Our Policies

 

Please find listed below our Group Policies, beneath each section you will have access to download the policy if you wish.  Kindly note that this download will take you to our dropbox page. 

Should you have any questions regarding any of our Group Policies please email - policies@grahamegardner.co.uk 


ETHICAL BASE CODE POLICY

INTRODUCTION

1.1       The Group is committed to ensuring that its internal organisation, suppliers, contractors and other parties active within the Group’s supply chain adhere to the Ethical Base Code (Code of Labour Practice) attached at Enclosure 1.  The Group’s commitment will be policed via the Labour Standards Assurance System (LSAS): a range of policies, procedures and practices employed to identify labour standard abuses, mitigate risks and drive continual improvement. 

1.2       Many of these procedures are already embedded within our organisation and indeed our supply chain.  However, it is incumbent that current practice is identified, recorded and managed with a view to continual review and improvement.  This Paper details current internal & wider supply chain management procedures, and future targets for improvement.

ORGANISATION, TRAINING & AWARENESS

2.1       Board Responsibilities.     Ultimate responsibility for the Group’s Ethical Practice rests with the Board of Directors, with its management delegated to the Operations Director.  Ethical Practice is reviewed as a specific agenda item at Board meetings, supported by a bi-annual LSAS Status Report issued to all Directors.

2.2       Training & Awareness.     All new staff are issued with an Arrival Pack when they join the company which refers then directly to the Group’s Ethical Practice commitment.  This Policy Paper and the Ethical Base Code are displayed in all departments.  In addition, all key Buying Department staff Training & Development Plans, list Ethical Base Code Awareness as a core competency.

 

CURRENT SUPPLY CHAIN ASSESSMENT

3.1       Internal Position.     Internally, the Group has active & long established health & safety, and training & development procedures in place and ISO 9001 (2015) accreditation.  The Company is a Rated Supplier on the Chartered Institute of Purchasing & Supply (CIPS) Sustainability Index which independently audits our social, economic and environmental performance: our status was reaffirmed in March 2017.  Moreover, clear disciplinary, grievance, consultation and equal opportunities procedures are laid down in our Policies & Procedures document which is issued to all staff when they commence employment, and is readily available to all staff via our internal server.

3.2       Supply Chain.     The Group currently uses and maintains an LSAS file on each of its overseas suppliers.  The file records current LSAS status, specifically identifying what audit procedures they have in place, copies of their last audit reports and a record of the on-going improvement action required by the Group as its moves its supply base towards eventual Level 4 LSAS compliance.  An update on each overseas supplier is presented via the bi-annual LSAS Status Report to the Directors.

3.3       External Monitoring of Global Ethical Standards.   The Group keep abreast of changes in International Law, standards and procedures via the Consultancy, IMPACTT and ETI.  IMPACTT and ETI work closely with governments, academics & NGOs to maximise the positive impact of global trade on workers & local communities.  The Group receives Newsletters from both organisations which are circulated to management.

 

ONGOING IMPROVEMENT

4.1       Immediate & Intermediate Targets.     The Group secured Lloyds Register Quality Assurance (LRQA) approval for LSAS Level 2 in October 2014, this was re-confirmed in June 2017.  Continued compliance will be determined by an external audit with all subsequent Report recommendations and actions being pursued diligently.  In line with NHS Supply Chain requirements we must secure Level 3 LSAS compliance within 18 months of the Framework Agreement (FAG 15285) Contract award:  award will be confirmed in mid-late April 2017.    Further internal audits will be undertaken by the Group’s contracted ISO/Health & Safety consultant.  A Risk Assessment of our exposure to Labour Standard Issues is maintained and reviewed every 6 months by the Group Operations Director.

 4.2       Supplier & Service Level Agreement Commitment.     Ethical Practice will be an agenda item on all future meetings between buying staff and our suppliers.  Upon review or initial establishment, a clear commitment to LSAS will be part of all future Service Level Agreements.

 4.3       Internal Staff Training Commitment.     In addition, to their initial Awareness training, Buying Department management and key staff will receive more comprehensive training on the Ethical Base Code and its administration through LSAS.

 

CONCLUSION

 5.1       The Board of Directors has a moral and legal obligation to ensure the implementation, management and continual improvement towards the Ethical Base Code, and is subsequently committed to maintaining its LSAS status.

 

Download Ethical Base Code Policy

 

CODE OF LABOUR PRACTICE

 This document was amended 01 April 2014 with revisions to clause 6, Working hours are not excessive.

 1. Employment is freely chosen

1.1 There is no forced, bonded or involuntary prison labour.

1.2 Workers are not required to lodge "deposits" or their identity papers

with their employer and are free to leave their employer after reasonable notice.

 

2. Freedom of association and the right to collective bargaining are respected

2.1 Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.

2.2 The employer adopts an open attitude towards the activities of trade unions and their organisational activities.

2.3 Workers representatives are not discriminated against and have access to carry out their representative functions in the workplace.

2.4 Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining.

 

3. Working conditions are safe and hygienic

3.1 A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.

3.2 Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers.

3.3 Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided.

3.4 Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.

3.5 The company observing the code shall assign responsibility for health and safety to a senior management representative.

 

4. Child labour shall not be used

4.1 There shall be no new recruitment of child labour.

4.2 Companies shall develop or participate in and contribute to policies and programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child; “child” and “child labour” being defined in the appendices.

4.3 Children and young persons under 18 shall not be employed at night or in hazardous conditions.

4.4 These policies and procedures shall conform to the provisions of the relevant ILO standards.


5. Living wages are paid

5.1 Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs and to provide some discretionary income.

5.2 All workers shall be provided with written and understandable Information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid.

5.3 Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

 

6. Working hours are not excessive

6.1 Working hours must comply with national laws, collective agreements, and the provisions of 6.2 to 6.6 below, whichever affords the greater protection for workers. Sub-clauses 6.2 to 6.6 are based on international labour standards.

6.2 Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per week.*

6.3 All overtime shall be voluntary. Overtime shall be used responsibly, taking into account all the following: the extent, frequency and hours worked by individual workers and the workforce as a whole. It shall not be used to replace regular employment. Overtime shall always be compensated at a premium rate, which is recommended to be not less than 125% of the regular rate of pay.

6.4 The total hours worked in any seven day period shall not exceed 60 hours, except where covered by clause 6.5 below.

6.5 Working hours may exceed 60 hours in any seven day period only in exceptional circumstances where all of the following are met:

• this is allowed by national law;

• this is allowed by a collective agreement freely negotiated with a workers’ organisation representing a significant portion of the workforce;

• appropriate safeguards are taken to protect the workers’ health and safety; and

• the employer can demonstrate that exceptional circumstances apply such as unexpected production peaks, accidents or emergencies.

6.6 Workers shall be provided with at least one day off in every seven day period or, where allowed by national law, two days off in every 14 day period.

* International standards recommend the progressive reduction of normal hours of work, when appropriate, to 40 hours per week, without any reduction in workers’ wages as hours are reduced.

 

7. No discrimination is practised

7.1 There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union

membership or political affiliation.

 

8. Regular employment is provided

8.1 To every extent possible work performed must be on the basis of recognised employment relationship established through national law and practice.

8.2 Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, sub- contracting, or home-working

arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed-term contracts of employment.

 

9. No harsh or inhumane treatment is allowed

9.1 Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited. The provisions of this code constitute minimum and not maximum standards, and this code should not be used to prevent companies from exceeding these standards. Companies applying this code are expected to comply with national and other applicable law and, where the provisions of law and this Base Code address the same subject, to apply that provision which affords the greater protection.

 

 Note: We make every effort to ensure that the translations of the ETI Base Code and Principles of Implementation are as complete and accurate as possible. However, please note that in both cases it is the English language documents which should be treated as the official versions.  Date: March 2018

 

Download Code Of Labour Practice

 

GROUP ENVIRONMENTAL POLICY

INTRODUCTION

1.1       The Group is committed to ensuring that its internal organisation and wider supply chain recognise the role we have in ensuring future generations can live in a safe and healthy environment.   Consequently we aim to minimize any adverse effect that our operation may have on the environment.   To that end we are committed to improving awareness and understanding of sustainability across our business and supply chain, utilising new technology and ensuring that environmental considerations are integral to our operation.

 

ORGANISATION RESPONSIBILITIES

 2.1       Board Responsibilities.    Responsibility for the Group’s Environmental Policy rests with the Board of Directors, with management resting with the Managing Director. 

 2.2       Staff Awareness.    All staff within the organization are aware of their responsibilities regarding environmental issues.  New suggestions and ideas are positively encouraged.   Upon joining the organization, staff are specifically referred within their Arrival Pack to the Group’s environmental policy. 

 2.3       Supply Chain.         Suppliers are encouraged to adopt best practice with regard to environmentally friendly operations.  Key suppliers have clearly defined environmental sustainability policies of their own including Worldwide Responsible Accredited Production certification (WRAP) and/or certification to bodies such as the Supplier Ethical Data Exchange (SEDEX).

 

SUPPLY CHAIN PRACTICE

 3.1       Commitment.     Key suppliers have been actively encouraged to further develop their Environmental practice.  They have been asked to focus on a number of specific areas including recycling & waste reduction, waste disposal, water conservation practice, energy efficient appliances, ICT power down, vehicle share & cycle schemes, training & awareness, energy consumption, and Emergency Action Plans.  Supply Chain response has been positive and key evidence of good practice is detailed below.

 3.2       Key Supply Chain Initiatives.  Our largest supplier is based in Indonesia and has worked hard on reducing water usage with a strong visual campaign & bi-annual training to employees on the need cut water usage and by fitting low water use toilets & basins, and recycling other waste products.  Our Sri Lankan factory, has recently secured Government Central Environmental Authority Certification (attached) which confirms their factory works to their Country’s Environmental Agency standards: this factory recently secured WRAP Platinum status for 2017.  A copy of another key supplier’s comprehensive Waste Management Policy is attached: key points include the use of a certified dye house waste water treatment facility, recycling of machine oil & fabric & energy management.

 

INTERNAL POLICY & PRACTICE

4.1             Commitment.  We are committed to working in a sustainable manner and wherever possible to take in to consideration the potential impact of climate change.  We consequently aim to minimize our business emissions, waste and discharges to prevent pollution and lessen the burden on the environment.  Specific measures to support this strategy are detailed below.

4.2             Packaging.  Managed by our Group Logistics Manager, all redundant cardboard packaging received into our warehouse is collected by the recycling contractor, Elligia.  In addition, serviceable cardboard packaging is set aside and reused within our distribution operation. 

4.3             Paper.  All used office paper is recycled internally using our blue box system prior to collection by our recycling contractor.   We actively manage & maintain separate bulk waste bins at both UK sites for general & recyclable product.

4.4             IT Hardware & Printer Cartridges.  Redundant IT hardware is collected by a specialist recycling company, PCD Ltd.  Where accepted, used printer cartridges are collected and sent to a local charity for recycling.

4.5            Company Cars.  Cars are a major polluter; therefore a policy of low CO2 emissions for company vehicles is in place.

4.6             Redundant Garments.  Redundant garments are donated to overseas charities such as National Police Convoys, SOS Kit Aid & Colts for Africa.  Where no longer fit for purpose garments are collected by charities such as the Lincolnshire Air Ambulance for shredding and recycling.

4.7           Machinery.  Machinery is regularly serviced to maintain its efficiency and so reduce our carbon footprint.  Our boiler & heating systems are regularly serviced and specific investment was made in 2014 in our warehouse heating system, helping to significantly reduce fuel consumption and improve overall efficiency.

 

THE FUTURE

5.1       The Group pledge to build on the environmental strategies listed above. We fully intend to increase the environmental awareness of everyone within the organization and our wider supply chain.  We aim to improve on any negative effects that we may have on the environment, comply with all legislation regarding emissions, waste and pollution, and strive to further reduce our impact on our environment. 

5.2       We are also investigating registration to The International Environmental Management System Standard (ISO14001), and The Social Accountability Standard (SA8000).  In sum the Group is committed to minimising our environmental impact, and supporting the UK’s transition to a low carbon economy.

Download Our Group Environmental Policy

 

HEALTH & SAFETY POLICY STATEMENT

Health & Safety at Work Act 1974

This is the Health & Safety Policy Statement of Grahame Gardner Limited & Gymphlex Limited.

Our Statement of General Policy is:

 

•             To provide adequate control of the health & safety risks arising from our work activities.

•             To consult with our employees on matters affecting their health & safety.

•             To provide and maintain safe plant and equipment.

•             To ensure safe handling and use of substances.

•             To provide information, instruction & supervision for employees.

•             To ensure all employees are competent to do their tasks, and to give them adequate training.

•             To prevent accidents and cases of work-related ill health.

•             To maintain safe and healthy working conditions.

•             To review and revise this policy as necessary at regular intervals.

James Greenlees, CEO  May 2018         

                                  

Responsibilities

Overall and final responsibility for health & safety rests with: James Greenlees, Chief Executive Officer

Day to day responsibility for ensuring this Policy is put into practice, is delegated to: Sarah Lowe, Chief Operations Officer

To ensure health & safety standards are maintained and improved, the following people have responsibility in the following areas:

Sarah Lowe  Chairman Health & Safety Committee

Phil Willshere  Horncastle Site Representative

Simon Ward  Fire Officer

Jo Harding   Leicester Site Representative  

All employees have to:

•             Co-operate with supervisors and managers on health & safety matters.

•             Not interfere with anything provided to safeguard their health & safety.

•             Take reasonable care of their personal health & safety.

•             Report all health & safety concerns to an appropriate person (as detailed in this policy statement)

 

Health & Safety risks arising from our work activities

•             Risk Assessments will be undertaken by Departmental Managers and Supervisors in close liaison with the Health & Safety Committee.

•             The findings of the Risk Assessments will be reported to the Chairman of the Health & Safety Committee.

•             Action required to remove/control risks will be approved by the appropriate Departmental Manager.

•             The Health & Safety Committee will check that the implemented actions have removed/reduced the risks.

•             Assessments will be reviewed ANNUALLY or when the work activity changes, which ever is soonest.

 

Consultation with employees

•             Employee representatives are:

Sarah Lowe       Chairman Health & Safety Committee

Phil Willshere     Horncastle Site Representative

Simon Ward       Fire Officer

Jo Harding         Leicester Site Representative

•             Consultation with employees is provided through the Health & Safety Committee which reports to the Board of Directors via the Committee Chairman.

 

Safe plant, machinery & office equipment

•             Phil Willshere, Group Logistics Manager is responsible for enforcing safe practice within the warehouse & distribution operation, and monitoring the safety and maintenance of all Horncastle based utilities.

•             Phil Willshere, Group Logistics Manager is responsible for monitoring the safety and maintenance of all embroidery equipment, and ensuring that it is regularly serviced.  A service maintenance schedule of all embroidery machinery is held by Phil.

•             Simon Ward, Sales Director is responsible for monitoring the safety and maintenance of all, Woodside based utilities, and boilers.

•             The Health & Safety Committee is responsible for ensuring effective maintenance procedures are drawn up and followed by the Company.

•             PAT Testing.  Simon Ward & Phil Willshere will manage the PAT testing of all equipment on their respective sites in accordance with the following guidelines.

 

Equipment Type Formal Visual Check           Inspection & Test by engineer
Desktop computers, Photocopiers, Fax Machines           2 years 5 years
Fans & Table Lamps 2 years No Requirement
Machinery 1 year 1 year
Electric Kettles, Cables & Extension Leads 1 year 2 years

 

 




Safe Handling & use of Substances

•             Management in consultation with the H&S Committee is responsible for identifying all substances which need a Control of Substances Hazardous to Health (COSHH) assessment.

•             Delegated managers and supervisors are responsible for undertaking COSHH assessments.

•             Departmental managers are responsible for ensuring that all actions identified in the assessments are implemented.

•             The Health & Safety Committee Representatives are responsible for ensuring all relevant employees are informed about the COSHH assessments.

•             Managers will check with the Health & Safety Committee that new substances can be used safely before they are purchased.

•             Assessments will be reviewed ANNUALLY or when the work activity changes, whichever is soonest.

 

Information, Instruction & Supervision

•             The Health & Safety Law Poster is displayed in the Leicester Offices’ kitchen.  Likewise, the same poster is displayed outside the Horncastle based, Embroidery Department.

•             Health & Safety advice is available from the Health & Safety Committee Representatives.

•             Supervision of staff will be arranged, undertaken and monitored by departmental managers and supervisors.

•             Departmental managers are responsible for ensuring that our employees working at locations under the control of other employers are given relevant health & safety information.

 

Competency for tasks & training

•              Induction training will be provided for all employees by the appropriate department manager.

•              Job specific training will be identified by departmental managers and recorded on individual staff Training & Development Plans.

•              Specific jobs requiring specialist training will be identified during the production and maintenance of the Group’s Risk Assessments.

•              Training records detailing core competencies are to be kept by the departmental managers.  All staff must undertake basic fire awareness training within 2 weeks of joining the Group.  A master copy is held by the HSW Chairman.

•              Managers must ensure staff complete a VDU Assessment on joining the company and every time they subsequently move desk location or are issued with new IS.

•              Training will be identified, arranged and monitored by departmental directors & managers.

 

Accidents, first aid and work-related ill health

•             Site First Aid Boxes are checked monthly & maintained by Tracey Thain and Phil Willshere Boxes are located in:

•              Leicester Sales Office

•              Leicester 2nd Floor – Next to Photocopier

•             Horncastle– Picking Dept Notice Board

•             The appointed first aiders are: Tracey Thain (Leicester)     Phil Willshere & Phil Carter (Horncastle)

•             Accidents and cases of work-related ill health are to be recorded in the Accident Book held by the Tracey Thain, (Leicester) & Phil Willshere (Horncastle).  All Accident Reports are to be immediately forwarded to the H&S Committee Chairman who will ensure RIDDOR requirements are met and that the Committee reviews all other incidents with a view to implementing future preventative measures.

 

Monitoring

•             To check our working conditions, and ensure our safe working practices are being followed, the Health & Safety Committee will:

•              Meet bi-annually to discuss & review prevalent issues.

•              Review Risk Assessments annually.

•              Review COSHH Assessments annually.

•              Review the Accident Books annually.

 

The Health & Safety Committee is responsible for investigating accidents.

The Health & Safety Committee is responsible for investigating work-related causes of sickness absences.

The Directors are responsible for acting on investigation findings to prevent recurrence.

 

Emergency procedures – fire and evacuation

•             Simon Ward & Phil Willshere are responsible for ensuring the fire risk assessments are undertaken and implemented at their respective locations.

•              All managers are responsible for ensuring their departments escape routes are checked every week.

•              Fire extinguishers are checked annually by UK SAFETY LIMITED (Leicester) & FIRESTOP SERVICES LIMITED (Horncastle).

•              Alarms are tested in rotation by Simon Ward (Leicester) at 10:00 am every Tuesday, and & Phil Willshere (Horncastle) at 8.15 am every Thursday.

•              The Fire Plan & Maintenance Books are held by Simon Ward (Leicester) & Phil Willshere (Horncastle).

•              Emergency evacuation will be tested bi-annually on the direction of the Health & Safety Committee.

 

Download our Group Health & Safety Policy

 

WHISTLEBLOWING POLICY

1.  SCOPE

1.1 This policy applies to all workers and employees working for Ryland Dickson Limited or any company which is a subsiiary or holiday company of Ryland Dickson Limited ("the Company") in the UK.

1.2  This policy does not form part of any employee's contract of employment and it may be amended at any time.

 

2.  ABOUT THIS POLICY

2.1  This policy is designed to enable employees of the Company to raise concerns internally and at a high level and to disclose information which the individual believes shows malpractice or impropriety. This policy is intended to cover concerns which the employee reasonably believes are in the public interest and may at least initially be investigated separately but might then lead to the invocation of other procedures (such as the disiplinary procedure).

 

3.  WHAT IS WHISTLEBLOWING?

3.1  Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work. This may include:

(a)    Criminal Offences

(b)    Failure to comply with any legal obligations

(c)    Miscarriages of justice

(d)    Damage to the environment

(e)    Dangers to the Health & Safety of any individual

(f)    Modern day slavery or human trafficking concerns within the Company or its supply chain

(g)    Attempts to conceal any of these

 

3.2  A whistleblower is a person who raises a genuine concern relating to any of the above. If you have any genuine concerns related to suspected wrongdoing or danger affecting any of our activities (a whistleblowing concern) you should report it under this policy.

3.3  This policy should not be used for complaints relating to your own personal circumstances, such as the way you have been treated at work. In those cases you should use the Grievance Policy or Anti-harassment and Bullying Policy as appropriate.

3.4  If you are uncertain whether something is within the scope of this policy you should seek advice from a senior member of management.

 

4.  RAISING A WHISTLEBLOWING CONCERN

4.1  We hope that in many cases you will be able to raise any concerns with your line manager. However, where you prefer not to raise it with your manager for any reason, you should contact a senior member of management who will arrange a meeting with you as soon as reasonably to discuss your concern.

 

5. CONFIDENTIALITY

5.1  We hope that staff will feel able to voice whistleblowing concerns openly under this policy. We do not encourage staff to make disclosures ananymously. Proper investigation may be more difficult or impossible if we cannot obtain further information from you. It is also more difficult to establish whether any allegations are credible. If it is necessary for anyone investigating your concern to know your identity, we will discuss it with you.

 

6.  INVESTIGATION AND OUTCOME

6.1  Once you have raised a concern, we will carry out an initial assessment to determine the scope of any investigation. We will inform you of the outcome of our assessment. You may be required to attend additional meetings in order to provide further information. You should treat any information about the investigation as confidential.

6.2  In some cases we may appoint an investigator or team of investigators including staff with relevant experience of investigations or specialist knowledge of the subject matter. The investigator(s) may make recommendations for change to enable us to minimise the risk of future wrongdoing.

 

7.  PROTECTION AND SUPPORT FOR WHISTLEBLOWERS

7.1  It is possible that whistleblowers are sometimes worried about possible repercussions. We aim to encourage openness and will support staff who raise genuine concerns under this policy.

7.2  Whistleblowers must not suffer any detrimental treatment as a result of raising a concern. Detrimental treatment includes dismissal, disciplinary actions, treats or othe unfavourable tratment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform Human Resources immediately. If the matter is not remedied you should raise it formally using our Grievance Policy.

7.3  You must not threaten or retaliate against whistleblowers in any way. If you are involved in such conduct you may be subject to disciplinary action which could result in your summary dismissal.

Download Our Whistleblowers Policy