Our data protection policy

We follow the legal obligations that are set out under the Data Protection Act 2018.

This policy applies to current and former employees, workers, apprentices, volunteers

and consultants. If you fall into any of these categories, you should be already aware of

this policy from your contract of employment. This policy ensures the safety of all

information that the company has, including all employee data as well as customer,

supplier and contractors’ data. This is not part of your contract of employment and can be

changed at any time as it is fully compliant with the Data Protection Act 2018.

Data protection principles

The data protection principles are how any personal data must be processed in

accordance with these six principles:

★ be processed fairly, lawfully and transparently.

★ be collected and processed only for specified, explicit and legitimate purposes.

★ be adequate, relevant and limited to what is necessary for the purposes for which

it is processed.

★ be exact and kept up to date. Any inaccurate data must be deleted or rectified

without delay.

★ not be kept for longer than is necessary for the purposes for which it is processed.

and

★ be processed securely.

We are accountable for these principles and must be able to show that we are compliant.

Allergens onsite

As a 14-allergen free company we work in a non-comprised environment meaning there

is to be no allergens onsite listed below.

★ Celery

★ Cereals

★ Gluten

★ Crustaceans

★ Eggs

★ Fish

★ Lupin

★ Milk

★ Molluscs

★ Mustard

★ Peanuts

★ Sesame

★ Soybeans

★ Sulphur dioxide and sulphites

★ Tree nuts

If any employees are found to have any of the following allergens on the premises, then

there will be disciplinary action taken against them. However, as a business we may

provide all employees with 14 allergen free products (food items) if appropriate.

Policy

Discrimination in any form in the workplace is unacceptable and of nine

characteristics of the Equality Act 2010. It is unlawful to discriminate against anyone

whether it is.

★ Age

★ Gender

★ Marriage and civil partnership

★ Pregnancy and maternity

★ Race

★ Religion or belief

★ Gender

★ Sexual orientation

The Equal Opportunities Policy has therefore been developed to make sure that all job

applicants and employees are treated fairly, and we will apply the policy to the

employment, development and promotion of all people, judging only on merit and ability.

★ You must always observe and apply the Equal Opportunities Policy

★ The policy will be implemented per the requirements of relevant

legislation

★ All vacancies will be advertised as widely as possible, both internally and

externally

★ No job candidate or employee will receive less favourable treatment on the

grounds of any of the nine protected characteristics of the Equality Act 2010. We

will not ask for unnecessary information or qualifications during the recruitment

process and will select based on ability

★ The company will protect employees from victimisation. Victimisation occurs

when an employee is subject to a detriment, such as being denied a training

opportunity or a promotion because he or she made or supported a complaint or

raised a grievance under the Equality Act 2010, or because he or she is

suspected of doing so or about to do so.

★ It is unlawful for employees to discriminate directly or indirectly, or harass

customers or clients because of any of the nine protected characteristics in the

Equality Act 2010.

★ Associative discrimination, where an individual is discriminated against or

harassed for association with an individual who has a protected characteristic, is

also unlawful, and will be managed in the same way as any other form of

discrimination.

★ Perceptive discrimination, where an individual is discriminated against, or

harassed based on a perception that he or she has a protected characteristic

when he or she does not have that characteristic, is also unlawful and will

be managed in the same way as any other form of discrimination.

Modern Slavery Act

Anti-slavery policy

Modern slavery is a crime and a violation of fundamental human rights. It takes various

forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all

of which have in common the deprivation of a person’s liberty by another to

exploit them for personal or commercial gain.

The Company has a zero-tolerance approach to modern slavery, and we are committed

to acting ethically and with integrity in all our business dealings and relationships and to

implementing and enforcing effective systems and controls to ensure modern slavery is

not taking place anywhere in our own business or in any of our supply chains.

We are also committed to ensuring there is transparency in our own business and in our

approach to tackling modern slavery throughout our supply chains, consistent with our

disclosure obligations under the Modern Slavery Act 2015.

We expect the same exacting standards from all our contractors, suppliers and other

business partners, and as part of our contracting processes, in the coming year we will

include specific prohibitions against the use of forced, compulsory or trafficked labour, or

anyone held in slavery or servitude, whether adults or children, and we expect our

suppliers will hold their own suppliers to the same exacting standards.

This policy applies to all persons working for us or on our behalf in any role,

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 does not form part of any employee’s contract of employment, and we may

amend it at any time.

Responsibility for the policy

The Company has overall responsibility for ensuring this policy follows our legal

and ethical obligations, and that all those under our control follow it.

The Company has primary and day-to-day responsibility for implementing this policy,

monitoring its use and effectiveness, dealing with any queries about it, and auditing

internal control systems and procedures to ensure they are effective in countering

modern slavery.

Management at all levels handle ensuring those reporting to them

understand and follow this policy and are given adequate and regular training on it

and the issue of modern slavery in supply chains.

You are invited to comment on this policy and suggest ways in which it might be

improved. Comments, suggestions and queries are encouraged and should be

addressed to the Managing Director.

Protection against harassment

Harassment is defined as unwanted conduct related to protected characteristics under

the Equality Act 2010. These can be found in the equal opportunities section of this

handbook. These can be characterised as anything which has the purpose of violating a

person’s dignity or also creating an intimidating, hostile, degrading, offensive or

humiliating environment for that individual, or is reasonably considered by the individual

to have any of the following effects, even if it was not intended by the person

responsible.

Any form of harassment in the workplace is unacceptable and if it relates to the nine

characteristics in the Equality Act 2010, it is unlawful. Every employee is expected to

respect each other on feeling and wellbeing. It is also expected that you

remember that what might be acceptable to one person may be considered upsetting or

intimidating to another. We aim to create a working environment where all staff are

treated with respect and dignity.

The following outlines examples of the type of behaviour which could be considered to

be harassment and which could lead to disciplinary action, and in serious cases,

dismissal:

★ Coarse or insensitive jokes and pranks

★ Coarse or insensitive comments about appearance or character

★ Display of offensive material

★ Deliberate exclusion from conversation or activities

★ Unwelcome familiarity or body contact

★ Abusive, insulting or threatening language

★ Demands or threats to obtain favours or intimidate

★ Threatened or actual violence

The above examples are not an exhaustive list, and you should remember that

harassment depends on the view of the person on the receiving end of the behaviour.

We understand the sensitive nature of complaints of harassment, but would encourage

anyone who feels they have been harassed to implement the grievance procedure so

that the situation can be satisfactorily resolved promptly in a discreet and caring manner.

Harassment in the workplace by a third party such as a customer or supplier is

unacceptable and we will take all reasonable steps to protect employees from this sort

of behaviour. If you feel you are being harassed by a third party, you should raise the

matter with management, either informally or through the company’s grievance

procedure.