Policies

This statement is made as part of Venesky-Brown Recruitment’s commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act). It summarises how Venesky-Brown Recruitment operates, the policies and processes in place to minimise the possibility of any problems, any risks we have identified and how we monitor them and how we train our staff.

This statement is published in accordance with section 54 of the Act, and relates to the financial year April 2022 to April 2023.  It was approved by the board of directors on 1^st March 2022.

1. Our Business

Venesky-Brown Recruitment is a limited company operating in the recruitment sector.  We are a leading provider of resourcing solutions, rapidly expanding our presence across the UK into sectors including Construction, Engineering, Corporate Services, Digital and IT.

We have 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 appreciate that the construction sector is high risk when it comes to modern slavery and accounts for a significant portion of issues in the UK. We therefore continually renew and assess our processes and controls to ensure we have robust protection and protocols in place to eliminate any chances of modern slavery.

Who We Work With

All of the hirers that we work with, and all of the work-seekers we provide, are known to and identified by our staff.  All of the temporary workers we supply are identified by our staff. Some of these work-seekers operate through their own limited companies.

Other Relationships

As part of our business, we also work with the following organisations:

• The Recruitment and Employment Confederation (https://www.rec.uk.com/)
• The Scottish Building Federation (https://www.scottish-building.co.uk/)

2. Our Policies

Venesky-Brown Recruitment has the following policies which incorporate ethical standards for our staff and our suppliers

• Equality, Diversity & Inclusion Policy
• Anti-Bribery Policy
• Fatigue Management Policy
• Modern Slavery Policy
• Health and Wellbeing Policy
• Whistleblowing Policy

 Venesky-Brown’s policies are established by our directors and our senior leadership team, based on advice from HR professionals, industry best practice and legal advice. We review our policies annually or as needed to adapt to changes.

3. Our Processes for Managing Risk within our supply chain

In order to assess the risk of modern slavery, we use the following processes with our suppliers: 

• When engaging with suppliers, we ask for evidence of their processes and policies, including commitments around modern slavery, human trafficking, forced labour, human rights, and whistle-blowing.
• We review the potential for risk at regular intervals, including the possibility of auditing a supplier or conducting spot checks.

 Additionally, we have taken the following steps to minimise the possibility of any problems:

• We reserve the right to conduct spot-checks of the businesses who supply us, in order to investigate any complaints
• We require the businesses we work with to address modern slavery concerns in their policies.
• Only senior members of staff who have undergone appropriate training for assessing modern slavery risks in the supply chain are authorised to sign contracts and establish commercial relationships in any area where we have identified the potential for risk.
• We collaborate with our suppliers in order to improve standards and transparency across our supply chain.
• We ensure that all of our suppliers are members of appropriate industry bodies and working groups.
• We provide feedback on business incentives that can be given to suppliers and other business partners and contractors to implement anti-slavery policies
• We provide guidance on what steps a Company should take if suppliers or contractors do not implement anti-slavery policies in high-risk scenarios, including their removal from the Company’s supply chains

Our staff are encouraged to bring any concerns they have to the attention of management.

4. Our Performance

As part of monitoring the performance of Venesky-Brown Recruitment, we track the following general key performance indicators:

• Training: Modern Slavery training as part of the on-boarding to ensuring Modern Slavery awareness throughout the business.
• Recruitment: Where possible individuals are met face to face as part of their on-boarding and continuous communication throughout their placement. Where restrictions or distance make a face to face meeting impossible we have video calls with potential candidates.
• Right to Work: Stringent verification processes to ensure the right to work in the UK. These processes are in line with government guidelines in this area.
• Audits: We carry out internal audits on high risk groups

Dealing with Complaints: We aim to deal with all complaints received in line with our Complaints Policy.

5. Tackling Modern Slavery

Venesky-Brown have implemented the following:

• Signatory to GLAA Construction Protocol
• Partner of the Supply Chain Sustainability School
• Recurring annual Modern Slavery training for staff on how to spot the signs and reporting
• Right to work checks in line with government guidance
• Whistleblowing online reporting tool

2022-23 Plans

• Conduct toolbox talks on a regular basis specifically referencing current Modern Slavery issues & concerns
• Provide Modern Slavery updates via newsletters, social media posts, website news articles etc.
• Attend Modern Slavery workshops with the Supply Chain Sustainability School and GLAA
• Continually review and improve progress against the Supply Chain Sustainability School People Matter Charter to become experts.

6. Our Training

Our zero-tolerance approach to modern slavery is communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter. Training on the risk our business faces from modern slavery in its supply chains, forms part of our induction process for all individuals who work for us, and regular training will be provided as necessary. In particular:

Our leadership team receive detailed training in identifying and resolving concerns around modern slavery and human trafficking.

• Our Operations and HR Team undertake training courses that include guidance around modern slavery and human trafficking, as well as other wider human rights issues.
• All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.

As part of this, our staff are encouraged to discuss any concerns that they have with Management.

The policy will be reviewed annually to ensure that it remains relevant and up to date.

1. Introduction

It is the policy of Venesky-Brown Recruitment to provide and maintain safe and healthy working conditions, equipment and systems of work for all our employees, and to provide such information and training as they need for this purpose.

In accordance with our duty under Section 2(3) of the Health and Safety at Work etc. Act, 1974 and in fulfilling our obligations to both employees and others who may be affected by our business operations; it is our policy to ensure, so far as is reasonably practicable, the safety and health of all employees and others and to prevent work-related accidents and cases of occupational ill health. It is also our policy to eliminate hazards and reduce OH&S risks and we commit to continual improvement of the OH&S management system.

Venesky-Brown accepts its responsibility for health and safety of other persons who may be affected by the Company’s activities.

Following the identification of work-related risks and hazards, Venesky-Brown will take preventative and protective measures. It is also the policy of Venesky-Brown to ensure that its business is conducted in a manner so as to reduce the risks to members of the public. The Company may require you to attend such training and/or induction programmes in order to meet the aims of the Company.

The allocation of duties for safety matters, the identity of competent persons appointed with particular responsibilities, and the arrangements made to implement this policy are set out in this policy and in associated health and safety records.

This policy will be kept up to date, to reflect changes in the nature and size of the Company. To ensure this, the policy and its effectiveness will be reviewed annually.

Venesky-Brown is committed to continual improvement of our health and safety performance and compliance with ISO 45001:2018 Safety Standard, legislation and other requirements, such as internal company policies (for example fatigue, work safe and acceptable behaviour policies)

2. Scope

The scope of this Health and Safety Policy covers all employees based at the Venesky-Brown head office in Edinburgh covering the administration and management of the supply of person labour to the construction, engineering, IT and professional industries.

3. Duties

The directors recognise that they have ultimate responsibility to ensure that a risk management structure is in place and all reasonable precautions are taken to provide and maintain working conditions which are safe, healthy, and environmentally friendly and comply with all statutory requirements and codes of practice. However it should also be accepted that health and safety at work is everyone’s business and all employees have health and safety responsibilities commensurate with their role.

It is the duty of management to:

• provide and maintain systems of work that are safe and without risk to health;
• ensure safety and the absence of risks to health in connection with handling of equipment, storage and transport;
• provide information, instruction, training and supervision;
• maintain all places of work in a safe condition;
• provide and maintain a safe working environment.

Your responsibilities:
All employees and workers have a duty in law to act responsibly and to take reasonable care for the health and safety at work of both themselves and their colleagues. This duty can be carried out by:

• Comply with all risk assessments, Safe Systems of Work and associated health and safety guidance.
• Take reasonable care of themselves and others they are responsible for.
• Co-operate with the client to allow the client to comply with its legal duties.
• Only carry out work activities which they have been trained to undertake.
• Assent to all environmental legislations and regulations.
• Attend health and safety training as and when required.
• Report all unsafe practices and all accidents/incidents and near misses promptly to the client and/or line management.
• Use all equipment provided correctly and without interfering, damaging or misusing any equipment, safety device, material or facilities provided for their work activity.

All such incidents must be recorded and reported to Martin Cairns, Managing Director, using the internal report form (DOC66). Any failure to adhere to this policy and the procedures set out in it will be considered a serious disciplinary offence and is one which may lead to dismissal, refer to Disciplinary Policy (POL032).

4. Objectives

We strive to meet employee’s health and safety policy statement by setting and maintaining the following objectives and continually improving:

1. Taking all reasonable steps to minimise the risk of injury and illness to employees, visitors, members of the public and contractors by providing safe workplaces and equipment.
2. Implementing measures, so far as is reasonably practicable, to comply with the regulatory requirements of the Health and Safety at Work etc. Act 1974 and other relevant health and safety legislation.
3. Developing and implementing health and safety guidance and procedures to define our expectations and provide suitable information, instruction, training and supervision to enable employees to undertake their individual duties safely.
4. Reviewing accident statistics, monitoring health and safety compliance, setting targets and health and safety objectives to strive for improved health and safety performance.
5. Appointing competent persons and providing adequate resources to enable health and safety obligations to be discharged.
6. Consulting with employees on matters affecting their health and safety and working with all stakeholders to develop safer working practices and conditions where appropriate

5. Consultation & Participation with Employees

It is the policy of Venesky-Brown Recruitment to ensure the participation and consultation of employees and workers and workers representatives in all parts of the application of the Occupational Health and Safety Management System (OHSMS) and work-related activities.

In order to satisfy our policy and legal duties, we are committed to:

• Facilitating for views and discussion on matters relating to the health, safety and welfare of all our employees.
• Providing suitable information, instruction and training on health and safety management.
• Involving employees in the development of documentation and systems that affect their health, safety and wellbeing.

Venesky-Brown Recruitment’s main categories of interested parties include but are not limited to customers, employees, statutory/regulatory bodies, external providers and suppliers, local communities and banks.

This statement will be reviewed annually to monitor its effectiveness and to ensure that it reflects changing needs and circumstances of Venesky-Brown.

6. Security

If you are responsible for setting the alarm at the end of the day, failure to set the alarm may result in disciplinary action being taken.

7. Fire & Emergency

You must observe the evacuation procedures laid down in the event of a fire or any other emergency situation. You must be aware of the location of the emergency exits, assembly points and first aid kit. Procedures to be carried out in the event of a fire or emergency will be found in the Emergency Procedure – Fire (WIGH001)

8. Responsibilities

Ultimate responsibility for health and safety rests with the Board of Directors, with delegation of duty to managerial employees. Those named must be fully aware of their duties, details of which should be included in their job description.

• Overall and final responsibility within the Company rests with:
  Name: Martin Cairns
  Status: Managing Director
  Mobile Phone: 07835056200
  Email: Martin@venesky-brown.co.uk
• Person responsible for ensuring this health and safety policy is put into practice on a day-to-day basis is:
  Name: Bob Mitchell
  Status: Operations Director
  Mobile Phone: 07894 513 223
  Email: Bob@venesky-brown.co.uk
• In the absence of the person named in 2 (above), s/he will be deputised by:
  Name: Hannah Smiley
  Status: HR Manager
  Mobile Phone: 07803 899 633
  Email: Hannah@venesky-brown.co.uk
• In the event of accidents and dangerous occurrences, such incidents should be
  reported to:
  Name: Martin Cairns
  Status: Managing Director
  Mobile Phone: 07835 056 200
  Email: Martin@venesky-brown.co.uk

9. Risk Assessments

• Risk assessments will be undertaken by:
  Name: James Shahhet, Soteria UK (Consultant)
  Status: Director & Principal Consultant
  Telephone extension: 01925 626210
  Mobile Phone: 07825 642881
  Email: james.shahhet@soteriauk.co.uk
• The findings of the risk assessments will be reported to:
  Name: Martin Cairns
  Status: Managing Director
  Mobile Phone: 07835 056 200
  Email: Martin@venesky-brown.co.uk
• Action required to remove/control risks will be approved and implemented by:
  Name: Bob Mitchell
  Status: Operations Director
  Mobile Phone: 07894 513 223
  Email: Bob@venesky-brown.co.uk
• Risk assessments will be reviewed by:
  Name: Bob Mitchell
  Status: Operations Director
  Mobile Phone: 07894 513 223
  Email: Bob@venesky-brown.co.uk

10. Accident Reporting

If an accident arises out of or in connection with the work of our business which is:

• an injury causing incapacity for more than 7 days or
• fatal or specified major injury or condition

and happens to either:

• one of our employees, temporary workers, a trainee at work or a self-employed person working on our premises; or
• any other person who is not an employee or trainee at work, but who was either in/on premises under our control at the time

we must:

1. notify the Enforcing Authority (HSE)
2. send a written report on an approved form to the Enforcing Authority within 15 days of the accident.

If a different injury occurs, we must make and keep a record of the accident.

11. Emergency Services

1. Nearest Hospital with a Casualty Department:
   Name: Western General Hospital
   Address: Crewe Rd S, Edinburgh EH4 2XU
   Telephone Number: 0131 537 1000
2. Police Station:
   Name: Police Scotland
   Address: 6 Torphichen Pl, Edinburgh EH3 8DU
   Telephone Number: 01786 289070
3. Fire Station:
   Name: Tollcross Fire Station
   Address: Ponton St, Edinburgh EH3 9BP
   Telephone Number: 0131 229 8274

12. Fire Safety

It is essential that adequate equipment and staff training is provided on this subject.

• Facilities:
  Number/location of escape routes: 4
  Number/location of fire extinguishers: 2
  Number/location of fire alarms: 6
  Checked by: Office Manager
  Frequency: Weekly
• Fire Safety Training Officer:
  Name: Samantha Taljaard & Jonny Cunningham
  Status: Credit Control & Account Manager
  Mobile phone: 07710855462 & 077254 2764
  Email: Samantha@venesky-brown.co.uk & Jonny@venesky-brown.co.uk
• Fire Drills are the responsibility of:
  Name: Hannah Smiley
  Status: HR Manager
  Mobile Phone: 07803 899 633
  Email: Hannah@venesky-brown.co.uk
  Frequency: 6 months
• Fire equipment maintenance company:
  Name: Fesscom Fire Protection
  Address: 55 Forthview Crescent, Edinburgh, EH14 5QS
  Telephone Number: 0131 623 5203
  Email: info@fesscom.co.uk
• Rules/Procedure in the event of a fire:

  Please refer to the Emergency Procedure – Fire (WIGH001)

13. Workplace Equipment

All workplace equipment should be treated with respect and checked regularly

• Responsibility for inspecting all workplace equipment:
  Name: Hannah Smiley
  Status: HR Manager
  Mobile Phone: 07803 899 633
  Email: Hannah@venesky-brown.co.uk
• Frequency of Inspections:
  Electronic equipment: Annually
• Procedure Detail:

  Fixed wiring, circuit boards and plug sockets > Every 5 years or after any refurbishment or major works has been undertaken which effects the installation. Periodic Inspection Report (PIR) by competent electrical engineer
  Test to take place out of hours.
  Residential Properties – As above. Every 10 years or at every change in tenancy (whichever occurs first). As above.
  Portable Equipment Equipment which has a lead and a plug; and is normally moved around such as kettles, vacuum cleaners, laptops, phone chargers, lamps, fans and employee’s personally owned appliances used at work. Prior to use. Visual inspection by user looking for damaged wires or cables or casing.
  Annually. Portable Appliance Test (PAT) by competent electrical engineer.
  Fixed Equipment
  Items such as PC’s, printers, fax machines.
  Every 4 years once equipment is 4 years old.
  Every 4 years once equipment is 4 years old.

  General rules governing the safe use of portable electrical equipment:

  • Encourage employees to look at the supply cable to the electrical equipment before they use it (user check).
  • Encourage employees to look at electrical equipment before they use it (user check).
  • Make sure that all portable equipment is visually inspected at initial intervals which could be between six months and four years, depending on the type of equipment. See the last bullet point on this list and Table 1 at the end of this leaflet for more information.
  • Arrange for equipment that is not double insulated to have a portable appliance test (including leads) at initial intervals which could be between one and five years, depending on the type of equipment.
  • Ensure that damaged or faulty equipment is recognised, removed from use without delay and either:
    • repaired by someone competent (ie with suitable training, skills and knowledge for the task to prevent injury to themselves or others); or
    • disposed of to prevent its further use – consult your local authority about arrangements for disposing of electrical equipment.
  • Review your maintenance system to determine whether you could decrease or increase your inspection and/or testing intervals. You may find it useful to keep records of all inspections and tests, and to label equipment with the result and date of the test, but there is no legal requirement to do either of these things.

  14. Health & Safety Training

  Good training will ensure that employees are competent to carry out their tasks, thus reducing risk to health and safety.

  • Person(s) responsible for health and safety training within the Company
    Name: Bob Mitchell
    Status: Operations Director
    Mobile Phone: 07894 513 223
    Email: Bob@venesky-brown.co.uk

  15. Information, Instruction & Supervision

  Health and safety information can be found:

  Health and Safety Manual (MAN06)

  Where employees or temporary workers work at locations under the control of another employer, health and safety risk assessments may need to be performed by the other employer.

  • Person(s) responsible for ensuring any necessary risk assessments are carried out by the other employer:
    Name: Bob Mitchell
    Status: Operations Director
    Mobile Phone: 07894 513 223
    Email: Bob@venesky-brown.co.uk
  • Person(s) responsible for ensuring that all employees and temporary workers, who work at locations under the control of other employers, are given all the health and safety information relevant to the other employer and their assignment (including whether personal protective equipment is required and if so, how it will be supplied):
    Name: Bob Mitchell
    Status: Operations Director
    Mobile Phone: 07894 513 223
    Email: Bob@venesky-brown.co.uk
  • Person(s) responsible for ensuring all employees and temporary workers working at location(s) under the control of another employer receive the necessary health and safety training:
    Name: Bob Mitchell
    Status: Operations Director
    Mobile Phone: 07894 513 223
    Email: Bob@venesky-brown.co.uk

  16. Personal Protective Equipment

  An employer has a duty to eliminate or control risk as far as is reasonably practicable before resorting to personal protective equipment. However, many tasks require such precautions, in which case persons at risk must be provided with suitable protective equipment.

  • Person responsible for assessing and issuing PPE
    Name: Bob Mitchell
    Status: Operations Director
    Mobile Phone: 07894 513 223
    Email: Bob@venesky-brown.co.uk
  • Person responsible for maintenance of PPE
    Name: Bob Mitchell
    Status: Operations Director
    Mobile Phone: 07894 513 223
    Email: Bob@venesky-brown.co.uk
  • Person responsible for training in the use of PPE
    Name: Bob Mitchell
    Status: Operations Director
    Mobile Phone: 07894 513 223
    Email: Bob@venesky-brown.co.uk

  17. First-aid & Medical Facilities on the Company’s Premises

  First Aid requirements must be met for all employees whether they are working at the designated premises or elsewhere. Employees must be made aware of the provision, and records must be kept of treatment administered.

  • First-Aiders
    Name(s): Melissa Clouston
    Status: Payroll Administrator
    Mobile Phone: 07710 856 207
    Email: Melissa@venesky-brown.co.uk
  • First-Aid Box is located at:
    Kitchen
  • The Accident Book is located at:
    Kitchen

  The following is a guide to the contents of the Company’s first-aid box:

  • Guidance Card – 1
  • Individually wrapped sterile adhesive dressings (assorted sizes and appropriate to work e.g. detectable for food handlers – 20
  • Sterile eye pads – 2
  • Individually wrapped triangular bandages (preferably sterile) – 4
  • Safety Pins – 6
  • Medium sized individually wrapped sterile unmedicated wound dressings (approx. 12 x 12cm) – 6
  • Large sterile individually wrapped unmedicated wound dressings (approx. 18 x 18cm) – 2
  • Disposable gloves – 1

1. Introduction

Venesky-Brown are committed to promoting equal opportunities, valuing diversity and supporting an inclusive working environment for all our colleagues under the Equality Act 2010. We operate in increasingly diverse environments, both in the UK and Ireland, and this is evident in our workforce, clients, customers and suppliers. In the competitive business environment, we operate in, we understand that the performance and engagement of our employees is central to our success. Our commitment therefore, is to build an environment in which each colleague is able to fulfil their potential and maximise their contributions. At Venesky-Brown we welcome diversity, and fully appreciate that everyone has something unique to offer. We respect and understand these differences and aim to make the most of everyone’s talents.

Venesky-Brown are certified to ISO 9001:2015, our QMS procedures ensure compliance with all aspects of this policy.

2. What is EDI?

At Venesky-Brown, equality, diversity and inclusion are important principles.

Venesky-Brown Recruitment will treat everyone equally and will not discriminate on the grounds of an individual’s “protected characteristic” under the Equality Act 2010 (the Act) which are age, disability, gender re-assignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation. We will not discriminate on the grounds of an individual’s membership or non-membership of a Trade Union. All staff have an obligation to respect and comply with this policy. Venesky-Brown Recruitment is committed to providing training for its entire staff in equality, diversity and inclusion.

To us, diversity is about understanding, recognising and valuing difference. We recognise that everyone is different. Likewise, equality means that we remove the barriers, eliminate discrimination and ensure equal opportunities for all employees.

To us, inclusion means that we focus on attracting and developing talent wherever it exists and we encourage everyone in our organisation to reach their full potential in whatever they do. We will continuously review all aspects of recruitment to avoid unlawful discrimination

Venesky-Brown Recruitment will not discriminate unlawfully when deciding which candidate/temporary worker is submitted for a vacancy or assignment, or in any terms of employment or terms of engagement for temporary workers.

Venesky-Brown Recruitment will ensure that each candidate is assessed in accordance with the candidate’s merits, qualifications and ability to perform the relevant duties for the role.

Our aim is to develop a culture where people’s differences are not only accepted, but they are valued, and used to enable everyone to thrive at work. We have developed an inclusive working environment where everyone feels they belong without having to conform, that their contribution matters and they are able to perform to their full potential, no matter their background, identity or circumstances.

Equality, Diversity & Inclusion (ED&I) are championed at the highest level in the organisation by the Directors and Senior Management. We have an Equality, Diversity & Inclusion Champion [Hannah Smiley, HR Manager] as well as two Fairness, Inclusion and Respect

Ambassadors:

• Hannah Smiley, HR Manager, Tel: 0131 357 2140, Email: Hannah@venesky-brown.co.uk
• Bob Mitchell, Operations Manager, Tel: 0131 357 2140, Email: Bob@venesky-brown.co.uk

As well as champions and ambassadors, we have created a Steering Committee which include members of all levers from across different departments of our organisation. The Steering Committee provides direction, promotes an inclusive workplace culture and facilitates the sharing of best practice across the organisation.

Venesky-Brown are accredited with Investors in Diversity following an assessment process. The journey and achievement of this standard gives a positive message to all of our stakeholders, internal and external. The Investors in Diversity Award is recognised as the national equality standard. Providing organisations with a bespoke approach for improving Fairness, Respect, Equality, Diversity, Inclusion and Engagement (FREDIE) practices in the workplace. The process of achieving this award helped us to place structured FREDIE standards at the heart of everything we do..

Venesky-Brown also participate in diversity campaigns throughout each year.

There are many benefits of embracing Equality, Diversity and Inclusion to Venesky-Brown, these include:

• Reduced staff grievances
• Reduced staff turnover
• Increased staff development
• Improved customer service and satisfaction
• Improved links between employee activities and strategic objectives
• Improved culture, attitudes, behaviours and conduct
• Improved marketing approaches
• Increased market share

3. Scope

The scope of this Equality, Diversity and Inclusion Policy covers all employees based at the Venesky-Brown head office in Edinburgh covering the administration and management of the supply of person labour to the construction, engineering, IT and professional industries.

4. Objectives

At Venesky-Brown and in line with legislation across the UK and Ireland, we aim to:

• ensure equality, diversity and inclusion in the workplace are fully supported
• offer fair treatment in every aspect of working life in Venesky-Brown. This applies to all employment policies and practices including those relating to:
  • Recruitment, selection and retention;
  • Terms and conditions of employment;
  • Working environment;
  • Learning and development;
  • Promotion and career progression;
  • Redundancy and re-deployment.
  • promote a culture where employees recognise the value that a diverse and inclusive workforce brings.
• be recognised as an employer with a positive reputation for equality, diversity and inclusion practices
• ensure that all job descriptions and job adverts are fully inclusive

5. Discrimination

Under the Act unlawful discrimination occurs in the following circumstances:

5.1 Direct Discrimination

Direct discrimination occurs when an individual is treated less favourably because of a protected characteristic. Treating someone less favourably means treating them badly in comparison to others that do not have that protected characteristic.
It is unlawful for a recruitment consultancy to discriminate against a person on the grounds of a protected characteristic:

• in the terms on which the recruitment consultancy offers to provide any of its services;
• by refusing or deliberately omitting to provide any of its services;
• in the way it provides any of its services.

Direct discrimination can take place even if the individual does not have the protected characteristic but is treated less favourably because it is assumed he or she has the protected characteristic or is associated with someone that has the protected characteristic.

Direct discrimination would also occur if a recruitment consultancy accepted and acted upon instructions from an employer which states that certain persons are unacceptable due to a protected characteristic, unless an exception applies. The Act contains provisions that permit specifying a requirement that an individual must have a particular protected characteristic in order to undertake a job. These provisions are referred to as occupational requirements.

Where there is an occupational requirement then the client must show that applying the requirement is a proportionate means of achieving a legitimate aim, i.e. the employer must be able to objectively justify applying the requirement. An occupational requirement does not allow an employer to employ someone on less favourable terms or to subject a person to any other detriment. Neither does an occupational requirement provide an excuse against harassment or victimisation of someone who does not have the occupational requirement.

5.2 Indirect Discrimination

Indirect discrimination occurs when a provision, criterion or practice (PCP) is applied but this results in people who share a protected characteristic being placed at a disadvantage in comparison to those who do not have the protected characteristic. If the PCP can be objectively justified it will not amount to discrimination.

Indirect discrimination would also occur if a recruitment consultant accepted and acted upon an indirectly discriminatory instruction from an employer.

If the vacancy requires characteristics which amount to an occupational requirement or the instruction is discriminatory but there is an objective justification, Venesky-Brown Recruitment will not proceed with the vacancy unless the client provides written confirmation of the occupational requirement, exception or justification.

Venesky-Brown Recruitment will use best endeavours to comply with the Act and will not accept instructions from clients that will result in unlawful discrimination.

6. Harassment

Under the Act, harassment is defined as unwanted conduct that relates to a protected characteristic which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual. This includes unwanted conduct of a sexual nature.

Venesky-Brown Recruitment is committed to providing a work environment free from unlawful harassment.

Venesky-Brown Recruitment will ensure that the consultants do not harass any individual.
Examples of prohibited harassment are:

• verbal or written conduct containing derogatory jokes or comments;
• slurs or unwanted sexual advances;
• visual conduct such as derogatory or sexually orientated posters;
• photographs, cartoons, drawings or gestures which some may find offensive;
• physical conduct such as assault, unwanted touching, or any interference because of sex, race or any other protected characteristic basis;
• threats and demands to submit to sexual requests as a condition of continued employment or to avoid some other loss, and offers of employment benefits in return for sexual favours;
• retaliation for having reported or threatened to report harassment.

If an individual believes that they have been unlawfully harassed, they should make an immediate report to the HR Manager followed by a written complaint as soon as possible after the incident. The details of the complaint should include:

• Details of the incident
• Name(s) of the individual(s) involved
• Name(s) of any witness(es)

Venesky-Brown Recruitment will undertake a thorough investigation of the allegations. If it is concluded that harassment has occurred, remedial action will be taken.

All employees and workers will be expected to comply with Venesky-Brown Recruitment’s policy on harassment in the workplace. Any breach of such a policy will lead to the appropriate disciplinary action.

Any individual who Venesky-Brown Recruitment finds to be responsible for harassment will be subject to the disciplinary procedure and the sanction may include termination.

7. Victimisation

Under the Act victimisation occurs when an individual is treated unfavourably because he/she has done a ‘protected act’ which is bringing a claim for unlawful discrimination or raising a grievance about discrimination or giving evidence in respect of a complaint about discrimination.

Venesky-Brown Recruitment will ensure that the consultants do not victimise any individual.

8. Disabled Persons

Discrimination occurs when a person is treated unfavourably as a result of their disability.

In direct discrimination occurs where a provision, criterion or practice is applied by or on behalf of an employer, or any physical feature of the employer’s premises, places a disabled person at a substantial disadvantage in comparison with persons who are not disabled.

In recruitment and selection there may be a requirement to make reasonable adjustments. For example, it might be necessary to have different application procedures for partially sighted or blind applicants that enable them to use Braille. With testing and assessment methods and procedures, tests can only be justified if they are directly related to the skills and competencies required for the job. Even then, it might be appropriate to have different levels of acceptable test results, depending on the disability. For example, an applicant with a learning disability might need more time to complete a test, or not be expected to reach the same standard as other non-disabled applicants.

Reasonable adjustments in recruiting could include:

• modifying testing and assessment procedures;
• meeting the candidate at alternative premises which are more easily accessible;
• having flexibility in the timing of interviews;
• modifying application procedures and application forms;
• providing a reader or interpreter.
  Wherever possible Venesky-Brown Recruitment will make reasonable adjustments to hallways, passages and doors in order to provide and improve means of access for disabled employees and workers. However, this may not always be feasible, due to circumstances creating such difficulties as to render such adjustments as being beyond what is reasonable in all the circumstances.

Venesky-Brown Recruitment will not discriminate against a disabled person:

• in the arrangements i.e. application form, interview or arrangements for selection for determining whom a job should be offered; or
• in the terms on which employment or engagement of temporary workers is offered; or
• by refusing to offer, or deliberately not offering the disabled person a job for reasons connected with their disability; or
• in the opportunities afforded to the person for receiving any benefit, or by refusing to afford, or deliberately not affording him or her any such opportunity; or
• by subjecting the individual to any other detriment (detriment will include refusal of training or transfer, demotion, reduction of wage, or harassment).

Venesky-Brown Recruitment will make career opportunities available to all people with disabilities and every practical effort will be made to provide for the needs of staff, candidates and clients.

8.1 Disability Confident Committed

Venesky-Brown Ltd are proud to be recognised as a Disability Confident Committed employer. The scheme supports employers to make the most of the talents disabled people can bring to the workplace and aims to help employers successfully recruit and retain disabled people and those with health conditions. By joining Venesky-Brown Ltd have committed to:

• Ensuring our recruitment process is inclusive and accessible
• Communicate and promote vacancies
• Offer an interview to disabled people
• Anticipate and provide reasonable adjustments as required
• Support any existing employee acquiring a disability or long term health condition to stay in work.

8. Age Discrimination

Under the Act, it is unlawful to directly or indirectly discriminate against or to harass or victimise a person because of age. Age discrimination does not just provide protection for people who are older or younger. People of all ages are protected.
A reference to age is a reference to a person’s age group. People who share the protected characteristic of age are people who are in the same age group.
Age group can have various references:

• Under 21s
• People in their 40s
• Adults

Venesky-Brown Recruitment will not discriminate directly or indirectly, harass or victimise any person on the grounds of their age. We will encourage clients not to include any age criteria in job specifications and every attempt will be made to encourage clients to recruit on the basis of competence and skills and not age.

Venesky-Brown Recruitment is committed to recruiting and retaining employees whose skills, experience, and attitude are suitable for the requirements of the various positions regardless of age. No age requirements will be stated in any job advertisements on behalf of the company.

If Venesky-Brown Recruitment requests age as part of its recruitment process such information will not be used as selection, training or promotion criteria or in any detrimental way and is only for compilation of personal data, which the company holds on all employees and workers and as part of its equal opportunities monitoring process. In addition if under age 22 to adhere to Conduct of Employment Agencies and Employment Business Regulations 2003 and other relevant legislation applicable to children or young candidates.

Where a client requests age or date of birth, this will have to be under an occupational requirement or with an objective justification which should be confirmed in writing.

10. Part-time Workers

This policy also covers the treatment of those employees and workers who work on a part-time basis, Venesky-Brown Recruitment recognises that it is an essential part of this policy that part time employees are treated on the same terms, with no detriment, as full time employees (albeit on a pro rata basis) in matters such as rates of pay, holiday entitlement, maternity leave, parental and domestic incident leave and access to our pension scheme. Venesky-Brown Recruitment also recognises that part time employees must be treated the same as full time employees in relation to training and redundancy situations.

11. Gender Reassignment

Venesky-Brown Recruitment recognises that any employee or worker may wish to change their gender during the course of their employment with the Company.

Venesky-Brown Recruitment will support any employee or worker through the reassignment.

Venesky-Brown Recruitment will make every effort to try to protect an employee or worker who has undergone, is undergoing or intends to undergo gender reassignment, from discrimination or harassment within the workplace.

Where an employee is engaged in work where the gender change imposes genuine problems Venesky-Brown Recruitment will make every effort to reassign the employee or worker to an alternative role in the Company, if so desired by the employee.

Any employee or worker suffering discrimination on the grounds of gender reassignment should have recourse to the Company’s grievance procedure.

12. Recruitment of Ex-Offenders

Where Venesky-Brown Recruitment has registered with the Disclosure and Barring Service (DBS) and has the authority to apply for criminal records checks on individual because they are working with children or vulnerable adults or both, we will comply with the DBS’s Code of Practice which includes having a policy on the recruitment of ex-offenders.

13. Training

We will provide diversity and inclusion training to managers and others likely to be involved in recruitment, performance management, talent management and other decision making where equal opportunities issues are likely to arise.

Our Equality, Diversity & Inclusion Policy is included in our Employee Handbook and Induction Packs. It is also made available on our company shared documents.

Employees at Venesky-Brown participate in annual Equality, Diversity and Inclusion training as well as refresher courses through the year. As partners of the Supply Chain Sustainability School, we ensure that our employees complete online training modules in relations to Equality, Diversity and Inclusion.

14. Reasonable Adjustments

Venesky-Brown will make any reasonable adjustments that are required to ensure the health, safety and convenience of our employees, this is our duty and responsibility as employers. As part of the job application process candidates are asked if they require reasonable adjustments made to facilitate job interviews. As part of our ISO 9001 QMS, DOC111 is used to ensure that clients provide us with detailed description of the working environment and job descriptions.

Venesky-Brown have made adjustments to our head office where interviews take place to meet the requirements of the Equality Act 2010. Adaptations have been made to pedestrian and vehicle access with designated parking provided for disabled badge holders, the accessible entrance to the building is clearly signed. Our access system is suitable for deaf and individuals who are hard of hearing. Main access doors can be operated at low level and are sufficiently wide to accommodate wheel chair users.

Specialist equipment including supportive chairs, height adjustable and standing desks are available. Interpreters are provided for people who are deaf or have a speech impairment. With respect to assignments Venesky-Brown can have the responsibility as employers to provide auxiliary aids or assistance for temporary workers.

15. Supply Chain

We are actively committed to advancing EDI among our supply chain. Venesky-Brown treat all of our suppliers with respect and actively build relationships to ensure we can effectively support and engage with our supply chain.

Venesky-Brown’s Approved Supplier Questionnaire (DOC89) includes a section on EDI to ensure that the importance of EDI is reflected throughout our supply chain.

16. Your Responsibility

We need your support, to meet our commitment to ensure equality, diversity and inclusion in employment and avoid unlawful discrimination. It is important to adhere to the spirit of the policy as you could be held personally liable as well as, or instead of, Venesky-Brown for any act of unlawful discrimination. We consider acts of discrimination against those we employ, or our customers, as disciplinary offences that may be dealt with under the disciplinary procedure

17. Complaints

Employees should disclose any instances of discrimination of which they become aware of to the HR Department (please see the Whistleblowing Policy, on the intranet). If you consider that you may have been unfairly treated or subjected to direct or indirect discrimination, you may use the grievance procedure to make a complaint, where every effort will be made to secure a satisfactory resolution.

Please refer to our Complaints Policy POL050.

18. Measuring Policy Effectiveness

Some ways in which we will measure the effectiveness of our ED&I policy include:

• Collating and reviewing quantitative and qualitative data to identify any areas requiring action;
• Publishing annual diversity data regarding the demographics of our workforce
• Undertake regular audits and reviews
• Highlight where barriers exist and show the positive impact of the company initiatives

19. Monitoring

We continuously review this Policy, together with all of our employment policies and practices to maintain our focus on equality of opportunity. To ensure that this Policy and other procedures are operating effectively, HR will continue to monitor and measure the records of our employees, benchmark our performance as a Company and ensure that any patterns or trends are identified and resolved.

Venesky-Brown are subject to Recruitment Employment Confederation (REC) equality legislation compliance test every two years.

The policy will be reviewed annually to ensure that it remains relevant.

1. Introduction

Venesky-Brown are committed to providing a safe, healthy and productive working environment. This includes ensuring that all staff are fit to carry out their jobs safely and effectively in an environment which is free from alcohol and drug misuse.

The purpose of this policy is to increase awareness of the effects of alcohol and drug misuse and its likely symptoms and to ensure that:

• All staff are aware of their responsibilities regarding alcohol and drug misuse and related problems.
• Staff who have an alcohol or drug-related problem are encouraged to seek help, in confidence, at an early stage.
• Staff who have an alcohol or drug-related problem affecting their work are dealt with sympathetically, fairly and consistently.
• The misuse of drugs and/or alcohol has the potential to cause us reputational damage, lower the standard of service that we provide to our clients and jeopardise health and safety. With this in mind this policy is to be read in conjunction with our Disciplinary Procedure as any use of drugs or alcohol which is deemed as improper by us may result in disciplinary action.

Venesky-Brown will not accept staff arriving at work under the influence of alcohol or drugs, and/or whose ability to work is impaired in any way by reason of the consumption of alcohol or drugs, or who consume alcohol or take drugs (other than prescription or over the counter medication, as directed) on our premises or our client’s premises.

This policy covers all employees, officers, consultants, contractors, casual operatives, agency workers and candidates for employment who are yet to be employed where they are required or will be required to work for our client.

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

You will comply with all instructions and requests concerning drug screening and searches given by our clients as if they were given by us. For the avoidance of doubt, whilst our clients may conduct the drug screening and/or searches our clients do not have the right to take any action against you. Any disciplinary action can only be taken by us.

2. Scope

The scope of this Drugs and Alcohol Policy covers all employees based at the Venesky-Brown head office in Edinburgh covering the administration and management of the supply of person labour to the construction, engineering, IT and professional industries.

3. Responsibility

The Company Director has overall responsibility for the effective operation of this policy but has delegated day-to-day responsibility for overseeing its implementation to the Major Projects Manager, and onsite Labour Managers.

All managers have a specific responsibility to operate within the boundaries of this policy, to ensure that all staff understand the standards of behaviour expected of them and to take action when behaviour falls below its requirements.

Managers will, if appropriate, be given training in:

• The nature and causes of alcohol and drug problems
• The effect of alcohol and drug misuse on workplace safety and performance
• The assistance that can be provided by outside agencies

4. Identifying a Problem

If you notice a change in a colleague’s pattern of behaviour you should encourage them to seek assistance through their manager. If they will not seek help themselves you should draw the matter to the attention of your manager. You should not attempt to cover up for a colleague whose work or behaviour is suffering as a result of an alcohol or drug-related problem.

If you believe that you have an alcohol or drug-related problem you should seek specialist advice and support as soon as possible. You should also seek support and guidance from the Venesky-Brown HR Manager if you believe your alcohol or drug-related problem is affecting you at work.

5. Alcohol & Drugs at Work

Misuse of alcohol and drugs can lead to reduced levels of attendance, reduced efficiency and performance, impaired judgement and decision making and increased health and safety risks for you and other people. Irresponsible behaviour or the commission of offences resulting from the misuse of alcohol or drugs may damage our reputation and, as a result, our business.

You are expected to arrive at work fit to carry out your job and to be able to perform your duties safely without any limitations due to the use or after effects of alcohol or drugs (whether prescribed, over the counter or illegal).

You should not drink alcohol during the normal working day, at lunchtime, at other official breaks and at official work-based meetings and events. Drinking alcohol while at work without authorisation or working under the influence of alcohol may be considered serious misconduct.

You must comply with drink-driving laws at all times. Conviction of a drink-driving offence may harm our reputation and, if your job requires you to drive, you may be unable to continue to do your job. Committing a drink-driving offence while working for us or outside working hours may lead to action under our Disciplinary Procedure and could result in dismissal.

If you are prescribed medication you must seek advice from your GP or pharmacist about the possible effect on your ability to carry out your job and whether your duties should be modified or you should be temporarily reassigned to a different role. If so you must tell your line manager without delay.

6. Searches

Venesky-Brown reserves the right to conduct searches for alcohol or drugs on our premises (or for our clients to conduct searches on any of their premises), including, but not limited to, searches of lockers, filing cabinets and desks, bags, clothing and packages.

Any alcohol or drugs found as a result of a search will be confiscated and action may be taken under our Disciplinary Procedure.

7. Drug Screening

All candidates and employees will be asked to participate in a drug screening programme on the terms below:

• If a person holds an up to date PTS Card (or Sentinel smartcard) they may not need to be screened for drugs before commencing work on our client’s site.
• If a person has successfully completed a drug screening test with us in the last 12 weeks they may not be required to undertake a pre-employment drug screen unless we have reasonable grounds for requiring a fresh drugs screen.
• If the person cannot satisfy the above then they will be required to undertake a drug screen within the first 14 days of employment.
• All employees / candidates will be subject to random drug screening in line with Network Rail Procedures.

All candidates and employees will undertake drug screening whether it is requested of you by us or by our client. Failure by employees/candidates to cooperate with a requested screening could be treated as a positive test and disciplinary action may result.

Drug screening will be conducted by an external provider. Arrangements will be discussed with affected members of staff at the start of each screening programme.

A positive result means the testing for drugs and alcohol shows:

• The presence of drugs, for which there is no legitimate need for either their use or the quantity or their use;
• More than 29 milligrams of alcohol in 100 millilitres of blood, or
• More than 13 micrograms of alcohol in 100 millilitres of breath, or
• More than 39 milligrams of alcohol in 100 millilitres of urine.

A positive result may result in disciplinary action including dismissal following an investigation.

8. Managing Suspected Substance Misuse

Where a manager considers that deterioration in work performance and/or changes in patterns of behaviour may be due to alcohol or drug misuse they should seek advice and assistance from the HR Manager.

If your manager has reason to believe that you are suffering the effects of alcohol or drugs misuse, they will invite you to an investigatory interview. The purpose of the interview is to:

• discuss the reason for the investigation and seek your views on, for example, the deterioration of your work performance and/or behaviour; and
• where appropriate, offer to refer you to an Occupational Health Provider, Specialist or GP for medical and/or specialist advice.

If you arrive at work and a manager reasonably believes you are under the influence of alcohol or drugs, they shall immediately contact Human Resources in order that you can be provided with assistance and an initial investigation can be undertaken.

If you agree to be referred to the HR Manager, your manager will request an urgent appointment and prepare a letter of referral, a copy of which will be provided to you.

The HR Manager may ask for your consent to approach your GP for advice. A report will be sent to your manager who will then reassess the reasons for their investigatory meeting with you and decide on the way forward.

If, as the result of the meeting or investigation, your manager continues to believe that you are suffering the effects of alcohol or drugs misuse and you refuse an offer of referral to the Occupational Health Department or appropriate treatment providers the matter may be dealt with under our Disciplinary Procedure.

9. Providing Support

Alcohol and drug-related problems may develop for a variety of reasons and over a considerable period of time. We are committed, in so far as possible, to treating these problems in a similar way to other health issues.

We will provide support where possible with a view to a return to full duties. This may include:

• Referral to appropriate treatment providers, where necessary in conjunction with your GP
• Time off work to attend treatment
• Adjusting your duties or other support as recommended by your GP or specialist during treatment and for an agreed period thereafter, subject to operational requirements and feasibility

If you do not finish a programme of treatment, or your recovery and return to work does not go as planned, the HR Manager will meet with you to decide what further action if any should be taken.

10. Confidentiality

Venesky-Brown aims to ensure that the confidentiality of any member of staff experiencing alcohol or drug-related problems is maintained appropriately. However, it needs to be recognised that, in supporting staff, some degree of information sharing is likely to be necessary.

If you seek help with an alcohol or drug-related problem directly from Human Resources and you wish to keep matters confidential from your manager and colleagues, this will be respected unless there is reason to believe that this could put you, your colleagues or anyone else at risk or carries some other material risk for the business. In those circumstances the HR Department will encourage you to inform your manager and will give you sufficient time to do so before discussing the matter with them.

11. Performance & Disciplinary Issues

If you agree to undertake appropriate treatment and/or rehabilitation for an acknowledged alcohol or drug-related problem, we may decide to suspend any ongoing disciplinary action against you for related misconduct or poor performance, pending the outcome of the treatment.

Our intention is to support all staff with alcohol or drug-related problems to regain good health. Depending on the progress made on the course of treatment, any disciplinary action may be suspended for a specified period, discontinued or restarted at any time as we see fit.

12. Drugs & Alcohol Testing

Alcohol Screening – Breath/Saliva testing for alcohol can be undertaken to ensure individuals are not under the influence of alcohol while at work.

Drug Screening – Drug (Urine) screening may be undertaken in one or two separate tests. The first screening rapidly identifies negative samples. The instant tests are called ‘Multi-Drug Rapid Tests’. A second screening can be sent to a lab for testing and results that screen is negative are reported usually within 48 hours.

Searches – Venesky-Brown reserves the right to conduct searches for alcohol or drugs on our premises (or for our clients to conduct searches on any of their premises), including, but not limited to, searches of lockers, filing cabinets and desks, bags, clothing and packages. Any alcohol or drugs found as a result of a search will be confiscated and action may be taken under our Disciplinary Procedure.

Pre-employment testing is conducted at registration for all employees prior to the commencement of the project, and thereafter in accordance with project requirements. The Onsite Labour Manager may request ‘with cause’ testing or ‘random’ testing as directed by the client.

Individuals refusing to take part in Drug or Alcohol testing are to be informed that such a refusal may be treated as a positive test result and that disciplinary action may follow as a result of their refusal.

Arrangements for ‘with cause’ and ‘random’ testing:

• With Cause – Requests for ‘with cause’ Drug or Alcohol tests are to be made by the Client Safety Manager of the company concerned. In the case of ‘with cause’ testing the Onsite Labour Manager will obtain from the site/workplace Manager a list of those persons requiring testing.
• Random – ‘Random’ testing will be implemented by either the Client Safety Manager or Venesky-Brown on-site Labour Manager. In the case of ‘random’ testing the Onsite Labour Manager will obtain separate lists of all directly employed and sub-contractors present on site and hands these to the tester, who selects at random those to be tested. Unless specified otherwise this will be 10% of those present. It is important that, other than establishing that representative sampling will be achieved, no other influence is placed on the tester’s selection.

13. Facilities for Testing

Facilities provided for D&A testing must be in good order.

The ideal set-up for a single tester is:

• A room large enough to accommodate a table that will seat up to four people comfortably
• A nearby WC with hand-washing facility, made unavailable for general use for the duration of testing
• Another room nearby to serve as a waiting room

The minimum requirement is for a room in which to undertake testing, as described above, with a dedicated Portaloo with hand-washing facility nearby.

The Onsite Labour Manager and an HR representative if necessary are to be on site for the duration of the testing.

14. Notification of Testing

Following the identification of need for ‘with cause’ Drug and Alcohol testing, the Onsite Labour Manager will contact the Testing Company to arrange date/time of testing.

15. Undertaking the Test

The Onsite Labour Manager will meet as arranged with the site/workplace manager and the tester. The Onsite Labour Manager briefs the site/workplace Manager and confirms with the tester that the facilities provided meet their needs. Where more than one tester is to work concurrently, the Onsite Labour Manager will liaise with the lead tester to ensure that satisfactory arrangements are in place. In the case of ‘with cause’ testing the Onsite Labour Manager will obtain from the site/workplace Manager a list of those persons requiring testing.

In the case of random testing, individuals should not be made aware at this stage that D&A testing is to be carried out.

The Onsite Labour Manager should brief each person or group upon arrival at the waiting area as to the purpose of the day’s testing, e.g.
“We are carrying out Drug &/or Alcohol testing today. I am (name) from Venesky-Brown and I am here to witness the testing. A representative is here from Venesky-Brown HR Department to witness events and answer any HR-related questions. The Tester works for an independent testing company and they will talk you through the process. Please read the briefing notes provided and if you have any questions at any time please raise them.”

Individuals are to be provided with a copy of and asked to read a briefing note outlining the procedure whilst they are in the waiting area. Individuals identified as having reading and/or English-speaking issues are to be offered assistance, typically their supervisor or a work colleague acting as an interpreter, with test documentation annotated accordingly.

The independent tester will take the lead during the actual test. A minimum of one company witness is required per tester, requiring the presence of the Onsite Labour Manager in the testing room at all times when testing is taking place.

Testing is carried out by an independent tester. The alcohol test is done via a breathalyser which gives an instant result.

The drugs screening is as follows:

The tester asks the individual a series of questions regarding any over-the-counter or prescription medication. (The person being tested has the right to declare their medication in confidence to the tester, in which case other witnesses will be asked to leave the room briefly).

• The testers use a sealed testing kit for each person tested.
• The individual is required to provide a urine sample into a pot.
• The tester accompanies the individual to the designated toilet facilities to ensure that the sample is not tampered with.
• The tester uses a sealed test kit to screen sample provided for evidence of drugs.
• The test shows an instant result.
• Should the test prove positive, the preparation of the sample for detailed laboratory analysis will follow

In the event of a non-negative test result, the sample will be sent to a lab for testing, and results that screen negative are reported usually within 48 hours.

All persons testing non-negative for drugs, including those declaring medication, are to be advised by the Onsite Labour Manager that, pending the findings of the laboratory analysis, they will not be allowed to remain at the site/workplace. Confirmation of results typically takes 3-5 working days.

A person who has been tested positive for drugs or alcohol at this point may be subject to disciplinary action, which could result in dismissal for cases of gross misconduct.

A person who voluntarily comes forward for confidential assistance for a drugs or alcohol problem may be subject to periodic testing for a period of 12 months or until the company deems reasonable after negative screening, administered at random by an external collection agency.

The testing will only be done on a ‘case by case’ basis following medical investigation to ensure that any prescribed course of counselling or rehabilitation is being followed (e.g. where a candidate has completed a counselling or rehabilitation programme and it is necessary to check progress and compliance).

16. Returning to Work

Alcohol – Following a positive test, a return to work may be considered if Venesky-Brown can demonstrate the operative is ‘Fit for Task’ and has undertaken a risk review, a copy of which may be required by the Main Contractor.

Drugs – Following a positive test at site, which is confirmed by a further lab test, the individual will be excluded from attending any Venesky-Brown projects until the individual can demonstrate through clinical re-testing that further results are negative and that we can confirm they are fit for task.

1. Definitions

In this policy “we”, ‘us”, and “the Company” mean Venesky-Brown Recruitment.

“Bribe” means an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage; “to Bribe” and “Bribery” are construed accordingly.

“Relevant Person” means any individual (whether an officer of employee of the Company, or a temporary worker, contractor or consultant providing services to or on behalf of the Company) or any corporate entity who performs functions for or on behalf of the Company.

2. Introduction

One of the Company’s core values is to uphold responsible and fair business practice. It is committed to promoting and maintaining the highest level of ethical standards in relation to all of its business activities. Its reputation for maintaining lawful business practices is of paramount importance and this Policy is designed to preserve these values. The Company therefore has a zero tolerance policy towards bribery and corruption and is committed to acting fairly and with integrity in all of its business dealings and relationships and to implementing and enforcing effective systems to counter bribery.

3. Scope

The scope of this Quality Policy covers all employees based at the Venesky-Brown head office in Edinburgh covering the administration and management of the supply of person labour to the construction, engineering, IT and professional industries.

4. Purpose

This Policy sets out the steps all of us must take to prevent bribery and corruption in our business and to comply with relevant legislation. It is aimed at:

• ensuring compliance with anti-bribery laws, rules and regulations, not just within the UK but in any other country within which the Company may carry out its business or in relation to which its business may be connected;
• enabling any Relevant Person to understand the risks associated with bribery and to encourage them to be vigilant and effectively recognise, prevent and report any wrongdoing, whether by themselves or others;
• providing suitable and secure reporting and communication channels and ensuring that any information that is reported is properly and effectively dealt with;
• creating and maintaining a rigorous and effective framework for dealing with any suspected instances of bribery or corruption.

All Relevant Persons are expected to adhere to the principles set out in this Policy.

5. The Bribery Act 2010

The Bribery Act 2010 (the Bribery Act) came into force on 1 July 2011. The Bribery Act affects the Company in its business relations anywhere in the world.

Under the Bribery Act it is an offence to:

1. bribe a person i.e. to offer, promise or give a financial or other advantage to another person, whether within the UK or abroad, with the intention of inducing or rewarding improper conduct;
2. receive a Bribe i.e. to request, agree to receive or accept a financial or other advantage for or in relation to improper conduct;
3. bribe a foreign public official;
4. fail to prevent Bribery.

6. Risks of not Acting with Integrity

Involvement in Bribery or corruption carries many risks. Among them are:

• a company which pays or accepts Bribes is not in control of its business and is at risk of blackmail;
• if the Company is found guilty of Bribery or even of failing to have adequate procedures in place to prevent Bribery, it will be subject to unlimited fines;
• any person found guilty of Bribery will be subject to fines and/or imprisonment of up to 10 years;
• a public exposure, or even allegation, of bribery would entail severe reputational damage. The Company’s banking or supply facilities might be withdrawn or be available on much less favourable terms, and the Company could be blacklisted as an approved tenderer for both public and private sector contracts;
• the cost of our insurance cover could increase very significantly; and
• good people will not want to work for us.

7. Benefits of Acting with Integrity

Equally, there are very clear benefits to acting with propriety. These include:

• we increase our chances of being selected as a supplier in both the public and private sectors;
• we remain in good standing with our banks and our own suppliers and they will want to keep doing business with us;
• a business with high ethical standards is a good place to work; and
• it is a requirement of the REC Code of Professional Practice that we act with integrity at all times.

8. Policy Statement

All Relevant Persons and Associated Persons are required at all times:

• not to commit an offence listed above at section 4 or any other offence;
• to comply with the Bribery Act
• to act honestly, responsibly and with integrity;
• to safeguard and uphold the Company’s core values by operating in an ethical, professional and lawful manner at all times.

Bribery of any kind is strictly prohibited. Under no circumstances should any provision be made, money set aside or accounts created for the purposes of facilitating the payment or receipt of a Bribe. The Company recognises that industry practices may vary from country to country or from culture to culture. What is considered unacceptable in one place may be normal or usual practice in another. You should seek appropriate guidance from the Company’s Compliance Officer. All Relevant Persons and all Associated Persons are expected to adhere strictly at all times to the guidelines set out in this Policy. If you are in doubt as to what might amount to bribery or what might constitute a breach of this Policy, refer the matter to your line manager.

9. Gifts & Hospitality

This Policy covers the offer or receipt of gifts, hospitality or expenses to ensure that any legitimate expenditure is recorded and does not improperly affect the outcome of procurement, application or any other business transaction.

1. The Company forbids any Relevant Person from soliciting any gift or hospitality in the course of his/her employment or engagement with the Company or, if a corporate entity, for the duration of any contract between that corporate entity and the Company.
2. The Company forbids any Relevant Person from offering or receiving from any person or organization who has had, has or may have any influence over the business of the Company:

(a). a personal or corporate gift to a value in excess of £50;

(b). hospitality to a value in excess of £50.

3. The Company forbids any officer, employee, temporary worker or contractor of the Company from offering or receiving any gift or hospitality which is in breach of relevant law.
4. The Company forbids any Relevant Person either directly or indirectly from making an offer of, or making a donation to any political, charitable or not for profit organisation in the course of his/her employment or engagement with the Company or, if a corporate entity, for the duration of any contract between that corporate entity and the Company, as a way to obtain an advantage in a business transaction.
5. The Company may exercise its discretion to permit gifts or hospitality which exceeds the threshold limits in paragraph 2. This discretion may only be exercised by the Managing Director.
6. All Relevant Persons must enter details of all gifts and hospitality made or received which are permitted by paragraphs 2, 4 and 5, onto the Central Register of Gifts. The Central Register of Gifts is reviewed and monitored by the Managing Director and the management of the Company and will be audited.

10. Facilitation Payment

Any payment or gift to a public official or other person to secure or accelerate the prompt or proper performance of a routine government procedure or process, otherwise known as a “facilitation payment”, is also strictly prohibited. Facilitation payments are not commonly paid in the UK but they are common in some other jurisdictions.

11. What are the Indicators of Bribery

Common indicators of corruption include those listed below. There may well be others. For example:

• payments are for abnormal amounts (e.g. commission), or made in an unusual way, eg what would normally be a single payments is made in stages, through a bank account never previously used, or in a currency or via a country which has no connection with the transaction;
• process is bypassed for approval or sign-off of terms or submission of tender documents, payments, or other commercial matters; those whose job it is to monitor commercial processes (e.g [insert person or department specific to Company, e.g. Internal Audit]) may be prevented from or hindered in doing so;
• individuals are secretive about certain matters or relationships and/or insist on dealing with them personally. They may make trips at short notice without explanation, or have a more lavish lifestyle than expected;
• decisions are taken for which there is no clear rationale;
• records are incomplete or missing.

12. Political Contributions

You should be aware that such contributions can be (or be seen as) Bribes in disguise. We do not make donations to political parties. No individual is to make a donation stated to be, or which could be taken to be, on our behalf without the prior approval of the Board. You may, of course, make political donations in a personal capacity but please be sensitive to how such contributions could be perceived, especially by those who are aware of your connection with the Company.

13. Charitable Donations

Bribes may even be disguised as charitable donations. Again, for that reason, donations we make are approved by resolution of the Board and recorded. Whilst individuals may of course make personal donations to charity, they should not do so on behalf of the Company without prior approval from the Board.

14. Local Circumstances

We understand that different parts of the world have different social and cultural customs. This does not affect our position that we do not pay or accept bribes or act corruptly: we do not and will not. However, subject to that position, we understand the need to be sensitive to local customs. For example, there are cultures in which refusing (or even failing to offer) a gift is considered impolite, and could alienate a key contact. In such cases, please refer to the Human Resources Department.

15. Exceptional Circumstances

In some circumstances a payment is justifiable. If one of our people is faced with a threat to his or her personal safety or that of another person if a payment is not made, they should pay it without fear of recrimination. In such cases, however, the HR Department must be contacted as soon as possible, and the payment and the circumstances in which it was made must be fully documented and reported to the Finance Director or Human Resources Manager for the business concerned within five working days.

Such cases will be rare. All Relevant Persons visiting regions where they are more common should familiarise themselves, prior to travel, with current guidance relating to those countries. The Human Resources Department should be consulted if in doubt.

16. Responsibility to Report and the Reporting Procedure

All Relevant Persons are contractually required to take whatever reasonable steps are necessary to ensure compliance with this Policy and to prevent, detect and report any suspected Bribery or corruption. All Relevant Persons have a duty to prevent, detect and report any incident of Bribery and any potential risks of Bribery. If you know or suspect that any Relevant Person plans to offer, promise or give a Bribe or to request, agree to receive or accept a Bribe in connection with the Company’s business, you must disclose this to your line manager as quickly as possible to allow appropriate action to be taken promptly.

The Company is committed to taking appropriate action against Bribery and corruption. This may include either reporting the matter to an appropriate external government department, regulatory agency or the police and/or taking internal disciplinary action against relevant employees and/or terminating contracts with associated persons.

The Company will keep your disclosure confidential during any investigation it undertakes to the extent that this is practical and appropriate in the circumstances. The Company will support anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. The Company is also committed to ensuring nobody suffers any detrimental treatment as a result of refusing to take part in bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential bribery or corruption offence has taken place or may take place in the future or because they may assist in the investigation of an allegation of Bribery or corruption.

17. Record Keeping

All accounts, receipts, invoices and other documents and records relating to dealings with third parties must be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off the record” to facilitate or conceal improper payments.

18. Monitoring Compliance

The Company’s Compliance Officer has primary responsibility for ensuring compliance with this Policy and will review its contents on a regular basis. S/he will be responsible for monitoring its effectiveness and will provide regular reports in this regard to the directors of the Company who have overall responsibility for ensuring this Policy complies with the Company’s legal and ethical obligations.

19. Training

The Company will provide training to all employees to help them understand their duties and responsibilities under this Policy. The Company’s zero tolerance approach to Bribery will also be communicated to all business partners at the outset of the business relationship with them and as appropriate thereafter.

20. Sanctions for Breach of this Policy

A breach of any of the provisions of this Policy by any Relevant Person who is an officer or employee of the Company will constitute a disciplinary offence and will be dealt with in accordance with the Company’s disciplinary procedure. Depending on the gravity of the offence, it may be treated as gross misconduct and could render the officer or employee liable to summary dismissal.

Breach of this policy by any Relevant Person who is a temporary worker, contractor or consultant providing his/ her services to the Company may lead to the immediate termination of that temporary worker’s, contractor’s or consultant’s engagement by the Company.

Breach of this policy by any Relevant Person which is a corporate entity could lead to the suspension or termination of any relevant contract, sub-contract or other agreement between the corporate entity and the Company.

The policy will be reviewed annually to ensure that it remains relevant.

Venesky-Brown Recruitment Ltd respects and values the privacy of our customers and clients. This Privacy Policy applies to our job candidates, our associates, users of this websites, and representatives of our clients.

This Policy describes the types of information we collect, how we use the information, who we share it with, how we protect your information and the rights of individuals regarding our use of their information.

Information We Collect

Information Collected By Automated Means

How We Use the Information We Collect

Interest-Based Advertising

Information We Share

Your Rights And Choices

Data Transfers

How We Protect Personal Information

Links To Third-Party Sites, Apps and Services

Updates To Our Global Privacy Policy

How To Contact Us

Information We Collect

Venesky-Brown collects personal information about through our Site and social media channels; our events; phone and fax; job applications and in connection with in-person recruitment; and in connection with our interactions with clients and vendors, in addition to other methods. We may collect the following types of personal information (as permitted by local law):

• Contact information (such as name, postal address, email address and telephone number)
• Information you provide about friends or other people you would like us to contact
• Other information you may provide to us, such as in surveys or through the “Contact Us” feature on our Site
• Employment and education history
• Language proficiencies and other work-related skills
• National Insurance Number, Birth Certificate or other government-issued identification number
• Date of birth
• Gender
• Disabilities and health-related information
• Results of drug tests and criminal and other background checks
• Tax-related information
• Information provided by references
• Information contained in your resume or C.V., information you provide regarding your career interests, and other information about your qualifications for employment.

Venesky-Brown also collects information you provide to us about other individuals, such as information related to emergency contacts.

Information Collected By Automated Means

When you visit the Venesky-Brown site, we may collect information by automated means, such as cookies, web beacons and web server logs. The information we may collect in this manner includes IP address, unique device identifier, browser characteristics, device characteristics, operating system, language preferences, referring URLs, information on actions taken on our Site, dates and times of visits to our Site and other usage statistics.

A “cookie” is a file that websites send to a visitor’s computer or other Internet-connected device to identify the visitor’s browser or to store information or settings.

A “web beacon” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and is used to transmit information collected through cookies back to a web server.

Through these automated collection methods, we may obtain “clickstream data,” which is a log of the links and other content on which a visitor clicks while browsing a website: a record of the users click-action may be collected and stored. Some data elements collected through automated means, such as your browser information, may be linked with other information we have obtained about you: i.e., we may track open rate and click rates of emails.

Some browsers offer notifications of cookies and restriction options, but please note that disabling cookies may prevent you from using all of the features of our Site. To the extent required by applicable law, we will obtain your consent before collecting personal information using cookies or similar automated means.

The providers of third-party apps, tools, widgets and plug-ins on our Site, such as social media sharing tools, also may use automated means to collect information regarding your interactions with these features. This information is collected directly by the providers of the features and is subject to the privacy policies of these providers. Subject to applicable law, Venesky-Brown Recruitment Ltd is not responsible for these providers’ information practices.

How We Use the Information We Collect

Venesky-Brown use the information described above to perform the following activities (as permitted by local law):

• Providing labour solutions and connecting people to work
• Creating and managing online accounts
• Processing payments
• Managing our clients and vendors
• Sending promotional materials, including alerts regarding available positions, special events, programmes, offers, surveys, contests and market research
• Responding to individuals’ inquiries
• Operating, evaluating and improving our business (including developing, enhancing, analysing and improving our services; managing our communications; performing data analytics; and performing accounting, auditing and other internal functions)
• Protecting against, identifying and seeking to prevent fraud and other unlawful activity, claims and other liabilities
• Complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies.

In addition to the activities listed above, if you are an associate or job candidate and you apply for a position or create an account to apply for a position, as permitted by local law, we use the information described in this Privacy Policy to:

• Provide you with job opportunities and work
• Provide HR services to you, including administration of benefit programmes, payroll, performance management and disciplinary actions
• Provide additional services to you, such as training, career counselling and career transition services
• Assess your suitability as a job candidate and your associate qualifications for positions
• Perform data analytics, such as (i) analysing our job candidate and associate base; (ii) assessing individual performance and capabilities, including scoring on work-related skills; (iii) identifying skill shortages; (iv) using information to match individuals and potential opportunities, and (v) analysing pipeline data (trends regarding hiring practices).

Venesky-Brown also may use the information in other ways for which we provide specific notice at or prior to the time of collection.

In addition, Venesky-Brown use information collected through cookies, web beacons, pixels, web server logs and other automated means for purposes such as (i) customising the user’s site experience; (ii) providing tailored content; and (iii) managing our Site and other aspects of our business. To the extent required by applicable law, we will obtain your consent before collecting information using cookies or similar automated means.

Venesky-Brown also uses third-party analytics services on our Sites, such as those of Google Analytics and Adobe Omniture. The analytics providers that administer these services use technologies such as cookies, web server logs and web beacons to help us analyse your use of our Sites. The information collected through these means (including IP address) may be disclosed to these analytics providers and other relevant third parties who use the information, for example, to evaluate the use of the Site. To learn more about these analytics services and how to opt out, please visit the following sites:

Google Analytics: tools.google.com/dlpage/gaoptout

Adobe Analytics: adobe.com/privacy/analytics.html#1

Interest-Based Advertising

On the Venesky-Brown site, we may collect information about your online activities to provide you with tailored advertising. We also may obtain information for this purpose from third-party websites on which our ads are served.

You may see certain ads on other websites because we engage third-party advertising networks. Through such advertising networks, we can target our messaging to users through demographic, interest-based and contextual means. Through the ad networks, we can track your online activities over time by collecting information through automated means, including through the use of third-party cookies, web server logs, pixels and web beacons. The information our advertising networks may collect on our behalf includes data about your visits to websites that serve Venesky-Brown advertisements, such as the pages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Sites and on third-party websites that participate in these ad networks. This process also helps us track the effectiveness of our marketing efforts. To learn how to opt out of this ad network interest-based advertising, please visit aboutads.info/choices/. To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising.

Venesky-Brown’s sites are not designed to respond to “do not track” signals from browsers.

Information We Share

Venesky-Brown will not disclose personal information collected about you, except as described in this Privacy Policy or in separate notices provided in connection with particular activities. We share personal information with vendors who perform services on our behalf based on our instructions. We do not authorise these vendors to use or disclose the information except as necessary to perform services on our behalf or comply with legal requirements. We also may share your personal information (i) with our subsidiaries and affiliates; (ii) if you are a job candidate, with clients who may have job opportunities available or interest in placing our job candidates; and (iii) with others with whom we work, such as job placement consultants and subcontractors, to find you a job.

In addition, Venesky-Brown may disclose information about you (i) if we are required to do so by law or legal process; (ii) to law enforcement authorities or other government officials based on a lawful disclosure request; and (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We reserve the right to transfer personal information we have about you in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganisation, dissolution or liquidation).

Information collected through third-party plug-ins and widgets on the Venesky-Brown site is collected directly by the providers of the plug-ins and widgets, and is subject to the privacy policies of the providers of the plug-ins and widgets. Venesky-Brown is not responsible for those providers’ information practices.

Your Rights and Choices

Venesky-Brown offers choices about how we collect personal information and communicate with you: to update your preferences on mailing lists, exercise your rights or submit a request, please contact us as indicated in the “Contact Us” section of this Privacy Policy. To the extent provided by the law of your jurisdiction, you may request access to the personal information we maintain about you or request that we correct, amend, delete or block the information by contacting us as indicated below. Where provided by law, you may withdraw any consent you previously provided to us or object at any time on legitimate grounds to the processing of your personal information, and we will apply your preferences going forward.

How We Protect Personal Information

Venesky-Brown maintains administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use.

Updates to our Global Privacy Policy

The Venesky-Brown Privacy Policy may be updated periodically to reflect changes in our personal information practices. For significant changes, we will notify you by posting a prominent notice on our Site indicating at the top of the Policy when it was most recently updated.

Contact Us

For queries, questions or comments regarding this Privacy Policy, please write to info@venesky-brown.co.uk.

Terms and Conditions

Terms

Lawful Use

Links

Copyright

Protected Rights

Changes to these Terms and Conditions

The Accuracy of your Registration Information

Your Username and Password

Information that you submit on the website

Governing Law and Applicable Legislation

Terms
“Venesky-Brown” shall mean Venesky-Brown Recruitment Ltd.

Use of this website is governed by these Terms and Conditions and you agree to be bound by them each time you access the website.

The material on this website is provided purely for your information, and should not be taken as legal advice. Please make independent inquiries before relying on such information. Venesky-Brown may make alterations to the website at any time: the latest version of the website shall prevail.

Any employment placement will be subject to Venesky-Brown’s current standard employment terms and conditions.

The information on this website is updated from time to time. Whilst Venesky-Brown has made every effort to ensure the accuracy and completeness of information on this website, Venesky-Brown makes no representations or warranties whatsoever, express or implied, as to the quality, accuracy or completeness of such information.

Venesky-Brown may without notice modify, suspend or discontinue the website or any part of it at any time without any liability to you or any third party.

To the full extent permitted by law, Venesky-Brown accepts no liability in contract, tort or otherwise (including liability for negligence) for loss or damage of any kind including without limitation: direct or indirect loss or damage, loss of business, revenue or profits, corruption or destruction of data, or any other consequential loss or damage arising out of your use or inability to use the website (or other site linked to the website) or in connection with any computer virus or system failure.  Venesky-Brown excludes any such liability even if Venesky-Brown is expressly advised of the possibility of such damage or loss.

You will indemnify Venesky-Brown against all costs, losses, expenses or other liabilities incurred by Venesky-Brown arising from the use of the website by you.

Lawful Use
You will use the website for lawful purposes only.

Links
You should note that Venesky-Brown provides links to websites maintained by others. Venesky-Brown accepts no responsibility or liability for the accuracy or legality of any content contained in such websites. The fact that you may use a Venesky-Brown link to access other websites is not an endorsement by Venesky-Brown of any content contained in those websites. Neither you nor any third party may link another site to the Venesky-Brown website without Venesky-Brown’s prior written consent.

Copyright
Unless otherwise stated, the copyright and similar rights for this website and all its content belong to Venesky-Brown Recruitment Ltd.  You are only permitted to copy or print extracts of the material for your own personal use. You may not use any of this material for commercial or public purposes.

All rights reserved. No part of this website may be transmitted, reproduced or redistributed mechanically or electronically without prior written permission of Venesky-Brown. Any request for such permission may be sent to Venesky-Brown by e-mail to info@venesky-brown.co.uk.

Protected Rights
Venesky-Brown is the registered trademark of Venesky-Brown Recruitment Ltd. Misuse or reproduction of any Venesky-Brown trademark, service mark, logo or any other intellectual property right contained on this website is strictly prohibited. You agree not to use the website in any way which infringes, or is likely to infringe, any trademark, service mark, logo, copyright or any other intellectual property rights of Venesky-Brown.

Changes to these Terms and Conditions
Venesky-Brown may add to or change these Terms and Conditions from time to time. You are deemed to have accepted changed or additional Terms and Conditions when you access the website following any such change or addition.

The Accuracy of your Registration Information
You are responsible for ensuring that any information you provide to Venesky-Brown, including your CV, is accurate, complete and your own. If Venesky-Brown has any reason to believe that any information you have supplied is false, inaccurate or not your own, we may prohibit you from using this site.

Information that you submit on the website

Venesky-Brown will store any personal information submitted via our Website, for up to two years, in line with UK-GDPR legislation. We will only collect, process and share personal data fairly and lawfully, for the purposes of recruitment. Please review our UK-GDPR policy for further information here.

Venesky-Brown reserves the right, at your cost, at any time to remove any material from the site which it believes to be salacious, defamatory or offensive or which Venesky-Brown believes may be in breach of a third party’s rights, such as a third party’s intellectual property or confidentiality rights. You agree to indemnify Venesky-Brown on a full and continuing basis against any loss or damage suffered or costs (including legal costs) incurred by Venesky-Brown in defending any action brought against Venesky-Brown as a result of any information you have posted on the website.

Governing Law and Applicable Legislation
These Terms and Conditions are governed by Scottish law and you agree that the Scottish courts shall have exclusive jurisdiction to determine any matter or dispute arising out of or in connection with use of this website and these Terms and Conditions.

It is not intended that a third party should have the right to enforce any provision of the Terms and Conditions pursuant to the Contracts (Rights of Third Parties) Act 1999 Scotland. Furthermore, Venesky-Brown may, and without the consent of a third party to whom the right of enforcement of any of the terms has been expressly provided, vary and amend the Terms and Conditions.

Use of the Venesky-Brown website may not be allowed in countries outside the United Kingdom where such use may be contrary to local law or regulation. If you access information on this website it is your sole responsibility to ensure compliance with any applicable laws or regulations in any other country. Any use of this website outside the United Kingdom is your responsibility and we accept no liability whatsoever in connection with such use.

Venesky-Brown has the right at any time to terminate or suspend access to, or use of, the website where we reasonably believes you have infringed the Terms and Conditions.

Venesky-Brown Recruitment Ltd Registered Office 4A Rutland Square, Edinburgh

Please find below printable and downloadable copies of our GDPR polices.

GDPR Policy 

Privacy Notice

1. Introduction

Venesky-Brown Recruitment is committed to conducting its business with honesty and integrity and aims to achieve the highest possible standards of service and ethical standards in all of its practices.
We expect all staff to maintain the same high standards too; however, all organisations face the risk of things going wrong and sometimes malpractice and wrongdoing can take place. We take malpractice and wrongdoing very seriously and aim to prevent and eliminate any wrongdoing or malpractice within the organisation.

We therefore encourage all staff to raise any concerns they may have about malpractice or wrongdoing within the organisation freely and without fear of suffering a detriment or dismissal to enable us to eliminate and prevent wrongdoing or malpractice within the organisation.
We will treat any concerns raised seriously and will protect and support any individual who makes a disclosure in line with this policy.
We will provide regular training to all staff in relation to whistleblowing law and this policy.

This policy does not form part of any contract; Venesky-Brown Recruitment reserves the right to amend this policy at any time without prior notice.

2. Scope

The scope of this Whistleblowing Policy covers all employees based at the Venesky-Brown head office in Edinburgh covering the administration and management of the supply of person labour to the construction, engineering, IT and professional industries.

3. Who can raise a concern under this policy?

This policy applies to all current and former employees, workers, officers, consultants, contractors of our business, including home workers, trainees, apprentices, agency workers, casual workers and limited company contractors.

No qualifying length of service is required in order to raise a concern under this policy.

4. When to use this policy

This policy should be used to report concerns of malpractice or wrongdoing in relation to our organisation’s activities where you have information which you reasonably believe tends to show one or more of the following:

• that a criminal offence has been committed, is being committed or is likely to be committed, excluding those in relation to bribery and corruption, which should be reported using the procedure set out in the Anti-Bribery and Corruption Policy; or
• that a person has failed, is failing or is likely to fail to comply with any legal obligation to which he or she is subject, excluding those in relation to bribery and corruption, which should be reported using the procedure set out in the Anti-Bribery and Corruption Policy.; or
• that a miscarriage of justice has occurred, is occurring or is likely to occur; or
• that the health or safety of an individual has been, or is being or is likely to be endangered; or
• that the environment has been, is being or is likely to be damaged; or
• that any of the above malpractices have been, are being or are likely to be deliberately concealed. This applies whether the malpractice has already occurred, is currently in progress, or is likely to happen in the future.
• This policy also covers matters which are specific to our business, namely the REC Code of professional practice

You must reasonably believe that the disclosure is being made in the public interest.

It doesn’t matter if you are mistaken about your concern but you must have information that tends to show some malpractice or wrongdoing rather than an opinion or a feeling.

5. Disclosures that are not covered by this policy

You will not qualify for protection under this policy if you commit an offence in making the disclosure, or if you disclose a matter that is subject to legal, professional privilege (for example, correspondence between Venesky-Brown Recruitment and our lawyers regarding a specific case).

If your concern relates to your own treatment as an employee of Venesky-Brown Recruitment, including personal circumstances at work, you should raise it under our grievance procedure instead, unless you reasonably believe that the matter is in the public interest.

If your concern relates to your own treatment or personal circumstances at work but you are not an employee of Venesky-Brown Recruitment, you should use our complaints procedure instead of the grievance procedure. Our complaints policy is available on Venesky-Brown’s internal shared drive.

If you wish to raise a concern of suspected malpractice or wrongdoing in relation to a hirer’s activities you may need to raise the concern directly with the hirer instead.

Any other concerns about our services generally which are not related to the types of wrongdoing or malpractice covered by this policy should be raised using our complaints policy instead.
Venesky-Brown Recruitment, Ltd., 4a Rutland Square, Edinburgh, EH1 2AS
t: 0131 357 2140 e:

info@venesky-brown.co.uk

w: www.venesky-brown.co.uk

Company Registration No: 279944

6. How to raise a concern

If you have any concerns of the types of malpractice or wrongdoing covered by this policy, you should in the first instance make a disclosure to your immediate superior. Agency workers should disclose concerns to the consultant who is responsible for managing their assignment.

If, for any reason, you feel that you cannot tell your immediate superior, or in the case of an agency worker the consultant responsible for managing your assignment, you should raise the issue with the HR Manager or the Managing Director.

If you have made a disclosure and are still concerned, or the matter is so serious that you feel you cannot discuss it with either of the two persons named above, you should raise the matter with the following member of management: Craig Brown, Director.

A disclosure of a concern can be made by telephone, in person or in writing (including by email). However, it is preferable for the disclosure to be made in writing so that we can keep an exact record of your concern.
You are not expected to prove the truth of your concern beyond reasonable doubt or provide any evidence; however, you will generally need to provide the following information as a minimum:

• the nature of the concern;
• why you believe it to be true;
• the background and history of the concern; and
• relevant dates where possible.

You can raise any concerns anonymously; however, we encourage you to give your name when reporting your concern wherever possible because it may be more difficult for us to protect your position or give you feedback on the outcome of investigations if you choose to remain anonymous.
You may wish to consider discussing your concern with a colleague before raising it formally under this policy. You can also choose to raise a concern under this policy alone or with a colleague; however, it is in the interests of all parties to maintain confidentiality once you have raised a formal concern.

7. How do we respond to concerns raised under this policy?

We are committed to ensuring that all disclosures raised in accordance with this policy will be dealt with objectively, consistently, fairly and professionally.

We will take the time to listen to any issues raised and arrange a meeting as soon possible to discuss your concern (unless the concern has been raised anonymously). The aim of the meeting will be to establish the background and facts in order to help us decide whether and how to carry out any subsequent investigation. We may ask you for further information about the concern raised, either at this meeting or at a later stage.
You may bring a colleague to any meeting that takes place. The companion must respect the confidentiality of the disclosure and any subsequent investigation.

Any concerns you raise in line with this policy will be recorded in our Whistleblowing Report Register.

After the meeting, we will decide how to respond. This will usually involve making internal enquiries in the first instance, but it may be necessary to carry out an investigation at a later stage which may be formal or informal
Venesky-Brown Recruitment, Ltd., 4a Rutland Square, Edinburgh, EH1 2AS
t: 0131 357 2140 e:

info@venesky-brown.co.uk

w: www.venesky-brown.co.uk Company Registration No: 279944 depending on the nature of the concern raised. We will endeavour to complete investigations within a reasonable time.

We will keep you informed of the progress of the investigation as it is carried out and when it is completed, and give you an indication of the timescale for any actions or next steps that we may take. We cannot inform you of any matters that would breach any duty of confidentiality owed to others.

We will consider any concerns raised anonymously at our discretion, taking into account factors such as the seriousness of the issue raised, the credibility of the concern and the likelihood of confirming the allegation from other sources. However, concerns that are expressed completely anonymously are much less powerful and are difficult to investigate. It may also be difficult for us to provide you with feedback if you cannot be contacted.

If disciplinary or other proceedings follow the investigation, we may need to ask you to come forward as a witness to help us take appropriate action to end the wrongdoing. If you agree to this, you will be offered advice and support.

8. Confidentiality

All concerns raised will be treated as confidential and every effort will be made not to reveal the identity of any individual who raises a concern. Unless the law requires otherwise, we will only make disclosures to third parties or other staff with your consent.

9. Raising your concern externally (exceptional cases)

The main purpose of this policy is to give all our staff the opportunity and protection they need to raise concerns internally. We would expect that in almost all cases raising concerns internally would be the most appropriate course of action in order to resolve the issue.

However, if for whatever reason you feel you cannot raise your concerns internally and you reasonably believe the information and any allegations are substantially true and in the public interest, the law recognises that it may be appropriate for you to raise the matter with another approved person, such as a regulator, professional body, or an MP. A list of the relevant prescribed people and bodies that you can raise a concern with is available on the GOV.UK website here.

We strongly encourage individuals to seek appropriate advice before reporting a concern to an external person. Public Concern at Work is a leading independent charity whose main objective is to promote compliance with the law and good practice in the public, private and voluntary sectors. They are a source of further information and advice and operate a confidential helpline. ACAS also operate a free confidential helpline that you can contact for advice. The contact details for both organisations are set out in the information and contacts section under paragraph 10 below.

10. Protection & support for those raising concerns

We hope that all staff will feel able to voice their concerns freely under this policy.

Venesky-Brown Recruitment is committed to good practice and high standards and to being supportive of staff who raise genuine concerns under this policy, even if they turn out to be mistaken.

Any individual raising a genuine concern must not suffer any detriment as a result of doing so. If you believe that you have suffered such treatment, you should inform the HR Manager immediately.

Venesky-Brown Recruitment will not tolerate any harassment or victimisation of individuals who raise concerns about wrongdoing or malpractice in the workplace. No member of staff may threaten or retaliate against an individual who has raised a concern. Any person involved in such conduct may be subject to disciplinary action and in some cases will be liable to a claim for compensation brought against them personally

To ensure the protection of all our staff and the integrity of our business, those who raise a concern frivolously, maliciously and/or for personal gain and/or make an allegation they do not reasonably believe to be true and/or not made in the public interest may also be subject to disciplinary action.

If you are not happy with the way in which a matter has been addressed or dealt with you should raise it formally using our complaints procedure. Employees of Venesky-Brown Recruitment can use our grievance procedure to address the issue instead.

11. Further information & contacts

If you have any queries about the application of this policy, please contact the HR Manager in the first instance.

Public Concern at Work is a source of further information and advice. It also provides a free helpline offering confidential advice on 020 7404 6609. Further information is available on their website here.

The Advisory, Conciliation and Arbitration Service (ACAS) also has a free helpline that you can contact for further advice. The ACAS telephone number is: 0300 123 1100 and the helpline is open Monday to Friday from 8am to 8pm and Saturday from 9am to 1pm. The website can be found here.

If you are a member of a recognised trade union, you can also seek information and advice from your trade union representative.

The policy will be reviewed annually to ensure that it remains relevant.