Policies

Below are four of our key policies, others are available on request.

ANTI-SLAVERY POLICY
HUMAN RIGHTS POLICY
EMPLOYEE PRIVACY NOTICE
ANTI-BRIBERY POLICY

ANTI-SLAVERY POLICY

Policy Statement

AJ & CI Snell’s Anti-Slavery Policy applies to all employees regardless of seniority or status and will be applied consistently and in a non-discriminatory manner.

AJ & CI Snell strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers will hold their own suppliers to the same high standards.

Our Commitment:

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights.

We shall be a company that expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

We have a zero-tolerance approach to modern slavery in our organisation and our supply chains.
The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy.
We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.
You must notify your manager or Human Resources, as soon as possible if you believe or suspect that a breach of this policy has occurred, or may occur in the future.
You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business at the earliest possible stage.
If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or Human Resources as soon as possible.
If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions constitute any of the various forms of modern slavery, you should raise it with your manager or Human Resources.

Breaches of this policy:

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working for us or on our behalf (including suppliers) if they breach this policy.

HUMAN RIGHTS POLICY

Respect for human rights is fundamental to the sustainability of The Company
and the communities in which we operate. In our Company and across our system, we are
committed to ensuring that people are treated with dignity and respect.
The Company’s Human Rights Policy is guided by international human rights
principles encompassed in the Universal Declaration of Human Rights, the International
Labour Organisation’s Declaration on Fundamental Principles and Rights at Work, the
United Nations Global Compact and the United Nations Guiding Principles on Business
and Human Rights.
The Human Rights Policy applies to The Company, the entities that it owns,
the entities in which it holds a majority interest, and the facilities that it manages.
The Company is committed to working with and encouraging our partners to
uphold the principles in this Policy and to adopt similar policies within their businesses.
The guiding principles apply to our partners and our suppliers and are
aligned with the expectations and commitments of this Policy.
Respect for Human Rights
The Company respects human rights. It is committed to identify, prevent, and
mitigate adverse human rights impacts resulting from or caused by our business activities
before or if they occur through human rights due diligence and mitigation processes.
Community and Stakeholder Engagement
The Company recognises its impact on the communities in which it operates. We are
committed to engaging with stakeholders in those communities to ensure that we are listening
to, learning from and taking into account their views as we conduct our business. Where
appropriate, we are committed to engaging in dialogue with stakeholders on human rights
issues related to our business. We believe that local issues are most appropriately addressed
at the local level. We are also committed to creating economic opportunity and fostering
goodwill in the communities in which we operate through locally relevant initiatives.
Valuing Diversity
The Company values the diversity of the people with whom we work and the contributions
they make. We have a long-standing commitment to equal opportunity and intolerance of
discrimination and harassment. We are dedicated to maintaining workplaces that are free from
discrimination or harassment on the basis of race, sex, colour, national or social origin, religion,
age, disability, sexual orientation, political opinion or any other status protected by applicable
law. The basis for recruitment, hiring, placement, training, compensation and advancement at
the Company is qualifications, performance, skills and experience.
Regardless of personal characteristics or status, the Company does not tolerate disrespectful
or inappropriate behaviour, unfair treatment or retaliation of any kind. Harassment is
unacceptable in the workplace and in any work-related circumstance outside the workplace.
These principles apply not only to Company employees but also to the business partners with
whom we work.
Freedom of Association and Collective Bargaining
The Company respects our employees’ right to join, form or not to join a labour/trade union without
fear of reprisal, intimidation or harassment. Where employees are represented by a legally
recognised union, we are committed to establishing a constructive dialogue with their freely
chosen representatives. The Company is committed to bargaining in good faith with such
representatives.
Safe and Healthy Workplace
The Company provides a safe and healthy workplace and complies with applicable safety
and health laws, regulations and internal requirements. We are dedicated to maintaining a
productive workplace by minimising the risk of accidents, injury and exposure to health risks.
We are committed to engaging with our employees to continually improve health and safety
in our workplaces, including the identification of hazards and remediation of health and
safety issues.
Workplace Security
The Company is committed to maintaining a workplace that is free from violence, harassment,
intimidation and other unsafe or disruptive conditions due to internal and external threats.
Security safeguards for employees are provided as needed and will be maintained with respect
for employee privacy and dignity.
Forced Labour and Human Trafficking
The Company prohibits the use of all forms of forced labour, including prison labour,
indentured labour, bonded labour, military labour, slave labour and any form of human trafficking.
Child Labour
The Company prohibits the hiring of individuals that are under 18 years of age for positions in
which hazardous work is required.
Work Hours, Wages and Benefits
The Company compensates employees competitively relative to the industry and local
labour market. We operate in full compliance with applicable wage, working hours, overtime and
benefits laws.
Guidance and Reporting for Employees
The Company creates workplaces in which open and honest communications
among all employees are valued and respected. The Company is committed to following all
applicable labour and employment laws wherever we operate.
If you believe that a conflict arises between the language of the policy and the laws, customs
and practices of the place where you work, if you have questions about this policy or if you
would like to report a potential violation of this policy, you should raise those questions and
concerns through existing processes, which make every effort to maintain confidentiality.
You may ask questions or report potential violations to your Manager, Human Resources, or the
Senior Management Team. No reprisal or retaliatory action will be taken against any employee for
raising concerns under this policy. The Company is committed to investigating, addressing and
responding to the concerns of employees and to taking appropriate corrective action in
response to any violation.
AJ & CI Snell reserves the right to amend this policy at any time.

EMPLOYEE PRIVACY NOTICE

Data controller: AJ & CI Snell, Pencoyd Court Farm, St. Owens Cross, Hereford

Data protection officer Luke Jones

The organisation collects and processes personal data relating to its employees to manage the employment relationship. The organisation is committed to being transparent about how it collects and uses that data and to meeting its data protection obligations.

What information does the organisation collect?

The organisation collects and processes a range of information about you. This includes:

your name, address and contact details, including email address and telephone number, date of birth and gender;
the terms and conditions of your employment;
details of your qualifications, skills, experience and employment history, including start and end dates, with previous employers and with the organisation;
information about your remuneration, including entitlement to benefits such as pensions or insurance cover;
details of your bank account and national insurance number;
information about your marital status, next of kin, dependants and emergency contacts;
information about your nationality and entitlement to work in the UK;
information about your criminal record;
details of your schedule (days of work and working hours) and attendance at work;
details of periods of leave taken by you, including holiday, sickness absence, family leave and sabbaticals, and the reasons for the leave;
details of any disciplinary or grievance procedures in which you have been involved, including any warnings issued to you and related correspondence;
assessments of your performance, including appraisals, performance reviews and ratings, training you have participated in, performance improvement plans and related correspondence;
information about medical or health conditions, including whether or not you have a disability for which the organisation needs to make reasonable adjustments;
details of trade union membership; and
equal opportunities monitoring information, including information about your ethnic origin, sexual orientation, health and religion or belief.]

The organisation collects this information in a variety of ways. For example, data is collected through application forms, CVs or resumes; obtained from your passport or other identity documents such as your driving licence; from forms completed by you at the start of or during employment; from correspondence with you; or through interviews, meetings or other assessments.

The organisation seeks information from third parties with your consent only.

Data is stored in a range of different places, including in your personnel file, in the organisation's HR management systems and in other IT systems (including the organisation's email system).

Why does the organisation process personal data?

The organisation needs to process data to enter into an employment contract with you and to meet its obligations under your employment contract. For example, it needs to process your data to provide you with an employment contract, to pay you in accordance with your employment contract and to administer pension entitlements.

In some cases, the organisation needs to process data to ensure that it is complying with its legal obligations. For example, it is required to check an employee's entitlement to work in the UK, to deduct tax, to comply with health and safety laws and to enable employees to take periods of leave to which they are entitled.

In other cases, the organisation has a legitimate interest in processing personal data before, during and after the end of the employment relationship. Processing employee data allows the organisation to [list the appropriate points and expand on them as necessary]:

run recruitment and promotion processes;
maintain accurate and up-to-date employment records and contact details (including details of who to contact in the event of an emergency), and records of employee contractual and statutory rights;
operate and keep a record of disciplinary and grievance processes, to ensure acceptable conduct within the workplace;
operate and keep a record of employee performance and related processes, to plan for career development, and for succession planning and workforce management purposes;
operate and keep a record of absence and absence management procedures, to allow effective workforce management and ensure that employees are receiving the pay or other benefits to which they are entitled;
obtain occupational health advice, to ensure that it complies with duties in relation to individuals with disabilities, meet its obligations under health and safety law, and ensure that employees are receiving the pay or other benefits to which they are entitled;
operate and keep a record of other types of leave (including maternity, paternity, adoption, parental and shared parental leave), to allow effective workforce management, to ensure that the organisation complies with duties in relation to leave entitlement, and to ensure that employees are receiving the pay or other benefits to which they are entitled;
ensure effective general HR and business administration;
provide references on request for current or former employees;
respond to and defend against legal claims; and
maintain and promote equality in the workplace.

Where the organisation relies on legitimate interests as a reason for processing data, it has considered whether or not those interests are overridden by the rights and freedoms of employees or workers and has concluded that they are not.

Some special categories of personal data, such as information about health or medical conditions, is processed to carry out employment law obligations (such as those in relation to employees with disabilities and for health and safety purposes).

Where the organisation processes other special categories of personal data, such as information about ethnic origin, sexual orientation, health or religion or belief, this is done for the purposes of equal opportunities monitoring.

Who has access to data?

Your information will be shared internally, including with [members of the HR and recruitment team (including payroll), your line manager, managers in the business area in which you work and IT staff if access to the data is necessary for performance of their roles].

The organisation shares your data with third parties in order to obtain pre-employment references from other employers, obtain employment background checks from third-party providers and obtain necessary criminal records checks from the Disclosure and Barring Service. The organisation may also share your data with third parties in the context of a sale of some or all of its business. In those circumstances the data will be subject to confidentiality arrangements.

The organisation also shares your data with third parties that process data on its behalf [, in connection with payroll, the provision of benefits and the provision of occupational health services, eg Pension provider Now Pensions].

The organisation will not transfer your data to countries outside the European Economic Area.

How does the organisation protect data?

The organisation takes the security of your data seriously. The organisation has internal policies and controls in place to try to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by its employees in the performance of their duties.

Where the organisation engages third parties to process personal data on its behalf, they do so on the basis of written instructions, are under a duty of confidentiality and are obliged to implement appropriate technical and organisational measures to ensure the security of data.

For how long does the organisation keep data?

The organisation will hold your personal data for [the duration of your employment]. The periods for which your data is held after the end of employment are [set out relevant retention periods which will be at least 3 years in order to cater for HMRC enquiries, but might be 6 years in order to deal with any contract claims].

Your rights

As a data subject, you have a number of rights. You can:

access and obtain a copy of your data on request;
require the organisation to change incorrect or incomplete data;
require the organisation to delete or stop processing certain parts your data, for example where the data is no longer necessary for the purposes of processing;
object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing; and
ask the organisation to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the organisation's legitimate grounds for processing data.

If you would like to exercise any of these rights, please contact HR manager or the Data Protection Officer

If you believe that the organisation has not complied with your data protection rights, you can complain to the Information Commissioner.

What if you do not provide personal data?

You have some obligations under your employment contract to provide the organisation with data. In particular, you are required to report absences from work and may be required to provide information about disciplinary or other matters under the implied duty of good faith. You may also have to provide the organisation with data in order to exercise your statutory rights, such as in relation to statutory leave entitlements. Failing to provide the data may mean that you are unable to exercise your statutory rights.

Certain information, such as contact details, your right to work in the UK and payment details, have to be provided to enable the organisation to enter a contract of employment with you. If you do not provide other information, this will hinder the organisation's ability to administer the rights and obligations arising as a result of the employment relationship efficiently.

Automated decision-making

Employment decisions are not based solely on automated decision-making.

ANTI-BRIBERY POLICY

Introduction

One of the Company’s core values is to uphold responsible and fair business practices. 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 implementing and enforcing effective systems to counter bribery.

Purpose and scope of policy

This policy sets out the Company’s position on any form of bribery and corruption and provides guidelines 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 employees and persons associated with the Company 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.

This policy applies to all permanent and temporary employees of the Company (including any of its intermediaries, subsidiaries or associated companies). It also applies to any individual or corporate entity associated with the Company or who performs functions in relation to, or for and on behalf of, the Company, including, but not limited to, directors, agency workers, casual workers, contractors, consultants, seconded staff, agents, suppliers and sponsors (“associated persons”). All employees and associated persons are expected to adhere to the principles set out in this policy.

Legal obligations

The UK legislation on which this policy is based is the Bribery Act 2010 and it applies to the Company’s conduct both in the UK and abroad. A bribe is an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage.

It is an offence in the UK to:

offer, promise or give a financial or other advantage to another person (i.e. bribe a person), whether within the UK or abroad, with the intention of inducing or rewarding improper conduct
request, agree to receive or accept a financial or other advantage (i.e. receive a bribe) for or in relation to improper conduct
bribe a foreign public official.

You can be held personally liable for any such offence.

It is also an offence in the UK for an employee or an associated person to bribe another person in the course of doing business intending either to obtain or retain business, or to obtain or retain an advantage in the conduct of business, for the Company. The Company can be liable for this offence where it has failed to prevent such bribery by associated persons. As well as an unlimited fine, it could suffer substantial reputational damage.

Policy statement

All employees and associated persons are required to:

comply with any anti-bribery and anti-corruption legislation that applies in any jurisdiction in any part of the world in which they might be expected to conduct business
act honestly, responsibly and with integrity
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.

The Company recognises that industry practices may vary from country to country or from culture to culture. What is considered unacceptable in one place may be normal or usual practice in another. Nevertheless, a strict adherence to the guidelines set out in this policy is expected of all employees and associated persons at all times. If in doubt as to what might amount to bribery or what might constitute a breach of this Policy, refer the matter to your line manager or to the Company’s Anti-Corruption Officer.

For the Company’s rules and procedures in relation to the receipt of business gifts from third parties and corporate hospitality offered to or received from third parties, please refer to the Company’s gifts from clients/suppliers policy and its corporate hospitality policy. They form part of the Company’s zero tolerance policy towards bribery and they should be read in conjunction with this policy.

The giving of business gifts to clients, customers, contractors and suppliers is not prohibited 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.

Responsibilities and reporting procedure

It is the contractual duty and responsibility of all employees and associated persons to take whatever reasonable steps are necessary to ensure compliance with this policy and to prevent, detect and report any suspected bribery or corruption in accordance with the procedure set out in the Company’s whistleblowing policy. You must immediately disclose to the Company any knowledge or suspicion you may have that you, or any other employee or associated person, has plans to offer, promise or give a bribe or to request, agree to receive or accept a bribe in connection with the business of the Company. For the avoidance of doubt, this includes reporting your own wrongdoing. The duty to prevent, detect and report any incident of bribery and any potential risks rests not only with the directors of the Company but applies equally to all employees and associated persons.

The Company encourages all employees and associated persons to be vigilant and to report any unlawful conduct, suspicions or concerns promptly and without undue delay so that investigation may proceed and any action can be taken expeditiously. In the event that you wish to report an instance or suspected instance of bribery, you should follow the steps set out in the Company’s whistleblowing policy. Confidentiality will be maintained during the investigation to the extent that this is practical and appropriate in the circumstances. The Company is committed to taking appropriate action against bribery and corruption. This could 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 support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. It 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.

Record keeping

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.

Sanctions for breach

A breach of any of the provisions of this policy 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 employee liable to summary dismissal.

As far as associated persons are concerned, a breach of this policy could lead to the suspension or termination of any relevant contract, sub-contract or other agreement.

Monitoring compliance

The Company’s Anti-Corruption Officer has lead responsibility for ensuring compliance with this policy and will review its contents on a regular basis. They 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.

Training

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.

Examples of potential risks

The following is a non-exhaustive list of possible issues which raise bribery concerns and which you should report in accordance with the reporting procedure set out above:

a third party insists on receiving a commission or fee before committing to signing a contract with the Company, or carrying out a government function or process for the Company
a third party requests payment in cash, or refuses to sign a formal commission or fee agreement, or to provide an invoice or receipt for a payment made
a third party requests an unexpected additional commission or fee to facilitate a service
a third party demands lavish, extraordinary or excessive gifts or hospitality before commencing or continuing contractual negotiations or provision of services
you are offered an unusually lavish, extraordinary or excessive gift or hospitality by a third party
you receive an invoice from a third party that appears to be non-standard or extraordinary
the Company is invoiced for a commission or fee payment that appears large given the service stated to have been provided.