Accessing and use of Strategic Resources European Recruitment Consultants Ltd (known as Strategic Resources) website constitutes your acceptance of the following terms and conditions:
This site is only for lawful purposes.
This site should not be used for transmitting unlawful, defamatory, obscene or offensive data, or material that may be deemed criminal. Strategic Resources will work with the relevant authorities and will identify anyone using the website unlawfully or in an inappropriate manner.
Whilst every effort is made to ensure the accuracy of the content of this site, Strategic Resources accept no responsibility or liability arising from the content, errors or omissions that may occur.
Whist there are links to other websites through Strategic Resources site, these links are not under our control and we cannot accept any responsibility for the content. We offer no guarantee of the availability of the links. Whilst links are used on our site, Strategic Resources take no responsibility for the content of these links and it should not be construed as endorsement of their material.
Strategic Resources operate a stringent virus control programme. We recommend that individuals and businesses run anti-virus programmes for their own safety. We do not accept any responsibility for loss, damage or disruption to data or computer systems whilst using this site or links associated with this site.
The Company is committed to the principle of equal opportunity in employment.
The terms equality, inclusion and diversity are at the heart of this policy. ‘Equality’ means ensuring everyone has the same opportunities to fulfil their potential free from discrimination. ‘Inclusion’ means ensuring everyone feels comfortable to be themselves at work and feels the worth of their contribution. ‘Diversity’ means the celebration of individual differences amongst the workforce. We will actively support diversity and inclusion and ensure that all our employees are valued and treated with dignity and respect. We want to encourage everyone in our business to reach their potential.
We value people as individuals with diverse opinions, cultures, lifestyles and circumstances. All job applicants, employees and workers (including agency workers) are covered by this policy and it applies to all areas of employment including recruitment, selection, training, career development, and promotion. These areas are monitored and policies and practices are amended if necessary to ensure that no unfair or unlawful discrimination, intentional, unintentional, direct or indirect, overt or latent exists.
Equality of opportunity, valuing diversity and compliance with the law is to the benefit of all individuals in our Company as it seeks to develop the skills and abilities of its people. While specific responsibility for eliminating discrimination and providing equality of opportunity lies with managers and supervisors, individuals at all levels have a responsibility to treat others with dignity and respect. The personal commitment of every employee to this policy and application of its principles are essential to eliminate discrimination and provide equality throughout the Company.
Management will ensure that recruitment, selection, training, development and promotion procedures result in no job applicant, employee, or worker receiving less favourable treatment because of a protected characteristic within the Equality Act 2010 which are race (including colour, nationality, ethnic or national origin and caste), religion or belief, disability, sex, sexual orientation, pregnancy or maternity, gender reassignment, marriage/civil partnership and age. In accordance with our overarching equal treatment ethos, we will also ensure that no-one is treated less favourably on account of their trade union membership or non-membership, or on the basis of being a part-time worker or fixed term employee. The Company’s objective is to ensure that individuals are selected, promoted, and otherwise treated solely on the basis of their relevant aptitudes, skills and abilities.
We will ensure that the policy is circulated to any agencies responsible for our recruitment and a copy of the policy will be made available for all employees and made known to all applicants for employment.
The policy will be communicated to all private contractors reminding them of their responsibilities towards the equality of opportunity.
The policy will be implemented in accordance with the appropriate statutory requirements and full account will be taken of all available guidance and in particular any relevant Codes of Practice.
Management has the primary responsibility for successfully meeting these objectives by:
not discriminating in the course of engagement against employees, workers or job applicants;
not inducing or attempting to induce others to practise unlawful discrimination;
bringing to the attention of our workforce that they may be subject to action under the disciplinary procedure, or other appropriate action, for unlawful discrimination of any kind.
You can contribute by:
not discriminating against fellow employees, workers, customers, suppliers or members of the public with whom you come into contact during the course of your duties;
not inducing or attempting to induce others to practise unlawful discrimination;
reporting any discriminatory action to [Manager]. .
The successful achievement of these objectives necessitates a contribution from everyone and you have an obligation to report any act of discrimination known to you.
If you consider that you are a victim of unlawful discrimination you may raise the issue through the grievance procedure.
DEFINITIONS
Throughout this document the following shall apply:
“Agency Worker” PAYE Agency Worker
“Candidate” Registered Candidate
“Client” Client companies where services are provided
“Consultancy” Limited Company Contractor or Umbrella Company Contractor
“Contractor” PAYE Agency Worker or Consultancy
“Employee” Staff member of Strategic Resources
“Relevant Person” Registered Candidate, Contractor or any corporate entity who performs functions for or on behalf of the Company
“Strategic Resources” Strategic Resources European Recruitment Consultants Ltd
Introduction
Strategic Resources whose registered address is Migvie House, 23 North Silver Street, Aberdeen, AB10 1RJ, is committed to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act). This document summarises how Strategic Resources operates, the policies and processes in place to minimise the possibility of any problems, risks identified and how they are monitored and the training of Employees.
Strategic Resources’ Business
Strategic Resources is a limited company business operating in the recruitment sector supplying temporary, contract and permanent recruitment services, Contractor Management Services and payroll services in the commercial, admin and engineering sectors of business.
Strategic Resources is part of the wider CorpAcq Ltd group. For details of our group structure, see https://www.corpacq.com/
Provision of Services
Clients and Relevant Persons are known to and identified by Strategic Resources’ Employees and registered in the Strategic Resources database.
Clients are mainly located in the UK and Europe. Relevant Persons live mainly in the UK and Europe.
Other relationships
As part of Strategic Resources’ business with the following organisations are used:
First Point Assessment
the Recruitment and Employment Confederation (https://www.rec.uk.com) and/or the Institute of Recruitment Professionals (https://www.rec-irp.uk.com)
Policies
In addition to the Modern Slavery Policy, Strategic Resources policies incorporate ethical standards for Employees, Relevant Persons, Clients and suppliers. Policies which can be read in conjunction with this Policy include:
Anti-Bribery and Corruption Policy;
Privacy and Data Protection Policy;
Business Ethics Policy;
Health, Safety and Environmental Policy;
Policy development and review
Strategic Resources’ policies are established by the senior management team, based on advice from HR professionals, industry best practice and legal advice. Policies are reviewed regularly or as required to adapt to changes.
Processes for Managing Risk
In order to assess the risk of modern slavery with suppliers:
Additionally, the following steps have been taken to minimise the possibility of any problems:
Employees are encouraged to bring any concerns they have to the attention of senior management.
Performance
As part of performance monitoring, Strategic Resources track the following general key performance indicators:
Verification of identity and right to work. Right to Work checks are carried out on Relevant Persons in line with the Home Office requirements;
The level of modern slavery training and awareness amongst Employees.
Our indicators are carefully considered in order to ensure there is no undue pressure on suppliers that might increase the potential for risk.
Training
Employees receive awareness-raising information around issues involving modern slavery and human trafficking, enabling them to bring any concerns they may have to the attention of senior management. Situations may be reported to the police or Modern Slavery Helpline on 0800 0121 700.
Sanctions for breach of this Policy
Breach of this policy by any Relevant Person or corporate entity could lead to the suspension or termination of any relevant contract, sub-contract or other agreement between the Relevant Person, the corporate entity and Strategic Resources.
This Policy is made pursuant to section 54(1) of the Modern Slavery Act 2015.
DEFINITIONS
Throughout this document the following shall apply:
“Agency Worker” PAYE Agency Worker
“Bribe” an inducement or reward offered, promised or provided in order to gain any commercial, contractual, regulatory or personal advantage; “to Bribe” and “Bribery” are construed accordingly
“Candidate” Registered Candidate
“Client” Client companies where services are provided
“Consultancy” Limited Company Contractor or Umbrella Company Contractor
“Contractor” PAYE Agency Worker or Consultancy
“Employee” Staff member of Strategic Resources
“Relevant Person” Registered Candidate, Contractor or any corporate entity who performs functions for or on behalf of the Company
“Strategic Resources” Strategic Resources European Recruitment Consultants Ltd
Introduction
One of Strategic Resources’ core values is to uphold responsible and fair business practices and to be committed to promoting and maintaining the highest level of ethical standards in relation to all business activities. Strategic Resources’ reputation for maintaining lawful business practices is of paramount importance and this Policy is designed to preserve these values and have a zero tolerance towards bribery and corruption, be committed to acting fairly and with integrity in all of its business dealings and relationships; implementing and enforcing effective systems to counter bribery.
Purpose and scope of this Policy
This Policy sets out the steps all of us must take to prevent bribery and corruption in the business and to comply with relevant legislation. It is aimed at:
ensuring compliance with anti-bribery laws, rules and regulations, not just within the UK but in any other country within which Strategic Resources may carry out its business or in relation to business which it may be connected;
enabling any Relevant Person to understand the risks associated with bribery and to encourage them to be vigilant and effectively recognise, prevent and report any wrongdoing, whether by themselves or others;
providing suitable and secure reporting and communication channels and ensuring that any information that is reported is properly and effectively dealt with;
creating and maintaining a rigorous and effective framework for dealing with any suspected instances of bribery or corruption.
All Relevant Persons are expected to adhere to the principles set out in this Policy.
The Bribery Act 2010
The Bribery Act 2010 (the Bribery Act) came into force on 1 July 2011.
Under the Bribery Act it is an offence to:
Bribe a person i.e. to offer, promise or give a financial or other advantage to another person, whether within the UK or abroad, with the intention of inducing or rewarding improper conduct;
Receive a Bribe i.e. to request, agree or receive or accept a financial or other advantage for or in relation to improper conduct;
Bribe a foreign public official;
Fail to prevent Bribery;
Risks of not acting with integrity.
Involvement in Bribery or corruption carries many risks. Among them are:
A company which pays or accepts Bribes is not in control of its business and is at risk of blackmail;
If the Company is found guilty of Bribery or even failing to have adequate procedures in place to prevent Bribery, it will be subject to unlimited fines;
Any person found guilty of Bribery will be subject to fines and/or imprisonment of up to 10 years;
A public exposure, or even allegation, of bribery would entail severe reputational damage. The Company’s banking or supply facilities might be withdrawn to be available on much less favourable terms, and the Company could be blacklisted as an approved tenderer for both public and private sector contracts;
The cost of our insurance cover would increase very significantly;
Good people will not want to work for us.
Benefits of acting with integrity
Equally, there are very clear benefits to acting with propriety. These include:
Increasing Strategic Resources’ chances of being selected as a supplier in both the public and private sectors;
Remaining in good standing with banks and suppliers;
Being a business with high ethical standards is a good place to work;
Being a requirement of the REC Code of Professional Practice, that Strategic Resources acts with integrity at all times.
Policy statement
All Relevant Persons are required at all times:
not to commit an offence listed above at section 4 or any other offence;
to comply with the Bribery Act and any anti-bribery and anti-corruption legislation that applies in any jurisdiction in any part of the world in which they might be expected to conduct business;
to act honestly, responsibly and with integrity;
to safeguard and uphold the Company’s core values by operating in an ethical, professional and lawful manner at all times.
Bribery of any kind is strictly prohibited. Under no circumstances should any provision be made, money set aside or accounts created for the purposes of facilitating the payment or receipt of a Bribe. Strategic Resources’ recognise that industry practices may vary from country to country or from culture to culture.
What is considered unacceptable in one place may be normal or usual practice in another. In this instance the Relevant Person should seek appropriate guidance from a Director. All Relevant Persons are expected to adhere strictly at all times to the guidelines set out in this Policy. If there is any doubt as to what might amount to bribery or what might constitute a breach of this Policy, refer the matter to a Director.
Gifts and hospitality
Strategic Resources may occasionally provide gifts and hospitality to Clients, Contractors and suppliers. This is not prohibited by the Bribery Act provided the following requirements are met:
The gift is not made with the intention of influencing a third party to obtain or retain business or a business advantage, or to reward the provision or retention of business or a business advantage;
It complies with local laws;
It is given in the name of Strategic Resources, not in the giver’s personal name;
It does not include cash or cash equivalent (such as gift vouchers)
It is of an appropriate and reasonable type and value and given at an appropriate time;
It is given openly, not secretly;
It is approved in advance by a Director.
In summary, it is not acceptable to give, promise to give or offer, a payment, gift or hospitality with the expectation or hope that a business advantage will be received, or to reward a business advantage already given, or to accept a payment, gift or hospitality from a third party that you know or suspect is offered or provided with the expectation that it will obtain a business advantage for them.
Facilitation payments
Any payment or gift to a public official or other person to secure or accelerate the prompt or proper performance of a routine government procedure or process, otherwise known as a “facilitation payment”, is also strictly prohibited. Facilitation payments are not commonly paid in the UK but they are common in some other jurisdictions.
Common indicators of corruption include those listed below. There may well be others. For example:
Payments are for abnormal amounts (e.g. commission), or made in an usual way, e.g. what would normally be a single payment is made in stages, through a bank account never previously used, or in a currency or via a country which has no connection with the transaction;
Process is bypassed for approval or sign-off of terms or submission of tender documents, payments, or other commercial matters; those whose job it is to monitor commercial processes (e.g. Director) may be prevented from or hindered in doing so;
Individuals are secretive about certain matters or relationships and/or insist on dealing with them personally. They may make trips at short notice without explanation, or have a more lavish lifestyle than expected;
Decisions are taken for which there is no clear rationale;
Records are incomplete or missing.
Political contributions
You should be aware that such contributions can be (or be seen as) bribes in disguise. We do not make donations to political parties. No individual is to make a donation stated to be, or which could be taken to be, on our behalf without the prior approval of a Director. You may, of course, make political donations in a personal capacity but please be sensitive to how such contributions could be perceived, especially by those who are aware of your connection with the Company.
Charitable donations
Bribes may even be disguised as charitable donations. Again, for that reason, donations we make are approved by resolution of a Director and recorded. Whilst Relevant Persons may of course make personal donations to charity, they should not do so on behalf of the Strategic Resources without prior approval from a Director.
Local circumstances
It is understood that different parts of the world have different social and cultural customs. This does not affect the position of Strategic Resources that no Bribes shall be paid or accepted or to act corruptly. However, subject to that position, it is understood that there may be a need to be sensitive to local customs e.g. there are cultures in which refusing (or even failing to offer) a gift is considered impolite and could alienate a key contact. In such cases, please refer to a Director for establishing variations to this Policy.
Exceptional circumstances
In some circumstances a payment is justifiable. If a Relevant Person is faced with a threat to his or her personal safety if a payment is not made, they should pay it without fear of recrimination. In such cases, however, a Director must be contacted as soon as possible, and the payment and the circumstances in which it was made must be fully documented and reported to the Managing Director within 2 working days.
Such cases will be rare. All Relevant Persons visiting regions where the acceptance of gifts or payments is accepted, should familiarise themselves, prior to travel, with current guidance relating to those countries. A Director should be consulted if in doubt. For general information on travelling to a particular country, please consult the latest information from the Foreign and Commonwealth Office.
Responsibility to report and the reporting process
It is the contractual duty and responsibility of all Relevant Persons to take whatever reasonable steps are necessary to ensure compliance with this Policy and to prevent, detect and report any suspected Bribery or corruption. All Relevant Persons have a duty to prevent, detect and report any incident of Bribery and any potential risks of Bribery. If you know or suspect that any Relevant Person plans to offer, promise or give a bribe or to request, agree to receive or accept a bribe in connection with the business of the Company, you must disclose this to a Director as quickly as possible to allow appropriate action to be taken promptly.
Strategic Resources is committed to taking appropriate action against Bribery and corruption. This may include either reporting the matter to an appropriate external government department, regulatory agency or the police and/or taking internal disciplinary action against Relevant Persons and/or terminating contracts with Associated Persons.
Strategic Resources will keep any disclosure confidential during an investigation to the extent that this is practical and appropriate in the circumstances. Support will be provided to anyone who raises genuine concerns in good faith under this Policy, even if they turn out to be mistaken. Strategic Resources is also committed to ensuring nobody suffers any detrimental treatment as a result of refusing to take part in Bribery or corruption, or because of reporting in good faith their suspicion that an actual or potential Bribery or corruption offence has taken place or may take place in the future or because they may assist in the investigation of an allegation of Bribery or corruption.
Record keeping
All accounts, receipts, invoices and other documents and records relating to dealings with third parties shall be prepared and maintained with strict accuracy and completeness. No accounts will be kept “off the record” to facilitate or conceal improper payments.
Monitoring compliance
The Managing Director has primary responsibility for ensuring compliance with this Policy, reviewing its contents and monitoring its effectiveness ensuring this Policy complies with the Company’s legal and ethical obligations. Feedback will be provided to the other Directors.
Training
Strategic Resources shall provide training to all Employees to help them understand their duties and responsibilities under this Policy. The zero tolerance approach to Bribery will also be communicated to business partners at the outset of the business relationship with them and as appropriate thereafter.
Sanctions for breach of this Policy
A breach of any of the provisions of this Policy by an Employee of the Strategic Resources will constitute a disciplinary offence and will be dealt with in accordance with Strategic Resources’ disciplinary procedure. Depending on the gravity of the offence, it may be treated as gross misconduct and could render the Employee liable to summary dismissal.
Breach of this policy by any Contractor providing services to the Company may lead to the immediate termination of that Contractor’s Agreement.
Breach of this policy by any Relevant Person or corporate entity, could lead to the suspension or termination of any relevant contract, sub-contract or other agreement between the Relevant Person, the corporate entity and Strategic Resources.
DEFINITIONS
Throughout this document the following shall apply:
“Agency Worker” PAYE Agency Worker
“Client” Client companies where services are provided
“Consultancy” Limited Company Contractor or Umbrella Company Contractor
“Contractor” PAYE Agency Worker or Consultancy
“Employee” Staff member of Strategic Resources
“Relevant Person” Registered Candidate, Contractor or any corporate entity who performs functions for or on behalf of the Company
“Strategic Resources” Strategic Resources European Recruitment Consultants Ltd
Strategic Resources’ goal is to maintain the highest standards of ethics, professionalism and business conduct as well as ensure business is conducted in strict compliance with the law at all times. Senior management will not tolerate any behaviour or practice that compromises Strategic Resources’ integrity or honesty. All decisions will be fair and based on transparent processes.
Compliance
Strategic Resources aims to maintain high ethical standards in carrying out its business activities, practices of any sort that are incompatible with business principles and policies will not be tolerated. Strict adherence to these principles and supporting policies is a condition of employment. The Managing Director has overall responsibility for ensuring compliance with the objectives of this Policy.
Independence and Objectivity
Strategic Resources is committed to being fair, transparent and impartial in all business transactions and Employees are expected to adhere to specific standards of behaviour, namely:
To act in a way that is unbiased, and they must not be subject to any influence which may lead them to favour any particular person or organisation;
Other than the salary paid by Strategic Resources, Employees may not directly or indirectly accept any form of payment or material benefit from third parties for services they perform on behalf of Strategic Resources;
Declare in writing any financial or personal interest, direct or indirect, in another company which is either a supplier to or a competitor of Strategic Resources.
Modern Slavery Act 2015
Strategic Resources is committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses.
Employees and any Relevant Persons Strategic Resources may supply (directly or indirectly) shall not be subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses.
Unethical Behaviour and ‘Whistle-Blowing’
Strategic Resources promotes a working environment which encourages all team members to express their concerns about behaviour or decisions they perceive to be unethical without fear of reprisal or victimisation. Any Relevant Person who requires guidance or advice on business ethics or slavery to human trafficking issues should speak to the Managing Director.
The Managing Director is responsible for initiating and supervising the investigation of all reports of breaches of these principles and policies and ensuring that appropriate disciplinary action is taken when required.
Employment Policies
Strategic Resources is committed to attaining the highest standards of employment practice and wishes to be recognised as a good employer. It is committed to communicating its strategy and objectives to Employees and to keeping them informed on the progress against the strategy and objectives.
Strategic Resources supports and promotes the ethos and principles of equal opportunities in employment, striving to create a culture where Relevant Persons and every member of the team is treated fairly and without fear of harassment or victimisation for any reason.
Balancing Transparency with Confidentiality
Strategic Resources will:
Be transparent in all of its operations except where it is constrained by issues of confidentiality;
will strive to communicate clearly and succinctly in order to minimise complexity in business dealings;
Comply with the provisions of the Data Protection Act and members of staff will be trained accordingly.
Protecting Business Assets
All Employees are:
Required to avoid waste and extravagance and are encouraged to identify improvements to systems and procedures to achieve optimal effectiveness, efficiency and responsiveness;
Expected to follow agreed procurement procedures when commissioning third party services. They are also bound by Strategic Resources’ Business Expenses Policy when incurring business expenses.
Strategic Resources’ assets and funds may only be used for the legitimate business purposes of the company.
Suppliers, Clients and Contractors
Strategic Resources will aim to develop relationships with its suppliers, Clients and Contractors based on mutual trust and shared values. Therefore:
All Employees will conduct business with suppliers, Clients and Contractors in a professional manner;
Strategic Resources will pay its suppliers, advisers and agents on time and according to agreed terms;
As far as is practicable, will engage with our business partners on matters relating to Corporate Responsibility;
No incentives shall be offered in return for business opportunities.
Competitors
Strategic Resources will:
Compete in a lawful manner;
Not seek to damage the reputation of competitors, either directly or by implication or innuendo;
Avoid discussing proprietary or confidential information in any contacts with competitors;
Not attempt to acquire information regarding a competitor’s business by unlawful means, including industrial espionage, hiring competitors’ employees to obtain confidential information, urging competitors’ Employees, Clients or occupiers to disclose confidential information, or any other approach that is not above board.
Governance and Financial Matters
Strategic Resources will:
Comply with all laws, rules and government regulations that are applicable to the company;
Maintain accurate business records, following best practice in all respects;
Maintain financial statements and accounts in a manner that are accurate and auditable.
Contractual Arrangements
Strategic Resources is committed to meeting its contractual commitments and will build relationships with its suppliers, agents and contracted service providers based on mutual trust.
All Employees are expected to understand and comply with the terms of the contracts for which they have a responsibility.
PURPOSE
The purpose of this Corporate Social Responsibility (CSR) Policy is to outline Strategic Resources European Recruitment Consultants commitment to ethical business practices, sustainability, and contributing positively to society and the environment. This Policy reflects our dedication to corporate citizenship and social responsibility by promoting responsible business conduct.
SCOPE
This Policy applies to all employees, contractors, vendors, and authorised representatives acting on behalf of Strategic Resources European Recruitment Consultants. It encompasses all aspects of CSR, including environmental stewardship, ethical business conduct, and community engagement.
POLICY STATEMENTS
Ethical Business Conduct
Strategic Resources European Recruitment Consultants is committed to conducting business with the highest ethical standards, integrity, and transparency. We will comply with all applicable laws and regulations in all jurisdictions where we operate.
Environmental Stewardship
Strategic Resources European Recruitment Consultants acknowledges the importance of environmental sustainability. We will strive to reduce our environmental footprint by:
Reducing energy consumption.
Minimising waste and promoting recycling and responsible disposal practices.
Implementing eco-friendly initiatives and practices in our business.
Evaluating and mitigating environmental risks associated with our business activities.
Social Responsibility
Strategic Resources European Recruitment Consultants is dedicated to positively impacting the communities where we operate. We will engage in initiatives that support education, social welfare, and community development.
Diversity and Inclusion
We believe in fostering a diverse and inclusive workplace where all employees are treated with respect and provided equal opportunities for growth and development.
Human Rights
Strategic Resources European Recruitment Consultants is committed to upholding the rights and well-being of our employees and those throughout our supply chain. We will not tolerate forced labour, child labour, or any form of exploitation.
Transparency and Reporting
We will maintain transparency in our CSR efforts and report regularly on our progress, achievements, and challenges. This information will be shared with stakeholders and the public.
Community Engagement
Strategic Resources European Recruitment Consultants encourages employees to actively participate in volunteer and charitable activities. We support and recognize employee efforts to give back to their communities.
Supply Chain Responsibility
We will work with our suppliers and partners to promote responsible and sustainable practices throughout our supply chain.
RESPONSIBILITIES
Employees: Responsible for adhering to this Policy, actively participating in CSR activities, and promoting ethical business conduct within the organization.
Management: Responsible for supporting and promoting CSR efforts, providing resources, and aligning business strategies with CSR goals.
COMPLIANCE AND CONSEQUENCES
Non-compliance with this Corporate Social Responsibility Policy may result in corrective actions in accordance with Strategic Resources European Recruitment Consultants policies and procedures. Disciplinary actions may include verbal counseling, written warnings, or other appropriate measures, depending on the severity and frequency of the violation.
POLICY REVIEW
This Corporate Social Responsibility Policy will be reviewed annually or more frequently if necessary. Updates or changes to the Policy will be communicated to all relevant personnel to ensure continued adherence to CSR guidelines.
Health, safety and environment is of paramount importance. It is Strategic Resources’ to prevent accidents, manage occupational ill health and where possible, eliminate hazards in the workplace and to minimise the impact that our business may have on the environment. It is Strategic Resources’ intention to:
Provide a safe and healthy workplace for all our Employees. This will include the provision of risk assessments, safe systems of work, safe equipment and premises. Strategic Resources will ensure that adequate information, instructions, training and supervision is provided to ensure that all employees can carry out their work safely.
As a minimum, purchase environmentally friendly office supplies (including recycled paper) and cleaning products, minimise the generation of waste and promote recycling, turn off lights and other electrical equipment including heating / printers / photocopiers when not in use and use refillable ink cartridges and recycle ink cartridges where possible.
Ensure that others who are affected by our activities are not subjected to risks to their health, safety and to promote a socially responsible attitude to the environment to all Relevant Persons including visitors, customers, contractors, agency workers and members of the public.
The establishment of an effective Safety Management System and Health, Safety and Environmental Policy within Strategic Resources will achieve these intentions. This will involve the implementation of arrangements for the effective planning, organising, control, monitoring and review of preventative and protective measures.
It is recognised that activities and processes undertaken may present a risk to the health and safety of Employees and any Relevant Persons. These risks shall be minimised by the provision of trained, competent and appropriately qualified personnel. Strategic Resources shall discharge its responsibilities in this respect by its strict adherence at all management and personnel levels to the requirements of the Health and Safety at Work Etc Act 1974 and to other relevant legislation and codes of practice.
Any Relevant Person based onshore will be subject to Strategic Resources’ and / or Client’s Health, Safety and Environmental Policies pertaining to their work location. Where working offshore, Relevant Persons are required to abide by the Government safety legislation and the rules and regulations of the operator controlling the work site.
Health, safety and environmental standards shall be maintained with the co-operation of all Employees and Relevant Persons – all Staff and Contractors have a legal and moral duty to ensure that this standard is upheld and maintained. The effective implementation of health, safety and environmental objectives by all levels of Management, Employees and Relevant Persons will ensure that the company continues to achieve its business goals. In addition, Strategic Resources will ensure that all visitors and Relevant Persons are provided with the information they require to enable them to comply with this policy.
The effectiveness of the policy will be regularly monitored by Management to ensure that health, safety and environmental arrangements are being implemented and that those with responsibility for the implementation of the policy are discharging their duties accordingly. The policy will be reviewed annually and revised where necessary. All Employees will complete a range of training relevant to their roles to ensure a sufficient level of awareness and competence to assist in the implementation of this policy.
Adopted and revised by Strategic Resources June 2025.
Registered Office Address: CorpAcq House, 1 Goose Green, Altrincham, Cheshire, WA14 1DW Whistleblowing Policy
The following document sets out the policy of CorpAcq Limited (“the Company” / ”CorpAcq”) on whistleblowing. It is important that every employee is aware of their obligations under this Policy, and any queries should be addressed to your Line Manager.
Purpose
We recognise that staff are often the first to realise that something may be wrong within the organisation, so staff are encouraged to raise reasonable concerns about wrongdoing at the earliest possible stage. This is known as ‘whistleblowing’.
The aims of this policy are:
To encourage staff to report suspected wrongdoing as soon as possible, safe in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected if requested, insofar as possible.
To provide staff with guidance as to how to raise those concerns.
To reassure staff that they should be able to raise concerns without fear of reprisals, even if they turn out to be mistaken.
Scope
The policy applies to all employees, workers, officers, volunteers, casual workers and agency workers. There is no minimum length of service required in order to raise a concern.
The policy does not form part of any employee’s contract of employment and it may be amended at any time.
Responsibilities
The CorpAcq Board has overall responsibility for approving the policy.
A recipient of a whistleblowing disclosure as set out in this policy (at section 5) will, as soon as possible, report the receipt of a complaint and the proposed investigation procedure to relevant internal channels. If a disclosure has been made confidentially, the name of the worker will not be included in this report without the worker’s prior consent.
Steve Scott is the designated Whistleblowing Officer and has day-to-day operational responsibility for the policy and must ensure that anyone who investigates matters under this policy is suitably experienced or trained. The policy will be reviewed by the Steve Scott at least once a year through the governance review arrangements for policies agreed by the CorpAcq Board. Where Steve Scott has a conflict of interest in dealing with any particular disclosure raised, the designated officer will be the David Martin who may act as designated officer or appoint another person.
Line Managers will ensure that any matters raised are treated seriously and dealt with in accordance with this policy and procedure. They will ensure that the Whistleblowing Officer is aware of all reported concerns.
Staff, Board Members and everyone working on behalf of the CorpAcq Group are responsible for the success of the policy and are encouraged to suggest ways in which it might be improved by sending these to Steve Scott.
Whistleblowing
Disclosure
A ‘whistleblowing disclosure’ is a report of information which an individual reasonably believes shows that one of the following has occurred or is likely to occur:
a criminal offence has been committed, is being committed or is likely to be committed. This includes any wrongdoing that you reasonably believe breaks the law; for example: fraud, financial irregularity, improper or unauthorised use of public funds, bribery or corruption etc;
someone’s health and safety is put in danger;
damage to the environment;
a miscarriage of justice;
a failure to comply with a legal obligation e.g. breaking the law by not having the correct insurance, etc.
covering up or concealing wrongdoing described in a-e above.
Workers who have information about suspected wrongdoing or danger in relation to our activities should report it under this policy. You must have a reasonable belief that raising the concern is in the public interest and should not raise malicious or vexatious matters that are not in the public interest.
The policy should not be used for complaints relating to your own personal circumstances, such as the way you have been treated at work where these do not have a wider public interest. In such circumstances, you should use relevant HR policies.
Whistleblowing is covered by the Employment Rights Act 1996 Part IVA, as amended by the Public Interest Disclosure Act 1998.
If you are unsure about whether anything is within the scope of this policy you should seek clarification from Steve Scott.
How to make Disclosure
Disclosures can be made in person, verbally or in writing.
In Person - If you feel comfortable doing so, you should report your concerns to a line manager or any other manager.
Verbally – dedicated whistleblowing hotline 0161 241 6869
Via email– whistleblowing@corpacq.com
In Writing – FAO Steve Scott, CorpAcq House, 1 Goose Green, Altrincham, WA14 1DW
You can also raise the matter with any member of CorpAcq board. If the disclosure relates to a legal matter, you should raise the concern with Steve Scott. If the concern is against or in any way related to the actions of the Steve Scott, you should raise your concern with David Martin.
When making a disclosure under this policy, you should try to provide the following information:
the background and any reason behind the concern;
whether you have already raised the concern with anyone and their response;
any relevant dates and times;
if you have a personal interest in the matter, you should declare this when raising the concern; and
why you believe that raising the concern is in the public interest.
The disclosure must contain sufficient factual information and be sufficiently specific, as opposed to an opinion, in order for it to be investigated as a qualifying disclosure.
If you want to you can use the template which is attached as an appendix to this policy below
Confidentiality and anonymity
All disclosures will be treated in a sensitive manner.
If requested by the worker, CorpAcq will take steps to ensure that confidentiality is maintained in so far as possible. It may not be possible to maintain confidentiality if the information is already in the public domain, there is a legal obligation to disclose the information or there is another compelling reason that means it is not possible to maintain confidentiality.
You are encouraged to put your name to any report you make. Disclosures made without giving your name will be considered at the CorpAcq’s discretion but they are more difficult to investigate fully. The factors that the designated officer will take into account in deciding whether to exercise discretion to investigate disclosures made anonymously are:
the seriousness of the issue(s) raised;
the credibility of the concern; and
the likelihood of being able to investigate the allegation.
If you put your name to your report, you may ask that your identity be kept confidential; the recipient of your disclosure will make reasonable efforts to protect your identity, subject to 3.2 above.
Investigation
Following receipt of a disclosure, the person contacted must report the matter to Steve Scott who will make a decision on how to proceed. If Steve Scott is subject to a conflict of interest or if the disclosure relates to Steve Scott, the report should be made to David Martin.
If it appears to the recipient (Steve Scott or David Martin) that the disclosure is actually a grievance properly handled under the Grievance Policy, the recipient will discuss this with the whistle-blower to determine whether the issue is in the public interest. If not, then with the consent of the whistleblower, the recipient will bring the disclosure to the attention of Paul Baird – Head of HR and the matter will be dealt with accordingly. If the matter is dealt with under the Whistleblowing policy, the following provisions will apply.
Steve Scott (or David Martin) will lead the investigation and/or appoint an investigation manager such as the Investor Director team given they will have a much deeper understanding of the portfolio companies. The investigation must be conducted thoroughly and impartially.
The investigation manager will be responsible for:
sending a written acknowledgement of the disclosure to the reporting worker, if the reporting worker has given their name;
ensuring the worker is aware of and has a copy of this policy;
protecting the identity of the worker, where possible, in accordance with section 3 above;
informing the person/people against whom the disclosure has been made as soon as possible - but not at a time or in such a way as to impede a thorough and full investigation;
conducting a full investigation where appropriate;
ensuring the allegation is investigated as quickly as possible without affecting the depth and quality of the investigation;
protecting the effective operation of the organisation to the extent possible in the circumstances of the case;
consider whether other parties, such as the Police or other relevant third parties need to be involved;
keeping the worker informed in writing of the progress of the investigation and its likely timescale;
preparing a report on the outcome of the investigation.
Usually you will be offered a meeting in confidence as soon as practicable after the initial disclosure in order for an initial assessment to be carried out. You can be accompanied by another member of staff for support at the meeting.
We will give you feedback about how we intend to deal with the disclosure made. This may be Steve Scott, investigation manager or the person you reported the concern to. You may be invited to attend additional meetings in order to provide further information.
Outcome
Sometimes the need for confidentiality may prevent us giving you specific details of the investigation or any disciplinary action taken as a result. You must treat any information about the investigation as confidential.
The investigating manager may make recommendations in a report to Steve Scott (or David Martin) for changes to enable us to minimise the risk of future wrongdoing and may also recommend disciplinary action or a wider investigation.
Steve Scott will submit a report and recommendations to the CorpAcq Board, who will consider the report and may accept the recommendations in whole or in part and arrange for a nominated individual to put arrangements in place to implement the recommendations. The CorpAcq Board will then consider the report and may accept the recommendations in whole or in part.
If you are dissatisfied with the outcome, you may raise your concern with David Martin
If you need further help or advice you can obtain this from the charity Protect (formerly Public Concern at Work) which has a confidential helpline and website offering guidance on whistleblowing – 020 3117 2520 or https://protect-advice.org.uk/
The CorpAcq Board recognises the rights of people to make disclosures to prescribed persons such as the Health and Safety Executive and the National Audit Office, or, where justified, elsewhere. A full list of these prescribed bodies or persons can be found on the gov.uk website
Protection and Support for whistle-blowers
It is understandable that those making qualifying disclosures are sometimes worried about possible repercussions. We aim to encourage openness and will support staff who raise reasonable concerns under this policy, and no action will be taken if the investigation does not confirm the allegation made, provided that the allegation is not malicious or vexatious.
Anyone making a qualifying disclosure must not suffer any detrimental treatment as a result of making a qualifying disclosure. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with making a disclosure. If you believe that you have suffered any such treatment, you should inform Steve Scott, immediately. Steve Scott will consider what action to take.
CorpAcq will not tolerate any harassment or victimisation of staff raising concerns in the public interest. You must not threaten or retaliate against anyone raising a concern in any way. If you are involved in such conduct you may be subject to a disciplinary process. If you believe that you have suffered any such treatment, you should inform Steve Scott
During an investigation into a disclosure, every effort will also be made to protect staff and/or other persons cited within the disclosure, and steps may (if appropriate) include:
not identifying those concerned before any investigation of the disclosure has been completed, except where there is a legal obligation to do so, or to a professionally qualified lawyer to get legal advice or unless not identifying them would be prejudicial to the investigation; and
in some cases, moving anyone involved from the area of work concerned whilst the investigation is being carried out.
You can also obtain confidential advice from Protect (formerly Public Concern at Work). This is an independent charity and is a leading authority on public interest whistleblowing.
Emails and any attachments are confidential and may be privileged or otherwise protected from disclosure. Emails are solely intended for the person(s) named on the email. If you are not the intended recipient any reading, use, disclosure, copying or distribution of all or parts of the e-mail or associated attachments is strictly prohibited. Therefore if you have received a message in error, please notify the sender immediately and remove it from your system and delete any printed copy. Internet email may be susceptible to data corruption, interception and unauthorised amendment over which we have no control.
Strategic Resources shall not be liable for the message if altered or falsified and we accept no legal responsibility for the content of the message. Any views or opinions presented are solely those of the author and do not necessarily represent those of Strategic Resources. The recipient is responsible for verifying its authenticity before acting on the contents. Warning: Although Strategic Resources takes reasonable precautions to ensure no viruses are present in email messages, the company cannot accept responsibility for any loss or damage arising from the use of email messages or attachments.
Strategic Resources European Recruitment Consultants Ltd, Migvie House, 23 North Silver Street, Aberdeen, AB10 1RJ. Tel: 01224 628220.
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