies who are licenced and can produce waste charts for our clients as required.

Social

Starfish 9 Ltd operates an equal opportunities policy. We are committed to paying above the Living Wage. All our staff are inducted and given the appropriate training and support for their job. We do not employ underage workers. We have a company handbook that is issued to every employee which details their benefits and our disciplinary procedures. Our staff are required to sign a non­bribery agreement.

We operate an accredited (ISO 18001) Integrated Management System where all our systems and procedures are kept - this is available to staff online at any time. 

Customer safety is paramount, and we ensure all site staff have as a minimum CSCS training. Starfish 9 Ltd operate a CSR Policy.

Economic

Before committing to undertake any project, we will assess our financial standing. As a AAA credit rated business, we are currently financially stable to undertake projects up to the value of £2.Sm. We ensure that our cash flow will be sufficient to fund the entirety of any project without eroding our capital.

We operate a website and issue monthly e-mailers to increase our market presence. All of our vehicles have vivid logos as do our staff on their clothing and PPE.

Starfish 9 Ltd. Sustainability Policy - January 2019
(Last Review Jan 2019 - Next Planned Review- Jan 2020)

Integrated Health, Safety, Quality & Environmental Policy

As a progressive forward-looking and responsible organisation, our aim is to provide a quality product and service in line with specified customer requirements and pre-determined compliance criteria, while at the same time ensuring compliance with all forms of health, safety and environmental legislation. While striving to achieve these aims, we, the Management of Starfish 9 Limited, at all times remain committed to the maintenance, application, maintenance and monitoring of an effective management system based on the widely recognised management standards BS EN ISO 9001, BS EN ISO 14001 and OHSAS 18001 as well as all other industry-specific and customer-related standards that may apply to our operations. We are also committed to the prevention of pollution, the safe and effective mitigation of all manner of risk and the reduction of impact from any significant environmental aspects resulting from our activities, while at the same time promoting the conservation of our natural environment, cultural heritage and the reasonably practicable reduction, recycling and re-use of waste. It is we believe as a result of these commitments, that when correctly communicated and applied, the needs and expectations of our environment, business, employees and customers shall be satisfied.

To further ensure the continuing development of our operations, all Company personnel are encouraged to take an active role in our decision-making processes, including wherever possible the future re-design, implementation and application of our management systems. We believe by adopting this policy a positive and pro-active operating culture shall ensue based on the continuing co-operation, understanding and personal development of our workforce. We recognise that in order to maintain these standards, it will be necessary to develop and maintain a high level of commitment and communication throughout our operations that actively encourage leadership at all levels. We also recognise that in order to realise this commitment and to support our efforts it will be necessary to provide adequate facilities and resource, the level of which shall at all times be commensurate to quantified risk. Integral to our management systems are pre-determined aims and objectives, the detail and levels of which are closely linked to the achievement of constantly improving performance criteria. The ongoing monitoring and development of this criterion are subsequently used to best represent the ongoing development of our business operations through the application and use of recognised continual improvement principles.
The ultimate responsibility for all aspects of health, safety, quality and environmental management is that of the Managing Director.

Starfish 9 Ltd HSQE Policy-2019
(Last Review Jan 2019- Next Planned Review Jan 2020)

Data Protection Policy

Starfish 9 Ltd requires the collection of data from its staff, clients, sub-contractors and suppliers which may also include personal details. This ensures that we hold the correct and current information as required by our operational needs. All data is held securely by Starfish 9 Ltd. Data will be treated confidentially and will not be disclosed to external organisations, other than those on related projects or for other legitimate reasons. Starfish 9 Ltd take our responsibility for looking after information seriously. We comply with the GDPR & Data Protection Act 2018 at all times when asking for or handling your information including:

• Personal data shall be processed fairly and lawfully;
• Data is processed only for the purpose(s) for which it was collected;
• Data is adequate, relevant and not excessive;
• Data is accurate and kept up to date;
• Data is not kept longer than necessary;
• Data is kept secure against unauthorised access and loss or damage;
• Processing personal data only in order to meet our operational needs or fulfil legal requirements;
• Providing adequate training for all staff responsible for personal data;
• Ensuring that queries about data protection, internal and external to other organisation, are dealt with effectively and promptly;
• Personal data shall not be transferred to a country or territory outside the European Economic Area unless that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data;
• Regularly reviewing data protection procedures and guidelines within the organisation.

All members of staff are to be made fully aware of this policy and of their duties and responsibilities under the Act. All clients or other contractors who are users of personal information supplied by us will be required to confirm that they will abide by the requirements set out by GDPR & The Data Protection Act 2018.

Starfish 9 Ltd HSQE Policy-2019
(Last Review Jan 2019- Next Planned Review Jan 2020)

Anti-Fraud Policy

Background

This anti-fraud policy has been established to facilitate the development of controls which will aid in the detection and prevention of fraudulent behaviour affecting the business operations of Starfish 9 Limited. It is the intention of Starfish 9 to promote consistent organizational behaviour by providing guidelines and assigning responsibility for the development of controls and conduct of investigations.

Scope of Policy

This policy applies to any suspected fraudulent activity, involving the business operations of Starfish 9 Limited, as well as its Company Directors, Senior Managers and staff, as well as any other consultants, vendors, contractors, outside agencies with whom we interact. Any investigative activity required will be conducted without regard to the suspected wrongdoer's length of service, position/title, or relationship within the Company.

Policy

Company Directors are responsible for the detection and prevention of fraud, including the misappropriation of a financial asset, and any other inappropriate conduct. Fraud is defined as the intentional false representation or concealment of a material fact for the purpose of inducing another to act upon it to his or her injury/ loss. Each member of the management team will be familiar with the types of improprieties that might occur within his or her area of responsibility and be alert for any indication of irregularity. Any fraud that is detected or suspected must be reported immediately to the Managing Director who shall coordinate all resulting action and investigation.

Starfish 9 Ltd Anti-Fraud Policy-2019
(Last Review Jan 2019- Next Planned Review Jan 2020)

Bribery and Corruption Policy

Bribery and corruption is, unfortunately, a feature of corporate and public life in many countries across the world. Governments, businesses and non-governmental organisations such as ours are working together to tackle the issue but despite our collective efforts eradicating all forms of bribery and corruption will take time. Starfish 9, therefore, has a clear policy on this subject, and as such we shall continue to support our employees in decision-making processes that support our stated position, the overall intention of which being to ensure that at all times we act professionally, fairly and with integrity. Starfish 9 does not tolerate any form of bribery and corruption. This policy applies to all employees (staff, contract and temporary) employed directly and indirectly by Starfish 9 Limited, involving any business dealings and transactions we may be involved with throughout the UK. Where we have a minority interest we will encourage the application of this policy amongst our business partners including contractors, suppliers and joint venture partners. This policy should also be considered and implemented in conjunction with the ethical guidance offered by senior management when giving and accepting gifts and hospitality.

Our Business Principles set out our commitment to operate responsibly wherever we work and to engage with our stakeholders to manage the social, environmental and ethical impact of our activities in the different markets in which we operate. Our first principle, 'integrity is in corporate conduct', where we advocate that we shall not engage in bribery or any form of unethical inducement or payment including facilitation payments and 'kickbacks.' All employees are required to avoid any activities that might lead to or suggest a conflict of interest within the business operations of our Company. Employees must declare and keep a record of hospitality or gifts accepted or offered, which will be subject to managerial review. We do not make direct or indirect contributions to political parties. We will uphold laws relevant to countering bribery and corruption in all the jurisdictions in which we operate, particularly laws that are directly relevant to specific business practices.

Starfish 9 Ltd Anti-Fraud Policy-2019
(Last Review Jan 2019- Next Planned Review Jan 2020)

Modern Slavery and Human Trafficking Policy

Modern slavery is a crime resulting in an abhorrent abuse of the human rights of vulnerable workers. It can take various forms, such as slavery, servitude, forced or compulsory labour and human trafficking. Starfish 9 Ltd has a zero-tolerance approach to modern slavery and is committed to acting ethically and with integrity and transparency in all of its business dealings and relationships and to implementing and enforcing effective systems and controls to ensure that modern slavery and human trafficking are not taking place anywhere within either its own business or in any of its supply chains, consistent with its obligations under the Modern Slavery Act 2015.

The Company also expects the same high standards from all of its suppliers, contractors and other business partners and, as part of its contracting processes, it includes specific prohibitions against the use of modern slavery, and expects that its suppliers will, in turn, hold their own suppliers to the same standards.

Identifying potential victims of modern slavery can be a challenge because the crime can manifest itself in many different ways. There is a spectrum of abuse and it is not always clear at what point, for example, poor working practices and lack of health and safety awareness have become instances of human trafficking, slavery or forced labour in a work environment. In addition, some suppliers may go to great lengths to hide the fact that they are using slave labour. However, Starfish 9 Ltd accepts that it has a responsibility through its due diligence processes to ensure that workers are not being exploited, that they are safe and that relevant employment, health and safety and human rights laws and standards are being adhered to, including freedom of movement and communications. This policy applies to all individuals working for Starfish 9 Ltd or on Starfish 9 Ltd's behalf in any capacity, including employees, directors, officers, agency workers, volunteers, agents, contractors, consultants and business partners.

Responsibility for the policy

The Managing Director has overall responsibility for ensuring that this policy complies with the Company's legal and ethical obligations. The SHEQ Manager has day-to-day responsibility for implementing this policy, monitoring its use and effectiveness and auditing internal control systems and policies and procedures to ensure they are effective in preventing or remediating the risk of modern slavery. They are also responsible for investigating allegations of modern slavery in the Company's business or supply chains. Line managers are responsible for ensuring that those reporting to them understand and comply with this policy.

Compliance

The prevention, detection and reporting of modern slavery in any part of Starfish 9 Ltd business or supply chains, whether in the UK or abroad, is the responsibility of all those working for Starfish 9 Ltd or under the Starfish 9 Ltd's control. You are required to avoid any activity that might lead to a breach of this policy.

Starfish 9 Ltd Modern Slavery Policy-2019
(Last Review Jan 2019- Next Planned Review Jan 2020)

Whistleblowing Policy

Starfish 9 Ltd encourages a free and open culture in dealings between managers, employees and all people with whom it engages in business and legal relations. In particular, breaches or failures are to be effectively dealt with. This policy is designed to provide guidance to all those who work with or within the company who may from time to time feel that they need to raise certain issues relating to the company with someone I confidence. Anyone who in the public interest raises genuine concerns under this policy will not under any circumstances be subject to any form of detriment or disadvantage as a result of having raised their concerns. Procedure This policy will apply in cases where individuals genuinely believe that one of the following set of circumstances is occurring, has occurred or may occur within the company and that it is in the public interest for the employee to disclose it.

The matters that may be disclosed in this way are:

• A criminal offence has been committed, is being committed or is likely to be committed;
• A person has failed, is failing or is likely to fail to comply with any legal obligation to which he or she is subject;
• A miscarriage of justice has occurred, is occurring or is likely to occur;
• The health and safety of any individual are likely to be damaged;
• The environment has been, is being or is likely to be damaged;
• Information tending to show any matter falling within any one of the preceding paragraphs has been, is being or is likely to be deliberately concealed.

There is no need for and individual to prove that the breach or failure that they are alleging has occurred or is likely to occur: a reasonable suspicion will suffice, ie, where the individual reasonably believes that the information disclosed is substantially true, However, it should be noted that they are not entitled to make a disclosure if in doing they commit a criminal offence. If workers wish to raise or discuss any issues which might fall into one of the categories listed above, they should contact the Managing Director, or in his absence the Health & Safety Manager. The person will, insofar as possible treat the matter in confidence. It is likely that an investigation will be necessary and the employee who has made the disclosure may be required to attend an investigatory hearing and or/ a disciplinary hearing ( as a witness). Appropriate steps will be taken to ensure that the individuals working relationships are not prejudiced by the fact of the disclosure. If felt that the relevant failure ( ie. One of the sets of circumstances listed above) relates wholly or mainly to the conduct to a person other than their employer or any other matter for which a person other than the company has a legal responsibility, then they should make that disclosure to that other person.

Everyone should be aware that the policy will apply where they believe that the information disclosed, and any allegation contained in it are substantially true. If any disclosure concerns information which employees do not substantially believe is true, or indeed if the disclosure is made for personal gain, then such as disclosure will constitute a disciplinary offence for the purposes of the company's disciplinary policy and procedures and may constitute gross misconduct for which summary dismissal may be an outcome. While we hope that such disclosures will never be necessary, we recognise that we may find circumstances which are new to it, therefore, each will be treated on its own merits.

Anyone who makes a disclosure is protected from detrimental treatment by the company, by a colleague or by an agent of the business. An employer is vicariously liable for detrimental treatment. If this occurs, it should be raised immediately with the line manager so that the matter can be investigated thoroughly without due delay. Detrimental treatment includes, for example, harassment and bullying or not complying with the person's rights and entitlements under his or her contract of employment. An employee is also protected from dismissal by the company form making a protected disclosure.

Starfish 9 Ltd. Whistleblowing Policy - Jan 19
(Last Review Jan 2019- Next Planned Review- Jan 2020)

Harassment and Bullying Policy

Starfish 9 Ltd. recognises that all employees have a right to work in an environment in which the dignity of individuals is respected and which is free from harassment and bullying. It is committed to eliminating intimidation in any form.

The Policy applies to harassment on the grounds of disability, gender, marital status, sexual orientation, age, creed, colour, race or ethnic origin.

Harassment breaches Starfish 9 Ltd. Policy as outlined and it is classified as a serious offence which may result in disciplinary action including summary dismissal under the Disciplinary Procedure.

The Policy applies to all staff employed by Starfish 9 Ltd.

Definitions

Harassment is generally described as "unwanted conduct which affects the dignity of women or men at work; it encompasses unwelcome physical, verbal or non- verbal behaviour which denigrates or ridicules or is intimidatory". The essential characteristic of harassment is that the action(s) is unwanted by the recipient.
The following interpretations and examples of harassment may be helpful in determining whether harassment has taken place.

General Harassment

"Harassment can take many forms and may be directed in particular against women and ethnic minorities or towards people because of their age, disability, gender/gender reassignment, marriage / civil partnership, pregnancy/maternity, race, religion or belief, sex, or sexual orientation. It may involve action, behaviour, comment or physical contact which is found objectionable or which causes offence; it can result in the recipient feeling threatened, humiliated or patronised and it can create an intimidating work environment."

Sexual Harassment

"Sexual harassment can be defined as an uninvited, unreciprocated and unwelcome behaviour of a sexual nature which is offensive to the person involved and causes that person to feel threatened, humiliated or embarrassed. Examples of sexual harassment are:
requests for sexual favours, including implied or overt promises of preferential treatment or threats concerning present or future employment status;
offensive gestures or comments;
sexually-orientated jibes, innuendo or jokes;
unwanted physical contact;
the display of sexually offensive visual material such as calendars, photographs, books or videos.
Sexual harassment may be experienced by men or women as a result of the conduct of men or women. It applies equally regardless of grade or level of job and may also occur when dealing with external clients and/or members of the public".

Racial or Sectarian Harassment

"In the workplace, racial or sectarian harassment may take the form of actual or threatened physical abuse or it may involve offensive jokes, verbal abuse, language, graffiti or literature of a racist or sectarian nature or offensive remarks about a person's skin colour, physical characteristics or religion. It may also include repeated exclusion of a person from an ethnic or religious minority from conversations, patronising remarks, unfair allocation of work or pressure about the speed and/or quality of their work in a way which differs from the treatment of other employees."

Bullying

“Bullying is the intimidation or belittling of someone through the misuse of power or position which leaves the recipient feeling hurt, upset, vulnerable or helpless. It is often inextricably linked to the areas of harassment described above. The following are examples of bullying:
Unjustified criticism of an individual’s personal or professional performance, shouting at an individual, criticising an individual in front of others.
Spreading malicious rumours or making malicious allegations.
Intimidation or ridicule of individuals with disabilities and /or learning difficulties.
Ignoring or excluding an individual from the team/group"

Responsibilities of Managers

Every manager has an obligation to prevent harassment/bullying and to take immediate action once it has been identified, whether or not a complaint has been made.

Allegations of harassment or bullying, received either informally or formally, must be dealt with promptly and sensitively.

It is important that managers recognise that sexual harassment is any sexual advance unwanted by the recipient or behaviour which causes offence to the recipient. Similarly, racial harassment is behaviour which is racially offensive to the recipient. Managers must, therefore, take care to ensure that they do not prejudge situations based on their own sexual or racial attitudes and perceptions.

It may not always be appropriate for a line manager to be involved with specific complaints. For example, if the complainant is male and wishes to speak to a male, but the manager is female, or if the complaint relates to the conduct of the line manager. The procedure below sets out the alternatives for such instances.

Responsibilities of all Employees

Every employee has a personal responsibility NOT to harass or bully other members of staff.

An employee who becomes aware of harassment or bullying occurring should bring the matter to the attention of his/her manager.

Redress

An employee who feels that he/she has been harassed or bullied has a right to seek redress via the procedures set out below.

Procedure for dealing with harassment

An employee who feels that he/she is being subjected to harassment or bullying may attempt to resolve the matter informally in the first instance. In some cases, it may be possible and sufficient for him/her to explain clearly to the person(s) engaged in the unwanted activities that the behaviour is unwelcome, that it offends or makes him/her uncomfortable.
If at the initial informal discussion stage the circumstances are too difficult or embarrassing to approach the harasser alone, the complainant may wish to be accompanied by a friend or colleague.

The complainant may wish to write a letter/email to the harasser (research has shown this to be very effective).

The complainant should keep a record of any incidents, detailing when, where, what occurred, and witnesses (if any);

In some cases, victims of harassment or bullying may not be sufficiently confident to tell the harasser that his or her behaviour is unacceptable. Starfish 9 Ltd. emphasises therefore that staff are not required to approach the harasser in an attempt to resolve the problem informally, and are entitled to report the matter immediately if they so wish.

Where the steps outlined above are unsuccessful or inappropriate, the complainant should raise the matter informally and in confidence with his/her manager. Alternatively, the matter may be raised with a more senior manager (if felt necessary this could be of the same sex as the complainant).

If the complaint relates to the conduct of the complainant's manager, the complainant may choose to discuss the matter with his/her manager's line manager.

The Manager will discuss the matter with the complainant and agree on a course of action. The complainant may be accompanied by a representative or work colleague at these meetings. The alleged harasser will also have the right to state their version of events to the manager and to also be accompanied by a representative or colleague.

The complainant must be assured that he/she will not be discriminated against or victimised for raising the complaint. Confidentiality will be observed throughout and the need for any disclosure of the details of the case will be discussed and agreed.

At any stage of the process the complainant, the manager dealing with the complaint or the accused may feel that they need the help of an independent person before deciding on the best course of action. Starfish 9 Ltd. will seek the advice of a suitably trained person who can give confidential advice and assistance, including:

Advising on the nature of harassment;
Offering guidance on resolving harassment problems, including acting as an independent broker

If the situation cannot be resolved informally then the complainant has the right to pursue his or her complaint formally via the Starfish 9 Ltd.'s Grievance Procedure.

Where management consider that there may be evidence of harassment, they may consider it appropriate to undertake a full investigation of the circumstances. In this case, a manager not connected with the department involved, or an individual external to the Starfish 9 Ltd. will be commissioned to undertake this investigation.

Best practice in relation to confidentiality will be maintained during this investigation, and both the complainant and alleged harasser will have the opportunity to have their say. The investigator will also interview and take statements from any appropriate witnesses to the alleged harassment.

Where there is evidence that harassment has occurred, prompt and corrective action will be taken, including disciplinary action where appropriate. Harassment is a serious offence which may result in summary dismissal.

Communication

All staff will be informed of the Harassment and Bullying Policy and Procedure. They must be reassured regarding:

Fear that others will consider the behaviour trivial and not take complaints of harassment seriously;
Fear that no action will be taken against a person guilty of harassment;
Fear of retaliation or victimisation in registering a complaint either informally or formally through the Grievance Procedure.

The Harassment and Bullying Policy will be part of staff induction.

Training

Training will be provided for those employees who have specific responsibility for implementing this Procedure or who may be involved in dealing with complaints which arise.

Monitoring and Review

In order to assess the effectiveness of the Procedure, statistics will be maintained in respect of the complaints of harassment. Strict confidentiality will be maintained and the monitoring process will comply with the Data Protection Act.

The effectiveness of this policy will be reviewed regularly.

Starfish 9 Ltd. Harassment and Bullying Policy - Jan 19
(Last Review Jan 2019- Next Planned Review- Jan 2020)

Young Person Policy

Introduction

A young person is someone who has not reached the age of 18, and a child at work is a young person who has not reached the minimum school leaving age (MSLA), usually 15. Young people are at greater risk whilst at work for the following reasons:

• Lack of knowledge and/or training;
• A young person's body has not fully developed; and
• A young person may be more likely to:
  • Take risks;
  • Respond to peer group pressure; and
  • Be over-enthusiastic.

Risks

Before employing a young person Starfish 9 Ltd. will conduct a risk assessment to identify control measures needed to minimize health & safety risks specific to the young person. These risk assessments should consider:

• The workplace where the young person will work;
• Physical, biological and chemical agents;
• The work equipment;
• The organisation of work and the processes involved;
• Health & Safety training;
• Risks from particular:
  • Agents, carcinogens;
  • Processes, e.g. explosives, COSHH Regulations, manual handling, tools and equipment; and
  • Dangerous work, e.g. working at height and hot-work.

If a significant risk remains after control measures have been introduced, the risk assessment will determine whether the work of young persons should be restricted, or whether the young person must not be employed to do the work. Young people over the MSLA should not be employed to do work which:

• Is beyond their physical or psychological capacity;
• Exposes them to substances chronically harmful to human health, e.g. those which are known to be either toxic or carcinogenic, or to have effects likely to be passed on genetically, or likely to harm the unborn child;
• Exposes them to radiation;
• Involves a risk of accidents which they are unlikely to recognize because of, e.g. their lack of experience or training; and
• Involves a risk to their health from extreme heat, noise or vibration.

Exceptions to the above may be made were young workers, e.g. apprentices, are doing work necessary for their training, under proper supervision by a competent person/coach, providing the risks are reduced to the lowest level. Under no circumstances can children under MSLA do work involving these risks, e.g. work experience.

Control Measures

STARFISH 9 LTD will not take a young person into their employ unless a risk assessment has been carried out. As with any risk assessments, it must be reviewed and revised if necessary periodically or where circumstances ( e.g. nature of work changes, the incident occurs) may make the risk assessment no longer valid. When carrying out the risk assessment or the review of the risks to young persons, employers must take into consideration:

• The inexperience and immaturity of young persons;
• Their lack of awareness of risks to their health and safety;
• The fitting out and layout of their workstation and workplace;
• The nature, degree and duration of any exposure to biological, chemical or physical agents;
• Work in which there is a risk of their health from exposure to extreme cold or heat, noise or vibration;
• The form, range use and handling of work equipment;
• The way in which processes and activities are organized;
• Any health and safety training given or intended to be given;
• The risk associated with the agents, processes and work listed in the Annex to EC Directive 94/33/EC;
• Accidents, which are unlikely to be recognized because of a lack of experience, training or sufficient attention to safety;
• Provide information to parents/guardians of school-age children about the risks and the control measures to be adopted;
• Take account of the Risk Assessments and determine whether the young person should be prohibited from certain work activities except where it is necessary for their training;
• Proper supervision is to be provided by a competent person.

The following generic control measures must also be considered:

• Induction training;
• Close supervision/coaching/mentoring.
• Specific health surveillance;
• Clear lines of communication;
• Restricting the type of work carried out; and
• Restricting the hours worked.

Other factors that should be considered utilising young persons on a site/project include:

• Any statutory restrictions on young persons carrying out activities, e.g. driving;
• Ensuring that any PPE which is required is suitable for their size, shape and purpose; and
• Insurance requirements.

All Starfish 9 Ltd employees/subcontractors are subject to STARFISH 9 LTD site rules and conditions at all times. All STARFISH 9 LTD employees/subcontractors will receive and sign for a site induction/briefing including STARFISH 9 LTD competencies prior to commencing work on-site.

Working at Height

Any young person must be under supervision at all times when working at height. STARFISH 9 LTD will check with our or our sub-contractors insurer that we have sufficient cover to employ young persons and that there are no limits on height; we must also obtain permission to use young persons at height from the principal contractor - their site rules and instructions are FINAL. In respect of Sub-Contractors employing young persons, proof of Risk Assessments, information, instruction and training is to be provided prior to commencement on site.

The regulations require that young workers aged between 16-18 are not employed for more than eight hours a day or for more than 40 hours a week, including overtime hours. THERE IS NO OPT-OUT AVAILABLE TO YOUNG PERSONS. Employees of this age are also entitled to:-

• A break of 30 minutes every 4 ½ hours worked;
• A rest period of 12 hours between each working day;
• Two days off a week.

Young workers may not ordinarily work at night between 10 pm and 6 a.m.

Training

Young persons/apprentices will undergo an appropriate apprenticeship which includes successful completion of the Construction Skills programme including college attendance and examinations/on-site assessments. In terms of competency assessment, apprentices will be subject to assessment at 'Manager' level on completion of their apprenticeship. Part of their development will be aspiring to achieve those competency requirements as well as attaining SVQ/NVQ level 2 qualifications and CSCS cards. They will also be expected to undertake on the job coaching as well as attending and participating in monthly briefings and any appropriate customer training required as part of their development.

Redundancy

Age legislation removes the age limit on redundancy pay.

Starfish 9 Ltd. Young Person Policy- Jan 19
(Last Review Jan 2019- Next Planned Review- Jan 2020)

Lone Workers Policy

It is STARFISH 9 LTD's Policy that no contract work shall be carried out on roofs by a person working alone. By necessity, most roof/building surveys are carried out whilst working alone, and in these circumstances, it is important that the individual advises their Line Manager and a client representative where he/she is working, approximately how long he/she will be and that he/she reports off when finished.

Roof Surveys and Inspections

When carrying out a survey on your own, the following procedures are to be adhered to:

• Liaise with site personnel before going out on onto roof (ensure the mobile telephone is with you);
• Carry out thorough Risk Assessment prior to going onto the roof;
• Ensure you have client/reception contact number in an emergency;
• If in doubt over safety stop until safe procedures agreed;
• Sign off with client on completion of survey i.e, advise you have completed and are now leaving the premises.

Loan Workers Out Of Hours

• Working alone outside normal business hours has some possible added risks, even if the person is working at a desk doing normal office type work;
• Most fires occur outside normal business hours;
• Accidents such as tripping, slipping or falling could render a person unconscious or incapable of calling for help;
• Attacks on employees for whatever reasons, e.g, vandals, burglars etc, whether they are entering, leaving or actually working in the premises;
• These are just a few examples of how the lone worker in premises outwith normal working hours could be at risk;
• If after assessing all the circumstances the manager decides to allow the person to work after normal business hours and alone, the manager must ensure that the person is made well aware of all the information that they require, i.e, phone number, first aid kit, don't walk in the dark and so on;
• It is also prudent to set up call procedures whereby the person working alone can phone at regular intervals to some contact point (designated person).

Starfish 9 Ltd. Lone Workers Policy- Jan 19
(Last Review Jan 2019- Next Planned Review- Jan 2020)

Alcohol and Drugs Policy

As a responsible employer, we agree to honour both our statutory and corporate obligation to meet the requirements of current health and safety legislation. In so doing we believe we shall be satisfying the needs and expectations of our business, employees and clients through the application of effective control measures in the use and abuse of alcohol and drugs in the workplace. It is subsequently a mandatory condition of employment, that all staff we employ and issue company vehicles shall not;

• Report or endeavour to report for duty, or drive a company vehicle having just consumed alcohol or when under the influence of unauthorised drugs;
• Report for duty or drive a company vehicle in an unfit state due to the use of alcohol or drugs;
• Be in possession of unauthorised drugs in the workplace, including when driving a company vehicle;
• Abuse authorised drugs or consume any alcohol whilst on duty, including when driving a company vehicle.

It is also a mandatory requirement that all staff we employ and/ or sponsor are fully aware and agree to comply with the following terms and conditions as an integral part of their contract of employment;

• Unannounced Screening - once employed staff may be subject to unannounced screening through a random selection process. (Note: this level may be increased or reduced based on the company's perception of risk, whereby its current activity and the roles of those employed and sponsored would be taken into account).
  
  Following unannounced screening - those screened shall be allowed to continue to work as normal while awaiting their results unless of course there are reasonable grounds to suspect they may be unfit for duty.
• For Cause Screening - Following an accident, incident or near miss, staff whose acts or omissions may have lead or contributed to its cause may be subject to 'for cause screening'.

Staff suspected to be under the influence of alcohol and/or drugs may also subject to for-cause screening, and as such the same terms and conditions shall apply. Staff subject to for-cause screening shall be suspended from any on-track/ safety-critical duties until such time as a 'pass' (negative) result has been confirmed.

Starfish 9 Ltd. Alcohol and Drugs Policy - Jan 19
(Last Review Jan 2019 - Next Planned Review- Jan 2020)

Smoking and Vaping Policy

To protect and enhance indoor air quality and contribute to the health and well being of all employees and visitors Starfish9 Ltd shall be totally smoke and vape free.

Smoking and vaping are prohibited in all Starfish 9 Ltd. properties including company vehicles. Smoking, vaping or other use of tobacco products (including, but not limited to pipes, cigars, snuff or chewing tobacco) is not permitted in any part of company buildings or in vehicles owned, leased, or rented to the company.

No additional breaks beyond those allowed under the company’s break policy may be taken for the purpose of using e-cigarettes or tobacco products. Employees may smoke outside the building during breaks but not in doorways or entrances. All employees must also strictly adhere to clients smoking policies.

There is still a lot we do not know about e-cigarettes. They are not risk-free but based on current evidence, they have a much lower risk than tobacco Regardless of the potential health risks, second-hand aerosols from nearby vaping can also be a nuisance since the e-cigarettes can include strong flavours and leave pungent odours.

All employees are expected to abide by this policy while at work, whether on company premises, at a customer’s site, or in vehicles owned, leased or rented by the company. Failure to do so may result in disciplinary action. Starfish 9 Ltd.

Smoking and Vaping Policy – Jan 19
(Last Review Jan 2019-Next Planned Review Jan 2020)