Company Policies

UK Manufacturing Media Ltd

Company Policies

Updated December 2023

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SCHEDULE

Schedule 1       Diversity, equity and inclusion policy
Schedule 2       Anti-harassment and bullying policy
Schedule 3       Anti-corruption and bribery policy
Schedule 4       Whistleblowing policy
Schedule 5       Anti-Slavery Policy
Schedule 6       Health and safety policy
Schedule 7       Environment and Sustainability Policy
Schedule 8       Safeguarding Policy

Diversity, equity and inclusion policy

  1. Our commitments

We are committed to promoting equal opportunities in employment and creating a workplace culture in which diversity and inclusion is valued and everyone is treated with dignity and respect. As part of our zero-tolerance approach to discrimination in any form, you and any job applicants will receive equal treatment regardless of age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation (Protected Characteristics). We are also committed to providing equitable treatment to all those we deal with as an organisation, including customers and suppliers.

  1. About this policy

This policy sets out our approach to diversity, equity and inclusion. Our aim is to encourage and support diversity, equity and inclusion and actively promote a culture that values difference and eliminates discrimination in our workplace. It applies to all aspects of employment with us, including recruitment, pay, benefits and conditions, flexible working and leave, training, appraisals, promotion, conduct at work, disciplinary and grievance procedures, and termination of employment.

This policy applies to all employees, officers, consultants, contractors, volunteers, interns, casual workers and agency workers.

Neil Hartley is responsible for this policy and will review it annually.

This policy does not form part of any contract of employment or other contract to provide services, and we may amend it at any time.

  1. Diversity and inclusion training

Managers will be given appropriate training on recognising and avoiding discrimination, harassment and victimisation, and promoting equality of opportunity and diversity in the areas of recruitment, development and promotion. Neil Hartley has overall responsibility for equality training, for staff and managers as appropriate.

We will provide you with regular training to ensure that everyone is aware of and understands the contents of this policy [and the Anti-harassment and Bullying Policy]. Following the training, you will be required to confirm that you have read, understand and will comply with this policy [and the Anti-harassment and Bullying Policy].

  1. Discrimination

You must not unlawfully discriminate against or harass other people, including current and former staff, job applicants, clients, customers, suppliers and visitors. This applies in the workplace, outside the workplace (when dealing with customers, suppliers or other work-related contacts [or when wearing a work uniform]), and on work-related trips or events including social events.

The following forms of discrimination are prohibited under this policy and are unlawful:

  • Direct discrimination: treating someone less favourably because of a Protected Characteristic. For example, rejecting a job applicant because of their religious views or because they might be gay.
  • Indirect discrimination: a provision, criterion or practice that applies to everyone but adversely affects people with a particular Protected Characteristic more than others, and is not justified. For example, requiring a job to be done full-time rather than part-time would adversely affect women because they generally have greater childcare commitments than men. Such a requirement would be discriminatory unless it can be justified.
  • Harassment: this includes sexual harassment and other unwanted conduct related to a Protected Characteristic, which has the purpose or effect of violating someone’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. [Harassment is dealt with further in our Anti-harassment and Bullying Policy].
  • Victimisation: retaliation against someone who has complained or has supported someone else’s complaint about discrimination or harassment. This includes where someone mistakenly believes that the person victimised has done so.
  • Disability discrimination: this includes direct and indirect discrimination, any unjustified less favourable treatment because of the effects of a disability, and failure to make reasonable adjustments to alleviate disadvantages caused by a disability.
  1. Recruitment and selection

Recruitment, promotion, and other selection exercises such as redundancy selection will be conducted on the basis of merit, against objective criteria that avoid discrimination. When recruiting or promoting, we will aim to take steps to improve the diversity of our workforce and provide equality of opportunity. Shortlisting [and interviewing] should be done by more than one person where possible. Our recruitment procedures will be reviewed regularly to ensure that individuals are objectively assessed on the basis of their relevant merits and abilities.

Vacancies should generally be advertised to a diverse section of the labour market. Advertisements should avoid stereotyping or using wording that may discourage particular groups from applying. [They should include a short policy statement on equal opportunities and the employer’s commitment to diversity, equity and inclusion in the workplace and state that a copy of this policy will be made available on request.]

Job applicants should not be asked questions which might suggest an intention to discriminate on grounds of a Protected Characteristic. For example, applicants should not be asked whether they are pregnant or planning to have children.

Job applicants should not be asked about health or disability before a job offer is made, except in the very limited circumstances allowed by law: for example, to check that the applicant could perform an intrinsic part of the job (taking account of any reasonable adjustments), or to see if any adjustments might be needed at interview because of a disability. Where necessary, job offers can be made conditional on a satisfactory medical check. Health or disability questions may be included in equal opportunities monitoring forms, which must not be used for selection or decision-making purposes.

We are required by law to ensure that all employees are entitled to work in the UK. Assumptions about immigration status should not be made based on appearance or apparent nationality. All prospective employees, regardless of nationality, must be able to produce original documents (such as a passport) before employment starts, to satisfy current immigration legislation. The list of acceptable documents is available from the HR Department or UK Visas and Immigration.

  1. Disabilities

 If you are disabled or become disabled, we encourage you to tell us about your condition so that we can consider what reasonable adjustments or support may be appropriate.

  1. Part-time and fixed-term work

Part-time and fixed-term staff should be treated the same as comparable full-time or permanent staff and enjoy no less favourable terms and conditions (on a pro-rata basis where appropriate), unless different treatment is justified.

  1. Breaches of this policy

 We take a strict approach to breaches of this policy, which will be dealt with in accordance with our Disciplinary Procedure. Serious cases of deliberate discrimination and victimisation may amount to gross misconduct resulting in dismissal.

If you believe that you have suffered harassment, bullying or discrimination, or witnessed it happening to someone else in the workplace, you can raise the matter [using the procedure set out in this policy] [through our Grievance Procedure] [and through our Anti-harassment and Bullying Policy as appropriate]. Complaints will be treated in confidence and investigated as appropriate.

There must be no victimisation or retaliation against staff who complain about or report discrimination. If you believe you have been victimised for making a complaint or report of discrimination, or have witnessed it happening to someone else in the workplace, you should raise this through [the procedure set out in this policy OR our Grievance Procedure].

We encourage the reporting of all types of potential discrimination, as this assists us in ensuring that diversity, equity and inclusion principles are adhered to in the workplace. However, making a false allegation in bad faith, or that you know to be untrue, will be treated as misconduct and dealt with under our Disciplinary Procedure.

Anti-harassment and bullying policy

  1. About this policy

UK Manufacturing Media Ltd is committed to providing a working environment free from harassment and bullying and ensuring all staff are treated, and treat others, with dignity and respect.

This policy covers harassment or bullying which occurs at work and out of the workplace, such as on business trips or at work-related events or social functions. It covers bullying and harassment by staff (which may include consultants, contractors and agency workers) and also by third parties such as customers, suppliers or visitors to our premises.

This policy does not form part of any employee’s contract of employment and we may amend it at any time.

  1. What is harassment?

Harassment is any unwanted physical, verbal or non-verbal conduct that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. A single incident can amount to harassment.

It also includes treating someone less favourably because they have submitted or refused to submit to such behaviour in the past.

Unlawful harassment may involve conduct of a sexual nature (sexual harassment), or it may be related to age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation. Harassment is unacceptable even if it does not fall within any of these categories.

Harassment may include, for example:

  • unwanted physical conduct or “horseplay”, including touching, pinching, pushing and grabbing;
  • unwelcome sexual advances or suggestive behaviour (which the harasser may perceive as harmless);
  • offensive e-mails, text messages or social media content;
  • mocking, mimicking or belittling a person’s disability.

A person may be harassed even if they were not the intended “target”. For example, a person may be harassed by racist jokes about a different ethnic group if the jokes create an offensive environment.

  1. What is bullying?

Bullying is offensive, intimidating, malicious or insulting behaviour involving the misuse of power that can make a person feel vulnerable, upset, humiliated, undermined or threatened. Power does not always mean being in a position of authority, but can include both personal strength and the power to coerce through fear or intimidation.

Bullying can take the form of physical, verbal and non-verbal conduct. Bullying may include, by way of example:

  • physical or psychological threats;
  • overbearing and intimidating levels of supervision;
  • inappropriate derogatory remarks about someone’s performance;

Legitimate, reasonable and constructive criticism of a worker’s performance or behaviour, or reasonable instructions given to workers in the course of their employment, will not amount to bullying on their own.

  1. If you are being harassed or bullied

If you are being harassed or bullied, consider whether you feel able to raise the problem informally with the person responsible. You should explain clearly to them that their behaviour is not welcome or makes you uncomfortable. If this is too difficult or embarrassing, you should speak to [your line manager OR the Human Resources Department], who can provide confidential advice and assistance in resolving the issue formally or informally.

If informal steps are not appropriate, or have not been successful, you should raise the matter formally under our Grievance Procedure.

We will investigate complaints in a timely and confidential manner. The investigation will be conducted by someone with appropriate experience and no prior involvement in the complaint, where possible. Details of the investigation and the names of the person making the complaint and the person accused must only be disclosed on a “need to know” basis. We will consider whether any steps are necessary to manage any ongoing relationship between you and the person accused during the investigation.

Once the investigation is complete, we will inform you of our decision. If we consider you have been harassed or bullied by an employee the matter will be dealt with under the Disciplinary Procedure as a case of possible misconduct or gross misconduct. If the harasser or bully is a third party such as a customer or other visitor, we will consider what action would be appropriate to deal with the problem. Whether or not your complaint is upheld, we will consider how best to manage any ongoing working relationship between you and the person concerned.

  1. Protection and support for those involved

Staff who make complaints or who participate in good faith in any investigation must not suffer any form of retaliation or victimisation as a result. Anyone found to have retaliated against or victimised someone in this way will be subject to disciplinary action under our Disciplinary Procedure.

  1. Record-keeping

Information about a complaint by or about an employee may be placed on the employee’s personnel file, along with a record of the outcome and of any notes or other documents compiled during the process. [These will be processed in accordance with our Data Protection Policy.]

Anti-corruption and bribery policy

  1. About this policy

It is our policy to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships.

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct. Any non-employee who breaches this policy may have their contract terminated with immediate effect.

This policy does not form part of any employee’s contract of employment and we may amend it at any time. It will be reviewed regularly.

  1. Who must comply with this policy?

This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives and business partners.

  1. What is bribery?

Bribe means a financial or other inducement or reward for action which is illegal, unethical, a breach of trust or improper in any way. Bribes can take the form of money, gifts, loans, fees, hospitality, services, discounts, the award of a contract or any other advantage or benefit.

Bribery includes offering, promising, giving, accepting or seeking a bribe.

All forms of bribery are strictly prohibited. If you are unsure about whether a particular act constitutes bribery, raise it with your manager or [POSITION].

Specifically, you must not:

  • give or offer any payment, gift, hospitality or other benefit in the expectation that a business advantage will be received in return, or to reward any business received;
  • accept any offer from a third party that you know or suspect is made with the expectation that we will provide a business advantage for them or anyone else;
  • give or offer any payment (sometimes called a facilitation payment) to a government official in any country to facilitate or speed up a routine or necessary procedure;

You must not threaten or retaliate against another person who has refused to offer or accept a bribe or who has raised concerns about possible bribery or corruption.

  1. Gifts and hospitality

This policy does not prohibit the giving or accepting of reasonable and appropriate hospitality for legitimate purposes such as building relationships, maintaining our image or reputation, or marketing our products and services.

A gift or hospitality will not be appropriate if it is unduly lavish or extravagant, or could be seen as an inducement or reward for any preferential treatment (for example, during contractual negotiations or a tender process).

Gifts must be of an appropriate type and value depending on the circumstances and taking account of the reason for the gift. Gifts must not include cash or cash equivalent (such as vouchers), or be given in secret. Gifts must be given in our name, not your name.

Promotional gifts of low value such as branded stationery may be given to or accepted from existing customers, suppliers and business partners.

  1. Record-keeping

You must declare and keep a written record of all hospitality or gifts given or received. You must also submit all expenses claims relating to hospitality, gifts or payments to third parties in accordance with our expenses policy and record the reason for expenditure.

All accounts, invoices, and other records relating to dealings with third parties including suppliers and customers should be prepared with strict accuracy and completeness. Accounts must not be kept “off-book” to facilitate or conceal improper payments.

  1. How to raise a concern

If you are offered a bribe, or are asked to make one, or if you suspect that any bribery, corruption or other breach of this policy has occurred or may occur, you must [notify your manager or [POSITION] OR report it in accordance with our Whistleblowing Policy] as soon as possible.

Whistleblowing policy

  1. About this policy

We are committed to conducting our business with honesty and integrity and we expect all staff to maintain high standards. Any suspected wrongdoing should be reported as soon as possible.

This policy covers all employees, officers, consultants, contractors, [volunteers,] [interns,] casual workers and agency workers.

This policy does not form part of any employee’s contract of employment and we may amend it at any time.

  1. What is whistleblowing?

Whistleblowing is the reporting of suspected wrongdoing or dangers in relation to our activities. This includes bribery, facilitation of tax evasion, fraud or other criminal activity, miscarriages of justice, health and safety risks, damage to the environment and any breach of legal or professional obligations. It also includes the following matters specific to this workplace: [ADD ANY OTHER WORKPLACE-SPECIFIC CONCERNS].

  1. How to raise a concern

We hope that in many cases you will be able to raise any concerns with your manager. However, where you prefer not to raise it with your manager for any reason, you should contact the [Whistleblowing Officer ([NAME])] [or the Managing Director ([NAME])]. Contact details are at the end of this policy.

We will arrange a meeting with you as soon as possible to discuss your concern. You may bring a colleague or union representative to any meetings under this policy. Your companion must respect the confidentiality of your disclosure and any subsequent investigation.

  1. Confidentiality

We hope that staff will feel able to voice whistleblowing concerns openly under this policy. Completely anonymous disclosures are difficult to investigate. If you want to raise your concern confidentially, we will make every effort to keep your identity secret and only reveal it where necessary to those involved in investigating your concern.

  1. External disclosures

The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases you should not find it necessary to alert anyone externally.

The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. We strongly encourage you to seek advice before reporting a concern to anyone external. Protect operates a confidential helpline. Their contact details are at the end of this policy.

  1. Protection and support for whistleblowers

We aim to encourage openness and will support whistleblowers who raise genuine concerns under this policy, even if they turn out to be mistaken.

Whistleblowers must not suffer any detrimental treatment as a result of raising a genuine concern. If you believe that you have suffered any such treatment, you should inform [the Whistleblowing Officer OR [POSITION]] immediately. [If the matter is not remedied you should raise it formally using our Grievance Procedure.]

You must not threaten or retaliate against whistleblowers in any way. If you are involved in such conduct you may be subject to disciplinary action. [In some cases the whistleblower could have a right to sue you personally for compensation in an employment tribunal.]

However, if we conclude that a whistleblower has made false allegations maliciously, the whistleblower may be subject to disciplinary action.

Protect operates a confidential helpline. Their contact details are at the end of this policy.

Anti-Slavery Policy

  1. What is modern slavery?

Modern slavery is a crime and a violation of fundamental human rights. It takes many forms, including slavery, servitude, forced and compulsory labour, and human trafficking, all of which involve the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

  1. What is our approach?

UK Manufacturing Media Ltd takes a zero-tolerance approach to modern slavery, and we are committed to acting ethically and with integrity in all of our business dealings and relationships, as well as implementing and enforcing effective systems and controls to ensure modern slavery does not exist anywhere in our own business or in any of our supply chains.

We are also committed to ensuring transparency in our own operations and in our approach to combating modern slavery throughout our supply chains, in accordance with our disclosure obligations under the Modern Slavery Act.

  1. Working with contractors

We expect the same high standards from all of our contractors, suppliers, and other business partners, we will continue to include specific prohibitions against the use of forced, compulsory, or trafficked labour, as well as anyone held in slavery or servitude, whether adults or children, in our contracting processes, and we expect our suppliers to hold their own suppliers to the same high standards.

  1. To whom this policy applies

This policy applies to all individuals who work for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors, external consultants, third-party representatives, and business partners.

This policy is not part of any employee’s employment contract, and we reserve the right to change it at any time.

  1. Policy Responsibilities

UK Manufacturing Media Ltd is ultimately responsible for ensuring that this policy conforms with our legal and ethical commitments, as well as that all people under our control abide by it.

UK Manufacturing Media Ltd is in charge of implementing this policy on a daily basis, monitoring its usage and effectiveness, dealing with any questions about it, and reviewing internal control systems and processes to ensure they are successful in combating modern slavery.

Management at all levels is responsible for ensuring that people reporting to them understand and comply with this policy, as well as that they get proper and ongoing training on it and the subject of modern slavery in supply chains.

Feedback and suggestions for the improvement of this policy are welcomed.

Any comments, suggestions or queries are encouraged and should be addressed to Nick Peters.

  1. Policy Compliance

You must read, understand, and enforce this policy. The prevention, identification, and reporting of modern slavery in any element of our company or supply chains is the duty of everyone who works for us or is under our authority. Refrain from engaging in any action that might lead to or imply a violation of this policy.

If you have reason to believe that a conflict with this policy has occurred, is happening, or may occur in the future, please contact your line manager or a business director as soon as possible. You are urged to express concerns about any issue or suspicion of modern slavery in any aspect of our business or any supplier tier’s supply chain as soon as possible.

Note that where appropriate, and with the welfare and safety of local workers as a priority, we will give support and guidance to our suppliers to help them address coercive, abusive, and exploitative work practices in their own business and supply chains.

If you have any doubts about whether a specific act, the treatment of employees in general, or their working circumstances inside any tier of our supply chains represents any of the numerous types of modern slavery, please contact your line manager or a company director.

We want to promote transparency and will assist anybody who expresses serious concerns in good faith under this policy, even if those worries turn out to be incorrect. We are dedicated to ensuring that no one experiences any adverse treatment as a result of reporting in good faith their concern that modern slavery in any form is or may be occurring in any section of our own business or in any of our supplier networks.

Dismissal, disciplinary action, threats, or other unfavourable treatment as a result of voicing a concern is considered detrimental treatment. If you suspect you have been subjected to such treatment, you should immediately notify your line manager. If the problem is not resolved, and you are an employee, you should file a formal complaint.

  1. Communication & Awareness

Training on this policy, as well as the threat our company faces from modern slavery in its supply chains, is part of the induction process for all new employees, and updates will be offered through established channels of communication between the company and you.

Our zero-tolerance stance to modern slavery must be conveyed to all suppliers, contractors, and business partners from the beginning of our commercial engagement with them and reinforced as needed subsequently.

  1. Policy Breaches

Any employee who violates this policy may face disciplinary action, which might result in dismissal for misconduct. If other persons or organisations working on our behalf violate this policy, we reserve the right to terminate our relationship with them with immediate effect.

 

Health and safety policy

  1. About this policy

This policy sets out our arrangements for ensuring we meet our health and safety obligations to staff and anyone visiting our premises or affected by our work.

Neil Hartley has overall responsibility for health and safety and the operation of this policy.

This policy does not form part of any employee’s contract of employment and we may amend it at any time. We will continue to review this policy to ensure it is achieving its aims.

  1. Your responsibilities

All staff share responsibility for achieving safe working conditions. You must take care of your own health and safety and that of others, observe applicable safety rules and follow instructions for the safe use of equipment.

You should report any health and safety concerns immediately to your line manager or Neil Hartley.

You must co-operate with managers on health and safety matters, including the investigation of any incident.

Failure to comply with this policy may be treated as misconduct and dealt with under our Disciplinary Procedure.

  1. Information and consultation

We will inform and consult your elected workplace safety representatives OR directly with all staff] regarding health and safety matters.

  1. Training

We will ensure that you are given adequate training and supervision to perform your work competently and safely.

Staff will be given a health and safety induction and provided with appropriate safety training, including [manual handling][, control of substances hazardous to health (COSHH)][, working at height][, asbestos awareness][, gas safety][, electrical safety][ and the use of personal protective equipment (PPE)].

  1. Equipment

You must use equipment in accordance with any instructions given to you. Any equipment fault or damage must immediately be reported to your line manager. Do not attempt to repair equipment unless trained to do so.

  1. Accidents and first aid

Details of first aid facilities and the names of trained first aiders are displayed on the notice boards.

All accidents and injuries at work, however minor, should be reported to Neil Hartley and recorded in the Accident Book which is kept in the main office.

  1. Fire safety

All staff should familiarise themselves with the fire safety instructions, which are displayed on notice boards and near fire exits in the workplace.

If you hear a fire alarm, leave the building immediately by the nearest fire exit and go to the fire assembly point [shown on the fire safety notices OR [LOCATION OF FIRE ASSEMBLY POINT]].

Fire drills will be held at least every [12 OR [NUMBER]] months and must be taken seriously. We also carry out regular fire risk assessments and regular checks of fire extinguishers, fire alarms, escape routes and emergency lighting.

  1. Risk assessments and measures to control risk

We carry out general workplace risk assessments periodically. The purpose is to assess the risks to health and safety of employees, visitors and other third parties as a result of our activities, and to identify any measures that need to be taken to control those risks.

  1. Computers and display screen equipment

If you use a computer screen or other display screen equipment (DSE) as a significant part of your work, you are entitled to a workstation assessment and regular eyesight tests by an optician at our expense.

Further information on workstation assessments, eye tests and the use of DSE can be obtained from Neil Hartley.

 

Environment and Sustainability Policy

  1. Preamble

We recognise that our activities have an impact on the environment, most significantly events, travel and procurement. We operate an environmental management system to manage and minimise these impacts and ensure prevention of pollution and legislative compliance. This policy provides the guiding framework for that system and details actions we are taking and our targets for improvement. Working in the environmental sector we also have a responsibility to demonstrate best practice to our customers, suppliers and the wider business community.

  1. Energy

Lights and equipment are switched off when not required and heating controls accurately set. We choose venues with good natural light and set lighting level at events to lowest level practical

  1. Waste

We communicate, invoice, do our banking and store documents electronically

We print only where 100% necessary

Stationary and scrap paper is re-used

Waste paper, card, plastics, metals, glass, batteries and ink cartridges are recycled using licensed waste carriers.

Food waste from our office and events is composted

We avoid single use plastics and disposables such as sugar sachets or individual milk pots

We ask event participants to help minimise waste by not giving out printed materials apart from business cards and we give bags to event participants to take food away at the end

  1. Travel

We travel by public transport to events, site audits and meetings. When this is not possible, we car-share and co-ordinate meetings to minimise the number of journeys required

We select event venues that are easily accessible by public transport

Employees have the option and are provided the equipment to work from home

  1. Procurement

Energy efficiency is a priority when purchasing electronic equipment

Safeguarding Policy

  1. Purpose

The purpose of this policy is to protect people, particularly children, at risk adults and beneficiaries of assistance, from any harm that may be caused due to their coming into contact with UK Manufacturing Media Ltd.  This includes harm arising from:

  • The conduct of staff or personnel associated with UK Manufacturing Media Ltd
  • The design and implementation of UK Manufacturing Media Ltd’s programmes and activities
  • The policy lays out the commitments made by UK Manufacturing Media Ltd, and informs staff and associated personnel[1] of their responsibilities in relation to safeguarding.

This policy does not cover:

  • Sexual harassment in the workplace – this is dealt with under UK Manufacturing Media Ltd’s Anti Bullying and Harassment Policy[2]
  • Safeguarding concerns in the wider community not perpetrated by UK Manufacturing Media Ltd or associated personnel
  1. What is safeguarding?

In the UK, safeguarding means protecting peoples’ health, wellbeing and human rights, and enabling them to live free from harm, abuse and neglect[3]

In our sector, we understand it to mean protecting people, including children and at risk adults, from harm that arises from coming into contact with our staff or programmes.

 Further definitions relating to safeguarding are provided in the glossary below.

  1. Scope

All staff contracted by UK Manufacturing Media Ltd

Associated personnel whilst engaged with work or visits related to UK Manufacturing Media Ltd, including but not limited to the following: consultants; volunteers; contractors; programme visitors including journalists, celebrities and politicians

  1. Policy Statement

UK Manufacturing Media Ltd believes that everyone we come into contact with, regardless of age, gender identity, disability, sexual orientation or ethnic origin has the right to be protected from all forms of harm, abuse, neglect and exploitation.  UK Manufacturing Media Ltd will not tolerate abuse and exploitation by staff or associated personnel.

This policy will address the following areas of safeguarding [as appropriate]:  child safeguarding, adult safeguarding, and protection from sexual exploitation and abuse.  These key areas of safeguarding may have different policies and procedures associated with them (see Associated Policies).

UK Manufacturing Media Ltd commits to addressing safeguarding throughout its work, through the three pillars of prevention, reporting and response.

  1. Prevention

UK Manufacturing Media Ltd will:

Ensure all staff have access to, are familiar with, and know their responsibilities within this policy

Design and undertake all its programmes and activities in a way that protects people from any risk of harm that may arise from their coming into contact with UK Manufacturing Media Ltd.  This includes the way in which information about individuals in our programmes is gathered and communciated

Implement stringent safeguarding procedures when recruiting, managing and deploying staff and associated personnel

Ensure staff receive training on safeguarding at a level commensurate with their role in the organization

Follow up on reports of safeguarding concerns promptly and according to due process

  1. Staff responsibilities

Child safeguarding

UK Manufacturing Media Ltd staff and associated personnel must not:

Engage in sexual activity with anyone under the age of 18

Sexually abuse or exploit children

Subject a child to physical, emotional or psychological abuse, or neglect

Engage in any commercially exploitative activities with children including child labour or trafficking

Adult safeguarding

UK Manufacturing Media Ltd staff and associated personnel must not:

Sexually abuse or exploit at risk adults

Subject an at risk adult to physical, emotional or psychological abuse, or neglect

Protection from sexual exploitation and abuse

UK Manufacturing Media Ltd staff and associated personnel must not:

Exchange money, employment, goods or services for sexual activity. This includes any exchange of assistance that is due to beneficiaries of assistance

Engage in any sexual relationships with beneficiaries of assistance, since they are based on inherently unequal power dynamics

Additionally, UK Manufacturing Media Ltd staff and associated personnel are obliged to:

Contribute to creating and maintaining an environment that prevents safeguarding violations and promotes the implementation of the Safeguarding Policy

Report any concerns or suspicions regarding safeguarding violations by an UK Manufacturing Media Ltd staff member or associated personnel to the appropriate staff member

  1. Enabling reports

UK Manufacturing Media Ltd will ensure that safe, appropriate, accessible means of reporting safeguarding concerns are made available to staff and the communities we work with.

Any staff reporting concerns or complaints through formal whistleblowing channels (or if they request it) will be protected by UK Manufacturing Media Ltd’s Disclosure of Malpractice in the Workplace (Whistleblowing) Policy.

UK Manufacturing Media Ltd will also accept complaints from external sources such as members of the public, partners and official bodies. 

  1. How to report a safeguarding concern

Staff members who have a complaint or concern relating to safeguarding should report it immediately to their Safeguarding Focal Point [as appropriate] or line manager.  If the staff member does not feel comfortable reporting to their Safeguarding Focal Point or line manager (for example if they feel that the report will not be taken seriously, or if that person is implicated in the concern) they may report to any other appropriate staff member.  For example, this could be a senior manager or a member of the HR Team.

  1. Response

UK Manufacturing Media Ltd will follow up safeguarding reports and concerns according to policy and procedure, and legal and statutory obligations (see Procedures for reporting and response to safeguarding concerns in Associated Policies).

UK Manufacturing Media Ltd will apply appropriate disciplinary measures to staff found in breach of policy.

UK Manufacturing Media Ltd will offer support to survivors of harm caused by staff or associated personnel, regardless of whether a formal internal response is carried out (such as an internal investigation).  Decisions regarding support will be led by the survivor.

  1. Confidentiality

It is essential that confidentiality in maintained at all stages of the process when dealing with safeguarding concerns.  Information relating to the concern and subsequent case management should be shared on a need to know basis only, and should be kept secure at all times.

  1. Associated policies

Code of Conduct

Anti Bullying and Harassment policy

Disclosure of Malpractice in the Workplace (Whistleblower) policy

Child Safeguarding policy

Adult Safeguarding policy

PSEA (Protection from Sexual Exploitation and Abuse by staff) policy

Complaints Policy

Procedures for reporting and response to safeguarding concerns

Procedures for safeguarding in staff recruitment

Other policies as appropriate

  1. Glossary of Terms

Beneficiary of Assistance

Someone who directly receives goods or services from UK Manufacturing Media Ltd’s programme.  Note that misuse of power can also apply to the wider community that the NGO serves, and also can include exploitation by giving the perception of being in a position of power.

Child

A person below the age of 18

Harm

Psychological, physical and any other infringement of an individual’s rights

Psychological harm

Emotional or psychological abuse, including (but not limited to) humiliating and degrading treatment such as bad name calling, constant criticism, belittling, persistent shaming, solitary confinement and isolation

Protection from Sexual Exploitation and Abuse (PSEA)

The term used by the humanitarian and development community to refer to the prevention of sexual exploitation and abuse of affected populations by staff or associated personnel.  The term derives from the United Nations Secretary General’s Bulletin on Special Measures for Protection from Sexual Exploitation and Abuse (ST/SGB/2003/13)

Safeguarding

In the UK, safeguarding means protecting peoples’ health, wellbeing and human rights, and enabling them to live free from harm, abuse and neglect[4]

In our sector, we understand it to mean protecting people, including children and at risk adults, from harm that arises from coming into contact with our staff or programmes.  One donor definition is as follows:

Safeguarding means taking all reasonable steps to prevent harm, particularly sexual exploitation, abuse and harassment from occurring; to protect people, especially vulnerable adults and children, from that harm; and to respond appropriately when harm does occur.

This definition draws from our values and principles and shapes our culture. It pays specific attention to preventing and responding to harm from any potential, actual or attempted abuse of power, trust, or vulnerability, especially for sexual purposes.

Safeguarding applies consistently and without exception across our programmes, partners and staff. It requires proactively identifying, preventing and guarding against all risks of harm, exploitation and abuse and having mature, accountable and transparent systems for response, reporting and learning when risks materialise. Those systems must be survivor-centred and also protect those accused until proven guilty.

Safeguarding puts beneficiaries and affected persons at the centre of all we do.

Sexual abuse

The term ‘sexual abuse’ means the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions.

Sexual exploitation

The term ‘sexual exploitation’ means any actual or attempted abuse of a position of vulnerability, differential power, or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another.  This definition incudes human trafficking and modern slavery.

Survivor

The person who has been abused or exploited. The term ‘survivor’ is often used in preference to ‘victim’ as it implies strength, resilience and the capacity to survive, however it is the individual’s choice how they wish to identify themselves.

At risk adult

Sometimes also referred to as vulnerable adult.  A person who is or may be in need of care by reason of mental or other disability, age or illness; and who is or may be unable to take care of him or herself, or unable to protect him or herself against significant harm or exploitation.