Information Security and Data Protection Policy
The Data Protection Act 1998
PureTech Talent Ltd (“the Company”) processes personal data in relation to its own staff, work-seekers and individual client contacts – therefore it is a “data controller” for the purposes of the Data Protection Act 1998. The Company has notified the Information Commissioner’s Office – the Company’s data protection registration number is ZA269993 The Company holds personal data on individuals (“data subjects”) for the following general purposes:
- Staff administration.
- Advertising, marketing and public relations.
- Accounts and records.
- Administration and processing of work-seekers personal data for the purposes of work-finding services.
The eight principles of data protection
The Data Protection Act 1998 requires the Company as data controller to process data in accordance with the principles of data protection. These require that personal data shall be:
- Fairly and lawfully processed.
- Processed for limited purposes.
- Adequate, relevant and not excessive.
- Not kept longer than necessary.
- Processed in accordance with the data subjects rights.
- Kept securely.
- Not transferred to countries outside the European Economic Area without adequate protection.
“Personal data” means data, which relates to a living individual who can be identified from the data or from the data together with other information, which is in the possession of, or is likely to come into possession of the Company.
“Processing” means obtaining, recording or holding the data or carrying out any operation or set of operations on the data. It includes organising, adapting and amending the data, retrieval, consultation and use of the data, disclosing and erasure or destruction of the data. It is difficult to envisage any activity involving data, which does not amount to processing. It applies to any processing that is carried out on computer including any type of computer however described, main frame, desktop, laptop, iPad, Blackberry ® or other mobile device.
Personal data should be reviewed on a regular basis to ensure that it is accurate, relevant and up to date and those people listed in the Appendix shall be responsible for doing this.
Personal data may only be processed with the consent of the person whose data is held. Therefore if they have not consented to their personal details being passed to a third party this may constitute a breach of the Data Protection Act 1998. By instructing the Company to look for work and by providing us with personal data contained in a CV work-seekers will be giving their consent to processing their details for work-finding purposes. If you intend to use their personal data for any other purpose you MUST obtain their specific consent.
Caution should be exercised before forwarding the personal details of any individuals on whom personal data is held, to any third party such as past, current or prospective employers, suppliers, customers and clients, persons making an enquiry or complaint and any other third party.
Sensitive personal data
Personal data in respect of the following is “sensitive personal data” and any information held on any of these matters MUST NOT be passed onto any third party without the express written consent of the individual:
- Any offence committed or alleged to be committed by them.
- Proceedings in relation to any offence and any sentence passed.
- Physical or mental health or condition.
- Racial or ethnic origins.
- Sexual life.
- Political opinions.
- Religious beliefs or beliefs of a similar nature.
- Whether someone is a member of a trade union.
From a security point of view, only those staff listed in the Appendix are permitted to add, amend or delete personal data from the Company’s database(s) (“database” includes paper records or records stored electronically). However all staff are responsible for notifying those listed where information is known to be old, inaccurate or out of date. In addition all employees should ensure that adequate security measures are in place. For example:
- Computer screens should not be left open by individuals who have access to personal data.
- Passwords should not be disclosed.
- Email should be used with care.
- Personnel files and other personal data should be stored in a place in which any unauthorised attempts to access them will be noticed. They should not be removed from their usual place of storage without good reason.
- Personnel files should always be locked away when not in use and when in use should not be left unattended.
- Any breaches of security should be treated as a disciplinary issue.
- Care should be taken when sending personal data in internal or external mail.
- Destroying or disposing of personal data counts as processing. Therefore care should be taken in the disposal of any personal data to ensure that it is appropriate. Such material should be shredded or stored as confidential waste awaiting safe destruction.
It should be remembered that the incorrect processing of personal data e.g. sending an individual’s details to the wrong person, allowing unauthorised persons access to personal data, or sending information out for purposes for which the individual did not give their consent, may give rise to a breach of contract and/or negligence leading to a claim against the Company for damages from an employee, work-seeker or client contact. A failure to observe the contents of this policy will be treated as a disciplinary offence.
Subject access requests
Data subjects are entitled to obtain access to their data on request and after payment of a fee. All requests to access personal data by data subjects should be referred to Company Directors whose details are listed in the Appendix to this policy.
Any requests for access to a reference given by a third party must be referred to Ken Acar or Jason Sperrin and should be treated with caution even if the reference was given in relation to the individual making the request. This is because the person writing the reference also has a right to have their personal details handled in accordance with the Data Protection Act 1998, and not disclosed without their consent. Therefore when taking up references an individual should always be asked to give their consent to the disclosure of the reference to a third party and/or the individual who is the subject of the reference if they make a subject access request. However if they do not consent then consideration should be given as to whether the details of the individual giving the reference can be deleted so that they cannot be identified from the content of the letter. If so the reference may be disclosed in an anonymised form.
The Human Rights Act 1998
Finally it should be remembered that all individuals have the following rights under the Human Rights Act 1998 and in dealing with personal data these should be respected at all times:
- Right to respect for private and family life (Article 8).
- Freedom of thought, conscience and religion (Article 9).
- Freedom of expression (Article 10).
- Freedom of assembly and association (Article 11).
- Freedom from discrimination (Article 14).
- Mr Ken Acar – Director
- Mr Jason Sperrin – Director
Equal Opportunities & Diversity Policy
PureTech Talent Ltd embraces diversity and aims to promote the benefits of diversity in all of our business activities. We seek to develop a business culture that reflects that belief. We will expand the media in which we recruit to in order to ensure that we have a diverse employee and candidate base. We will also strive to ensure that our clients meet their own diversity targets.
PureTech Talent Ltd is committed to diversity and will promote diversity for all employees, workers and applicants. We will continuously review all aspects of recruitment to avoid unlawful discrimination.
PureTech Talent Ltd will treat everyone equally and will not discriminate on the grounds of an individual’s “protected characteristic” under the Equality Act 2010 (the Act) which are age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation. We will not discriminate on the grounds of an individual’s membership or nonmembership of a Trade Union. All staff have an obligation to respect and comply with this policy.
PureTech Talent Ltd is committed to providing training for its entire staff in equal opportunities and diversity.
PureTech Talent Ltd will avoid stipulating unnecessary requirements which will exclude a higher proportion of a particular group of people and will not prescribe discriminatory requirements for a role.
PureTech Talent Ltd will not discriminate unlawfully when deciding which candidate/temporary worker is submitted for a vacancy or assignment, or in any terms of employment or terms of engagement for temporary workers.
PureTech Talent Ltd will ensure that each candidate is assessed in accordance with the candidate’s merits, qualifications and ability to perform the relevant duties for the role.
Under the Act unlawful discrimination occurs in the following circumstances:
Direct discrimination occurs when an individual is treated less favourably because of a protected characteristic. Treating someone less favourably means treating them badly in comparison to others that do not have that protected characteristic. It is unlawful for a recruitment consultancy to discriminate against a person on the grounds of a protected characteristic:
- in the terms on which the recruitment consultancy offers to provide any of its services;
- by refusing or deliberately omitting to provide any of its services;
- in the way it provides any of its services.
Direct discrimination can take place even if the individual does not have the protected characteristic but is treated less favourably because it is assumed he or she has the protected characteristic or is associated with someone that has the protected characteristic.
Direct discrimination would also occur if a recruitment consultancy accepted and acted upon instructions from an employer which states that certain persons are unacceptable due to a protected characteristic, unless an exception applies. The Act contains provisions that permit specifying a requirement that an individual must have a particular protected characteristic in order to undertake a job. These provisions are referred to as occupational requirements.
Where there is an occupational requirement then the client must show that applying the requirement is a proportionate means of achieving a legitimate aim, i.e. the employer must be able to objectively justify applying the requirement. An occupational requirement does not allow an employer to employ someone on less favourable terms or to subject a person to any other detriment. Neither does an occupational requirement provide an excuse against harassment or victimisation of someone who does not have the occupational requirement.
Indirect discrimination occurs when a provision, criterion or practice (PCP) is applied but this results in people who share a protected characteristic being placed at a disadvantage in comparison to those who do not have the protected characteristic. If the PCP can be objectively justified it will not amount to discrimination.
Indirect discrimination would also occur if a recruitment consultant accepted and acted upon an indirectly discriminatory instruction from an employer.
If the vacancy requires characteristics which amount to an occupational requirement or the instruction is discriminatory but there is an objective justification,
PureTech Talent Ltd will not proceed with the vacancy unless the client provides written confirmation of the occupational requirement, exception or justification. PureTech Talent Ltd will use best endeavours to comply with the Act and will not accept instructions from clients that will result in unlawful discrimination.
Under the Act, harassment is defined as unwanted conduct that relates to a protected characteristic which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual. This includes unwanted conduct of a sexual nature.
PureTech Talent Ltd is committed to providing a work environment free from unlawful harassment.
PureTech Talent Ltd will ensure that the consultants do not harass any individual.
Examples of prohibited harassment are:
- verbal or written conduct containing derogatory jokes or comments;
- slurs or unwanted sexual advances;
- visual conduct such as derogatory or sexually orientated posters;
- photographs, cartoons, drawings or gestures which some may find offensive;
- physical conduct such as assault, unwanted touching, or any interference because of sex, race or any other protected characteristic basis;
- threats and demands to submit to sexual requests as a condition of continued employment or to avoid some other loss, and offers of employment benefits in return for sexual favours;
- retaliation for having reported or threatened to report harassment.
If an individual believes that they have been unlawfully harassed, they should make an immediate report to a PureTech Talent Ltd Human Resources Representative followed by a written complaint as soon as possible after the incident. The details of the complaint should include:
- Details of the incident
- Name(s) of the individual(s) involved
- Name(s) of any witness(es)
PureTech Talent Ltd will undertake a thorough investigation of the allegations. If it is concluded that harassment has occurred, remedial action will be taken.
All employees and workers will be expected to comply with PureTech Talent Ltd’s policy on harassment in the workplace. Any breach of such a policy will lead to the appropriate disciplinary action.
Any individual who PureTech Talent Ltd finds to be responsible for harassment will be subject to the disciplinary procedure and the sanction may include termination.
Under the Act victimisation occurs when an individual is treated unfavourably because he/she has done a ‘protected act’ which is bringing a claim for unlawful discrimination or raising a grievance about discrimination or giving evidence in respect of a complaint about discrimination.
PureTech Talent Ltd will ensure that the consultants do not victimise any individual.
Discrimination occurs when a person is treated unfavourably as a result of their disability.
In direct discrimination occurs where a provision, criterion or practice is applied by or on behalf of an employer, or any physical feature of the employer’s premises, places a disabled person at a substantial disadvantage in comparison with persons who are not disabled.
In recruitment and selection there may be a requirement to make reasonable adjustments. For example, it might be necessary to have different application procedures for partially sighted or blind applicants that enable them to use Braille. With testing and assessment methods and procedures, tests can only be justified if they are directly related to the skills and competencies required for the job. Even then, it might be appropriate to have different levels of acceptable test results, depending on the disability. For example, an applicant with a learning disability might need more time to complete a test, or not be expected to reach the same standard as other non-disabled applicants.
Reasonable adjustments in recruiting could include:
- modifying testing and assessment procedures;
- meeting the candidate at alternative premises which are more easily accessible;
- having flexibility in the timing of interviews;
- modifying application procedures and application forms;
- providing a reader or interpreter.
Wherever possible PureTech Talent Ltd will make reasonable adjustments to hallways, passages and doors in order to provide and improve means of access for disabled employees and workers. However, this may not always be feasible, due to circumstances creating such difficulties as to render such adjustments as being beyond what is reasonable in all the circumstances.
Will not discriminate against a disabled person:
- in the arrangements i.e. application form, interview or arrangements for selection for determining whom a job should be offered; or
- in the terms on which employment or engagement of temporary workers is offered; or
- by refusing to offer, or deliberately not offering the disabled person a job for reasons connected with their disability; or
- in the opportunities afforded to the person for receiving any benefit, or by refusing to afford, or deliberately not affording him or her any such opportunity; or
- by subjecting the individual to any other detriment (detriment will include refusal of training or transfer, demotion, reduction of wage, or harassment).
PureTech Talent Ltd will make career opportunities available to all people with disabilities and every practical effort will be made to provide for the needs of staff, candidates and clients.
Under the Act, it is unlawful to directly or indirectly discriminate against or to harass or victimise a person because of age. Age discrimination does not just provide protection for people who are older or younger. People of all ages are protected.
A reference to age is a reference to a person’s age group. People who share the protected characteristic of age are people who are in the same age group.
Age group can have various references:
- Under 21s
- People in their 40s
PureTech Talent Ltd will not discriminate directly or indirectly, harass or victimise any person on the grounds of their age. We will encourage clients not to include any age criteria in job specifications and every attempt will be made to encourage clients to recruit on the basis of competence and skills and not age.
PureTech Talent Ltd is committed to recruiting and retaining employees whose skills, experience, and attitude are suitable for the requirements of the various positions regardless of age. No age requirements will be stated in any job advertisements on behalf of the company.
If PureTech Talent Ltd requests age as part of its recruitment process such information will not be used as selection, training or promotion criteria or in any detrimental way and is only for compilation of personal data, which the company holds on all employees and workers and as part of its equal opportunities monitoring process. In addition, if under age 22 to adhere to Conduct of Employment Agencies and Employment Business Regulations 2003 and other relevant legislation applicable to children or young candidates.
Where a client requests age or date of birth, this will have to be under an occupational requirement or with an objective justification which should be confirmed in writing.
This policy also covers the treatment of those employees and workers who work on a part-time basis, PureTech Talent Ltd recognises that it is an essential part of this policy that part time employees are treated on the same terms, with no detriment, as full-time employees (albeit on a pro rata basis) in matters such as rates of pay, holiday entitlement, maternity leave, parental and domestic incident leave and access to our pension scheme. PureTech Talent Ltd also recognises that part time employees must be treated the same as full time employees in relation to training and redundancy situations.
GENDER REASSIGNMENT POLICY
PureTech Talent Ltd recognises that any employee or worker may wish to change their gender during the course of their employment with the Company. PureTech Talent Ltd will support any employee or worker through the reassignment.
PureTech Talent Ltd will make every effort to try to protect an employee or worker who has undergone, is undergoing or intends to undergo gender reassignment, from discrimination or harassment within the workplace.
Where an employee is engaged in work where the gender change imposes genuine problems will PureTech Talent Ltd make every effort to reassign the employee or worker to an alternative role in the Company, if so desired by the employee.
Any employee or worker suffering discrimination on the grounds of gender reassignment should have recourse to the Company’s grievance procedure.
RECRUITMENT OF EX-OFFENDERS
Where PureTech Talent Ltd has registered with the Disclosure and Barring Service (DBS) and has the authority to apply for criminal records checks on individual because they are working with children or vulnerable adults or both, we will comply with the DBS’s Code of Practice which includes having a policy on the recruitment of ex-offenders.
COMPLAINTS AND MONITORING PROCEDURES
PureTech Talent Ltd has in place procedures for monitoring compliance with this policy and for dealing with complaints of discrimination. These are available from PureTech Talent Human Resources Department and will be made available immediately upon request. Any discrimination complaint will be investigated fully.
Anti-Bribery and Corruption Policy
In this policy “we”, ‘us”, and “the Company” mean PureTech Talent Ltd.
“Bribe” means an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage; “to Bribe” and “Bribery” are construed accordingly.
“Relevant Person” means any individual (whether an officer of employee of the Company, or a temporary worker, contractor or consultant providing services to or on behalf of the Company) or any corporate entity who performs functions for or on behalf of the Company.
One of the Company’s core values is to uphold responsible and fair business practice. It is committed to promoting and maintaining the highest level of ethical standards in relation to all of its business activities. Its reputation for maintaining lawful business practices is of paramount importance and this Policy is designed to preserve these values. The Company therefore has a zero-tolerance policy towards bribery and corruption and is committed to acting fairly and with integrity in all of its business dealings and relationships and to implementing and enforcing effective systems to counter bribery.
Purpose and scope of this policy
This Policy sets out the steps all of us must take to prevent bribery and corruption in our business and to comply with relevant legislation. It is aimed at:
- ensuring compliance with anti-bribery laws, rules and regulations, not just within the UK but in any other country within which the Company may carry out its business or in relation to which its business may be connected;
- enabling any Relevant Person to understand the risks associated with bribery and to encourage them to be vigilant and effectively recognise, prevent and report any wrongdoing, whether by themselves or others;
- providing suitable and secure reporting and communication channels and ensuring that any information that is reported is properly and effectively dealt with;
- creating and maintaining a rigorous and effective framework for dealing with any suspected instances of bribery or corruption.
All Relevant Persons are expected to adhere to the principles set out in this Policy.
The Bribery Act 2010
The Bribery Act 2010 (the Bribery Act) came into force on 1 July 2011. The Bribery Act affects the Company in its business relations anywhere in the world. Under the Bribery Act it is an offence to:
- bribe a person i.e. to offer, promise or give a financial or other advantage to another person, whether within the UK or abroad, with the intention of inducing or rewarding improper conduct;
- receive a Bribe i.e. to request, agree to receive or accept a financial or other advantage for or in relation to improper conduct;
- bribe a foreign public official; and
- fail to prevent Bribery.
Risks of not acting with integrity
Involvement in Bribery or corruption carries many risks. Among them are:
- a company which pays or accepts Bribes is not in control of its business and is at risk of blackmail;
- if the Company is found guilty of Bribery or even of failing to have adequate procedures in place to prevent Bribery, it will be subject to unlimited fines;
- any person found guilty of Bribery will be subject to fines and/or imprisonment of up to 10 years;
- a public exposure, or even allegation, of bribery would entail severe reputational damage. The Company’s banking or clientele would be available on much less favourable terms, and the Company could be blacklisted as an approved tenderer for both public and private sector contracts;
- the cost of our insurance cover could increase very significantly; and
- good people will not want to work for us.
Benefits of acting with integrity
Equally, there are very clear benefits to acting with propriety. These include:
- we increase our chances of being selected as a supplier in both the public and private sectors;
- we remain in good standing with our banks and our own suppliers and they will want to keep doing business with us;
- a business with high ethical standards is a good place to work; and
- it is a requirement of the REC Code of Professional Practice that we act with integrity at all times.
All Relevant Persons and Associated Persons are required at all times:
- not to commit an offence listed above at section 4 or any other offence;
- to comply with the Bribery Act and any other anti-bribery and anti-corruption legislation that applies in any jurisdiction in any part of the world in which they or the Company might conduct business;
- to act honestly, responsibly and with integrity;
- to safeguard and uphold the Company’s core values by operating in an ethical, professional and lawful manner at all times.
Bribery of any kind is strictly prohibited. Under no circumstances should any provision be made, money set aside or accounts created for the purposes of facilitating the payment or receipt of a Bribe. All Relevant Persons and all Associated Persons are expected to adhere strictly at all times to the guidelines set out in this Policy. If you are in doubt as to what might amount to bribery or what might constitute a breach of this Policy, refer the matter to the Human Resources/Compliance Director.
Gifts and Hospitality
The Company occasionally provides gifts and hospitality to clients, customers, contractors, and suppliers. This is not prohibited by the Bribery Act provided the following requirements are met:
- the gift is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage;
- it complies with local laws;
- it is given in the Company’s name, not in the giver’s personal name;
- it does not include cash or a cash equivalent (such as gift vouchers);
- it is of an appropriate and reasonable type and value and given at an appropriate time;
- it is given openly, not secretly;
- it is approved in advance by a director of the Company.
In summary, it is not acceptable to give, promise to give, or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given, or to accept a payment, gift or hospitality from a third party that you know or suspect is offered or provided with the expectation that it will obtain a business advantage for them.
Any payment or gift to a public official or other person to secure or accelerate the prompt or proper performance of a routine government procedure or process, otherwise known as a “facilitation payment”, is also strictly prohibited. Facilitation payments are not commonly paid in the UK but they are common in some other jurisdictions.
What are the indicators of bribery?
Common indicators of corruption include those listed below. There may well be others. For example:
- payments are for abnormal amounts (e.g. commission), or made in an unusual way, e.g. what would normally be a single payment is made in stages, through a bank account never previously used, or in a currency or via a country which has no connection with the transaction;
- process is bypassed for approval or sign-off of terms or submission of tender documents, payments, or other commercial matters; those whose job it is to monitor commercial processes i.e. Human Resources/Compliance Director may be prevented from or hindered in doing so;
- individuals are secretive about certain matters or relationships and/or insist on dealing with them personally. They may make trips at short notice without explanation, or have a more lavish lifestyle than expected;
- decisions are taken for which there is no clear rationale;
- records are incomplete or missing.
You should be aware that such contributions can be (or be seen as) Bribes in disguise. No individual is to make a donation stated to be, or which could be taken to be, on our behalf without the prior approval of the Board. You may, of course, make political donations in a personal capacity but please be sensitive to how such contributions could be perceived, especially by those who are aware of your connection with the Company.
Bribes may even be disguised as charitable donations. Whilst individuals may of course make personal donations to charity, they should not do so on behalf of the Company without prior approval from the Board.
We understand that different parts of the world have different social and cultural customs. This does not affect our position that we do not pay or accept bribes or act corruptly: we do not and will not. However, subject to that position, we understand the need to be sensitive to local customs. For example, there are cultures in which refusing (or even failing to offer) a gift is considered impolite, and could alienate a key contact. In such cases, please refer to the Human Resources/Compliance Director Exceptional circumstances In some circumstances, a payment is justifiable. If one of our people is faced with a threat to his or her personal safety or that of another person if a payment is not made, they should pay it without fear of recrimination. In such cases, however, the Financial Director must be contacted as soon as possible, and the payment and the circumstances in which it was made must be fully documented and reported to the for Human Resources/Compliance Director the business concerned within five working days. Consider carefully whether to involve the police. There may be cases where this will actually make the situation worse Such cases will be rare. All Relevant Persons visiting regions where they are more common should familiarise themselves, prior to travel, with current guidance relating to those countries. The Human Resources/Compliance Director should be consulted if in doubt.
Responsibility to report and the reporting procedure
All Relevant Persons are contractually required to take whatever reasonable steps are necessary to ensure compliance with this Policy and to prevent, detect and report any suspected Bribery or corruption. All Relevant Persons have a duty to prevent, detect and report any incident of Bribery and any potential risks of Bribery. If you know or suspect that any Relevant Person plans to offer, promise or give a Bribe or to request, agree to receive or accept a Bribe in connection with the Company’s business, you must disclose this to Human Resources/Compliance Director as quickly as possible to allow appropriate action to be taken promptly.
The Company is committed to taking appropriate action against Bribery and corruption. This may include either reporting the matter to an appropriate external government department, regulatory agency or the police and/or taking internal disciplinary action against relevant employees and/or terminating contracts with associated persons.
The Company will keep your disclosure confidential during any investigation it undertakes to the extent that this is practical and appropriate in the circumstances. The Company will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. The Company is also committed to ensuring nobody suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or corruption offence has taken place or may take place in the future or because they may assist in the investigation of an allegation of Bribery or corruption.
All accounts, receipts, invoices and other documents and records relating to dealings with third parties must be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off the record” to facilitate or conceal improper payments.
The Company’s Human Resources/Compliance Director has primary responsibility for ensuring compliance with this Policy and will review its contents on a regular basis. She will be responsible for monitoring its effectiveness and will provide regular reports in this regard to the directors of the Company who have overall responsibility for ensuring this Policy complies with the Company’s legal and ethical obligations.
The Company will provide training to all employees to help them understand their duties and responsibilities under this Policy. The Company’s zero tolerance approach to Bribery will also be communicated to all business partners at the outset of the business relationship with them and as appropriate thereafter.
Sanctions for breach of this Policy
A breach of any of the provisions of this Policy by any Relevant Person who is an officer or employee of the Company will constitute a disciplinary offence and will be dealt with in accordance with the Company’s disciplinary procedure. Depending on the gravity of the offence, it may be treated as gross misconduct and could render the officer or employee liable to summary dismissal.
Breach of this policy by any Relevant Person who is a temporary worker, contractor or consultant providing his/ her services to the Company may lead to the immediate termination of that temporary workers, contractor’s or consultant’s engagement by the Company.
Breach of this policy by any Relevant Person which is a corporate entity could lead to the suspension or termination of any relevant contract, sub-contract or other agreement between the corporate entity and the Company.
- PureTech talent Ltd is committed to conducting its business with honesty and integrity and aims to achieve the highest possible standards of service and ethical standards in all of its practices.
- We expect all staff to maintain the same high standards too; however, all organisations face the risk of things going wrong and sometimes malpractice and wrongdoing can take place. We take malpractice and wrongdoing very seriously and aim to prevent and eliminate any wrongdoing or malpractice within the organisation.
- We therefore encourage all staff to raise any concerns they may have about malpractice or wrongdoing within the organisation freely and without fear of suffering a detriment or dismissal to enable us to eliminate and prevent wrongdoing or malpractice within the organisation.
- We will treat any concerns raised seriously and will protect and support any individual who makes a disclosure in line with this policy.
- This policy does not form part of any contract; PureTech Talent Ltd reserves the right to amend this policy at any time without prior notice.
WHO CAN RAISE A CONCERN UNDER THIS POLICY?
- This policy applies to all current and former employees, workers, officers, consultants, contractors of our business, including home workers, trainees, apprentices, agency workers, casual workers and limited company contractors.
- No qualifying length of service is required in order to raise a concern under this policy.
WHEN TO USE THIS POLICY
- This policy should be used to report concerns of malpractice or wrongdoing in relation to our organisation’s activities where you have information which you reasonably believe tends to show one or more of the following:
- that a criminal offence has been committed, is being committed or is likely to be committed
- that a person has failed, is failing or is likely to fail to comply with any legal obligation to which he or she is subject or
- that a miscarriage of justice has occurred, is occurring or is likely to occur; or
- that the health or safety of an individual has been, or is being or is likely to be endangered; or
- that the environment has been, is being or is likely to be damaged; or
- that any of the above malpractices have been, are being or are likely to be deliberately concealed. This applies whether the malpractice has already occurred, is currently in progress, or is likely to happen in the future.
- You must reasonably believe that the disclosure is being made in the public interest.
- It doesn’t matter if you are mistaken about your concern but you must have information that tends to show some malpractice or wrongdoing rather than an opinion or a feeling.
DISCLOSURES THAT ARE NOT COVERED BY THIS POLICY
- You will not qualify for protection under this policy if you commit an offence in making the disclosure, or if you disclose a matter that is subject to legal, professional privilege (for example, correspondence between PureTech Talent Ltd and our lawyers regarding a specific case).
- If your concern relates to your own treatment as an employee of PureTech Talent Ltd, including personal circumstances at work, you should raise it under our grievance procedure instead, unless you reasonably believe that the matter is in the public interest.
- If your concern relates to your own treatment or personal circumstances at work but you are not an employee of PureTech Talent Ltd, you should use our complaints procedure instead of the grievance procedure.Our complaints policy is available on request.
- If you wish to raise a concern of suspected malpractice or wrongdoing in relation to a hirer’s activities you may need to raise the concern directly with the hirer instead.
- Any other concerns about our services generally which are not related to the types of wrongdoing or malpractice covered by this policy should be raised using our complaints policy instead.
HOW TO RAISE A CONCERN
- If you have any concerns of the types of malpractice or wrongdoing covered by this policy, you should in the first instance make a disclosure to your immediate superior. Agency workers should disclose concerns to the consultant who is responsible for managing their assignment.
- If, for any reason, you feel that you cannot tell your immediate superior, or in the case of an agency worker the consultant responsible for managing your assignment, you should raise the issue with the Human Resources/Compliance Director at firstname.lastname@example.org or Jason Sperrin at email@example.com
- If you have made a disclosure and are still concerned, or the matter is so serious that you feel you cannot discuss it with either of the two persons named above, you should raise the matter with the following member of management: Ken Acar, Director, firstname.lastname@example.org
- A disclosure of a concern can be made by telephone, in person or in writing (including by email). However, it is preferable for the disclosure to be made in writing so that we can keep an exact record of your concern.
- You are not expected to prove the truth of your concern beyond reasonable doubt or provide any evidence; however, you will generally need to provide the following information as a minimum:
- the nature of the concern;
- why you believe it to be true;
- the background and history of the concern; and
- relevant dates where possible.
- You can raise any concerns anonymously; however, we encourage you to give your name when reporting your concern wherever possible because it may be more difficult for us to protect your position or give you feedback on the outcome of investigations if you choose to remain anonymous.
- You may wish to consider discussing your concern with a colleague before raising it formally under this policy. You can also choose to raise a concern under this policy alone or with a colleague; however, it is in the interests of all parties to maintain confidentiality once you have raised a formal concern.
HOW WE RESPOND TO CONCERNS RAISED UNDER THIS POLICY
- We are committed to ensuring that all disclosures raised in accordance with this policy will be dealt with objectively, consistently, fairly and professionally.
- We will take the time to listen to any issues raised and arrange a meeting as soon possible to discuss your concern (unless the concern has been raised anonymously). The aim of the meeting will be to establish the background and facts in order to help us decide whether and how to carry out any subsequent investigation. We may ask you for further information about the concern raised, either at this meeting or at a later stage.
- Any concerns you raise in line with this policy will be recorded by our Human Resources/Compliance Director.
- After the meeting, we will decide how to respond. This will usually involve making internal enquiries in the first instance, but it may be necessary to carry out an investigation at a later stage which may be formal or informal depending on the nature of the concern raised. We will endeavour to complete investigations within a reasonable time.
- We will keep you informed of the progress of the investigation as it is carried out and when it is completed, and give you an indication of the timescale for any actions or next steps that we may take. We cannot inform you of any matters that would breach any duty of confidentiality owed to others.
- We will consider any concerns raised anonymously at our discretion, taking into account factors such as the seriousness of the issue raised, the credibility of the concern and the likelihood of confirming the allegation from other sources. However, concerns that are expressed completely anonymously are much less powerful and are difficult to investigate. It may also be difficult for us to provide you with feedback if you cannot be contacted.
- If disciplinary or other proceedings follow the investigation, we may need to ask you to come forward as a witness to help us take appropriate action to end the wrongdoing.
- All concerns raised will be treated as confidential and every effort will be made not to reveal the identity of any individual who raises a concern. Unless the law requires otherwise, we will only make disclosures to third parties or other staff with your consent.
RAISING YOUR CONCERN EXTERNALLY (EXCEPTIONAL CASES)
- The main purpose of this policy is to give all our staff the opportunity and protection they need to raise concerns internally. We would expect that in almost all cases raising concerns internally would be the most appropriate course of action in order to resolve the issue.
- However, if for whatever reason you feel you cannot raise your concerns internally and you reasonably believe the information and any allegations are substantially true and in the public interest, the law recognises that it may be appropriate for you to raise the matter with another approved person, such as a regulator, professional body, or an MP. A list of the relevant prescribed people and bodies that you can raise a concern with is available on the GOV.UK website via the following link: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/510962/BIS-16-79-blowing-the-whistle-to-a-prescribed-person.pdf.
- We strongly encourage individuals to seek appropriate advice before reporting a concern to an external person. Public Concern at Work is a leading independent charity whose main objective is to promote compliance with the law and good practice in the public, private and voluntary sectors. They are a source of further information and advice and operate a confidential helpline. ACAS also operate a free confidential helpline that you can contact for advice. The contact details for both organisations are set out in the “FURTHER INFORMATION AND CONTACTS” section below.
PROTECTION AND SUPPORT FOR THOSE RAISING CONCERNS
- We hope that all staff will feel able to voice their concerns freely under this policy.
- PureTech Talent Ltd is committed to good practice and high standards and to being supportive of staff who raise genuine concerns under this policy, even if they turn out to be mistaken.
- Any individual raising a genuine concern must not suffer any detriment as a result of doing so. If you believe that you have suffered such treatment, you should inform Human Resources/Compliance Director immediately.
- Puretech Talent Ltd will not tolerate any harassment or victimisation of individuals who raise concerns about wrongdoing or malpractice in the workplace. No member of staff may threaten or retaliate against an individual who has raised a concern. Any person involved in such conduct may be subject to disciplinary action.
- To ensure the protection of all our staff and the integrity of our business, those who raise a concern frivolously, maliciously and/or for personal gain and/or make an allegation they do not reasonably believe to be true and/or not made in the public interest may also be subject to disciplinary action.
- If you are not happy with the way in which a matter has been addressed or dealt with you should raise it formally using our complaints procedure. Employees of PureTech Talent Ltd can use our grievance procedure to address the issue instead.
FURTHER INFORMATION AND CONTACTS
- If you have any queries about the application of this policy, please contact Human Resources/Compliance Director in the first instance.
- Public Concern at Work is a source of further information and advice. It also provides a free helpline offering confidential advice on 020 7404 6609. Further information is available on their website at www.pcaw.co.uk.
- The Advisory, Conciliation and Arbitration Service (ACAS) also has a free helpline that you can contact for further advice. The ACAS telephone number is: 0300 123 1100 and the helpline is open Monday to Friday from 8am to 8pm and Saturday from 9am to 1pm.The website can be found here: www.acas.org.uk.
- If you are a member of a recognised trade union, you can also seek information and advice from your trade union representative.
Customer Service Policy
PureTech Talent Ltd is a member of the Recruitment and Employment Confederation (REC) and adheres to their Code of Professional Practice.
PureTech Talent Ltd Customer Service Policy Statement
At PureTech Talent Ltd we endeavour to provide you with the best possible service at all times. If you would like to make any comments, suggestions, raise a query or make a complaint about the service you have received, please contact us, our contact details are set out below. We will respond to your query within 3 – 5 working days.
This policy will be kept up to date, to reflect changes in the nature and size of the business. To ensure this, the policy and its effectiveness will be reviewed annually.
All recruitment consultants will be trained in customer service standards; will exhibit customer friendly service skills; and be knowledgeable, professional and courteous in meeting the needs of our customers.
We PureTech Talent Ltd will return all phone calls and emails received from clients and registered candidates and applications in respect of specific vacancies within agreed timescales. Where we are unable to meet this agreement, we will inform you of this as soon as possible and agree a new deadline.
As part of our commitment to upholding professional standards, we will review our policies annually to ensure that they continue to meet business needs and the Recruitment and Employment Confederation’s Code of Professional Practice; and that they are consistently applied to all our customers.
PureTech Talent Ltd seeks fair, just and prompt solutions when possible to any complaints and appeals. All such issues should be directed to the Director of HR/ Compliance in the first instance, where they will be acknowledged and directed to the attention of the appropriate person. A complaints process is in place for any disputes; copies are available from our offices or on www.puretechtalent.com
Access to Information
We comply fully with the provisions of the Data Protection Act 1998. Any personal or confidential information held by us about a client or work seeker is fully accessible to that person or body for review or editing by contacting the Director of HR and Compliance.
Wherever possible, without compromising our legal requirements and professional standards we strive to reduce the burden of unnecessary paperwork.
How to Contact Us:
Provision of Services Regulations 2009
The Provision of Services Regulations 2009 (the “Regulations”) implement the Services Directive (Directive 2006/123/EC) in the UK. The Regulations came into effect on 28 December 2009.
The Regulations require the Company to make available certain information to service recipients i.e. work-seekers and our clients. We must give you some of this information before we enter into a contract, we must supply other information if you request it.
We will make this information available as follows:
at the place where we provide our services or enter into a contract with you; and/ or
on our website www.puretechtalent.com
Service provider information
PureTech Talent Limited
Company Reg no:10890268
3 Waterhouse Square, 138 – 142 Holborn, London, EC1N 2SW
Vat No: 277 2911 78
Directors: Ken Acar & Jason Sperrin
Registration/ authorisation details
- PureTech Talent Ltd is listed on the following trade or other similar public register:
- Recruitment and Employment Confederation, Corporate Membership no.1063
- PureTech Talent Ltd is subject to authorisation/ licensing by the following authority(ies):
- Employment Agency Standards Inspectorate – http://www.bis.gov.uk/policies/employment-matters/eas
- Information Commissioner’s Office – https://ico.org.uk/
Terms and Conditions of Business
PureTech Talent Ltd provides work-finding services to hirers and work-seekers. We are prohibited from charging work-seekers for those work-finding services. The charges or the method of calculating the charges payable by hirers are set out in our Terms of Business.
The terms on which we contract with hirers and work-seekers are set out in our Terms of Business. Our terms are subject to English law and to the jurisdiction of the English Courts
After-sales guarantee or refunds
We offer refunds to hirers in certain limited circumstances the details of which are set out in our Terms of Business.
Professional liability insurance
We are required to hold professional liability insurance. Details of this are available on request from email@example.com
Code of Conduct
As a member of the Recruitment and Employment Confederation (REC), we are subject to the REC’s Code of Professional Practice which is available here www.rec.uk.com/membership/compliance. The Code is available in English only.
The REC Code of Professional Practice does not offer a non-judicial dispute resolution procedure. It does offer a procedure whereby clients or individuals who have used the services of an REC member can complain about breaches of that Code of Professional Practice by that member.
The REC accepts complaints and queries in regard to the standards of best practice of its corporate members. It is a condition of REC membership that we have in place a Complaints Procedure to deal with complaints. Therefore, before referring a complaint to the REC, we would encourage you to use our Complaints Procedure, a copy of which is available on request.
The REC Professional Standards Team are not able to: –
- investigate the conduct of an agency that is not a member of the REC
- offer legal advice
- intervene to decide disputes of a legal nature, or contractual or commercial disputes, or those driven by competition
- decide disputes between members and their employees or employers,
- instigate a formal complaints procedure whilst any legal, tribunal or court action is ongoing or unresolved.
- suspend or expel a member (this decision can only be made by the Professional Standards Committee)
- make an agency apologise.
Please note: the REC complaints procedure does not deal with compensation in any respect.
PureTech Talent Ltd is committed to providing a high-level service to our customers. If you do not receive satisfaction from us we need you to tell us about it. This will help us to improve our standards.
If you have a complaint, please contact Jason Sperrin, Director by phone 0203 6331609 in the first instance so that we can try to resolve your complaint informally.
At this stage, if you are not satisfied please contact Ken Acar, Director. You can write to him at:
PureTech Talent Ltd
3 Waterhouse Square
- We will send you a letter acknowledging your complaint and asking you to confirm or explain the details set out. We will also let you know the name of the person who will be dealing with your complaint. You can expect to receive our letter within 5 days of us receiving your complaint.
- We will record your complaint in our central register within a day of having received it.
- We will acknowledge your reply to our acknowledgment letter and confirm what will happen next. You can expect to receive our acknowledgement letter within 5 days of your reply.
- We will then start to investigate your complaint. This will normally involve the following steps;
- We may ask the member of staff who dealt with you to reply to your complaint within 5 days of our request;
- We will then examine the member of staff’s reply and the information you have provided for us. If necessary we may ask you to speak to them. This will take up to 4 days from receiving their reply.
- Jason Sperrin will then invite you to meet him to discuss and hopefully resolve your complaint. He will do this within 5 days of the end of our investigation.
- Within 2 days of the meeting Jason Sperrin will write to you to confirm what took place and any solutions he has agreed with you.
- If you do not want a meeting or it is not possible, Jason Sperrin will send you a detailed reply to your complaint. This will include his suggestions for resolving the matter. He will do this within 5 days of completing his investigation.
- At this stage, if you are still not satisfied you can write to the REC, our trade association of which we are a member marked for the attention of the Consultancy and Compliance Team, REC, Dorset House, 1st Floor, 27 – 45 Stamford Street, London, SE1 9NT.
If we have to change any of the time scales above, we will let you know and explain why.
NOTE: In any event, we will comply with any statutory procedures that may relate to your complaint.