Ethical Code of Practice

Ethical Conduct Policy

At Arinsdale Ltd we are committed to doing the right thing in all aspects of our business. This requires that every day everyone working for us needs to have an unwavering dedication to the highest ethical standards. It is fundamental that every employee and worker carries a share of the responsibility for our conduct and contributes to our success.

Our culture is built on four key values. These shape our behaviour toward customers and toward one another. Together, they drive our organisation forward. The values are:

Integrity

We demand of each other and ourselves the highest standards of individual and corporate integrity. We do the right thing, because it is the right thing to do. It is every employee’s responsibility to safeguard organisation assets and foster an environment of trust with our -workers, customers, communities and suppliers. We should always comply with all our organisation policies, meet legal requirements, and create an environment of transparency in which all reporting requirements are met.

Excellence

We routinely challenge ourselves to improve our products, services and processes. We strive always to understand our customers’ businesses and help them achieve their goals. We serve our customers by anticipating and responding to their needs. We are dedicated to diversity, fair treatment, mutual respect and trust. We are committed to producing products and serving our customers with zero harm to people and the environment.

Teamwork

We foster an environment that encourages innovation and creativity, and delivers results through collaboration. We practice leadership that teaches, inspires and promotes full participation and career development. We encourage open and effective communications and interaction with all workers and stakeholders, actively working together to keep each other safe and in good health. We believe that none of us is as capable or effective as all of us – and together, there’s no limit to what we can achieve.

Accountability

We honour the commitments we make and take personal responsibility for all actions and results. Our actions match our words, and we demand responsibility – from ourselves and others – in everything we do. We operating on the basis that continuous improvement is an integral part of our culture.

Regardless of our position within the organisation, we share equal accountability for:

• Conducting business with integrity, preserving our strong reputation and expanding our position in the marketplace.
• Fostering an inclusive culture in which we all feel respected and have the opportunity to reach our full potential.
• Providing a healthy and safe work environment, and complying with applicable environmental laws and regulations wherever we operate around the world contributing to the sustainability of the communities in which we live and work.

Modern Slavery Statement

This statement applies to Arinsdale Limited. The information included in the statement refers to the financial year 2021/2022.

Arinsdale Limited are a leading manufacturer of load securing straps and equipment. Our products also include textile lifting slings and associated lifting equipment. Many of our products are manufactured and tested at our production facility here in Grangemouth, United Kingdom.

The majority of our products are shipped by carriers and palletised transport around the United Kingdom and further afield throughout Europe and to the rest of the World.

The labour supplied to the organisation in pursuance of its operation is carried out in wholly in the United Kingdom.

The organisation considers that modern slavery encompasses:

• Human trafficking;
• Forced work, through mental or physical threat;
• Being owned or controlled by an employer through mental or physical abuse of the threat of abuse;
• Being dehumanised, treated as a commodity or being bought or sold as property;
• Being physically constrained or to have restriction placed on freedom of movement

Arinsdale Limited acknowledges its responsibilities in relation to tackling modern slavery and commits to complying with the provisions in the Modern Slavery Act 2015. Arinsdale Limited understands that this requires an ongoing review of both its internal practices in relation to its labour force and, additionally, its supply chains.

Arinsdale Ltd does not enter into business with any other organisation, in the United Kingdom or abroad, which knowingly supports or is found to involve itself in slavery, servitude and forced or compulsory labour.

No labour provided to Arinsdale Ltd in the pursuance of the provision of its own services is obtained by means of slavery or human trafficking. The Company strictly adheres to the minimum standards required in relation to its responsibilities under relevant employment legislation in the United Kingdom.

In order to fulfil its activities, the main supply chains include those related to the purchase of webbing, endfittings e.g. Metal hooks and webbing tensioners e.g. Ratchets and other webbing buckles. Many of these supplies come from European and far eastern countries.

Arinsdale Limited considers its main exposure to the risk of slavery and human trafficking to exist from supplies obtained from other countries.

In general, we consider our exposure to slavery/human trafficking to be relatively limited. Nonetheless, we have taken steps to ensure that such practices do not take place in its business nor the business of any organisation that supplies goods and/or services to it.

Arinsdale Limited carries out due diligence processes in relation to ensuring slavery and/or human trafficking does not take place in its organisation or supply chains, including conducting a review of the controls of its suppliers as part of our QMS Approved Suppliers procedure/process.

Arinsdale Limited has not, to its knowledge, conducted any business with another organisation which has been found to have involved itself with modern slavery.

In accordance with section 54(4) of the Modern Slavery Act 2015, Arinsdale Limited has taken the following steps to ensure that modern slavery is not taking place:

• All our current suppliers have been contacted and asked to provide their up to date stance and policy on the Modern Slavery Act 2015. All responses will be logged.
• Ongoing, we will monitor our existing suppliers and also assess potential suppliers.
• This is done as part of our ISO9001 supplier assessments. Any supplier found to be in breach of our policy will be removed from our Approved Suppliers List.
• We have a robust Disciplinary and Reporting Policy in place whereby any staff can freely report to Management, concerns they have regarding their own or another staff members’ welfare.
• We retain the services of Peninsula Business Services Limited, to ensure we adhere strictly to all current Employment Legislation.

Arinsdale Limited has set the following key performance indicators to measure its effectiveness in ensuring modern slavery is not taking place in the Company or its supply chains.

• Suppliers are assessed constantly as part of our ongoing ISO9001:2015 reviews.

Arinsdale Limited has a Slavery Compliance Officer, to whom all concerns regarding modern slavery should be addressed, and who will then undertake relevant action with regard to our obligations in this regard.

This statement is made in pursuance of Section 54(1) of the Modern Slavery Act 2015 and will be reviewed for each financial year.

Child Labour

The Company will ensure that all relevant legislation and restrictions are adhered to in regards to the use of young workers. We will ensure that the necessary checks are carried out to verify an individual’s age and right to work, and that relevant Health and Safety codes are adhered to.

Where required, the Company will ensure that the relevant employment permit is received from the education department of the local council.

We will also carry out spot checks when required and will retain copies of age records within the place of work.

Restrictions For Children Aged 14 Years Old

There are restrictions that apply to the employment of children aged 14 years old, as follows:-

• You must not work before 7.00 am. or after 7.00 pm. on any day;
• You must not work for more than 2 hours on any day when you are required to be at school;
• You must not work during school hours;
• You must not work for more than 5 hours on a Saturday or on weekdays during school holidays;
• You must not work for more than 2 hours on a Sunday;
• You must not work for more than 4 hours in any day without a rest break of 1 hour.
• You must not work for more than 12 hours in any school week; and
• You must not work for more than 25 hours a week during school holidays

Restrictions For Children Aged 15 And 16 Years Old

There are restrictions that apply to the employment of children aged 15 and 16 years old, as follows:-

• You must not work before 7.00 am. or after 7.00 pm. on any day;
• You must not work for more than 2 hours on any day when you are required to be at school;
• You must not work during school hours;
• You must not work for more than 8 hours on a Saturday or on weekdays during school holidays;
• You must not work for more than 2 hours on a Sunday;
• You must not work for more than 4 hours in any day without a rest break of 1 hour
• You must not work for more than 12 hours in any school week; and
• You must not work for more than 35 hours a week during school holidays.

Restrictions For Young Workers Over Compulsory School Leavers Age

There are restrictions that apply to the employment of young workers over compulsory school leaver’s age, as follows:-

• You must not work for more than 8 hours a day;
• You must not work for more than 40 hours a week;
• You must not work for more than 4.5 hours in any day without a rest break of 30 minutes.
• You must have a rest period of not less than 48 hours in each seven day period.

Anti-Bribery Policy

A) Introduction

Bribery is, in the conduct of the organisation’s business, the offering or accepting of any gift, loan, payment, reward or advantage for personal gain as an encouragement to do something which is dishonest, illegal or a breach of trust.

Bribery is a criminal offence. The Organisation prohibits any form of bribery. We require compliance, from everyone connected with our business, with the highest ethical standards and anti-bribery laws applicable. Integrity and transparency are of utmost importance to us and we have a zero tolerance attitude towards corrupt activities of any kind, whether committed by Arinsdale Ltd employees or by third parties acting for or on behalf of Arinsdale Ltd.

B) Offences

It is a criminal offence to:

• offer a bribe;
• accept a bribe;
• bribe a foreign official;
• as a commercial organisation, to fail to prevent a bribe.

You should be aware that if you are found guilty by a court of committing bribery, you could face up to 10 years in prison and/or an unlimited fine. The Organisation could also face prosecution and be liable to pay a fine.

C) Purpose

The purpose of this policy is to convey to all employees and interested parties of Arinsdale Ltd the rules of the Organisation in relation to our unequivocal stance towards the eradication of bribery and our commitment to ensuring that Arinsdale Ltd conducts its business in a fair, professional and legal manner.

D) Definitions Of Bribery And Corruption

Corruption is the misuse of office or power for private gain. Bribery is a form of corruption which means in the course of business:

• Giving or receiving money, gifts, meals, entertainment or anything else of value.
• As an inducement to a person to do something which is dishonest or illegal.

E) Scope

This policy applies to all employees of Arinsdale Ltd, regardless of seniority or site. It also extends to anyone working for or on our behalf e.g. those engaged by us on a self-employed basis or an agency arrangement.

We will encourage the application of this policy where our business involves the use of third parties e.g. suppliers; contractors.

F) Policy

It is prohibited, directly or indirectly, to offer, give, request or accept any bribe i.e. gift, loan, payment, reward or advantage, either in cash or any other form of inducement, to or from any person or organisation in order to gain commercial, contractual or regulatory advantage for the Organisation, or in order to gain any personal advantage for an individual or anyone connected with the individual in a way that is unethical.

It is also prohibited to act in the above manner in order to influence an individual in his capacity as a foreign public official. You should not make a payment to a third party on behalf of a foreign public official.

If you are offered a bribe, or a bribe is solicited from you, you should not agree to it unless your immediate safety is in jeopardy. You should immediately contact a Director so that action can be taken if considered necessary. You may be asked to give a written account of events.

If you, as an employee or person working on our behalf, suspect that an act of bribery, or attempted bribery, has taken place, even if you are not personally involved, you are expected to report this to a Director. You may be asked to give a written account of events.

Appropriate checks will be made before engaging with suppliers or other third parties of any kind to reduce the risk of our business partners breaching our anti-bribery rules.

The Organisation will ensure that all of its transactions, including any sponsorship or donations given to charity, are made transparently and legitimately.

Arinsdale Ltd takes any actual or suspected breach of this policy extremely seriously and will carry out a thorough investigation should any instances arise.

We will uphold laws relating to bribery and will take disciplinary action against any employee, or other relevant action against persons working on our behalf or in connection with us, should we find that an act of bribery, or attempted bribery, has taken place. This action may result in your dismissal if you are an employee, or the cessation of our arrangement with you if you are self-employed, an agency worker, contractor etc.

Staff are reminded of the Organisation’s Whistleblowing Policy which is available in the Employee Handbook, or upon request.

G) Gifts And Hospitality

We realise that the giving and receiving of gifts and hospitality where nothing is expected in return helps form positive relationships with third parties where it is proportionate and properly recorded. This does not constitute bribery and consequently such actions are not considered a breach of this policy.

Gifts include money; goods (flowers, vouchers, food, drink, event tickets when not used in a hosted business context); services or loans given or received as a mark of friendship or appreciation.

Hospitality includes entertaining; meals or event tickets (when used in a hosted business context) given or received to initiate or develop relations. Hospitality will become a gift if the host is not present.

No gift should be given nor hospitality offered by an employee or anyone working on our behalf to any party in connection with our business without receiving prior written approval from a Director. Similarly, no gift nor offer of hospitality should be accepted by an employee or anyone working on our behalf without receiving prior written approval from a Director.

A record will be made of every instance in which gifts or hospitality are given or received.

As the law is constantly changing, this policy is subject to review and the Organisation reserves the right to amend this policy without prior notice.

Anti-Tax Evasion Policy

A) Introduction

Tax evasion is a criminal offence. The Organisation prohibits any form of tax evasion. Involvement in the criminal facilitation of tax evasion exposes the Organisation and the person facilitating the evasion to a criminal offence. It will also damage our reputation and the confidence of our customers, suppliers and business partners.

Indicators of tax evasion are:- Our position is simple: we conduct our business to the highest legal and ethical standards. We will not be party to tax evasion or the facilitation of tax evasion of any form. Such acts would damage our reputation and expose us, and our staff and representatives, to the risk of fines and imprisonment.

We take a zero-tolerance approach to tax evasion facilitation by our people and our third party representatives. We are committed to: We require compliance in regards to this from everyone connected with our business. Integrity and transparency are of utmost importance to us.

B) Definitions Of Tax Evasion

Tax evasion is the practice of using illegal methods to avoid paying tax. It frequently involves contrived, artificial transactions that serve no purpose other than to reduce tax liability.

C) Policy

It is prohibited, directly or indirectly, for any employee or person working on our behalf to take part in any activity relating to tax evasion.

If we suspect that you have taken part in such activity, an investigation will be carried out and, in line with our disciplinary procedure where appropriate, action may be taken against you which may result in your dismissal, or the cessation of our business arrangement with you.

If you, as an employee or person working on our behalf, suspect any activity related to tax evasion or attempted tax evasion has taken place, even if you are not personally involved, you are expected to report this to a Director. You may be asked to give a written account of events.

D) Training/monitoring/review

The Organisation will ensure that it gives all relevant training for staff in relation to financial crime detection and prevention, it will ensure it monitors and enforces compliance with the prevention procedures and regularly review the effectiveness of prevention procedures, refining them where necessary.

E) Concerns

Staff are reminded of the Organisation’s Whistleblowing policy which is available in the Employee Handbook, or upon request.

Whistle-Blowing Procedure

A) Introduction

Under certain circumstances, employees are protected from suffering any detriment or termination of employment if they make disclosures about organisations for whom they work.

B) Qualifying Disclosures

C) The Procedure

D) Treatment By Others

Bullying, harassment or any other detrimental treatment afforded to a colleague who has made a qualifying disclosure is unacceptable. Anyone found to have acted in such a manner will be subject to disciplinary action.

Equality & Diversity Policy

A) Introduction

B) Our Commitment As An Employer

C) Our Commitment As A Service Provider

D) Policy Statements

Age

We will:

• ensure that people of all ages are treated with respect and dignity;
• ensure that people of working age are given equal access to our employment, training, development and promotion opportunities; and
• challenge discriminatory assumptions about younger and older people.

Disability

We will:

• provide any reasonable adjustments to ensure disabled people have access to our services and employment opportunities;
• challenge discriminatory assumptions about disabled people; and
• seek to continue to improve access to information by ensuring availability of loop systems, braille facilities, alternative formatting and sign language interpretation.

Race

We will:

• challenge racism wherever it occurs;
• respond swiftly and sensitively to racists incidents; and
• actively promote race equality in the Organisation.

Gender

We will:

• challenge discriminatory assumptions about women and men;
• take positive action to redress the negative effects of discrimination against women and men;
• offer equal access for women and men to representation, services, employment, training and pay and encourage other organisations to do the same; and
• provide support to prevent discrimination against transsexual people who have or who are about to undergo gender reassignment.

Sexual Orientation

We will:

• ensure that we take account of the needs of lesbians, gay men and bisexuals; and
• promote positive images of lesbians, gay men and bisexuals.

Religion Or Belief

We will:

• ensure that employees’ religion or beliefs and related observances are respected and accommodated wherever possible; and
• respect people’s beliefs where the expression of those beliefs does not impinge on the legitimate rights of others.

Pregnancy Or Maternity

We will:

• Ensure that people are treated with respect and dignity and that a positive image is promoted regardless of pregnancy or maternity;
• challenge discriminatory assumptions about the pregnancy or maternity of our employees; and
• ensure that no individual is disadvantaged and that we take account of the needs of our employees’ pregnancy or maternity.

Marriage Or Civil Partnership

We will:

• Ensure that people are treated with respect and dignity and that a positive image is promoted regardless of marriage or civil partnership;
• challenge discriminatory assumptions about the marriage or civil partnership of our employees; and
• ensure that no individual is disadvantaged and that we take account the needs of our employees’ marriage or civil partnership.

Ex-offenders

We will:

• prevent discrimination against our employees regardless of their offending background (except where there is a known risk to children or vulnerable adults).

Bullying & Harassment Policy

All members of staff are entitled to be treated with dignity and respect in their place of work. This means freedom from behaviour by colleagues that can be interpreted as bullying or harassment or that causes offense, and access to redress if such behaviour does arise. It also means standards of everyday behaviour that contribute to a working environment in which mutual respect and individual dignity are maintained.

A) Bullying And Harassment

Behaviour can constitute bullying or harassment where: it violates the dignity of a member of staff on the grounds of their age, disability, gender reassignment, marriage and civil partnership, pregnancy or maternity, race, religion or belief, sex or sexual orientation (the protected characteristics); or where it creates an intimidating, hostile and degrading, humiliating or offensive environment. Individual or accumulative acts can seriously undermine the dignity, confidence, and work satisfaction to such an extent that it has an effect on job performance, and general happiness both inside and outside work.

Conduct becomes harassment if it persists and it has been made clear that it is regarded as offensive by the recipient or a witness to the conduct, although a single offensive act can amount to harassment if it is sufficiently serious.

Bullying and harassment can be further defined in the following ways:

B) Harassment Based On Race, Colour Or Ethnic Origin

Harassment based on race, colour or ethnic origin is conduct at work directed towards a colleague by another colleague or group of colleagues which is racist in nature, and which is regarded as unwelcome or offensive by the recipient or a witness.

• The following are examples that illustrate such conduct, though this is not an exhaustive list:
• Jokes about race, colour or ethnic origin
• Use of offensive names.
• References to colleagues by offensive racist descriptions.
• Use of offensive or insensitive stereotypes.
• Verbal abuse based on race, colour or ethnic origin.
• Circulation, or display, of offensive material based on race, colour or ethnic origin.
• Detrimental behaviour because of a colleague’s race, colour or ethnic origin.

C) Harassment Based On Pregnancy Or Maternity

Harassment based on pregnancy or maternity is conduct at work directed towards a colleague by another colleague or group of colleagues which is based on the pregnancy or maternity of the colleague, and which is regarded as unwelcome or offensive by the recipient or a witness.

The following are examples that illustrate such conduct, though this is not an exhaustive list:

• Jokes about pregnancy or maternity.
• Use of offensive names.
• Use of offensive or insensitive stereotypes
• Verbal abuse based on pregnancy or maternity.
• Circulation, or display, of offensive material based on pregnancy or maternity.
• Detrimental behaviour because of a colleague’s pregnancy or maternity.

D) Sexual Harassment

Sexual harassment is conduct directed towards a colleague by another colleague or group of colleagues which is of a sexual nature, or which is based on a colleague’s gender, and which is regarded as unwelcome or offensive to the recipient or a witness.

The following are examples which illustrate such conduct, though this is not an exhaustive list:

• Unwanted physical contact.
• Contact which is intimidating, or physically or verbally abusive.
• Jokes that are based on sexual or gender issues.
• Non-verbal conduct, such as staring or gestures.
• Suggestions that sexual favours may further a persons career, or that refusal may hinder it.
• Sexual advances, propositions, suggestions or pressure for sexual activity at or outside work.

E) HARASSMENT BASED ON DISABILITY

Harassment based on disability is conduct directed towards a colleague by another colleague or group of colleagues which is based on the colleague’s disability or association with someone who has a disability and which is unwelcome to the recipient or a witness.

The following are examples which illustrate such behaviour, though this is not an exhaustive list:

• Jokes about disability.
• Use of offensive names.
• Use of offensive or insensitive stereotypes.
• Verbal abuse based on disability.
• Circulation, or display, of offensive material based on disability.
• Deliberate actions designed to hinder a colleague’s ability to undertake his/her duties because of their disability.

F) HARASSMENT BASED ON SEXUAL ORIENTATION OR GENDER REASSIGNMENT

Harassment based on sexual orientation or gender reassignment is conduct directed towards a colleague by another colleague or group of colleagues which is based on the sexuality of the colleague and which is unwelcome by the recipient or a witness.

The following are examples which illustrate such behaviour, though this is not an exhaustive list:

• Jokes about sexuality or gender reassignment.
• Use of offensive names.
• Use of offensive or insensitive stereotypes.
• Verbal abuse based on sexuality or gender reassignment.
• Circulation, or display, of offensive material based on sexuality or gender reassignment.

G) Harassment Based On Marriage Or Civil Partnership

Harassment based on marriage or civil partnership is conduct directed towards a colleague by another colleague or group of colleagues which is based on the marriage or civil partnership of the colleague and which is unwelcome by the recipient or a witness.

The following are examples which illustrate such behaviour, though this is not an exhaustive list:

• Jokes about marriage or civil partnership.
• Use of offensive names.
• Use of offensive or insensitive stereotypes.
• Verbal abuse based on marriage or civil partnership.
• Circulation, or display, of offensive material based on marriage or civil partnership.

H) Harassment Based On Religion Or Belief

Harassment based on religion or belief is conduct directed towards a colleague by another colleague or group of colleagues which is based on the religion or belief of the colleague and which is unwelcome by the recipient or a witness.

The following are examples which illustrate such behaviour, though this is not an exhaustive list:

• Jokes about religions or beliefs.
• Use of offensive names.
• Use of offensive or insensitive stereotypes.
• Verbal abuse based on religion or belief.
• Circulation, or display, of offensive material based on religion or belief.

I) Harassment Based On Age

Harassment based on age is conduct directed towards a colleague by another colleague or group of colleagues which is based on the age of the colleague and which is unwelcome by the recipient or a witness.

• Jokes about age.
• Use of offensive names.
• Use of offensive or insensitive stereotypes.
• Verbal abuse based on age.
• Circulation, or display, of offensive material based on age.

J) Detrimental Behaviour Because Of An Association With A Protected Characteristic

Bullying and harassment may not be based on the fact that a colleague belongs to a particular group, but simply because the individual has been singled out for such treatment or associates with someone of a protected characteristic. For example, this would include claiming someone is gay when they are not or making fun of someone who has a disabled relative. The bullying and harassment may take the following forms, though again this is not intended as an exhaustive list:

• Limiting or withdrawing verbal communication.
• Isolating a colleague by unfriendly behaviour.
• Behaviour designed to belittle or produce anxiety in a colleague.
• Unreasonable scrutiny of work.
• Unreasonable criticism of work, and adopting double standards in expectations of work performance.
• Unreasonable denial of leave and/or special leave requests.
• Unreasonable denial of requests for flexible working.
• Work or staff social activities that deliberately exclude a colleague.
• Jokes or inappropriate humour at the expense of a colleague.

K) STANDARDS OF WORK BEHAVIOUR

• Courtesy towards colleagues.
• Consideration and understanding of the work demands of colleagues.
• Maintaining a temperate tone, and temperate language, in all verbal and written communication with colleagues.
• Avoidance of the use of foul language.
• Awareness of language and conduct which have the potential to offend a colleague.
• Obtaining the express or implied permission of a colleague before adopting familiarity in conduct or language.

L) What To Do If You Or A Colleague Is Subject To Bullying Or Harassment

The company is committed to ensuring that there is no harassment or bullying in the workplace. Allegations of harassment will be treated as a disciplinary matter, although every situation will be considered on an individual basis and in accordance with the principles of the grievance and disciplinary procedures, a copy of which is available from our Administration Manager.

1) Informal Complaint

The first step you are encouraged to take is to raise such issues with a senior colleague of your choice (whether or not that person has a direct supervisory responsibility for you) as a confidential helper. However this person cannot be a Director, who will be responsible for investigating the matter if it becomes a formal complaint.

If you decide you can deal with the inappropriate behaviour informally, for example, if the act concerned is relatively minor, isolated or clearly unintentional. In these situations it is possible that the matter can be resolved immediately by letting your colleague know that the behaviour in question is unacceptable to you and should be avoided in future. If you feel unable to do this verbally, you should hand a written request to your harasser; this is something your confidential helper can assist you with.

2) Formal Complaint

If you feel uncomfortable about raising the issue directly with your harasser or if you consider the behaviour is more serious because it was deliberate, part of a persistent pattern, or serious in nature, or has been repeated despite having discussed a previous incident informally, then you should bring the matter to the attention of a Director as a formal written complaint and again this is something that your confidential helper can assist you with.

If possible, you should keep notes of the harassment so that the written complaint can include:

• the name of the alleged harasser;
• the nature of the alleged harassment;
• the dates and times when the alleged harassment occurred;
• the names of any witnesses; and
• any action already taken by you to stop the alleged harassment.

On receipt of a formal complaint we will take action to separate you from the alleged harasser to enable an uninterrupted investigation to take place. This may involve a temporary transfer of the alleged harasser to another work area or suspension with contractual pay until the matter has been resolved.

The person dealing with the complaint will invite you to attend a meeting, at a reasonable time and location, to discuss the matter and carry out a thorough investigation. You have the right to be accompanied at such a meeting by your confidential helper or another work colleague of your choice and you must take all reasonable steps to attend. Those involved in the investigation will be expected to act in confidence and any breach of confidence will be a disciplinary matter.

On conclusion of the investigation which will normally be within ten working days of the meeting with you, the decision of the investigator detailing the findings will be sent, in writing, to you.

You have the right to appeal against the findings of the investigator in accordance with the appeal provisions of the grievance procedure.

L) What To Do If You Or A Colleague Is Subject To Bullying Or Harassment

Environmental Policy

Arinsdale Ltd is committed to a policy of sound environmental management on its own account and in partnership with clients, designers and other contractors. Our principle goal is to prevent harm to people and damage to the environment or property.

This commitment is driven at all levels of the organisation and we devote time and resources to evaluating and reducing the effects that our work may have on the local environment.

We aim to:

• Establish and maintain working procedures that are environmentally sound.
• Fully integrate these procedures as essential elements of our business.
• Assess the environmental impact of all new works before they start and during their progress.
• Be efficient in the consumption of energy and natural resources, and where possible ensure that materials used can be reduced, recycled, reused, or disposed of safely.
• Make our clients aware of alternative approaches to their projects or changes in materials that would be of greater environmental benefit than those specified.
• Keep abreast of product and procedural developments so that we can continually improve our approach to environmental issues and our environmental footprint.
• Promote the adoption of these principles by any sub-contractors working for us.
• Have emergency procedures that take account of environmental spills and releases, which indicate those that should be reported to the authorities.
• Educate, train and motivate our employees to conduct their activities in an environmentally responsible manner in accordance with this policy.

The Board of Directors has been appointed to take charge of environmental issues for this business. They are responsible for auditing against this policy and for its regular review.