Policies and Procedures

• Introduction

1.1. This policy sets out Sporting Aid approach to dealing with Antisocial Behaviour (ASB).

• • This policy is supported by the Antisocial Behaviour Procedure, which should be used by all Sporting Aid staff when dealing with cases of ASB.

• Scope

2.1. This policy applies to all participant for our projects, this also includes staff members from Sporting Aid, partners, visitors, volunteers, youth leaders and parents.

• Definitions

3.1. ASB, as defined by Part 1 of the Antisocial Behaviour, Crime & Policing Act 2014, is:

• Conduct that has caused, or is likely to cause harassment, alarm or distress to any

Person

• Conduct capable of causing nuisance or annoyance to a person in relation to that

person’s occupation of residential premises, or

• Our approach

4.1. This policy and the associated procedure sets out our approach to tackling ASB through

prevention, enforcement and support. The aim of the policy is to prevent and minimise the

amount of ASB that our customers suffer and which impacts adversely on the communities

within which we operate.

• • This policy sets out what our customers can expect from us, and what we expect of them, to protect their right to the peaceful enjoyment of their community.

• • We will ensure that participant are aware of their responsibilities and rights in relation to ASB. This is explained in detail at participant sign up and starter pack.

• • We will enable ASB to be reported to us in different ways, including in person, in writing, over the phone, by email and on our website. We also offer an opportunity to report using the ASB Respect Line out of normal working hours.

4.5. All reports of ASB will be responded to in line with our service standards. Contact will be

made with those reporting ASB within one working day. Priority will be given to high risk

(hate crime, domestic abuse, violence, risk of harm) or medium risk incidents.

4.6. We will carry out an initial risk assessment when ASB cases are reported and review the

assessment when necessary throughout the management of the case.

4.7. We will not take action where following investigation there is insufficient evidence to take the case further. Where the main responsibility and power to deal with ASB lies with another

service such as the Police or Local Authority we will support and work with them and our

actions will be guided by their findings and outcomes.

4.8. We will promote the view that everyone has the right to their own chosen lifestyle providing this does not impact on the quality of life of others. We will not usually take action where a complaint concerns the behaviour that results from different lifestyles, or which would not generally be considered to be unreasonable.

4.9. We will only investigate noise nuisance where the noise is frequently excessive in volume and durations or occurs at unreasonable hours, typically but not always between 11pm and 7am.

4.10. We will encourage participant to take responsibility for solving minor personal disputes

between themselves where appropriate and to involve us only where a resolution has not

been possible. 

4.11. We will agree a realistic action plan with the complainant and any witnesses and keep them informed of the actions we take. We will contact them when we close a case, giving reasons for doing so. A courtesy call will be made 3 months after the case is closed to confirm there have been no further issues.

4.12. We will close a case after investigation and appropriate action is taken and where:

• It is successfully resolved

• No further action can be taken

4.13. We will offer support to anyone that agrees to give evidence in ASB cases. We will offer advice on what to expect in Court and provide assistance with transport and costs.

4.14. We will work in partnership and consult with residents, the wider public, statutory services, local authorities, the Police, Community Safety Partnership, support providers, community groups, registered providers and other agencies as necessary to tackle ASB in our neighbourhoods.

4.15. We will use a range of preventative measures, early intervention and legal action to tackle ASB. This includes the full range of tools and powers available to us as outlined in the ASB, Crime and Policing Act 2014. The methods used will be proportionate to the seriousness, impact and frequency of the behaviour, the level of risk that it poses to those affected and the evidence available to support the case.

4.16. We will ensure that staff managing ASB cases, including those staff receiving initial reports of ASB, are fully trained in our victim centred approach to ASB. This will ensure a consistent approach across all teams ensuring that we provide the best possible service to our customers.

4.17. We will share information with third parties where we have an information sharing protocol in place or where there are safeguarding concerns. We have a duty to do so for the purpose of crime prevention under the provisions of the Crime and Disorder Act 1998.

4.18. We will process personal data and information in line with the Data Protection Act 1998 and our Data Protection policy.

4.19. We will monitor the feedback we receive about how we manage and respond to cases of ASB to continue to improve customer satisfaction and a high standard of service.

4.20. Service Standards

Sporting Aid service standards in relation to ASB are:

• We will respond to all reports of ASB by contacting the victims within one working day

• We will agree an initial action plan with them

• We will agree an appropriate timescale with victims of ASB for keeping them informed of

the progress of their case

• We will contact all victims of ASB before considering closing their case.

4.21. Measurements:

4.21.1. The success of this policy will be measured using Key Performance Indicators (KPI)

reporting mechanisms to establish and monitor trends. We will also use feedback

from those residents involved in cases to ensure that our policy and procedure

supports successful outcomes and resident expectations. Regular quality control

checks will be carried out to ensure that commitments made in the Service Standards

are being complied with. Satisfaction surveys will also be carried out when cases are

closed.

4.21.2. Current ASB KPIs are:

• ASB number of cases closed – resolved

• ASB number of new cases

• ASB ongoing cases

• ASB closed cases

4.21.3. The number and range of KPIs will be reviewed following the implementation of the

Group’s new IT system and ASB management system to ensure that the Service

Standards are monitored and reported on.

4.22. This Policy will be periodically reviewed to ensure compliance with:

• RSH’s Regulatory Framework

• Changes to legislation

• Changes to Central Government Policy

• Antisocial Behaviour Procedure

• Data Protection Procedure

• Starter Participant Procedure

• Any other Policy or Procedure created further to future statutory or regulatory changes

4.23. This document will be reviewed in conjunction with:

• Complaints Policy

• Whistleblowing Policy

• Safeguarding Policy

• Equality Scheme

5. Equality, Diversity and Inclusion

5.1. ASB can impact disproportionately on vulnerable customers and Sporting Aid will ensure that a victim centred approach will be taken to all reports of ASB to ensure that appropriate support is provided either directly or by referring customers to other agencies.

5.2. Sporting Aid will treat all customers with fairness and respect. We recognise that we have a duty to advance equality of opportunity and prevent discrimination on the grounds of age, sex, sexual orientation, disability, race, religion or belief, gender re-assignment, pregnancy and maternity, marriage and civil partnership.

• Legislation and Regulation

6.1. This policy complies with the Anti-social Behaviour, Crime and Policing Act 2014. Further considerations are given to the Data Protection Act 1998, the Equality Act 2010, the Human Rights Act 1998, and the Crime and Disorder Act 1998.

• Introduction

1.1 At Sporting Aid, we aim to be a great place to work and to deliver an excellent customer

experience every time, to help us achieve our strategic goals. In doing this, we need to

make sure we actively assist you when there is a genuine lack of capability to meet the

required standards of performance.

• Scope

• • This policy applies to all colleagues of Sporting Aid, and its subsidiaries. It does not apply to Board or committee members, third parties who work on our behalf or anyone who is still in their probationary period (see the Probationary Guidance).

• • This policy does not apply to:

• performance concerns within the probationary period.

• misconduct, which includes a deliberate failure to perform to an acceptable level, or it is

believed you have been negligent in any area of work – see the Disciplinary Policy and

Procedure

• Ongoing health concerns or attendance, which includes proactively managing your

health and wellbeing – see the Sickness Absence Policy and Procedure

• Our approach

3.1 If there are any concerns about your capability and your performance is falling below our

expected standards, your manager will make you aware as soon as possible.

Informal stage

3.2 Your manager will share any initial concerns with you, discuss reasons why you may be

failing to meet the standards set and agree actions to help you improve your performance.

3.3 These conversations will take place as soon as possible. You will work with your manager, during an agreed period (usually 4 weeks), to address concerns in order to improve your performance.

3.4 Your manager will clarify which areas you are under-performing in, agree clear objectives and give you the opportunity to meet these during an informal review period.

3.5 You will meet with your manager on a weekly basis to review the informal performance

improvement plan (PIP). A record of the conversations will be kept and, where applicable,

regular support, guidance and training will be offered throughout.

3.6 If the agreed standards are not met during the informal review period, this may result in a

formal capability meeting being held, and progression to Formal Stage 1 of the Capability

Policy and Procedure.

Formal stage 1

3.7 If, despite support provided, you have not been able to meet the required standards during the agreed informal period, you will be invited to attend a Stage 1 Capability meeting.

3.8 You will be given written notice of the meeting at least five working days before, which will outline the objectives to be discussed. This will also include a copy of the PIP, detailing the reasons why your performance continues to be below the required standard.

3.9 The Capability meeting will be chaired by your manager with support from a representative from the People team and/or a note taker. Your manager will explain reasons why the meeting has been arranged and will outline the performance issues. You will have the opportunity to discuss the concerns and respond.

3.10 You may wish to bring a colleague or trade union representative with you. The Individual Companion Support Guidance (Appendix 3) provides further clarity on the role of the companion and what to do if you wish to be accompanied. You will need to tell us in advance of the meeting if you wish to be accompanied and who it will be.

3.11 Following the meeting, your manager will consider all points discussed and decide on an appropriate outcome – see section 4.1.

3.12 If a First Capability Warning is issued, you will receive the outcome in writing, stating an

agreed time period in which you will need to meet the required standards. The required

standards will be set out by your manager with specific measures for improvement.

3.13 The outcome will also contain information on how to appeal, should you choose to do so. If you decide to appeal, the next stage of the process will continue whilst your appeal is heard.

3.14 A note taker for all formal hearings is provided, therefore, you will not be allowed to use any electronic devices to record meetings.

Formal stage 2

3.15 If your performance has not sufficiently improved in the specified timescales, or significantly deteriorates prior to the timescale elapsing, then you will be invited to a Stage 2 meeting.

3.16 The same principles as Stage 1 will be applied, giving you five working days’ notice in writing and offering you the right to be accompanied. A formal meeting will be held with you and your manager, with support from a representative from the People team/a note taker. Your manager will discuss the reasons why the meeting has been arranged, and you will have the opportunity to respond to the concerns.

3.17 Following the meeting, your manager will consider their decision taking into account any previous ‘live’ warnings (see section 4.1). You will receive the outcome in writing, including information on how to appeal, should you choose to do so.

3.18 If a Final Capability Warning is issued, an agreed period will be identified to meet the

required standards. The required standards will be set out by your manager, with specifics

measures for improvement. You will be advised that if your performance does not improve

within this period, a potential outcome may be that your employment is terminated.

3.19 The outcome will also contain information on how to appeal should you choose to do so. If you decide to appeal, the next stage of the process will continue whilst your appeal is heard.

Formal stage 3

3.20 If your performance has not sufficiently improved in the specified timescales or significantly deteriorates prior to the timescale elapsing, then you will be invited to a Stage 3 Capability meeting.

3.21 As with the previous stages, you will be given five working days’ notice in writing and have the right to be accompanied.

3.22 Your Stage 3 meeting will be chaired by a manager who is senior to the Stage 2 meeting chair or a manager of similar seniority who has not previously been involved with the process. A member of the People team/note taker will also be present.

3.23 After consideration of the facts, a decision may be made to terminate your employment with notice or payment in lieu of notice (see section 4.1). Within five working days of the meeting date, the reasons for this decision will be confirmed in writing by the person conducting the meeting.

3.24 Other actions that could be taken at this stage include:

• an extension of the Stage 2 warning

• encouraging you to apply for an alternative role

 

3.25 If a decision is made to extend the Stage 2 warning and your performance deteriorates or does not meet the required standards whilst the warning is still ‘live’, you may be invited to a further Stage 3 meeting.

• What are the possible outcomes?

• • Possible capability sanctions:

Informal stage

If performance improves sufficiently, no further action

will be taken. However, if performance deteriorates or

is not sustained, the formal process will be followed

Formal stage 1

First Capability Warning and/or targets set which will

be kept on your record for a period of 6 months,

unless agreed to extend

Formal stage 2

Extension of the First Capability Warning and targets

set, or a Final Capability Warning and targets set

which will be kept on your record for a period of 12

months, unless agreed to extend

Formal stage 3

Extension of the Final Capability Warning and targets

set, your employment is terminated with notice or

payment in lieu of notice, or encouragement to apply

for an alternative role

• • We may choose to extend the period of a formal warning where there are further concerns or in exceptional circumstances.

• • If a formal warning is given, the outcome will outline:

• What the capability concerns are

• The improvement required and the timescales

• What support and training will be given

• The arrangements for monitoring and further review meetings

• That the warning is part of the formal capability procedure

• What the next stage will be if you fail to meet the required improvement standard

• the right to appeal.

Appeal

4.4 You can appeal against the decision of the Capability meeting at any stage of the formal

process. You can do this by completing the Capability Form 1 – Appeal (CF1) and sending

this to the manager stated in your outcome letter. All appeals must be made within 5 working

days of receiving the decision in writing.

4.5 The appeal procedure is not to re-hear a Capability meeting (except in special

circumstances). Grounds for appeal can either be:

• Based on the decision that was reached

• The process that was followed

• The availability of new evidence

4.6 You will be given at least five working days’ notice to attend an appeal meeting, and will be provided with an outcome in writing.

4.7 The decision of the appeal is final with no further right to appeal.

4.8 If the decision to dismiss is revoked at the appeal meeting, reinstatement or reengagement with continuous service will apply.

Gross Incompetence

4.9 In exceptional circumstances, if you commit a single error and the actual or potential

consequences of that error are, or could be, extremely serious, warnings may not be

appropriate. In such circumstances, your manager would present a report outlining their

findings. This could lead to dismissal in line with the Disciplinary Policy and Procedure.

Suspension

4.10 Sporting Aid have a duty of care to make sure you are safe at work. If we are concerned that your health and safety is at risk, or there are medical grounds to suspend you and we are unable to make temporary adjustments to your working conditions or offer suitable alternative work, you may be suspended on full pay until it is safe for you to return to work.

4.11 A decision to suspend can be made by an appropriate manager with support from the People team. The suspending manager will give the reason and terms of suspension, which will also be confirmed in writing.

4.12 For the duration of the suspension, your access to all our IT systems will be suspended. You will be asked to return property belonging to us, including any IT equipment and your access pass to any of our offices.

4.13 Suspension should be for the shortest practicable time in order for the investigation to be completed. This will normally be for no longer than 10 working days.

• Equality, Diversity and Inclusion

• • We are committed to applying a fair and consistent approach to dealing with any concerns at work. We are open to accommodating any special requirements and reasonable adjustments to make sure colleagues understand standards expected of them. We will make reasonable adjustments on a case-by-case basis.

• Legislation and Regulation

• • This policy is reflective of the principles outlined in the Code of Practice and statutory legislation relating to employment rights/relations, equality and data protection.

• Responsibilities

• • Managers are responsible for:

• Providing a clear and thorough welcome to new starters, outlining expectations of the

role and business, and acknowledging any training needs

• Offering ongoing support and training as necessary

• Addressing any performance concerns in regular meetings and in line with this policy

and procedure. A written note should be kept.

• Managing the process in confidence with support from the People team

• Demonstrating our values in consistently applying this policy and procedure.

• • The People team are responsible for enabling managers to consistently and fairly apply the policy and procedure, providing support and advice throughout.

• • Colleagues are responsible for:

• Raising any concerns to their manager if they are experiencing difficulties meeting the

required standards

• Co-operating with us throughout the process by attending meetings, clarifying

expectations where necessary and striving to meet the standards expected of their role.

Appendix 1 – Capability Procedure

Informal stage

• If your performance falls below the expected standards, your manager will make you aware

as soon as possible

• You will work together with your manager to understand concerns and create and review

your performance improvement plan (PIP) on a weekly basis. Support will be provided

throughout

• A record of the conversations will be documented during the PIP and, if the required

standard is not met during the agreed period, you will be invited to a Stage 1 meeting

Formal stage 1

• You will receive an invite to the meeting no later than five working days before the

scheduled time. You may wish to be accompanied by colleague or trade union

representative

• Your manager will chair the meeting and will explain reasons why the meeting has been

arranged, before detailing the performance issues. You will have the opportunity to discuss

the issues and respond

• Where appropriate witnesses may also need to be interviewed and/or statements gathered

• Your response will be summarised at the end of the meeting

Decision to be confirmed in writing

• A decision will be confirmed in writing without delay. See section 4.1

Formal stage 2

• If your performance does not meet the required standards, you will receive an invite to a

Stage 2 meeting no later than 5 working days before the scheduled time. The meeting

format will be as in Stage 1

Decision to be confirmed in writing

• A decision will be confirmed in writing without delay. See section 4.1

Appeal

• You may wish to appeal the outcome at any formal stage

• An invite to the appeal hearing will be sent to you giving at least five days’ notice

• If you wish, you can bring a colleague or a trade union official

Decision to be confirmed in writing

• Appeal Chair overturns previous decision and concludes there is insufficient evidence, no

further action or recommendations/expectations set

• Appeal Chair upholds previous decision

• No further right to appeal

Formal Stage 3

• If your performance does not meet the required standards, you will receive an invite to a

Stage 3 meeting no later than five working days before the scheduled time.

• The meeting format will be as in Stage 1 and 2, however, this will be chaired by a manager

who is senior to the Stage 1 and 2 meeting chair, or a manager of similar seniority who has

not previously been involved with the issue.

Decision to be confirmed in writing

• A decision will be confirmed in writing without delay. See section 4.1.

Appendix 2 – Example of Capability Meeting format

Chair’s welcome and meeting purpose

Explain that the purpose is to discuss your performance under the Capability policy and

procedure.

Who – Chair

Chair introduces all present and confirms their roles during the meeting. These

are:

• Chair – to direct proceedings, to hear evidence and make decisions

• People team representative – to provide support and guidance

• Note taker – to make summary notes

• Colleague companion (if applicable) – to provide support. Can ask questions

but cannot answer them on behalf of the colleague

who – Chair

Chair outlines the process, including:

• Process will be managed by the Chair

• Adjournments can be requested at any stage

• Following the meeting, the outcome will be sent to the colleague in writing.

Who – Chair

Chair confirms the issues to be considered during meeting Chair

Chair considers the evidence available and asks questions to ensure colleague

understands the facts

who – Chair

Colleague’s response

This includes any further evidence and/or mitigating circumstances they wish to make

known to the Chair

who – Colleague

Chair asks any further questions

To make sure they have all of the facts and information they need to make a decision

Who – Chair

Chair invites any further comments from any party

Who – All

Chair adjourns meeting for deliberation

If employee is currently suspended, confirm the suspension will remain in place until

the employee is notified of the outcome

who – Chair

Appendix 3 – Individual companion support guidance

This document sets out Sporting Aid support and arrangements for employee companions who have been asked by a colleague to support them in accordance with relevant Sporting Aid policies, including Grievance, Disciplinary, Capability, Sickness Absence, policies and procedures.

• Role of the companion

• You have the right to be accompanied at all formal hearings/meetings where you may be

issued a formal sanction as a result.

• Your companion may be a Sporting Aid colleague or a trade union representative. You may

not be accompanied by a friend, family member, or legal representative.

• The role of the companion is to provide support and guidance to you during the process.

They may help you prepare prior to the meeting, attend the meeting with you, put any

relevant questions to the Chair, and hold discussions with you during the meeting.

However, they are not able to respond to any questions on your behalf.

• If you intend to be accompanied, you must confirm to the People Team by email who

your companion will be no later than 2 working days before the meeting date.

• If you are unable to attend a meeting, you must notify the People Team by email no later

than 2 working days before the meeting date, and you must provide a reasonable and

acceptable reason for being unable to attend. If you are unable to attend a formal

meeting, you may choose to send representation with your companion.

• Although there is no statutory right for a colleague to be accompanied at an investigatory

meeting, Sporting Aid will allow a companion to be present if, by doing so, there is no delay

in holding the investigatory meeting.

• Your companion should make every effort to attend the meeting so as not to

unreasonably delay the process.

• Communication

• Employment processes and procedures are a matter between you and Sporting Aid;

therefore, all dialogue and communication is best managed between us directly. We will

copy an identified work colleague/trade union companion in responses and include them

in any appropriate individual consultation meetings where you advise us that this is your

wish, but this will always be in addition to the communication with you and not as an

alternative to it. It is obviously important that you are fully involved in all communications

that relate to you personally.

• In line with this principle, Sporting Aid will only be able to respond to communications from

companions where you are copied in and it is absolutely clear that your companion is

acting with your express authority. In these situations, the response will be addressed to

you and your companion will be copied.

• Where communications are received from companions on behalf of unidentified

individuals, Sporting Aid will not be able to respond as this would clearly be inappropriate.

• Outside of any formal meetings, if your companion has any queries relating to the case

or other matters, these should be directed to the People Team only.

• Conduct at meetings

• All those present must behave in a professional, respectful and courteous manner

throughout; this behaviour must be extended to both the process and the people

involved.

• The Chair may adjourn the meeting in the event of unreasonable behaviour by anyone

present.

• Time off to provide support

• On request, work companions will be allowed reasonable paid time to accompany a

colleague at formal meetings and prepare for those meetings. What is reasonable

depends on the case, but would normally be no longer than an hour of preparation time

and the length of the meeting itself.

• Head of operations approval must be requested for time off to support a colleague.

Companions must give no less than 2 days’ advance written notification of this time off.

The following information should be provided:

 

– Date/times/location/expected duration of absence.

– Brief description of activity and purpose i.e. that you are a companion at a

disciplinary, grievance or capability hearing.

• It is for the companion’s Head of Operation to determine whether they can be released to

support a work colleague. Heads of Operation are expected to grant all reasonable

requests for time off by companions. Where a Head of Service has any doubts about

approving a companion’s request for time off, they should seek advice from the People

Team.

• If an individual believes that the support arrangements have been unreasonably

refused, they should raise this immediately with the Executive Director of People and culture

What is the Code of Conduct?

This Code of Conduct (Code) sets out how we achieve the highest standards of conduct and integrity. The objective of the Code is to provide guidance to help your better understand the behaviour required to meet this obligation.

Who does the Code apply to?

The Code of Conduct applies to all board and committee members, colleagues, contractors, and temporary workers while performing their duties, as well as any involved residents who form part of formal governance and consultation structures.

It applies to Sporting Aid and its subsidiaries, which are collectively referred to as ‘the Group’ in this document.

Compliance with the Code

PROBITY

Our approach

We expect individuals working for and with us to fulfil their duties and obligations responsibly, acting in the best interests of the Group, its customers, residents, and other service users.

Guiding principles

You will inevitably face situations not directly addressed by the Code. We trust you to rely on your own judgement in the proper performance of your duties and responsibilities. If a situation does arise where you are unsure of the proper course of action, you can seek advice from an appropriate person. If you are an employee this will usually be your line manager. If you are a board or committee member, or an involved resident, this could be the chair of the board or committee or the Group Chief Executive. You can also speak to the Company Secretary who will help to signpost you to the most appropriate person.

A useful set of principles that you can use for guidance are the seven Principles of Public Life (the Nolan Principles):

• Selflessness – You should take decisions solely on the basis of our values and objectives. You should not do so in order to gain financial or other material benefits for yourself or someone closely connected to you.

• Integrity – You should avoid placing yourself under any obligations, financial or otherwise, to outside individuals or organisations that might influence you in the performance of your duties.

• Objectivity – You should ensure that in the delivery of services, the appointment of employees or the award of contracts, you maintain impartiality and base decisions on merit alone.

• Accountability – You must accept accountability for your decisions and actions and submit yourself to appropriate scrutiny.

• Openness – You should be as open as possible about all the decisions and actions that you take. You should give reasons for your decisions and restrict information only when individual or commercial confidentiality clearly demands.

• Honesty – You must declare any private interests relating to your duties and take steps to resolve any conflicts arising in a way that is lawful and protects our reputation, values and mission.

• Leadership – You must promote and support these principles by leadership and example

2 LOYALTY & CONFLICTS OF INTEREST

Our approach

We expect you to ensure that your personal and private interests do not influence the decisions you make on behalf of the Group. You need to avoid conflicts of interest where possible or ensure that you declare these where appropriate.

Conflicts of interest

A conflict of interest will arise in any circumstance where doubt can be cast on your ability to act objectively. Where a conflict of interest arises exists between your duties to the Group and your personal interests, you must declare this.

Conflicts can arise from your own personal, financial or social interests or through your close connections. They may occur where you have a connection with another organisation. This could be through employment, personal relationship, commercial interest or management interest.

You should not carry out business on behalf of the Group with any organisation where you (or a closely connected person) have a personal interest.

If you are employed by another organisation this could lead to a conflict of interest. If you are an employee, you must obtain written permission from your Director to work for another organisation whilst you are employed by us.

You should also declare where you are a board or committee member of another organisation, or are part of any other membership body

What is a closely connected person?

A closely connected person is a family member or other person with whom you have a close personal association. It includes ex-family members, people living together as partners, dependents, anyone on whom an individual depends, and any person who might reasonably be regarded as similar to family members even where there is no relationship by birth or in law. It can include friends, neighbours, business associates or someone known through general social contacts. If you are not sure if someone is closely connected or not you can speak to the Company Secretary for advice.

Purchasing goods and services

To make a clear distinction between your own personal affairs and those of the Group, you must not use any contractor or supplier with whom you have a professional or commissioning relationship for personal purposes. Colleagues can check with the Procurement Team to see if a supplier or contractor is used by us. Board and committee members and involved residents can carry out this check via the Company Secretary.

If it is not possible to avoid using a particular Group contractor or supplier then you must obtain permission in advance by contacting the Company Secretary.

Where we have arrangements in place for a corporate discount with any company, you must not use that discount for personal purposes.

How to declare an interest

You are required to sign a declaration of interest form when you start working for us and must update this whenever your circumstances change. The declaration of interest form aims to establish any potential or actual conflicts of interest, and to ensure transparency. If you are not sure whether something is likely to be a conflict, a good test is to consider how the situation would be perceived by a third party. If in doubt you should make a declaration.

Any necessary actions or undertakings will be agreed with your line manager, who will sign the form before a copy is returned to you. You will be expected to follow any actions agreed.

All declarations of interest are recorded in a register, which is available for inspection by the relevant board, our Audit and Committee and internal members.

If you need advice on how to complete a declaration of interest, please contact the Company Secretary.

3. REMUNERATION

Our approach:

We have a few processes in place to ensure that decisions regarding pay are in line with the law, fair, proportionate and transparent.

How we make decisions about pay

The Remuneration and Succession Planning Committee is responsible for oversight of remuneration. The committee makes recommendations to the Group Board, which is responsible for approving any proposals.

Board and committee member remuneration is proportionate to the size of the organisation, and linked to members collectively and individually carrying out specific functions. Every three years an independent review of board and committee pay is carried out by a third party organisation which makes recommendations for remuneration in line with the market. Remuneration for the Group Chair and individual board members is published in the Annual Report and Financial Statements.

Colleague remuneration is agreed as part of the Annual Pay Review, which is approved by the Remuneration and Succession Planning Committee. Any non- contractual payments must be authorised in line with our Governance Framework.

4. PERSONAL BENEFIT

Our approach:

We have put in place policies and procedures to prevent anyone from receiving preferential treatment in the provision of benefits, including the allocation of housing and through the recruitment process. You must ensure that you do not use your position to obtain personal gain of any sort, either for yourself directly, or for your families, friends or associates.

Employment Policy

All employment decisions must be fair and transparent and, where they involve board and committee members, involved residents, colleagues or closely connected persons the correct internal procedure must be followed. Before inviting a connected person for an interview, you must obtain permission from the relevant Executive Director. They will carry out a risk assessment process to ensure that:

• There has been a rigorous, fair and competitive recruitment process and

• There is a low risk of complicity between connected persons and

• There is a low risk of a breach in confidentiality between the connected persons and

• The close connection does not diminish the capacity for effective line management.

There will be an assumption against employing connected people within the same team.

Board and committee members taking part in any recruitment exercises should make the Company Secretary aware of applicants with whom they have a connection. The Company Secretary will carry out the relevant risk assessment and put appropriate controls in place.

5. PREVENTION OF BRIBERY AND CORRUPTION

Our approach:

We have an Anti-Fraud, Bribery and Corruption Policy which sets out details of our organisational measures designed to prevent bribery and corruption. By following our policies and procedures you help to keep all of us safe.

Bribery

Bribery is the act of taking or receiving something with the intention of influencing the recipient in a way that is favourable to the person providing the bribe. Bribery is illegal and can attract a prison sentence or fine.

Gifts and Hospitality

Our approach to accepting and declining gifts and hospitality is designed to avoid any question that we are giving or receiving bribes or preferential treatment. Any gifts, accepted or declined, must be declared in the gifts and hospitality register (except where set out below).

Accepting and declining gifts and hospitality Never accept:

Never accept

• Cash or cash equivalents (including vouchers) of any amount.

• Anything offered as a bribe or inducement or which could be interpreted as a way of exerting an improper influence over the way you carry out their duties.

• Gifts with an estimated value of more than £100.

• Offers of payment from third parties for domestic or overseas travel.

• Lavish hospitality or hospitality for social events such as fine dining, sports matches, concerts or the theatre.

• Any gifts or hospitality from suppliers or contractors involved in a current procurement exercise (check with the Procurement Team if unsure).

Accept and declare:

• Small personal gifts with an estimated value of more than £30 but less than

£100 may be accepted provided that that such items are raffled or donated to a charity approved by the Group.

• Attendance at relevant charity, fundraising or other events connected with a business purpose

• Modest working meals and light refreshments or other hospitality where:

o There is a genuine need to impart information or represent the Group;

o The event is clearly part of the life of the community or where we should be seen to be represented; or

o The hospitality is part of a relevant business conference or course.

If in doubt, colleagues should pay their own share of any costs and claim these in line with the expenses policy.

Accept and do not declare:

Very low value items, such as pens or other small promotional items. Modest working lunches provided as part of a meeting or training event.

Gifts with an estimated value of £30 or less provided that these are shared amongst

the recipient’s team or department or raffled.

Note: Gifts which need to be donated can be left with a member of the Facilities Management Team or the Company Secretary

Giving Gifts and Hospitality

Giving gifts and offering hospitality to colleagues:

In exceptional circumstances we may wish to organise an event for a colleague, board or committee member or involved resident (for example to mark their retirement). This may only be done with the prior approval of the relevant senior management team or appropriate board or committee Chair. Any gifts or hospitality given should be recorded on the Gifts & Hospitality Register in the usual way.

This does not include flowers or other small tokens sent to individuals (for example due to illness or to mark a birth) which can be approved by any senior management team as well as the Company Secretary.

Giving gifts and offering hospitality externally:

Giving gifts and hospitality to another individual or organisation may only be made in exceptional circumstances. This requires the prior approval of the Group Chair or Group Chief Executive. Any gifts or hospitality given to external parties must be recorded in the Gifts & Hospitality Register.

Travel

Where you are required to travel for work-related purposes, we will pay for all legitimately incurred expenses associated with the trip, including travel, food and accommodation. These should never be paid for by suppliers, contractors or third parties.

Where your work requires you to undertake overseas travel, you must have prior authorisation from your senior management team.

Any expenditure must not be excessive and should be proportionate to the business being undertaken.

Closely connected persons are not permitted to accompany colleagues on any domestic or overseas trips.

Fraud

Fraud and attempted fraud are extremely serious offences. All incidents of fraud will be reported to the police and/or the Serious Fraud Office.

The Committee is responsible for investigating allegations of fraud and attempted fraud. Terms of Reference can be found in the Governance Framework.

All individuals have a duty to prevent fraud and to report any attempted or suspected fraud. Further details on how we prevent, detect and report on fraud are set out in the Anti-Fraud, Bribery and Corruption Policy available on the intranet or from the Company Secretary.

Misuse of assets

You must ensure that you do not use company assets for personal purposes or gain. This includes funds, resources, equipment (including computers, phones and vehicles) and supplies (including stationery and other items).

Our approach:

Everyone has a duty to report:

• Any breaches of the Code of Conduct

• Any actions which might call into question our integrity

• Any potential fraud or misuse of company assets

• Serious shortcomings in service delivery which have the potential to cause harm or detriment

• Abuse or neglect of vulnerable people

• Bullying, discrimination, harassment or victimisation in the working environment

• Any other impropriety.

Who to report to?

Colleagues can report wrongdoing to your line manager, Director or senior management team as appropriate. Depending on the concern raised, we will determine how best to investigate this in line with the most appropriate policy or procedure. Board and committee

Whistleblowing

Certain types of serious wrongdoing can be reported under the Whistleblowing Policy and Procedure. Please read the policy on the intranet to find out more.

RESPECT

Our approach:

We want to be a great place to work in every way and this includes making sure everyone is treated with dignity and respect.

Conduct in the workplace

We do not tolerate any form of discrimination, including bullying, harassment or victimisation. We always expect individuals to treat each other with respect and courtesy and to conduct themselves in a professional manner.

If you believe you are experiencing bullying, harassment or victimisation please speak to your line manager of a member of the HR team. Board and committee members and involved residents should contact the Company Secretary if they require guidance or support.

• Introduction

1.1. We are committed to earning and keeping our participants’ trust and experience that people love. We understand that sometimes things may go wrong. Feedback is really

important to us. We use feedback to work together and rebuild the relationship and trust by

putting things right for our participants. We always aim to resolve a participants complaint to a satisfactory level, we are kind, honest and transparent and learn from the complaints we

receive to constantly improve our services.

1.2. This policy sets out our approach on how we deal with complaints from our participants,

anyone who is affected by our services made by representatives, such as MPs, Local Councillors or other advocates acting on their behalf.

1.3. The policy supports our commitment to providing excellent customer experience. It should be read in conjunction with our Equality, Diversity and Inclusion Policy available.

• Scope

• • This policy applies to Sporting Aid and all subsidiaries (the Group).

• • The policy applies to all our customers who use our services, and it applies to all Sporting Aid colleagues and contractors acting on our behalf. 

• • Reports of Anti-Social Behaviour, Insurance Claims, defects in a warranty period or where legal action has been instigated will be dealt with by the relevant teams outside of this policy. Customers may make a complaint in line with this policy about the way the way these things have been handled

• Definition of a complaint

3.1. We follow a complaint as ‘an expression of dissatisfaction, however made, about the standard of service, actions or lack of action by the organisation, its own staff, or those acting on its behalf, affecting an individual resident or group of residents.’

3.2. We want to make it clear that customers do not need to use the word complaint for us to treat it as such.

3.3. Sometimes, we receive service requests from our customers which may be an issue that has not been raised to us previously. When this happens, we want to resolve the request within 48 hours. We will contact the customer and advise on which service area or team will be resolving their request and when they can expect resolution.

• Our approach to resolving complaints

 

4.1. Complaints have to be raised by the customer within six months of a problem arising.

However, we will consider complaints outside of the six months in exceptional

circumstances.

4.2. We welcome complaints as this is the best way to understand where we can improve our services. We’ve made it easy for our customers to contact us regarding a complaint by

opening all channels such as by phone, email, social media, face to face, letter or through

our website. All complaints including social media are dealt with by a dedicated team and

will be handled in line with our Data Protection Policy and Customer Privacy Statement.

4.3. The role of the Head of operation when customers feel the outcome is unfair. Customers can contact the Chief Exec at any given point throughout the life of a complaint.

4.4. Resolving complaints is really important to us, which is why we have a dedicated team. We prefer talking through a complaint over the phone to create a human connection. We will

contact the customer within two working days to:

• Acknowledge the complaint

• Identify the reason/reasons for the complaint in detail

• Identify the series of events that led to the complaint (including dates and details of

previous correspondence where available)

• Understand customer’s expectations regarding what a resolution would be

• Investigate the complaint promptly and fairly, resolving problems at the earliest

opportunity

• Highlight what steps need to be taken to resolve complaint

• Apologise when we get things wrong

• Confirm with the customer agreed method of contact e.g. phone, email, letter and social

media

• Learn from customers’ feedback to improve our services.

 

4.5. We always aim to resolve to all complaints within 10 working days.

4.6. We are always kind and transparent with our customers. If we find through the investigation that we have kept to our responsibilities or commitments we explain this to the customer and take the opportunity to learn from the complaint.

• The Complaints Process

• • Stage 1 – Complaint Review

5.1.1. We always ensure the customer has a single point of contact who is empowered to

act to resolve complaints efficiently and fairly. If for any reason we cannot resolve the

complaint immediately, we provide an explanation as to why and confirm timescales

with the customer of when they can expect to receive a response.

5.1.2. We aim to resolve all complaints at Stage 1. We also know that this can’t be always

the case. If the customer remains dissatisfied with our response and wishes to

escalate their complaint, they need to inform us of any issues that have not been

resolved. We will review these reasons and decide whether an escalation is required.

• • Stage 2 – Appeal

5.2.1. We review all appeal requests looking at it from the customer’s point of view to

determine whether further action is required. New emerging issues or concerns raised

at this stage may be raised as a new complaint.

5.2.2. There may be occasions where we will not escalate the complaint to Stage 2 for

reasons such as:

• It involves a claim for payments that is contrary to our compensation policy

• Previous resolution offered is in line with policy and procedures

• The customer has started legal proceedings to address the issues raised

• The customer’s intended outcome is beyond the duty or remit of Sporting Aid.

If this is the case, we notify customers of our decision to not escalate the complaint

within five working days and signpost to the appropriate organisation to manage.

5.2.3. An independent review of the complaint and previous decisions made will be carried

out by a Manager or Senior Manager who has not previously been involved in the

complaint or directly responsible for the service provided, so that the Manager can

provide an impartial review of the complaint.

5.2.4. Once the review is complete, the Manager will call or write to the customer explaining

the decision made. The customer is informed of our decision within 10 working days

of the appeal date. The outcome will always be confirmed in writing.

5.2.5. When the reviewing Manager has found that the appeal decision is fair and effective

steps have been taken, they will explain to the customer the outcome and that they

have reached the end of our complaints process.

• • Making a complaint to Head of Operation

5.3.1. If a customer remains dissatisfied with our final decision, they can refer their

complaint to a designated person or wait for eight weeks before referring it to the

Head of Operation. A designated person is a Member of Parliament, Local

Councillor, or alternatively a panel member recognised by us for the purpose of

reviewing complaints. 

5.3.2. The Head of Operation will only review complaints and contact the right people for advice and support the customer and outcomes.

5.3.3. If the complaint is about debt advice provided by us, or our administration of an equity

loan, which started prior to April 2014, and the customer remains dissatisfied with our

response, a referral can be made to the Exec Team. The complaint needs to be made within six months of our final decision.

5.3.4. If the customer is buying, they can refer the complaint to the Head of Operation.

• Unreasonable complaints

6.1. We understand that sometimes customers may get upset, frustrated or disappointed by our actions and or how we have dealt with their issues. In situations where a customer becomes unreasonable in their demands or behaviour, we may consider the complaint to be

unreasonable. This means that we may not be able to investigate the complaint.

6.2. The following actions are considered to be unreasonable, where the customer:

• Continues to pursue a complaint when this policy has been fully and properly completed

• Makes repeated unsubstantiated complaints

• Is unwilling to accept documented evidence eg computer records as factual or does not

accept that facts can be difficult to verify when a long period of time has elapsed

• Has been physically or verbally abusive or aggressive to a colleague investigating their

complaint

• Has made an excessive number of contacts in relation to a complaint, placing

unreasonable demands on colleagues. Discretion will be used in determining what

constitutes an excessive number of contacts

• Adopting a ‘capture-all’ approach by contacting many of our colleagues via their

personal social media accounts rather than using our corporate accounts to raise

complaints.

6.3. Where we consider the complaint to be unreasonable, we will advise the customer of the relevant organisation, Head of Operation or advisory service they can speak to.

6.4. We consider unreasonable behaviour as excessive contact before we have had a chance to make a response to the complaint, within the specified timescales, or using threatening or abusive language towards or about any of our colleagues. We aim to work with the customer or find alternative means of communication, eg through an agreed communication plan, mediation or engage a third party, such as an advocate, to act on their behalf. We reserve the right to restrict direct communication with the customer while we continue our investigation through to giving the final decision. We will also reserve the right to restrict direct communication with customers if it is relating to the same issue covered in the final decision.

6.5. Any decision taken not to escalate the complaint will be decided by the Head of operations.

Where the complaint is related to concerns about the safety of a property the Head of Health, Safety and Sustainability will be consulted. Any decisions will be discussed with the customer first where possible and confirmed in writing.

• Legislation and Regulation

• • The key pieces of legislation are:

• The Localism Act 2011

• Equality Act 2010

• Data Protection Act 2018

7.2. This policy complies with the requirements set out in other policies.

• • This policy meets the guidance set out in our code of conduct, staffing behaviour, recruitment policy and ASB policy.

• Responsibilities

8.1. All directors are responsible for monitoring compliance with this policy within their

Directorate, making sure complaints are well managed and lessons learnt are being used to

improve their services.

8.2. The Director of Customer Experience has overall accountability for this policy

• Introduction

• • This policy sets out how we collect and use of Personal Data. It covers our obligations under data protection law, which includes the Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679 (GDPR).

• • The purpose of this policy is to support all employees to act in accordance with the law and in line with best practice.

• • This policy should be read in conjunction with our policies for information security and the Data Protection Procedure.

• Scope

• • This policy applies to Sporting Aid and all its subsidiaries, It applies to board and committee members, employees and third parties including contractors. Non-compliance with data protection law can lead to us incurring a penalty fine, legal action against us and damage to our reputation.

• • This policy covers all Personal Data we hold, including any Special Categories of Personal Data.

• • Personal Data, however it is collected, recorded and used, must be handled and dealt with in a proper and appropriate manner, in order to safeguard the rights of individuals.

• Definitions

• • The key definitions that apply in this policy are as follows:

Data

Controller

The person or organisation that determines when, why and how to

Process Personal Data. It is responsible for establishing practices

and policies in line with data protection law.

The following entities are registered as Data Controllers:

• Sporting Aid

Data Subject

A living, identified or identifiable individual about whom we hold

Personal Data.

ICO

Information Commissioner’s Office – the United Kingdom’s independent

authority and regulator set up to uphold information rights in the public

interest, promoting data privacy for individuals.

Personal Data

Information from which a Data Subject can be identified (directly or

indirectly) from that data alone or in combination with other identifiers

we possess or can reasonably access. This includes Special

Categories of Personal Data.

Personal data can be factual (for example, a name, identification

number, email address, location, date of birth, photograph or CCTV

image) or an opinion about that person’s actions or behaviour.

Examples of the ways in which we collect Personal Data include:

• standard forms (for example, participants application form, volunteer forms, DBS form, Next of Kin details form, job application form)

• surveys

• telephone conversations

• emails

Personal Data Breach

A breach of security leading to the accidental or unlawful destruction,

loss, alteration, unauthorised disclosure of, or access to, Personal

Data transmitted, stored or otherwise Processed.

Processing (including Process and Processed)

Any activity that involves the use of Personal Data. It includes

obtaining, recording or holding the data, or carrying out any

operation or set of operations on the data including organising,

amending, retrieving, using, disclosing, erasing or destroying it.

Processing also includes transmitting or transferring Personal Data

to third parties.

Special Categories of Personal Data

Information revealing racial or ethnic origin, political opinions,

religious or similar beliefs, trade union membership, physical or

mental health conditions, sex life, sexual orientation, biometric or

genetic data, and Personal Data relating to criminal offences and

convictions.

Additional safeguards must be in place when processing Special Categories of Personal Data.

Fairly, lawfully and transparently

This means we must:

• have specific lawful grounds for collecting and using the Personal Data

• not use the Personal Data in ways that have unjustified adverse effects on the

individuals concerned

• be transparent about how we intend to use the Personal Data, and give individuals

appropriate privacy notices when collecting their Personal Data

• handle people’s Personal Data only in ways they would reasonably expect

• not do anything unlawful with the Personal Data.

For specific and defined purposes

This means we must:

• be clear from the outset about why we are collecting Personal Data and what we intend

to do with it

• comply with the fair processing requirements set out in data protection law – including

the duty to give privacy notices to individuals when collecting their Personal Data

• ensure that if we wish to use or disclose the Personal Data for any purpose that is

additional to or different from the originally specified purpose, the new use or disclosure

is compatible with that original purpose and is notified to the Data Subject in advance.

That is adequate, relevant and not excessive

• This means we must only collect and use the minimum amount of Personal Data that is

necessary for the purposes we are using it and do not hold more information than we

need for that purpose.

That is accurate and up to date

• This means we review the Personal Data we hold on a regular basis to ensure it is

accurate and up to date. Where information is found to be inaccurate we must update it

in a timely manner

Only while we need it

• This means we dispose of Personal Data once there is no longer a need to hold it, in

line with our data retention schedule. We must review our retention periods regularly

and consider the purpose(s) we hold the information for in deciding whether (and how

long) to retain it. We must securely delete or destroy information that is no longer

needed for the purpose it was collected.

Securely and confidentially

• This means we take appropriate measures to prevent deliberate or accidental loss,

destruction or damage to Personal Data. We protect the information we hold in

accordance with our Information Security Policy.

• Data Subject’s Rights

• • Data Subjects have a number of rights in relation to the information that we hold about them.

These are:

• Right of access: Anybody has the right to make a written request for details of Personal

Data about them held by us, and in most cases, a copy of that Personal Data.

• Right to rectification: Individuals have a right to have inaccurate information about them

rectified.

• Right to erasure (‘right to be forgotten’): Individuals have a right to have Personal Data

about them erased by us in certain circumstances specified by data protection law.

• Right to restriction of processing: Individuals have the right in certain circumstances to

require us to restrict its use of their Personal Data.

• Right to object: Individuals have the right to object to processing of Personal Data in

certain circumstances.

• Right to data portability: Individuals have a right, in certain circumstances, to have their

Personal Data transferred in machine readable format for use by another Data

Controller.

• Right not to be subject to automated decision making: In certain circumstances,

individuals have the right not to have important decisions about them made solely by

way of automated processing.

4.2 It is important to note that these rights are not absolute and there are various exemptions

contained within the Data Protection Laws.

4.3 Further information about each of these rights and further information around handling

subject access requests are contained in the Data Protection Procedures.

• Responsibilities

• • This policy applies to all board and committee members, employees and third parties working on our behalf.

• • Everyone is responsible for reading and following this policy and its associated procedure when dealing with Personal Data.

• •  

The Executive Committee

has overall oversight and accountability for ensuring that

appropriate policies, procedures and resources are available to

ensure we comply with data protection law.

Directors

are accountable for compliance with this policy throughout their

respective directorates.

Data Protection Champions / GDPR Champions

are selected from all parts of the Group and are responsible for data

protection within their business area, including for promoting key

data protection principles, ensuring employees comply with the

policy and associated procedure and supporting with data protection

queries.

The Data Protection Officer (DPO)

is the nominated individual for each legal entity who is responsible

for:

• co-ordinating our approach to data protection, advising onany

data protection impact assessments which need to becarried

out, and for monitoring and reporting levels of compliance to

the Audit and Risk Committee, the Group Board and any

relevant subsidiary board;

• the content of training and raising awareness of issues

linked to data protection;

• investigating Personal Data Breaches or suspected breaches

and taking any required action including, where itis a reportable

breach, reporting to the ICO;

• responding to requests from Data Subjects; and

• maintaining appropriate records of any data breaches and

enforcement action

.

For Sporting Aid and all other entities in the Group, the DPO is the

Company Secretary.

Line managers:

are responsible for communicating the importance of this policy to

employees in their teams and ensuring its principles are understood.

All employees:

are responsible for following this policy, including attending training

sessions. Everyone managing and handling Personal Data is

responsible for following good data protection practices and any

breaches of data protection laws may result in disciplinary action.

All contractors and persons working on our behalf:

are responsible for:

• ensuring that they and anyone working for them who has

access to Personal Data held or Processed on behalf of us, are

aware of and fully trained in their data protection responsibilities

• following the requirements of this Data Protection policy and

associated procedure and data protection law in respect of any

Personal Data supplied by us or Processed on behalf of us.

Equality, Diversity and Inclusion

6.1 We are committed to respecting equality and diversity in all aspects of our work and will not tolerate any form of discrimination either direct or indirect. This policy will ensure that all

employees, tenants and customers are treated fairly in relation to their personal data.

• Legislation and Regulation

• • Legislation applicable to this policy includes:

• General Data Protection Regulation ((EU) 2016/679)

• Data Protection Act 2018

• Privacy and Electronic Communications Regulations 2003

• Regulation of Investigatory Powers Act 2000

• Telecommunications (Lawful Business Practice) (Interception of Communications)

Regulation 2000

• Telecommunications (Data Protection and Privacy) Regulations 1999;

7.2 The Freedom of Information Act 2000 (FOIA) gives individuals the right to access public

records held by public authorities. Currently, we are not deemed to be a public authority, as

defined in the FOIA, and accordingly are not governed by its provisions.

Introduction

• • At Sporting Aid, we aim to be a great place to work by making sure we demonstrate our values in everything we do. This includes meeting expectations regarding conduct and performance, not through a lack of capability.

• • On the rare occasions that your behaviour causes concern, you have deliberately failed to perform to an acceptable level or have been negligent in an area of your work, this policy and procedure makes sure a fair and consistent approach is taken to address the issues.

Scope

2.1 This policy applies to all colleagues of Sporting Aid, and its subsidiaries, except for. It does not apply to Board or committee members, third parties who work on our behalf or anyone who is still in their probationary period.

2.2 This policy does not apply to:

• Performance or misconduct concerns within the probationary period.

• Performance concerns where there is a genuine lack of capability, to meet the required

standards of performance.

• Short term sickness or rare occasions of more serious health issues.

Our approach

3.1 If an allegation of misconduct, negligence or deliberate failure to perform to an acceptable level occurs, we will deal with these allegations quickly and fairly.

3.2 If you’re off work due to sickness or are unable to attend meetings for any other reason, we may go ahead with an investigation and/or disciplinary action in your absence.

3.3 If you raise a complaint under the Grievance Policy and Procedure, the disciplinary process will continue unless a clear link between the allegations and your complaint can be

established.

 

Informal

3.4 Where appropriate, your manager will try to resolve concerns informally.

3.5 Your manager will meet with you to discuss the concerns and set clear expectations for

future conduct in the workplace – in line with our values and professional standards. A written

record of the conversation will be shared with you.

3.6 In many cases this will address the issues raised, and you and your manager can agree a way of working moving forwards.

Investigation

3.7 Where appropriate, all necessary investigations will be carried out as quickly as possible.

The purpose of an investigation is to gather the facts and any documents relating to the

allegations. If required, this may involve interviewing you and/or other people involved or any

witnesses to the allegations.

3.8 There is no right to be accompanied during an investigation.

3.9 Wherever possible the investigator should not be involved in the issue being investigated.

Suspension

3.10 In some cases, you may be suspended on full pay while an investigation is carried out and/or until the disciplinary process has been concluded. Suspension is usually considered in cases where there is a serious allegation of misconduct, when there could be a risk to the business, other colleagues, customers or the investigation itself.

3.11 It’s important to note that suspension is not a disciplinary sanction. Periods of suspension will be reviewed regularly and kept as short as possible.

3.12 A decision to suspend can be made by an appropriate manager with support from the People team. The suspending manager will give the reason and terms of suspension, which will also be confirmed in writing.

3.13 For the duration of the suspension your access to all our IT systems will be suspended and you will be asked to return property belonging to us. This includes any IT equipment and your access pass to any of our offices.

3.14 Suspension should be for the shortest practicable time in order for the investigation to be completed. This will normally be for no longer than 10 working days.

Formal Disciplinary

3.15 Disciplinary action won’t be taken until a formal disciplinary hearing has taken place.

3.16 If you’re asked to attend a formal disciplinary hearing, you’ll be given at least 5 working days’ notice in writing of the hearing. We’ll share the allegation(s) with you in advance including any relevant documents that will be referred to in the hearing.

3.17 You may wish to bring a colleague or trade union representative to the hearing. You will need to inform us in advance of the meeting if you wish to be accompanied and who this will be.

3.18 The hearing will be chaired by an independent and appropriate level manager and there will also be support from a representative from the People Team / a note-taker. You’ll be given a chance to respond to the allegation(s) before any decision / outcome is made. If necessary we may look to appoint a second panel member based on the complexity and seriousness of the case.

3.19 A note-taker for all formal hearings is provided, therefore you will not be allowed to use any electronic devices to record meetings.

3.20 If you’d like any other evidence to be considered by the hearing Chair, you should provide this to the People team as soon as you can prior to the hearing.

3.21 Following the meeting, the Chair will consider the information presented, and may decide to impose a sanction (see section 4.1). You will receive a letter confirming the outcome with the right to appeal.

Appeal

3.22 To ensure impartiality, managers selected to hear an appeal will have no prior involvement in the case.

3.23 If you are issued a formal warning following the hearing, you will be given the right to appeal. If you wish to appeal, you must do so in writing within 5 working days of receiving the outcome. The person to whom you submit your appeal to will be specified in your outcome letter; this will usually be to the next level of management or a member of the People team.

3.24 The appeals procedure is not (expect in special circumstances) to re-hear a disciplinary

case. Grounds for appeal can be one or all of the following:

• based on the decision that was reached

• the process that was followed

• the availability of new evidence

3.25 You can set out your grounds for appeal in the Disciplinary Form 1 – Appeal making sure you attach any other relevant supporting documents.

3.26 The appeal Chair will either uphold or reject the original decision. They can choose to lower the level of sanction originally issued but they can’t increase it. The appeal decision is final and there is no further right of appeal.

What are the possible outcomes?

4.1 Possible disciplinary sanctions

(see Appendix 1 for examples of misconduct and gross misconduct)

No sanction –  If there is no case to answer or insufficient evidence

for the allegation

First written warning – Issued for first instances of misconduct. Kept on your

employee record for a period of 6 months

Final written warning – Issued for more serious cases of misconduct, or if there is a further misconduct whilst a previous warning is still live. Kept on your employee record for

12 months

Dismissal  – In cases of gross misconduct or if there is further misconduct whilst a previous final written warning is still live, you may be dismissed. If a decision is made that your actions amount to gross misconduct this would lead to instant dismissal without notice

Other sanctions

4.2 In some exceptional cases, we may at our discretion offer an alternative to dismissal. Any such offer will be accompanied by a final written warning. If you are offered an alternative to dismissal and you refuse it, dismissal will be the only alternative which you would have the right to appeal. If you accept an alternative to dismissal, this will be confirmed by letter. In these cases there would be no right to appeal a sanction short of dismissal as you would have already consented to the decision.

Criminal offences

4.3 If your conduct is the subject of a criminal investigation, charge or conviction, we’ll

investigate the facts before deciding whether to take formal disciplinary action. We won’t

usually wait for the outcome of any prosecution before deciding what action, if any, to take. If

you are unable or have been advised not to attend a disciplinary hearing or say anything

about a pending criminal matter, we may have to take a decision based on the evidence

available. An investigation may recommence if you are charged.

Equality, Diversity and Inclusion

5.1 We are committed to applying a fair and consistent approach to dealing with any concerns at work. We are open to accommodating any special requirements and reasonable adjustments to make sure colleagues understand standards expected from them. We will make reasonable adjustments on a case-by-case basis.

6 Legislation and regulation

6.1 This policy is reflective of the principles outlined in the Code of Practice and statutory legislation relating to employment rights/relations, equality and data protection.

7. Responsibilities

7.1 Managers are responsible for:

• Proactively addressing any minor concerns informally or in regular meetings before they

escalate. A written note should be kept in these cases

• Applying this policy (if required) as soon as reasonably practical

• Demonstrating our values in consistently applying this policy

• Investigating allegations and managing disciplinary hearings and appeals, taking

ownership of the decisions made

7.2 The People team are responsible for enabling managers to consistently and fairly apply the policy and procedure, providing support and advice throughout from informal to formal

stages.

7.3 Colleagues are responsible for cooperating with us throughout the process by attending

meetings, providing statements, acting as a witness and/or attending hearings.

Appendix 1 – Examples of misconduct

These lists are not exhaustive.

Misconduct

This is a breach that may lead to disciplinary action being taken but is not serious enough to justify dismissal at the first stage.

Examples:

• An action that amounts to a breach of your employment contract

• An action that amounts to a breach of our Code of Conduct

• An action that amounts to a breach of our values

• An action that amounts to a breach of any of our policies and procedures

• Unauthorised absences from work

• Poor timekeeping, eg repeated absence, lateness, excessive lunch breaks, leaving early or

  excessive use of the internet

• Failure to meet reasonable standards of behaviour and performance, not through a genuine lack of capability

• Repeated acts of minor offences

• Excessive and/or improper personal use of office telephone/company mobile phone

• Excessive and/or improper personal use of internet (including social network sites) during

  working hours and/or excessive data use at our expense

• Excessive use of personal mobile phone during working hours

• Misuse of email

• Minor damage to company property through carelessness/negligence

• Failure to carry out any reasonable instructions given by a supervisor or manager, such as    to attend training

• Smoking and/or using e-cigarettes/vaping anywhere other than in designated smoking areas

• Standards of behaviour that have failed to improve with support or within a set time frame

Gross Misconduct

This is a serious breach that is so severe that it may justify dismissal for the first offence, without notice or notice payment.

Examples:

• An action that amounts to a serious breach of your employment contract

• An action that amounts to a serious breach of our Code of Conduct

• An action that amounts to a serious breach of our values

• An action that amounts to a serious breach of any of our policies and procedures

• Physical assault, verbal abuse, bullying, or threatening behaviour

• Unlawful discrimination or harassment

• Any serious misconduct or deliberate and/or negligent act which is or can be to the detriment

of the business or our reputation

• Any serious misconduct or deliberate and/or negligent act which causes or can cause

unacceptable loss, damage or injury

• Actual or attempted theft or fraud

• Unauthorised use of our equipment or facilities for private purposes

• Actual or attempted theft, fraud or deliberate falsification of any documents to gain monetary or other advantages. Please refer to the Anti-Fraud, Bribery and Corruption Policy.

• Undertaking unauthorised private work (paid or unpaid) during working hours when contracted

to work for us

• Malicious damage to any property belonging to us, colleagues or members of the public

• Serious breach of Health and Safety rules and/or legislation

• Serious breach of our financial rules and procedures

• Serious insubordination

• Possession or use of controlled substances whilst on duty or when representing us

• Incapacity through alcohol or any controlled substance whilst on duty or when representing us

• Actions which constitute a criminal offence (see ‘Criminal Offences’)

• Failure to disclose criminal convictions and related court actions incurred whilst employed by us

Appendix 2 – Procedure Summary

Stage 1 – informal stage

• Your manager will meet with you to discuss the concerns and outline expectations

• A record of the conversation will be documented

Stage 2 – investigation

• Where the Informal Stage has not led to the required improvement, or where the allegation

is serious enough to warrant an investigation in the first instance

• All facts relating to the allegation(s) will be gathered as soon as possible and without delay

• In some circumstances the colleague may not need to be interviewed before going to a

disciplinary hearing; in other cases an investigation meeting may be held in order to decide

if a formal disciplinary hearing should be convened

• Witnesses may also need to be interviewed and/or statements gathered

• All relevant documents will be reviewed e.g. emails, meeting notes, systems, dialogues,

CCTV

Decision to be confirmed in writing

• If there is no case to answer, no further action or recommendations/expectations set; all

references to the investigation removed from file

• If there is a case to answer, recommendation to refer to a disciplinary hearing

Stage 3 – disciplinary hearing

• An invite to the disciplinary hearing will be sent to you giving at least 5 days’ notice and

will include all documentation to be referred to

• If you wish, you can bring a Catalyst colleague or a trade union official

Decision to be confirmed in writing

• If the hearing chair concludes there is insufficient evidence of the allegations, no further

action or recommendations/expectations set. All references to the investigation removed

from file

• If hearing chair decides there is sufficient evidence of the allegations, sanction issued in

line with section 4.1

Stage 4 – appeal

• An invite to the appeal hearing will be sent to you giving at least 5 days’ notice

• If you wish, you can bring a colleague or a trade union official.

Decision to be confirmed in writing

• Appeal Chair overturns previous decision and concludes there is insufficient evidence of

the allegations, no further action or recommendations/expectations set; all references to

the investigation removed from file

• Appeal Chair overturns previous decision and issues reduced sanction in line with

section 4.1

• Appeal Chair upholds previous decision

• No further right to appeal

Appendix 3 – Example format of Disciplinary hearing

Action

Chair’s welcome and meeting purpose – Explain purpose is to hear allegations raised under the Catalyst disciplinary policy & procedure against the employee

Who – Chair

Chair introduces all present and confirms their roles during the hearing

Chair – to direct proceedings, to hear evidence and make decisions

– People team representative – to provide support and guidance.

– Note taker – to make summary notes.

– Colleague companion (if applicable) – to provide support to the employee. Can ask questions but cannot answer them on the employee’s behalf

Who – Chair

Chair outlines the process, including:

– Process will be managed by the Chair

– Adjournments can be requested by any of the parties present

– Following the Hearing, the outcome will be sent to the employee in writing

Who – Chair

Chair confirms the issues to be considered during the hearing

Read out the allegations to be considered and confirm whether the allegations

are being considered as misconduct or gross misconduct, as set out in the

disciplinary hearing invite letter.

Who – Chair

Chair considers the evidence available and asks questions to ensure

understanding of the facts

who – Chair

7. Colleague response

This includes any further evidence and/or mitigating circumstances they wish

to make known to the Chair

who – Colleague

Chair asks any further questions

This ensures that the colleague has all of the facts and information they need

to make a decision.

Who – Chair

Chair invites any further comments from any party

Who – All

Chair adjourns hearing for deliberation

If employee is currently suspended, confirm the suspension will remain in place until the employee is notified of the outcome

Who – Chair

Appendix 4 – Individual companion support guidance

This document sets out Sporting Aid support and arrangements for employee companions who have been asked by a colleague to support them in accordance with relevant Sporting Aid policies, including Grievance, Disciplinary, Capability, Sickness Absence, and Redundancy and Redeployment policies and procedures.

• Role of the companion

• You have the right to be accompanied at all formal hearings/meetings where you may be

issued a formal sanction as a result.

• Your companion may be a Sporting Aid colleague or a trade union representative. You may

not be accompanied by a friend, family member, or legal representative.

• The role of the companion is to provide support and guidance to you during the process.

They may help you prepare prior to the meeting, attend the meeting with you, put any

relevant questions to the Chair and hold discussions with you during the meeting.

However, they are not able to respond to any questions on your behalf.

• If you intend to be accompanied, you must confirm to the People Team by email who

your companion will be no later than 2 working days before the meeting date.

• If you are unable to attend a meeting, you must notify the People Team by email no later

than 2 working days before the meeting date, and you must provide a reasonable and

acceptable reason for being unable to attend. If you are unable to attend a formal

meeting, you may choose to send representation with your companion.

• Although there is no statutory right for a colleague to be accompanied at an investigatory

meeting, Sporting Aid will allow a companion to be present if, by doing so, there is no delay

in holding the investigatory meeting.

• Your companion should make every effort to attend the meeting so as not to

unreasonably delay the process.

• Communication

• Employment processes and procedures are a matter between you and Sporting Aid

therefore, all dialogue and communication is best managed between us directly. We will

copy an identified work colleague/trade union companion in responses and include them

in any appropriate individual consultation meetings where you advise us that this is your

wish, but this will always be in addition to the communication with you and not as an

alternative to it. It is obviously important that you are fully involved in all communications

that relate to you personally.

• In line with this principle, Sporting Aid will only be able to respond to communications from

companions where you are copied in and it is absolutely clear that your companion is

acting with your express authority. In these situations, the response will be addressed to

you and your companion will be copied.

• Where communications are received from companions on behalf of unidentified

individuals, Sporting Aid will not be able to respond as this would clearly be inappropriate.

• Outside of any formal meetings, if your companion has any queries relating to the case

or other matters, these should be directed to the People Team only.

• Conduct at meetings

• All those present must behave in a professional, respectful and courteous manner

throughout; this behaviour must be extended to both the process and the people

involved.

• The Chair may adjourn the meeting in the event of unreasonable behaviour by anyone

present.

• Time off to provide support

• On request, work companions will be allowed reasonable paid time to accompany a

colleague at formal meetings and prepare for those meetings. What is reasonable

depends on the case, but would normally be no longer than an hour of preparation time

and the length of the meeting itself.

• Head of Operation approval must be requested for time off to support a colleague.

Companions must give no less than 2 days’ advance written notification of this time off.

The following information should be provided:

– Date/times/location/expected duration of absence.

– Brief description of activity and purpose i.e. that you are a companion at a

disciplinary, grievance or capability hearing.

• It is for the companion’s Head of Operation to determine whether they can be released to

support a work colleague. Heads of Operation are expected to grant all reasonable

requests for time off by companions. Where a Head of Operation has any doubts about

approving a companion’s request for time off, they should seek advice from the People

Team.

• If an individual believes that the support arrangements have been unreasonably

refused, they should raise this immediately with the Executive Director.

1. Introduction 1.1 Sporting aid has an absolute commitment to champion and celebrate equality, diversity, and inclusion. We are proud of the diversity of the communities we serve and the people we employ. We strongly believe in the power of diversity of thought and achieve this through hearing the voices of all our customers and colleagues.

1.2 Equality, diversity, and inclusion (EDI) is crucial to our vision to earn and keep your trust. For our customers, colleagues, and partners to trust us, they must feel they are treated fairly and with respect.

2. Scope 2.1 This policy covers all colleagues and customers of Sporting Aid and all subsidiaries.

2.2 Contractors and third parties working on our behalf are expected to work to the principles set out in this policy.

3. Definitions 3.1 Equality – is treating people in a way that means they are not at a disadvantage compared to others no matter what their differences are. Treating people equally does not mean treating them the same e.g. providing a ramp to an entrance provides equal access for wheelchair users.

3.2 Diversity – is about recognising and valuing differences such as race, religion, age, gender, ability, education, sexual orientation, background, and skills.

3.3 Inclusion – is about embracing all people regardless of things such as their protected characteristics, personal circumstances, background, or individual needs and removing any barriers that may prevent them from being included or fully engaged.

3.4 Protected Characteristics – under the Equality Act 2010, it is against the law to discriminate against someone because of certain protected characteristics. These are age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation. This policy covers all the protected characteristics but included below are more detailed definitions of some of the characteristics that are directly referred to in this policy.

3.4.1. Disability – under the Equality Act, a person has a disability if they have a physical or mental impairment which has a substantial and long-term adverse effect on their ability to carry out normal day-to-day activities. This also covers developmental impairments or

disabilities such as Autism Spectrum Disorder.

3.4.2. Race – refers to a group of people defined by their race, colour, and nationality (including citizenship), ethnic or national origins.

4. Our approach 4.1 Our approach is to listen to and appreciate each person as an individual with unique needs and aspirations, and not to limit our considerations to the protected characteristics.

4.2 We are committed to being an anti-racist organisation. We don’t tolerate discrimination or harassment and we tackle prejudice and promote understanding between people from different groups.

4.3 Any decisions that are made will be based on the facts and objective grounds and will be taken in a way that avoids direct or indirect discrimination. We make sure individual needs are considered when we are delivering a service or working with a colleague or customer.

4.4 We make sure that our offices are accessible for both colleagues and visitors.

4.5 We monitor our performance around EDI to help us improve the experience of customers and colleagues, and the services and support we offer.

5. Colleagues 5.1 We’re committed to having recruitment processes which are fair and unbiased. More information can be found in our Recruitment Policy and Procedure.

5.2 We comply with gender pay gap reporting requirements, publishing our gender pay gap annually, and have begun ethnicity pay gap reporting.

5.3 Having an awareness of equality, diversity and inclusion issues is essential for all colleagues, and we provide this through diversity and inclusion training. Board and Committee members also receive specific training on their roles and responsibilities in relation to fairness and equality.

5.4 All colleagues have fair access to learning and development opportunities, regardless of their background, experience, or protected characteristics.

5.5 We have a commitment, and stretching targets, to increase the diversity of our board membership and leadership team.

5.6 We run internal and external programmes to support and develop diversity at leadership levels, using our Talent and Succession Framework to identify the rising stars from under-represented groups. These colleagues will have clear and tailored development plans to accelerate their careers and remove any barriers to progression.

5.7 We provide support for colleagues with specific requirements including mental health issues, disability and learning differences, by making Mental Health First Aiders available, signposting to our Employee Assistance Programme, and making reasonable adjustments where required.

5.8 We celebrate our diverse and inclusive organisation by acknowledging key dates from religious and cultural celebrations, and across protected characteristics. We work to keep colleagues informed on diversity and inclusion issues by engaging in relevant activities and campaigns throughout the year.

5.9 We have a range of People policies which support colleagues and give them the flexibility to work in a way which best suits their needs, including Blended Working, Flexible Working and Family Friendly.

5.10 We carry out regular colleague engagement surveys and identify and tackle any differences in perception by protected characteristic or other group.

5.11 If a colleague feels that they may have been discriminated against, they can speak to their manager or use the complaint procedure.

6. Customers 6.1 We always treat customers fairly and with respect.

6.2 We make sure that colleagues receive appropriate training to help them support customers with needs.

6.3 We co-create services with customers (and colleagues) so that we understand them from their perspective and how our different customers may experience them.

6.4 We listen to customers’ needs and use their feedback to influence the services we provide. We make our customer engagement activities open to all and do all we can to remove any barriers that prevent customers participating, including offering a range of methods of involvement.

6.5 We analyse how customers are using and accessing our services, and their opinions about services, to ensure different groups are treated fairly.

6.6 We take account of customers’ needs, considering their requirements in relation to their responsibilities, to provide a flexible service. We don’t make assumptions about whether a customer requires any adjustments or what those adjustments should be. We discuss the customer’s requirements with them and agree with them the best way to meet their needs.

6.7 We make sure that any decisions about whether we make reasonable adjustments are made in line with the Equality Act 2010. Where it’s not possible to meet a customer’s preferred method of communication or interaction, for example if it would not be practical or would be too expensive, then we will work with them to find the best solution.

6.8 We deliver our services and communications in a clear and accessible way that is easy to understand and meets customers’ needs. We make sure all our customer communication is accessible with the use of alternative formats including pictorial, audio and translation services where they are needed. Our imagery reflects the diversity of the communities that we work in.

6.9 We make it clear to customers how to request information or communication in alternative formats, such as other languages or large print.

Accessibility and reasonable adjustments

6.12 If requested we communicate with customers through their chosen representative, advocate, or family member. In such cases we make sure that, where possible, we have received clear authorisation from the customer or their legal representative, eg someone with Power of Attorney, to deal with that person.

6.13 We don’t charge customers for providing communication in any alternative formats or adjusting services in line with this policy.

6.14 We record the details of any adjustments in delivering a service made for a customer on our IT systems.

6.15 We provide informal interpreting through colleagues with language skills who volunteer to help.

6.16 Where needed, translations can be provided by a customer’s advocate such as a family member or support worker with the customer’s consent, but for legal or sensitive issues we will always use a professional translation service if translation is needed.

6.17 We translate written documents on request where it is practical and cost effective. If we’re unable to provide the customer’s preferred method or format, we make sure they understand the information provided by using an alternative where needed, such as audio format.

6.18 Other examples of adjustments we might make to support a customer need if requested are:

Translations and interpreting

Other examples of adjustments

• Providing documents or correspondence in a larger font size (minimum of Arial 16)

• Providing documents on coloured paper or with a specific colour contrast which can help people with conditions such as dyslexia

 

• Providing information in an audio format – either informally or through a specialist transcription agency

• Using email or phone instead of hard copy letters where possible, which may assist those with a vision impairment.

6.19 If necessary, and if there are no legal requirements dictating a certain deadline, we will review the timescales for a process to enable the customer to fully engage. An example could be accepting a complaint outside of the usual time limit if a customer has been ill or allowing a person who has a learning disability or mental health problems more time than would usually be allowed to provide further information.

6.20 For customers who are d/Deaf or have hearing impairments we can provide on request:

• British Sign Language (BSL) interpretation (via professional interpretation services)

• Text Relay (Next Generation Text)

• Induction Loops in main offices

6.21 For Supported Sporting Aid customers we will provide easy read formats for key documents and other easy read documents may be produced and made available on request.

6.22 We treat customers fairly and with respect and we expect customers to have the same respect for our colleagues, contractors, and other customers. We will act against any customer who abuses or discriminates against a colleague, contractor or another customer in line with our Antisocial Behaviour Policy.

7. Partners and suppliers 7.1 We expect our suppliers and partners to share our commitment to equality, diversity, and inclusion. Our procurement processes will make sure that suppliers’ approaches are aligned with ours.

7.2 We make sure that tenders for contracts for services include social value as one of the criteria to be assessed.

8. Legislation and Regulation 8.1 The key piece of legislation which applies to this policy is the Equality Act 2010 including the Gender Pay Gap Information Regulations 2017.

8.2 The Board members are required to demonstrate a clear and active commitment to achieve equality of opportunity, diversity and inclusion in all the organisation’s activities.

8.3 The information and communication that are appropriate to the diverse needs of our customers, and to treat customers with fairness and respect.

8.4 We have in place a reasonable adjustments policy that covers how we may adapt normal policies, procedures, or processes to accommodate an individual’s needs. This policy meets that requirement.

9. Responsibilities 9.1 All colleagues have a responsibility to follow the principles of this policy and take personal accountability for their own approach. Additional and specific responsibilities apply to those who manage others and to those who are involved in recruitment, promotion, training, and development.

9.2 Contractors have a responsibility to ensure they follow the principles of this policy.

9.3 Everyone within the organisation has responsibilities for the customer elements of equality, diversity and inclusion.

9.4 The Head of Operation has responsibility for the colleague elements covered by this policy.

9.5 The Head of Operation has responsibility for overseeing the elements of this policy related to partners and suppliers. 

9.6 The Head of Operation has overall accountability for this policy and implementation.

Introduction

This policy sets out the guidelines and controls for employees claiming expenses.

Policy Statement

This policy applies to all permanent Sporting Aid staff and should be read along with the Employee Code of Conduct. It doesn’t apply to those who are employed on an interim or consultancy basis, as they are paid through separate contractual arrangements.

Scope

Sporting Aid will reimburse all approved expenses incurred by employees carrying out work on behalf of the organisation. This policy allows reimbursements to be controlled, as well as highlighting what evidence of expenditure and authorisation is required. 

Responsibility

It’s the primary responsibility of the claimant and their authorising manager to make sure all expenses claims comply with this policy.

The Head of Operation and Chief Exec will check each claim submitted.

Any expenses incurred outside of what is set out in this policy, will be deemed a taxable benefit. It will then appear on the employee’s monthly payslip and P11D form at the end of the tax year. 

 

If expense claims appear incorrect or incomplete, Head of Operation or Chief Exec /or the Head of Financial Services will query them. If adequate explanations are not provided or if these are not in line with this policy, the claim will be rejected and returned to the employee. A further investigation will follow and if submissions are found misleading, this could be considered as gross misconduct and result in disciplinary action. This may ultimately result in dismissal.

Supporting Evidence

All expense claims must be supported by original receipts or invoices.

So Sporting Aid can claim back VAT, each receipt or invoice should include a:

• VAT registration number
• Description of goods or services supplied
• Gross charge
• Name and address of supplier
• Date of supply

If any part of a claim is not supported by a receipt(s), the expense will not be reimbursed.

Submission and authorisation

All expenses must be claimed by completing the Expense Claim Form.

Completed expense claim forms must be approved by line managers, who must make sure:

 

• expenses incurred are wholly and exclusively for business purposes;
• claims are supported by valid and original itemised VAT receipts;
• mileage amounts claimed include dates, the business reason for travel and address visited;
• claims without valid receipts are not approved.

All business mileage claims should only relate to miles driven over and above a standard daily commute to the primary place of work. The following rates apply – Car allowance: £0.45/mile non-taxable. Mortorbike allowance: £0.24/mile. Bicycle allowance: £0.20/mile.

Authorising managers must not approve any expense where they benefitted from the activity relating to the claim. These claims must be approved by the manager’s manager.

The Head of Operation team will process expense claims through payroll. The cut off for expenses to be included on that month’s payroll run is the 5^th of each month and all expenses must be claimed within three months. It’s the responsibility of the claimant to make sure expense claim is correctly completed and submitted on time. 

 

Employees must get prior approval from their line manager for expenses over £100 per item.

Line managers shouldn’t approve expense claims where they’ve been involved in the activity relating to the claim. Where it’s unclear who has been involved, this should be stated by the claimant so it’s clear the claim was approved independently.

Guidelines

Expenses will only be reimbursed if incurred wholly and exclusively for Sporting Aid business purposes. The guidelines below allow reimbursements to be controlled and provide employees with a clear framework when submitting expense claim forms.

Employees should make every effort to reduce expenses for example through cost-cutting initiatives or booking trips in advance.

Below is a list of things employees can claim expenses for and what will be reimbursed:

• Rail travel to and from corporate conferences over and above the normal cost of commuting to an employees’ main place of work. Standard class tickets should be used for all journeys.
• Air travel. Economy class tickets should be used for all journeys.
• Overnight accommodation when travelling for company business. Where possible, employees are expected to use hotels where a group or corporate rate has been negotiated. The type and quality of accommodation should be standard and should not exceed £150 per night.
• Evening meals should be chosen from fixed price menus or the equivalent. These should not exceed £20 per meal per person unless approved by the Chief Executive Officer or Chairman.
• Business and employee entertainment where the business purpose is known and evidenced.
• Other incidental expenditure which results from the employee performing business duties. For example the cost of parking, buses, taxis, personal car mileage or business telephone calls.
• Training courses when pre-approved by the authorising manager and Learning and Development Manager.
• Membership of professional bodies.

Below is a list of expenditure that falls outside this policy:

• Alcohol unless authorised by a member of Head of Operation Team.
• Any expenditure that should be processed should be approved by the other senior manager.
• Any expenditure relating to service charges.

Where a claim is submitted and other employees have benefitted from the expenditure incurred, details of these employees (including full name and position) must be included on the expenses claim form.

Employees must get prior approval for any expenditure over £100.

• Introduction

• • At Sporting Aid, we aim to be a great place to work in every way. This includes making sure that we support you to resolve any concerns you may have as soon as they arise. Our values help us to maintain good relationships with colleagues. We believe that a fast and relevant solution helps get everyone back to doing a great job.

• • Grievances may relate to your work or role, working conditions, relationships with colleagues or other similar issues.

• • This policy and procedure does not apply to a serious act of wrongdoing including a criminal act, breach of regulations or a serious health and safety concern at work. Please refer to the Whistleblowing Policy for further guidance on these matters.

• • If your complaint refers to bullying, harassment or victimisation please refer to Appendix 1 of this policy.

• Scope

• • This policy applies to all colleagues of Sporting Aid, and its subsidiaries. It does not apply to Board or committee members or third parties who work on our behalf.

• • For complaints relating to bullying, harassment or victimisation Appendix 1 of this policy will also cover contractors, agency workers and anyone else engaged to work with Sporting Aid.

3. Our approach

3.1. On the rare occasion that a workplace concern arises, we will support the timely resolution of these by following the below procedure. Full details of each stage of the procedure can be found at Appendix 2.

3.2. We will take your concerns seriously and make sure you feel that you can raise concerns without fear of any negative consequences. Your concerns will be handled with sensitivity and in confidence, as far as is practicable, throughout.

3.3. Informal stage

3.3.1. In the first instance, you are responsible for doing whatever you can to resolve your

concerns informally, and within one month of them occurring. This may be through

discussions with your manager or another appropriate manager in your team.

3.3.2. When trying to resolve your concern, you should be clear from the start what support

is needed and what resolution you are looking for. Your manager, or the person you

report it to, will need to take a record of informal conversations and the steps agreed.

3.3.3. If your concern involves your manager, you can raise it with another manager in your

team or one of the People team.

3.4. Formal stage

3.4.1. If you are unable to resolve the concerns informally, you can put your concerns in

writing using the Grievance Resolution Form (GR1). Please include all relevant

information on the form before submitting it to your manager or appropriate alternative

manager. They will then seek advice from your HR Advisor in order to conduct a formal investigation.

3.4.2. The first step will normally be for your manager or appropriate alternative manager to

hold a resolution meeting with you, as soon as possible. We will inform the

colleague(s) who you have raised the concern about, to give them an opportunity to

respond.

3.4.3. The formal resolution meeting will address:

• the concern

• the desired resolution

• what has been done to resolve this informally

• consideration of any further action to be taken

3.4.4. If you are invited to attend a formal meeting or appeal, you may wish to bring a

colleague or trade union representative with you. The Individual Companion Support

Guidance (Appendix 3) provides further clarity on the role of the companion and what

to do if you wish to be accompanied.

3.5. Appeal

3.5.1. If, after the investigation has closed, you still don’t feel that things have been fully

resolved, you can appeal to the next level of management. You’ll need to put your

points in writing using the Grievance Resolution Form 2 – Appeal (GR2). You must do

this within five days of receiving the outcome letter.

3.5.2. You must clearly focus on the area not yet resolved and include copies of any

relevant documents. Your appeal will involve a further meeting. You will have the right

to be accompanied, and you will receive a written summary of the final outcome.

There is no further right of appeal once an appeal decision has been communicated.

• What are the possible outcomes?

• • The investigating manager will review all relevant documents with the People team and will write to you with a summary of the outcome.

• • It may be necessary to involve other people to get your concerns resolved. The manager dealing with your complaint will decide what actions to take.

4.3. If as a result of further investigations it comes to light that a breach of rules, behaviours,

and/or policies or procedures has taken place, we may take disciplinary action.

4.4. You will be kept informed if there is likely to be a delay as a result of other actions taking

place before the outcome can be decided.

Other points to note

4.5. If you raise a concern while you are subject to disciplinary or capability proceedings, these processes will continue unless a clear link between the allegation and your complaint can be established.

4.6. If you act in good faith, i.e. you genuinely believe that what you are saying is true, you will not be held accountable for making a complaint. However, if the investigation shows that your allegations were untrue and/or malicious we will take appropriate action which could include disciplinary action.

4.7. Resolving concerns involves getting the right people together to help resolve them. In some cases, we may recommend a supported mediation meeting with all colleagues concerned in the complaint, to try to resolve the concerns you have raised. This will only proceed with the agreement of all parties involved.

4.8. We recognise that this may be a difficult situation for everyone involved, so we’ll always aim for the investigation to be carried out as quickly and sensitively as possible. Some complaints may involve interviewing other colleagues and witnesses or gathering evidence from other sources. In more serious cases it may be necessary to suspend the person being

complained about or arrange for colleagues to avoid directly working together during the

investigation process. This decision will be made by the manager dealing with the complaint.

4.9. At any stage in the process you are encouraged to use the confidential Employee Assistance Programme.

• Equality and diversity

• • We are committed to applying a fair and consistent approach to dealing with any concerns at work. We are open to accommodating any special requirements and reasonable adjustments to make sure colleagues understand standards expected from them. We will make reasonable adjustments on a case-by-case basis.

• Legislation and regulation

• • The legislation and regulation relevant to this policy and procedure includes:

• Employment Rights Act 1996

• Code of Practice

• Responsibilities

• • Managers are responsible for:

• Proactively addressing any minor concerns informally or in regular meetings before they

escalate. A written note should be kept in these cases

• Applying this policy, if required, as soon as reasonably practical

• Demonstrating our values in consistently applying this policy and procedure

• Managing concerns in confidence with support from the People team

• • The People team are responsible for:

• Enabling managers to consistently and fairly apply the policy and procedure, providing

support and advice throughout from informal to formal stages

• Enabling managers and colleagues to resolve concerns quickly and fairly to minimise

escalation to formal stage.

• • Colleagues are responsible for:

• Positively raising and resolving concerns informally with support from their manager in

the first instance

• Raising concerns in a timely manner and without unreasonable delay

• Co-operating with us throughout the process by attending meetings, providing

statements, acting as a witness and taking part in mediation if required

Appendix 1 – Bullying, harassment and victimisation

In cases where complaints relate to bullying, harassment or victimisation, this policy will also cover contractors, agency workers and anyone else engaged to work with Sporting Aid. This could be in the workplace or in any work-related setting outside the workplace, e.g. business trips and work – related social events.

The definitions of each of these can be found below:

Bullying

Offensive, intimidating, malicious or insulting behaviour, an abuse or misuse of power through means that undermine, humiliate, denigrate or injure the recipient.

Harassment

Unwanted conduct related to a relevant protected characteristic with the purpose or effect of

violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that person.

We all have the right to decide what behaviour is acceptable to us and to have our feelings

respected by others. Conduct may be harassment whether or not it is meant to offend. What is a ‘joke’ to one colleague may offend another. Unwelcome behaviour (such as certain ‘banter’, flirting or asking someone out) may unintentionally cause offence. This may not be harassment in the first instance but it will become harassment if the recipient makes it clear that the behaviour is unwelcome and the behaviour continues.

Victimisation

Subjecting a person to a detriment because they have, in good faith, complained (whether formally or otherwise) that someone has been bullying or harassing either them or someone else, or they have supported someone to make a complaint or given evidence in relation to a complaint.

Bullying, harassment and victimisation can be physical, verbal or non-verbal. For example, by telephone, letter, email, social media or face to face. It can also involve one person or a group. Serious acts of harassment can amount to a criminal offence.

We all have a responsibility to help create a bullying, harassment and victimisation-free

environment. You can do this by:

• Being clear with colleagues if you find their behaviour unacceptable

• Being aware of how your own behaviour may affect others and, if need be, change it

• Treating your colleagues with dignity and respect

• Intervening, if possible, to stop harassment, bullying or victimisation, and supporting the

victim

• Reporting harassment, bullying or victimisation to your manager, or to Head of Operation

• Supporting anyone investigating a complaint by being open and honest about what

you’ve seen and heard

• If you’re a manager, making sure your team understand what unacceptable behaviour

looks like and act quickly if you become aware of a potential issue

Examples of bullying and harassing behaviour include, but are not limited to:

• Physical conduct ranging from unwelcome touching to serious assault

• Unwelcome sexual advances, innuendo, leering, whistling, lewd comments or questions

of a sexual nature

• Demeaning comments about a person’s appearance

• Unwelcome jokes or comments of a sexual or racial nature or about an individual’s age,

disability, sexual orientation, religion, beliefs or any other protected characteristic

• Abusive or obscene gestures

• Excluding someone or subjecting them to unwanted conduct because they are perceived

to have a protected characteristic (even if they don’t have that protected characteristic)

or they are associated or connected with someone with a protected characteristic

• The offer of reward for going along with sexual advances, e.g. promotion or access to

training

• Threats for rejecting sexual advances, e.g. suggestions that refusing advances will

adversely affect the individual’s employment, evaluation, pay, advancement, assigned

work, or any other condition of employment or career development

• The open display of pictures, literature or objects with sexual, racial or otherwise

offensive overtones, even if not directed at any particular person

• Spreading malicious rumours or insulting someone

• Ridiculing someone or deliberately setting them up to fail

• Making threats or comments about someone’s job security without good reason

• Isolating or refusing to reasonably and professionally co-operate with someone at work

• Any other conduct which deliberately humiliates, ridicules, intimidates or physically abuses an individual or group.

These definitions of unacceptable behaviour shouldn’t be used to undermine management

processes such as performance management or disciplinary procedures. They should not be used in reaction to reasonable requests made by managers. Robust and respectful management and leadership is a fundamental requirement of those who have responsibility for others. Sporting Aid managers will give feedback to their team members with respect and without compromising the dignity of the individual.

Appendix 2 – Grievance Procedure

Stage 1 – informal stage

• You should meet with your manager or appropriate alternative manager to raise your

Concerns

• We may keep a record of the informal conversations and next steps agreed. This may

include a supported mediation meeting with those involved

Stage 2 – formal stage

• It takes time for new ways of working together to embed. If the concerns have not

been resolved fully at the informal stage, you should submit the Grievance

Resolution Form 1 (GR1) without unreasonable delay after the informal process has

Concluded

• Attach any relevant information to the GR1 before submitting to your manager (or

appropriate other manager, or one of the People team if your concern is in relation to

your manager)

• A formal resolution meeting will be held. If you wish, you can bring a Sporting Aid

colleague or a trade union official

Decision to be confirmed in writing

• All relevant documents will be reviewed and you will receive a written summary of

the outcome following the meeting

• You will be kept informed if there is likely to be a delay as a result of other actions

taking place before the outcome can be decided

Stage 3 – appeal

• If you wish to appeal the outcome, you must do so within five working days of

receiving the outcome letter by completing a Grievance Resolution Form 2 – Appeal

(GR2).

• An invite to appeal hearing will be sent to you giving at least five days’ notice

• If you wish, you can bring a Sporting Aid colleague or a trade union official

Decision to be confirmed in writing, possible outcomes are:

• Appeal Chair overturns previous decision

• Appeal Chair upholds or partially upholds previous decision

• There is no further right of appeal

Appendix 3 – Individual companion support guidance

This document sets out Sporting Aid support and arrangements for employee companions who have been asked by a colleague to support them in accordance with relevant Sporting Aid policies and procedures, including Grievance, Disciplinary, Capability and Sickness Absence,

• Role of the companion

• You have the right to be accompanied at all formal hearings / meetings where you may

be issued a formal sanction as a result.

• Your companion may be a Sporting Aid colleague or a trade union representative. You may

not be accompanied by a friend, family member, or legal representative.

• The role of the companion is to provide support and guidance to you during the process.

They may help you prepare prior to the meeting, attend the meeting with you, put any

relevant questions to the Chair, and hold discussions with you during the meeting.

However, they are not able to respond to any questions on your behalf.

• If you intend to be accompanied, you must confirm to the People team by email who

your companion will be no later than two working days before the meeting date.

• If you are unable to attend a meeting, you must notify the People team by email no later

than two working days before the meeting date, and you must provide a reasonable and

acceptable reason for being unable to attend. If you are unable to attend a formal

meeting, you may choose to send representation by way of a written statement to be

considered at the meeting in your absence.

• Although there is no statutory right for a colleague to be accompanied at an investigatory

meeting, we will allow a companion to be present if by doing so there is no delay in

holding the investigatory meeting.

• Your companion should make every effort to attend the meeting so as not to

unreasonably delay the process.

• Communication

• Employment processes and procedures are a matter between you and Sporting Aid,

therefore, all dialogue and communication is best managed between us directly. We will

copy an identified work colleague / trade union companion into responses and include

them in any appropriate individual consultation meetings where you advise us that this is

your wish, but this will always be in addition to the communication with you and not as

an alternative to it. It is obviously important that you are fully involved in all

communications that relate to you personally.

• In line with this principle, we will only be able to respond to communications from

companions where you are copied in and it is absolutely clear that your companion is

acting with your express authority. In these situations, the response will be addressed to

you and your companion will be copied.

• Where communications are received from companions on behalf of unidentified

individuals, we will not be able to respond as this would clearly be inappropriate.

• Outside of any formal meetings, if your companion has any queries relating to the case

or other matters, these should be directed to the People team only.

• Conduct at meetings

• All those present must behave in a professional, respectful and courteous manner

throughout. This behaviour must be extended to both the process and the people

involved.

• The Chair may adjourn the meeting in the event of unreasonable behaviour by anyone

present.

• Time off to provide support

• On request, work companions will be allowed reasonable paid time to accompany a

colleague at formal meetings and prepare for those meetings. What is reasonable

depends on the case, however this would normally be no longer than an hour of

preparation time and the length of the meeting itself.

• Head of operations approval must be requested for time off to support a colleague.

Companions must give no less than two days’ advance written notification of this time

off. The following information should be provided:

– Date/times/location/expected duration of absence.

– Brief description of activity and purpose i.e. that you are a companion at a disciplinary, grievance or capability hearing.

• It is for the companion’s Head of operation to determine whether they can be released to

support a work colleague. Heads of operation are expected to grant all reasonable

requests for time off by companions. Where a Head of Service has any doubts about

approving a companion’s request for time off, they should seek advice from the People

team.

• If an individual believes that the support arrangements have been unreasonably

refused, they should raise this immediately with the Executive Director of People and culture

1. Introduction

1.1 This Health and Safety Policy Framework (Policy Framework) sets out the high level arrangements in place for Sporting Aid and its subsidiaries (collectively ‘the Group’) which will deliver the aspirations of our Health and Safety Policy Statement (see section 2).

1.2 Good health and safety underpins our core values. Although priorities change, core values remain and provide long-term stability, supporting our aspiration to make us a responsible organisation where the risk of harm, ill-health or damage is minimised through effective controls and procedures.

1.3 We ensure that the way our work is carried out does not, so far as is reasonably practicable, affect the health and safety of our residents, contractors, visitors, the general public and other stakeholders.

1.4 The Policy Framework incorporates the Health and Safety Policy Statement and a summary of health and safety arrangements. It applies to all Group activities and entities. It defines the way that we manage health and safety, taking into account our general duties under the Health and Safety at Work etc. Act 1974 and other health and safety regulations.

2. Our approach – Our Health and Safety Policy Statement

2.1 Our approach is set out in the following policy statement which is available on the intranet. It is reviewed and published annually. Revisions to the policy will be discussed and agreed by the Committee before recommendation for approval by the Group Board.

Health and Safety Policy Statement

Our values align with our health and safety ambitions.

We will be open regarding our health and safety performance, demonstrating that we do the right thing.

Our leaders, managers and colleagues will show their integrity by demonstrating positive Health and safety behaviours.

We will be inclusive in our approach and make sure our customers, colleagues and other stakeholders receive health and safety related services and information fairly.

We will care for our colleagues, residents and visitors by seeking to prevent accidents and cases of work-related ill-health by managing health and safety risks in the workplace.

We will be pioneering with our health and safety management system by:

• Aiming to achieve more than statutory compliance.

• Providing clear and easily accessible instructions and information.

• Providing training, to ensure colleagues are competent to do their work.

• Engaging and consulting with colleagues on all health and safety matters where practicable.

• Implementing emergency procedures, for example in case of fire or other significant incident.

• Preventing pollution arising from our work activities.

• Maintaining safe and healthy working conditions, by providing and maintaining plant, equipment and machinery, and ensuring safe storage/use of substances.

• Ensuring hazards are identified and controls put in place to reduce risks as far as is reasonably practicable.

• Seeking to continually improve our organisational health and safety performance using the ‘Plan, Do, Check, Act’ model.

Health and safety excellence will be achieved through the collective responsibility and co-operation of leaders, managers, colleagues and other stakeholders. While we will ensure that implementation of this Policy Framework is a management responsibility, we expect everyone to work together to maintain a positive health and safety culture.

3. Policy Scope

3.1 This policy applies to all Group companies. It sets out the strategic importance of health and safety within the Group along with the levels of responsibility for promoting and ensuring adequate management of health and safety throughout our business activities.

3.2 This policy forms part of our overall framework of health and safety management within the Group. Health and safety management is controlled by a hierarchy of documents starting with this primary policy and supported by more detailed arrangements that include policies and operational procedures and standards, which should be read in conjunction with this Policy.

3.3 A distinction is made in this Policy Framework in respect of the employing entities in the Group which have additional responsibilities under the Health and Safety at Work Act 1974.

4. Our Health and Safety Arrangements

4.1 This section sets out a high level summary of arrangements for the effective planning, organisation, control, monitoring, resourcing and review of preventive and protective measures to ensure health and safety.

4.2 Strategic Approach to Health and Safety

4.2.1 We recognise health and safety as a strategic risk to the organisation, with the potential to adversely impact reputation, capability and viability if not well managed.

4.2.2 Our approach to health and safety is to mitigate exposure to risks that may give rise to injury, ill-health or damage. We use regular forecasting, planning and monitoring, assessment of risk, and review of controls in order to deliver good health and safety outcomes and benefit business performance.

4.3 Health and Safety arrangements

4.3.1 The Health and Safety arrangements provide all employees and other stakeholders with the detailed information relating to our policies, standards, processes and procedures relevant to discrete topics. These are summarised within the table below and are available. Third party contractors are required to demonstrate a comparable level of compliance to these arrangements within their own health and safety policies.

Topic

Accident/Incident Reporting

Alcohol and drugs

Catering and Food Safety

Control of Substances Hazardous to Health (CoSHH)

Consultation with employees

Display Screen Equipment

Electrical Safety

Event Safety

Fire Safety

First Aid

Lifts and Lifting Equipment

Lone Working

Machinery and Work Equipment

Managing Contractors

Manual Handling

Noise and Vibration

Personal Protective Equipment (PPE)

Risk Management (including new/expectant mothers and young person risk assessment)

Violence at Work

Stress Management

Health and Safety Training

Work-Related Driving

Work at Height

4.4 Health and Safety Strategy, Objectives and Targets

4.4.1 We will develop and implement a Health and Safety Strategy to deliver continuous improvement in health and safety performance. This will be approved by the Group Board and will detail our aspirational objectives and targets for health and safety. It will be reviewed by the Head of operation periodically.

4.4.2 The aspirations of the Health and Safety Strategy will be translated into the objectives of the Health and Safety Operational Plans. The responsibilities for developing the Health and Safety Operational Plans are set out below:

Sporting Aid and all other subsidiaries – The Head of Operation.

4.4.3 The Health and Safety Operational Plans will be approved by the Committee and reported to the respective board of each entity.

4.4.4 Progress against the Health and Safety Operational Plan will be monitored by the Head of Operation through a suite of targets, linked to the corporate scorecard. Targets will be cascaded to relevant colleagues to drive appropriate day to day behaviours, performance and actions.

4.4.5 Performance monitoring of the Health and Safety Operational Plans is undertaken by the Committee and reported to the relevant board on an exceptions basis. Actions are proposed and agreed by the Committee to rectify any significant departure from target.

4.5 Monitoring of Performance

4.5.1 An Annual Health and Safety Review will be carried out each year. This will include a review of progress against the Health and Safety Operational Plans and their targets.

4.5.2 In addition to the Annual Health and Safety Review, regular reports on health and safety performance will be provided to the Committee and Group Board. Health and safety KPIs are reported in the Committee and Board scorecards.

4.5.3 Any health and safety procedures that require amendments will be documented as part of the Annual Health and Safety Review, with a summary of the change required and the rationale for the change. Employees will be consulted on any proposed changes that may substantially affect their health and safety at work. Consultation take place through a variety of mechanisms, include direct consultation with all colleagues, with groups of affected colleagues and by using employee representative forums.

4.6 Review of this Health and Safety Policy Framework

4.6.1 This Policy Framework is subject to continuous monitoring and review. We use proactive and reactive monitoring to demonstrate the effectiveness of this policy.

4.6.2 A formal review of the Policy Framework will be completed annually.

4.6.3 The Head operation will propose amendments to the Policy Framework to ensure ongoing compliance with legislation and best practice standards. Any changes proposed will be approved in line with the provisions of the Governance Framework.

4.7 Worker Consultation and Communication

4.7.1 We value the contribution of all colleagues in improving health and safety performance. Engagement with those who deal with any risks on a day to day basis is achieved through multiple channels including induction, information sessions (such as Exchanges) and regular meetings.

4.7.2 Sporting Aid has a formal employee consultation body, which supports clear two-way communication between management and the workforce. In order to ensure effective consultation with employees on health and safety matters, each meeting will have health and safety as a permanent agenda item for each meeting. Members are responsible for communicating key health and safety information from their meeting to colleagues.

4.7.3 Members are required to attend training in order to be competent to be a Representative of Employee Safety (ROES) and act for their constituents.

4.7.4 At Sporting Aid, we consult with colleagues, however we will utilise other approaches to consultation to ensure we communicate with as many colleagues as possible. Our overall aim is to gain real insight and input from our colleagues helping to shape our approach to health and safety management.

4.8 Risk Management and Safe Systems of Work

4.8.1 The fundamentals of good risk management are embedded throughout all of the Group’s activities.

4.8.2 All Group-controlled operations will be assessed for health and safety risks and appropriate control measures will be identified and implemented. These will be documented and communicated to those potentially at risk.

4.8.3 Workplace inspections will identify new hazards, confirm the effectiveness of control measures and identify areas requiring further attention (further detail can be found in the Health and Safety Risk Management arrangement).

4.8.4 Where appropriate, safe systems of work will be created to further protect our employees, other stakeholders and Group assets from harm (further information regarding safe systems of work can be found on the intranet).

4.9 Health and Safety Training and Competence

4.9.1 Employing entities are responsible for ensuring that all employed personnel (colleagues and contractors) are competent to carry out their roles and responsibilities. Competency is defined as having the skills, knowledge and experience that allow an individual to perform a task in an efficient manner without risk to themselves or others.

4.9.2 Employing entities are responsible for delivering an annual training programme which is designed to meet the health and safety requirements of our employees. This should be bespoke to the Group’s needs and provide training commensurate with an individual’s role and responsibilities. Health and safety training is of mutual benefit to colleagues and the Group alike. Attendance at any arranged training is mandatory.

4.9.3 A learning matrix has been developed by Sporting Aid, which sets out details of mandatory training for their respective employees. This is approved by the Committee and is monitored by the Learning and Development Team to ensure compliance.

4.10 Contract and Supply Chain Management

4.10.1 The health and safety performance of our suppliers and contractors can adversely impact on the overall health and safety performance of the company.

4.10.2 We use a range of controls to select, appoint, monitor, manage and control the performance of our suppliers and contractors. The detailed arrangements are documented within the health and safety arrangements for Managing Contractors (policy, procedure and other useful guidance (available on the intranet).

4.10.3 The health and safety performance of contractors and suppliers is monitored through a combination of reporting, internal inspections, meetings and other mechanisms. We have specific health and safety standards for suppliers and contractors and these are part of wider processes to ensure works and services supplied are performed by organisations who are aligned with our core values.

4.10.4 At Sporting Aid, the relevant committee members for the department or function managing the supplier or contractor is responsible for gaining assurance regarding their competency as part of the procurement process and for ensuring that appropriate supervision and/or monitoring arrangements are in place to check that they are carrying out activities in a safe manner.

4.11 Emergency preparedness

4.11.1 Emergency arrangements to deal with fire and other unplanned events are established at all Group managed premises. Such arrangements, whilst dealing with the immediate circumstances, will also trigger incident notification and may invoke Business Continuity Plans as appropriate to each individual circumstance.

• • • First aid and fire arrangements will be maintained in all Group workplaces.

4.12 Accident Reporting, Investigation and Management

4.12.1 All accidents, incidents and near misses must be reported using the local arrangements found at all Group premises or by using the online reporting tool. Prompt reporting enables corrective action to be taken.

4.12.2 The Health and Safety Team will coordinate the investigation of accidents, incidents and near misses for Sporting Aid. Serious incidents, such as fatalities, will be overseen and co-ordinated by the Director.

4.12.3 Investigations will provide an understanding of why the incident occurred, the effectiveness of existing controls and the actions required to prevent repetition. The Health and Safety Team will be responsible for notifying the Group insurance team of any relevant incidents.

4.12.4 Line managers are required to ensure that all accidents, incidents and near misses are reported by their teams, and to investigate minor accidents and incidents.

4.12.5 Corrective actions arising from accident investigations will be managed to ensure full implementation. The Health and Safety Team will advise managers on appropriate actions where necessary and monitor progress until completion.

4.12.6 Accident trends and progress summaries with corrective and improvement actions will be reported to the Committee and the respective boards on a regular basis. Information will also be periodically provided to employee engagement forums.

4.12.7 Further information and detail guidance can be found within the Accident and Incident arrangements available on the intranet.

4.13 Monitoring, Health and Safety Audits and Reviews

4.13.1 Group workplaces will receive regular health and safety inspections in order to confirm appropriate standards are maintained. Further information is available in the Workplace Inspection Procedure available on the health and safety intranet pages.

4.13.2 Any issues identified are actioned by the manager completing the inspection. Any issues that cannot be resolved immediately will be risk assessed to determine appropriate interim control measures until the preferred solution can be achieved.

4.13.3 Regular monitoring of the health and safety management system (this policy framework, specific arrangements, local instructions and any software systems) will be undertaken using a combination of informal reviews, inspections, internal and external audits to critically appraise the effectiveness of our health and safety arrangements.

4.13.4 Regular reports of health and safety related monitoring data and control arrangements will be provided to the Committee, and the relevant boards as appropriate. These reports provide confirmation that the health and safety management system and arrangements are appropriate in controlling risks, or identify any corrective actions required to achieve the desired performance.

5 Legislation and Regulation

5.1 A list of applicable legislation is available in Appendix 1 (not exhaustive).

6. Responsibilities

6.1 The following section sets out the responsibilities of individuals within the Group in respect of health and safety. It is through individuals performing these roles and discharging their responsibilities that we can deliver our aim of providing healthy and safe workplaces and premises which minimise the likelihood of injury, ill-health or damage.

6.2 All employees are responsible for reading and complying with this policy and its associated procedure.

6.3 The chart on the next page outlines a simplified hierarchy of our organisation and the primary responsibilities of managing health and safety.

Sporting Aid Board Members.

Sporting Aid Committee Members,

Head of Health and Safety

The Head of Operation,

Directors of Service

Health and Safety Managers

Line Managers / Team Leaders / Supervisors employees

Employee Consultation Groups

Director of Governance and Compliance

Health and Safety

Advisors

6.4 Specific Responsibilities
6.4.1 The Group Board is responsible for:

Key:

Line management responsibility

Competent Person(s) for Health and Safety

Health and Safety Information Flow

Health and Safety Oversight

• Establishing a suitable Group-wide Health and Safety Policy Framework that highlights collective and individual responsibilities, ownership and duties that is in place and understood by all employees of the Group

• Approving the Health and Safety Policy Statement and authorising the Chief Executive to sign on its behalf

• Ensuring that other Group subsidiary entities follow Group policies and procedures relating to health and safety and have appropriate management arrangements in place

• Ensuring appropriate co-operation and liaison with relevant governing bodies such as Regulator of Health and Safety Executive (HSE) if required

• Ensuring health and safety arrangements are adequately resourced

• Obtaining competent advice on health and safety in relation to the needs of the business

• Ensuring a process is in place to consult with employees on health and safety matters

• Considering regular reports on safety performance against agreed objectives and targets.

• Approving the Group Health and Safety Policy Statement

6.4.3 Subsidiary board responsibilities

6.4.4 It is the responsibility of the boards of subsidiary companies to ensure compliance and adherence to this Policy Framework as it applies to their operations.

6.4.5 The Group Chief Executive

6.4.6 The Group Chief Executive has executive responsibility for all health and safety matters relating to the activities of the Group, in addition to the Executive Director responsibilities below.

6.4.9 The Head of Health and Safety

6.4.10 The Head of Health and safety, accountable to the Director of Governance and Compliance, is responsible for:

• Leading the development of the Policy Framework and health and safety arrangements

• Providing specialist health and safety advice and guidance to the business

• Acting as subject matter expert in specifying required health and safety training in order to achieve high standards of risk management throughout Sporting aid

• Raising the profile of health and safety and risk management awareness with employees across Sporting Aid

• Reporting all incidents that fall within the requirements of the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) to the Health and Safety Executive

• Reporting on a regular basis to the Committee and Group Board on health and safety performance, compliance and the effectiveness of the health and safety management system

• Providing assurance of the effectiveness of the Health and Safety Policy Framework and arrangements to the Board.

6.4.13 Health and Safety Advisors

6.4.14 Health and Safety Advisors are accountable to Health and Safety Managers. They support the Health and Safety Managers to carry out the tasks described above.

6.4.21 Executive Directors

6.4.22 The Executive Directors will ensure that their health and safety responsibilities are discharged effectively within their directorates. This includes, but is not limited to:

• Ensuring appropriate allocation and delegation of responsibility for health and safety within their areas of responsibility

• Reviewing the effectiveness of health and safety responsibilities through performance appraisal

• Ensuring health and safety issues are considered as an integral part of the business of their Directorate

• Establishing communication channels where they are informed of accidents, incidents and significant near misses occurring within their Directorate, including the investigation outcomes and the action taken to prevent a reoccurrence of the incident

• Ensuring all colleagues within their Directorate receive appropriate health and safety training relevant to their job role and as required by Group training programmes.

6.4.23 Director of Governance and Compliance

6.4.24 The Director of Governance and Compliance is responsible for:

• Ensuring appropriate allocation and delegation of responsibility for health and safety within their Directorate

• Ensuring the development of the Health and Safety Policy Framework and arrangements

• Ensuring the organisation has access to specialist health and safety management advice and guidance

• Ensuring the reporting of all incidents that fall within the requirements of the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) to the Health and Safety Executive

• Ensuring there are regular reports to the Committee and respective board on health and safety performance, compliance and the effectiveness of the health and safety management system

• Provide assurance of the effectiveness of the Health and Safety Policy Framework and arrangements to the Group Board.

6.4.25 Directors / Heads of Service

6.4.26 Directors / Heads of Service are responsible for, and directly accountable to, their Executive Director for implementing this Policy Framework within their area of service and for all other matters relating to health and safety.

6.4.27 This will include taking all reasonable steps to:

• Ensure all necessary procedures for health and safety are in place and operating efficiently by regularly monitoring health and safety performance

• Ensure all employees, contractors or other relevant persons in the Directorate are aware of the procedures, risks and control measures associated with their work

• Ensure that a risk assessment process is in place for relevant activities, that suitable risk assessments are carried out and appropriate control measures applied

• Ensure that any risk assessments are communicated to relevant stakeholders, are documented and maintained

• Identify the need for, and ensure the development of, new safe working practices

• Ensure the implementation of emergency procedures and the development of local emergency procedures as appropriate

• Ensure that accidents/incidents are reported, investigated and the appropriate preventative actions taken

• Ensure that suitable arrangements exist for effective consultation with employees within the Directorate

• Ensure key responsible people / job holders are identified and that health and safety roles and responsibilities are clearly set out

• Ensure all employees, contractors and other relevant persons have the necessary training, skills, knowledge and experience to fulfil their responsibilities and are given enough time to do so.

6.4.28 Managers

6.4.29 Managers are responsible and accountable to their Directors/Heads of Service/ Department for the implementation of the Policy Framework within their area of responsibility.

• • • her/his includes taking all reasonable steps to:

• Ensure the effective day to day management of health and safety and any local health and safety procedures

• Undertake risk assessments and ensure control measures are maintained, monitored and reviewed

• Ensure that accidents, incidents, near misses and hazards are recorded, reported and investigated

• Identify and inform their Director/Head of Department of any individual or departmental health and safety training needs and, where appropriate, fulfilling these needs

• Undertake regular inspections of their area of control to monitor working practices

• Ensure effective communication of health and safety information to relevant stakeholders

• Consult with employees and the Health and Safety Team when considering changes in working arrangements.

6.4.31 Employees (including Volunteers)

6.4.32 Employees have a duty to:

• Take reasonable care of themselves and others around them

• Consider the safety of other persons who may be affected by their acts or omissions

• Work in accordance with information, instruction and training provided

• Refrain from intentionally misusing or recklessly interfering with anything that has been provided for health and safety reasons

• Report any hazards, defects and shortcomings in existing safety arrangements to their line manager without delay (escalating where required)

• Report any accidents or incidents to their line manager without delay

• Comply with this Policy Framework, health and safety procedures and associated instructions and working practices.

6.5 Responsible Persons

6.4.33 A Responsible Person is a term used to describe a specific individual who has the competency (skills, knowledge and other qualities) to be able to discharge a duty of care owed under a specific legislative requirement.

6.4.34 Across the Group we have Responsible Persons for:

6.4.35 Fire Responsible Person:

6.4.36 The Fire Responsible Person must assess risks relating to fire which people may be exposed to and to identify general fire precautions. These are measures to reduce the risk of fire, the spread of fire, measures in relation to fighting fire, in relation to the detection of fire and the ability to warn of fire.

6.4.37 For a workplace, the Fire Responsible Person is usually the employer. For other premises, it will be the person who has control of the premises.

6.4.38 More detailed information is provided in the Fire specific arrangements (available on the intranet).

6.4.39 Legionella Responsible Person:

6.4.40 The Legionella Responsible Person has day-to-day responsibility for controlling any identified risk from legionella bacteria.

6.4.41 The appointed person should have the authority, competence and knowledge of the relevant water systems to ensure that all operational procedures to prevent legionella are carried out effectively and in a timely way. More detailed information is provided in the Legionella specific arrangement (available on the intranet).

6.4.42 Asbestos Responsible Person:

6.4.43 The Asbestos Responsible Person assists in the management of asbestos containing materials in buildings. More detailed information is provided in the Asbestos specific arrangement (available on the intranet).

6.4.44 In respect of emergency arrangements, the key roles and responsibilities are detailed below:

6.4.45 First Aid Roles:

6.4.46 First aid trained personnel are located across the Group’s workplaces. The role of a first aider is to provide help and assistance to someone who is injured or ill, to keep them safe until they can get more advanced medical treatment from a trained medical professional. More detailed information is provided in the First Aid specific arrangement (available on the intranet).

6.4.47 Fire Warden Roles:

6.4.48 A Fire Warden’s roles and responsibilities fall into two categories: proactive and reactive.

• Proactive – Fire Wardens carry out proactive duties to reduce the chance of a fire occurring. For example, testing the fire alarm system and ensuring fire extinguishers are in their correct place and have been serviced.

• Reactive – Fire Wardens also react to fire emergencies by ensuring safe and effective evacuation of our premises. More detailed information is provided in the Fire specific arrangements (available on the intranet).

Responsible Officer: secretary

 

• Introduction

At Sporting Aid, we recognise that our people are fundamental to our success and long-term

future. Therefore, we aim to attract and retain talented people who embody our values and

support our purpose and vision.

Our four strategic People priorities are:

1. Thriving organisation, thriving individuals, thriving leaders

2. Growth Ready, and partner of choice

3. A recognised employer of choice, and a great place to work

4. A culture that enables high performance, growth, and opportunity for everyone

• Who does this policy and procedure apply to?

This policy and procedure applies to Sporting Aid and its subsidiaries (the Group).

This policy and procedure is to be followed by all board and committee members, directors,

managers and colleagues, including third parties who work on our behalf which are

contractors.

• Our approach

At Sporting Aid, we have an open, fair, objective and consistent approach to internal and external recruitment. This is to make sure we select the best people with the right skills, knowledge and abilities.

All candidates will be treated fairly, with respect and without discrimination. Candidates will

be assessed on merit; their knowledge, experience, skills and abilities will be considered

when assessing their suitability for any post. We will also consider our company values and

the cultural fit of all candidates when assessing their suitability for any post.

• Equality and Diversity

Our ambition is to work together to promote a more diverse and inclusive environment – a

place where we can all be ourselves and succeed on merit. By ensuring an inclusive

approach, we are more likely to attract a diverse pool of talent and experience which signals

our commitment to celebrate and promote diversity.

All candidates should be treated equally, recognising some may require additional support or

reasonable adjustments in order to overcome a disadvantage and compete for jobs on an

equal basis. This includes making reasonable adjustments, where required, throughout the

interview process.

We are committed to ensuring diversity and inclusion is considered throughout our

recruitment and selection processes, including interview panels and candidate selections.

• Internal Candidates

At sporting Aid, we foster development and progression, therefore we encourage and support internal applications. However, we will not be able to consider an application from a

colleague who has not yet completed their probation period.

If an internal applicant has any sanctions that relate to performance management,

disciplinary, grievance or absence, their application may not be considered until the sanction

has been resolved.

We have a transparent approach to communication at Sporting Aid, so we’d appreciate the same from internal applicants. It’s best practice to let your line managers know when you’re

planning to apply for a different position within Sporting Aid.

• Legislation and Regulation

Sporting Aid is governed by various Legislation and Regulations which include the following:

The Equality Act 2010

The Equality Act came into force on 1 October 2010 and it aims to provide a simpler, more

consistent and more effective legal framework for preventing discrimination. The stated aim

of the Act is to reform and harmonise discrimination law, and to strengthen the law to support progress on equality. The Equality Act covers the following `protected characteristics´:

• age

• disability

• gender reassignment

• race

• religion or belief

• sex

• sexual orientation

• marriage and civil partnership

• pregnancy and maternity

Immigration, Asylum and Nationality Act 2006 (Eligibility to Work in the UK)

These provisions came into force on 29 February 2008 and aim to prevent illegal migrant

working in the UK. Failure to comply with these regulations can result in becoming

liable to pay a civil penalty of up to £10,000 for every illegal worker.

General Data Protection Regulation (GDPR)

Information provided to Sporting Aid as part of the recruitment process will be processed and

stored in line with the General Data Protection Regulation (GDPR) and associated

legislation. At appointment, information provided by successful applicants during the

recruitment and selection process will be used to establish their employee records. Please

refer to our Privacy Policy for more details.

Disclosure and Barring Service

The DBS helps employers make safer recruitment decisions and prevent unsuitable people

from working with vulnerable groups, including children. Should a role require a DBS check,

this will be agreed with the hiring manager and included in any advert.

There are three types of DBS check:

1. Standard – this is to check for spent and unspent convictions, cautions, reprimands and

final warnings

2. Enhanced – this covers the same as a standard check plus any additional information

held by local police that’s reasonably considered relevant to the role being applied for.

3. Enhanced with list checks – this is like the enhanced check, but includes a check of the

DBS barred lists.

Sporting Aid uses an online service, details of which will be provided by a member of the People Team as part of the on-boarding process.

• Responsibilities

Hiring managers are responsible for:

• Proactively identifying if a role is required, even in the instance where a role is a

replacement

• Working effectively with both the Recruitment and People teams through the entirety of a

recruitment campaign

• Applying this policy as soon as reasonably practical

• Demonstrating our values in consistently applying this policy

• Taking ownership of their responsibilities as detailed in the procedure

The Recruitment Team are responsible for:

• Supporting hiring managers through the entirety of a recruitment campaign by offering a

partnering service

• Working effectively with both the hiring manager and People team through the entirety of

a recruitment campaign

• Applying this policy as soon as reasonably practical

• Demonstrating our values in consistently applying this policy

• Taking ownership of their responsibilities as detailed in the procedure

The People Team are responsible for:

• Working collaboratively with both hiring managers and the Recruitment team during the

recruitment campaign, where required

• Applying this policy as soon as reasonably practical

• Demonstrating our values in consistently applying this policy

• Taking ownership of their responsibilities as detailed in the procedure (Appendix 1)

The Candidates are responsible for:

• Providing Sporting Aid with up to date and accurate information

• Displaying their skills and knowledge to the best of their ability

Appendix 1 – The Procedure

1. A recruitment requirement is identified by the hiring manager; this could be a replacement for an existing role, either permanent or fixed term contract/secondment. Or it could be a brand new role which is not currently within budget, in which case an approved Business Case must be completed beforehand.

2. The hiring manager will need to make sure a Role Profile template has been completed with the up to date details, with support from recruitment specialist.

3. The hiring manager needs to login in a ‘Request a Vacancy’. The hiring manager will complete the online ‘Request to Fill’, ensuring all mandatory boxes are completed. This will include confirming the name of their Director Approver, Finance BP Approver and HR BP Approver. Once they submit the ‘Request to Fill’, the recruitment will be notified and will check the details and the benchmark salary.

4. Once the recruitment team have checked the details are correct, they will assign the vacancy to be approved based on the details provided by the hiring manager. The vacancy will go to the Director for approval first, then to the Finance BP and finally to the HR BP.

5. If there are any discrepancies on the Request to Fill, a Recruitment Specialist needs to set up a meeting with the hiring manager to discuss and correct.

6. Recruitment Specialist reaches out to the hiring manager to arrange an initial meeting to

discuss recruitment needs. During the meeting, recruitment specialist and hiring manager will agree on the best recruitment campaign for the vacancy and discuss the following:

• Internal and external talent pipeline

• The role assessment criteria (form on the Intranet)

• Dates, times and panel* for first and second stage interviews and/or assessments

• Hiring manager to book rooms and coordinate interviews/assessments on the day,

including the necessary materials and equipment

• Recruitment Specialist to support hiring manager to agree interview questions and

Assessment

*Panel at first stage should consist of hiring manager and an internal customer or

stakeholder; Panel at second stage should consist, as a minimum hiring manager and

recruitment specialist, and if required, an internal customer or stakeholder. Panel needs

to be diverse and inclusive.

7. As a minimum, we will advertise the role for one week internally. Additional advertising will be agreed at the initial recruitment meeting.

8. Recruitment Specialist reviews the applications received and any existing talent pipeline for candidates. CVs screened against the role profile and assessment criteria that was agreed during the initial recruitment meeting.

9.The panel will receive a notification when the candidates are available to review and score. The panel will conduct the CV Scoring against the assessment criteria for the role. Once scoring is complete, the panel will then submit the shortlist and the recruitment team will receive a notification.

10. Hiring manager confirms the availability for the panel and/or the assessment (if applicable) and will book the rooms if required. Recruitment Administrator contacts the selected candidates and arranges the interviews. Recruitment Administrator sends all candidates interview confirmation emails. hiring manager will be responsible for the coordination of interviews/assessments on the day.

11. If necessary following the initial meeting, hiring manager and Recruitment Specialist work further together to draft and/or select appropriate interview questions in alignment with the selection criteria.

12. The panel conduct the first stage interview. Once all the interviews have been completed, the panel will upload interview notes and select the appropriate outcome for each candidate. The recruitment team will receive a notification and will follow up with the hiring manager to discuss feedback and confirm their availability for second stage interviews.

13. Recruitment administrator to update unsuccessful external candidates of their application, giving them the opportunity to request detailed feedback (via phone). Irrespective of outcome, hiring manager will deliver the outcome of the interview directly to internal candidates, with guidance from Recruitment Specialist if required. Recruitment Administrator will arrange second stage interviews with the successful candidates and send confirmation emails.

14. The Recruitment Specialist and hiring manager will agree on second stage interview

questions; assessing the areas from the first stage that need to be probed further and the

cultural and team fit.

15. Recruitment Specialist and all panel members discuss the outcome from the second stage interviews and agree on an offer proposal for the successful candidate.

16. If the candidate is external, the Recruitment Specialist will make the verbal offer. If the

candidate is internal, hiring manager will make the verbal offer. Hiring manager will need to

liaise with the internal candidate’s current line manager to mutually agree on a start date.

Recruitment Specialist will then contact the internal candidate to follow up and confirm the

details of the offer in writing.

17. If the candidate declines the offer of employment, recruitment specialist and hiring manager to discuss options and next steps. If an offer exceeds the benchmark salary, hiring manager must obtain sign off from HR Business Partner, Finance Business Partner, relevant Executive Director and Executive Director of People.

18. Once the candidate has accepted the verbal offer, the Recruitment Specialist will contact the hiring manager to confirm their provisional start date.

19. Hiring manager logs in to Recruitment, and completes the online Recruitment Decision Form, selecting the Recruitment Team as authorisers. The recruitment team will receive a notification to check the RDF details are correct, authorise and send through to the People Team for next steps. If an offer over benchmark has been approved, confirmation of this will need to be uploaded with the RDF.

20. The recruitment team send the candidate an email to confirm their offer detail, along with an invitation to the New Starter Portal, and a request for them to upload supporting documents.

21. The People team receive notification of the offer and will then liaise directly with the hiring manager on status of new starter to support with onboarding

1 Introduction

1.1 This procedure outlines the steps to be taken by colleagues, including those who work on our behalf in the event of actual or suspected abuse of a child or young person we can reasonably identify and instances where a child or young person is the alleged perpetrator of abuse.

1.2 The procedure works in conjunction with the following policies and procedures which provide a framework of overall approach to safeguarding, and should be applied in those situations:

• Recruitment policy and procedure which sets out the requirements of managers and colleagues to disclose criminal offences and the use of Disclosure and Barring Service checks. This includes third parties, such as contractors and volunteers who work on our behalf.

• Whistleblowing policy which encourages and protects colleagues notifying us of any concern of inappropriate or abusive behaviour.

• Other colleague related policies, including the code of conduct, colleague handbook, disciplinary policy and procedure.

• Information and data protection policies and procedures providing the framework for recording and sharing sensitive and confidential information to the local safeguarding boards and other agencies.

• Anti-social Behaviour (ASB) policies to be followed for incidents of anti-social behaviour and supporting victims, including domestic abuse and hate crime.

2 Definitions

2.1 Safeguarding children and young people and promoting their welfare means protecting them from maltreatment, preventing impairment of their health and development, ensuring that they grow up in circumstances consistent with the provision of safe and effective care and taking action to enable all children to have the best outcomes.

2.2 Children and Young People – for the purpose of this procedure the term child / children are used which includes all those under the age of 18.

2.3 Abuse occurs when children are hurt physically, emotionally or in some other way. Children can be abused in any section of society. Children may be abused by family or friends, by professionals who are in a caring role or by strangers. All forms of abuse can have damaging effects on the welfare and development of children.

2.4 Main types of abuse:

2.4.1 Physical abuse includes hitting, shaking, throwing, poisoning, burning, or scalding, drowning, suffocating, or otherwise causing physical harm to a child. Physical harm may also be caused when a parent fabricates the symptoms of, or deliberately induces illness in a child.

2.4.2 Emotional (psychological) abuse is the persistent emotional maltreatment of a child such as to cause severe and persistent effects on the child’s emotional development, and may involve:

• conveying to children that they are worthless or unloved, inadequate, or valued only insofar as they meet the needs of another person

• imposing age or developmentally inappropriate expectations on children. These may include interactions that are beyond the child’s developmental capability, as well as overprotection and limitation of exploration and learning, or preventing the child participating in normal social interaction

• seeing or hearing the ill-treatment of another e.g. where there is domestic abuse

• serious bullying, causing children frequently to feel frightened or in danger

• exploiting and corrupting children.

2.4.3 Sexual abuse involves forcing or enticing a child or young person to take part in sexual activities, not necessarily involving a high level of violence, whether the child is aware of what is happening. The activities may involve physical contact, including assault by penetration (e.g. rape or oral sex) or non-penetrative acts such as masturbation, kissing, rubbing, and touching outside of clothing.

2.4.4 Neglect is the persistent failure to meet a child’s basic physical and/or psychological needs, likely to result in the serious impairment of the child’s health or development. Neglect can also occur during pregnancy because of maternal substance misuse, maternal mental ill health or learning difficulties or a cluster of such issues.

• provide adequate food, clothing, and shelter (including exclusion from home or abandonment)

• protect a child from physical and emotional harm or danger

• ensure adequate supervision (including the use of inadequate caregivers)

• ensure access to appropriate medical care or treatment.

2.4.5 Other types of abuse can be found in Appendix 1 – Safeguarding – other related issues.

Some level of emotional abuse is involved in all types of maltreatment of a child, though it may occur alone.

Once a child is born, neglect may involve a parent failing to:

It may also include neglect of, or unresponsiveness to, a child’s basic emotional, social and educational needs. Where there is a case of domestic abuse the needs of the child may be neglected and needs to be considered.

3 Identifying abuse

3.1 All colleagues have a responsibility to report their concerns to ensure all children are safe. This includes others who work on our behalf (contractors and volunteers) to:

• be alert to potential indicators of abuse or neglect.

• be alert to the risks which individual abusers, or potential abusers, may pose to children.

• report concerns in line with this procedure.

• provide any additional information requested to assist in case reviews.

3.2 Children who may be more at risk are those who:

• are disabled and have specific additional needs

• are young carers

• are showing signs of engaging in anti-social or criminal behaviour

• have challenging family circumstance, such as substance misuse, adult mental health problems or domestic abuse

• are showing early signs of abuse or neglect.

4 Responsibilities

4.1 All colleagues have a responsibility to raise safeguarding alerts. An alert is made by completing the Safeguarding Internal Referral Form on the Hive and sending this via email to the safeguarding queries inbox. All reported safeguarding cases are managed by the Senior Management team.

4.2 All reports will be reviewed by the Senior managers, in the absence of the Senior Managers, the named deputy is the Team Leader. The Head of Operations will lead or delegate the case with responsibility for overseeing progress if the Senior Team or Team Leader are unavailable.

4.3 The Team Leader is responsible for the management of cases within their jurisdiction although may delegate day to day responsibility outside of their direct line management reporting structure.

4.4 The Team Leader is responsible for monitoring safeguarding cases on an ongoing basis, managing the safeguarding queries email inbox and referring cases to the relevant leads.

4.5 The Head of Operations is responsible for overseeing the approach to safeguarding.

5 Reporting an incident or suspicion of abuse and ‘raising an alert’

5.1 Concerns about suspected or actual abuse can be reported by:

• direct disclosure from the child.

• a colleague or those working on our behalf (including contractors and volunteers);

• a resident, service user or a third party (e.g. a neighbour) or

• the local authority children’s social care team requesting information about a child of one of our resident’s or service user who has already been reported to them.

5.2 All colleagues, including those working on our behalf, have a responsibility to report any concerns referred to ‘raising an alert’ in line with this procedure.

5.3 It can be distressing for colleagues who are involved in a safeguarding case and therefore managers should make sure that support is provided.

5.4 Raising an alert
5.4.1 Where the child is severely injured or in immediate danger, the colleague will contact the emergency services (e.g. ambulance, police) to have any medical treatment needed and protect the child from further harm.

The protection of the child is paramount. Consent does not have to be given by a parent as the law protects any professions taking reasonable steps to offer the child immediate protection (including from an aggressive parent)

5.4.2 In the case of abuse which may lead to criminal investigation, the colleague should not move or discard any evidence or items which may be required for any investigation by the emergency service or other investigative body. Where possible the colleague should secure the location.

5.4.3 Where there is a child or children under the age of 18 unsupervised by an adult, the colleague should not enter the property. The colleague should remain outside the property but ask the child opening the door:

• where the parent / supervising adult is and how long they will be

• how many other children are in the property and ask for them to come to the door to be kept in sight

5.4.4 If it has not been possible to contact the resident or parent, the police should be contacted as the children are at risk of harm. The police have a duty of care to assist and supervise the child/ children.

5.4.5 Once in attendance the emergency services are responsible for the welfare of the child / children.

5.4.6 Within four hours the colleague should contact the senior Management team to ‘raise an emergency referral form due to alert’.

5.4.7 The colleague should now follow the non-emergency alerts procedure, see below.

5.4.8 As soon as possible and within one working day the colleague should complete the Safeguarding referral form and email this to the safeguarding queries inbox.

5.4.9 The Team Leader Co-ordinator will log the case.

5.4.10 The Team Leader Co-ordinator will allocate to the relevant colleague which can be NEM, ASB Officer. In the absence of the lead or their named deputy they will allocate this to the named deputy. 

5.4.11 The lead officer is responsible for deciding whether a referral to the local authority is required. where a referral is required the lead officer is responsible for ensuring this is made within one working day of being informed.

5.4.12 The lead officer is responsible for management of cases within their jurisdiction and. may delegate responsibilities for day to day management to another colleague, including outside of their line management reporting structure.

5.4.13 Any serious situation, which is likely to attract media interest, should also be referred to the Head of operations or in their absence, the Senior Manager.

5.5 Responding to a disclosure
5.5.1 If a child reports that they have been abused the colleague dealing with the report should:

• listen to what the child or young person is saying to be able to report on the information

• remain calm and manage their emotions

• not press for further information or ask leading questions.

• explain that the information provided will be reported to help protect them

• follow the emergency and / or non-emergency alert process as appropriate.

5.6 Responding to a concern raised by a third party
5.6.1 Any reports of abuse by a third party should be dealt with by following the emergency or non-emergency alert process. The colleague should not discuss or reveal any personal details of our members with a reporting third party who does not have authority to discuss the case. The colleague should follow the emergency or non-emergency alert process and record all information on the safeguarding referral form.

6 Making a referral to the local authority children’s social care team

6.1 Decision to make a referral
6.1.1 The decision to make a referral to the local authority safeguarding team belongs to the team leader or the senior management team.

6.1.2 A referral must be made to the local authority children’s social care team if there are concerns that a child is at risk of harm, neglect or other abuse or if there are signs that a child / young person (including an unborn baby):

• has suffered significant harm through abuse or neglect

• is likely to suffer significant harm in the future.

6.2 Consent
6.2.1 The lead is responsible for making decisions on the level of involvement and consent gained from the child and parents on a case by case basis taking into consideration the risk to the child’s and other children’s safety and guidance from the Pan London Child Protection Procedures (below).

Pan London Child Protection Procedures ‘If the child can understand the significance and consequences of making a referral to the local authority children’s social care, they should be asked their view. However, it should be explained to the child that whilst their view will be taken into account, the professional has a responsibility to take whatever action is required to ensure the child’s safety and the safety of other children.

7 Allegations against colleagues (including contractors and volunteers)

7.1 All colleagues (including contractors and volunteers) must inform their line manager within one working day if there are any concerns that a colleague, contactor or volunteer has behaved in a way that has:

• harmed, or may have harmed, a child or young person

• possibly committed a criminal offence against, or related to, a child or young person

• behaved towards a child or young person in a way that indicates s/he is unsuitable to work with them.

7.2 All colleagues (including contractors and volunteers) should follow the emergency or non-emergency alert process. The colleague does not have to investigate or substantiate the concern and is protected from any repercussions as long as it is made in the public interest (see the Whistleblowing Policy).

7.3 Allegations against a colleague (s)
7.3.1 The emergency or non-emergency alert process should be followed as well as the Whistleblowing Policy and Procedure. On receiving the alert the senior team must inform the relevant safeguarding lead, the Head of Operations and the relevant line manager.

7.3.2 On receiving the report, the line manager should contact Human Resources to start an investigation under the Disciplinary Policy and Procedure.

7.3.3 The notes on the report should not include the names of colleagues, (this includes both the reporting party and alleged perpetrator). The purpose of logging the case is to ensure a record of the safeguarding incident. The notes on the report should be brief (stating an incident has occurred) and refer the reader to HR where detail is required.

7.3.4 The Head of Operations is responsible for liaising with the Local Authority Designated Officer (LADO) before any formal action or investigation is taken against the colleague. This includes where a colleague resigns before any investigation or formal action was taken. The LADO can also advise on making a referral to the Disclosure and Barring Service (DBS) and any other regulatory bodies.

7.3.5 With advice from the LADO and Human Resources the Head of Operations will investigate the allegation with the line manager in line with the disciplinary procedures (see Disciplinary Policy and Procedure). During the investigation the colleague should be informed that:

• That an allegation has been made but not the details of the allegation

• No further work with the client group can be done during the investigation. The colleague may be assigned, such as non-frontline duties, subject to the circumstances and risk assessment. In some circumstances the colleague will be suspended.

• How the enquiries will be conducted, and how his/her co-operation will be sought

• The outcome of the investigation and the nature of any further actions.

7.3.6 In the absence of the Head of Operations the Senior Management will be responsible for informing the LADO and leading the investigation with the line manager.

7.4 Allegations against contractors
7.4.1 The emergency or non-emergency alert process should be followed. In addition any allegation against a contractor should be sent to the contract manager by the lead. The contract manager is then responsible for raising the concern with the contractor manager, including instruction that the operative should not be assigned to any further work in or around our properties and discuss any further investigation needed by us and the contractor.

7.4.2 The Senior Management Team is responsible for carrying out the investigation and discussing action to be taken to the manager of the contractor. The overall decision on action will be taken by the Head of Operations, including liaising with the relevant LADO.

7.5 Allegations against volunteers
7.5.1 The emergency or non-emergency alert process should be followed. In addition any allegation against a volunteer should be notified to the relevant coordinator by the lead. The relevant coordinator will inform the volunteer that they will not be able to carry out their volunteer activities until an investigation has taken place.

7.5.2 The Senior Management Team is responsible for carrying out the investigation and recommending action to be taken for decision by the Head of Operations, including liaising with the relevant LADO. 

8 Closing cases

8.1 When closing cases, the lead / person managing the case will update:

• the safeguarding incident sheets

• any other colleagues involved, including the initial referring colleague.

8.2 The Report should explain the case closure decision, including why closure is a proportionate and legitimate action.

9 Recording and monitoring

9.1 Anyone who identifies, or suspects abuse is responsible for recording and reporting details of the abuse or neglect to the safeguarding queries inbox where the Senior Management team will enter it on our case management system.

9.2 Monitoring responsibilities:

Safeguarding Leads:

• Responsible for reviewing all cases in their portfolio to inform actions, identify any lessons learnt and inform any additional training or changes to operational practice required.

The Senior Managers:

• Provides a quarterly report of all alerts raised, the type of abuse, the number of referrals made to the local authority safeguarding board and outcomes.

The Head of Operations:

• Is responsible for overseeing the approach to safeguarding, operational decisions and reporting.

10 Complaints

10.1 Complaints about the behaviour of a child or young person who lives in one of our homes is dealt with via the Anti-Social Behaviour Policy and Procedure, with consideration made whether the issues also indicate a safeguarding concern.

10.2 Any complaints received about our safeguarding practice should be dealt with via the complaint’s procedure.

Appendix 1 – Other related issues for safeguarding

Domestic abuse can also mean children or young people are may also be affected by some level of abuse and neglect. This can be through seeing, hearing and living with domestic violence and abuse as well as being caught up in any incidents directly, whether to protect someone or as a target. This procedure should be followed where there is any concern about children within the household.

Gang related activities

Children and young people may become involved in gang related activities for a variety of reasons. It is important to be aware of possible signs and to look out for unusual behaviour, such as:

• new groups of friends that are not known, often older, and have sudden importance

• unexplained money, gadgets, clothes or trainers and other amenities

• constant phone calls and leaving the home quickly without adequate explanation

• started to use new or unknown slang words, ways of talking and hand signs

• stopping or dropping out of hobbies or clubs they’re involved in

• school or reports or relationships with parents or carers change dramatically

• going missing for long periods, staying out later than scheduled, particularly if overnight

• new habits, for example smoking, drinking, dealing or taking drugs, taking an interest in illegal activities

• adopting a change of name, or new nickname.

Any concerns about a child getting involved in gang related activities should be referred to the Senior Management Team who will make an assessment under the independent offer process. Where there are concerns that a child is at immediate risk of suffering serious harm the police should be notified immediately. It may be necessary to ensure that the child remains in a safe place or is removed to a safe place, either on a voluntary basis or by obtaining an Emergency Protection Order (EPO). The police have powers to remove a child to suitable accommodation in cases of emergency.

Female Genital Mutilation (FGM) is the partial or total removal of external female genitalia for non-medical reasons, can cause severe and long-lasting damage to physical and emotional health and is classified as child abuse.

It is a criminal offence for any persons (regardless of their nationality or residency status) to perform FGM, or to assist a girl to carry out FGM on herself. It is also an offence to take child abroad to have FGM. Anyone found guilty of the offence faces a maximum penalty of 15 years in prison.

Anyone can apply to the court for an FGM Protection Order if they are concerned that someone is at risk of FGM. Breaching an FGM Protection Order is a criminal offence with a maximum sentence of 5 years imprisonment.

It is mandatory for regulated health and social care professionals and teachers to report any cases to the police.

Faith Based Abuse (FBA) is a belief in concepts of witchcraft and spirit possessions, demons or the devil acting through children or leading them astray. The killing of children is believed to bring supernatural benefits or the use of their body parts to produce potential magical remedies. It can also be the use of belief to create fear in children to make them more complaint when they are being trafficked for domestic slavery or sexual exploitation

Any concerns about FBA should be raised with the Senior Management Team who will record the case and decide whether to report these to the local authority children social care team.

Forced Marriage (FM) is a marriage in which one or both parties do not consent to the marriage and duress is involved. A marriage involving one or both parties under the age of 16 or young people with a learning or physical disability can be seen as FM. It is a criminal offence5 to force someone to marry. This includes:

• Taking someone overseas to force them to marry (whether or not the marriage takes place)

• Marrying someone who lacks the mental capacity to consent to the marriage (whether they’re pressured or not)

• Breaching a Forced Marriage Protection Order (FMPO).

Forcing someone to marry can result in a sentence of up to seven years in prison.

Any concerns about FM should be raised with the Senior Management Team who will record the case and decide whether to report these to the local authority children social care team.

Private Fostering is where a child is being looked after by someone other than their parent (or guardian) or close relative for more than 28 days of more. This applies to children who are under the age of 16 or under 18 if they are disabled.

Where it is known that a child or young person are living in private fostering arrangements the local authority must be informed. Any concerns about a child should be discussed with the Senior Management Team who will record the details and refer on to the relevant local authority private fostering team.

Violent Extremism is where groups or individuals condone violence to a political end. Causes range from animal rights to far right politics to international terrorist organisations.

Any concerns about a child or young person being involved in or at risk of being influenced by extremist views or violence should be discussed with the Senior Management Team.

Peer to Peer Peer-on-peer abuse is any form of physical, sexual, emotional and financial abuse, and coercive control, exercised between children and within children’s relationships (both intimate and non-intimate). Peer-on-peer abuse can take various forms, including serious bullying (including cyber-bullying), relationship abuse, domestic violence, child sexual exploitation, youth and serious youth violence, harmful sexual behaviour, and/or gender based violence.

• Introduction

• • At Sporting Aid, we’re committed to ensuring the health and wellbeing of all of our colleagues. Absences from work also have a big impact on other team members and our ability to provide a great service to our customers, so it’s really important that we have processes in place to manage sickness absence and support you back to work.

• • Our aim is to assist you in proactively managing your health and wellbeing to allow you to get back to doing a great job.

• • If you’re too ill to work, this policy and procedure sets out your responsibilities to inform and update us on the reasons for your absence, and also explains the support and benefits you can expect in return.

• • This policy and procedure will help guide periods of both short-term and long-term sickness absence. Time off work not related to sickness is covered in other policies and procedures.

• • As the reasons and circumstances for absences are unique, we may vary the procedures set out in this policy and implement appropriate requirements to reflect specific circumstances.

• Who does this policy apply to?

• • This policy applies to all colleagues of Sporting Aid, and its subsidiaries. It does not apply to Board or committee members, or third parties who work on our behalf.

• Definitions

3.1. Statutory Sick Pay (SSP) – SSP is available for up to 28 weeks to all colleagues who meet the eligibility criteria as set out by the government. The amount of SSP is set by the

government.

3.2. Company Sick Pay (CSP) – CSP is a discretionary payment on top of SSP, and makes up the difference between SSP and your normal basic salary, or between SSP and half of your normal basic salary. Your entitlement to CSP is outlined in your contract of employment.

3.3. Short term Sickness – is defined as any sickness that is less than four weeks.

3.4. Long term sickness – is defined as sickness that is more than four weeks.

• Our approach

4.1. First Care: access to medical advice from day 1

Your call will be taken by a trained advisor and you’ll have the option to speak to a registered

nurse who can assess your illness and provide advice.

4.2. Company sick pay scheme

Money can be a worry when you’re ill, so if you’re too sick to work we’ll top up your Statutory

Sick Pay (SSP) with Company Sick Pay (CSP). Further information can be found in section

7. In return you’re expected to comply with this policy and procedure to help you get back to

work.

4.3. A positive and proactive approach to helping colleagues return to work

We’ll do what we can to help you get back to work quickly and safely. This may involve

holding welfare meetings with you, referring you to our Early Intervention Service or

Occupational Health providers, conducting a Health and Safety risk assessment, or even a

Wellbeing Action Plan. All colleagues also have access to our Employee Assistance

Programme (EAP), who can provide you with confidential support on personal or

professional concerns 24 hours a day, 7 days a week. They can be contacted via email  info@SportingAid.org

4.4. A focus on consistent and fair intervention

If the level or frequency of your absences from work becomes a concern, we’ll apply easy to

understand Review Points to guide further intervention. See section 5.

4.5. Links to other policies

Should a colleague fail to follow this policy and procedure, we may refer to our Disciplinary

Policy and Procedure.

4.6. Underlying medical conditions

We’re aware that sickness absence may result from a disability. At each stage of the

sickness absence procedure, particular consideration will be given to whether there are

reasonable adjustments that can be made to a job or other working arrangements that will

provide support at work or assist a return to work. If you consider that you are affected by a

disability or any underlying medical condition which affects your ability to undertake your

work, you should inform your line manager.

4.7. Sensitivity and confidentiality

We recognise that medical matters can be sensitive so we’ll manage your absence with

sensitivity and in confidence, whilst ensuring that your personal data is protected. Any

information you provide to us about your health will be processed lawfully and in accordance

with our Employee Privacy Statement which can be found on the company website.

• Short term sickness absence

5.1. We monitor sickness absence levels, frequencies and any patterns of absence. Cause for

concern and further invention will include:

• Hitting a Review Point of three occasions (of any length) within a rolling six-month period

• Hitting a Review Point of four non-consecutive working days of absence within a rolling

six-month period

• Any pattern of absence (for example several occasions of absence connected to a

weekend)

• Any other concerns relating to the nature of your absences.

5.2. Review Points will be pro-rated if you work on a part time basis. All absences of half a day or more will be treated as an occasion of sickness absence.

5.3. If your sickness absence causes concern, we’ll meet with you to discuss this. Depending on the circumstances, this could be an informal or formal meeting. The purpose of this meeting

is to:

• Discuss the frequency and reasons for your absences, and any concerns around this

• Understand what you have done to try to improve your health and attendance

• Jointly establish further action or support that could be provided to help you to improve

your attendance

• Agree a plan of action or improvement target to avoid further escalation of the concerns

• Agree a timescale for review.

5.4. If the meeting is a formal one we’ll make you aware of this in writing beforehand. The

process and possible outcomes of formal absence meetings is covered in Appendix 1.

5.5. We’ll conduct all absence meetings fairly and reasonably, taking account of the facts

available. We’ll only issue formal warnings or other sanctions when there is cause to do so,

for example where we are unable to sustain your absence levels.

5.6. If you’re issued with a formal absence warning at any stage of the absence process, you may lose the benefit of CSP (but will continue to be eligible for SSP) whilst your warning remains active.

• Long term sickness absence

6.1. Sporting Aid recognises that colleagues who are absent from work due to sickness absence for extended periods of time need support, and we’ll treat all cases sensitively.

6.2. Our aim is to make sure you are assisted in a safe return to work when you are able.

6.3. We understand that it can be difficult returning to work after a long period of sickness

absence. In order to make your return easier, we’ll:

• Monitor your progress over the first few weeks to ensure that you are coping with your

return

• Ensure your workload is appropriate and reasonable, for example you’re not required to

deal with an unreasonable backlog of work caused by your period of absence

• Take all reasonable steps to facilitate your reintegration back into the workplace,

including any adjustments that may be required

• Consider a phased return where medical evidence supports this. For the first two weeks

of a phased return period you’ll receive your full salary. If your phased return continues

for longer than two weeks, you’ll be paid for the hours you work. We normally expect you

to be back to work on a full time basis within two weeks or within a maximum of four

weeks, but this will be reviewed on a case-by-case basis.

6.4. Our full procedure is outlined in Appendix 1.

7. What happens to your pay if you’re not well enough

to work?

7.1. Statutory Sick Pay (SSP)

SSP is available for up to 28 weeks to all colleagues who meet the eligibility criteria as set

out by the government. You can check if you qualify for SSP on the government website

(https://www.gov.uk/statutory-sick-pay). The amount of SSP is set by the government. If you

are not eligible for SSP or if your SSP entitlement is coming to an end, we will give you an

SSP1 form telling you the reasons; this form can then be used to support your claim for any

social security benefits.

7.2. Company Sick Pay (CSP)

You’ll normally be able to participate in the CSP scheme providing you fully comply with this

policy and procedure. CSP is a discretionary payment on top of SSP, and makes up the

difference between SSP and your normal basic salary, or between SSP and half of your

normal basic salary. Your entitlement to CSP is outlined in your contract of employment. All

payments will be pro-rata for colleagues who work part time hours.

7.3. You’ll pay tax and National Insurance (NI) as normal on all CSP and SSP payments you

receive.

7.4. Once you’ve taken all of your SSP and CSP, your salary payments will stop until you return to work. We won’t normally inform you, unless, you are on long term sick, if you are about to exhaust your SSP and / or CSP as it is your responsibility to keep track of this.

7.5. Due to the way sickness absence payments are processed in the monthly payroll, you may be overpaid. If this happens, we’ll recover the overpayment from any future payments (salary or otherwise) due to you.

7.6. Should your absence be due to an accident at work for which you later receive

compensation, any payments made to you in relation to the absence may be recovered from

you.

• What else might you need to know?

8.1. Pension payments during periods of sickness absence

If you are a member of the pension scheme, we’ll continue to make deductions from your

salary while you’re receiving SSP and CSP. If you’ve exhausted sick pay, no pension

payments will be made but you’ll remain a member of the pension scheme.

8.2. Annual leave and holidays

If you fall ill while you’re on annual leave and you wish to reinstate your holiday entitlement,

you’ll need to report this as usual and provide a fit note to cover the whole period of sickness, even if you’re abroad.

8.3. Long term sick: accruing holiday

If you’re unwell for an extended period you’ll continue to accrue annual leave, even if you’re

no longer receiving sick pay. If you’ve been unable to take your leave due to a long-term illness, you can request to carry forward up to four weeks, but this must be taken within 18 months of the last date of the holiday year in which the leave was accrued. Alternatively, you’re able to request to take annual leave during a period of sickness absence; in these situations, your sick pay will be paused for the duration of annual leave and you will receive your normal basic salary.

8.4. Medical / Dental Appointments

You can request in advance reasonable time off to attend medical or dental appointments,

with the time to be made up as agreed with your manager. You’re expected to try to book

appointments at the beginning or end of the working day to minimise the impact on the

business and you must get your manager’s approval before booking these. We reserve the

right to request proof of medical appointments requiring time off from a working day.

If you have voluntary surgery or treatment (i.e. cosmetic), it should be scheduled in your own

time and you won’t receive CSP for any time off for treatment.

8.5. Fertility Treatment (IVF)

IVF treatment is not treated as sickness absence and requests for leave will be treated

sensitively and considerately. Managers should seek advice from the People Team if

required.

8.6. Injury at work

If your absence is the result of an accident/incident at work, then the accident/incident

reporting procedure should be followed in addition to this policy.

9. Equality and Diversity

9.1. We’re committed to equality of opportunity for all and to respecting the needs of our diverse colleagues and communities.

9.2. We recognise and value diversity within our organisation and the contribution a diverse

workforce makes to enhancing our services and understanding the needs of our colleagues

and customers.

9.3. We’re committed to developing an organisational culture which values people from all areas of society, the contribution that each individual can make and lets people choose to be

themselves at work.

9.4. We will go beyond the bare minimum in relation to diversity and inclusion – we’re strongly committed to making sure all our colleagues understand and welcome the differences in our society, and that we operate fairly for all our colleagues and customers so everyone has an pportunity to be included in our organisation.

9.5. We will promote and encourage diversity in everything that we do, ensuring we develop the capability to deliver our customer experience and ambitions for growth.

10. Legislation and Regulation

• Social Security Contributions and Benefits Act 1992

• Social Security Administration Act 1992

• Social Security (Incapacity for Work) Act 1994

• Statutory Sick Pay (General) Regulations 1982 (SI 1982/894)

• Employment and Support Allowance Regulations 2008 (SI 2008/794)

• Social Security Benefits Up-rating Order 2020 (SI 2020/234)

• Regulations 2020 (SI 2020/374)

11. Responsibilities

11.1 Colleagues

11.1.1. You are expected to do everything you can to maintain good health, and in the

event, you are unwell, to act reasonably and to return to work as soon as you can.

11.1.2. When you are unwell, you must email your line manager and email info@SportingAid.org as soon as you are aware that you’ll be unable to work, and well before your usual start time. The centre is open 24 hours a day, seven days a week, so you do not need to wait until the morning to call. You’ll need to contact your line manager for every occasion of absence, even if your absence is for less than one working day.

11.1.3. You must also call your manager on your first day of absence and keep in regular

contact. Contact on the first day must be made by phone call; subsequent contact

methods can be agreed with your line manager e.g. texting or emailing. In

exceptional circumstances, for example if you’re taken seriously ill and in hospital, a

relative or friend may call on your behalf until you are able to do so.

11.1.4. During the first week of absence, unless agreed otherwise with your manager, you

should maintain daily contact. Thereafter, unless otherwise agreed, you should

maintain weekly contact.

11.1.5. If your sickness absence continues for more than seven days (including any

weekends and non-working days), you must provide a fit note from your GP or

hospital to cover you from the eighth day of absence until you return to work. You

should retain the original and send a copy to your manager as soon as you receive

it.

11.1.6. Your first fit note should be provided on or before your eighth day of absence.

Subsequent fit notes should be provided prior to the expiry of your previous fit note.

11.1.7. If your doctor provides a certificate stating that you “may be fit for work” you should

inform your manager immediately so you can discuss any recommendations or

adjustments suggested by your doctor that will help your return to work. A copy of

this fit note must also be sent to your manager. If appropriate measures cannot be

taken, you’ll remain on sick leave and we’ll set a date to review the situation.

11.1.8. If you feel well enough to return to work before the date on your most recent fit note,

you should contact your doctor to obtain another certificate stating that you are fit to

return to work sooner, and send a copy to your manager and the People Team

before you return to work.

11.1.9. When you are well enough to return to work, you’ll need to call First Care to ‘close’

your absence. This is important so we can record that you’re back. If you registered

for text updates when you opened your absence, you’ll also be able to close your

absence by text.

11.1.10. You must participate in any meetings or Occupational Health appointments we

arrange for you and follow any medical advice you’re given. If you don’t attend, we’ll

make any decisions based on the information available.

11.1.11. Occasionally, we might ask you for a fit note or letter from your doctor for an

absence of fewer than seven calendar days. If we do, we’ll cover reasonable costs

you incur if you provide a valid receipt.

11.1.12. Any absence that hasn’t been notified according to the sickness absence procedure

will be treated as unauthorised. If you don’t report for work and haven’t contacted

your line manager to explain the reason for your absence, we’ll try to contact you by

telephone and in writing if necessary.

11.1.13. If you fail to follow the steps outlined in this policy and procedure, or we have reason to believe that you’ve not behaved in a way conducive to your recovery, or that your

sickness absence may not be genuine, your Company Sick Pay may be stopped

and an investigation may be conducted under the Disciplinary Policy and Procedure.

11.2 Managers

Managers will:

11.2.1 Assess each case individually and ensure consistency and fairness in application.

11.2.2 Lead on absence review meetings where a review point has been met, and set

attendance targets using discretion in case management.

11.2.3 Make contact with the colleague whilst they are off sick in the event that the

colleague doesn’t get in touch.

11.2.4 Make sure all sickness absence in their teams is recorded appropriately. This includes the uploading of fit notes.

11.2.5 Contact the People Team for further advice if there are repeated attendance or

absence issues that may need to be dealt with under the Disciplinary Policy and

Procedure, or if a medical issue is having a direct impact on a colleague’s capability

and performance.

11.2.6 On the colleague’s first day back from sick leave or within two days of their return

wherever possible, conduct a return to work meeting with your line manager and discuss

the absence and any support the colleague may need. In the event that the

manager is unavailable, this conversation should be held by another manager.

11.2.7 Where a manager is concerned about your health or your ability to carry out your

work safely, we may suspend you from work on medical grounds. This suspension

will be on full pay and may continue until you are found fit to work or certified as sick

by your GP or an independent medical professional.

11.3 People Team

The People Team will:

11.3.1 Make sure that sickness absence procedures are fairly and consistently applied with

no direct or indirect discrimination to colleagues.

11.3.2 Report on sickness absence statistics to managers.

11.3.3 Partner with and provide support to managers and colleagues where required.

Appendix 1 – Absence processes

Each attendance concern is unique so depending on the circumstances we may vary these

processes. Sporting Aid reserves the right to start a procedure at any stage of the process depending on the circumstances of the case. For example, if you have hit any of the Review Points outlined in section 5 of this policy, we may start the procedure at the next stage to the stage you had previously reached, even if any formal warnings have expired. If you wish, you can be accompanied at any formal meetings by a colleague or a union official – see Appendix 2 for more information.

You should make every effort to attend all meetings arranged for you; failure to attend without good reason may be treated as misconduct, and we may hold the meeting in your absence and reach a decision based on the information available. If you’re unable to attend with good reason, we’ll consider how else the meeting can go ahead as soon as reasonably possible. The options may include you providing a written statement instead of coming to the meeting, or holding the meeting by telephone or at a different venue.

A note-taker is provided for all formal meetings; therefore, you will not be allowed to use any

electronic devices to record meetings.

Any appeal you wish to submit in line with the processes below should be made in writing, stating the full grounds of appeal, to the person outlined in your outcome letter. You will be given reasonable written notice of an appeal meeting. Where practicable, an appeal meeting will be chaired by a manager senior to the Chair who conducted the absence meeting.

The appeals procedure won’t, except in special circumstances, re-hear a case. Grounds for appeal

can be one or all of the following:

• based on the decision that was reached

• the process that was followed

• the availability of new evidence.

The final decision will be confirmed in writing within five working days of the appeal meeting,

unless otherwise stated. There is no further right of appeal.

The date that any dismissal takes effect will not be delayed by an appeal; however, should a

decision to dismiss you be overturned following an appeal, you’ll be reinstated to your post and keep your original length of service

• Short-term absence process

Meeting Stage	Process	Outcome	Appeal
Informal Meeting	Your manager will meet with you to discuss your attendance level	You’ll be given a target to improve your attendance, which will be followed up in writing. This will be kept on your employment record.	There is no right of appeal
Stage 1	Should your attendance level continue to be a concern, or be serious enough to warrant skipping the informal stage, you will be invited to a formal absence meeting	You will be given a target to improve your attendance. You may also be issued with a first written warning for a period of six or 12 months. This will be kept on your employment record.	You have the right to appeal the outcome of the meeting. You must provide your written grounds of appeal within five working days of receiving the outcome
Stage 2	Should your attendance level continue to be a concern, you will be invited to a further formal absence meeting	You will be given a target to improve your attendance. You may also be issued with a final written warning for a period of six or 12 months. This will be kept on your employment record.	You have the right to appeal the outcome of the meeting. You must provide your written grounds of appeal within five working days of receiving the outcome
Stage 3	Should your attendance level continue to be a concern or if your absence reaches a review point while in your probationary period, you will be invited to a further formal absence meeting	Following the formal meeting you could be issued with an extension to your final written warning or be dismissed on capability grounds	You have the right to appeal the outcome of the meeting. You must provide your written grounds of appeal within five working days of receiving the outcome

• Long term absence process

Managers will normally start the long term absence process when you are absent for four weeks or more due to sickness.

There are normally four steps in the long term absence process:

Step Purpose

1 To introduce you to the long term absence process and give you an

opportunity to ask questions. We may also ask for your consent to

refer you to our Occupational Health Advisors.

2 To review the advice of Occupational Health and create a plan for

your return to work.

3 If you are unable to return to your original role, we will look at

suitable alternative options across the business.

4 If you have been unable to return to your original role, and we have

been unable to redeploy you to a suitable alternative position within

Sporting Aid, we will unfortunately have to consider dismissal due to ill

health. As this is a formal meeting, you’ll have the right to be

accompanied and be made aware of the possible outcomes of this

prior to the meeting. You will have the right to appeal this decision

within five working days of receiving the outcome in writing.

There’s no set timeframe for how long the above process will take, as this will be dependent on your individual case.

Permanent Health Insurance (PHI)

If you’re seriously unwell and unfit to return to work after a period of 26 weeks, or earlier if the advice from OH or other medical reports confirms there is no foreseeable return to work date, you may be eligible for Permanent Health Insurance under the Sporting Aid scheme. This is a noncontractual benefit and any referral to the scheme is at our discretion. Sporting Aid reserves the right to vary the terms of the scheme or remove the scheme at any time.

Eligibility for this benefit and the calculation of payments is subject to the terms and conditions of the insurance scheme and the insurer’s requirements. If you don’t comply with these terms and conditions or meet the insurer’s requirements, the insurer may decline or withdraw your claim. In such instances the insurer’s decision is final.

Appendix 2 – Individual companion support

This document sets out Sporting Aid support and arrangements for employee companions who have been asked by a colleague to support them in accordance with relevant Sporting Aid policies, including Grievance, Disciplinary, Capability and Sickness Absence

• Role of the companion

• You have the right to be accompanied at all formal hearings/meetings where you may be

issued a formal sanction as a result.

• Your companion may be a Sporting Aid colleague or a trade union representative. You may

not be accompanied by a friend, family member, or legal representative.

• The role of the companion is to provide support and guidance to you during the process.

They may help you prepare prior to the meeting, attend the meeting with you, put any

relevant questions to the Chair, and hold discussions with you during the meeting.

However, they are not able to respond to any questions on your behalf.

• If you intend to be accompanied, you must confirm to the People Team by email who

your companion will be no later than two working days before the meeting date.

• If you are unable to attend a meeting, you must notify the People Team by email no later

than two working days before the meeting date, and you must provide a reasonable and

acceptable reason for being unable to attend. If you are unable to attend a formal

meeting, you may choose to send representation with your companion.

• Although there is no statutory right for a colleague to be accompanied at an investigatory

meeting, Sporting Aid will allow a companion to be present if, by doing so, there is no delay

in holding the investigatory meeting.

• Your companion should make every effort to attend the meeting so as not to

unreasonably delay the process.

• Communication

• Employment processes and procedures are a matter between you and Sporting Aid;

therefore, all dialogue and communication is best managed between us directly. We will

copy an identified work colleague / trade union companion in responses and include

them in any appropriate individual consultation meetings where you advise us that this is

your wish, but this will always be in addition to the communication with you and not as

an alternative to it. It is obviously important that you are fully involved in all

communications that relate to you personally.

• In line with this principle, we will only be able to respond to communications from

companions where you are copied in and it is absolutely clear that your companion is

acting with your express authority. In these situations, the response will be addressed to

you and your companion will be copied.

• Where communications are received from companions on behalf of unidentified

individuals, we will not be able to respond as this would clearly be inappropriate.

• Outside of any formal meetings, if your companion has any queries relating to the case

or other matters, these should be directed to the People Team only.

• Conduct at meetings

• All those present must behave in a professional, respectful and courteous manner

throughout; this behaviour must be extended to both the process and the people

involved.

• The Chair may adjourn the meeting in the event of unreasonable behaviour by anyone

present.

4. Time off to provide support

• On request, work companions will be allowed reasonable paid time to accompany a

colleague at formal meetings and prepare for those meetings. What is reasonable

depends on the case, but would normally be no longer than an hour of preparation time

and the length of the meeting itself.

• Head of Operation approval must be requested for time off to support a colleague.

Companions must give no less than two days’ advance written notification of this time

off. The following information should be provided:

– Date/times/location/expected duration of absence.

– Brief description of activity and purpose i.e. that you are a companion at a

disciplinary, grievance or capability hearing.

• It is for the companion’s Head of Operation to determine whether they can be released to

support a work colleague. Heads of Operation are expected to grant all reasonable

requests for time off by companions. Where a Head of Operation has any doubts about

approving a companion’s request for time off, they should seek advice from the People

Team.   

• If an individual believes that the support arrangements have been unreasonably

refused, they should raise this immediately with the Executive Director of People

and Culture

Responsible officer: Secretary

Scope:

This policy applies to volunteers engaged by the Sporting Aid organisation including. It may include student/educational placements, short term work experience, ad-hoc community projects/groups and other projects or events.

Summary:

This policy outlines the principles upon which the relationship between volunteers and the

organisation is based. It provides basic information about volunteering and what it means to be a volunteer.

The purpose of this policy is to ensure that:

• The role of volunteers is clearly defined

• There is clarity around what we expect from volunteers

• Volunteers feel valued and supported, and have the necessary training and skills to

  volunteer successfully

• Volunteers find their time with us enjoyable and rewarding

Context:

Volunteers are the link to communities in which we operate. This policy will support the Corporate Strategy aims by getting closer to our customer through the engagement of volunteers in our organisation.

Regulatory and Legal Compliance:

This policy adheres to the following legislation, in connection with the recruitment and selection of volunteers:

• The Rehabilitation of Offenders Act 1974 (Exceptions) order 1975

• Asylum and Immigration Act 1996

• Data Protection Act 1998

• Safeguarding Vulnerable Groups Act 2006

• The Equality Act 2010

Depending on the activity they are involved in our volunteers may be required to have a Disclosure Barring Service (DBS) check. Please refer to the Disclosure and Barring Service (DBS) Policy for more information.

Detail:

• Commitment to Volunteering

Sporting Aid recognises the value and contribution of volunteers in the business. Volunteers are the link to communities in which we operate and contribute strongly to our aims, objectives and values.

• The Volunteering Relationship

The volunteering relationship is outlined in the Volunteer Agreement which is issued at the start of the volunteer assignment. This agreement does not create an employment contract but outlines

what’s expected of the volunteer and what the volunteer can expect from us. The volunteering relationship may be cancelled at any time by either party.

No payment, other than the reimbursement of agreed expenses, is made by Sporting Aid to volunteers.

The rights of any original works, such as photography or written work, produced by a volunteer will belong to Sporting Aid, unless otherwise agreed.

• Recruitment

We aim to promote an equal and diverse workforce and will recruit and support volunteers in

accordance with our Equality Scheme.

• Responsibilities and Expectations

4.1 Sporting Aid responsibilities:

• To provide an open and inclusive culture, which respects and values the benefits of

volunteers

• To provide information about Sporting Aid policies, processes and procedures

• To provide access to appropriate induction, training and support

• To ensure every volunteer is briefed on and understands the Health and Safety Policy and

any related Health and Safety procedures associated to their volunteering work

• To make the necessary arrangements to ensure every volunteer’s health, safety and

wellbeing

• To provide access to trained employees, to support, guide, advise and provide feedback

which maximises contribution and performance

• To reimburse out of pocket expenses in accordance with the Expenses Policy and

Procedures

4.2. Expectations of volunteers:

• To work in partnership with other volunteers, employees and customers

• To support, respect and adhere to Sporting Aid policies, procedures and processes

• To take reasonable care for their own health and safety and of others who may be affected

by their acts or omissions

• To support and implement management decisions

• To protect any personal or confidential information to which they may have access

throughout and after their volunteering period

• To always consider and protect Sporting Aid brand and reputation through their actions and

conduct

• To act responsibly and within the law

• To aim for high standards of performance, reliability and quality

• To have the best possible experience by getting involved and enjoying their volunteering

time with Sporting Aid.

Measurements:

The success of volunteers will be measured by the feedback received via customers and

employees about the value and benefits of having volunteers and their overall contribution and effectiveness. This may be supported by Impact Assessments, which evaluate the volunteering experience and opportunities made available to them.

Review this document in conjunction with:

• Code of Conduct

• Health and Safety Policy

• Expenses Policy

• Equality Scheme

• Recruitment and Selection Policy

• Disclosure and Barring Service (DBS) Policy

• Safeguarding Policy

• Volunteer Agreement

Equality and Diversity Issues

We are committed to embracing diversity and promoting equality and inclusion for all our

volunteers. All volunteers will be a representative group of Sporting Aid, its customers and employees.

We will make any reasonable adjustments and provide support for any volunteers who have

specific requirements and needs, for example, a disability or a language support need.

• Introduction

• • At Sporting Aid, we’re committed to the highest standards of quality, integrity and accountability and ensuring that any malpractice, should it occur, is dealt with immediately.

• • We are all responsible for protecting our standards and speaking up if we become aware of any suspected wrongdoing. We encourage transparency, openness and feedback and see whistleblowing as a vital means of tackling wrongdoing in the workplace.

• • The aims of this policy are:

• to encourage you to raise any concerns you have about poor practice at

Sporting Aid without fear of repercussions

• to reassure you that your concerns will be taken seriously

• to let you know how to raise your concerns.

• • We will raise awareness of this policy and our Code of Conduct through our induction and training programmes. We’ll also encourage people and organisations who work on our behalf to adopt this policy or a similar approach.

• Scope

• • This policy applies to Sporting Aid and all its subsidiaries. It applies to all colleagues, board and committee members and others working on our behalf.

• What is whistleblowing?

3.1 Whistleblowing is disclosing information about serious wrongdoing or dangers at work.

You’re protected by law if you report any of the following:

• actual or suspected criminal offence

• miscarriage of justice

• serious health and safety risks

• financial malpractice or impropriety (including tax evasion)

• fraud

• damage to the environment

• failure to comply with legal obligations

• deliberate suppression or concealment of any of the above.

3.2 A whistleblower is a person who raises a concern linked to one of the above. So, if you have any genuine concerns – based on factual information – related to suspected wrongdoing or danger in relation to any of our activities, you should report it under this policy.

3.3 If you have concerns which are not covered by this policy, you can raise them in other ways:

• Complaints relating to your personal circumstances, such as the way you are

treated at work or your terms and conditions of employment – You should

raise these concerns to your manager, in line with our Grievance Policy and

Board and Committee Member Disputes Policy.

• General concerns relating to third parties (eg suppliers and contractors) – You

should direct these concerns to the supplier in line with the terms of our

contract with them.

• Safeguarding concerns about someone who does not work for us (eg the

Whistleblowing Policy abuse of a participants) – You should refer to our Safeguarding Policy.

3.4 If you’re not sure whether something is within the scope of this policy, you can always speak – in confidence – to the Head of Operation. Sporting Aid colleagues can also speak to the Sporting Aid Chief Executive.

• How do we protect whistleblowers?

• • We follow these principles when we deal with allegations under this policy:

• Protection and support. We aim to safeguard everyone involved in a

whistleblowing investigation and ensure that a fair process is followed.

• Confidentiality. We will treat any information you give us confidentially, and

expect you to do the same.

• Anonymity. We will take all reasonable steps to protect your anonymity.

• Protection against repercussions. We understand that whistleblowers

might be worried about possible repercussions. We encourage openness at

Sporting Aid so we will protect and support you if you raise a genuine concern

under this policy, even if you turn out to be wrong. However, if you abuse this

process on purpose, for example by making a malicious allegation that you

know is not true, this may be treated as a disciplinary matter.

• Straightforward process. We aim to make it easy for colleagues to raise

any concerns under this policy.

• • Whistleblowers making a disclosure are legally protected from reprisal if:

• they believe the disclosure is made in the public interest

• they believe it is true

• it is not made for personal gain

• the information meets the criteria of a ‘qualifying disclosure’ – ie it discloses

acts or omissions which show or tend to show a whistleblowing concern.

• How to raise a concern

5.1 You will find more information about how you can raise a concern in the Whistleblowing

Procedure.

• Legislation and Regulation

6.1 Key legislation affecting this Policy includes the Public Interest Disclosure Act 1998,

Enterprise and Regulatory Reform Act 2013, and the Criminal Finances Act 2017.

• Responsibilities

• • The Company Secretary has overall responsibility for the maintenance and operation of this policy. This includes keeping a record of concerns raised and the outcomes of investigations (in a confidential format) and reporting them as necessary to the Audit and Risk Committee, Group Board and any relevant subsidiary boards.

• • The Executive Committee makes sure that all cases of whistleblowing are dealt with in line with this policy, with guidance from relevant teams and colleagues. If a complaint relates to any member of the Executive Committee that member will not be involved in investigating or Whistleblowing.reviewing it. It also makes sure that colleagues, board and committee members receive regular training on whistleblowing.

7.3 The Audit and Risk Committee approves this policy and the approach set out in it. They also review any significant or material whistleblowing events to make sure that our whistleblowing arrangements are adequate and secure