What Responsible Procurement means to us

This document states our positive intentions with our suppliers, purchase decisions and future targets.

We are keenly aware that what we design often has to be sourced, manufactured, delivered and installed on behalf of our clients. These five processes all have a social, environmental and economic impact. Our aim through the creation of this policy document is to lessen our impact and uphold a fair and responsible process throughout all of our business procurement processes.

This is our policy for Responsible Procurement. Many of the active and positive unwritten policies are already embedded in Double Retail which we will explicitly note later.

“In summary, Responsible Procurement is the act of procuring goods, services, or works in a manner that is considerate of the impact, both positive and negative, that the University may have on the environment, the economy, and society in general”

Environmental considerations

As a business overview we often project manage the sourcing with external manufacturers and construction of many of our designs on behalf of our clients. The build* of our designs falls into the following categories;

1. Retail fixtures - made from multiple materials and often sourced multiple suppliers including their packaging for transport.

2. Store interior construction - site works carried out by a third-party Main Contractor that include;

   • Mechanical and electrical works

   • Heating and ventilation works

   • Shell construction - floors, walls, staff comfort, store rooms and offices

   • Store front - including signage and windows. Also including temporary shuttering and signage prior to store opening

   • Lighting

3. Waste removal and recycling

4. Deliveries - from supplier to supplier and finished goods and materials to the store or distribution centres.

5. Installation - installers and Double Retail staff, their materials and associated travel and accommodation.

*Build – The manufacture, delivery and installation of fixtures and fittings into a retail space or environment

We recognise that all of the activities above have an environmental impact and wherever possible we will look to reduce our impact through better environmental consideration through all of our design service and sourcing phases. We also recognise that to reduce our environmental impact we will, wherever feasible, source locally to the intended point of use and manufacture with considered material choices and deliver responsibly.

To do this effectively we will collaborate with our suppliers and clients and adhere to our Responsible Design Principles.

We will use our best judgement to consider the final destination of products in our supplier selection to reduce material, waste and transport impacts.

Socially considerate

We have a long-standing commitment to our core suppliers located locally to our offices in Bristol. We will favour their supply and balance this with the final intended destination of the goods to ensure our ongoing commitment to them as partners and the adverse impacts of their distance from the final intended destination of the products and associated transport impacts.

All of our suppliers have been screened, whether or not already done so by our clients directly. We ensure they meet our Code of Conduct standards [please refer to our Code of Conduct document for details]

We visit all of our main suppliers through our selection process to ensure the validity of our assessments. Our commitment to our clients - at all times Double and our suppliers will;

• Comply with the requirements of the Modern Slavery Act.

• Be compliant with all local employment laws and respect employment diversity.

• Understand the impact that our procurement decisions to suppliers and their staff & community.

Economic considerations

As a founding business principal, we have put payment on time as a primary goal of our business.

Wherever possible we will follow these payment principals to our suppliers;

• Payment terms are always discussed and never assumed so that mutual understanding of ours and our suppliers’ financial needs are clearly understood and mutually agreed.

• Once payment terms are agreed by all parties then Double will meet these terms and if, for whatever reason, we need to delay payment beyond the agreed terms we will contact the affected suppliers to agree new mutually beneficial arrangements.

• Wherever possible we will offer EU standard payment 30 days terms or better.

• We recognise that some SME’s and sole traders require special consideration and wherever appropriate we will make immediate payment or within 15 days wherever possible.

Future targets

We will actively engage and look to influence other tenants in our shared building to engage in positive action on Responsible Procurement principles.

We will look to influence our suppliers, clients and business community to engage in positive change through Responsible Procurement principles.

At Double, we are on a mission to Design Better.

Through the work that we do we want to inspire better ways of working, better working environments, better development opportunities for all, better business practices, better creative projects and better relationships. We have worked hard to teach ourselves what better means and through this site, we want to share what we have learned with the world.

We believe that knowledge, shared knowledge, is power. It gives everyone the power to build better businesses with stronger, more resilient, more engaged communities around them.

Take a look around our Company. See how we work, what we believe in and the changes that we’ve made to Design Better. And of course, feel free to share new thoughts and ideas with us. Our collective skills, talents and strengths will create our future.

Thank you!

Introduction

At Double, we deeply value the relationships we have with the people we work with and consider many of our clients and suppliers to be part of our wider team. These relationships are built on trust and honesty so committing to having open conversations and regularly engaging with those involved is extremely important to us. To create the most positive impact from our business together, it is crucial for us to understand our different needs and expectations and to monitor the changing material issues we each have. For this reason, we actively seek to engage our stakeholders in our business purpose, to make process changes and decisions together, that will incrementally improve our work.

Our mission is to design better ways of working and better built environments that affect positive change within our industry. We measure our success through the eyes of our stakeholders through regular consultation and feedback.

We consider our stakeholders to be our internal team and their families, our client teams and their customers for whom we design and build spaces, our supplier and partner teams who provide materials, goods and services to us and the communities around us, both locally and internationally.

The purpose of this policy is to formally document and outline Double’s commitment and approach to inclusive stakeholder engagement.

Statement of Commitment

As a responsible business, Double is committed to:

• Engaging our stakeholders to develop and maintain positive and productive relationships.

• Ensuring key stakeholders are well informed and have access to information about our business and our activities.

• Involving our stakeholders in identifying issues which are material to our business.

• Implementing initiatives and programmes that contribute to sustainable development and generate shared value.

• Monitoring our stakeholder engagement process and continually identifying areas for improvement.

Objectives of Engagement

• Collaborating with stakeholders to identify emerging issues and develop solutions to these and future challenges.

• Ensuring that our business activities meet our stakeholders’ needs.

• Identifying material issues in a collaborative way to create value for Double and our stakeholders.

• Assessing and creating wider community support for Double and our work.

• Continuing communication with stakeholders across all areas of our business.

Stakeholder Engagement Process

Our stakeholder engagement process requires us to identify and prioritise material issues with every appropriate stakeholder. Ongoing engagement is achieved through a number of different channels. These may include:

Implementation and Evaluation

To be effective in our stakeholder engagement we need to be aware of potential risks. We always consider potential stakeholder engagement risks prior to selecting the level or method of engagement. Potential risks will include conflicts of views and interest, and engagement challenges.

Our internal team monitor and evaluate the application of engagement across our business and ensures that our stakeholders are engaged on all issues identified as material.

Our Board of Directors is responsible for the operation of this policy and the board is regularly briefed on stakeholder engagement activities and progress.

What we continue to do.

Source 100% of our energy from a ‘clean’ renewables energy provider

Light our office using 100% low energy LED lighting

Have low power management set as default across all computers, servers and other appliances

Responsibly source all consumables for our working environment:

• 100% recycled paper / paper towels 100% recovered fibre and FSC accredited

• Local ethical coffee beans

• Fairtrade tea

• Organic locally sourced milk

• Ecologically sound cleaning products

Recycle all printer toner cartridges, plastic bags, polystyrene, plastics, card, metals and food waste appropriately.

So far this year we have we have.

Encouraged low carbon commuting through a low carbon commuting incentive and have reduced our emissions by 25%

Started to track all energy use within our office

Started to track all direct transportation emissions

Followed and shared our Responsible Design Principles

Engaged in talks to our industry and local educators to spread what we are doing

Written articles about our sustainability efforts and shared with our clients, suppliers and our wider community

Gifted to charity or schools all usable furniture, lighting and electrical items and recycled all remaining obsolete office fixtures and fittings through approved free or paid schemes.

Started a office building tenant sustainability team with other businesses to tackle energy, water and waste efficiencies within our shared building

Environmental goals that are in sight.

Monitor our green house emissions (scope 1 & 2, start to calculate scope 3 emissions)

• Set Energy use reduction targets within our office

• Calculate embodied carbon for 25% projects 2019-20

Offset 100% our GHG emissions (scope 1 & 2) year on year

Offset 25% of calculated project emissions in 2019-20, to be increased to 100% over the coming years

Monitor our water usage

Reduce our office waste output - monitor and set reduction targets

Encouraging and working with our supply chain to implement sustainable policies into their businesses.

Work towards creating an on-boarding process for current and future suppliers and partners that assess their approach to sustainability, governance and community

Looking ahead.

We will continue to explore ways we can operate in a fully circular economic model

How we practice design and build.

At Double we have developed a series of 9 sustainable design principles. We aim to apply these principles to everything we work on alongside the measurable factors of a project’s life cycle.

These principles enable us to design in a more considered and responsible way, addressing the impact of our work at every life cycle stage.

Principle 1: Start with a sustainability target.

Greater transparency leads to better decisions, and setting a sustainability target with a logical breakdown of considerations will give focus to your project goals.

Keep goals measurable and manageable.

Principle 2: Test your material claims.

Sustainability jargon is rife within industry and we should take responsibility to exercise due diligence in verifying the claims made by suppliers.

Ask more questions of your suppliers.

Principle 3: Make informed design decisions.

Looking at the bigger picture and considering the wider influences on design such as material sizing, energy processes, and material sourcing drive positive impact.

Design for purpose, not promise.

Principle 4: Reduce energy intensive processes.

Consider the quantity and locations of processes required in the manufacture and finishing of goods.

Streamline production from point A to point B.

Principle 5: Consider transportation.

Design can account for transportation by considering how to reduce the physical footprint of a product before it requires assembly.

Avoid transporting costly volumes of air.

Principle 6: Never work in a bubble.

Your partners and suppliers bring specific knowledge to the table. The broader your resources, the more knowledge gets shared.

Engage with experts to make better project decisions.

Principle 7: Keep materials separable.

The construction and ease of separation of every material type and fixing, should be simplified to encourage cost and time efficient recycling.

Consider the sum of the parts, not the whole.

Principle 8: Design waste out.

Maximising the use of purchased raw materials in their delivered state will minimise excess waste on final assembly.

Be resourceful with your materials.

Principle 9: Aim for reuse ahead of recycling.

Consider an item’s future beyond the initial brief to increase its chances of re-use. Items that are adaptable to other purposes can find their way into other commercial or residential opportunities.

Always see reuse as the first priority.

© Double Retail Ltd. All rights reserved

Double is designing better

• Reducing the environmental impact of and influencing change within our industry

• Valuing respectful relationships, creating a happy and supportive work environment, inspiring better ways of working together.

• Building a financially secure and responsible future for our Double community.

Introduction

Welcome to Double Retail Limited's privacy notice.

Double Retail Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and when you engage us as a client for our services and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively if you would like a PDF version of the Notice, please contact one of the team.

Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. Important information and who we are

2. The data we collect about you

3. How is your personal data collected

4. How we use your personal data

5. Disclosures of your personal data

6. International transfers

7. Data security

8. Data retention

9. Your legal rights

10. Glossary

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Double Retail Limited may collect and process personal data through your use of this website and our services.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.

Controller

Double Retail Limited is the controller and responsible for your personal data (collectively referred to as "Double Retail", "we", "us" or "our" in this privacy notice).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Our full details are: Full name of legal entity: Double Retail Limited Name or title of DPO: Laura Templeton-Cox Email address: hello@doubleretail.com Postal address: Double Retail Limited, 1 Brunswick Square, Bristol BS2 8PE

Telephone number: +44 1173 706 600

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 16th January 2020. The data protection law in the UK changed on 25th May 2018. This privacy notice sets your rights under the new laws.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

• Contact Data includes billing address, delivery address, email address and telephone numbers.

• Financial Data includes bank account and payment card details.

• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

• Property Information includes property address and description.

• Usage Data includes information about how you use our website, products and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • Apply for our products or services;

  • Subscribe to our service or publications;

  • Request marketing to be sent to you; or

  • Give us some feedback

• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookies Policy for further details.

• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

  • Technical Data from the following parties:

    • (a) analytics providers such as Google based outside the EU;

    • (b) search information providers such as Experian based inside the EU.

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as TNT based inside the EU and Oak International Ltd based inside the EU.

  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation. Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside the Double Retail group for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service or other transactions supplied to you.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

• External Third Parties as set out in the Glossary; and

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

To assist us with various aspects of our business, Double Retail uses the following third party companies who are based outside of the EEA:

• MailChimp (who are based in the US), in respect of email marketing campaigns and newsletters;

• Wrike (who are based in the US), in respect of project and business task-based project management support;

• Smartsheet (who are based in in the US), in respect of work process project management support;

• Xero (who are based in New Zealand), in respect of financial and accounting software and compliance, and as such we may transfer personal data outside of the European Economic Area (‘EEA’).

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.

• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

THIRD PARTIES

External Third Parties

• Service providers acting as processors based both in the United Kingdom, Europe and outside of the EEA who provide IT and system administration services.

• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, insurers and project managers based in the UK and Europe who provide consultancy, banking, legal, insurance and accounting services.

• HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

Last Updated: January 2020

Founded in 2009, Double is a design business working with international clients to design, engineer and build retail and commercial environments that express brand values within a physical space. We exist to shape the future of the design and build industry, to ensure we all thrive and grow while taking responsibility for the social and environmental impact of our work. We strive for a future where each and every newly built environment has a positive purpose at its core, where environmental impact is lowered or regenerative, and its very existence must create benefit beyond financial profit alone.

The commercial design industry can be enormously wasteful. The burden on the environment through the extraction and use of materials, manufacturing processes and throw-away culture needs to be improved. Our ultimate goal is to change our industry to one that chooses a circular design path for all its design and build projects. Through our design and operational processes, we aim to widen the lens through which brands, retailers and suppliers to the industry perceive the impact of the design and build process.

Working with trust, mutual respect and freedom, our self-managing team have the power to positively evolve the business together. By recognising that our strength and future sustainability will come from developing our individual skills and taking time to educate others, we help influence and effect change across our business and our industry.

Through the collective awareness of our team, we have made a conscious decision to commit our business to social and environmental measures. All of our energy now comes from renewable sources, we set annual energy reduction targets and have moved all of our office supplies to responsible suppliers. We are committed to ensuring the profit we make is fair for both our business and our wider community of stakeholders. We commit to giving a portion of our time and revenue to charitable causes and any investments we make are done so consciously, to provide improvements in our business footprint.

We are by no means perfect, but we strongly believe in doing our part for our planet, our people and to use our business to affect positive change.

Ethical and responsible relationships

Double was started in 2009 to encourage employees to build better relationships with clients, suppliers, and ultimately, each other. Through our design and working processes, we aim to shift the way in which brands, retailers and suppliers perceive the impact of their actions on the environment.

Our vision is to change an industry that blindly designs, uses and wastes resources, and operates with wilful ignorance*, to one that understands and chooses a circular design path for all of its retail design and build projects. Shaping the future of retail to one where each and every newly built environment reduces the impact on people and planet.

Double operates by self-managing principles where all staff are treated as equals and we treat each other with respect and fairness. In our daily working relationships, we expect our suppliers to uphold this understanding of equality, respect and fairness regardless of our colleagues age, gender or other orientation and belief.

With our vision in mind we recognise that through our work, we work with many suppliers and factories. We respect that all of our business partners are operated with their own frameworks and codes of conduct. This document is intended as a checkpoint to ensure your business meets Double Retail's ethical and responsibility standards. We kindly request that you read, acknowledge receipt and share this document with your workforce on an open access source for all company employees to see**.

'* Wilful Ignorance - The practice or act of intentional and blatant avoidance, disregard or disagreement with facts, empirical evidence and well-founded arguments because they oppose or contradict your own existing personal beliefs.

'** Please translate to your local language if needed for your workforce

Our principles

1. Fairness & equality – we treat all people equally, fairly and with dignity. We do not accept physical, psychological or verbal force to be used.

2. Legal and ethical business – we operate, at all times, within the law.

3. Child/juvenile labour – we say no to this. No exceptions.

4. Forced labour – forced, indentured, bonded or any form of slave or human trafficked labour will not be used.

5. Wages & benefits – All workers will receive fair compensation at a rate that allows some discretionary income and reasonable prosperity.

6. Hours of work – We recognise that all workers shall not exceed 48 hours a week unless they agree, without coercion, in extreme circumstances.

7. Freedom of Association* and collective bargaining will be allowed.

8. Non-discrimination – workers will not be discriminated against in any way.

9. Women’s rights – all women will be treated with equality of opportunity, remuneration and are never discriminated against prior to, during and post pregnancy.

10. The environment – all suppliers must operate within and comply with local environmental laws and expected Double Retail standards.

'* Wikipedia - Freedom of Association - 'encompasses both an individual's right to join or leave groups voluntarily, the right of the group to take collective action to pursue the interests of its members, and the right of an association to accept or decline membership based on certain criteria'.

Fair and achievable

This Code of Conduct applies to all of Double Retail suppliers and their sub-contractors or any other person or organisation involved in supplying goods to Double Retail. We have written the code to be fair, achievable, and easy to check, and to promote the ongoing development of our beneficial relationship.

We require all suppliers to have read and acknowledged our code of conduct before we place orders with you.

Legal & ethical business

At all times you must meet the legal standards and requirements of the countries in which you are working.

Manufacturing Processes

You are reminded all premises involved in manufacture are subject to your local legal standards. This includes premises used by subcontractors* and dormitory accommodation.

Sub-contracting and home-working must be declared and have our written permission.

'* A subcontractor is a secondary business which supplies the company with goods integral to and used for the production of the Company's goods.

Monitoring and inspection

You are responsible for making sure that everyone in your supply chain knows about and complies with this Code of Conduct.

• You must keep records to show that you are carrying out regular reviews and checks.

• Our staff or representatives may visit your factory without warning to carry out inspections.

• You must provide all information requested by Double Retail to confirm compliance to the code. We will keep this information confidential*

'* As part of our commitment to be a better and beneficial business we share this Code of Conduct with the public and indicate the percentage of our suppliers that have signed and agreed to its principles.

Non-Compliance

If you are unable to comply with any parts of the code, please contact Double Retail to give reason for failure and timescale to meet standards. We will work with you to correct the non-compliance.

The following sections of our Code of Conduct expand the context of our principles.

Workers’ rights

We insist employment is freely chosen and there is no forced, bonded or involuntary prison labour*.

We also insist your workers are not required to lodge “deposits” or their identity papers with you as an employer and are free to leave their employment after reasonable notice.

Companies must respect the principles of the Universal Declaration of Human Rights, the United Nations Convention on the Rights of the Child and the United Nations Convention to Eliminate All Forms of Discrimination against Women.

'* FORCED or BONDED - All work or service extracted from any person under menace of any penalty for which said person has not offered him/herself voluntarily or for which such work is demanded as a means of repayment of debt.

Other workers’ rights we expect from you as our supplier;

• Freedom of association and right to collective bargaining are respected.

• Workers, without distinction, have the right to join or form trade unions of their own choosing.

• The employer adopts an open attitude towards the activities of trade unions and their organisational activities.

• Workers representatives are not discriminated against and have access to carry out their representative functions in the workplace.

• Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent, free association and bargaining.

• A safe and hygienic environment shall be provided, bearing in mind prevailing knowledge of the industry and any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.

• Workers shall receive regular recorded health and safety training and the training shall be repeated for new or reassigned workers.

• Access to clean toilet facilities and to safe drinking water, and if appropriate, sanitary facilities for food storage shall be provided.

• Accommodation where provided, shall be clean, safe and meet basic needs of workers.

• The company observing the Code shall assign responsibility for health and safety to a senior management representative.

• The company must have a waste management policy and procedure, so waste is minimised; is correctly and safely handled, stored and disposed; is not a hazard to the environment or if subsequently used; and is recycled where possible.

Child labour

We define a child as any person less than 15 years of age unless local minimum age law stipulates a higher age for work or mandatory schooling, in which case the higher age shall apply. If however, local minimum age law is set at 14 years of age in accordance with developing country exceptions under ILO Convention No. 138, the lower will apply

There shall be no recruitment of child labour*;

• Companies should develop, participate and contribute to policies and programmes, which provide remediation of any child, found to be performing labour to enable them to attend and remain in quality education until no longer a child.

• Children and young workers** under 18 shall not be employed at night or in hazardous conditions.

• These policies and procedures shall conform to the provisions of the relevant ILO (International Labour Organisation) standards.

'* Child Labour - Any work by a child or young person younger than the age(s) specified in the text, which does not comply with the provisions of the relevant ILO standards, and any work that is likely to be hazardous or to interfere with the child's or young person's education, or to be harmful to the child's or young person's health or physical, mental, spiritual, moral or social development.

'** Young worker - any worker over the age of a child as defined above and under the age of 18

A living wage and fair place to work

Wages and benefits paid for a standard working week meet, at a minimum, national legal standards, but preferably take into account and pay at an industry benchmark standard. In any event wages should always be enough to meet basic needs and to provide some discretionary income.

All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about particulars of their wages for the pay period concerned each time that they are paid.

Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned.

All disciplinary measures should be recorded.

Working hours are not excessive

Working hours need to comply with national laws and benchmark industry standards whichever affords greater protection; In any event workers shall not, on a regular basis, be required to work in excess of 48 hours per week and shall be provided with at least one day off for every 7-day period on average.

Overtime shall be voluntary, shall not exceed 12 hours per week, shall not be demanded on a regular basis.

Equality

There should be no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.

Regular employment is provided to every extent possible and work performed must be on the basis of recognised employment relationship established through national law and practice.

Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, sub-contracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through excessive use of fixed-term contracts of employment.

All workers must be validated for their legal right to work by reviewing original documentation. The company should implement procedures to demonstrate compliance. This code of conduct also applies to agency staff and immigrant workers.

No harsh or inhumane treatment is allowed

Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.

I agree to Double Retail’s Code of Conduct

The provisions of this code constitute minimum and not maximum standards.

The code should not be used to prevent companies from exceeding these standards. Companies applying this code are expected to comply with national and other applicable law and where the provisions of law and this code address the same subject, to apply that provision which affords greater protection.

As a supplier to Double Retail you have read and understand the expectations of Double Retail Code of Conduct and acknowledge that you abide by these expectations.

You further understand that failure to abide by these expectations may result in punitive action up to and including termination of the business relationship.

Last Updated February 2020

The structure of our business is the result of a lot of experimenting and a belief in designing better ways of working together. We are a self-managing team which provides an equal platform for the generation and implementation of ideas and innovation. Everyone has their individual skills and responsibilities and we come together to provide collective strength for the business.

We regularly meet, usually on a monthly basis, to discuss business-wide strategic topics including financial decisions, recruitment, marketing, sales, reward and recognition, wellbeing and business vision. We encourage everyone to be involved and to share thoughts and ideas. When decisions need to be taken that effect the whole team, we operate a consensus decision making process. This ensures everyone’s voice is heard and we reach the best decision for Double.

We have worked hard to create easy to use project processes. These balance information sharing and communication to allow visibility of work across the business without duplication of tasks and responsibilities.

Communication is key. As long as we are all talking, listening and sharing, we’re going to provide great service to our clients and suppliers and create a happy and supportive place to work.

May we take this opportunity to welcome you to the Double team. We hope your time with Double will be both enjoyable and rewarding. In everything you do, we encourage you to bring your best and be yourself. Our differences, our skills and our talents make Double the place it is. The team bring our culture to life and help inspire each other to grow and develop.

It is important for us to communicate regularly, on our projects, our roles, the financial health of the business and our wellbeing as a team. We look to you to share your views and ideas and help make Double be a great business to be a part of.

Common interests bring us together, the outdoors, popular culture, technology, travel, food and music. We don’t seek to be different in our culture for differences sake. We believe in empathy, trust, creativity and honesty. Our workspace is relaxed and our appetite for change means that our ways of working are open to change to keep our world fresh.

It is our firm intention that all team members should have equal opportunities to advance in their roles, gain access to support and training they require and be rewarded irrespective of sex, race, colour, gender, religion, sexual orientation or age. Our Company Handbook describes our culture, ways of working and general practices and provides details of our policies and procedures. If you need any further information or help in any way, do not hesitate to ask any member of the team. We are all more than happy to help.

Your induction programme is designed to help you settle in quickly and effectively. From spending time with your new colleagues to receiving information on the company and current projects, we hope that by the end of the first few weeks at Double, you feel at home.

There will be a number of courses that we will ask you to take as these form part of our compliance processes. These include fire safety, health and safety, and GDPR certifications.

From time to time your personal circumstances may change.

To help us assist you in your employment, we require that all information on your personnel records is kept up to date so please let us know if there are any changes in your personal circumstances, including changes of;

• Address and telephone number

• Name

• Next of Kin

• Rights to Work

Your personal information is classified as confidential and held in line with our privacy policy.

The first period of your employment with Double will be a probationary period during which your conduct, suitability and capability to fulfil your role will be monitored. The duration of the probation period will be detailed in your Employment Contract.

A member of the team will ensure that you have clarity of your role and objectives within this period and beyond through informal day-to-day discussions.

During this time, we welcome any feedback from you and will meet with you regularly to evaluate your learnings and provide any feedback from the team.

At the end of your probationary period, we will discuss whether you wish to remain working with us and either confirm your employment with Double in the successful completion of the probationary period or provide feedback to extend this period or terminate your employment.

At any time during or at the end of the probationary period (other than in case of gross misconduct where no notice or pay in lieu of notice is due), Double may terminate your employment, giving you one week’s written notice and we would ask that you provide the same.

We have a set of values that we do our best to live and work by. They help to remind us of what is important to our business and our working life.

Foster the culture of learning.

We believe that deepening of knowledge is vital to constantly improving our business, our processes and our ways of working. We actively encourage each other to explore and share ideas and insight and to build and develop our skill sets.

Strive to make it better.

We are always looking to improve our business, to experiment, innovate and implement newness.

Have honest conversations with open minds.

By having confidence to share your view, by treating each other with empathy and learning to listen, our world becomes clearer and we can work together with a greater understanding of our strengths.

Understand that even the smallest actions build trust.

To allow us to work freely and independently, yet closely together, trust is everything. It can be built upon all the time and should be treated with great care and respect. Trust, and the relationships that we’ve built with it, is what makes Double what it is today.

Company health and safety policy statement

We firmly believe that adequate provisions for health and safety are essential to working life. The maintenance of healthy and safe working conditions and the prevention of injuries and losses are not only of vital importance to the Company’s efficiency and success, but also in the best interests of all our employees and their families.

We therefore aim to ensure that all employees are fully aware of their responsibility for safety and of the safety rules which are relevant to their own jobs. We will provide up to date information about health and safety issues at work.

Please refer to our Health and Safety Policy and Risk Assessment for more information.

First Aid Provision

We currently have two trained first-aiders at Double who are Ellie Stopher and Dave Corke. Both are trained to perform emergency life-saving first aid and have knowledge of workplace health and safety regulations covering:

• Adult resucitation (CPR)

• Burns and scolds

• Choking adult

• Communication and casualty care

• Defibrillator prompts and how to respond (theory based)

• Defibrillator pad placement (theory based)

• Minor and severe bleeding

• Role of the first aider (including knowledge of health and safety regulations)

• Seizures

• Shock

• Unresponsive adult

We also have a trained mental health first aider, Georgia Williams. Should you have concerns relating to either your own or another member of staff's mental health or would like to know where to go for further advice, please speak to Georgia.

You are a valuable part of the team; your attendance is important to the business and is therefore monitored. If you are unable to work for any reason, we ask that you inform the team by 9am on the morning of your absence and that it is logged on our internal system.

Following the completion of your probationary period, and on the understanding that you have complied with the Company’s absence procedures, you will be entitled to receive full pay for the first 10 days of any sickness absence in any rolling 12-month period.

If you are absent due to sickness or injury for a period or periods in excess of your maximum entitlement, you are entitled to Statutory Sick Pay which will be paid in line with the statutory requirements.

Return to work discussions

When you return to work from any absence (excluding holidays) we may hold a discussion with you on the first day of your return to work or as soon as reasonably practicable after that, in order to ensure your smooth integration back to work.

Please refer to our Sickness Absence Policy for more information including the Company’s absence procedures.

Payment of salary

Salary is paid in arrears on the closest working day to 25th of each month. Salary is paid directly into your bank or building society account and an itemised pay statement showing gross earnings, fixed and variable deductions and net salary will be emailed to you at the time of each salary payment. Your starting salary is that stated in your written contract of employment.

Your salary will be reviewed on an annual basis and may be increased from time to time without affecting the other terms of your employment. We will let you know in writing of any subsequent changes to your salary. There is no obligation for the Company to review your salary after notice has been given.

Pension

Upon joining Double, each Employee is automatically enrolled into the company pension scheme, subject to satisfying certain auto-enrolment criteria and the rules of the Scheme.

Based on your joining and contributing a minimum of 5% of your gross salary to the scheme (which can be done by salary sacrifice), Double will also automatically contribute 5% of your gross salary (excluding bonuses) to your pension fund.

Employees have the option to opt-out of the scheme at any time. In this situation, the Company pension contributions will also cease.

A sustainable Investment option for your pension fund is also available through the Company Pension Scheme.

Full details of the Scheme are available from Laura Templeton-Cox.

Hours of work

Your normal hours of work are those agreed in your Contract of Employment however there is an element of flexibility based on workload and personal requirements. Depending on the demands on the business, the way you work these hours or the number of hours you work may be changed. More detail on this can be found under the Flexible Working section of the handbook.

If you would like to discuss any personal circumstances surrounding your working hours, please ask a Company Director.

Overtime

From time to time, you may be required to work overtime and we hope that everyone in the team will be willing to do so. Overtime is not paid, but each individual case is reviewed and time off in-lieu may be offered as an alternative.

Expenses

Sometimes you may incur costs that are related to company business such as travel costs, hotels, or subsistence. You are entitled to be repaid all company related expenses properly and reasonably incurred by you in or about the performance of your duties as an employee of Double. We ask that you submit your expense requests on a monthly basis, providing the required receipts.

Payments for all approved expenses will be paid directly into your bank or building society account during the following month.

Please refer to our Expenses Policy for full details.

Cycle to Work Scheme

All employees are entitled to take part in the Cycle to Work Scheme after completion of their probationary period.

This employee benefit enables you to get a new bike and accessories without paying anything upfront. Double purchase the bike for you and hire it back to you. Payments are then taken tax efficiently from your salary each month for a period of time by salary sacrifice in order for you to buy the bike back.

For more information, please contact Laura Templeton-Cox.

Benefits for Part Time Workers

All benefits are available to all staff irrespective of the hours worked. Some benefits will be pro-rated based on the contracted hours of the individual, this includes salary, pension and holiday.

Other benefits, for example Cycle to work scheme, Birthday Day, Volunteering days, are available to all staff.

If in any doubt, please speak to a Company Director.

To ensure the continuous well-being of our staff, we encourage you to take all of your holiday each year. Should you not be able to, up to 2 days can be carried over into the following calendar year.

We operate an open holiday booking process where each member of the team is responsible for booking their own holiday. Holiday requests must be discussed with affected team members and as a team we must be conscious to ensure the ongoing high standard of service that we deliver. Please discuss any holiday request of more than 10 consecutive days, occurring at the same time as team members or block booking days on consecutive weeks with a Company Director.

Holiday bookings will be recorded to ensure everyone takes their allocated amount each year.

If your employment with Double terminates, you will be entitled to payment in lieu of holiday which is untaken on the date that of termination of employment takes effect. If you have taken holiday in excess of your entitlement, pay that you have received for this time may be deducted from any pay due to you on the termination of your employment.

Holiday pay is calculated on the basis of the rate of pay recorded on your personnel records.

In addition to the standard Holiday entitlement, there are two other circumstances when holiday can be taken:

• Annual Christmas Shutdown – we shut the office between Christmas and New Year each year to enable all Employees to spend time with their families. This is in addition to the standard holiday entitlement.

• Birthday Day Off – In honour of our Birthdays, we encourage each Employee to take an extra day off to do something to celebrate. We ask that this is taken during your Birthday month at a time to suit you as it cannot be carried forward towards your standard entitlement.

For your holiday entitlement, please refer to your Contract of Employment.

The wider community is very important to us all at Double and we like to try and offer our support to charities that need it, whether it's in terms of time or money.

Volunteering

We encourage all staff to take up to 2 paid working days to volunteer for a charitable cause over the course of each year. This could be to plant trees, take part in a beach clean, practical help for a local charity, work in a soup kitchen; whatever you feel passionate about and that will help make a difference to others. Ideas can be discussed with the team and days should be organized to fit in with work and team schedules.

We also provide opportunities to take part in Company-wide volunteering days as part of this.

Charitable Donations

In order to support the causes that mean a lot to us and enable them to use the financial resources in the ways that they feel best, we aim to donate 0.25% of our turnover to our chosen charity each year. These donations are based on the previous years' financial results and are paid over a period of months to the charity (or charities) of choice.

Physical Donations

Whenever we need to dispose of equipment, whether that is furniture from the office, computers or mobile phones, we will always try to find a good home for it with people that can make good use of them.

In the past we have had desks going to schools and pre-schools, computers and mobile phones sent to Africa, and old furniture donated to raise funds for a homeless charity, and for use in not for profit establishments such as voluntary groups and hospitals.

We encourage all staff to suggest and seek out charities that Double can offer support to. Suggestions are very welcome at one of our team meetings.

Flexible working is a way of working that suits an employee’s needs.

Double encourages a flexible approach towards working hours, to help suit employees’ life work balance. For example, some employees may decide to come in later in the morning but leave later in the evening, while others may decide to take a shorter lunch break and leave earlier.

For this to work every member of the team is aware that they are responsible for completing their workload and hitting their deadlines, discussing their requests for flexible working with colleagues as they arise and as it is necessary. Internal meetings will not be held outside of the hours of 9.30am and 4.30pm unless there are exceptional circumstances.

Should you wish to adapt your working hours or location on a permanent basis we ask you to discuss this with a Director in line with our Flexible Working Policy and with the team in terms of the implications on your work.

All requests must be made in writing and the Company has a statutory duty to consider the request seriously and to refuse it only if there are clear business grounds for doing so. Employees making applications for flexible working have the right to be accompanied at any meetings by a fellow employee.

Working Remotely

For many people working from home or another remote location can provide the ability to be more flexible in your life. It can also have the added benefits of being able to provide some peace and quiet to focus on a task.

At Double, we encourage employees to work from home or from another location, other than the main office, to help them achieve a work life balance.

There will also be times when it might be necessary for you to work from somewhere that isn't home or the office. We ask that you apply the same principles to these circumstances as you would working at home.

We ask that all ad-hoc requests to work from home are discussed with your team members to ensure that they do not affect the day to day running of projects and business, and that you are flexible with your plans if required.

All changes to working arrangements should be logged on our internal project management system to ensure that everybody knows of your whereabouts.

Permanent changes to your working location will need to be formally requested in writing and will then be considered by the company directors in line with the Flexible Working Policy.

The guidelines surrounding remote working (including from home) can be found in our Remote Working (Virtual Office Stewardship) policy.

Sabbaticals

Double will always make an effort to accommodate employees who wish to take a sabbatical.

As each employees role is different, with a variety of responsibilities and skill sets, sabbaticals will need to be considered case by case, but will be accommodated where possible.

We encourage every member of the team to seek out any further training and personal development that they would like to pursue to improve their ability to fulfil their role at Double.

We aim to help you develop the skills and give you the knowledge necessary to do the role for which you have been recruited and to broaden your abilities across the Company, achieving a flexible and dynamic team.

We want to equip you to be the best you can be and grow your role and expertise within the Company. We believe this increases the effectiveness of everyone in the Company and therefore of the company as a whole. Any request for training should be discussed with the team in line with company budgets.

Reviews

We have an open appraisal process which is both formal and informal, evaluating everyone’s performance and the relationships we have with our colleagues, clients and suppliers. The objective of every review is to create a forum for having open and honest conversations and manage a working development programme. By setting out clear personal accountabilities and defining the value of each role, we strive to achieve our collective business goals.

Every member of the team is encouraged to request such conversations as and when they feel the need for developmental support alongside reviews being scheduled by Company Directors or other members of the team.

Career Development

Our structure is created to recognise and reward success and achievement in individual roles. Levels of expertise and breadth of knowledge build to create a more experienced team and many aspects of your current performance and future capabilities will be assessed in relation to accepting greater responsibility within the business.

Any recognition of career development will be made solely on the basis of individual merit, and all suitable candidates will be considered .

As we strive to work more effectively than we did yesterday, we welcome any ideas that lead to greater efficiency and productivity, or ideas for the improved safety and well-being of all employees. Feel free to discuss any ideas you have with Company Directors and the rest of the team.

Using our online project management software, feel free to post any useful industry or personal notes and information for the team to read. It is everybody’s duty within the team to keep this updated, sharing thoughts and ideas as frequently as possible.

We also welcome suggestions of charities to be considered for financial donation or voluntary support by the Company.

The most important means of communication, however, are the informal discussions that occur each day. The team acts as your prime source of information about your role or the Company. Everyone has a wealth of knowledge and expertise for you to learn from. It is part of everyone’s role to inform, ask and answer questions and listen to constructive opinions, comments or suggestions.

If you ever need to discuss a personal matter, please contact a Company Director for a private conversation.

Maternity, Paternity, Adoption & Shared Parental Leave

We endeavour to ensure all parents are given support and encouragement before, during, and on return to work from maternity, paternity, adoption or shared parental leave.

We aim to ensure that the employee’s duties are adequately covered during family leave and that an effective dialogue is implemented at all stages so that employees feel fully informed about both their entitlements and the process.

All employees, including those on part-time contracts, taking leave are covered by our Family Friendly Policies, which can be referred to for further information on Maternity, Paternity, Adoption and Parental and Shared Parental Leave.

If would like to discuss a personal situation, please contact a Company Director.

Maternity Pay

We offer an enhanced maternity package over and above the statutory requirements.

Providing you have been employed by Double for over one year and have passed your probationary period, you will be entitled to receive the following remuneration:

• 90% of your average weekly earnings for 6 weeks

• 50% of your average weekly earnings for the following 12 weeks

• Statutory Maternity Pay for the remaining 21 weeks of statutory maternity leave.

All mothers have the option to extend their maternity leave up to 52 weeks but the remaining period above the statutory 39 weeks will be without pay.

Paternity Pay

For employees that have been employed for over 12 months and have passed their probation period, we also offer an enhanced Paternity package where Fathers’ receive two weeks’ of paternity leave at their full rate of pay.

Paternity leave should be taken in line with the statutory requirements.

Parental Rights

Time off to deal with a family emergency

We understand that sometimes unforeseen events occur and all employees are entitled to a reasonable time off work with pay, to deal with an emergency involving a dependent. For example, if a dependent falls ill or is injured, if care arrangements break down, or to arrange or attend a dependent’s funeral.

Please discuss any needs you have with one of the CompanyDirectors.

As with Absence and Sickness, we will keep a record of any time out of the business.

Parental leave

Employees who have completed one year’s service with the Company are entitled to 18 weeks’ unpaid parental leave for each child born or adopted. The leave can start once the child is born or placed for adoption with the employee or as soon as the employee has completed a year’s service, whichever is later. It may be taken at any time up to the child’s eighteenth birthday and must be taken as whole weeks (for example 1 week or 2 weeks), unless otherwise agreed with a Director or if your child

is disabled. The maximum amount that of leave that can be taken in a year is 4 weeks per child, again unless otherwise agreed with a Company Director.

For individual days specifically for school related events, such as concerts, sports and parent days, we encourage all parents to attend and these are offered by the Company outside of your standard holiday entitlement.

The purpose of our Grievance procedure is toprovide employees with a readily accessible procedure for addressing any problems or concerns they may have at work.

This procedure should not replace normal cross team dialogue, however where such informal dialogue has failed to resolve an issue of concern then an employee may utilise this procedure in an effort to have an issue resolved.

A three-step procedure will be followed to ensure that employee complaints or problems receive full and careful attention which will take the following format.

• Informal Discussion

• Formal Procedure

• Appeal

You have the right to be accompanied at meetings by a colleague.

Where a grievance concerns a matter of public interest, the Whistleblowing policy provides the procedure that should be followed.

Full details of the Grievance procedure can be found in the Grievance Policy.

We are an equal opportunities employer. We are committed to equality of opportunity and to providing a service and following practices which are free from unfair and unlawful discrimination.

We aim to ensure that no applicant or member of the team receives less favourable treatment on the grounds of age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation, or is disadvantaged by conditions or requirements which cannot be shown to be relevant to performance. We also seek to ensure that no person is victimised or subjected to any form of bullying or harassment.

Our Equality and Diversity policy is available for further information and we also provide training on this subject on our Online Training Platform.

Introduction

What is the purpose of this document?

Double Retail Limited ("we", "our", "us", "the Company") is committed to protecting the privacy and security of the personal information of our customers, suppliers, employees, workers and other third parties.

This Privacy Standard sets out how we handle Personal Data and applies to all Personal Data we process regardless of the media on which that data is stored or whether it relates to past or present employees, workers, customers, clients or supplier contacts, shareholders, website users or any other Data Subject.

It applies to all Company’s personnel ("you", "your"). You must read, understand and comply with this Privacy Standard when Processing Personal Data on our behalf. This Privacy Standard sets out what we expect from you in order for the Company to comply with applicable law. Your compliance with this Privacy Standard is mandatory and any breach of this Privacy Standard may result in disciplinary action.

This is an internal document and cannot be shared with third parties, clients or regulators without prior authorisation from the Data Protection Officer (DPO).

This notice does not form part of any contract of employment or other contract to provide services. We may update this notice at any time.

1. Interpretation and Definitions

“Automated Decision-Making (ADM)”; when a decision is made which is based solely on Automated Processing (including profiling) which produces legal effects or significantly affects an individual. The GDPR prohibits Automated Decision-Making (unless certain conditions are met) but not Automated Processing.

“Automated Processing”; any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that individual's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. Profiling is an example of Automated Processing.

“Company name”; Double Retail Limited.

“Company personnel”; all employees, workers contractors, agency workers, consultants, directors, members and others.

“Consent”; agreement which must be freely given, specific, informed and be an unambiguous indication of the Data Subject's wishes by which they, by a statement or by a clear positive action, signifies agreement to the Processing of Personal Data relating to them.

“Data Controller”; the person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the GDPR. We are the Data Controller of all Personal Data relating to our Company personnel and Personal Data used in our business for our own commercial purposes.

“Data Subject”; a living, identified or identifiable individual about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data.

“Data Privacy Impact Assessment (DPIA)”; tools and assessments used to identify and reduce risks of a data processing activity. DPIA can be carried out as part of Privacy by Design and should be conducted for all major system or business change programs involving the Processing of Personal Data.

“Data Protection Officer (DPO)”; the person required to be appointed in specific circumstances under the GDPR. Where a mandatory DPO has not been appointed, this term means a data protection manager or other voluntary appointment of a DPO or refers to the Company’s data privacy team with responsibility for data protection compliance.

“EEA”; the 28 countries in the EU, and Iceland, Liechtenstein and Norway.

“Explicit Consent”; consent which requires a very clear and specific statement (that is, not just action).

“General Data Protection Regulation (GDPR)”; the General Data Protection Regulation ((EU) 2016/679). Personal Data is subject to the legal safeguards specified in the GDPR.

“Personal Data”; any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data includes Sensitive Personal Data and Pseudonymised Personal Data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person's actions or behaviour.

“Personal Data Breach”; any act or omission that compromises the security, confidentiality, integrity or availability of Personal Data or the physical, technical, administrative or organisational safeguards that we or our third-party service providers put in place to protect it. The loss, or unauthorised access, disclosure or acquisition, of Personal Data is a Personal Data Breach.

“Privacy by Design”; implementing appropriate technical and organisational measures in an effective manner to ensure compliance with the GDPR.

“Privacy Notices (also referred to as Fair Processing Notices) or Privacy Policies”; separate notices setting out information that may be provided to Data Subjects when the Company collects information about them. These notices may take the form of general privacy statements applicable to a specific group of individuals (for example, employee privacy notices or the website privacy policy) or they may be stand-alone, one time privacy statements covering Processing related to a specific purpose.

“Processing or Process”; any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties.

“Pseudonymisation or Pseudonymised”; replacing information that directly or indirectly identifies an individual with one or more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the use of additional information which is meant to be kept separately and secure.

“Sensitive Personal Data”; information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and Personal Data relating to criminal offences and convictions.

2. Scope

We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the organisation and will provide for successful business operations. Protecting the confidentiality and integrity of Personal Data is a critical responsibility that we take seriously at all times. The Company is exposed to potential fines of up to EUR20 million (approximately £18 million) or 4% of total worldwide annual turnover, whichever is higher and depending on the breach, for failure to comply with the provisions of the GDPR.

All Employees are responsible for ensuring they comply with this Privacy Standard and need to implement appropriate practices, processes, controls and training to ensure such compliance.

The DPO is responsible for overseeing this Privacy Standard and, as applicable, developing related policies and procedures. That post is held by the Finance Director.

Please contact the DPO with any questions about the operation of this Privacy Standard or the GDPR or if you have any concerns that this Privacy Standard is not being or has not been followed. In particular, you must always contact the DPO in the following circumstances:

• if you are unsure of the lawful basis which you are relying on to process Personal Data (including the legitimate interests used by the Company) (see section 4 below);

• if you need to rely on Consent and/or need to capture Explicit Consent (see section 4 below);

• if you need to draft Privacy Notices or Fair Processing Notices (see section 4 below);

• if you are unsure about the retention period for the Personal Data being Processed (see section 10 below);

• if you are unsure about what security or other measures you need to implement to protect Personal Data (see section 11 below);

• if there has been a Personal Data Breach (section 12 below);

• if you are unsure on what basis to transfer Personal Data outside the EEA (see section 13 below);

• if you need any assistance dealing with any rights invoked by a Data Subject (see section 14);

• whenever you are engaging in a significant new, or change in, Processing activity which is likely to require a DPIA (see section 15.3 below) or plan to use Personal Data for purposes others than what it was collected for;

• if you plan to undertake any activities involving Automated Processing including profiling or Automated Decision-Making (see section 15.4 below);

• if you need help complying with applicable law when carrying out direct marketing activities (see section 15.5 below); or

• if you need help with any contracts or other areas in relation to sharing Personal Data with third parties (including our vendors) (see section 15.6 below).

3. Personal Data Protection Principles

We adhere to the principles relating to Processing of Personal Data set out in the GDPR which require Personal Data to be:

• Processed lawfully, fairly and in a transparent manner (Lawfulness, Fairness and Transparency).

• Collected only for specified, explicit and legitimate purposes (Limitation on Purpose).

• Adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed (Minimising Data).

• Accurate and where necessary kept up to date (Accuracy).

• Not kept in a form which permits identification of Data Subjects for longer than is necessary for the purposes for which the data is Processed (Storage Limitation).

• Processed in a manner that ensures its security using appropriate technical and organisational measures to protect against unauthorised or unlawful Processing and against accidental loss, destruction or damage (Security, Integrity and Confidentiality).

• Not transferred to another country without appropriate safeguards being in place (Transfer Limitation).

• Made available to Data Subjects and Data Subjects allowed to exercise certain rights in relation to their Personal Data (Data Subject's Rights and Requests).

We are responsible for and must be able to demonstrate compliance with the data protection principles listed above (Accountability).

4. Lawfulness, Fairness and Transparency

Personal data must be Processed lawfully, fairly and in a transparent manner in relation to the Data Subject.

You may only collect, Process and share Personal Data fairly and lawfully and for specified purposes. The GDPR restricts our actions regarding Personal Data to specified lawful purposes. These restrictions are not intended to prevent Processing but ensure that we Process Personal Data fairly and without adversely affecting the Data Subject.

The GDPR allows Processing for specific purposes, some of which are set out below:

• the Data Subject has given his or her Consent;

• the Processing is necessary for the performance of a contract with the Data Subject;

• to meet our legal compliance obligations.;

• to protect the Data Subject's vital interests; or

• to pursue our legitimate interests for purposes where they are not overridden because the Processing prejudices the interests or fundamental rights and freedoms of Data Subjects. The purposes for which we process Personal Data for legitimate interests need to be set out in applicable Privacy Notices or Fair Processing Notices.

You must identify and document the legal ground being relied on for each Processing activity.

5. Consent

A Data Controller must only process Personal Data on the basis of one or more of the lawful bases set out in the GDPR, which include Consent.

A Data Subject consents to Processing of their Personal Data if they indicate agreement clearly either by a statement or positive action to the Processing. Consent requires affirmative action so silence, pre-ticked boxes or inactivity are unlikely to be sufficient. If Consent is given in a document which deals with other matters, then the Consent must be kept separate from those other matters.

Data Subjects must be easily able to withdraw Consent to Processing at any time and withdrawal must be promptly honoured. Consent may need to be refreshed if you intend to Process Personal Data for a different and incompatible purpose which was not disclosed when the Data Subject first consented.

Unless we can rely on another legal basis of Processing, Explicit Consent is usually required for Processing Sensitive Personal Data, for Automated Decision-Making and for cross border data transfers. Usually we will be relying on another legal basis (and not require Explicit Consent) to Process most types of Sensitive Data. Where Explicit Consent is required, you must issue a Fair Processing Notice to the Data Subject to capture Explicit Consent.

You will need to evidence Consent captured and keep records of all Consents so that the Company can demonstrate compliance with Consent requirements.

6. Transparency (Notifying Data Subjects)

The GDPR requires Data Controllers to provide detailed, specific information to Data Subjects depending on whether the information was collected directly from Data Subjects or from elsewhere. Such information must be provided through appropriate Privacy Notices or Fair Processing Notices which must be concise, transparent, intelligible, easily accessible, and in clear and plain language so that a Data Subject can easily understand them.

Whenever we collect Personal Data directly from Data Subjects, including for human resources or employment purposes, we must provide the Data Subject with all the information required by the GDPR including the identity of the Data Controller and DPO, how and why we will use, Process, disclose, protect and retain that Personal Data through a Fair Processing Notice which must be presented when the Data Subject first provides the Personal Data.

When Personal Data is collected indirectly (for example, from a third party or publicly available source), you must provide the Data Subject with all the information required by the GDPR as soon as possible after collecting/receiving the data. You must also check that the Personal Data was collected by the third party in accordance with the GDPR and on a basis which contemplates our proposed Processing of that Personal Data.

7. Limitations on Purpose

Personal Data must be collected only for specified, explicit and legitimate purposes. It must not be further Processed in any manner incompatible with those purposes.

You cannot use Personal Data for new, different or incompatible purposes from that disclosed when it was first obtained unless you have informed the Data Subject of the new purposes and they have Consented where necessary.

8. Minimising Data

Personal Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed.

You may only Process Personal Data when performing your job duties requires it. You cannot Process Personal Data for any reason unrelated to your job duties.

You may only collect Personal Data that you require for your job duties: do not collect excessive data. Ensure any Personal Data collected is adequate and relevant for the intended purposes.

You must ensure that when Personal Data is no longer needed for specified purposes, it is deleted or anonymised in accordance with the Company's data retention guidelines.

9. Accuracy

Personal Data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when inaccurate.

You will ensure that the Personal Data we use, and hold is accurate, complete, kept up to date and relevant to the purpose for which we collected it. You must check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. You must take all reasonable steps to destroy or amend inaccurate or out-of-date Personal Data.

10. Storage Limitation

Personal Data must not be kept in an identifiable form for longer than is necessary for the purposes for which the data is processed.

You must not keep Personal Data in a form which permits the identification of the Data Subject for longer than needed for the legitimate business purpose or purposes for which we originally collected it including for the purpose of satisfying any legal, accounting or reporting requirements.

The Company will maintain retention policies and procedures to ensure Personal Data is deleted after a reasonable time for the purposes for which it was being held, unless a law requires such data to be kept for a minimum time.

You will take all reasonable steps to destroy or erase from our systems all Personal Data that we no longer require in accordance with all the Company's applicable records retention schedules and policies. This includes requiring third parties to delete such data where applicable.

You will ensure Data Subjects are informed of the period for which data is stored and how that period is determined in any applicable Privacy Notice or Fair Processing Notice.

11. Security Integrity and Confidentiality

Protecting Personal Data

Personal Data must be secured by appropriate technical and organisational measures against unauthorised or unlawful Processing, and against accidental loss, destruction or damage.

We will develop, implement and maintain safeguards appropriate to our size, scope and business, our available resources, the amount of Personal Data that we own or maintain on behalf of others and identified risks (including use of encryption and Pseudonymisation where applicable). We will regularly evaluate and test the effectiveness of those safeguards to ensure security of our Processing of Personal Data. You are responsible for protecting the Personal Data we hold. You must implement reasonable and appropriate security measures against unlawful or unauthorised Processing of Personal Data and against the accidental loss of, or damage to, Personal Data. You must exercise particular care in protecting Sensitive Personal Data from loss and unauthorised access, use or disclosure.

You must follow all procedures and technologies we put in place to maintain the security of all Personal Data from the point of collection to the point of destruction. You may only transfer Personal Data to third-party service providers who agree to comply with the required policies and procedures and who agree to put adequate measures in place, as requested.

You must maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as follows:

• Confidentiality means that only people who have a need to know and are authorised to use the Personal Data can access it.

• Integrity means that Personal Data is accurate and suitable for the purpose for which it is processed.

• Availability means that authorised users are able to access the Personal Data when they need it for authorised purposes.

You must comply with and not attempt to circumvent the administrative, physical and technical safeguards we implement and maintain in accordance with the GDPR and relevant standards to protect Personal Data.

12. Reporting a personal data breach

The GDPR requires Data Controllers to notify any Personal Data Breach to the applicable regulator and, in certain instances, the Data Subject.

We have put in place procedures to deal with any suspected Personal Data Breach and will notify Data Subjects or any applicable regulator where we are legally required to do so.

If you know or suspect that a Personal Data Breach has occurred, do not attempt to investigate the matter yourself. Immediately contact the person or team designated as the key point of contact for Personal Data Breaches. You should preserve all evidence relating to the potential Personal Data Breach.

13. Transfer Limitation

The GDPR restricts data transfers to countries outside the EEA in order to ensure that the level of data protection afforded to individuals by the GDPR is not undermined. You transfer Personal Data originating in one country across borders when you transmit, send, view or access that data in or to a different country.

You may only transfer Personal Data outside the EEA if one of the following conditions applies:

• the European Commission has issued a decision confirming that the country to which we transfer the Personal Data ensures an adequate level of protection for the Data Subjects' rights and freedoms;

• appropriate safeguards are in place such as binding corporate rules (BCR), standard contractual clauses approved by the European Commission, an approved code of conduct or a certification mechanism, a copy of which can be obtained from the DPO;

• the Data Subject has provided Explicit Consent to the proposed transfer after being informed of any potential risks; or

• the transfer is necessary for one of the other reasons set out in the GDPR including the performance of a contract between us and the Data Subject, reasons of public interest, to establish, exercise or defend legal claims or to protect the vital interests of the Data Subject where the Data Subject is physically or legally incapable of giving Consent and, in some limited cases, for our legitimate interest.

14. Data Subjects Rights and Requests

Data Subjects have rights when it comes to how we handle their Personal Data. These include rights to:

• withdraw Consent to Processing at any time;

• receive certain information about the Data Controller's Processing activities;

• request access to their Personal Data that we hold;

• prevent our use of their Personal Data for direct marketing purposes;

• ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or Processed or to rectify inaccurate data or to complete incomplete data;

• restrict Processing in specific circumstances;

• challenge Processing which has been justified on the basis of our legitimate interests or in the public interest;

• request a copy of an agreement under which Personal Data is transferred outside of the EEA;

• object to decisions based solely on Automated Processing, including profiling (ADM);

• prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else;

• be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms;

• make a complaint to the supervisory authority; and

• in limited circumstances, receive or ask for their Personal Data to be transferred to a third party in a structured, commonly used and machine readable format.

You must verify the identity of an individual requesting data under any of the rights listed above (do not allow third parties to persuade you into disclosing Personal Data without proper authorisation).

You must immediately forward any Data Subject request you receive to Laura Templeton-Cox

15. Accountability

The Data Controller must implement appropriate technical and organisational measures in an effective manner, to ensure compliance with data protection principles. The Data Controller is responsible for, and must be able to demonstrate, compliance with the data protection principles.

The Company must have adequate resources and controls in place to ensure and to document GDPR compliance including:

• appointing a suitably qualified DPO (where necessary) and an executive accountable for data privacy;

• implementing Privacy by Design when Processing Personal Data and completing DPIAs where Processing presents a high risk to rights and freedoms of Data Subjects;

• integrating data protection into internal documents including this Privacy Standard Privacy Notices or Fair Processing Notices;

• regularly training Company personnel on the GDPR, this Privacy Standard and data protection matters including, for example, Data Subject's rights, Consent, legal basis, DPIA and Personal Data Breaches. The Company must maintain a record of training attendance by Company personnel; and

• regularly testing the privacy measures implemented and conducting periodic reviews and audits to assess compliance, including using results of testing to demonstrate compliance improvement effort

Record Keeping

The GDPR requires us to keep full and accurate records of all our data Processing activities.

You must keep and maintain accurate corporate records reflecting our Processing including records of Data Subjects' Consents and procedures for obtaining Consents.

These records should include, at a minimum, the name and contact details of the Data Controller and the DPO, clear descriptions of the Personal Data types, Data Subject types, Processing activities, Processing purposes, third-party recipients of the Personal Data, Personal Data storage locations, Personal Data transfers, the Personal Data's retention period and a description of the security measures in place. In order to create such records, data maps should be created which should include the detail set out above together with appropriate data flows.

Training and Audit

We are required to ensure all Company personnel have undergone adequate training to enable them to comply with data privacy laws. We must also regularly test our systems and processes to assess compliance.

You must undergo all mandatory data privacy related training and ensure your team undergo similar mandatory training.

You must regularly review all the systems and processes under your control to ensure they comply with this Privacy Standard and check that adequate governance controls and resources are in place to ensure proper use and protection of Personal Data.

Privacy by Design and Data Protection Impact Assessments (DPIA)

We are required to implement Privacy by Design measures when Processing Personal Data by implementing appropriate technical and organisational measures (like Pseudonymisation) in an effective manner, to ensure compliance with data privacy principles.

Data controllers must also conduct DPIAs in respect to high risk Processing.

Automated Processing (Including Profiling) & Automated Decision Making (ADM)

Generally, ADM is prohibited when a decision has a legal or similar significant effect on an individual unless:

• a Data Subject has Explicitly Consented;

• the Processing is authorised by law; or

• the Processing is necessary for the performance of or entering into a contract.

If certain types of Sensitive Data are being processed, then grounds (b) or (c) will not be allowed but such Sensitive Data can be Processed where it is necessary (unless less intrusive means can be used) for substantial public interest like fraud prevention.

If a decision is to be based solely on Automated Processing (including profiling), then Data Subjects must be informed when you first communicate with them of their right to object. This right must be explicitly brought to their attention and presented clearly and separately from other information. Further, suitable measures must be put in place to safeguard the Data Subject's rights and freedoms and legitimate interests.

We must also inform the Data Subject of the logic involved in the decision making or profiling, the significance and envisaged consequences and give the Data Subject the right to request human intervention, express their point of view or challenge the decision.

A DPIA must be carried out before any Automated Processing (including profiling) or ADM activities are undertaken.

Where you are involved in any data Processing activity that involves profiling or ADM, you must comply with the Company's guidelines on profiling or ADM.

Direct Marketing

We are subject to certain rules and privacy laws when marketing to our customers.

For example, a Data Subject's prior consent is required for electronic direct marketing (for example, by email, text or automated calls). The limited exception for existing customers known as "soft opt in" allows organisations to send marketing texts or emails if they have obtained contact details in the course of a sale to that person, they are marketing similar products or services, and they gave the person an opportunity to opt out of marketing when first collecting the details and in every subsequent message.

The right to object to direct marketing must be explicitly offered to the Data Subject in an intelligible manner so that it is clearly distinguishable from other information.

A Data Subject's objection to direct marketing must be promptly honoured. If a customer opts out at any time, their details should be suppressed as soon as possible. Suppression involves retaining just enough information to ensure that marketing preferences are respected in the future.

Sharing Personal Data

Generally we are not allowed to share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place.

You may only share the Personal Data we hold with another employee, agent or representative of our group (which includes our subsidiaries and our ultimate holding company along with its subsidiaries) if the recipient has a job-related need to know the information and the transfer complies with any applicable cross-border transfer restrictions.

You may only share the Personal Data we hold with third parties, such as our service providers if:

• they have a need to know the information for the purposes of providing the contracted services;

• sharing the Personal Data complies with the Privacy Notice provided to the Data Subject and, if required, the Data Subject's Consent has been obtained;

• the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place;

• the transfer complies with any applicable cross border transfer restrictions; and

• a fully executed written contract that contains GDPR approved third party clauses has been obtained.

16. Changes to this Data Privacy Standard

We reserve the right to change this Privacy Standard at any time without notice to you so please check back regularly to obtain the latest copy of this Privacy Standard.

Last Updated: January 2020

Whistleblowing is the name given to the disclosure of information about a wrongdoing that the Company is responsible for.

You’re a Whistleblower if you’re a worker and you report certain types of wrongdoing, either because you know or you suspect it. This will usually be something you’ve seen at work. You must genuinely and reasonably believe that the wrongdoing you disclose is in the public interest. This means it must affect others, for example the general public.

As a Whistleblower you are protected by law – you should not be treated unfairly or lose your job because you ‘blow the whistle’. By making a qualifying disclosure, you are protected by The Public Interest Disclosure Act 1998.

You can raise your concern at any time about an incident that happened in the past, is happening now, or you believe will happen in the near future.

Our Whistleblowing policy is available for further information.

Double values its reputation and is committed to maintaining the highest level of ethical standards in the conduct of its business affairs. The honest actions and conduct of our staff as well as others acting on our behalf are key to maintaining these standards.

Acts of bribery or corruption are designed to influence an individual in the performance of their duty and incline them to act in a way that a reasonable person would consider to be dishonest under the circumstances.

Our Anti-Bribery and Corruption Policy is available for further information and helps to outline what these terms mean, where the key areas of risk are and what individuals can do to ensure that we adhere to the law.

You can raise concerns or questions at any time with a Company Director.

As an employee of Double, you agree to give the Company full written details of all Inventions and of all works embodying Intellectual Property Rights made wholly or partially by you at any time during the course of your employment which relate to, or are reasonably capable of being used in, the business of the Company. You also acknowledge that all Intellectual Property Rights subsisting (or which may in the future subsist) in all such Inventions and works shall automatically, on creation, vest in the Company absolutely. To the extent that they do not vest automatically, you agree you hold them on trust for the Company. You further agree to promptly execute all documents and do all acts as may, in the opinion of the Company, be necessary to give effect to this.

It is understood that you irrevocably waive all moral rights under the Copyright, Designs and Patents Act 1988 (and all similar rights in other jurisdictions) which you have or will have in any existing or future works.

You also irrevocably appoint the Company to be your attorney in your name and on your behalf to execute documents, use your name and do all things which are necessary or desirable for the Company to obtain for itself or its nominee the full benefit of this clause. A certificate in writing, signed by any director or the secretary of the Company, that any instrument or act falls within the authority conferred by this agreement shall be conclusive evidence that such is the case so far as any third party is concerned.

In this agreement:

‘Intellectual Property Rights’ means any patents, rights to Inventions, copyright and related rights, trade marks, trade names and domain names, rights in get-up, rights in goodwill or to sue for passing off, unfair competition rights, rights in designs, rights in computer software, database rights, topography rights, rights in confidential information (including know-how and trade secrets) and any other intellectual property rights, in each case whether registered or unregistered and including all applications (or rights to apply) for, and renewals or extensions of, such rights and all similar or equivalent rights or forms of protection which subsist or will subsist now or in the future in any part of the world.

‘Invention’ means any invention, idea, design, process, discovery, development, improvement or innovation, whether or not patentable or capable of registration, and whether or not recorded in any medium.

We nurture an open, honest and trusting company culture where our place of work, each other and our business should be respected. We want to ensure that everyone has the freedom to feel safe and relaxed in their working environment so there are a few rules that we ask everyone to be aware of.

Personal conduct

You must not drink alcohol, except during recognised social activities, or gamble on company premises.

We recommend that lunch is eaten away from your work station and we encourage employees to take the full lunch break.

Respect for colleagues is paramount and is consistently encouraged throughout the business. Any bullying or disrespectful taunting will be not be tolerated.

Personal property

The company will not accept responsibility for loss of, or damage to your property whilst it is on company premises. However, if you lose or find any article please notify a Company Director without delay.

Internet and Social Media

IT and Communication plays an essential role in the conduct of our business and personal social interaction. We encourage employees to respectfully, responsibly and positively use Email, Internet and Social Media, at all times considering the content, protecting both personal and businessreputation.

In order to protect our business data and email accounts, we ask that passwords be kept confidential and secure and that they are changed on at least an annual basis.

Please see our Email, Internet and Social Media Use Policy for moreinformation.

Visitors and telephone calls

We work in a social environment and enjoy visits and calls from friends and family but we ask that you be aware of your colleagues working around you. We request that you don’t make an excessive amount of personal calls during the working day and should you have friends or family visiting the office, it’s appreciated that you check that this will not disrupt the team.

Outside interests

Should you wish to take on part-time employment outside working hours, you should first discuss the matter with a Company Director. Under no circumstances should you undertake any other business or work during working hours or using the company’s premises or equipment without the prior agreement of a Company Director.

Sale of goods

Sale of goods on company premises is not permitted, although you may advertise goods for sale to colleagues.

Collections & personal deliveries

If you wish to carry out collections for charities, for employees, or for outside organisations within your working day, you must get approval from a Company Director.

We are happy for you to accept personal deliveries, within reason, and if you are not at work we shall sign for the goods on your behalf.

In signing your contract of employment with Double, you warrant that all information you have supplied to the Company prior to your employment including, but not limited to, qualifications and other relevant matters, whether in an application form, at interview, in correspondence or otherwise, is true, accurate and complete.

You also warrant that the information you have provided to the Company about unspent previous criminal convictions is true, accurate and complete and you agree to immediately inform the Company if at any time you are questioned, arrested, charged or summonsed in connection with a criminal offence of any nature.

You warrant that you have been fully released by all previous employers in respect of any contracts you may have entered into with them. Furthermore, you warrant that no action is currently being taken by previous employers and that no such action could be taken that would restrict your ability to properly carry out the role for which you have been employed by the Company.

You acknowledge that, in the event that the Company reasonably believes that you are in breach of any warranty set out above, such breach may be treated as gross misconduct for which you may be summarily dismissed.

During your employment you may be party to Confidential Information concerning the Company and its business. You shall make yourself aware of the Company’s policies in relation to compliance with the General Data Protection Regulation and the Data Protection Act in force and undertake to act in accordance with these at all times. This includes exercising reasonable care to keep safe all documentary or other material containing confidential information. You shall inform the Company immediately upon discovery of a data breach. You shall, at the time of termination of your employment with us, or at any other time upon demand, return to us any such material in your possession. You shall not (except in the proper course of your duties), either during your employment or at any time after its termination (however arising), use or disclose to any person, company or other organisation whatsoever (and you agree to use your best endeavours to prevent the publication or disclosure of) any Confidential Information.

This shall not apply to:

• any use or disclosure authorised by the Company or as required by law;

• any information which is already in, or comes into, the public domain other than through your unauthorised disclosure; or

• any protected disclosure within the meaning of section 43A of the Employment Rights Act 1996.

In this agreement ‘Confidential Information’ means any information (whether or not recorded in documentary form, or stored on any magnetic or optical disk or memory) relating to the business, products, affairs and finances of the Company for the time being confidential to the Company and trade secrets including, without limitation, technical data, designs and know-how relating to the business of the Company or any of its business contacts, customers and suppliers, including in particular (by way of illustration only and without limitation) details of the Company’s business contacts, customers and suppliers and their requirements, terms of business withcustomers including prices charged, marketing plans, financial information (save to the extent that these are included in published audited accounts), details of employees and officers of the Company and of the remuneration and other benefits paid to them, information relating to secret processes, designs and product lines, know-how, and whether or not any such information is marked or stated to be confidential, and any information which has been given to the Company in confidence by business contacts, customers or suppliers or any other third party.

The Company retains and processes personal data in relation to itsemployees.

In signing your contract of employment you agree and explicitly consent to the Company processing:

• personal data where this is necessary or reasonably required for the purposes of your employment (both during and after employment) or the conduct of the Company’s business or where it is required by law; and

• sensitive personal data, including without limitation any self certification forms or medical certificates supplied to the Company to explain your absence by reason of illness or injury, any record of sickness absence of any medical records or health assessments where this is necessary or reasonably required for the purposes of your employment (both during and after employment) or the conduct of the Company’s business or where it isrequired by law;

• and you acknowledge that such data may be legitimately disclosed to appropriate persons and the Company’s professional advisors, pursuant to the Data Protections Act 2018 (“DPA”).

You must, at all times during your employment, act in accordance with the DPA principles and Company Privacy Statement and Privacy Notice as provided to you and must comply with any policy introduced by the Company to comply with current data protection regulations.

In accordance with the principles of the DPA (2018), the aim is to ensure that data held by the Company is as accurate and up to date as reasonably practicable. If you consider that data held on you is or may be inaccurate, or if you wish to have access to such data, please contact a Director.

Please refer to our Privacy Notice and Privacy Policy for further information.

In order to ensure that you are treated fairly if your conduct or performance does not meet the standards required by the Company, we will adopt the following process:

• Investigation and Informal Discussion

• First written warning

• Final written warning

• Dismissal or alternative action

Gross Misconduct

If an employee commits an extremely serious disciplinary offence the Company may dismiss them without prior warnings and without notice.

Some examples of offences which constitute gross misconduct are:

• dishonesty, theft or fraud

• malicious damage

• fighting, assault on another person

• serious incapability through alcohol or illegal drugs

• actions which endanger employees’ safety

• falsification or unauthorised removal of company records or property

• a serious act of insubordination

This list is not exhaustive or exclusive, and offences of a similar nature will be dealt with under this procedure.

If the employee is alleged to have carried out such an act of gross misconduct the company will suspend them on full pay whilst it carries out an investigation into the alleged offence. At the disciplinary hearing the employee will be given the opportunity to state their case and be represented or accompanied by a colleague of their choice or by a trade union official.

If, after investigation, it is confirmed that an employee has committed an act of gross misconduct the normal consequence will be dismissal without notice or payment in lieu of notice.

Please refer to our Disciplinary Policy for more information.

You must return to the Company upon request and, in any event, upon the termination of your employment (however so arising), all documents and tangible items which belong to the Company or which contain or refer to any Confidential Information and which are in your possession or under your control. This includes but is not limited to documents, correspondence, customer lists, magnetic disks, tapes or other software storage media and all other property belonging to the Company.

You must, if requested by the Company, delete irretrievably any Confidential Information or information relating to the business of the Company that you have stored on any magnetic or optical disk or memory device and all matter derived from such sources which is in your possession or under your control outside the premises of the Company.

You agree, if requested to do so by a Company Director, to provide a signed statement that you have complied fully with your obligations and shall provide such reasonable evidence of compliance as may be requested, including allowing the Company to inspect any computer or other device belonging to you or under your control.

Double values its reputation and is committed to maintaining the highest level of ethical standards in the conduct of its business affairs. The honest actions and conduct of our staff as well as others acting on our behalf are key to maintaining these standards.

The purpose of this document is to set out our policy in relation to bribery and corruption. The policy applies strictly to all employees (whether temporary, fixed-term or permanent), agents, consultants, contractors and to any other people or bodies associated with Double, wherever they are based.

Understanding and recognising bribery and corruption

Acts of bribery or corruption are designed to influence an individual in the performance of their duty and incline them to act in a way that a reasonable person would consider to be dishonest under the circumstances.

Bribery can be defined as offering, promising, receiving or giving a financial (or other) advantage to another person so as to induce or influence an action or decision.

Corruption is any form of abuse of entrusted power for private gain and may include, but is not limited to, bribery.

Bribes are not always a matter of handing over or receiving cash. Gifts, hospitality and entertainment can be bribes if they are intended to influence a decision.

Facilitation payments and charitable contributions can also be deemed as bribes.

Penalties

Double is bound by the Bribery Act 2010 which came into force on 1st July 2011 and take our legal responsibilities seriously. Under that Act, bribery by individuals is punishable by up to 10 years imprisonment and/ or an unlimited fine. If Double is found to have taken part in bribery or is found to lack adequate procedures to prevent bribery, it too could face an unlimited fine.

A conviction for a bribery or corruption related offence would have severe reputational and/or financial consequences for Double.

Policy

Double will not tolerate bribery or corruption in any form.

We prohibit the offering, giving, solicitation or acceptance of any bribe or corrupt inducement, whether in cash or in any other form:

• To or from any person or company wherever located, whether a public official or public body, or a private person or company

• By any individual employee, partner, agent, consultant, contractor or other person or body acting on Double’s behalf

• In order to gain any commercial, contractual or regulatory advantage for the practice in any way which is unethical or to gain any personal advantage, pecuniary or otherwise, for the individual or anyone connected with the individual

This policy is not intended to prohibit the following practices provided they are appropriate, proportionate and are properly recorded:

• Normal hospitality

• Fast tracking a process which is available to all on the payment of a fee; and/or

• Providing resources to assist a person or body to make a decision more efficiently, provided that it is for this purpose only

It may not always be a simple matter to determine whether a possible course of action is appropriate. The below requirements give some guidance, but if you are in any doubt as to whether a possible act might be in breach of this policy or the law, the matter should be referred to a Company Director who will seek further advice.

• It is not made with the intention of influencing to obtain or reward the gain or retention of business.

• It is not made with the suggestion that a return favour is expected.

• It is in compliance with local law

• It is given in the name of the company not an individual.

• It does not include cash or a cash equivalent

• It is appropriate for the circumstances (e.g. small Christmas or thank you gifts)

• It is of an appropriate type and value and given at an appropriate time

• It is given/ received openly, not secretly

• It is not selectively given to a key, influential person

• It is not offered to or accepted from a government official or politician without prior approval from a Company Director.

The Company Directors will investigate thoroughly any actual or suspected breach of this policy. Employees found to be in breach of this policy may be subject to disciplinary action which may ultimately result in their dismissal for gross misconduct.

Key risk areas

Bribery can be a risk in many areas of the organisation. Below are the key areas you should be aware of in particular:

• Excessive gifts, entertainment and hospitality can be used to exert improper influence on decision makers. Gifts, entertainment and hospitality are acceptable provided they are within reasonable limits. Any excessive gifts or hospitality, either given or received, should be reported to a Company Director.

• Facilitation payments are used by businesses or individuals to secure or expedite the performance of a routine or necessary action to which the payer has an entitlement as of right. Double will not tolerate or excuse such payments being made.

• Reciprocal agreements or any other form of ‘quid pro quo’ are never acceptable unless they are legitimate business arrangements which are properly documented and approved by a Company Director. Improper payments to obtain new business, retain existing business or secure any improper advantage should never be accepted or made.

• Actions by third parties for which Double may be held responsible can include actions by a range of people, e.g. agents, contractors and consultants. Appropriate due diligence should be undertaken before a third party is engaged. Third parties should only be engaged where there is a clear business rationale for doing so, with an appropriate contract. Any payments to third parties should be properly authorised and recorded.

• Record keeping can be exploited to conceal bribes or corrupt practices. We must ensure that we have robust controls in place so that our records are accurate and transparent.

Cultural Variations

We recognise that the practice of giving and receiving business gifts varies between countries, regions, cultures and religions so definitions of what is acceptable and not acceptable will inevitably differ for each.

Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/ culture who may take offence), the gift may be accepted so long as it is declared to a Company Director who will assess the circumstances.

Employee responsibility and how to raise a concern

The prevention, detection and reporting of bribery or corruption are the responsibility of all employees and they are required to avoid any activities that could lead to, or imply, a breach of this policy.

If you become aware or suspect that an activity or conduct which is proposed or has taken place is a bribe or corrupt, then you have a duty to report this to a Company Director without delay.

No one that refuses to accept or offer a bribe or that reports a concern relating to a potential act of bribery or corruption, will suffer any detrimental treatment as result of doing so and Double will ensure you are fully supported in line with our Whistleblowing policy, even if investigation finds that you were mistaken.

Last Updated: January 2020

We are an equal opportunities employer. We are committed to equality of opportunity and to providing a service and following practices which are free from unfair and unlawful discrimination. We aim to ensure that no applicant or member of the team receives less favourable treatment on the grounds of age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation, or is disadvantaged by conditions or requirements which cannot be shown to be relevant to performance. This statement seeks also to ensure that no person is victimised or subjected to any form of bullying or harassment.

We value people as individuals with diverse opinions, cultures, lifestyles and circumstances. All employees are covered by this statement and it applies to all areas of employment including recruitment, training, career development, role review and promotion. These areas are monitored and policies and practices are amended if necessary to ensure that no unfair or unlawful discrimination, intentional, unintentional, direct or indirect, overt or latent exists.

The Company Directors have particular responsibility for implementing and monitoring the equality and diversity within the business.

All employees, workers or self-employed contractors whether part time, full time or temporary, will be treated fairly and with respect. Selection for employment, promotion, training, or any other benefit will be on the basis of aptitude and ability. All employees will be helped and encouraged to develop their full potential and the talents and resources of the workforce will be fully utilised to maximise the efficiency of the Company.

Equality of opportunity, valuing diversity and compliance with the law is to the benefit of all individuals in our Company as it seeks to develop the skills and abilities of its people. While specific responsibility for eliminating discrimination and providing equality of opportunity lies with the Company Directors, individual team members have a responsibility to treat others with dignity and respect. The personal commitment of every employee to this policy and application of its principles are essential to eliminate discrimination and provide equality throughout the Company.

Our commitment as an employer

The Company is committed to:

• creating an environment in which individual differences and the contributions of all our staff are recognised and valued

• every employee, worker or self-employed contractor is entitled to a working environment that promotes dignity and respect to all. No form of intimidation, bullying or harassment will be tolerated

• providing training, development and progression opportunities to all staff

• reviewing all our employment practices and procedures to ensure fairness

Our commitment as a service provider

The Company is committed to:

• providing services to which all clients are entitled regardless of age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation, offending past, caring responsibilities or social class

• making sure our services are delivered equally and meet the diverse needs of our service users and clients by assessing and meeting the diverse needs of our clients

• fully supporting this policy and ensuring agreement has been reached with employee representatives

• monitoring and reviewing this policy annually

• having clear procedures that enable our clients, candidates for jobs and employees to raise a grievance or make a complaint if they feel they have been unfairly treated

• treating breaches of our equality and diversity policy as misconduct which could lead to disciplinary proceedings.

Last Updated: January 2020

Policy purpose and scope

The Company acknowledges that its employees may incur expenses in the carrying out of their role. This document sets out the Company’s stance on the scope, authorisation and reimbursement of those expenses.

Expense claims must be supported by full and accurate details of the expense and receipts to evidence expenditure. In addition, claims will only be processed where the Company considers the employee’s expenditure to be reasonable and necessary.

Misuse of the Company’s expenses policy is considered to be a disciplinary offence under the Company’s disciplinary procedure which may result in the employee’s dismissal.

Employees are encouraged to consider the necessity of all costs and expenses incurred as all purchases and expenses submitted affect project and business profitability. Should you have any queries regarding an expense purchase, please discuss with a Company Director in advance.

Types of expenses

Noted below are the most common types of expenditure for which the Company will reimburse the cost. The cost of other expenditure may also be reimbursed, however, it is requested that employees always seek agreement for large or unexpected expenses from a Company Director before purchase.

Travelling expenses

Employees should:

• Consider whether travel is necessary or whether the task could be completed by telephone or video conference

• Choose the most cost-effective methods of travel

• Consider whether travel expenses can be re-charged to clients against a project

Road Travel

When travelling by road for the purpose of business, the employee should endeavour to use a hired vehicle through the Company car hire account. Should this not be possible or practical, use of personal vehicles should be approved by a Company Director.

When using personally owned vehicles for business purposes, the employee must ensure the vehicle is legal and roadworthy and the employee must have relevant Business Use car insurance, providing the Company with a copy of the insurance document every 12 months.

Whether driving own or hired vehicles, the employee should operate the car at all times in accordance with road traffic laws, including, but not limited to, laws prohibiting speeding and the use of mobile phones when driving. The employee should not drive when tired, taking necessary rest to preserve their own and other road users safety.

The employee is responsible for the payment of all fines incurred for traffic offences and parking fines and should notify a Company Director of any accidents involving the car whilst driving for business.

It is the employee’s responsibility to immediately inform the Company if they are convicted of a driving offence or disqualified from driving.

Car mileage

Business mileage against use of own vehicles may be claimed at prevailing HMRC rates with production of a VAT fuel receipt dated within the month mileage is claimed. Fuel for all business mileage must be purchased and claimed back through personal expenses, not using Company credit cards.

There will be no reimbursement of home to office mileage and return unless it is necessary for an onward journey for company business.

Rail and air travel

Where such travel has been agreed and it is necessary to undertake travel by rail or air, any travel paid direct by the employee will be reimbursed through the expense claim process, for which a receipt must be provided. In normal circumstances, such travel is to be booked through the most cost efficient travel provider, for example direct with airlines, Expedia, Booking.com, Trainline.com or using the Company account with Corporate Traveller.

When travelling by rail or air, standard or Economy Class travel should be selected. Paid seating selection should be avoided unless necessary and paid luggage allowance should be only be used on trips of a duration of 3 days or more or where there is a business need.

The purchase of onboard food and drinks should be kept to a minimum and employees should be aware that at all times they are a representative of the Company. Alcohol should only be consumed in moderation.

Parking, road tolls, underground, taxi and bus fares

Parking, road tolls, underground, taxi and bus fares will be reimbursed, but usage must be appropriate, cost effective and supported by receipts. Expenses incurred when travelling from home to the office will not be reimbursed.

Accommodation and allowances

Overnight accommodation will only be approved when significant travel has to be undertaken and will only be authorised in respect of overnight, early morning or overseas work.

Where overnight accommodation is authorised and booked, this should take the form of hotels or privately rented rooms or apartments directly or through services such as Expedia and AirBnB. Accommodation should be clean, safe and well located for the purpose of the stay, however employees should use their discretion with regards to cost. The reasonable cost of meals and drinks will also be reimbursed but must be supported by a relevant receipt.

Client/Staff entertainment & Gifts

Where employees entertain or purchase gifts for clients or other staff members, the Company will reimburse costs on production of receipts via the expenses procedure. Client and staff entertainment and gifts budgets should be agreed in advance.

Credit card

Company credit cards are to be used for business purposes including but not limited to reasonable travelling expenses, reasonable accommodation costs and client and staff entertaining expenses.

For any purchase made, all receipts including VAT receipts, should be provided within 5 working days of the date on which your account statement is received.

You are not permitted to use the Company credit card for personal use. Any unauthorised personal transaction via your Company credit card will automatically be deducted from your next salary payment, as per the written term of your contract of employment.

When using a Company credit card you are an ambassador of the company therefore you should deal with all transactions courteously and professionally.

On termination of employment, your Company credit card should be handed in to a Company Director on your last date of employment along with receipts of any purchases made in the current statement month.

If at any time cash or foreign currency is required for business purposes, please arrange this in advance of your trip with Laura Templeton-Cox or Rachael Butler. We hold petty cash of Euros, Swiss Francs and Swedish Krona. Other currencies can be ordered but require 5 working days notice.

Phone calls & mobile data

Company mobile phones are provided to you in order for you to fulfil your duties professionally and efficiently. The mobile phone provided does not belong to you. It is to be used strictly for business purposes, only except in the case of an emergency.

We reserve the right to monitor Company mobile phone & data use to ensure compliance with our policy and any personal use will be recharged back to you.

Where available, wifi and non-charged methods of calling and data use such as Skype and Whatsapp should be selected.

Sundry & Project expenses

Purchases made for client projects or Company use, such as installation or office supplies, should be done with consideration of the cost to the business. Such purchases should be reasonable and cost effective as these affect the project and business profitability.

Expense claim procedure

Claim forms are available to all employees through Synergist. Employees should submit the completed form, including receipts, via Synergist for authorisation within 5 working days of the end of the month. The claim will then be processed and claims submitted and approved will be paid in arrears directly into the employee’s bank or building society account.

Original receipts should be retained until your expense claim, for either Company credit card or personal expenses, has been approved and paid.

Policy last updated: January 2020

Purpose

IT and communication plays an essential role in the conduct of our business. The IT infrastructure including e-mail and internet access have therefore significantly improved business operations and efficiencies.

This policy applies to all members of the Company who use our or our clients’ communications facilities, whether Directors/Consultants, full or part-time employees, contract staff or temporary staff. The parameters and restrictions are outlined below and you are required to read them carefully. The purpose of this policy is to define acceptable email and internet use within working time.

General Principles

You must use our information technology and communications facilities sensibly, professionally, lawfully, consistently with your duties and in accordance with this policy and other Company rules and procedures.

At all times employees must behave with honesty and integrity, and respect the rights and privacy of others in relation to electronic communication and information.

Every employee will be given access to the intranet and/or internet as appropriate to their job needs. For those who do not have daily PC access occasional access will be arranged, as necessary.

All PC/network access will be through passwords, and no individual is permitted onto the system using another employee’s password. Employees are not permitted to share their password with anyone inside or outside the company. Individuals will be allowed to set their own passwords, and must change them on an annual basis, or as requested by the system set-up requirements.

All information relating to our clients/customers and our business operations is confidential. You must treat our paper-based and electronic information with utmost care.

Many aspects of communication are protected by intellectual property rights which can be infringed in a number of ways. Downloading, copying, possessing and distributing material from the internet may be an infringement of copyright or of other intellectual property rights.

Particular care must be taken when using e-mail as a means of communication because all expressions of fact, intention and opinion in an e-mail may bind you and/or the Company and can be produced in court in the same way as other kinds of written statements.

Email & Internet use for personal purposes

Company email addresses and internet access in the office is primarily provided for business use and the use of Company email addresses and internet for personal reasons should be limited and kept to a minimum during working hours.

Upmost care should be taken in assessing email content prior to opening, particularly in relation to suspicious attachments, links and file formats.

Unauthorised use of email and internet

The Company will not tolerate use of email and internet for unofficial or inappropriate purposes, including but not limited to:

• any messages that could constitute bullying, harassment or other detriment

• on-line gambling & excessive trading

• accessing or transmitting pornography

• accessing other offensive, obscene or otherwise unacceptable material

• transmitting copyright information and/or any software available to the user

• posting confidential information about other employees, the Company or its customers or suppliers

• use of a personal VPN

• mining crypto currencies

• hacking

• excess gaming

Downloading of material

In order to prevent the introduction of virus contamination into the software system the following must be observed:

• all software must be virus checked by pre-installed Company anti-virus software before being used

• software including public domain software, magazine cover disks/CDs or Internet/World Wide Web downloads must be used with caution and anti-virus software recommendations must be adhered to

• all employees are individually responsible for maintaining their anti-virus software with the latest updates version

Employees are individually responsible for crediting and using downloaded design and research assets responsibly, adhering to copyright laws.

The Company does not permit the use of illegal software or the illegal downloading of any software or other digital media files. This includes any files that do not adhere to copyright law.

On-line blogs & forums

When contributing to online forums, blogs or other digital publications, either on behalf of the business or personally using Company equipment, the following rules apply:

• personal blogs should contain a disclaimer that the views expressed on it are personal views of the author only

• you should not at any time make comments in a blog which bring the Company into disrepute

• you should not reveal confidential Company information, or information on clients/customers/suppliers etc

• you should not share any Company derived assets unless agreed by a Company Director

• you should not at any time make comments in a blog or online forum which amount to bullying, harassment or any other detriment towards other employees/ contractors/suppliers/clients/customers or any other individual working in connection with us

Storage of personal and other digital data

Employees should ensure they regularly audit their emails, computer files and shared folders in order to archive or delete anything that contains information that is no longer required in order for the Company to comply with its obligations under the Data Protection Act 1998.

Company’s website

Unless you are responsible for the upkeep of the Company’s website as part of your role, you are not permitted to add anything to the website without express permission of a Company Director.

Monitoring

The Company is ultimately responsible for all business communications but subject to that will, so far as possible and appropriate, respect your privacy and autonomy. The Company may monitor your business communications for business reasons.

Social media policy

The Company operates a social media policy to govern the use of this media within the Company. The policy covers profile pages and other resources maintained by employees on networking sites including, but not limited to, Facebook, Twitter, Instagram and LinkedIn, as well as blogs, forums, message boards, review sites and online polls.

Social media can be a distracting technology which causes a negative effect on the productivity of employees working for the Company, however, it can also be an engaging platform that enables the Company to build new relationships with new and existing customers.

This policy sets out how employees must behave when using the Company’s social media platforms and governs how employees should refer to and promote the Company on their own personal accounts.

Policy aims

The Company’s social media use policy is applied in conjunction with the Company’s internet policy and publicity policies. This policy applies to all employees, contractors and volunteers who use social media either for personal or professional reasons.

It is important that employees using social media in the workplace use it in a way which does not adversely affect the Company’s reputation.

Social media can involve communication between job applicants and employees and is an avenue for the Company to promote and control their reputation. Social media may blur the boundaries between what is home and work. Access is often public, even amongst a limited group of connected accounts, and comments are often permanent.

Employees should be honest and respectful when using social media. Everything posted on social media may be tracked back to the source so employees must ensure content posted on social media accounts, both in a work and personal capacity, fits with the Company ethos, GDPR Regulations, CSR and marketing brands.

Terms of use

When using social media, either in a personal or work capacity, during or outside working hours, posts on social media must not:

• compromise the Company, disclose confidential data or disclose sensitive data

• must not damage the Company’s reputation or brand

• must not breach copyright or data protection

• contain libel or defamatory content

• must not engage in bullying or harassment

• be of illegal, sexual or offensive content

• interfere with your work commitments

• use the name of the Company to promote products or political opinions.

Employees should ensure they consider the Company’s other policies on marketing, promotion, sales and branding.

Social media content attributable to you which breaches the terms of this policy, or the other related policies, may result in an investigation and disciplinary action under the Company’s disciplinary policy.

Social media and recruitment

Recruitment processes are increasingly utilising social media as a method of engaging job-seekers. Due to the increasing amount of content posted online, viewing candidate’s social media profiles is a quick and effective way of checking details contained in a CV or getting an idea of the personality of the candidate.

The Company does not permit those involved in the recruitment process to review or access candidate’s social media profiles.

Business contacts

Details of business contacts obtained during the course of an employee’s employment are considered confidential information, remain the property of the Company and are protected under GDPR regulations. Business contact details includes the contacts records in computer software installed on an employee’s computer and mobile phone as well as maintained in third party websites including social media.

Business contacts may not be added to personal social media accounts during the course of your employment. If any are, these must be removed upon termination of an employee’s employment.

Business contacts may be added to corporate social media accounts. A separate record of business contacts on social media should be maintained within the Company, updated as and when the contacts are added.

Policy enforcement

Using social media to refer to or notify business or personal contacts of an employee’s new employer will be seen as an attempt to solicit customers or poach staff and may result in civil proceedings being brought against the individual.

Using social media in a way which breaches this policy will result in such content being removed from corporate accounts and the employee’s authorisation to use corporate social media accounts on behalf of the Company being suspended and removed. Such content may be damaging to the Company or employees and may lead to disciplinary action under the Company’s disciplinary policy, which may be serious or gross misconduct.

The Company reserves the right to check the social media accounts of employees in accordance with the internet and monitoring policy.

Enforcement

Failure to comply with this policy may result in disciplinary action being taken against you. If there is anything in this policy that you do not understand, please discuss it with a Company Director.

Last Updated: January 2020

Policy and purpose

The Company is committed to treating all staff fairly and equitably and to helping employees to perform effectively. However, there will be occasions when it may be necessary to invoke disciplinary procedures. Should the need arise, the employee will be given the opportunity to improve throughout the stages of the procedure.

When work falls below an acceptable standard, help will be given to the employee to improve. If standards of work continue to fall and there is a necessity for action, it will automatically begin with a pre-disciplinary informal discussion. Similarly, when an employee’s behaviour is potentially inappropriate and unacceptable, it will mean the initiation of a pre-disciplinary informal discussion or the disciplinary procedure, depending on the severity.

If disciplinary action should become necessary, each case will be treated consistently and fairly, and the disciplinary procedure will be observed at all steps. The employee will be given the opportunity to provide their version of events and any extenuating circumstances will be considered. An employee’s rights will be upheld at all times, and employees will have the right to:

• know the case against him/her

• reply

• due consideration of their case

• be accompanied

• appeal

This policy is adopted on a non-contractual basis and therefore does not make up part of employees’ contractual terms and conditions.

Investigation

Prior to taking the decision to invoke the disciplinary procedure, the Company will ensure that a thorough investigation is carried out. This is a fact-finding process and may necessitate the gathering of detailed information as well as the carrying out of formal interviews, taking of written statements, etc.

A proper investigation is an integral part of the process and, where an allegation of gross misconduct is involved, may require employees to be suspended on contractual pay whilst this is carried out. Suspension on pay is not considered to be a sanction taken under the disciplinary procedure. It is there to ensure that issues are dealt with in a fair and reasonable manner, and adequate protection is given to all employees.

Informal pre-disciplinary discussion

Where appropriate, prior to using the formal aspects of the Company’s disciplinary procedure, a pre-disciplinary discussion will be held with the employee.

Minor misconduct, poor performance or minor breaches of rules will normally result an in informal warning being given by a Company Director. This will not be recorded in writing. If that approach is not successful, the Company is likely to escalate it to the formal disciplinary procedure.

The disciplinary procedure

This procedure will be used in cases of a breach of the rules or poor performance that have not been remedied by an informal warning. Normally, the procedure will follow the steps listed below, although it is acceptable to move directly to steps two or three if a case is sufficiently serious.

From the first formal step of the disciplinary procedure there will be the presence of the same Company Director in conjunction with another member of the management team. Employees have the option to have a work colleague or trade union representative present.

At each step in the procedure a disciplinary meeting will be held where all the facts will be considered and any mitigating circumstances discussed. Where a warning is issued a copy will be placed on the employee’s personnel file for the specified period. All warnings issued under this procedure will state clearly that the employee will be liable for further disciplinary action should their performance not improve or should there be a further breach of Company rules. In the event of no further misconduct occurring and the performance improving, the warning will be removed and the employee’s file will be clear. The employee will also be advised of their right to appeal against the decision to take disciplinary action.

The steps in the disciplinary procedure are as follows:

First written warning (step one)

A first written warning will be applied where the matters of concern are substantiated. A record of the first written warning will be given to the employee and a copy will be retained on the personnel file for 6 months unless there is repetition within this period.

Final written warning (step two)

A final written warning will be applied where the matters of concern are substantiated. A record of the final written warning will be given to the employee and a copy will be retained on the personnel file for 6 months unless there is repetition within this period. The employee will be informed that further misconduct within the specified period may result in their dismissal.

Dismissal or action short of dismissal (step three)

An employee will be dismissed if they have failed to improve during the previous steps. In the event of a gross misconduct allegation, the Company may enter the process at step three and dismissal for first offence may occur. Alternatively to dismissal, the Company may decide that suspension without pay, transfer or demotion are appropriate sanctions.

Gross misconduct

The following offences will be viewed by the organisation as gross misconduct:

• unauthorised use of the Company’s assets and equipment

• insubordination e.g. refusal to carry out duties or obey reasonable instructions, except where employee safety may reasonably be in jeopardy

• intentional sexual harassment, harassment, bullying or violent, dangerous or intimidatory conduct

• serious breach of rules, policies or procedures, especially those designed to ensure safe operation

• divulging or misusing confidential information

• theft of fraud

• possession or consumption of alcohol or drugs, or intoxication by reason of alcohol or drugs, which could affect work performance in any way or have an impact on other employees

• unauthorised or inappropriate use of email, internet and/or computer systems

• falsification of any Company records including reports, accounts, expenses claims or self-certification forms

• bringing unauthorised person(s) onto Company premises

This list of examples is not exhaustive or exclusive, and offences of a similar nature will be dealt with under this procedure. Gross misconduct will result in the initiation or escalation of the Company disciplinary procedure, and may result in immediate dismissal without notice or pay in lieu of notice.

Appeals

At every step, the employee has the right to appeal in writing. In all cases of dismissal or demotion, a Company Director will be considered as the final arbiter. If you wish to appeal you should do so in writing within 5 working days of the decision. You will be invited to attend an appeal hearing, after which a decision will be made on whether the disciplinary sanction is to be upheld or overturned. The decision of the appeal panel will be final.

Third parties

We reserve the right to engage an independent third party to assist at any stage of the disciplinary procedure.

Last Updated: January 2020

Scope

The Company believes that its staff members are its most valuable asset and is committed to attracting and retaining the very best talent. It also appreciates that the UK workforce is becoming increasingly diverse and includes a high percentage or parents and individuals with caring responsibilities, as well as those whose interests and aspirations impact on their time.

The Company recognises the importance of helping its employees balance their work and home life by offering flexible working arrangements that enable them to balance their working life with other priorities. In addition, the Company recognises that staffing levels must remain in line with the demands of the business at all times.

This policy aims to set out the ways in which flexible working can increase staff motivation, build better relationships between the Company and its employees, increase the rate of retention of staff, reduce absence, attract new talent, promote work-life balance and reduce employee stress. In doing so, this will improve the Company’s efficiency, productivity and competitiveness.

The business need

Although the Company is committed to providing the widest possible range of working patterns for its workforce, we all need to be realistic and recognise that the full range of flexible working options will not be appropriate for all jobs across all areas of the business.

When a request of flexible working is received, the Company will need to take into account a number of criteria including (but not limited to) the following:

• the cost of the proposed arrangement

• the effect of the proposed arrangement on other staff

• the level of supervision that the post-holder requires

• the structure of the team and staff resources

• other issues specific to the individual’s team

• an analysis of the tasks specific to the role, including their frequency and duration

• an analysis of the workload of the role

• the needs of clients or suppliers in line with project delivery

Eligibility to make a request

Employees must have 26 weeks’ continuous service to make a statutory request for flexible working. Employees must not have made a request for flexible working within 12 months previous to the date of their request.

Employees in all areas and levels of the Company will be considered for flexible working regardless of their age, sex, sexual orientation, race, religion or belief, disability, marital status, pregnancy or maternity, or gender reassignment.

Scope of a request

The Company recognises that eligible employees can make a request for one of, or a combination of, the following:

• job sharing

• part time working

• annualised hours

• compressed hours

• flexitime

• term time working

• swapping hours

• working from home

Any agreement to a request for flexible working will take effect as a permanent variation to the employee’s terms and conditions, unless it is mutually agreed that this will be a temporary variation.

Applying for flexible working

The application must:

• be made in writing and state that it is an application for flexible working under the statutory right to make a request

• state whether a previous application for flexible working has been made under this procedure and, if so, when

• specify the change applied for and the proposed date for the change to become effective

• explain the effect the employee thinks the change will have on the Company and their colleagues and explain how any effect should be handled

• be signed and dated.

The application must also state whether the variation requested is made in pursuance of a reasonable adjustment under the disability discrimination provisions of the Equality Act 2010.

Procedure for handling an application

A discussion regarding the application will be held between the employee and a Company Director within 28 days of the application, unless the Company Director notifies the employee in writing of their agreement to the variation. The time and place of the discussion will be convenient to both the Company Director and the employee.

Once a decision has been reached, the employee will be informed within 14 days of the discussion. Where the decision is to agree to the application, the notice will specify the contract variation agreed to and state the date the variation will take effect.

Where the decision is to refuse the application, the notice will state which of the specified grounds for refusal are considered to apply and contain an explanation of why this ground applies.

An employee may appeal against the decision to refuse the application within 14 days of the decision. The notice of appeal must be in writing, setting out the grounds for appeal and sent to the Company Director.

The Company Director will discuss the appeal with the employee within 14 days after receipt of the appeal, unless the Company notifies the employee in writing of the decision to overturn the original decision and specifies the variation which is now agreed and the date on which it will take effect. If an appeal meeting is held, the time and place must be convenient to both the Company Director and the employee.

Within 14 days of the date of the appeal discussion, the Company Director will give the employee written notice of the appeal decision. Where the Company Director upholds the appeal, the notice will specify the contract variation agreed to and state the date on which it is to take effect.

Where the decision is to dismiss the appeal, the notice will state the grounds for the decision and contain an explanations as to why those grounds apply. The notice will also state that there is no further right of appeal.

An application for flexible working will be concluded within 3 months of the date of the application, unless an extension of time is mutually agreed.

Refusal of an application

The employee will be informed of the refusal of their application in writing.

The application may be refused on one or more of the following statutory grounds:

• a burden of additional cost on the Company

• a detrimental effect on the Company’s ability to meet customer demand

• an inability to re-organise work among existing staff

• an inability to recruit additional staff

• a detrimental effect on quality

• a detrimental effect on performance

• insufficient levels of work during the periods of proposed work

• a planned structural change

Withdrawal of application by employee

The employee can withdraw their application at any stage before agreement. The employee should write to the Company stating they wish to withdraw their application.

Where the employee fails to attend a meeting or appeal meeting on more than one occasion or they refuse to provide reasonable information to allow their application to progress, without reasonable excuse, the Company will treat the application as withdrawn.

The Company will confirm the withdrawal of the application to the employee in writing.

Non-statutory requests for flexible working

Ineligible employees may make an informal request for flexible working. This should be made, in writing, to a Company Director with information of their proposed pattern of working, the date they propose this to take effect, whether this variation is temporary or permanent, and how any negative effects of the proposed working pattern can be managed.

This request will be considered in line with the Company’s operational and staffing needs.

Last Updated: January 2020

Policy Scope

The Company understands that employees may need to be absent from work from time to time due to sickness. This policy covers employees and Company Directors in handling time off from work where the reason for absence is sickness. The Company aims to have as many employees as possible in attendance at all times during the working week and sickness absence needs to be managed so that an acceptable level of absence can be permitted and any problems resolved.

Procedure

Notification

If employees are unable to attend work due to sickness absence, they must notify their team by 09:00 on the morning of the absence and ensure that their sickness is logged on our internal system. They will need to explain why they are unable to attend and indicate when they intend to return to work.

Certification

Absences of eight days or longer should be certified by a Fit Note from a GP, however if the employee is absent for seven calendar days or less in each instance, the employee may instead self-certify their absence.

For absences of seven consecutive calendar days or less, upon their return to work, it may be requested that a self-certification form should be completed and passed to a Company Director.

For absences of eight days or more, a fit note is required. Fit notes are issued by the employee’s GP and should be passed to a Company Director upon their return to work. The fit note should cover each day of absence and, if multiple fit notes are issued, they should be posted to a Company Director with a brief explanation of their absence, the condition and if known their expected return to work date or next GP appointment.

Failure to follow the certification process outlined above may be considered misconduct and may be dealt with under the Company’s disciplinary process. Company sick pay and SSP (statutory sick pay) may be withheld during this time.

Private medical certificates

A private fit note may be considered necessary by the Company is there is a history of unusual absences or if a Company Director believes the employee may benefit from an intervention by a medical practitioner. The cost of obtaining a private fit note will be reimbursed by the Company. A private fit note may be requested by the Company regardless of the duration of the actual period of sickness absence.

Return to work

A fit note may make a recommendation for temporary changes to be made to an employee’s working environment or conditions to facilitate a return to work. The Company may require the employee to meet with a medical practitioner, of the Company’s choosing, to have the fitness to work arrangements of the employee assessed and confirmed.

Where the fit note contains recommendations for changes to be made to working conditions or practices, the Company will consider those recommendations and try as far as possible to accommodation those changes, where permissible in accordance with the needs of the business.

For extended periods of absence, the Company may require the employee to meet with a medical practitioner, of the Company’s choosing, to have the fitness to work arrangements of the employee assessed and confirmed.

In all circumstances, a return to work interview will be arranged by a Company Director for the employee.

The return to work interview will confirm the employee’s fitness to return to work, update the employee on any changes that may have taken place in the workplace whilst absent and confirm that if any necessary support is required, and make arrangements for this as appropriate.

Fit notes

Where a fit note is marked as “may be fit for work” by the employee’s General Practitioner, the GP usually sets out the possible alternations or amendments that could be made to the employee’s working practices to facilitate their fitness for work. Examples of the options available are:

• phased return to work

• amended duties

• altered hours

• workplace adaptations.

A meeting will be arranged for the employee to meet with a Company Director and team member (where relevant) to discuss the arrangements recommended in their fit note and how best the Company can facilitate a return to work.

In the event that adjustments and amendments cannot be made, the employee will not be able to return to work and will need to remain on sickness absence. However, where adjustments and amendments can be facilitated, regular reviews will be undertaken with the employee to confirm that the changes made continue to be adequate. The changes should be temporary and should not be considered permanent changes to the terms and conditions.

Medical examination

If the Company believes that a medical opinion is necessary, the Company reserves the right to require an employee to be referred to a medical practitioner for an assessment to be undertaken.

Access to medical reports

The Company may need to request a copy of an employee’s medical reports or medical records to assist in the assessment of the employee's medical condition. The employee’s consent, in line with requirements under the Access to Medical Reports Act 1988, will be obtained prior to the Company making contact with their GP and the employee is entitled to see a copy of the documentation provided. In line with data protection legislation, employees will also be given details on the reason for the examination, what the Company intends to do with the data obtained and the lawful basis for processing the data.

Long term sickness

Employees should be aware that although the Company is sympathetic towards genuine illnesses, it is not realistic for the sickness-related absence to continue forever. The Company will be eager to get the employee back into the workplace as appropriately and effectively as possible, but the employment may need to be reviewed if this cannot be achieved. There will be a full consultation with the employee, together with a medical investigation and consideration of redeployment or alternative employment.

If there is regular or persistent absence due to long term sickness, injuries etc, the situation is unlikely to be able to continue forever. Ultimately, employment may be terminated after full compliance with the Company’s termination procedures in these circumstances. See the section below in relation to dismissal for more information on this aspect.

The Company will usually require employees who have been absent for one month or more, or are expected to be absent for one month or more, to return some or all of their Company equipment. This may be requested so that the equipment can be redeployed to other employees.

Should a return to work be possible, the Company may require the employee’s current fitness to be determined and confirmed by a medical practitioner, of the Company’s choosing.

Updates during sickness

Employees are expected to keep a Company Director updated with their health and expected date of returning to work.

Company Directors will arrange periodic meetings with the employee to discuss the current situation so that each side is kept up to date with developments.

This will usually be at the employee’s usual place of work but if a home visit is necessary due to serious ill health or being physically unable to attend work, this can be accommodated.

Disability

The Company has a duty to make reasonable adjustments where an employee has a disability covered by the Equality Act 2010.

The duty to make reasonable adjustments covers elements such as making changes and adjustments to working hours, existing equipment, provision of different equipment and workplace practices, if the employee is placed at a substantial disadvantage. It may also involve physical changes, such as to the building entrance points, or alterations to the floor plan, furniture etc.

The employee will be consulted fully on these.

The duty to make the adjustments is ‘reasonable’ so if the suggested adjustment is not viable it will not be made. It may also be the case that no reasonable adjustments are possible to facilitate a return. There may be no alternative roles or employment available and if there is no prospect of the employee being able to return to work in the near future, it may be inevitable that a decision to dismiss is the last and only option.

Dismissal and the right to appeal

If long term sickness absence leads to dismissal, the employee will be provided with the reasons for the dismissal in writing.

The reasons for dismissal should set out the circumstances that led to the decision to dismiss. Employees have the right to appeal the decision and they should do so within five working days, to the named Company Director setting out the reasons for their appeal.

The appeal itself will be dealt with in accordance with the rules on appeals set out in the Company’s disciplinary process.

Payment arrangements and insurance

Statutory sick pay (SSP)

Employees qualify for SSP on Mondays to Fridays for full time employees and their normal working days for part time employees.

SSP payments are made subject to tax and national insurance deductions.

Company sick pay scheme

The Company sick pay scheme provides up to 10 days paid sickness in any 12 month period. Once that allowance is exhausted, you will revert of SSP.

Company sick pay payments are entirely at the discretion of a Company Director. Employees in a probationary period are not entitled to Company sick pay payments.

The sick pay scheme terms and conditions can be varied or revoked upon the giving by the Company of a calendar month’s written notice, to be provided on any significant change to the entitlements and amounts due under the sick pay scheme.

Unpaid sickness

Employees who are not eligible for SSP or for payments under the Company sick pay scheme will take that period of sickness as unpaid. No variable payments and no basic pay shall be made.

Employee’s annual leave entitlement will only accrue at their statutory entitlement under the Working Time Regulations 1998, ie pro rata up to a total of 28 days per annum. This includes public holidays.

Absences for reasons other than sickness

Long term absences for reasons other than sickness, such as career breaks or time off for long distance travel, will be considered by Company Directors at the request of an employee. The request will be considered in line with business needs and operational requirements prior to being authorised.

Unauthorised absences will be dealt with via the Company disciplinary procedure.

Protecting your data

All personal data obtained during sickness absence procedures will be handled with the utmost integrity and confidentiality and in line with our data protection policy. Employees may be reminded of the types of data the Company holds, including data on health, and our practices in relation to that data by reviewing the Company’s privacy notice.

Last updated: January 2020

Policy Scope

The purpose of this policy is to provide employees with a readily accessible procedure for addressing any problems or concerns they may have at work. This procedure should not replace normal cross-team dialogue. However, where such informal dialogue has failed to resolve an issue of concern, then an employee may utilise this procedure in an effort to have an issue resolved to his/her satisfaction.

It is accepted that when people work together there will inevitably be situations where misunderstandings, problems or concerns need to be resolved. It is the policy of the Company that a culture of good communication, openness and a willingness to co-operate and listen will exist. Therefore, it is envisaged that the majority of these issues or misunderstandings will be capable of being addressed informally in an efficient and effective manner. However, where such issues are unresolved they may become grievances. Employees are encouraged to seek resolution of an issue by utilising this procedure.

At each grievance meeting held under the formal procedure, the employee has a right to be accompanied by a colleague or a trade union official.

The grievance procedure should not be used to lodge appeals against disciplinary sanctions. The Company’s disciplinary procedure contains sufficient mechanism for dealing with an employee’s dissatisfaction at a disciplinary sanction applied to them.

The Company reserves the right to engage external third party assistance at any stage of the grievance process. In addition, a Company Director will be present at all formal grievance hearings.

This procedure does not constitute contractual terms and conditions. The Company reserves the right to amend any provision of this procedure subsequent to appropriate consultation.

Procedure

In order to provide an effective and timely resolution of employee concerns, the following procedure will be followed to ensure that employee complaints or problems receive full and careful attention.

Reasonable adjustments will be made to the procedure for disabled employees. Any employee who experiences difficulty with the procedure for any reason should seek assistance from a Company Director.

Informal discussion

Employees are encouraged to approach a Company Director in the first instance to discuss issues and attempt to informally resolve them. Informal discussion can frequently solve problems without the need for written record. Employees will receive an outcome within 7 days.

If an employee is dissatisfied with the outcome, they may invoke the formal grievance procedure.

Formal procedure – Stage One

The employee should raise the grievance in writing with a Company Director. This should explain the nature and extent of the grievance and indicate the outcome the employee is looking for.

If the employee’s grievance relates to concerns regarding a Company Director, the employee may enter the procedure directly at stage two.

If the nature of the employee’s grievance is such that the employee would not feel comfortable raising it with a Company Director due to the proximity in which they work, the employee may enter the procedure directly at stage two. Stage two can also be used as the starting point where allegations are made of bullying or discrimination.

Where a concern is of public interest it would fall within the scope of legislation on public interest disclosures (otherwise known as whistleblowing). The Company has a separate Whistleblowing policy which must be followed in this instance.

Under stage one, a meeting will be arranged between a Company Director and the employee. A minute taker will also be present. The employee may be accompanied by a fellow colleague or trade union official. The meeting will be held to discuss the grievance in detail and the employee should take any documents or evidence they have regarding the grievance to the meeting.

The Company Director will complete a full investigation in to the matter. This may involve holding investigation meetings with witnesses, requiring witness statements to be produced and reviewing written evidence. A decision will be taken by the Company Director following the investigation and the grievance will be responded to, in writing, within 10 working days of the meeting being held. The employee will be informed of actions to take if they wish to appeal the outcome.

Minutes of the meeting will be taken and copies will be made available to the employee. A copy of the minutes will be stored under current data protection guidelines.

Appeal – Stage Two

The matter will progress to be heard by an alternative Company Director if the employee is not satisfied with the outcome of Stage one. The employee should write to the Company Director setting out the reasons for their dissatisfaction. Stage two will involve the same procedural steps as stage one, and the outcome will be provided to the employee within 7 days of the hearing. The hearing will be held by an alternative Company Director.

There will be no further appeal after this stage. The Company Director’s decision on the grievance will be final.

Simultaneous grievance and disciplinary matters

The Company will make a decision on how to progress matters when an employee raises a grievance about a disciplinary procedure involving them. ACAS guidance suggests that disciplinary hearings may be suspended for a short duration while the grievance is investigated. The Company will assess the exact nature of the grievance and will have the final say over suspension of a disciplinary procedure.

Extending timescales under the procedure

The timescales outlined in this procedure will be adhered to whenever this is reasonably practicable. There may be extenuating circumstances that are outside of either parties’ control, for example, where a key witness is unavailable or the grievance requires extensive investigation.

Where it is not reasonably practicable to adhere to the deadlines, both parties will discuss and agree any extension to the timelines.

Mediation

The Company reserve the right to seek assistance from external mediators at any stage in the grievance procedure. Where both parties agree to undertake mediation, the grievance process will be suspended whilst this is ongoing.

Protection against detriment

Nothing in this procedure is intended to prevent the employee from raising any concerns they have. Employees who raise concerns under this procedure will not be subject to any detrimental or less favourable treatment as a result of doing so.

Where the grievance is made with malicious intent, the employee will be subject to the Company’s disciplinary procedure.

Last Updated: January 2020

Policy Scope

Whistleblowing is the name given to the disclosure of information about a wrongdoing that the Company is responsible for.

You’re a Whistleblower if you’re a worker and you report certain types of wrongdoing, either because you know or you suspect it. This will usually be something you’ve seen at work. You must genuinely and reasonably believe that the wrongdoing you disclose is in the public interest. This means it must affect others, for example the general public.

As a Whistleblower you are protected by law – you should not be treated unfairly or lose your job because you ‘blow the whistle’. By making a qualifying disclosure, you are protected by The Public Interest Disclosure Act 1998.

You can raise your concern at any time about an incident that happened in the past, is happening now, or you believe will happen in the near future.

Qualifying Disclosures

Certain information is protected by law as “qualifying disclosures”.

You are protected by law if you report any of the following:

• A criminal offence, for example fraud

• Someone’s health and safety is in danger

• Risk or actual damage to the environment

• A miscarriage of justice

• The company is breaking the law, for example does not have the right insurance

• You believe someone is covering up wrongdoing

These acts can be in the past, present or future, so that, for example, a disclosure qualifies if it relates to environmental damage that has happened, is happening, or is likely to happen.

The Company will take any concerns that you may raise relating to the above matters very seriously and we encourage you to use the procedure below to raise any concerns.

Should the concern not meet the requirement to be a qualifying disclosure, you should raise this under the Company’s grievance policy. It will be confirmed by a Company Director if this is the case.

Personal grievances (for example bullying, harassment, discrimination) are not covered by whistleblowing law, unless your particular case is in the public interest.

Procedure

Reporting a Concern

In the first instance you should report any concerns you may have to a Company Director. All concerns will be treated in the utmost confidence. You must say straight away if you do not want anyone else to know it was you who raised the concern.

You may be asked to confirm any verbal concerns in writing or to confirm a written record of a verbal report.

Concerns can also be directed to the appropriate organisation or regulatory body with authority for our business area.

Investigation Meeting

Following submission of a disclosure made under this policy, an investigation meeting will be held with the person who has made the report to listen to their concerns, gather information (including whether they have any supporting evidence or can identify any witnesses) and decide if any action is needed. This meeting will be held within 7 working days following receipt of the disclosure.

After this meeting, the investigating Director will conduct a full investigation into the concerns raised. The investigation will aim to gather all relevant information including relevant documentary evidence or witness statements.

This investigation will be completed within 4 weeks following receipt of the disclosure. If this is not possible, the investigating Director will speak to the employee in advance of the completion deadline to agree an extended period of investigation.

Once the investigation is complete, the investigation Director will write to the employee confirming the outcome.

Appeals

If the employee is not satisfied with the explanation or outcome, they may raise the matter with the appropriate official organisation or regulatory body. Alternatively, employees may raise a formal complaint under the Company’s grievance policy.

Formal action

Should formal action be required as a result of any disclosure made under this policy, this action will be carried out in accordance with the applicable internal policy. Any potential sanctions imposed will be fair and reasonable in line with the relevant policy.

Protection against detrimental treatment

All employees who raise matters of concern under this policy are protected against detrimental treatment, up to and including dismissal, because they have made a disclosure.

Bullying, harassment or any other detrimental treatment afforded to a colleague who has made a qualifying disclosure is unacceptable. Anyone found to have acted in such a manner will be subject to disciplinary action.

Last Updated: January 2020

This document outlines our approach and commitment to Health & Safety in the workplace and demonstrates the responsibilities of all those involved.

Health and Policy Statement

• Nothing we do at Double Retail is more important than health and safety. Creating and maintaining a safe and healthy workplace is fundamental to the success of Double Retail. We are committed to working in a way that protects the health, safety and welfare of employees and others affected by our activities.

• The company is committed to achieving continuous improvement in health and safety. All accidents and ill health will be learned from and actions and precautions put in place to prevent them happening again in the future.

• Everyone will be proactive and provide leadership in health and safety. All employees are accountable for the safety of their areas. This includes their operations, staff, contractors and visitors. Everyone should lead by example.

• We all have a responsibility for our own safety and that of our colleagues. Employees will be involved in the continuous improvement of the arrangements in place to ensure their safety.

To achieve our goals in health and safety we will:

• Provide a healthy and safe working environment.

• Provide suitable resources (including financial) to maintain policy achievement.

• Be proactive in assessing and reducing risk.

• Investigate accidents and incidents with the potential to cause harm, implementing actions to prevent recurrence. We will prioritise the removal of root causes.

• Provide safe systems of work (where necessary), that are workable in practice.

• Consult with our workforce through regular meetings.

• Provide adequate welfare facilities and occupational health support.

• Ensure competent staff. Provide information, instruction and training to this end.

The health and safety policy will be reviewed at least annually.

Laura Templeton-Cox - Director

Date: 15.01.2020

Health and Safety Responsibilities

Laura Templeton-Cox is ultimately responsible and accountable for Health and Safety within Double Retail. As the implementation of this policy progresses, other individuals will be identified with specific policy area implementation responsibilities.

Whilst Laura Templeton-Cox will be involved in all areas of this policy, this does not replace the responsibility all employees have towards their own safety and the safety of others. Employees responsibilities are covered later in this policy.

Responsibilities specially include:

Implementation

Ensuring that health and safety is managed through the implementation of the health and safety policy. Setting objectives that are integrated into all areas of the business and monitoring the effectiveness and attainment of those objectives. Delegation

Ensuring that those to whom health and safety responsibilities are delegated fully understand and are able to meet them.

Insurance

Arranging and maintaining suitable Employer’s Liability insurance and displaying of the current insurance certificate.

Risk Assessment

Ensuring that appropriate risk assessment techniques are used to identify hazards and those who might be exposed to them; to assess the risks and determine whether the risks are adequately controlled and what further action might be necessary to achieve adequate control.

Safe Environment

The promotion of a safe working environment including fire prevention by the adoption of management procedures such that hazards are identified, risks evaluated and any appropriate steps taken to ensure that suitable safeguards are in place where risks cannot be eliminated.

Information and communication

• Communicating relevant health and safety issues with all staff to ensure that the risk of injury from any potential hazard identified within the workplace is maintained at an acceptable level.

• The establishment of mechanisms for the effective joint consultation on safety, health and environment related matters with employees.

• Maintaining sufficient consultations with employees.

• The preparation of practical advice and guidance on key aspects of safety, health and environment at work based upon known risks and communication to those to whom it applies.

• Ensuring that health and safety issues are reported to the appropriate and employees.

• Maintenance of a Health and Safety information source on Wrike with general and specific safety information.

• Positioning of a Health and Safety Law poster available for all employees.

• The preparation of practical advice and guidance on key aspects of safety, health and environment at work, based upon known risks and communication to those to whom it applies.

Training

The identification and provision of appropriate instruction on health and safety at work and, where necessary, training programmes to provide the necessary knowledge and skills to attain individual competence for safe working.

Monitoring work activities and allocation of duties to ensure that employees are not expected to complete any activities for which they have not received suitable training.

Safe Systems of Work

The preparation and approval of formal practical procedures, where necessary, to assist in safe working with review and amendment as necessary and appropriate monitoring of their application.

Accident Reporting and Investigation

The recording and investigation of all accidents and incidents. The reporting of accidents, industrial diseases and dangerous occurrences as defined under RIDDOR. The development of corrective actions and risk assessment review following any accident or incident.

Fire Safety Management

Give due consideration to fire safety, taking into consideration; premises, occupants and activities. Ensure a current fire risk assessment is in place.

Ensure maintenance and testing of any fire safety equipment and systems.

The implementation of a suitable management system to monitor and maintain fire safety.

Absence monitoring

Keeping in contact with employees absent from work due to an injury or illness relating to work activities.

First aid

Ensuring there are suitable numbers of sufficiently qualified first aiders, and that there are adequate first aid facilities.

Welfare facilities

Ensuring that there is provision for adequate welfare facilities, including rest and eating facilities away from the workplace and sufficient breaks are taken.

The availability of potable drinking water.

The availability of hot water for personal hygiene purposes.

Resource availability

To ensure suitable resources are available (including financial), to allow the maintenance of suitably trained personnel, a safe environment and external expertise where required.

New Equipment and Processes

Compliance with appropriate standards of health and safety in the design and installation of all new facilities, manufacturing or otherwise.

Compliance with the provision and use of workplace equipment regulations (PUWER), where work equipment is required and provided for work activities.

Records

Maintaining suitable records to demonstrate compliance and implementation of this health and safety policy. Records would cover areas such as; accidents at work (including near misses); safe workplace checks; fore safety checks; servicing and maintenance of equipment; health surveillance where required.

Health and Safety Audits

To ensure that regular health and safety audits are carried out to identify risks, monitor standards and procedures and to review implementation of health and safety policies.

To take appropriate action where audits show policies are ineffectual or not implemented.

Contractors

Assessing suitability of contractors and maintenance of a contractor register.

Implementing and monitoring the application of the policy to the safety and health aspects of contractor activity.

Visitors and the General Public

Establishing and implementing measures to safeguard the public from risks to their safety and health arising from activities in areas under the control of the business.

Emergency Procedures

Ensuring that written emergency procedures in place.

Ensuring all relevant personnel are aware of emergency procedures and any duty or duties they may have.

Maintenance

Ensuring that there are systems in place for the maintenance of plant, machines, equipment and buildings.

Control of Substances Hazardous to Health. (COSHH).

Maintenance of current Safety Data Sheets for all substances used within the workplace or during work activities.

Completion of COSHH risk assessments where necessary related to use of substances.

Personal Protective Equipment (PPE)

Where risk assessments have identified the need for PPE, this will be provided by the Double Retail. PPE will be provided based on its suitability and ease of use rather than price. Employees will be expected use PPE where it has been deemed necessary and maintain it in good condition. Damaged or faulty PPE should be reported to their immediate manager.

Employee Responsibilities

All employees are responsible for their own health and safety and for:

• Assisting Double Retail in meeting its legal objectives through compliance with the health and safety policy and procedures;

• Bringing to the attention of the Laura Templeton-Cox any safety and health issues in the workplace.

• Undertaking their work in a safe manner having due regard for their own health and safety and that of others who may be affected by their acts and omissions;

• Following health and safety rules etc. at all times;

Employees must also note that:

• Failure to follow the appropriate rules is an offence under health & safety legislation and could render the employee liable to disciplinary action;

• It is important that employees do not attempt to undertake work for which they are not received adequate training, or, for which the instructions are agreed to be inadequate.

Hallaran Health and Safety Compliance

The Management of Health and Safety at Work Regulations 1999, regulation 7, requires that every employer appoint one or more competent persons to assist them with the implementation and provision of health and safety measures.

Hallaran Health and Safety Compliance has been appointed by Double Retail to provide competent assistance and advice as and when required.

Contractors and other non-employees

All contractors and non-employees will be expected to adhere to the requirements of the Double Retail Health and Safety Policy and all site procedures whilst on site engaged in company business.

All such persons must comply at all times with the local health & safety rules etc. as well as those of their parent organisation. Where the local Double Retail site requirement is stricter, this must take precedence. Failure to comply with this requirement will be deemed to be a serious breach of trust and may result in the contractor or non-employee involved being barred from work on Double Retail premises.

Reporting Structure

Health and Safety Reporting Structure for Double Retail

Health and Safety Management Processes

The general approach to a good health and safety management system is illustrated below. This is the approach adopted by Double Retail. Within this system, the key general elements are:

• Policy: A statement of the key objectives of the organisation signed by its most senior officer.

• Organisation: Identification of the management structure for the delivery of good health and safety performance. This will also identify the specific responsibilities/accountabilities of key post holders and (in more general terms) all employees, contractors and other non-employees.

• Planning & Implementation: A series of policies and procedures regarding how the organisation will deliver particular aspects of health & safety management. Typically, this will include the processes for undertaking risk assessments (generally and for specific issues such as COSHH, DSE, Manual Handling etc), learning from accidents, training requirements etc.

• Measuring & Reviewing Performance: How well is the organisation doing? This aspect is key to ensuring continuous improvement. It should include routine workplace inspections and feedback, the actual measures to be used and the setting of improvement targets, objectives and KPI’s.

• Audit: should be a continuing theme – from regular local audits through to audits by our external adviser.

This system will be delivered through the Plan, Do, Check, Act principles promoted by the Health and Safety Executive: Actions involved in delivering effective arrangements

(Source: Indg275 HSE).

Last Updated: January 2020

Maternity policy

Policy statement

At Double, we endeavour to ensure all women are given support and encouragement before, during, and on return to work from maternity leave.

We aim to ensure that the employee’s duties are adequately covered during maternity leave and that an effective dialogue is implemented at all stages so that employees feel fully informed about both their entitlements and the process.

All employees taking maternity leave are covered by this policy, including those on part-time contracts.

Maternity leave

Please notify us as soon as possible of your pregnancy to enable us to ensure that, where appropriate, any reasonable steps are taken to ensure the safety of yourself and your unborn child and that you are not subject to any unnecessary risks.

To qualify for maternity leave we require that you notify us in writing of your pregnancy, your expected week of childbirth (EWC) and the date on which you intend your ordinary maternity leave period to start, which can be any time from the 11th week before the EWC.

You should also give your MATB1 form to a Company Director. You would normally be given this at around the 20-week stage.

An informal meeting will then be arranged with a Company Director so that they ensure you are aware of all your entitlements and the processes involved. The meeting will include discussion on the following points:

• the amount of leave you can take and the payment arrangements

• the information that we will need from you to process your maternity leave

• time off for antenatal appointments

• risk assessments to ensure your role does not pose a risk to your, or your baby’s, health and safety

• your right to return after maternity leave to the same or a similar role

• the opportunity to request flexible working and how a request should be made

In order to ensure good communication and a smooth transition in the time leading up to maternity leave, and during the leave itself, you will be informed of the arrangements for covering your work and also for remaining in contact whilst you are on leave. We will ask you for your ideas on how best your workload can be covered during your leave and also on any temporary reporting arrangements while you are on leave.

We would like to keep you fully informed of any news or developments at work during your leave and so you will normally continue to receive Company updates via calls or emails and information on social events etc. We will also keep you informed of any recruitment exercises undertaken during your absence.

Time off for antenatal care

You are entitled to paid time off during normal working hours to receive antenatal care. Antenatal care can include not only medical examinations, but also relaxation and parent-craft classes.

Other than for the first appointment, you may be asked to provide an appointment card to a Company Director for our records.

You will receive full pay for the time taken to attend these appointments.

Length of maternity leave

You are entitled to 52 weeks’ maternity leave in total, broken down as follows:

• 26 weeks’ Ordinary Maternity Leave.

• Additional Maternity Leave that starts immediately after Ordinary Maternity Leave and continues for a further 26 weeks.

When does your maternity leave start?

You can start maternity leave between the beginning of the 11th week before the EWC and the day of the birth and you must notify us of the date you wish to start maternity leave. You may then change the date you wish maternity leave to start by giving us at least 28 days’ notice, provided that you have complied with the notification requirements set out below. Any application for a date change should be made in writing to a Company Director.

Compulsory maternity leave commences on the day after the childbirth occurs. Its purpose is to ensure that you have at least a two-week period (four weeks for factory workers) leave after the birth of your baby.

There are two incidences in which the maternity leave period is triggered automatically:

• Where childbirth occurs before the maternity leave period would otherwise commence. If this occurs, please notify us as soon as possible after the birth, of the date on which you gave birth. Your maternity leave period will begin automatically on the day following the date of the birth.

• If you are absent from work, wholly or partly due to your pregnancy, after the beginning of the fourth week before the EWC. In this circumstance, the Company may require that your maternity leave period begins on the day following the first day of such absence.

If you are absent from work, wholly or partly because of pregnancy, on the first day of the 4 weeks leading up to the EWC, your ordinary maternity leave will begin automatically the following day.

You do not need to notify us that you want your maternity leave to start, but you must notify a Company Director in writing as soon as possible that you are absent from work due to pregnancy, and the date your absence began.

If you give birth before your ordinary maternity leave has started, your leave will begin automatically the following day.

Once you have notified a Company Director of your intended start date or that your ordinary maternity leave period has been triggered due to premature absence or premature childbirth, we will confirm to you within 28 days the date that we expect you to return to work after additional maternity leave has ended.

Length of maternity leave

You are entitled to take 26 weeks’ ordinary maternity leave followed by 26 weeks’ additional maternity leave. This is irrespective of your length of service or the number of hours worked each week, provided you follow the notification requirements set out above. The initial two week period (four weeks for factory workers) after the birth of your child is compulsory leave and must be taken.

Unless you notify us that you wish to take a shorter period, the Company will automatically assume you are taking your full entitlement to 52 weeks, and write to you to confirm your expected return date.

Stillbirth and miscarriage

If you experience a miscarriage before 24 weeks of pregnancy, you will no longer be entitled to take maternity leave. It is anticipated that an employee may need some time off work in these circumstances and this will usually be taken as sick leave, during which the Company’s sickness absence policy will apply.

If you suffer a stillbirth after 24 weeks of pregnancy, your entitlement to maternity leave and pay will not be affected and you will still be able to take the time off, and receive pay, as planned.

Health and safety

So that we may assess any potential risk that your role poses to your health and safety, and the health and safety of your baby, you must notify a Company Director as soon as you are aware that you are pregnant. A Health and Safety Risk Assessment will be undertaken and action taken to eliminate any risk.

This may include making adjustments to your role or, if no adjustments can be identified that will reduce or remove the risk, you will be offered a suitable alternative role for the duration of your pregnancy. In the event that alternative work cannot be found, we reserve the right to place you on suspension on full pay until you are no longer at risk. If necessary, these arrangements will continue for a period of six months after the birth of your child.

Please speak with a Company Director immediately if you are worried about your own health and safety at any time.

Returning to work

If you return to work at the end of your ordinary maternity leave you are entitled to return to the same job, with the same terms and conditions, in which you were employed before your absence.

If you return to work after a period of additional maternity leave, you are entitled to return to the same job in which you were employed before your absence or, if that is not reasonably practicable, to another job which is both suitable and appropriate for you in the circumstances on terms no less favourable.

If you are made redundant during maternity leave, you will be offered a suitable alternative role.

Unless you state otherwise, it will be automatically assumed that you will return to work at the end of your full 52 week leave period. So that we may make effective plans for your return, we would be grateful if you would contact us shortly before your return. However, there is no obligation on you to do so unless you wish to change the date of your return, in which case you must give us eight weeks’ notice.

If you qualify for shared parental leave and wish to return early from maternity leave for this purpose, you must also give us eight weeks’ notice. You can find more information on this in our shared parental leave policy.

You may be invited to attend an informal meeting with a Company Director in order to discuss any arrangements regarding your return to work. This is likely to take place approximately two weeks before your return. The following points will be discussed at this meeting:

• any developments that have taken place at work

• any training which it may be appropriate to have in light of any developments

• any flexible working arrangements which have been agreed.

If you decide that you do not wish to return to work after your maternity leave, you are required to give us notice of your resignation and this amount is set out in your contract of employment. The Company will require repayment of any contractual maternity pay in excess of your statutory entitlement that you have received during maternity leave.

If you are unable to return on the agreed date due to sickness, please inform a Company Director immediately.

Flexible working

We recognise that women returning from maternity leave may wish to reduce their working hours or undertake homeworking.

We will make every effort to accommodate requests for part‑time working, provided that your duties can still be effectively carried out on such a basis. However, we must also take into account the needs of the business when assessing and granting any requests.

Any flexible working request should be made in line with the process set out in the flexible working policy.

Breastfeeding Mothers

We understand that some women will still be breastfeeding when they return to work and aim to make mothers feel comfortable should they wish to either breastfeed their babies at work or express milk for use later. Returning to work does not mean that you have to stop breastfeeding.

We commit to providing all breastfeeding mothers with:

• breaks for mothers to breastfeed or express milk as required

• a clean, warm, private room for expressing

• a secure, clean fridge to store expressed milk

• flexible working hours to fit in with breastfeeding

Written notification of a request to breastfeed before your return to work will be required to enable us to ensure a healthy and safe environment to support you. We will discuss with you how best to manage your return more easily and effectively with this in mind and what, if any, changes will need to be put in place.

We expect all other employees to respect breastfeeding mothers. Any harassment will not be tolerated and were necessary will be dealt with under the Disciplinary policy.

Maternity pay

Dependent upon your length of service, we offer enhanced Maternity Pay over and above the statutory requirements.

Providing you have been employed by Double for over one year and have passed your probationary period, you will be entitled to receive the following:

• 90% of your average weekly earnings for 6 weeks

• 50% of your average weekly earnings for the following 12 weeks

• Statutory Maternity Pay for the remaining 21 weeks of statutory maternity leave

If you have been employed by Double for less than one year or have not passed your probationary period, you may be entitled to Statutory Maternity Pay. If you do not qualify for such a payment, you may, dependent upon your circumstances, be eligible to receive state Maternity Allowance.

You will qualify for Statutory Maternity Pay (SMP) if you meet the following criteria:

• you have been continuously employed with us for at least 26 weeks’ continuing into the 15th week before the week the baby is due

• your average weekly earnings are not less than the lower earnings limit relevant for National Insurance purposes

• you are still pregnant at the 11th week before the EWC or have given birth by that time and

• you have complied with the relevant notification requirements

The period for which SMP may be paid is called the maternity pay period. The maternity pay period may start at any time from the start of the 11th week before the EWC and can continue for up to 39 weeks, even if you do not intend to return to work.

Payment will be made at the rate of 90% of your average earnings for the first six weeks’ of leave and then up to 33 weeks’ at the Standard Rate of SMP or 90% of your average weekly earnings (whichever is lower).

Your average earnings are calculated based on your earnings in the eight week period before your EWC.

Keeping in touch (KIT) days

You may, by mutual agreement, work for up to 10 days during your maternity leave period (but not during the compulsory maternity leave period) without losing statutory payments for that week, or ending your entitlement to leave.

For this purpose any work carried out on any day, even just an hour's work, is deemed to constitute "a day's work". Any days' work done under this provision will not have the effect of extending the total duration of the maternity leave period.

Contractual benefits

Your normal terms and conditions of employment will continue during your ordinary maternity leave period and your additional maternity leave period, with the exception of pay.

Holidays

You will continue to accrue holidays whilst you are on maternity leave. As these holidays cannot be taken whilst you are on maternity leave, it is important for us to discuss and agree the arrangements for the taking of these holidays.

Holiday entitlement accrued during maternity leave

At the pre-maternity leave interview, we will discuss and agree with you your intentions for taking holiday around maternity leave. This could include taking an amount of holiday before both before and after maternity leave, effectively increasing the amount of time off the employee takes at once.

Grievances related to maternity rights

The Company Grievance procedure may be used in the event that you are dissatisfied with any decision made in respect of your maternity rights.

Shared Parental Leave

You may be entitled to take shared parental leave and you should refer to our shared parental leave policy for further information on entitlements, eligibility and notice requirements.

Last Updated: January 2020

Policy and procedure on arranging maternity leave cover

Policy purpose

This policy sets out the Company’s stance on making provision for the cover of an employee’s duties whilst they are on maternity leave. The benefits of this are twofold: the operations of the Company will be maintained during the employee’s absence and the employee will experience a smooth and effective transition on her return to work.

Allocation of tasks

Upon being notified of an employee’s pregnancy, a Company Director will undertake necessary checks into the employee’s role to identify how, and by whom, the duties can be covered during maternity leave. There are several options available when considering how to allocate work. These include:

• providing training and assistance to other members of staff to carry out the employee’s duties

• reallocating work to other members of staff who are currently capable of undertaking the tasks

• making arrangements for a temporary replacement, which may include a secondment

The following procedure will apply in the event that:

• the employee’s duties are to be covered by other employees, or

• an employee is to be temporarily transferred on a secondment in the role.

A decision will be taken by the team in association with a Company Director to find a suitable temporary replacement by assessing the following factors:

• necessary capabilities

• experience

• capacity

• development opportunities

• associated costs

• impact on the business.

Handover plan

A plan will be put in place for the transfer of duties to the employee or employees covering the role. This will include a handover plan which will be discussed with the employee before her leave begins. The handover plan will contain details on the following:

• the employee’s current duties, workload and deadlines

• projects that are known to be taking place during the absence

• areas of work that can be undertaken by others

• names of those who are to cover the duties and how the duties will be done

• plans for the employee’s transition back in to work when the maternity leave comes to an end.

Flexibility will be built into the plan in case the employee decides to return to work earlier than planned. Employees on maternity leave should give as much notice of an early return as possible and, in any event, at least eight weeks’ notice.

Training and support

Any training or assistance required by members of staff covering the employee’s role will be provided by the employee and other team members during the handover period.

Absence immediately following leave

Absence following maternity leave for reasons such as sickness, scheduled annual leave or parental leave must be notified to the Company as early as possible before the employee’s expected return date. This will ensure the Company can make any necessary plans to cover the employee’s role for this continued period of absence.

Resigning following leave

An employee may wish to resign at the end of their maternity leave period. Written notice of the employee’s intention to resign must be sent to a Company Director.

Last Updated: January 2020

Paternity leave policy

The Company endeavours to provide help and assistance to employees who wish to use their right to take paternity leave. This policy outlines paternity leave entitlements and how employees should arrange this period of leave.

Eligibility

Paternity leave following the birth of a child

You will meet the eligibility criteria for paternity leave if you:

• are the child’s father, the mother’s husband or partner (whether of the same or different sex) or one partner in a couple who are both entitled to apply for, and propose to apply for, a Parental Order for the child

• have been employed and performed work for your employer for a minimum period of 26 weeks by the end of the 15th week before the expected week of childbirth (EWC)

• will be or expect to be responsible for the child’s upbringing, where you are the father, or expect to be mainly responsible for the child’s upbringing where you are the mother’s husband or partner but not the father of the child

• have given the required notice of your intention to take leave

• have not previously taken shared parental leave for the same child.

Paternity leave following adoption

You will be eligible for paternity leave and pay on the adoption of a child if you:

• will be or expect to be mainly responsible for the child’s upbringing

• are married to the child’s adopter or the partner of the child’s adopter (whether of the same or different sex)

• have been employed and performed work for your employer for a minimum period of 26 weeks by the end of the week the matching notification is given to the child’s adopter

• have given the required notice of your intention to take leave and, where requested, have provided evidence

• have not previously taken shared parental leave for the same child.

When does paternity leave start?

Paternity leave lasts for a fixed period of one week or two consecutive weeks. You may not take individual days or separate weeks as paternity leave. Leave can be chosen to start:

• from the birth date or date of adoption (whether this date is sooner or later than anticipated) or

• on a specific day after the birth date or date of adoption (whether this day is sooner or later than anticipated) or

• from a specific date that is after the first day of the EWC (in birth cases and not adoption) or

• on a specific date, arranged in advance, that is after the expected placement date (in adoption cases).

If the child is born earlier than expected before the EWC, paternity leave must be taken:

• within a period of 56 days from that date or

• within a period of 56 days from the child’s actual birth date.

If the same pregnancy results in more than one child being born, or more than one child is adopted in the same arrangement, the entitlement to paternity leave does not increase and only one period of leave can be taken.

Notification requirements

Paternity leave following the birth of a child

Unless not reasonably practicable, your intention to utilise a period of paternity leave must be notified to the Company during or before the 15th week before the EWC. A Company Director must be informed, in writing, of:

• the anticipated week of birth

• whether you intend to use one or two weeks’ leave

• the date you wish the leave to begin.

As soon as reasonably practicable after birth, you must notify us of the actual date of birth in writing.

A signed declaration stating you intend to utilise a period of paternity leave to care for a child or provide support to the mother of the child and that you meet the eligibility criteria for the leave may be requested.

If you wish to change the date of your paternity leave after giving notice, you must provide an additional written notice requesting a variation to the leave. This notice must be provided at least 28 days in advance of the new start date of the leave period.

Paternity leave following the adoption of a child

Unless not reasonably practicable, your intention to utilise a period of paternity leave must be notified to the Company within seven days of the date the matching notification is given to the child’s adopter. Where this is not reasonable practicable, the notification must be provided to the Company as soon as possible. A Company Director must be informed, in writing, of:

• the date the matching notification was given to the child’s adopter

• the expected date of placement

• whether you intend to use one or two weeks’ leave

• the date you wish the leave to begin.

Paternity pay

Dependent upon your length of service, we offer enhanced Paternity Pay over and above the statutory requirements.

Providing you have been employed by Double for over one year and have passed your probationary period, you will be entitled to receive your full rate of pay for the duration of the Paternity Leave.

If you have been employed by Double for less than one year or have not passed your probationary period, you may be entitled to receive statutory paternity pay (SPP) from the Company for the period of paternity leave. SPP is paid at a specific rate set by the government each tax year, or at 90 per cent of your average weekly during the relevant period, whichever is lower. For details of the current SPP rate, please contact a Company Director who will provide further information.

In order to meet the eligibility criteria for SPP, average weekly earnings for the relevant period must be equal to or higher than the specific lower earnings limit set by the government each tax year.

The relevant period is:

• the period of eight weeks which ends immediately before the 14th week before the EWC (in birth cases) or

• the period of eight weeks which ends immediately before the week where the matching notification was given to the child’s adopter (in adoption cases).

Dependent on your individual circumstances, you may be entitled to receive additional financial support. You should attend your local social security office (Department for Work and Pensions) to receive further information on this.

Contractual benefits

Whilst on paternity leave, you continue to be entitled to receive your normal terms and conditions of employment, other than wages or salary (unless expressly stated otherwise in your employment contract). You may be entitled to receive payment of statutory paternity pay for this period, as set out above.

Your contract of employment continues during paternity leave. As such, any contractual obligations continue to apply during your leave and you remain bound by these.

Returning to work

Following two weeks’ paternity leave, you have the right to come back to the same job role. The act of requesting or taking paternity leave will not cause you to suffer any disadvantage in the workplace.

If you wish to change your working hours following paternity leave, the Company will consider each request on its individual facts in line with the Company’s Flexible Working Policy. A copy of this policy is available from a Company Director. The Company Directors will fully consider your request and aim, wherever possible, to accommodate the change. The business needs will be assessed as part of this consideration and requests may be turned down where this as a business reason to do so. Requests should be submitted as far in advance as possible to allow the full consideration process to take place as early as possible.

You should discuss with a Company Director, as early as possible, where you are planning on not returning to work. Resignation should be notified to a Company Director, in writing, as set out in your employment contract. Following notification of your resignation, Company agreement is needed to withdraw this. Any payments of statutory paternity pay will not be altered by your resignation.

Shared parental leave

Following paternity leave, you may be entitled to take further periods of leave under the shared parental leave scheme. Full details on shared parental leave, including how to apply, can be requested from a Company Director.

Once a period of shared parental leave has been taken in respect of a child, paternity leave cannot be taken for the same child.

Last Updated: January 2020

Adoption leave policy

Policy statement

This policy sets out the Company’s entitlements for employees who are adopting a child within the UK, including notification requirements and rights to time off work.

If you are matched for adoption with a child, you may be entitled to either adoption leave or paternity leave. One parent cannot take both periods of leave, and it is up to you and your partner to decide who is the main adopter and so will take adoption leave. The main adopter’s partner may be entitled to pay paternity leave. You may also wish to refer to our Paternity Leave policy.

Main adopters are entitled to a total of 52 weeks’ leave. We have set out below all of your rights and obligations should you be matched for adoption. We would ask that you notify us as soon as possible of your situation so that we can ensure you are fully aware of all your entitlements and obligations.

Time off for adoption appointments

You are entitled to time off to attend adoption appointments in the period between notification of a match and the date of placement. For single adopters or the main adopter in a joint adoption, you are entitled to paid time off to attend up to five appointments, with a maximum of six and a half hours per appointment. The adopter’s partner in a joint adoption will be entitled to unpaid time off to attend up to two appointments.

Where the time is paid, you will be paid at your normal hourly rate for this time.

If the main adopter’s partner wishes to attend more than two adoption appointments, he/she should speak to his/her Company Director who will consider the request at their discretion.

Notification requirements

In order to take time off for adoption appointments, the Company may require employees to provide confirmation of the following to a Company Director;

• that they would like to take either time off and state whether this will be the paid or unpaid entitlement

• the date and time of the appointment

• that the appointment has been arranged by or at the request of the adoption agency.

Eligibility

You are entitled to adoption leave from the commencement of employment. Adoption leave is not available in circumstances where a child is not newly matched for adoption, for example when a step-parent is adopting a partner's child/children. You must have notified the adoption agency of agreement to the placement and of agreement to the date of the placement.

Only one period of leave is available irrespective of whether more than one child is placed for adoption as part of the same arrangement. However, if an additional child is adopted at a later date as a separate agreement then you could qualify again for a separate period of adoption leave.

Ordinary and additional adoption leave

Adoption leave is divided into two categories, 'ordinary' and 'additional'. Each is for 26 weeks, with additional leave following on from ordinary adoption leave, giving 52 weeks leave in total. If you are eligible for ordinary adoption leave you will also qualify automatically for additional adoption leave.

During ordinary adoption leave you are entitled to the benefit of your normal terms and conditions of employment, except wages and salary (unless your contract of employment states otherwise). However, in the majority of cases, you will either be entitled to an enhanced adoption pay package or Statutory Adoption Pay during this period.

During additional adoption leave the employment contract continues and you are entitled to the benefit of their normal terms and conditions of employment, except wages or salary (unless your contract of employment provides otherwise). However, in the majority of cases, you will either be entitled to an enhanced adoption pay package or Statutory Adoption Pay during some of this period.

Commencement of adoption leave

You can choose to start your adoption leave on the date of the child's placement (whether this is earlier or later than was expected), or on a predetermined fixed date no earlier than 14 days before the expected date of placement and no later than the date of placement. Adoption leave can start on any day of the week.

Notification requirements

You are required to give us notice, in writing, of your intention to take adoption leave within seven days of being notified by the adoption agency that you have been matched with a child, unless this is not reasonably practicable. The notice must specify:

• the date the child is expected to be placed with you; and

• the date you want the adoption leave to start.

You should provide the "matching certificate" from the adoption agency. The certificate will include basic information on matching and expected placement dates.

You are able to change your mind about the date on which you want your adoption leave to start providing you inform us at least 28 days in advance, unless this is not reasonably practicable.

We will write to you to notify you of the date on which you are expected to return to work if the full entitlement to adoption leave is taken, within 28 days of the date on which you notified us of your intention to take leave, or, if you have varied the date originally chosen to start adoption leave, within 28 days of the date on which adoption leave began.

Returning to work

If you are returning to work at the end of additional adoption leave, you should simply present yourself for work at the end of that period.

If you intend to return to work before the end of your additional adoption leave, you must give us at least eight weeks’ notice of the date on which you intend to return. If you do not give us eight weeks’ notice, we may postpone your return to a date ensuring that there has been eight weeks’ notice.

Shortly before your return to work, we will be in touch with you to arrange an informal meeting with a Company Director. The aim of this meeting is to discuss your return and to ensure it is as smooth a transition back to work as possible.

You have the right to return:

• with your seniority, pension rights and similar rights

• on terms and conditions no less favourable than those which would have applied if you had not been absent.

You will not be subject to any detriment by the company because you took or sought to take adoption leave.

Keeping In Touch days

You can work for up to 10 days during your adoption leave period without losing statutory payments for that week, or ending your entitlement to leave.

For this purpose, any work carried out on any day, even just an hour's work, is deemed to constitute "a day's work". Any days' work done under this provision will not have the effect of extending the total duration of the adoption leave period.

You will be paid at your normal rate of pay for a KIT day.

Adoption pay

Dependent upon your length of service, we offer enhanced Adoption Pay, for the main adopter, over and above the statutory requirements.

Providing you have been employed by Double for over one year and have passed your probationary period, you will be entitled to receive the following remuneration:

• 90% of your average weekly earnings for 6 weeks

• 50% of your average weekly earnings for the following 12 weeks

• Statutory Maternity Pay for the remaining 21 weeks of statutory maternity leave

If you have been employed by Double for less than one year or have not passed your probationary period, you may be entitled to statutory adoption pay (SAP). If you qualify for SAP this will be paid for the first six weeks at 90% of your normal weekly earnings in the eight week period up to the date of notification of a match, with the remainder paid at the earnings related limit or the statutory rate, whichever is lower. SAP will be paid in the same way as your wages would be paid if you were not on leave. If you do not qualify for such a payment, you may, dependent upon your circumstances, be eligible to receive allowances from the appropriate government departments.

If you are the partner of a main adopter, you may be entitled to Paternity Pay. Please see the paternity pay section for further details on this.

Shared parental leave and pay

You may be entitled to opt in to shared parental leave, sharing up to 50 weeks of leave and up to 37 weeks of pay (subject to availability). If you think you would like to take shared parental leave instead of adoption leave, please speak to a Company Director for more information.

Surrogacy and adoption rights

If you are an intended parent in a surrogacy arrangement who intends to apply for, or has already applied for, a Parental Order you may be entitled to either adoption leave and pay or paternity leave and pay. One parent cannot claim entitlement to both periods of leave and pay, and it is up to you to decide which you wish to claim (subject to eligibility).

You will be entitled to take unpaid time off to accompany the surrogate mother to up to two antenatal appointments, of up to six and a half hours per appointment.

You are entitled to adoption leave from the start date of your employment. This will be for a total of 52 weeks, split in to two periods of “ordinary” and “additional” adoption leave of 26 weeks each.

You are required to give us notice, in writing, of your entitlement to take adoption leave by the 15th week before the expected week of birth. You must also notify us of the actual date of birth as soon as is reasonably practicable after birth.

You should provide documentary evidence - a statutory declaration. This document will state that you have obtained, applied for or intend to apply for a Parental Order in respect of the surrogate child and, where not received, this is expected to be made.

If you have begun a period of adoption leave in respect of a child before approval of a Parental Order, and you are subsequently notified that the application is refused, your adoption leave period will end eight weeks after the week of that notification or the end of the adoption leave period, if that is earlier.

Dependent upon your length of service, you may either be entitled to enhanced Adoption Pay or Statutory Adoption Pay (SAP). If you qualify for SAP this will be paid for the first six weeks at 90% of your normal weekly earnings in the eight week period leading up to the end of the 15th week before the baby is due to be born, with the remainder paid at the earnings related limit or the statutory rate, whichever is lower. SAP will be paid in the same way as your wages would be paid if you were not on leave. If you do not qualify for such a payment, you may, dependent upon your circumstances, be eligible to receive allowances from the appropriate government departments.

A Company Director will be able to offer more information on this.

Dual approved prospective adopters and adoption leave

If you are a dual approved prospective adopter, a local authority foster parent who has a child placed with you with an expectation to adopt that child in accordance with section 22C of the Children Act 1989, you may be entitled to either adoption leave and pay or paternity leave and pay. One parent cannot claim entitlement to both periods of leave and pay, and it is up to you to decide which you wish to claim (subject to eligibility).

You are entitled to adoption leave from the start date of your employment. This will be for a total of 52 weeks, split in to two periods of “ordinary” and “additional” adoption leave of 26 weeks each.

Only one period of leave is available irrespective of whether you go on to adopt the same child or children placed with you under section 22C. However, if an additional child is placed with you under section 22C at a later date as a separate agreement then you could qualify again for a separate period of adoption leave.

You can choose to start your adoption leave on the date of the child's placement (whether this is earlier or later than was expected), or on a predetermined fixed date up to two weeks before the placement of the child and no later than the date of placement. Adoption leave can start on any day of the week.

You are required to give us notice, in writing, of your intention to take adoption leave within seven days of being notified of the child’s placement by the local authority in accordance with section 22C, unless this is not reasonably practicable. The notice must specify:

• the date the child is expected to be placed with you; and

• the date you want the adoption leave to start.

If you have begun a period of adoption leave in respect of a child placed with you under section 22C, and this placement does not proceed to a formal adoption, your adoption leave period will end eight weeks after the child is removed or the end of the adoption leave period, if that is earlier.

Dependent upon your length of service, you may be entitled to either enhanced Adoption Pay or Statutory Adoption Pay (SAP). If you qualify for SAP this will be paid for the first six weeks at 90% of your normal weekly earnings in the eight week period leading up to the date of notification, with the remainder paid at the earnings related limit or the statutory rate, whichever is lower. SAP will be paid in the same way as your wages would be paid if you were not on leave. If you do not qualify for such a payment, you may, dependent upon your circumstances, be eligible to receive allowances from the appropriate government departments.

Please discuss any questions you may have with a Company Director.

Last Updated: January 2020

Parental leave policy

This policy sets out the Company’s parental leave guidelines to its employees who are both natural parents and adoptive parents. Parental leave is available to eligible employees who wish to take time off work to spend with their child, for example, to accompany the child during a planned stay in hospital, or to go on holiday with the child. Statutory parental leave is unpaid leave.

Entitlement

You must meet certain eligibility criteria in order to take statutory parental leave, as follows:

• you must have at least one year’s continuous employment with the Company counted from the date that parental leave would start

• you have or expect to have parental responsibility for the child

• your child is under 18 years of age

• you take the leave before your child’s 18th birthday

• you provide the Company with evidence of eligibility when requested.

The following evidence may be requested from you in order to assess your eligibility for parental leave:

• that you have or expect to have parental responsibility for the child in relation to whom leave will be taken

• the child’s date of birth (in respect of natural parents)

• the date of adoption placement (in respect of adoptive parents)

• the child’s entitlement to disability living allowance (if appropriate) to permit you to take leave in in blocks of one day rather than one week.

Length of leave

Eligible employees will be entitled to take a total of 18 weeks’ leave in relation to each child until the child is 18 years old. No more than four weeks can be taken in relation to each child in one year.

A year is defined as a period of 12 months beginning on the date on which the employee first, or more recently, became entitled to take parental leave in respect of the child in question and each successive period of 12 months beginning on the anniversary of that date.

Leave is to be taken in blocks of whole weeks unless the child in relation to whom leave is taken is disabled in which case leave can be taken as individual days.

Save for in relation to a disabled child in which case leave may be taken in blocks of one day, part of a week counts as a week so that if a full time employee takes three days’ parental leave and then returns to work, one week is deducted from the 18 weeks.

Procedure

You must give a minimum notice period of 21 days before the leave is due to start and you must give notice of the exact day on which you wish leave to start and end. In the case of fathers who want to take parental leave straight after a baby is born or prospective adoptive parents who want to take parental leave straight after a child is placed with them for adoption, 21 days’ notice of the expected week of childbirth or the expected week of adoption must be given.

When the Company receives notice of intention to take parental leave, we may ask for evidence of eligibility as set out above.

The Company reserves the right to postpone a period of parental leave if we believe the operation of the business will be unduly disrupted by the employee’s absence. Leave will not be postponed where it is to be taken on the birth of a child or on the placement of a child for adoption. Where leave is to be postponed, we will discuss the reasons for the postponement with you and confirm in writing the newly agreed dates of leave. Leave will not be postponed for a period longer than six months from the start date of the leave originally requested.

Before taking parental leave

Shortly after we have received a notification from you that you wish to take parental leave, a meeting will be arranged between you and a Company Director. The purpose of this meeting is to discuss:

• your entitlement to parental leave

• the requirements to give appropriate notice

• arrangements to cover your duties in your absence

• your right to return to work

• opportunities for flexible working

• the nature of any appropriate contact during parental leave

• the fact that parental leave is unpaid

During parental leave

Your normal terms and conditions will apply during parental leave except for in relation to pay. Specifically:

• your implied obligation of good faith

• notice periods for termination of employment

• disclosure of confidential information

• acceptance of gifts

• whether you are participating in any other business

• disciplinary and grievance procedures

• redundancy pay

We will make arrangements for your duties to be covered for the duration of your leave. We would like to be able to keep you up to date with any developments at work that may affect you or any social events that occur.

Returning to work

Employees returning after an isolated period of parental leave lasting four weeks or less, or after a period of parental leave lasting four weeks or less which consecutively followed another period of statutory leave which did not include any period of additional maternity leave, or additional adoption leave, are entitled to return to the job in which he/she was employed before the absence.

Employees returning to work after a period of parental leave lasting more than four weeks, or after a period of parental leave lasting four weeks or less, which did consecutively follow a period of additional maternity leave or additional adoption leave, are entitled to return from leave to the job in which he/she was employed before the absence or, if that is not reasonably practicable, to another job which is both suitable and appropriate for him/her in the circumstances.

Return to the same job will mean that seniority, pension rights and similar rights are not affected. Terms and conditions will not less favourable than those which would have been applied if you had not been absent.

Last Updated: January 2020

Shared parental leave policy

This policy sets out the Company’s guidelines on employee entitlement to take shared parental leave, an explanation of the available entitlements and the procedures employees should follow in order to take leave. Shared parental leave may be taken in the case of both births and adoptions. This policy uses the word ‘parent’ to describe employees in both birth and adoption circumstances.

Any employee wishing to take shared parental leave should inform a Company Director at the earliest possible opportunity so that their entitlement can be explained to them. Due to the flexibility of the shared parental leave system, it is essential that employees understand the procedural requirements involved in taking such leave.

The essential features of shared parental leave (SPL) are:

• eligible employees will be able to bring maternity leave to an early end and share the remaining leave entitlement

• eligible employees will have a certain amount of flexibility to decide which parent takes leave and when, including being on leave at the same time

• the maximum amount of leave to be shared is 50 weeks

• leave may be taken in minimum blocks of one week

• eligible employees may make up to three requests for leave, including any changes to previously booked leave

• a request for a continuous period of leave becomes fixed

• a request for discontinuous leave is subject to agreement with the Company.

Eligibility requirements

In order to take SPL, both the employee and their partner must meet certain eligibility criteria. You must:

• be the mother, father, or main adopter of the child, or the partner of the mother or main adopter

• have 26 weeks’ service at the end of the 15th week before the expected week of childbirth (EWC)

• have a partner who meets the employment and earnings test (see below)

• share the primary responsibility for the child with the other parent at the time of the birth

• have made the required notifications in respect of their entitlement and have provided the necessary declarations and evidence

• be working for the Company until the week before any leave is taken.

Employment and earnings test

Your partner must have, in the 66 weeks before the EWC, worked for at least 26 weeks and earned on average at least £30 a week in any 13 weeks.

Amount and timing of SPL

Parents cannot take more than 52 weeks of leave in total made up of maternity or adoption leave and shared parental leave, but excluding paternity leave which is a standalone entitlement.

If the mother is entitled to statutory maternity/adoption pay/maternity allowance but not maternity/adoption leave, the maximum number of weeks of shared parental leave to be taken is the remainder of 52 weeks’ minus the number of weeks’ pay received.

Mothers are not able to share compulsory maternity leave entitlement of two weeks (or four weeks if the mother works in a factory environment). This is a statutory requirement enabling the employee to recover from the birth and is to be taken exclusively by her. Correspondingly, adopters may share a maximum of 50 weeks’ leave.

Shared parental leave can only be taken in minimum blocks of one week; it is not possible to take a day’s shared parental leave. The minimum amount that can be taken is one week.

Entitlement to Shared Parental Pay

Shared Parental Pay (ShPP) can be paid to both parents for a maximum of 39 weeks in total. This includes any weeks in which statutory maternity or adoption pay was received, and the timing of pay will be decided between the parents.

To be eligible to receive ShPP, you must:

• have been continuously employed for at least 26 weeks up to and including the “qualifying week” (the 15th week prior to the expected week of childbirth or placement for adoption)

• have average earnings not less than the lower earnings limit calculated over the eight weeks prior to the qualifying week

• comply with the notification requirements.

All ShPP is paid at the lower of the standard rate or 90 per cent of the employee’s normal weekly earnings.

Notification requirements

Notice of entitlement and intention to take leave and pay

At least eight weeks before any leave is to be taken, the employee must provide the following information to a Company Director:

• name of employee

• name of partner

• the start and end dates of maternity/adoption leave (or pay if employee was not entitled to leave)

• the total amount of shared parental leave available

• the expected week of childbirth/placement (or the actual date of birth/placement if this has taken place)

• a non-binding indication of how the employee and their partner think they will split and take shared parental leave.

If you are the mother, you must also provide a signed declaration confirming that you meet the eligibility requirements for taking leave and produce a signed declaration from the other parent confirming:

• his/her name and address

• that he/she meets the eligibility requirements

• that he/she consents to the employee taking the amount of leave it has been notified they intend to take

• that he/she permits the Company to process his/her information and

• that immediate notification will be made if any of the eligibility requirements cease to be met.

Curtailment notice

Maternity/adoption leave must be curtailed (ended early) if shared parental leave is to be taken. The mother/main adopter must inform the Company that maternity/adoption leave will be brought to an end by providing a curtailment notice at the same time as the notice of entitlement is provided. The curtailment notice will give eight weeks’ notice of leave (or pay in the event that the employee is not entitled to leave) being brought to an early end.

A notice of curtailment can only be revoked in the following specific circumstances:

• where it is discovered in the eight weeks following the notice that neither the mother/adopter nor their partner has any entitlement to shared parental leave or pay

• in the event of the death of the partner

• if the notice was given before the birth, and the mother revokes her maternity leave curtailment notice in the six weeks following the birth.

Notice of curtailment must be provided to Jobcentre Plus if the mother is not entitled to maternity pay but instead received maternity allowance.

Notice to take a specific period of SPL and ShPP

Although an indication of leave dates will have been given in previous notices, a period of leave is not fixed (unless stated to the contrary) until a period of leave notice is submitted. A maximum of three period of leave notices are permitted, which will include any notices to amend a period of leave already booked. A period of leave notice gives eight weeks’ notice to the Company that you intend to take leave on the specified dates. The date that leave will start should be given unless the period of leave notice is given before the birth of a child, in which case the start date may be expressed as, for example, ‘two weeks’ after the birth, to last for ‘four weeks’.

You should also indicate in this notice whether you intend to allocate ShPP to the period of leave.

There may be circumstances where the Company permits more than three period of leave notices to be submitted, for example, where the Company asks you to change a period of leave already booked.

It is important that all of the relevant information is provided according to the set timelines. If it is not, the Company cannot guarantee that the leave will be granted.

Confirmation of SPL and ShPP

If you request one continuous block of leave in a period of leave notice, you are entitled to take this period of leave and we will confirm the dates to you in writing.

However, if you request more than one period of leave ie discontinuous blocks of leave in one period of leave notice, the Company will make a decision on whether this can be accommodated. A Company Director will arrange a meeting with you at which the request will be discuss with you. The outcome of the request will be one of the following:

• agreement to the request

• proposal of alternative leave dates or

• refusal of the request.

If no agreement can be reached within two weeks of the period of leave notice being submitted, the default provisions will apply which means you are able to withdraw the request any time up to the 15th day after it was made.

If the request is not withdrawn, you can take the leave in one continuous block to start on the first date of leave specified in the notice. Alternatively, the leave can be taken in one block on a new date notified by you within 19 days of the original request.

Varying a period of leave

Once a period of leave notice has been submitted, you may change the dates on which leave is to be taken by submitting a request to vary a period of leave giving eight weeks’ notice. These notice provisions are waived in the event of an early birth and your leave will start the same length of time after the birth as it would have started had the baby not come early. In this case, notice should be given as soon as reasonably practicable. In all other cases, the following applies:

• in this case notice to vary the start date should be given as soon as reasonably practicable after the birth of the child

• in order to change the start date of leave, you must give eight weeks’ notice counted back from the earlier of either the original date or the new date

• to change the duration of a period of leave, you must give eight weeks’ notice of the original start date

You may also request that a continuous period of leave is separated into a discontinuous period, or that a discontinuous period is consolidated into a continuous period.

Submitting a variation notice will count towards your maximum three notices unless it is made as a result of the child being born earlier or later than the expected week of childbirth.

If you are submitting a variation notice subsequent to a request to do so by the Company, it will not count as one of the maximum three notices.

Evidence requirements

In order for us to verify the information you have provided, you may be required to produce:

• a copy of the child’s birth certificate

• and the name and address of the other parent’s employer

If the other parent is not employed, a declaration must be signed to this effect.

Within 14 days of our receipt of your notice of entitlement in relation to an adoption, you may be required to produce documents from the adoption agency which show the following:

• the adoption agency’s name and address

• the date you were notified of being matched with the child

• the expected date of placement.

Where requested, the information above must be provided within 14 days. Where you are unable to provide a birth certificate because it has not yet been issued, you will be required to sign a declaration to that effect which also includes the date and location of the child’s birth.

‘SPLIT’ days

During shared parental leave, you may work for up to 20 shared parental leave ‘in touch’ days (SPLIT days) without statutory payments being affected. We recognise the benefit of SPLIT days and encourage you to use them, however, they are optional: you are not obliged to use them and we are not obliged to permit them.

You will be paid at normal rate for work on a SPLIT day. Any work done on one day will count as one SPLIT day.

Your entitlement to 20 SPLIT days is not affected by your entitlement to 10 KIT days during maternity or adoption leave.

Terms and conditions during SPL

You will continue to receive all contractual benefits (with the exception of salary) during shared parental leave. For clarity, your holiday entitlement will continue to accrue during SPL in the same way as if you were not absent. Prior to taking your leave, a discussion will take place between you and a Company Director regarding arrangements on taking annual leave around your shared parental leave.

Returning from SPL

Employees who wish to amend the date on which they are to return to work after shared parental leave must give eight weeks’ notice of the original end date and the new end date, whichever is earlier.

After SPL, provided the total amount of leave taken by you (including maternity leave) does not exceed 26 weeks, you are entitled to return to the same job on the same terms and conditions of employment as if they had not been absent.

When you are considering your return to work, for reasons related to childcare, you may request a change to your previous working arrangements. Any such request will be considered in line with the operational requirements of the Company and there is no automatic right to return to work on altered conditions.

Last Updated: January 2020