Key Policies


These policies are taken from a handbook compiled for Tema Engineering Ltd (known herein as “The Company”) to give a broad, but focused overview of both company and employee responsibilities related to Quality, Health & Safety, the Environment and other essential employment law criteria. Its purpose is to give the company employees/workers/temporary workers/contractors and sub-contractors a greater awareness of these key issues to create a safer working environment for all. Please note that for the Health and Safety elements it does not supersede the main Health & Safety Policy document held by the company, it supplements it.

 The company commits to communicate these key company policies to all associated Internal and External Interested Parties. Internal Interested Parties will be issued with this Policy Handbook upon induction and policies displayed throughout the depots.

 The company will issue a copy of this “Tema Key Policies Handbook” to any External Interested parties if required upon request.

Quality Policy

The company is committed to the implementation and on-going improvement of our Quality System standards and to the involvement of all staff in the continual maintenance of the high standards of customer service provided by the company.

 We as a Company have a commitment to Quality and confirm we shall:

  •  Implement and maintain an effective set of quality procedures that comply with ISO 9001.
  • Setting and continually monitor / review our quality objectives through use of the company’s annual improvements plan.
  • Achieve continual improvement by regularly reviewing and evaluating our services supplied to meet client requirements.
  • A commitment to work with suppliers & customers to establish & maintain the highest quality standards.
  • A commitment to continual improvement in quality performance through the company’s annual improvements plan.

 Compliance to this combined policy is mandatory for all staff and only director approved deviances will be allowed.

The company recognises that the procedures in conjunction with this integrated policy statement which itself is an expression of the commitment of the company to environmental protection, quality throughout all business operations, and protecting the health & safety of all staff, as basic management responsibilities.

The Procedures Manual and associated work records define the processes implemented, to ensure compliance with both the company’s quality, legislative and British Standard requirements.

The policy will be reviewed and if required updated every 12 months unless legislative changes necessitate more frequent changes. The specific arrangements for the implementation of this policy and the personnel responsible are detailed in the management review procedure for the company.

Environmental Policy

The company is committed to the preservation of the environment by monitoring and minimising the impact of our activities. By developing our understanding of our impacts and by the setting of objectives, we will strive to continuously improve our environmental performance with the aim of minimising consumption and waste. The company will operate in compliance with all relevant existing and future environmental laws, regulations and associated codes of practice disciplines. This will be applicable to all regions in which we operate. We are committed to maintain effective communication systems on environmental matters, and we will respond positively to enquiries and suggestions from both inside and outside the company.

 We have a responsibility to the company and both our employees and the local community to maintain a safe environment and to operate in a sustainable manner, and as such we will respect our legal and ethical responsibilities through the use of appropriate training and learning

 We as a company have a commitment to the Environment and we shall:

  •  Preventing pollution by every means possible.
  • Protect the environment as much as we possibly can for all aspects of our work activities.
  • Monitor and try to reduce environmentally significant aspects / impacts.
  • Specifically minimise the environmental impact for the life cycle (including disposal) of any plant and/or equipment and other physical assets.
  • Setting & monitoring environmental objectives through the company’s annual improvements plan.
  • Limit the environmental impact of its activities by waste and material handling, and reduction methods.
  • Record, monitor and publish, if required, statistics related to environmental improvement target achievement.
  • Continual improve our environmental performance through the company’s annual improvements plan (Environmental Objectives).
Health and Safety Policy

It is the policy of the company to comply with the terms of the Health and Safety at Work Act 1974 and related legislation disciplines and to provide and maintain a healthy and safe working environment. The company health and safety objective is to minimise the number of instances of occupational accidents and illnesses and ultimately to achieve an accident-free workplace.

The company is committed to implementing this policy statement through its integrated QEHS management system, all associated procedures and practices in all aspects of our business scope of activities. We are committed to attainment of company and client requirements, and recognise that continually improving our performance is a key factor in our continuing business success. We ensure that the appropriate procedures cover all applicable environmental, quality, and health and safety areas of our business and our operations.

While the management of the company will do all that is within its powers to ensure the health and safety of its employees, it is recognised that health and safety at work is the responsibility of each and every individual associated with the company. It is the duty of each employee to take reasonable care of their own and other people’s welfare and to report any situation which may pose a threat to the well being of any other person.

An effective health and safety programme requires continuous communication between employees at all levels. It is therefore every employee’s responsibility to report immediately any situation which could jeopardise the well being of themselves or any other person.

We as a company have a commitment to Health & Safety and confirm we shall:

  • Ensure good H&S practices throughout the business so far as is reasonably practicable.
  • All employees will be provided with such equipment, information, training and supervision as is necessary to implement the policy and achieve the company’s annual improvements plan (H&S objectives).
  • Allocate appropriate finance and resource where appropriate to improve H&S throughout the business through compliance monitoring.
  • Report all RIDDOR categorised accidents, incidents, near misses or dangerous occurrences.
  • Protect the health and safety of all visitors to the company, including contractors and temporary employees, as well as any members of the public who might be affected by our operations.
  • Provide every employee with the training necessary to carry out their tasks safely.
  • Providing sufficient resources for the management of Health & Safety.
  • Setting & monitoring safety objectives through the company’s annual improvements plan.
  • Aim to continually improve our safety performance through compliance monitoring and feedback.
Corporate Social Responsibilty Policy

We recognise that we must integrate our business values and operations to meet the expectations of our stakeholders. They include customers, employees, regulators, investors, suppliers, the community and the environment.

  • We recognise that our social, economic and environmental responsibilities to these stakeholders and Interested Parties are integral to our business. We aim to demonstrate these responsibilities through our actions and within our corporate policies.  
  • We take seriously all feedback that we receive from our stakeholders and, where possible, maintain open dialogue to ensure that we fulfil the requirements outlined within this policy.
  • We shall be open and honest in communicating our strategies, targets, performance and governance to our stakeholders in our continual commitment to sustainable development.
  • The Managing Director is responsible for the implementation of this policy and will make the necessary resources available to realise our corporate responsibilities. The responsibility for our performance to this policy rests with all employees throughout the company.
  • We shall strive to improve our environmental performance through implementation of our Environmental policy.
  • We shall ensure a high level of business performance while minimising and effectively managing business risks.
  • We will register and resolve customer complaints in accordance with our non-conformance procedures.
  • We shall operate an equal opportunities policy for all present and potential future employees.
  • We will offer our employees clear and fairs terms of employment and provide resources to enable their continual development.
  • We shall maintain a clear and fair employee remuneration policy and shall maintain forums for employee consultation and business involvement.
  • We shall provide safeguards to ensure that all employees are treated with respect and without sexual, physical or mental harassment.
  • We shall provide, and strive to maintain, a clean, healthy and safe working environment.
  • We shall uphold the values of honesty, partnership and fairness in our relationships with stakeholders.
  • Our contracts will clearly set out the agreed terms, conditions and the basis of our relationship.
  • We will operate in a way that safeguards against unfair business practices.
  • We shall encourage suppliers and contractors to adopt responsible business policies and practices for mutual benefit.
Waste Minimisation and Sustainabilty Policy
  • Recycling implemented, with all reusable plastics, metals, glass and paper, batteries and cardboard being stored in designated areas and disposed of at recycling centres as appropriate or collected for recycling by a licensed waste contractor.
  • Where possible all business reports are digitised and saved electronically to reduce use of paper. Sensitive documents are shredded and then also recycled.
  • The company will replace standard lighting with energy efficient light bulbs where feasible and utilise the option of power saving modes present on all low energy consumption computers in the offices. With the exception of the dedicated server all computers and lighting in the offices are turned off at night.
  • Heating systems are serviced regularly, thermostatically controlled and switched off when not required.
  • Lighting is switched off when not required.
  • The company vehicles are maintained at the intervals specified by the manufacturer to the specifications recommended by the manufacturer. Regular servicing ensures that the emissions from the vehicles are kept at the correct levels and also increases vehicle life.
  • Vehicles are replaced regularly, which ensures the fleet is maintained at the latest emissions standards.
  • Journeys are planned to minimise emissions and the use of fuel.
  • Packaging materials are reused to minimise the use of new packaging.
  • We as a company procure materials from sustainable sources as much as we possibly can.
  • We have stringent guidelines involving our site works and field operations.
  • All site work is undertaken in accordance with environmental legislation to ensure that our works and processes do not increase risk of contamination on-site.
  • We are also careful to ensure that the materials used on site are appropriate to the job and will not present a contamination risk on site.
Equal Opportunities Policy

The Company recognises that discrimination exists in society, and is committed to developing and promoting ways of working that ensure that employees and clients are not subjected to direct or indirect discrimination. We wholeheartedly support the principles of equal opportunities in employment and service delivery, and oppose all forms of unlawful or unfair discrimination.

We will uphold all laws relevant to promoting equality and countering discrimination, and are bound by The Equality Act 2010. Under the Act, it is unlawful to discriminate against people at work because of the nine protected characteristics, these are;

  • Age
  • Disability
  • Race
  • Gender Reassignment
  • Marriage & Civil Partnership
  • Pregnancy & Maternity
  • Religion or Belief
  • Sex or Sexual Orientation

The Company is committed to equality of opportunity in its provision of services. To this end all who approach it for services will be treated fairly and equally. This will be promoted to all stakeholders and expected of all partnering organisations & individuals.

Anti-Slavery and Human Trafficking Policy Statement

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, volunteers, agents, contractors and suppliers.

The Company strictly prohibits the use of modern slavery and human trafficking in our operations and supply chain. We have and will continue to be committed to implementing systems and controls aimed at ensuring that modern slavery is not taking place anywhere within our organisation or in any of our supply chains. We expect that our suppliers and contractors will hold their own suppliers to the same high standards.

Modern slavery is a term used to encompass slavery, servitude, forced and compulsory labour, bonded and child labour and human trafficking. Human trafficking is where a person arranges or facilitates the travel of another person with a view to that person being exploited. Modern slavery is a crime and a violation of fundamental human rights. The Company is committed to enforcing the Modern Slavery Act (2015).

The Company expects everyone working with us or on our behalf to support and uphold the following measures to safeguard against modern slavery:

  • We have a zero-tolerance approach to modern slavery in our organisation and our supply chains;
  • The prevention, detection and reporting of modern slavery in any part of our organisation or supply chain is the responsibility of all those working for us or on our behalf. Workers must not engage in, facilitate or fail to report any activity that might lead to, or suggest, a breach of this policy; and
  • We are committed to engaging with our stakeholders and suppliers to address the risk of modern slavery in our operations and supply chain.

We take a risk based approach to our contracting processes and keep them under review. We assess whether the circumstances warrant the inclusion of specific prohibitions against the use of modern slavery and trafficked labour in our contracts with third parties. Using our risked based approach we will also assess the merits of writing to suppliers requiring them to comply with our Code of Conduct, which sets out the minimum standards required to combat modern slavery and trafficking.

Consistent with our risk based approach we may require:

  • Employment and recruitment agencies and other third parties supplying workers to our organisation to confirm their compliance with our Code of Conduct; and
  • Suppliers engaging workers through a third party to obtain that third parties’ agreement to adhere to the code of conduct.

As part of our ongoing risk assessment and due diligence processes we will consider whether circumstances warrant us carrying out audits of suppliers for their compliance with our Code of Conduct.

If we find that other individuals or organisations working on our behalf have breached this policy we will ensure that we take appropriate action. This may range from considering the possibility of breaches being remediated and whether that might represent the best outcome for those individuals impacted by the breach to terminating such relationship.

A signed and dated copy of this statement is available on request from 

Grievance Policy

You need to be aware that the Company is completely committed to the principle of equal opportunity in employment. Accordingly, management will ensure that any grievances are dealt with appropriately.

 This policy explains how employees/candidates/contractors (known as “The Worker”) etc can voice their complaints in a constructive way. Supervisors / Line Managers should be aware of what annoys employees or hinders their work, so they can resolve it as quickly as possible. The worker should be able to follow a fair grievance procedure to be heard and avoid conflicts.

 The company encourages employees to communicate their grievances. That way we can foster a supportive and pleasant workplace for everyone.


This policy refers to everyone in the company regardless of position or status:

  •  Policy elements
  • Grievance definition

 We define grievance as any complaint, problem or concern of an employee regarding their workplace, job or co-worker relationships.

 Workers can file grievances for any of the following reasons:

  • Workplace harassment
  • Health and safety Issues
  • Supervisor / Management behaviour
  • Adverse changes in employment conditions

 This list in not exhaustive. However, employees should try to resolve less important issues informally before they resort to a formal grievance.

 Workers who file grievances can:

  • Reach out to their direct supervisor or HR department
  • File a grievance form explaining the situation in detail
  • Refuse to attend formal meetings on their own
  • Appeal on any formal decision

 Workers who face allegation have the right to:

  • Receive a copy of the allegations against them
  • Respond to the allegations
  • Appeal on any formal decision

 The company is obliged to:

  • Have a formal grievance procedure in place
  • Communicate the procedure
  • Investigate all grievances promptly
  • Treat all employees who file grievances equally
  • Preserve confidentiality at any stage of the process
  • Resolve all grievances when possible
  • Respect its no-retaliation policy when employees file grievances with the company or external agencies (e.g. equal employment opportunity committee)

  Workers are encouraged to talk to each other to resolve their problems. When this isn’t possible, employees should know how to file a grievance:

 Communicate informally with their direct supervisor. The supervisor will try to resolve the problem. When employees want to complain about their supervisor, they should first try to discuss the matter and resolve it between them. In that case, they’re advised to request an informal meeting. Supervisors should try to resolve any grievance as quickly as possible. When they’re unable to do so, they should refer to the HR department and cooperate with all other procedures.

  1. If the grievance relates to a supervisor behaviour that can bring disciplinary action (e.g. sexual harassment or violence), employees should refer directly to the HR department or the next level supervisor.
  2. Accommodate the procedure outlined below

 The HR department (or any appropriate person in the absence of an HR department) should follow the procedure below:

 Discuss the grievance and record it formally as accurately as possible to ensure the matter is understood completely.

  1. Provide the employee who faces allegations with a copy of the grievance
  2. Organize mediation procedures (e.g. arranging a formal meeting)
  3. Investigate the matter or ask the help of an investigator when needed
  4. Keep employees informed throughout the process
  5. Communicate the formal decision to all employees involved
  6. Take actions to ensure the formal decision is adhered to
  7. Deal with appeals by gathering more information and investigating further
  8. Keep accurate records

 This procedure may vary according to the nature of a grievance. For example, if an employee is found guilty of racial discrimination, the company will begin disciplinary procedures.

Information Security Policy


The objective of information security is to ensure the business continuity of the company and to minimize the risk of damage by preventing security incidents and reducing their potential impact.


The company is committed to protecting our IT infrastructure, protecting data both internal and external to our business. Our business employs an external IT specialist who actively protects our entire IT infrastructure against current and future potential threats.

  • The policy’s goal is to protect the organization’s informational assets against all internal, external, deliberate or accidental threats.
  • The security policy ensures that:
    • Information will be protected against any unauthorized access;
    • Confidentiality of information will be assured;
    • All information is backed up on external servers located outside Pump Supplies premises.
    • Actively communicates procedures to all employees on IT security and associated risks.
    • Any new information systems implemented through the network fully complies with our IT information security infrastructure.
    • Availability of information for business processes will be maintained;
    • All actual or suspected information security breaches will be reported to the Managing Director who will thoroughly investigate and provide future guidance.
  •  Procedures exist to support the policy, including virus control measures, passwords and continuity plans.
  • Business requirements for availability of information and systems will be met.
Anti-Bribery Policy (In compliance with the Bribery Act 2010)

It is the policy of the company to conduct all of our business in an honest and ethical manner. We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our dealings wherever we operate. We are also committed to implementing and enforcing effective systems to counter bribery.

 This policy applies to all individuals working at all levels and grades, including senior managers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, and any other person providing services to us.

 A bribe is a financial or other advantage offered or given:

  • To anyone to persuade them to or reward them for performing their duties improperly
  • To any public official with the intention of influencing the official in the performance of his duties.

 This policy does not prohibit giving and receiving promotional gifts of low value and normal and appropriate hospitality. However, in certain circumstances gifts and hospitality may amount to bribery and all employees must notify the company in respect of gifts and hospitality. We will not provide gifts or hospitality with the intention of persuading anyone to act improperly or to influence them in the performance of their duties.

 We do not make, and will not accept, facilitation payments or “kickbacks” of any kind. All employees must avoid any activity that might lead to, or suggest, that a facilitation payment or kickback will be made or accepted by us. We do not make contributions of any kind to political parties. No charitable donations will be made for the purpose of gaining any commercial advantage.

 We will keep financial records and have appropriate internal controls in place which will evidence the business reason for making any payments to third parties.

 All expense claims relating to hospitality, gifts or expenses incurred to third parties must be approved prior to expenditure.  All accounts, invoices, memoranda and other documents and records relating to dealings with third parties, such as clients, suppliers and business contacts, must be prepared and maintained with strict accuracy and completeness. No accounts must be kept “off-book” to facilitate or conceal improper payments.

 Employees will be encouraged to raise concerns about any issue or suspicion of malpractice at the earliest possible stage. No employee will suffer any detriment as a result of raising genuine concerns about bribery, even if they turn out to be mistaken.  Internal control systems and procedures will be subject to audit under the internal audit process. 

 The responsibility for the implementation of this policy lies with the Managing Director.

Data Privacy Policy

This data privacy policy sets out how Tema Engineering Ltd (herein after referred to as “The Company”) uses and protects any information that Employees, Subcontractors, Customers and/or Suppliers gives to the company via email/post/in person.

 The company is committed to ensuring that your privacy is protected. We will comply with the principles of the Data Protection Act 1998 (guide) and the General Data Protection Regulation (GDPR) and aim to maintain best-practice standards in our processing of personal and/or sensitive personal / company sensitive data.

 Should we ask you to provide certain information by which you can be identified it will only be used in accordance with this privacy statement.

 Where changes to this policy are required updated issues will be emailed out and be made available to all appropriate personnel / interested parties.

 We may collect the following information:

  • Name and job title.
  • Contact information including email address.
  • Demographic information such as postcode.
  • National Insurance Number
  • Bank / Financial Details.
  • Date of birth.
  • Emergency Contact Name and Number
  • Copy of passport

 What we may have to do with the information:

  • Communicate with Subcontract companies, Clients during projects / contracts.
  • Payment of invoices / Salaries
  • Completion of security forms in order to obtain access to Government locations if required.
  • Health and safety documentation
  • Training documentation

 Who we collect information from:

  • Full Time/Part Time or Temporary Workers / Employees
  • Subcontractors (Individuals or Subcontract Companies)
  • Sponsored Individuals (for Railway Working)
  • Suppliers – company information only.


We are committed to ensuring that your information is secure. Electronic information stored on the company server is password protected. Passwords can be changed at periodic / regular intervals. The company server has a firewall protection.  Each computer system has virus protection that scans when the system initially starts and continually throughout the time it is running – for each document that is opened.

Paper documents are filed securely and only available to specific people.

Any personal information you send to us via email/post is done so at your own risk.

Sharing of data

Personal data may be shared with a third party where we have to check, then forward application forms for any required security clearances.

Personal data will not be shared unless prior agreement is made with those concerned.

Data Consent Form

Where individuals or organisations are requested to provide information to the company, a Data Consent Form (DCF) will also need to be completed by the individual(s) concerned. 

This will provide the company with the authority to use the data as specifically required.

How to withdraw your consent

You can withdraw the consent you are giving on the DCF at any time. You can do this by either writing to us, or emailing us at the addresses below:

Company Name: Tema Engineering Ltd

Address: Coleridge Road

Leckwith Industrial Estate


CF11 8BT

 Email Address:

 Access to Information

The Data Protection Act gives you the right to obtain/view the personal data held by the company at any time.  

Anti-Tax Evasion Policy

The Company is a values-led, purpose-driven Organisation committed to complying with all applicable legislation and acting professionally, fairly and with integrity in all business transactions.  Company ethical codes and standards are shared at all levels and visibly integrated into our Business social and environmental dealings.

We take pride in our Operations and our commitment to transparency, openness, and safety is taken extremely seriously by our entire workforce.

In compliance of the Criminal Finances Act 2017, The Company has a zero-tolerance to tax evasion and the facilitation of tax evasion and have adopted an Anti-Facilitation of Tax Evasion Statement of Value that governs our business dealings and the conduct of all persons or Organisations who are appointed to act on our behalf, wherever located.


 Tax evasion facilitation (whether UK tax or tax in a foreign country) is being knowingly engaged in, or taking steps with a view to, the fraudulent evasion of tax  by another person, or aiding, abetting, counselling, or procuring the commission of that offence.

Tax evasion is illegally cheating the public revenue, or fraudulently evading tax by intentionally suppressing income or sales, or by increasing expenses which results in reduction of total income.

Tax evasion deprives Governments of the revenues they need to provide vital public services.  The offence requires an element of fraud, which equates to deliberate action or omission with dishonest intent.

Tax evasion is not the same as tax planning or tax avoidance.

  • Tax Planning is a way to reduce tax liability by taking full advantage of the Act through various exemptions, deductions, rebates and relief.
  • Tax Avoidance involves taking advantage of loopholes within the Act to minimise tax payable or maximise tax reliefs.

 Tax means all forms of taxation including, but not limited to, income tax, national insurance contributions (and their equivalents in non-UK jurisdictions), value added tax, corporation tax, stamp duty, stamp duty land tax, and includes any other form of taxation or duty, however described.

 Foreign Tax Evasion means evading tax in a foreign country, provided that the conduct is an offence in that country and would be a criminal offence if committed in the UK.

 As with tax evasion¸ the element of fraud means there must be deliberate action or omission with dishonest intent.

 Facilitation of fraudulent evasion of tax is a criminal offence under the law of any part of the UK where it is done deliberately and dishonestly.


Employees and all those who have, or seek to have, a business relationship with our Company to familiarise themselves with this Policy and our Anti-Facilitation of Tax Evasion Statement of Value, and to ensure that they comply and act at all times in a way that is consistent with the contents.


This Policy applies to all persons working for, or on behalf of The Company in any capacity wherever located, including, but not limited to:

  • Directors
  • Associates
  • Employees
  • Business Partners
  • Agents
  • Contractors
  • Suppliers
  • External Consultants
  • Advisers
  • Intermediaries
  • Third-Party Representatives
  • Volunteers
  • Interns
  • Sponsors
  • Agency Workers
  • Any other persons who performs services associated with our Company


The Company will provide appropriate training to all staff on recognising and preventing financial crime.

 A financial risk assessment has resulted in the establishment of safeguarding procedures governing certain transactions with Third Parties that are designed to prevent specific areas of possible tax evasion by a Third Party.   Further guidance can be sought from The Company Board of Directors.

 In accordance with this Policy, it is not acceptable for anyone to:

  •  Engage in any form of facilitating Tax Evasion or Foreign Tax Evasion;
  •  Aid, abet, counsel or procure the commission of a Tax Evasion or Foreign Tax Evasion offence by another person;
  •  Fail to promptly report any demand or request from any third party to facilitate the fraudulent evasion of tax by another person;
  •  Threaten or retaliate against another individual who has refused to commit a tax evasion or foreign tax evasion offence, or who has raised concerns under this Policy;
  •  Engage in any activity that might lead to a breach of this Policy;


Employees have a fiduciary responsibility to follow Company policies and procedures at all times.  Any actions that breach the Criminal Finances Act 2017 and the tax laws of wherever we operate will bring harm to our Company that will not be tolerated.

 Any employee found to be in breach of this Policy will face disciplinary action.

 No employee will suffer penalties or other adverse consequences for refusing to engage in services where they suspect, or know, tax evasion to be taking place.

 Any concerns involving a potential breach of this Policy must be reported immediately to a Director.


As there is not an exhaustive list of tax evasion opportunities, the best defence against tax evasion and facilitation of tax evasion remains the vigilance of our Team Members and the adoption of a common sense approach supported by our clear whistleblowing procedure.

 In applying common sense, Team Members must be mindful and alert to the following:

  •  Is there anything unusual about the manner in which an Associate of the Company is conducting their relationship with a Third Party (i.e. a Client, Contractor etc.)?
  •  Is there anything unusual about an Associate or Client’s conduct or behaviour?
  •  Are there any unusual payment methods?
  •  Unusual payment methods or conduct of Third Parties with Company Associates can be indicative that a transaction may not be all that it seems.

 The Company’s whistle blowing / reporting procedure ensures that personnel are able to express any concerns regarding suspected breaches of the Criminal Finances Act 2017, malpractice, misconduct, wrongdoing, fraud, or breach of Legislation connected to any of our Business Operations without the fear of retribution, discriminatory or disciplinary action.


Reporting may be done by raising a concern internally with either a Line Manger or Director, or anonymously through external whistleblowing channels.

The Company upholds a Policy of “stand up, speak up” in relation to concerns of any nature so any suspicion or request to go outside our standard procedures should be reported immediately upon identification.  Management will report the circumstances to the appropriate Authority such as HMRC, Serious Fraud Office etc.


This should never happen.

If there is any suspicion of intention to evade tax, irrespective of whether a transaction has been finalised, the Company can be criminally prosecuted, subject to a large fine, and publicly named and shamed.


The Company Directors or Board of Directors has overall responsibility for ensuring that this Policy complies with the Company’s legal obligations, is communicated to all employees and Suppliers, and that all Team Members and associates comply with it.

 The Company Directors are responsible for ensuring that those reporting to them understand and comply with this Policy, and that adequate regular training is provided on recognising and preventing financial crime.

Refusal to work on grounds of Health and Safety (Rail)
  1. Introduction

1.1: This statement sets out the policy of the company in respect of “Refusal to work on the grounds of Health & Safety” by all employees (or sub-contractors, if appropriate) in line with the principles of NR’s “Worksafe Policy” as detailed in NR/L2/OHS/00112.

1.2: A copy of the above referenced document is available to the company should a fuller interpretation be required and forms the basis for the following synopsis.

1.3: All persons referred to in 1.1 above are to be made aware of the contents of this policy and become familiar with the conditions laid down.

  1. Responsibility

2.1: The Company will take all reasonable measures to ensure that those persons referred to in 1.1 above are made aware of the contents of this policy and that it will not effect their continued employment by the company in the event of any invoking of this policy.

2.2: The company will take all reasonable measures to prevent, so far as is reasonably practicable, any invocation placed on any person by this policy by planning safe working conditions and taking all factors into account.

2.3: Employees of the company will at all times exercise diligence in monitoring their safe working environment for themselves and other persons in the working area

      3. Criteria for Invoking the Policy

3.1: It is a condition of employment with the company that all persons referred to in 1.1 above shall        comply with the following:

  •  If any situation arises which an employee believes will or has resulted in an unsafe working environment for some or all they must immediately draw it to the attention of their direct line manager so he can investigate and resolve the issue locally, if possible via completion of the appropriate “Refusal to Work” report form.
  • If line management cannot be immediately contacted then in a safe manner stop or do not commence any working operations subject to the risks identified, and warn others in danger of the concerns you have.
  • Double check that there are no instructions or information available locally to resolve the issue
  • If the line manager does not support your concerns ask for a “second opinion” to either verify the line manager’s findings or support your concerns.
  • Ensure that you are clear in describing what the concerns or issues are
  • Providing the concern is genuine, even if it is ultimately seen to be unfounded then the employee will not be the subject of any detrimental action by The Company.
  1. CIRAS Reporting

Further to the company’s processes for refusal to work on the grounds of health and safety, all staff engaged in the railway infrastructure have a facility for reporting any safety concerns into a central, confidential reporting system, CIRAS (Confidential Incident Reporting & Analysis System) To comply with the RISQS & CIRAS reporting procedure the company will subscribe as a membership levy for a 12 month rolling renewable contract.

 CIRAS is an alternative way for rail industry staff to report safety concerns that they feel unable to report through company safety channels. It is a completely independent and confidential way to report safety concerns without fear of recrimination.

 You can now contact CIRAS by calling Freephone 0800 4 101 101, writing to Freepost CIRAS or texting 07507 285887 (standard text rates apply, or via the CIRAS Website at

 The responsibility for the implementation of this policy lies with the Managing director

Managemet of Fatigue - Hours Worked Policy (Rail)
  1. Introduction

1.1: This statement sets out the policy of the company in respect of Managing Hours Worked to minimise fatigue for ‘Safety Critical Work’ carried out by any employee or subcontractor under our control, in compliance with current version of NR/L2/ERG/003 Management of Fatigue – Control of Changes in Working Hours Safety – Critical Work and the ROGS 2006 (Railway & Other Guided Transport Systems) 2006.

1.2: The key compliance requirements and implementation guidance of the above referenced standards are integrated into the following policy and associated documents also referenced within the policy to support effective control.

1.3: All persons referred to in 1.1 above are to be made aware of the contents of this policy and become familiar with the conditions laid down.

  1. Responsibility

2.1:  The Company will take all reasonable measures to ensure that those persons referred to in 1.1 above are made aware of the contents of this policy and the effect of their continued employment by the company in the event of any breach of this policy.

2.2: The company will risk assess the scheduling of work patterns for safety critical workers following the HSE Fatigue Risk Assessment guidelines and conditionally formatted spreadsheet, available in client area, to ensure minimum risk of fatigue is achieved and will monitor compliance on an ongoing basis, and If appropriate, this will be done in liaison with the client, particularly for labour supply of SCW. (Safety Critical Workers)

2.3: Employees of the company.  will at all times exercise diligence in monitoring their hours worked, including any other/additional employment working, to ensure overall compliance with the limitations detailed below.

  1. Limits on Working Time

3.1: It is a condition of employment with the company that all persons referred to above (1.1) shall comply with the door to door travel guidance note Standard NR/GN/INI/001 (up to 2 additional hours travelling time)

  • No more than twelve hours to be worked per period of duty/shift
  • No more than seventy two hours to be worked in any seven day period
  • A minimum of twelve hours rest between booking off from a period of duty/shift to booking on for the next period of duty/shift
  • No more than thirteen periods of duty to be worked in any fourteen day period
  • For TFL contracts no more than 6 shifts in any 7 day period.

 3.2: The company will not accept any deviation from the above conditions unless emergency conditions prevail, in which case a risk assessment will be carried out to ensure necessary additional working hours, to those roistered, are in compliance with current Network rail Group and Company Standards

 3.3: No other employment working times should impact on the above to either exceed the limitations or compromise the flexibility of the workforce of the company.

     4. Compliance

In order to comply with this policy and to maintain the stated and accepted standards of the company, those persons referred to in 1.1 above should, at all times:

  • Avoid, wherever possible, other employment work in the company
  • Notify the signatory of this document should other employment working times impact on the limitations outlined
  • Refer to the signatory of this document should a more detailed review of the full document NR/L2/ERG/003 be required to ensure full understanding and compliance

 The responsibility for the implementation of this policy lies with the Managing Director

Drugs and Alchohol Policy Statement
  1. Introduction

1.1: This statement sets out the policy of the Company in compliance with the current version of Group Standard RIS-8070-TOM. It is enacted through Company standard NR/L1/OHS/051 (Drugs and Alcohol) which is supplemented by: NR/L2/OHS/00120 in respect of any employee, self-employed person or contractor under our control. It affects those whose proper performance of their duties is, or may be, impaired or otherwise affected as a result of the consumption of alcohol and/or illegal substances (or prescribed drugs in certain circumstances).

1.2: Provided that persons referred to in 1.1 above adhere to the provisions contained within this policy, then they will normally be considered to have demonstrated compliance with the conditions of employment or contract insofar as they refer to the use of alcohol and drugs.

1.3: All persons referred to in 1.1 above are to be made aware of the contents of this policy and become familiar with the conditions laid down.

1.4: Provided that persons referred to in 1.1 above adhere to the provisions contained within this policy, then they will normally be considered to have demonstrated compliance with the conditions of employment or contract insofar as they refer to the use of alcohol and drugs.

1.5: All persons referred to in 1.1 above are to be made aware of the contents of this policy and become familiar with the conditions laid down.

    2. Responsibility

2.1: The Company will take all reasonable measures to ensure that those persons referred to in above are made aware of the contents of this policy and the effect on their continued employment by The Company in the event of any breach of this policy.

2.2: The Company will take all reasonable measures to prevent, so far as is reasonably practicable, any breach of duty placed on any person by this policy.

2.3: Employees of The Company   will at all times exercise diligence in monitoring their colleagues and others who from time to time may be under the control of The Company   and noting and reporting any evidence of alcohol and/or drug abuse.

2.4: Should any employee suffer any problems or difficulties in respect of the misuse of drugs and/or alcohol, or should they have reason to believe that a colleague may be experiencing such difficulties, they may approach the signatory of this policy. That person will at all times treat any information provided in complete confidence and will take such measures that are deemed necessary to ensure that the matter may be resolved with the minimum of distress to the person concerned and any others who may be affected.

     3. Conditions

It is a condition of employment by the Company that no person referred to in 1.1 above shall:

  • Report, or endeavour to report, for duty whilst under the influence of alcohol or drugs (including any prescribed drugs that may have impair work ability)
  • Report, or endeavour to report, for duty whilst in an unfit state due to the previous consumption of alcohol or drugs (including any prescribed drugs that may impair work ability)
  • Be in possession of alcohol or non-prescribed drugs during working hours
  • Consume alcohol or non-prescribed drugs during working hours
  • Employees must subject themselves to medical checks (routine, unannounced/random or “for cause”, in line with the criteria detailed in the Group & Company standards listed above) to verify compliance. Refusal or failure to pass any test will be classed as gross misconduct.
  • Failure to maintain the standard set out by this policy will be considered as gross misconduct; appropriate action will be therefore be taken in all cases
  • Should any employee fail a drug/alcohol test then they will be automatically be suspended and not allowed to reapply for a rail related qualification to work on the rail infrastructure for a minimum of 5 years.

     4. Compliance

In order to comply with this policy and to maintain compliance with the standards listed above, those persons referred to in 1.1 above should, at all times avoid:

  • Consuming alcohol or non-prescribed drugs in the eight (8) hours immediately preceding attendance at work
  • Consuming alcohol or non-prescribed drugs during meal or other break times
  • Consuming alcohol or non-prescribed drugs during working hours
  • Consuming alcohol or non-prescribed drugs whilst not in work but “on-call”
  • In addition, those persons to which this policy applies must ensure that the company is made aware of any prescribed or over the counter medication being taken, which may in any way affect their performance at work which it is necessary for them to take during working hours.

 The responsibility for the implementation of this policy lies with the Managing Director