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Policies


Compliance

We take great responsibility for providing highly skilled candidates to meet our client’s requirements. We work relentlessly to gather every piece of documentation, identification and reference to ensure 100% compliance. Our extensive candidate analysis, project-matching procedures and training programmes enable us to consistently provide a high-quality, experienced workforce in the shortest time possible.

Our collaboration scheme with our clients increases standards of HSQE performance throughout the workforce and achieves the safest possible working environment. We manage procedures through our integrated business system: this incorporates planning, communication, training, site inspections, audit, review and feedback to ensure continuous improvement.

This statement is made as part of Venesky-Brown’s commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act). It summarises how Venesky-Brown 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.

1. Our Business

Venesky-Brown is a limited company operating in the recruitment sector. We specialise in high quality labour provision across the UK in the civil engineering, rail and aviation sectors.
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.
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.

2. Our Policies

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

  • Equal Opportunities and Diversity Policy
  • Anti-Bribery Policy
  • Fatigue Management Policy
  • Modern Slavery 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

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 re- auditing a supplier or conducting spot checks.

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

  • 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.

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

4. 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 Labour Manager 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.

Introduction

Venesky-Brown is a specialist provider of staffing and project solutions predominantly for the construction and engineering industries. As a trusted partner to companies and a trusted source of work opportunities, Venesky- Brown has established itself as a market leader and a benchmark for quality and efficiency.
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.

Health, Safety & Environmental Objectives

Venesky-Brown recognises that health & safety is an integral part of business performance and our main objective is to ensure a safe work environment for all employees and others. Venesky-Brown will set and maintain objectives in order to achieve performance and compliance with legal requirements.
Venesky-Brown also places great importance on improving the environmental performance of the organisations operations and maintain its commitment. Therefore, the policy is to develop and maintain environmental performance as required by International Standard ISO 14001 and EMAS requirement, so that the business will be able to meet relevant environmental legislation and regulations in all its operations.
We strive to meet employee’s health, safety and environment policy statement by setting and maintaining the following objectives and continually improving:

  • 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.
  • 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, safety and environmental legislation.
  • Developing and implementing health, safety and environmental guidance and procedures to define our expectations and provide suitable information, instruction, training and supervision to enable employees to undertake their individual duties safely.
  • Reviewing accident statistics, monitoring health and safety compliance, setting targets and health and safety objectives to strive for improved health and safety performance.
  • Immediately report any environmental damage, spillage, leak, punctured or damaged drum, bag or vessel, or any loss of containment of any solid, liquid or gas on any site.
  • Appointing competent persons and providing adequate resources to enable health and safety obligations to be discharged.
  • Consulting with employees on matters affecting their health and safety and working with all stakeholders to develop safer working practices and conditions where appropriate.
  • Continually improve environmental performance.
  • Reduce waste and recycle products and materials.
  • Advocate effective usage of resources and materials and utilities.
  • Develop a healthy and environmentally friendly workplace.

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.
Therefore, as a minimum all employees must:

  • 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.

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

Venesky-Brown Recruitment aim to be a leader in implementing sustainable business practices that minimise harm and maximise benefit to the environment and our local community.

We will manage activities over which we have control and which impact upon its various ‘environments’ in accordance with the principles of sustainable development.

Venesky-Brown Recruitment Ltd aims to use resources efficiently and will minimise waste, usage of water and energy and will seek to prevent pollution if applicable to our business operation.

We aim to raise the sustainability awareness of its staff, visitors, candidates and customers by promoting the concept of sustainable development and by openly recognising the on-going need to move towards a more sustainable future.

We will monitor the use of resources, both non-renewable and renewable, and maximise the efficiency and effectiveness with which they are used, with a view to minimising environmentalimpacts.

We will provide appropriate sustainability training and development for its staff, and will encourage them to apply sound sustainability practices at work, at home and within the wider community.

Venesky-Brown Recruitment Ltd aims to use resources efficiently and will minimise waste, usage of water and energy and will seek to prevent pollution if applicable to our business operation.

Our day to day office environment is also geared towards being as environmentally friendly as possible. We try where possible to operate a paperless office, with cloud-based software replacing the need for printing. We naturally recycle as much as possible in the office and have dedicated recycling facilities on-site. We also actively encourage our staff to be more environmentally friendly and provide them with the resources needed, we provide free sustainable bags to all staff.

Venesky-Brown Recruitment Ltd encourages staff to cycle or walk to work where possible and to use public transport and if appropriate to car share. We are part of the cycle 2 work scheme and our pool cars are hybrid vehicles and staff are encouraged to use these for sitevisits.

Introduction

Venesky-Brown is a specialist provider of staffing and project solutions predominantly for the construction and engineering industries. As a trusted partner to companies and a trusted source of work opportunities, Venesky-Brown has established itself as a market leader and a benchmark for quality and efficiency.

Our approach

We are focused on providing services which embrace diversity and equal opportunities. We will seek to promote the benefits of diversity in all of our business activities and nurture a culture that reflects that belief.
As an employer we are committed to equality and valuing diversity within our entire workforce and will support our clients to ensure that they meet their equality and diversity goals.

Equal Opportunities and Diversity Policy

This document summarises Venesky-Brown’s approach to equality and valuing diversity. It is supported by the staff handbook and other corporate policies.
Venesky-Brown is committed to providing equality of opportunity and will not tolerate unlawful discrimination on any grounds.
We will demonstrate our commitment bin the following ways:

  • We commit to treating everyone equally irrespective of sex, sexual orientation, gender reassignment, marital or civil partnership status, age, disability, colour, race, nationality, ethnic or national origin, religion or belief, political beliefs or membership or non-membership of a Trade Union or spent convictions, and places an obligation upon all staff to respect and act in accordance with the policy.
  • We will build in legislative requirements and best practice across all business activities and provide training and guidance for our entire workforce in equal opportunities practice.
  • We shall avoid stipulating any unnecessary requirements which would exclude a higher proportion of a particular gender, sexual orientation, age, religion or racial group or which would exclude disabled job applicants; and will avoid prescribing any requirements as to marital or civil partnership status.
  • We shall 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 will ensure that each candidate is assessed only in accordance with the candidate’s merits, qualifications and abilities to perform the relevant duties required by the particular vacancy.
  • We will promote an environment free from discrimination, bullying and harassment and tackling behavior which breaches this.
  • As a company we will ensure that our clients, candidates and partners are supported by this policy and are treated fairly and with respect.
  • Venesky-Brown will not accept instructions from clients that indicate an intention to discriminate unlawfully.

The Venesky-Brown HR Manager is responsible for establishing the overall equal opportunities and diversity policy. It will review performance on a regular basis and review this policy on an annual basis.

Information for Staff on Discrimination

Unlawful discrimination occurs in the following circumstances:

Direct Discrimination

Direct discrimination occurs where one individual treats or would treat another individual less favourably because of sex, sexual orientation, gender reassignment, marital or civil partnership, age, disability, colour, race, nationality, ethnic or national origin, religion or belief, political beliefs (“the protected categories”).
It is unlawful for a recruitment consultancy to discriminate against a person on the grounds of a protected category:

  • 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 would also occur if a recruitment consultancy accepted and acted upon a job registration from an employer which states that certain persons are unacceptable due to a protected category, unless one of the exceptions applies, for instance, the job demands a genuine occupational requirement or in the case of age, the discrimination can be lawfully justified.

Indirect Discrimination

Indirect discrimination occurs where an agency or employer applies a provision, criterion or practice generally, which disadvantages a minority group in the community on the basis of a protected category.
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 a genuine occupational requirement or the instruction is lawfully discriminatory due to a statutory exception or objective justification, Venesky-Brown will not deal further with the vacancy unless the client provides written confirmation of such genuine occupational requirement, exception or justification.

Disabled Persons

Direct discrimination against a person occurs where, a person is treated less favourably because of disability, either their own disability or because someone they are associated with has a disability.
Indirect discriminations occurs when a practice, criterion or provision which cannot be objectively justified is applied to everyone but results in person with a disability being placed at a disadvantage.
Disability arising from discrimination occurs when a person is treated unfavourably because of something arising in connection with their disability.
Duty to make reasonable adjustments and to provide auxiliary aids and services. This is a similar protection to indirect discrimination in the other protected categories.
Where a provision, criterion or practice 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, it will be the duty of an employer to take such steps as are reasonable, in all the circumstances of the case, to remove the provision, criterion, practice or physical feature.
Agencies must take reasonable steps to provide auxiliary aids or services if this would make it easier for the disabled person to use their services. For instance, an appropriate auxiliary aid or service can include the provision of information on audiotape or provision of a sign language interpreter.
Venesky-Brown will not discriminate against a disabled person on the grounds of disability:

  • in the arrangements i.e. application form, interview or arrangements for selection for determining to 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 him or her to any other detriment (detriment will include refusal of training or transfer, demotion, reduction of wage, or harassment).

Venesky-Brown will accordingly 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.
Wherever possible Venesky-Brown 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.

Age

Venesky-Brown 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 persuade clients to recruit on the basis of competence and skills and not age.
Venesky-Brown 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.
Venesky-Brown will request age as part of its recruitment process but 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.

Part-time Workers

This Diversity Policy also covers the treatment of those employees and workers who work on a part-time basis, Venesky-Brown 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 also recognises that part time employees must be  treated the  same as full time employees in relation to training and redundancy situations.

1. ABOUT THIS POLICY

1.1 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.
1.2 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: (a) All staff are aware of their responsibilities regarding alcohol and drug misuse and related problems. (b) Staff who have an alcohol or drug-related problem are encouraged to seek help, in confidence, at an early stage. (c) Staff who have an alcohol or drug-related problem affecting their work are dealt with sympathetically, fairly and consistently.
1.3 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
1.4 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.
1.5 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.
1.6 This policy does not form part of any employees contract of employment and we may amend it at any time.
1.7 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. PERSONNEL RESPONSIBLE FOR THIS POLICY

2.1 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.
2.2 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.
2.3 Managers will, if appropriate, be given training in: (a) The nature and causes of alcohol and drug problems (b) The effect of alcohol and drug misuse on workplace safety and  performance (c) The assistance that can be provided by outside agencies

3. IDENTIFYING A PROBLEM

3.1 If you notice a change in a colleagues 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.
3.2 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.

4. ALCOHOL AND DRUGS AT WORK

4.1 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.
4.2 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).
4.3 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.
4.4 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.
4.5 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.

5. SEARCHES

5.1 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.
5.2 Any alcohol or drugs found as a result of a search will be confiscated and action may be taken under our Disciplinary Procedure.

6. DRUG SCREENING

6.1 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.
    6.2 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.
    6.3 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.
    6.4 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.
    6.5 A positive result may result in disciplinary action including dismissal following an investigation.

    7. MANAGING SUSPECTED SUBSTANCE MISUSE

    7.1 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.
    7.2 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: (a) discuss the reason for the investigation and seek your views on, for example, the deterioration of your work performance and/or behaviour; and (b) where appropriate, offer to refer you to an Occupational Health Provider, Specialist or GP for medical and/or specialist advice.
    7.3 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.
    7.4 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.
    7.5 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.
    7.6 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.

    8. PROVIDING SUPPORT

    8.1 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: (a) Referral to appropriate treatment providers, where necessary in conjunction with your GP (b) Time off work to attend treatment (c) 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
    8.2 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.

    9. CONFIDENTIALITY

    9.1 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.
    9.2 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.

    10. PERFORMANCE AND DISCIPLINARY ISSUES

    10.1 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.
    10.2 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.

    11. DRUGS AND ALCOHOL TESTING

    11.1 Alcohol Screening – Breath/Saliva testing for alcohol can be undertaken to ensure individuals are not under the influence of alcohol while at work.
    11.2 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.
    11.3 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.
    11.4 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.
    11.5 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.
    11.6 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.

    12. FACILITIES FOR TESTING

    12.1 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.

    13. NOTIFICATION OF TESTING

    13.1 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.

    14. UNDERTAKING THE TEST

    14.1 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.
    14.2 In the case of random testing, individuals should not be made aware at this stage that D&A testing is to be carried out.
    14.3 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.
    14.4 “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.”
    14.5 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.
    14.6 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.
    14.7 Testing is carried out by an independent tester. The alcohol test is done via a breathalyser which gives an instant result.
    14.8 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

    14.9 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.
    14.10 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.
    14.11 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.
    14.12 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.
    14.13 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).

    15. RETURNING TO WORK

    15.1 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.
    15.2 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.

 

Policy Statement

This policy has been created to comply with the requirements of The Bribery Act 2010.
Venesky-Brown has a zero-tolerance to bribery and corruption. This policy extends to all the Company’s business dealings and transactions and these both have a wide interpretation across all functions. The policy is given force in a detailed anti-bribery programme which is regularly monitored and reviewed to capture changes in law, reputation, demands and changes in our business.

Who Is Covered By This Policy?

All Directors, Staff and Business Relationships.

What is Bribery?

The offering, promising, giving, accepting or soliciting of an advantage as an inducement for an action which is illegal or a breach of trust.

What is Corruption?

The abuse of entrusted power for private gain or advantage. It hurts everyone whose life, livelihood or happiness depends on the integrity of people in a position of authority.

How will the Policy be implemented?

The Policy will be implemented by:

  • An anti-bribery programme which will be actively managed and communicated to all our staff, to ensure that the policy is fully and consistently delivered in all our business dealings and transactions across all functions.
  • The visible commitment of the Directors leading to the encouragement of the full participation of all Staff and all our business relationships.
  • The Directors will regularly monitor and review the events that could give rise to bribery, the risk exposure to these events and the adequacy of the risk treatments in place.  Internal control issues including those identified by Internal and External Audit on implementing the policy and programme will be regularly reported to the Directors.

What specific controls are in place?

Some of the Company’s activities expose it to particular risks of being involved in corruption, in particular:

  • Corporate hospitality and gifts: There is a risk that corporate hospitality, such as customer or supplier entertainment and the giving or receiving of gifts might be seen as bribery.
  • Facilitation Payments – We do not make facilitation payments under any circumstances. These are small unofficial payments made to secure or expedite the performance of a routine or necessary action to which the payer of the facilitation payment has legal or other entitlement.
  • Sponsorship and charitable donations – Any sponsorship for events and individuals and charitable donations can only be approved by the Directors, whose approval will be contingent on, among other things, their personal assessment that it is not a subterfuge for bribery. All such payments will be accurately recorded and clearly declared in our financial records, statements and reports.

What is expected of the people covered by this policy?

All Directors and staff will be required to:

  • Understand how the policy and programme impact on themselves and their job.
  • Attend any training or other events designed to communicate the policy and the programme.
  • Comply with the policy and the anti-bribery programme at all times.
  • Re-sign the policy each year as evidence of their continued understanding of the policy, the programme and the impact on themselves and their own job.
  • Seek advice if unclear or unsure of any aspect of this policy and programme.

In meeting these requirements no employee will suffer demotion, penalty or other adverse consequences for refusing to pay bribes even if the Company loses business.
All Business relationships will be required to:

  • Understand how the policy and programme impact on themselves and their relationship.
  • Attend any training or other events designed to communicate the policy and the programme.
  • Comply with the policy and the anti-bribery programme at all times.
  • Sign the policy as evidence of their continued understanding of the policy, the programme and the impact on themselves and their own relationship. This may be part of the contract terms for Suppliers or in documentation appropriate to the relationship.
  • Seek advice if unclear or unsure of any aspect of this policy and programme.

What are the penalties of breaching this policy?

The Bribery Act 2010 makes provision for individual and corporate responsibility with imprisonment for up to 10 years and unlimited fines depending upon the nature of the offence for individuals and corporate fines that may be unlimited
Directors and Staff will be subject to our disciplinary procedures which could result in dismissal. There is also the possibility that criminal and or civil legal action will be taken.
Those acting in a Business Relationship (including Agents, Suppliers and Contractors) with Venesky-Brown will have their business relationship terminated, the matter will be reported to the appropriate authorities and there is the possibility of criminal and or civil legal action.

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 post 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 post on the website

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