Handy AV are committed to achieving and maintaining a quality management system to benefit all customers, owners, staff and suppliers. Within this system, we will endeavor to meet all customer (current and future) requirements and exceed expectations, wherever possible. All customers are given the maximum support possible, to guarantee that their needs are fully understood and met, at every stage of the project. Every job is managed by a fully competent member of staff throughout the project, creating a positive working relationship with all clients. All relevant documentation is controlled, maintained and archived wherever necessary. We respect end-user privacy and no data is ever used or released without permission from the client. Periodic reviews of staff and work are carried out to ensure all standards are met, abilities and skills are being drawn on and any opportunities for improvement are utilized. We conform to all relevant safety requirements and continuously look to improve the impact of all our actions harmful to the environment, in line with our environmental policy.
The company is committed to ensuring the health, safety and welfare of its employees and others who may be affected by our activities so fas as is reasonably practicable. The Company will take steps to ensure that its statutory duties are met at all times. Each employee will be given such information, instruction and training as is necessary to enable the safe performance of work activities. Its is the duty of management to ensure that all processes and systems of work are designed to take account of health and safety and are properly assessed and supervised at all times. Adequate facilities and arrangements will be maintained to enable employees and their representatives to raise issues of health and safety. Competent people will be appointed to ensure the Company meets its statutory duties. Every employee must cooperate with us to enable all statutory duties to be complied with.The successful implementation of this policy requires total commitment from all categories of employee, from board directors to the latest recruit. Each individual has a legal obligation to take reasonable care of their own health and safety, and the safety of other people who may be affected by their acts or omissions. The Company will realise its policy by establishing a culture of continuous improvement through risk assessment and staff training. This policy will be regularly monitored to ensure that the objectives are achieved. It will be reviewed and, if necessary, revised in the light of legislative or company changes.
The company recognises that in our day-to-day operations we inevitably impact on the environment in a number of ways and we are committed to minimising the potentially harmful effects of such activity wherever and whenever possible. We have undertaken to help company staff understand and implement the relevant aspects of this policy in their day-to-day work through regular communication of objectives and action plans. We will also ensure that the company's suppliers and subcontractors are aware of this policy and promote the principles of sound environmental practice. The Board of Directors has ultimate responsibility for the company's environmental policy and performance. The company is committed to prevention of pollution and minimising the impact of its operations on the environment by means of a programme of continuous improvement. In particular Handy AV will: Meet and, where appropriate, exceed all relevant legislative and other requirements – where no regulations exist we shall aim to set our own environmental friendly standards. Seek to reduce consumption of materials in our operations, reuse rather than dispose whenever possible, and promote recycling and the use of recycled materials. Address energy efficiency into new/existing buildings and manage energy wisely in all operations. Reduce wherever practicable the level of harmful emissions. Develop products that are safe to use, make efficient use of resources, and which can be reused, recycled or disposed safely. Work in partnership with our suppliers to minimise the impact of their operations on the environment through a quality purchasing policy. Include environmental issues in discussions with management through meetings and encourage the implementation by all company staff of sound environmental practices. Monitor progress and publish details of our environmental performance on an annual basis. Take such measures, as is necessary, to ensure that any asbestos found on company property is identified, controlled and if applicable, disposed of in a manner that is safe to staff and the environment. The environmental policy is communicated in order to raise awareness amongst all company staff. This policy is published on the company's website and displayed on company notices in each building and reviewed annually.
This policy extends to our clients, client's employees and workers, and any place or venue where work is carried out is deemed to be a work environment and as such this policy applies. Handy AV recognises that discrimination is unacceptable, we have therefore made the decision to adopt a formal equal opportunities policy from the start of trading to ensure that it is built into the culture of the company from day one. Breaches of the policy by employees could lead to disciplinary proceedings and, if appropriate, disciplinary action. The aim of our policy is to ensure no client, job applicant, employee or worker is discriminated against either directly or indirectly on the grounds of race, colour, ethnic or national origin, religious belief, political opinion or affiliation, sex, marital status, sexual orientation, gender reassignment, age or disability. We ensure that our policy is circulated to any agencies responsible for our recruitment and a copy of the policy will be made available for all employees and made known to all applicants for employment. The policy is communicated to all private contractors reminding them of their responsibilities towards the equality of opportunity. The policy is implemented in accordance with the appropriate statutory requirements and full account will be taken of all available guidance and in particular any relevant Codes of Practice. Handy AV maintains a neutral working environment in which no employee or worker feels under threat or intimidated. The recruitment and selection process is crucially important to any equal opportunities policy. We endeavour through appropriate training to ensure that employees making selection and recruitment decisions will not discriminate, whether consciously or unconsciously, in making these decisions. Promotion and advancement is made on merit and all decisions relating to this are made within the overall framework and principles of this policy. Job descriptions, where used, are revised to ensure that they are in line with our equal opportunities policy. Job requirements will be reflected accurately in any personnel specifications. We adopt a consistent, non-discriminatory approach to the advertising of vacancies. We do not confine our recruitment to areas or media sources which provide only, or mainly, applicants of a particular group. All applicants who apply for jobs with us receive fair treatment and will be considered solely on their ability to do the job. All employees involved in the recruitment process periodically review their selection criteria to ensure that they are related to the job requirements and do not unlawfully discriminate. Short listing and interviewing will be carried out by more than one person where possible. Interview questions will be related to the requirements of the job and will not be of a discriminatory nature. We do not disqualify any applicant because he/ she is unable to complete an application form unassisted unless personal completion of the form is a valid test of the standard of English required for the safe and effective performance of the job. Selection decisions are not influenced by any perceived prejudices of other staff. Senior staff receive training in the application of this policy to ensure that they are aware of its contents and provisions. All promotions are in line with this policy. We maintain and review the employment records of all employees in order to monitor the progress of this policy. Monitoring may involve: The collection and classification of information regarding the race in terms of ethnic/ national origin and sex of all applicants and current employees; The examination by ethnic/ national origin and sex of the distribution of employees and the success rate of the applicants; and Recording recruitment, training and promotional records of all employees, the decisions reached and the reason for those decisions. The results of any monitoring procedure will be reviewed at regular intervals to assess the effectiveness of the implementation of this policy. Consideration will be given, if necessary, to adjusting this policy to afford greater equality of opportunities to all applicants and staff.
Under data protection law, we have to:
•Tell you about your rights regarding the processing and control of your personal data
•Keep your records accurate and held securely
• Keep only enough data to provide information about our products and services and meet our contractual responsibilities
•Only keep your information for as long as it is necessary for a specific purpose
•Process personal data fairly and lawfully
•Be transparent about what information we process and how we use personal information
What is personal data?
Personal data includes information that relates to an identified or identifiable person. This may include your name, email address, organisation you work for and job title. Information is also collected about how you use the Handy AV website.
What personal data do we collect?
We collect personal data when you interact with us for a legitimate business purpose as a customer or partner, or when you complete a form on our website.
How do we collect this data?
Information we collect includes:
•Your title (Mr, Mrs)
•Your name - first name and last name
•Your job title
•Your business email address (or personal email address if provided by you)
•Name and address of the organisation you work for
•Your business phone and/or mobile number (or personal number if provided by you)
•Your username for logging in to the secure areas of the Handy AV website
•Financial and payment data (channel partners and/or end users only)
•Details of products or services you have purchased
The personal information we have for you is made up of what you tell us, and data we collect when you use our services, or from related third parties we work with.
We may also collect information about your online and website activity such as:
•MAC address details
•Your IP address
•We may track the details of the pages you visit on our website such as pages viewed and the resources that you access. Such information includes traffic, location and other communication data.
Cookies and Tracking Technologies
•We may use IP address tracking technology to analyse data about website traffic to help us improve our services and provide you with more relevant content
•Cookies are used to make the website work better, as well as to provide information on how the site is used
•To understand and improve upon how our customers and partners are engaging with our email communications, we may use analytics tools to allow us to analyse open and click rates
How do we collect this data?
•When you enter into a legal or financial contractual agreement with Handy AV
•When you complete a form on the Handy AV website
•When you provide your details to us at an event/trade show
•When you sign up for a Handy AV webinar
•When you register to attend a Handy AV training course
•When you complete an online survey sent out by Handy AV
•When you register for access to the Support, Partner or Consultant sections of the Handy AV website
•When you send a message to our support team - we collect this data in order to reply to help you and answer your enquiry
•When you apply for a job vacancy at Handy AV
•When we purchase a list from a GDPR-compliant data broker for marketing communication purposes
Why and How do we use personal data?
Under data protection law, we can only use your personal data if we have legal basis for doing so, e.g.:
•For the performance of our contract with you or to take steps at your request before entering into a contract;
•To comply with our legal and regulatory obligations;
•For our legitimate interests or those of a third party (see below);
•For the establishment, exercise or defence of legal claims or proceedings; or
•Where you have given consent.
The basis on which we use your personal data
•If you have previously purchased products or services from us we use your data to provide to you details of related products or services, or other products and services in which you may be interested.
•We may use your personal information to tell you about relevant products and offers. This is what we mean when we talk about ‘marketing’.
•We study this to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
•We can only use your personal information to send you marketing messages if we have either your consent or a ‘legitimate interest’ to do so, which is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.
•You can ask us to stop sending you marketing messages by contacting us at any time.
•Whatever you choose, you will still receive commercial statements, and other important information such as changes to your existing products and services.
•We may ask you to confirm or update your choices, for example, if you take out any new products or services with us in future. We will also ask you to do this if there are changes in the law, regulation, or the structure of our business.
•If you change your mind you can update your choices at any time by contacting us.
Processing Personal Data on the basis of consent
Data may be processed if we have gained freely given consent from an individual for any number of reasons outlined above.
Consent can be withdrawn at any time by clicking on the unsubscribe link in any of our email communications or you can email email@example.com and we will ensure that your details are removed from our mailing lists as requested.
Processing Personal Data for a Legitimate Interest
What does Legitimate interest mean?
Legitimate interest means the interests of our company in conducting and managing our business to enable us to give our customers and channel partners the best and most secure experience. For example, we have an interest in making sure our marketing is relevant for you, so we may process your information to send you marketing that is tailored to your interests and which will enable you to effectively use and/or promote our products and services.
Processing is necessary for the purposes of legitimate interests pursued by Handy AV, the controller, or by a third party, our selected channel partners, to provide you with details relating to our products and services.
Why would we process your information for a legitimate interest?
We process personal information for certain legitimate business purposes, which include some or all of the following:
•Where the processing enables us to enhance, modify, personalise or otherwise improve our products, services and communications for the benefit of our customers
•To identify and prevent fraud
•To enhance the security of our network and information systems
•To better understand how people interact with our websites
•To determine the effectiveness of promotional campaigns and advertising
•To protect our commercially valuable information and also our intellectual property;
•To prevent and detect fraud and/or criminal activity that could be damaging for us and for you;
•For credit control purposes and to make sure our customers can pay for the goods and services we provide; and
•Ensuring we are able to keep up to date with our customers and contacts and developments in their organisations.
Whenever we process data on the basis of legitimate interest we will ensure that we always keep your personal data rights in high regard and take account of these rights. You have the right to object to this processing if you wish, and if you wish to do so please contact firstname.lastname@example.org. Please bear in mind that if you object this may affect our ability to carry out tasks above for your benefit.
Any marketing undertaken by Handy AV is processed in compliance with e-privacy regulation and direct marketing best practice.
We may process personal data for direct marketing by email. If you are an existing channel partner or customer it is important that we are able to keep you updated with the latest news about Handy AV products, services and events. We are therefore legally allowed to send direct marketing to personal data obtained using soft opt-in consent as outlined in the EU Privacy and Electronic Communications Regulation (PECR).
Processing Personal data with Consent for direct marketing
You may freely consent to your personal data being processed by Handy AV for direct marketing in the following circumstances:
•When you tick an optional field for opt-in on a form on the website
•Where you click through to opt-in from an opt-in button in an email
•When you leave a business card or have your details collected at an event/ trade show - we may verbally ask whether you consent to receive communications from us
•Signing a consent statement on a paper form to receive marketing communications - you may be asked to do this at a trade show or event
Where applicable we keep clear records of where, when and how consent was obtained.
We process personal data for the purpose of direct marketing by electronic means, i.e., email. For individuals who are not current channel partners or existing customers (e.g. we may have acquired your details by purchasing a list from a third party), we require that individuals give consent - or opt-in - to receive direct marketing in accordance with applicable laws.
We ensure you have a free and fully informed choice to exercise your right to consent or actively opt-in. Where explicit consent is to be gathered we endeavour to ensure that you are fully aware of what you are consenting to and how your personal data will be used. These purposes may fall under the section Why and How do we use personal data?
You are able to withdraw your consent at any time by clicking on the Unsubscribe link in any of our email communications or you can email email@example.com and we will ensure that your details are deleted as requested.
Disclosing your information
If we have acquired your personal data from a data broker for direct marketing purposes we will ensure that prior consent has been obtained and will request consent from you for any future communications. We will also ensure that any personal data that is disclosed to us is held safely and securely.
We may disclose your personal data in these circumstances:
•For any of the reasons highlighted in the section above labelled Why and How do we use personal data?
•To further protect and reduce the risk of fraud
•In the event that we sell any or all of our business to a buyer
How long do we keep your personal data?
We do not keep any personal data for any longer than is reasonably necessary. If you are an existing channel partner or customer, it is important that you receive product and services information to ensure you are kept informed and up to date with the latest news. We will continue holding and processing this personal data until told otherwise e.g. by unsubscribing to marketing communications. For individuals who are not existing channel partners or end users we will keep data until consent is withdrawn, e.g. by unsubscribing to marketing communications or any other means.
Data Storage and Security
We ensure that all data is stored securely. All data is stored on secure servers within the EEA and where applicable is held in password protected accounts and accessible only by relevant personnel. A company-wide firewall is in place to ensure security.
Unfortunately, the sending of information via the internet is not totally secure and on occasion such information can be intercepted. We cannot guarantee the security of data that you choose to send us electronically and it will be done so at your own risk.
If you ask us to delete your information in accordance with your rights set out below, we will retain basic information on a suppression list to record your request and to avoid sending you unwanted materials in the future.
You have the following rights regarding the processing of your personal data:
•The right to object to the processing of your personal data based on legitimate interests.
•The right to withdraw your consent to processing at any time. This can be done at any time by yourself by unsubscribing to email communications or emailing firstname.lastname@example.org. This does not affect the lawfulness of processing based on consent before withdrawal;
•The right to request your data is erased where it is no longer necessary for Handy AV to retain
•The right to port your personal information in certain circumstances;
•The right to lodge a complaint with the UK regulator, the Information Commissioner’s Office, if you have concerns about how we use your personal information. Please see https://ico.org.uk/concerns/ to find out more.
•You have a right to see what information we hold about you. This is known as Subject Access and can be obtained by emailing email@example.com
•Right to rectification - we ensure that all data that is held is up to date and accurate. You have the right to have any inaccurate personal data we may hold about you rectified.
•Right to restrict processing - you may consent not to receive marketing communications when you complete any forms on our website. As a result, we may store your personal data but will not process it for any reason as we do not have your consent.
Transfer of Data Across Borders
We may update this privacy notice where necessary. Please check back frequently to see any changes and where applicable, we will ensure you are informed of any changes that have been made.
Handy AV’s vision is that staff are its most precious resource. It is clear that our staff have a crucial role to play in achieving the vision and strategic goals of the company. Handy AV therefore needs to be able to attract and retain staff of the highest calibre. The purpose of this policy is to provide a sound framework, based around core principles that are outlined below, within which to facilitate this requirement. The accompanying procedure provides clear guidance on the key stages in recruiting and selecting for a post.
This policy and procedure encompass all activities that form part of the recruitment and selection process. It is applicable to all staff recruitment irrespective of staff group or nature of employment. In order for the policy and procedure to be effective it is essential that any employee who is involved in any aspect of the recruitment and/or selection of staff is aware of this document and adheres to it. Ultimately it is the responsibility of the senior management of Handy AV to ensure that this is the case.
Core principles. Handy AV Limited will seek to attract the best candidate for the job based on merit and ensure the identification of the person best suited for the job. Handy AV Limited will ensure that the recruitment and selection of staff is conducted in a professional, timely and responsive manner and in compliance with current employment legislation. Handy AV Limited will provide appropriate training, development, and support to those involved in recruitment and selection activities in order to meet this core principle. Any member of staff involved in the selection of staff should satisfy him or herself that he/she is appropriately trained and can comply with the requirements of this policy and procedure. Recruitment and selection is a key exercise and should enhance the reputation of the company. Handy AV Limited will treat all candidates fairly, equitably and efficiently, with respect and courtesy, aiming to ensure that the candidate experience is positive, irrespective of the outcome. Handy AV Limited will continuously develop its practices to allow new ideas and approaches to be incorporated. We will ensure that its recruitment and selection process is cost effective.
When a vacancy first arises, whether this is due to the current post holder moving internally or externally, or a new role, it is important to evaluate carefully the continuing need for the role and in the context of the strategic plan. Consideration should be given to the purpose and content of the role as well as where it fits into the structure of the company.
Job description and person specification. A job description and person specification will be produced or updated for any vacant post that is to be filled. · The job description should accurately reflect all elements of the post. · The person specification should state both the essential and desirable criteria in terms of skills, aptitudes, knowledge and experience that are required for the job, all of which should be directly related to the job and applied equally to all applicants. Care should be taken when drawing up the person specification to avoid including criteria that may have the effect of indirectly discriminating against certain groups of applicants. All posts should be authorised prior to being advertised.
Advertising/attracting applicants. An advert, job description and person description are required to proceed to advertising stage. Advertisements should be based on the person specification and identify a number of the essential criteria required of the candidate in order to maximize the number of suitable applicants. There may be occasions where it is appropriate to make exceptions to normal advertising arrangements and an appointment is made without advertising. In such cases there will still however be a requirement for the applicant to go through a selection process to ensure that they meet all the essential criteria for the position. In certain circumstances it may be more effective to use a recruitment agency than to advertise externally. This will not however eliminate the need to advertise the position internally. All external job advertisements will be published as a minimum on the company website. Staff who have been acting-up in a position that subsequently becomes vacant will have to apply for the position when it is advertised. The closing date for applications will be included with the advert details online.
Managing the Application process. Applicants should complete an application, which may be online. Equal opportunities data will be completed by applicants
Short listing. All applicants should be assessed against the person specification and should meet, as a minimum, criteria identified as is possible to assess from the initial application. Those involved in short-listing should only use the evidence provided in the application when assessing the applicant against the criteria and should not use information obtained informally from other sources, e.g.social media. Short listing for all posts should be undertaken by a minimum of two people to avoid any possibility of bias, one of whom would normally be the direct line manager. Short listed candidates should be provided with details of the selection process, including any tests, by email or in writing giving as much prior notice as possible. Candidates with disabilities are asked to advise the recruiting manager if there are any particular arrangements or reasonable adjustments that should be made so that they can participate fully in the selection process. Applicants that have not been short-listed will receive an email from the company. Any member of staff involved in a selection process who has a personal or familial relationship with an applicant must bring this to the attention of the interviewing panel.
Selection. It is recommended that a range of selection methods, for assessing both the essential and desirable criteria in the person specification are established in advance of the selection process as this will enhance objective decision making which is difficult through interview alone.
· Interview questions and the structure of the interview should be consistently applied to all candidates and should be based on the person specification although this does not prevent interviewers from asking follow up questions to obtain more detail that are specific to an individual candidate.
· Wider knowledge of the candidates e.g. social media, LinkedIn, shared working may form part of the discussions during and following interview as appropriate.
· Notes recording the salient points of the interview should be taken, so that they can be referred to when assessing candidates against the person specification and making decisions. These interview notes and any other notes on the candidate taken during the recruitment and selection process should be kept for a minimum of one year following the selection process by the recruiting manager responsible for the process.
In the event that a candidate requests feedback about their performance in the selection process this should be provided by the recruiting manager. Unsuccessful interview candidates should be dealt with courteously and sensitively. The recruiting manager is responsible for contacting candidates after interview to communicate the outcome of the interview. Where there is disagreement amongst a panel as to the successful candidate the majority view shall prevail.
References. Information sought from referees should be structured around the requirements of the job and the job description should be provided. It should be noted that many organisations have a policy of not providing personal references and therefore references provided may only confirm details of current appointment. Usually 2 references will be taken up. This will normally be after the interview when a verbal offer is made, for reasons of confidentiality, unless the candidate has given explicit approval to take up references prior to interview. However, referees must not be contacted in any circumstances if the candidate has not given consent on the application form. Ultimately all offers are subject to satisfactory references and if a candidate is unable to comply with this requirement this could result in the offer of employment being withdrawn. The information provided should be treated as confidential and should be used only to verify information collected through the selection process. Documents relating to all applicants will be treated with the utmost confidentiality and in accordance with the Data Protection Act.
Making the appointment. It is normal practice for a verbal offer to be made after the interview by the recruiting manager although they have the discretion to delegate this responsibility. Once a selection decision has been made following all requirements listed above and clearance with the finance manager a written offer of employment will be made. Offers of employment are subject to satisfactory references and any medical clearance and any other checks as appropriate, such as Asylum and Immigration checks, Disclosure and Barring service checks (where eligible).
Joining the organisation. It is important that new employees receive a well-planned induction in order for them to become fully operational quickly. Further information on induction can be found in our training policy.
Modern slavery is a crime and a violation of fundamental human rights. All types of modern slavery have in common the deprivation of a person's liberty by another in order to exploit them for personal or commercial gain. We are committed to acting ethically and with integrity in all our business dealings and relationships and to ensure modern slavery is not taking place anywhere in our own business, or in any of our supply chains.
We are also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our business relationships, consistent with our disclosure obligations under the Modern Slavery Act 2015. As part of this process, we will undertaken a review of our supply chain to identify and assess potential risk areas and maintain a register detailing the same.
We expect high standards from all of our subcontractors, suppliers and other business partners and will make this a contractual term in our agreements with significant suppliers wherever possible.
This policy applies to all persons working for us or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, interns, agents, contractors, external consultants, third-party representatives and business partners.
This policy does not form part of any employee's contract of employment and we may amend it at any time.
RESPONSIBILITY FOR THE POLICY
The management of the firm has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all of our people comply with it.
The financial department has primary and day-to-day responsibility for implementing this policy, but the managing director provides assistance with reviewing the risk profile of our supply chain to ensure that any procedures implemented are effective in countering modern slavery.
COMPLIANCE WITH THE POLICY
People must ensure that they read, understand and comply with this policy.
The prevention, detection and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. People are required to avoid any activity that might lead to, or suggest, a breach of this policy.
Although people should report any concerns regarding modern slavery and/or human trafficking in any parts of our business or supply chains in accordance with our whistleblowing policy, they are also encouraged to discuss a specific matter (or our policy or relevant legislation) with any member of the management.
If people are in any doubt about whether a particular act or working conditions in any of our business relationships may contravene any aspect of this policy then err on the side of caution and report it in accordance with the whistleblowing policy, or speak to a member of the legal department. Continued:-
We encourage openness and will support anyone who raises genuine concerns in good faith in accordance with the firm’s whistleblowing policy, even if they turn out to be mistaken. We are committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their knowledge, or suspicion, that modern slavery is taking place in any part of our business or in any of our supply chains.
COMMUNICATION AND AWARENESS OF THIS POLICY
Our zero-tolerance approach to modern slavery is communicated to all significant suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.
BREACHES OF THIS POLICY
Any employee who breaches this policy could face disciplinary action, which could result in dismissal for misconduct or gross misconduct.
We may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.
1.1 This anti-bribery policy exists to set out the responsibilities of Handy AV Limited and those who work for us in regards to observing and upholding our zero-tolerance position on bribery and corruption.
1.2 It also exists to act as a source of information and guidance for those working for Handy AV Limited . It helps them recognise and deal with bribery and corruption issues, as well as understand their responsibilities.
2. Policy statement
2.1 Handy AV Limited is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented. Handy AV Limited has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate.
2.2 Handy AV Limited will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, in regards to our conduct both at home and abroad.
2.3 Handy AV Limited recognises that bribery and corruption are punishable by up to ten years of imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine, be excluded from tendering for public contracts, and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business, and take our legal responsibilities seriously.
3. Who is covered by the policy?
3.1 This anti-bribery policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK).
3.2 In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.
3.3 Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum standards and procedures relating to anti-bribery and corruption.
4. Definition of bribery
4.1 Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.
4.2 A bribe refers to any inducement, reward, or object/item of value offered to another individual in order to gain commercial, contractual, regulatory, or personal advantage.
4.3 Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.
4.4 Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company’s compliance manager.
4.5 A foreign or government official could include a public official, whether foreign or domestic; a political candidate or party official; a representative of government owned or majority controlled organisation; or an employee of a public international organisation.
4.6 Corruption is the misuse of entrusted power for personal gain.
5. What is and what is NOT acceptable
5.1 This section of the policy refers to 4 areas:
• Gifts and hospitality.
• Facilitation payments.
• Political contributions.
• Charitable contributions.
5.2 Gifts and hospitality Handy AV Limited accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements:
a. It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favours or benefits.
b. It is not made with the suggestion that a return favour is expected.
c. It is in compliance with local law.
d. It is given in the name of the company, not in an individual’s name.
e. It does not include cash or a cash equivalent (e.g. a voucher or gift certificate).
f. It is appropriate for the circumstances (e.g. giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).
g. It is of an appropriate type and value and given at an appropriate time, taking into account the reason for the gift.
h. It is given/received openly, not secretly.
i. It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.
j. It is not above a certain excessive value, as pre-determined by the company’s compliance manager (usually in excess of £100).
k. It is not offer to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s compliance manager.
5.3 Where it is inappropriate to decline the offer of a gift (i.e. when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is declared to the compliance manager, who will assess the circumstances.
5.4 Handy AV Limited recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each.
5.5 As good practice, gifts given and received should always be disclosed to the compliance manager. Gifts from suppliers should always be disclosed.
5.6 The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the compliance manager should be sought.
5.7 Facilitation Payments and Kickbacks Handy AV Limited does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action.
5.8 Handy AV Limited does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.
5.9 Handy AV Limited recognises that, despite our strict policy on facilitation payments and kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may put their/their family’s personal security at risk. Under these circumstances, the following steps must be taken:
a. Keep any amount to the minimum.
b. Ask for a receipt, detailing the amount and reason for the payment
5.10 Political Contributions - Handy AV Limited will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage.
5.11 Charitable Contributions Handy AV Limited accepts (and indeed encourages) the act of donating to charities – whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes.
5.12 Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery.
5.13 We will ensure that all charitable donations made are legal and ethical under local laws and practices, and that donations are not offered/made without the approval of the compliance manager.
6. Employee Responsibilities
6.1 As an employee of Handy AV Limited, you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information you are given.
6.2 All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy.
6.3 If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify the compliance manager.
6.4 If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. Handy AV Limited has the right to terminate a contractual relationship with an employee if they breach this anti-bribery policy.
7. What happens if I need to raise a concern?
7.1 This section of the policy covers 3 areas:
a. How to raise a concern.
b. What to do if you are a victim of bribery or corruption.
7.2 How to raise a concern If you suspect that there is an instance of bribery or corrupt activities occurring in relation to Handy AV Limited, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behaviour can be considered bribery or corruption, you should speak to your line manager, the compliance manager, the director, or the Head of Finance and Legal.
7.3 Handy AV Limited will familiarise all employees with its whistleblowing procedures so employees can vocalise their concerns swiftly and confidentially.
7.4 What to do if you are a victim of bribery or corruption You must tell your compliance manager as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity.
7.5 Protection If you refuse to accept or offer a bribe or you report a concern relating to potential act(s) of bribery or corruption, Handy AV Limited understands that you may feel worried about potential repercussions. Handy AV Limited will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken.
7.6 Handy AV Limited will ensure that no one suffers any detrimental treatment as a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption.
7.7 Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised.
7.8 If you have reason to believe you’ve been subjected to unjust treatment as a result of a concern or refusal to accept a bribe, you should inform your line manager or the compliance manager immediately.
8. Training and communication
8.1 Handy AV Limited will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked to formally accept that they will comply with this policy.
8.2 Handy AV Limited ’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third-parties at the outset of business relations, and as appropriate thereafter.
8.3 Handy AV Limited will provide relevant anti-bribery and corruption training to employees etc. where we feel their knowledge of how to comply with the Bribery Act needs to be enhanced. As good practice, all businesses should provide their employees with anti-bribery training where there is a potential risk of facing bribery or corruption during work activities.
9. Record keeping
9.1 Handy AV Limited will keep detailed and accurate financial records, and will have appropriate internal controls in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts and acts of hospitality are subject to managerial review.
10. Monitoring and reviewing
10.1 Handy AV Limited ’s compliance manager is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness.
10.2 Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice.
10.3 Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the compliance manager.
10.4 This policy does not form part of an employee’s contract of employment and Handy AV Limited may amend it at any time so to improve its effectiveness at combatting bribery and corruption.
This policy provides guidance for employee use of social media, which should be broadly understood for purposes of this policy to include blogs, wikis, microblogs, message boards, chat rooms, electronic newsletters, online forums, social networking sites, and other sites and services that permit users to share information with others in a contemporaneous manner.
The following principles apply to professional use of social media on behalf of Handy AV as well as personal use of social media when referencing Handy AV.
• Employees need to know and adhere to the Handy AV's Code of Conduct, Employee Handbook, and other company policies, when using social media in reference to Handy AV.
• Employees should be aware of the effect their actions may have on their images, as well as Handy AV's image. The information that employees post or publish may be public information for a long time.
• Employees should be aware that [Handy AV] may observe content and information made available by employees through social media. Employees should use their best judgment in posting material that is neither inappropriate nor harmful to [Handy AV], its employees, or customers.
• Although not an exclusive list, some specific examples of prohibited social media conduct
include posting commentary, content, or images that are defamatory, pornographic, proprietary, harassing, libellous, or that can create a hostile work environment.
• Employees are not to publish, post or release any information that is considered confidential or not public. If there are questions about what is considered confidential, employees should check with the Human Resources Department and/or supervisor.
• Social media networks, blogs and other types of online content sometimes generate press and media attention or legal questions. Employees should refer these inquiries to authorized Handy AV spokespersons.
• If employees encounter a situation while using social media that threatens to become antagonistic, employees should disengage from the dialogue in a polite manner and seek the advice of a supervisor.
• Employees should get appropriate permission before you refer to or post images of current or former employees, members, vendors or suppliers. Additionally, employees should get appropriate permission to use a third party's copyrights, copyrighted material, trademarks, service marks or other intellectual property.
• Social media use shouldn't interfere with employee’s responsibilities at Handy AV. Handy AV's computer systems are to be used for business purposes only. When using Handy AV's computer systems, use of social media for business purposes is allowed (ex: Facebook, Twitter, Handy AV blogs and LinkedIn), but personal use of social media networks or personal blogging of online content is discouraged and could result in disciplinary action.
• Subject to applicable law, after hours online activity that violates Handy AV’s Code of Conduct or any other company policy may subject an employee to disciplinary action or termination.
• If employees publish content after hours that involves work or subjects associated with
Handy AV, a disclaimer should be used, such as this: “The postings on this site are my own and may not represent Handy AV’s positions, strategies or opinions.”
• It is highly recommended that employees keep Handy AV related social media accounts separate from personal accounts, if practical.
Alcohol and drug misuse or abuse can be a serious problem within the workplace. Employees who drink excessively or take unlawful drugs are more likely to work inefficiently, be absent from work, have work accidents and endanger their colleagues. The Company has a duty to protect the health, safety and welfare of all its employees. However, the Company recognises that, for a number of reasons, employees could develop alcohol or drug related problems.
In relation to drugs, these rules apply to those that are unlawful under the criminal law and not to prescribed medication. These rules aim to promote a responsible attitude to drink and drugs and to offer assistance to employees who may need it.
Advice and counselling
It is the Company’s intention to deal constructively and sympathetically with an employee’s alcohol or drug related problems, such as alcohol or drug dependency. When it is known that an employee has an alcohol or drug problem Diane Wright HR Advisor, will be able to provide advice and guidance on how to seek suitable treatment. The primary objective of any discussions will be to assist the employee with the problem in as compassionate and constructive a way as possible. Any discussions of the nature of an employee’s alcohol or drug problem and the record of any treatment will be strictly confidential unless the employee agrees otherwise.
If you have an alcohol or drug problem, you should seek appropriate help. If you have an alcohol or drug problem which affects your conduct or performance at work and you refuse the opportunity to receive help, the matter will be referred for action under the Company’s disciplinary procedure as appropriate. Likewise, if after accepting counselling and assistance, and following review and evaluation, your conduct or work performance reverts to the problem level, the matter may also be dealt with through the disciplinary procedure.
Prohibition on alcohol and drug consumption in the workplace
No alcohol or drugs must be brought onto or consumed on Company premises at any time or whilst attending any training courses, whether internal or external, and for these purposes this includes performance-enhancing drugs used for “doping” purposes, even if they are not unlawful under the criminal law, unless they have been medically prescribed by a doctor. Staff must never drink alcohol or take drugs if they are required to drive private or Company vehicles on Company business. Staff must also not drink alcohol or take drugs when they are on operational standby or on call.
Employees are expected to be moderate if drinking alcohol during work breaks, e.g. lunchtimes. The following jobholders are prohibited from drinking alcohol during work breaks:
ALL Operational Staff.
Employees representing the Company at business/client functions or conferences or attending
Company organised social events outside normal working hours are expected to be moderate if drinking alcohol and to take specific action to ensure they are well within the legal limits if they are driving. They are prohibited from taking drugs on these occasions.
Social drinking after normal working hours and away from the Company’s premises is, of course, generally a personal matter and does not directly concern the Company. The Company’s concern only arises when, because of the pattern or amount of drink involved, the employee’s attendance, work performance or conduct at work deteriorates.
A breach of these provisions is a disciplinary offence and will be dealt with in accordance with the Company’s disciplinary procedure. Depending on the seriousness of the offence, it may amount to gross misconduct and could result in the employee’s summary dismissal.
Alcohol and drug related misconduct
Whilst these rules are aimed at assisting employees with alcohol or drug problems, action will nevertheless be taken under the Company’s disciplinary procedure if misconduct takes place at work as a result of drinking or taking drugs, or if an employee is found to be under the influence of alcohol or drugs whilst at work. Even a small amount of alcohol can affect work performance and, if an employee is found under the influence of alcohol whilst at work, there could be serious health and safety consequences. The same applies to being under the influence of drugs. Incapacity or misconduct caused by an excess of alcohol or drugs at work is a potential gross misconduct offence under the Company’s disciplinary procedure and the employee is therefore liable to be summarily dismissed. This also applies to any employee believed to be buying or selling drugs or in possession of or taking drugs on the Company’s premises.
The Company reserves the right in any of these circumstances to arrange for the employee to be escorted from the Company’s premises immediately and sent home without pay for the rest of the day or shift. The Company also reserves the right to suspend the employee on full pay while carrying out an investigation.
Alcohol and drug testing
On the grounds of protecting health and safety and only where necessary to achieve a legitimate business aim, the Company reserves the right to carry out random alcohol and drug screening tests on those employees in the workplace whose activities and job duties have a significant impact on the health and safety of others. If an employee receives a positive test result, this will be viewed as a potential gross misconduct offence and renders the employee liable to summary dismissal in accordance with the Company’s disciplinary procedure. Unreasonable refusal to submit to an alcohol or drug-screening test will also be dealt with through the disciplinary procedure.