Our policies

1.0 Introduction

This BEVA Group is committed to providing a safe, healthy and productive working environment for all employees, volunteers, customers and visitors involved in its operation. This policy sets out the company’s aims in reducing and managing alcohol and drug problems in the workplace.
Alcohol and drug problems are prevalent in society and are associated with a wide variety of costs for both employers and employees. These costs include ill-health sickness absence, reduced work performance and accidents. The consumption of alcohol and drugs has implications for health and safety at work since these substances impair co-ordination, judgement and decision making; as such this is a policy matter.

2.0 Policy aims and objectives

2.1 Aim: To clearly state the company’s position on alcohol and drugs within the workplace.

2.2 Objectives:

• To ensure the company complies with appropriate legislation
• To minimise the risks associated with alcohol and drugs in the workplace
• To have clear rules regarding alcohol and drugs in the workplace
• To provide employees with an education programme on the adverse health effects of alcohol and drugs
• To encourage the early identification of employees who may be experiencing alcohol or drug problems
• To provide support for employees experiencing alcohol and drug problems
• To provide training and support to line managers to ensure they are equipped to support employees experiencing problems.

3.0 Definitions

Alcohol problem: An alcohol problem is defined as any drinking, either intermittent or continual which interferes with a person’s health and/or social functioning and/or work capability or conduct.

Drugs: Any drug, whether illegal, prescribed or over the counter or solvents such as glue, butane, etc. In the case of prescribed and over the counter drugs, their possession and use by the employee is acknowledged as legitimate.

Drug problem: The use of illegal drugs, the deliberate use of prescribed or over the counter drugs (when not for a medical condition) and the use of solvents, either intermittent or continual which interferes with a person’s health and/or social functioning and/or work capability or conduct.

4.0 Legal

4.1 The Health and Safety at Work Act 1974 requires employers to protect the health, safety and welfare of their employees and others who may be affected by their activities, as far as is reasonably practicable.

4.2 The Management of Health and Safety at Work Regulations 1999 requires employers to carry out a risk assessment to identify hazards in the workplace and put measures in place to minimise these risks.

4.3 The Misuse of Drugs Act (1971) is the main legislation covering drugs and categorises them as classes A, B and C. These drugs are called controlled substances and class A drugs are considered to be the most harmful under this act. It is illegal for anyone, whether at work or not to produce, supply or be in possession of illegal drugs. Employers may be liable if they knowingly allow dispensing, manufacturing, possession, using or selling on their premises.

5.0 Policy rules

5.1 The company requires all employees to report for duty free from the effects of alcohol and drugs as defined in section 3.
It is not acceptable to be under the influence of alcohol or drugs at work or consume alcohol or drugs during hours of work, this includes paid and un-paid breaks, unless approved by the CEO/ President.

5.2 Employees found in possession of illegal drugs or using illegal drugs whilst at work will normally be reported to the police.

5.3 In some cases the legitimate use of prescribed drugs can affect a person’s ability to do their job. In such instances employees should inform their line manager.

6.0 Education

6.1 This policy will be sent to all staff on launch and will thereafter be held on the staff HR software, Breathe and on ASANA for access by the council.
New staff will be made aware of this policy at induction and will be directed to the policy on Breathe.

7.0 Implementation of the policy

7.1 Identification of a problem
Alcohol and drug problems may become apparent through a number of means, for example the following (particularly in combination) may result in a problem being suspected:

• Persistent short term absence Unauthorised absence
• Poor time keeping Reduced work performance 
• Poor working relationships
• Deterioration in appearance

However it must be remembered that these factors can have a number of other causes. Employees experiencing alcohol or drug problems may first become apparent to their colleagues. If a member of staff suspects an alcohol or drug problem in a colleague they should either:

• Encourage the person to seek help from support agencies
• Report the matter to a manager (particularly if the person is involved in a safety critical job).

7.2 Misconduct

This policy is primarily concerned with ongoing alcohol and drugs problems which are classed as capability issues, i.e. where the problem impacts on the person’s ability to do their job.

One-off cases where the rules of this policy are breached, such as someone reporting for work clearly under the influence of alcohol or drugs or suffering from the effects of alcohol will be classed as a conduct issue and will be dealt with under the normal disciplinary procedures.

Very serious incidents such as violence at work whilst under the influence of alcohol or drugs or dealing illegal drugs at work will be deemed serious misconduct justifying summary dismissal. In some instances of misconduct where the employee admits to having an alcohol or drug problem, disciplinary proceedings may be held in abeyance subject to successful outcome of treatment.

In instances of serious misconduct where the employee subsequently admits to having an alcohol or drug problem, the support route and the disciplinary route may be implemented in tandem.

7.3 Voluntary referral for support

Employees who suspect or know they have a drug or alcohol problem are encouraged to seek support at an early stage. Employees may or may not wish to inform their line manager in such instances.

7.4 Referral by management

Employees suspected of having an alcohol or drug problem will be offered support by their manager. Where the problem has become apparent through deterioration in work performance, the employee will have to demonstrate satisfactory completion of a programme of support and an improvement in work performance or disciplinary action will be taken.

Employees will be given the opportunity of attending treatment within work time. Alternatively if employees require to be absent from duty normal sick pay arrangements will apply.

7.5 Confidentiality 

The company aims to ensure that the confidentiality of all employees experiencing alcohol or drug problems is maintained by appropriate people, for example, human resources and line manager. Information regarding individual cases will not be divulged to third parties unless the safety of the person concerned or others would be compromised by not doing so.

7.6 Equal opportunities

This policy will apply equally to all staff regardless of grade, experience or role within the company.

7.7 Relapse

The company acknowledges that relapse is common with alcohol and drug problems. Employees will normally be supported through two relapses after treatment. Subsequent relapses will be reviewed on a case-by-case basis, taking into account the needs of the department affected and the business needs of the organisation. Employees should be aware that the disciplinary route might be followed after subsequent relapses.

7.8 Return to work

Following treatment the company will endeavour to ensure the employee returns to their existing job. If the employee is unable to fulfil those duties the company will consider alternative duties. Promotional prospects will be unaffected following treatment.

8.0 Monitoring and review

8.1 The CEO/HR Department is responsible for monitoring how this policy works in practice.

8.2 If employees have concerns about this policy they can be raised with the HR manager.

Last reviewed February 2022

Summary

The Bribery Act 2010 came into force on 1st July 2011. It applies to all UK registered companies, including their subsidiaries (whether in the UK or abroad).

Its focus is purely on bribery, not fraud, theft, money laundering, or Companies Act Offences.

It is essential that the Group, and its employees understand that bribery is taken extremely seriously by the Group, and full compliance with the Act is a requirement of all Group employees.

As well as employees, the Act also applies to ‘Associated persons’, which are defined as a person who performs services on behalf of the company – hence it will apply to contractors and agents of the Group as well.

Definition of bribery

Bribery is defined in the Act as: ‘giving someone a financial or other advantage to encourage that person to perform their functions or activities improperly or to reward that person for having already done so. This could cover seeking to influence a decision-maker by giving some kind of extra benefit to that decision maker rather than by what can be legitimately be offered as part of a tender process.’

The Act covers both the giving and receiving of bribes.

Statement of Group anti-bribery policy

The Group has the following policy with respect to bribery, for employees of the Group, compliance with this policy forms parts of your terms and conditions of employment, and as such any breaches are liable to disciplinary action.

• The Group is committed to carry on its business fairly, honestly, and openly in all of its markets across the world, and therefore takes a zero-tolerance approach to bribery
• The Group notes that it operates in some markets where there has historically been, and currently there is, a culture of bribery (as defined by the Act)
• The board and management teams of all parts for the Group are firmly committed to compliance with the Act, and as such expect all employees/contractors and agents to comply with the Act
• The Group and its employees/contractors/agents must not pay bribes
• The Group and its employees/contractors/agents must not accept bribes
• Any employee/contractor/agent becoming aware of any bribery within the Group, should report it to a manager/CEO as soon as possible
• The Group’s anti-bribery officer is Effie Brooks, who can also be contacted for any questions regarding compliance with the Act, and also for the reporting (in confidence) of any potential bribery instances
• Normal hospitality in the course of corporate business, signed off in accordance with budgets and the finance process is acceptable and is not seen as bribery

Last reviewed June 2020

Statement of policy

The Group is committed to encouraging and maintaining good employee relations within a working environment which fosters team working and encourages employees to give of their best. Everyone in the Group and those who have dealings with the Group has a responsibility to maintain good working relationships and not use words or deeds that may harm the wellbeing of others. In addition to the obligations placed upon both employers and employees by the Equality and Human Rights legislation, everyone has the right to be treated with consideration, fairness, dignity and respect. This contributes to a workplace environment in which individuals feel safe and can work effectively competently and confidently.

The Group’s policy applies to all staff working within the organisation and to all employees working off the premises. It extends to include non-permanent workers such as secondees, contractors, agency, temporary staff, consultants and any other workers. The policy, in addition, covers the behaviour of staff outside working hours which may impact upon work or working relationships.

The Group has a “zero tolerance” policy and will investigate vigorously any allegations of bullying or harassment, regardless of whether the matter has been raised formally or informally.

Key principles

The Group will provide and sustain a safe working environment in which everyone is treated fairly and with respect. Those working or dealing with the Group must not encounter harassment, intimidation or victimisation on the basis of gender, race, colour, ethnic or national origin, sexual orientation, marital status, religion or belief, age, trade union membership, disability, offending background or any other personal characteristic.

Everyone carries a personal responsibility for their own behaviour and for ensuring that their conduct is in accordance with the principles set out in this policy. In addition, each person has a responsibility to report any instance of bullying or harassment which they witness or which comes to their attention. Employees have a responsibility to act as role models, pro-actively addressing instances of bullying and harassment. Managers should also make themselves aware of their responsibility.

Harassment may be defined as any conduct which is: 

• unwanted by the recipient
• is considered objectionable
• causes humiliation, offence, distress or other detrimental effect

Harassment may be an isolated occurrence or repetitive: it may occur against one or more individuals. Harassment may be, but is not limited to:

• Physical contact – ranging from touching to serious assault, gestures, intimidation, aggressive behaviour.
• Verbal – unwelcome remarks, suggestions and propositions, malicious gossip, jokes and banter, offensive language.
• Non-verbal – offensive literature or pictures, graffiti and computer imagery, isolation or non-co-operation and exclusion or isolation from social activities.

Bullying is unlikely to be a single or isolated instance. It is usually, but not exclusively repeated and persistent behaviour which is offensive, abusive, intimidating, malicious or insulting. Bullying includes but is not limited to:

• Conduct which is intimidating, physically abusive or threatening 
• Conduct that denigrates, ridicules or humiliates an individual, especially in front of colleagues
• Humiliating an individual in front of colleagues
• Picking on one person when there is a common problem
• Shouting at an individual to get things done
• Consistently undermining someone and their ability to do the job
• Setting unrealistic targets or excessive workloads
• “cyber bullying” i.e. bullying via e-mail. (This should be borne in mind where employees are working remotely and are managed by e-mail. Care and sensitivity should be practised with regard to the choice of context and language).
• Setting an individual up to fail e.g. by giving inadequate instructions or unreasonable deadlines.

Harassment and Bullying may be summarised as any behaviour that is unwanted by the person to whom it is directed. It is the impact of the behaviour rather than the intent of the perpetrator that is the determinant as to whether harassment or bullying has occurred.

Any employee who wishes to make a complaint of harassment or bullying is encouraged to first discuss matters informally with their manager or with the CEO, provided that they feel able to do so. Should the issues not be resolved at this stage, or the employee feels unable to raise the issue informally, then a formal resolution should be sought.

When a complaint of Harassment or Bullying is brought to the attention of a manager at any level, whether informally or formally, prompt action must be taken to investigate the matter. Corrective action must be taken where appropriate and this may require an investigation under the Companies’ Disciplinary Policy and Procedure.

If it is considered that one of the parties concerned in a harassment or bullying case should be moved from their current workplace, then as a matter of principle the Group will normally remove the alleged perpetrator rather than the complainant. However, the final decision on who should be moved should reflect the particular circumstances of the case. It should be noted and explained to those concerned that the moving of either party is not an implication of guilt or culpability and no detriment to either party will be construed as a consequence.

All matters relating to the investigation of complaints of harassment or bullying will be treated in strict confidence. Any breach of confidentiality in this regard may render those responsible liable to disciplinary actions. However, it will be necessary that any alleged perpetrator is made aware of the allegations against them and the name(s) of those making the allegations together with the name(s) of any witnesses.

No employee will be victimised or suffer detriment for making a complaint of harassment or bullying and no manager shall threaten either explicitly or implicitly that an employee’s complaint will be used as the basis for decisions affecting that employee. Such conduct will be treated as a very serious disciplinary offence. Similarly, managers are required to act on any complaint of harassment or bullying. Failure to do so will be regarded as misconduct which if proven, will result in disciplinary action.

All complaints of harassment or bullying whether raised formally or informally must be notified by the recipient of the complaint to the CEO for recording in accordance with the requirements of the Equality and Human Rights legislation. This legislation requires such records to be maintained and the incidence of bullying and harassment to be monitored.

This policy and procedure will be reviewed periodically giving due consideration to legislative changes.

Procedure

1.0 Information resolution

1.1 Very often people are not aware that their behaviour is unwelcome or misunderstood and an informal discussion can lead to greater understanding and agreement that the behaviour will cease.

1.2 Complainants are therefore encouraged to try, if they feel able to do so, to resolve the problem informally by making it clear to the alleged harasser that his/her actions are unwanted and should not be repeated. This may be done verbally or in writing in which case the complainant should keep a copy of the documentation and, where possible, the times and dates of incidents should be recorded.

1.3 If the complainant feels unable to approach the alleged harasser, a work colleague, or Trade Union representative could be asked to speak to the alleged harasser on the complainant’s behalf. A note should be made of the action taken and the matter notified to Human Resources.

1.4 An individual who is made aware that their behaviour is unacceptable should:

• Listen carefully to the complaints and the particular concerns raised;
• Respect the other person’s point of view: everyone has a right to work in an environment free from harassment/intimidation;
• Understand and acknowledge that it is the other person’s reaction/perception to another’s behaviour that is important;
• Agree the aspects of behaviour that will change;
• Review their general conduct/behaviour at work and with workplace colleagues.

2.0 Formal resolution

2.1 If the alleged harassment continues, the complainant feels unable or unwilling to deal with the matter informally, or the allegation is so serious as to prevent use of the informal procedure, a complaint should then be raised formally with the employer.

2.2 Normally, the employer’s representative will be the employee’s manager. However, if the employee feels unable to do this they should submit the complaint in writing to a more senior manager within the company.

2.3 When dealing with a complaint of harassment under the Formal Resolution Procedure, the relevant manager should:

1. Take full details of the incidents in writing from the complainant and their representative (if appropriate);
2. Take full details from any witnesses/other complainants who come forward and may have witnessed the alleged behaviour
3. Inform the alleged harasser of the complaints against him/her, advise the alleged harasser to seek representation and invite him/her to a meeting in order that they can comment on the allegations against them.
4. Keep all parties informed of expected timescales.
5. Inform all parties in writing of the outcome and any action that may be required.

2.4 If the allegations and the working situation warrant it, the alleged harasser may be suspended during the investigation (in accordance with established disciplinary procedure) or transferred temporarily pending the outcome of the inquiry to another Department.

2.5 Should there be a case to answer against the alleged harasser, the manager who has dealt with the complaint will communicate this to an impartial manager who will conduct a separate disciplinary investigation. The normal disciplinary procedure for misconduct/gross misconduct should then be followed. However, the following points should be taken into account:

• The complainant will normally be required to attend the disciplinary hearing as a witness, unless there are exceptional circumstances which prevent them from doing so;
• If the complainant is required to attend, they are entitled to be accompanied by either a Trade Union representative or work colleague and have any questions directed through that person.

2.6 If the complaint is upheld at the disciplinary stage, there are a number of possible outcomes for the harasser, depending on the evidence presented and the circumstances. These could include, but are not limited to:

• Dismissal
• A formal warning
• A recommendation of redeployment of the harasser, either on a temporary or a permanent basis. This will not be on any less favourable terms and conditions of employment.
• Implementation of other sanctions as detailed in the Companies’ Disciplinary Policy.
• Making arrangements for both parties to work as separately as possible within the same workplace.

2.7 In addition to the above, the harasser may be required to attend any training courses as deemed necessary by the Companies.

2.8 It should also be noted that the complainant may wish to move Department/section depending upon the nature of the complaint and the people involved. Appropriate consideration should be given to this request and the outcome with reasons provided to the complainant.

2.9 With any allegation, the need for a thorough and objective investigation is paramount. Consequently, if through the course of the investigation evidence demonstrates that the allegation has been made frivolously, maliciously, or for personal gain, then the individual making the complaint will be subject to Disciplinary proceedings as outlined in the Companies’ Disciplinary Policy.

Appeals

Appeals against decisions taken under the Bullying and Harassment at Work Policy and Procedure shall be dealt with as follows:

• Appeals against a disciplinary sanction will be dealt with in accordance with the appeals process in the Disciplinary Procedure.
• Appeals by a complainant about the outcome of any inquiry will be dealt with in accordance with the appeal process in the Grievance Policy.

Records

Where the complaint is informal and resolved at this stage, no record will be kept on personal files.

Following formal investigation, where the complaint is not substantiated, no records will be retained.

Where a complaint is substantiated or partially substantiated but does not proceed to disciplinary, a letter confirming the outcome will be retained on the personal file and supporting documentation retained in a separate file for a period of 12 months.

Where the matter proceeds to a disciplinary hearing then the storage of records should be in accordance with the disciplinary procedure.

All directors, trustees, staff and volunteers, of the Group will strive to avoid any conflict of interest between the interests of the Organisation on the one hand, and personal, professional, and business interests on the other. This includes avoiding actual conflicts of interest as well as the perception of conflicts of interest.

The purpose of this policy is to protect the integrity of the Group’s decision-making process, to enable our stakeholders to have confidence in our integrity, and to protect the integrity and reputation of directors, trustees, volunteers and staff.

Examples of conflicts of interest include:

1. A trustee/employee who is also a user who must decide whether fees from users should be increased.
2. A trustee who is related to a member of staff and there is a decision to be taken on staff pay and/or conditions.
3. A trustee/employee who is also on the committee of another organisation that is competing for the same funding.
4. A trustee/employee who has shares in a business that may be awarded a contract to do work or provide services for the organisation.

Upon appointment each trustee will make a full, written disclosure of interests, such as relationships, and posts held that could potentially result in a conflict of interest. This written disclosure will be kept on file and it will be updated as appropriate.

In the course of meetings or activities, trustees/employees will disclose any interests in a transaction or decision where there may be a conflict between the organisation’s best interests and the trustee’s/employee’s best interests or a conflict between the best interests of the two organisations that the trustees/employees are involved with. After disclosure, the trustee/employee may be asked to leave the room for the discussion and may not be able to take part in the decision depending on the judgement of the other trustees present at the time. 

Any such disclosure and the subsequent actions taken will be noted in the minutes.

This policy is meant to supplement good judgment, and staff, volunteers and trustees should respect its spirit as well as its wording.

Introduction

This document describes the expenses policies which apply to all Group staff. The document attempts to take account of most eventualities as briefly as possible.

Travel

By motor vehicle

General

All claims should be in respect of the most economic route and cover business mileage only. Business mileage is defined as:

• journeys which members have to make in the performance of their duties; and
• journeys which members make to or from a place they have to attend in the performance of their duties - but not journeys which are ordinary commuting (travel between home and a permanent workplace) or private travel.

Own vehicle

It will be necessary for members to utilise their own private vehicle on Group business. In these circumstances members must ensure that the insurance cover in respect of the vehicle is fully comprehensive and that it includes provision for business use – this is standard in most policies and can usually be added, if necessary, at no additional cost.

The mileage rates which apply are as follows:

• Up to 10,000 miles: 45p
• Over 10,000 miles: 25p

These are HMRC approved, non-taxable rates.

By rail or sea

Rail and sea travel should be undertaken using the most economic route utilising any discounted tickets available. All travel must be at Standard Class.

By air

Air travel should be undertaken using the most economic route utilising any discounted tickets available. All air travel must be undertaken using the cheapest method, usually Economy Class.

By taxi

Taxis should only be used in exceptional circumstances e.g. where alternative forms of public transport are not available. If a taxi is used members must provide an explanation within their claim.

Accommodation

The following rates are the advisory rates in respect of overnight accommodation although cheaper accommodation should be sought if available.

• Outside London - £100
• Within London - £150

Every effort should be made to obtain suitable accommodation at lower prices VAT receipts must be submitted with all claims for accommodation.

If, in exceptional circumstances e.g. attendance at a conference where accommodation is included, or it is not possible to obtain accommodation at these rates the Group will reimburse the actual costs. Prior approval is required in these circumstances.

Miscellaneous Expenses

Claims for other associated expenses e.g. parking fees, publications, must be accompanied by a VAT receipt to support the claim. Credit card slips alone are not acceptable.

Entertaining

Although expenditure on business entertaining is sometimes necessary, it should be kept to a minimum and must only be incurred when benefit to the Group is likely to accrue as a result. All claims must be supported by VAT receipts which detail the expenditure. Credit card slips alone are not acceptable.

All such expenditure must be approved, preferably in advance.

Making an expenses claim

The Group use the software Webexpenses to manage expense claims. Please contact the Financial Manager or the Executive Assistant to be set up on the software. If it is not possible to use the software then a form can be used. The expense claim form is available in electronic form (Excel spreadsheet), please contact the Financial Manager if a form is required.

Claimants should provide as much detail as possible in order to describe the nature of each journey, meeting etc., on the reverse side of the form. They must calculate the mileage allowance, insert any other claims for expenditure and transfer the totals at the foot of the page to the relevant line in the front page summary. (This will be done automatically in electronic versions).

Following completion of the form, including a check of the calculations, it should be signed and passed to the Financial Manager for approval. The Financial Manager will check to ensure that the claim is complete, reasonable, and that the journeys and meetings were necessary, before authorising the expenditure and passing the claim for payment. The original signed claim must be provided together with all required receipts.

The deadline for receipt of authorised expense claim forms is the 15th of the month following the month of the event. Any incomplete claims will be returned and this may result in payment being delayed until the following month. Payment will be made by transfer to the member’s bank account or cheque.

We are committed to understanding and managing the environmental, economic and social impacts of our operations through the delivery of sustainable solutions. We recognize we play a role in protecting communities and the environment now and for the future.

The policy seeks to embed the consideration of social, environmental and economic impacts as factors in decisions made by staff and our partners.

BEVA and BEVA staff will strive to:

• Encourage and engage suppliers to develop a proactive approach to sustainability issues and deliver sustainable solutions
• Identify and review the sustainability risks and impacts of the products and services we procure
• Embed sustainability within tender documents by ensuring these are a proportionate part of the assessment criteria for significant impact procurements
• Develop processes that enable local businesses to be part of our supply chain
• Look to minimize the use of energy and natural resources and maximise the use of renewable energy sources
• Use and dispose of goods in an environmentally responsible way, including considering reducing, substituting, reusing and recycling sustainable options

We expect our suppliers to work collaboratively and be supportive of our approach to continually improve performance, through the selection of sustainable products and solutions, innovative thinking and the employment of best practice to meet our objectives and targets.

Policy in Practice

BEVA achieve this statement by ensuring the following criteria is met for purchases made on behalf of BEVA:

Considerations for all purchases:

• The location and how far the item will travel to reach us will be considered when making a purchase. Where possible BEVA uses local suppliers.
• The supplier's environmental credentials are reviewed before choosing to work with them. Preference is given to suppliers who have an environmental policy in place, use renewable energy, and can show their commitment to reducing their impact on the environment.

Venues for events:

• The location of the venue should be assessed. Where possible we should be selecting venues that are within easy reach of public transport.
• We ask to review the venue's sustainability policy (and/or efforts) and ensure they are doing their bit to minimise the impact on the environment. The waste and recycling efforts should be reviewed along with the types of energy they use.

IT equipment:

• IT products purchased must meet the latest minimum energy efficiency requirements prescribed by the EU Energy Star Regulation.
• Where suitable, purchasing refurbished IT equipment should be considered.

Office equipment and materials:

• Office supplies should be purchased in bulk (i.e. once per quarter) to reduce transportation and packaging.
• All materials and equipment should be sourced from environmentally friendly sources and where relevant made of recycled materials (i.e. all paper products purchased from September 2020 should be made of 100% recycled materials).
• Reusable and refillable items should be purchased (i.e. washing up bottles, hand wash)

The Hospitality and Gifts Policy of the Group is intended to provide guidance to staff on the giving and receipt of hospitality or gifts. This policy is equally applicable to individuals who are not employees of the Group but who voluntarily undertake duties on behalf of the Group and/ or act as representatives of the Group. This policy is not intended to cover monetary donations provided to finance the work of the Charity.

1.0 Policy and scope

1.1. Each staff member/representative has a personal responsibility to declare hospitality and gifts given or received while undertaking duties for/ on behalf of the Group.

1.2. It is the responsibility of all staff/representatives to ensure that they are not placed in a position that risks, or appears to risk, conflict between their personal interests and the Charity’s duties. If any doubt has arisen with the receiving of a gift or hospitality the CEO or President should be consulted.

1.3. It is the responsibility of the Finance Department to maintain the Charity’s Hospitality and Gifts Register and make it accessible to the Charity’s stakeholders.

1.4. The Register will be reviewed annually by the Board of Management and will be available to the Group’s external auditors.

2.0 Principles - receipt of hospitality and gifts

2.1 Neither members of staff nor representatives should accept any hospitality or gifts (or have them given to members of their family) from any organisation or individual with whom they have contact in the course of their work that would cause them to reach a position whereby they might be or be deemed to others to have been influenced in making a business decision because of accepting such hospitality or gifts. BEVA does recognise that in some cases non acceptance may cause embarrassment to the provider.

2.2 Acceptable hospitality
Modest hospitality provided it is normal and reasonable in the circumstances is acceptable and does not need to be recorded. This may, for example, include lunches in the course of working visits to other organisations. Other hospitality may be accepted, for instance where:

• A member of staff or representative is invited to a Society or Institute Dinner or function.
• There is a genuine need to impart information or represent the Group in stakeholder community events. An event is clearly part of the life of a stakeholder community or where the Group should be seen to be represented. A function or event is hosted for staff or representatives which adds benefit and value to the Charity.
• A function or event is hosted for staff or representatives only for the purposes of training or organisational development.
• The receipt of goods or services is below market value.

2.3 Unacceptable hospitality (these types of hospitality must be recorded)

The following examples are intended to give general guidance only on what may be regarded as unacceptable hospitality:

• A holiday abroad or weekend in a holiday centre.
• Offers of hotel accommodation.
• Use of a company flat or hotel suite.
• To attend a function or event restricted to staff which is not for the purposes of training or organisational development.

2.4 Acceptance of gifts

Offers of gifts should be declined except where they are of low intrinsic value (e.g. flowers, chocolates or small stationery items such as diaries or calendars, below £20 in value).

Where the refusal of a small gift may be felt to cause embarrassment to the provider advice should be sought from the Charity’s Chief Executive as to whether the gift should be accepted.

Monetary gifts (including gifts where a monetary value may be attributed eg vouchers) should not be accepted in any circumstances. Failure to comply with this policy will be regarded as a disciplinary offence which could lead to dismissal.

2.5 Commercial Sponsorship

Acceptance by staff or representatives for attendance at relevant commercially sponsored conferences and courses is acceptable, but only where acceptance will not, and cannot be seen as compromising purchasing decisions in any way. Receipt of such sponsorship should be recorded in the Register.

3.0 Principles – Provision of hospitality or gifts

3.1 Provision of Hospitality

Decisions regarding the provision of hospitality using Charity money should only be made by staff with budgetary responsibility for such expenditure. The provision of hospitality by staff of the Group to representatives of other organisations should be modest and be appropriate in the circumstances, for example lunches in the course of working visits. Provision of hospitality by the Group to staff of the Group would not normally be appropriate except in the case of working lunches where the majority of staff attending are away from their normal base, training courses or organisational development events. Authorisation of hospitality associated with personal esteem (which may include leaving / long service events) should be expressly authorised by the CEO and, where appropriate, the BoM. The use of Charity monies for hospitality should be carefully considered. Any such hospitality should be recorded in the Register.

3.2 Giving of gifts

Non-monetary gifts, charitable donations or rewards should not be given by any member of staff to an individual with whom they have contact in the course of their work, except for those dealing with the personal esteem or welfare of staff. If in any doubt, please consult the CEO/President. Authorisation of gifts associated with the personal esteem or welfare of staff must be requested via the CEO. Gifts should be reasonable and limited and should not exceed a maximum value of £100 per individual member of staff. All our other policies and procedures must also be adhered to.

4.0 Procedures – Records of Hospitality and Gifts Received, Provided or Offered

4.1 Requirement for a hospitality and gifts register

The Charity is required to maintain a register of hospitality and gifts recording any offer, receipt or provision of hospitality or gifts. The register will be subject to review by both the BoM and External Audit.

4.2 Maintenance of the register

The Group will maintain a central Register administered by the Finance Department. Individuals may wish to keep a personal copy of all submissions made when they are sent to the Finance department. When a submission is made it is also important to record the estimated value of the hospitality or gift received, provided or offered. Annual audits of the hospitality Register will be undertaken against the following performance measures:

• review of number of entries made to the Register and source
• analysis of value of hospitality / gifts offered but declined
• analysis of hospitality / gifts accepted
• analysis of value and nature of hospitality / gifts provided
• analysis of outside organisations offering hospitality / gifts
• analysis of outside organisations receiving hospitality

5.0 Information for The Register

5.1 Submissions
The information required for the Hospitality and Gifts Register is set out below. Staff should make submissions as soon as is practically possible.

5.2 Information Required

• Date of entry
• Name of recipient / provider
• Job title/representative role
• Nature and purpose of hospitality or gift received or provided and the name of any other organisation involved
• Nature and purpose of hospitality or gift declined and the name of the organisation offering the hospitality or gift.
• Estimated value
• Date of hospitality or gift.

If staff or representatives have any doubt about whether an item should be accepted or recorded they can consult the CEO or President.

Last reviewed: February 2022 Source: Gov.UK

1. Purpose

The purpose of this policy is to maintain a work environment that is free from sexual harassment, to outline the standards for acceptable behaviour, and to provide clear guidelines for reporting and responding to sexual harassment claims. Sexual harassment will not be tolerated under any circumstances.

2. Scope

This policy applies to all employees, contractors, volunteers, customers, or anyone associated with the organisation, regardless of their role or level. It covers conduct in the workplace, work-related functions, or any activity where the individual represents the company.

3. Definition of Sexual Harassment
Sexual harassment is unwelcome conduct of a sexual nature that creates a hostile, intimidating, or offensive work environment. It can take various forms, including but not limited to:

1. Verbal Harassment: Offensive or suggestive remarks, jokes, comments, or questions about an individual’s body, clothing, sexual activities, or sexual orientation.
2. Non-Verbal Harassment: Inappropriate gestures, leering, displaying sexually suggestive material, or sending unsolicited explicit emails, texts, or messages.
3. Physical Harassment: Unwanted physical contact such as touching, hugging, patting, pinching, or any form of sexual assault.
4. Quid Pro Quo: Offering employment benefits (e.g., promotions, raises, preferred assignments) in exchange for sexual favours or threatening negative consequences for refusing sexual advances.
5. Retaliation: Punishing someone for reporting sexual harassment or participating in an investigation.

4. Responsibilities 

Employees:

• All employees are responsible for maintaining a respectful workplace.
• Employees must avoid any form of sexual harassment and are encouraged to report any incidents.
• By acknowledging this policy, employees commit to uphold company values.

Supervisors and Managers:

• Must ensure the work environment is free from sexual harassment.
• Are obligated to address and report any complaints they witness or are made aware of.
• Must take immediate action if a complaint is filed and refer it to the HR or designated department.

Human Resources (HR) and Leadership:

• Responsible for developing, implementing, and reviewing this policy.
• Will ensure employees understand their rights and responsibilities.
• Will investigate complaints promptly and maintain confidentiality throughout the process.

5. Reporting sexual harassment

1. Informal Reporting: Employees who feel comfortable doing so are encouraged to directly address the harasser and explain that the behaviour is unwelcome and must stop.
2. Formal Reporting: Employees who experience or witness sexual harassment should report it immediately to their supervisor, HR department, or through the anonymous reporting system. If the complaint is being raised against part of the senior team and it is felt that it would be difficult to report through these channels the report can be made directly to a trustee of BEVA Ltd. Complaints should include:
   1. Names of involved parties.
   2. A detailed description of the incident(s).
   3. Date(s) and location(s) of the harassment.
   4. Any witnesses or supporting evidence.
3. Confidentiality: All complaints will be handled with the utmost discretion. Information will only be shared with those necessary to investigate and resolve the issue.

6. Investigation process

Once a report is filed, the following steps will be taken:

1. Acknowledgment: HR will acknowledge receipt of the complaint within 10 business days.
2. Investigation: HR will investigate the complaint by interviewing the parties involved, gathering evidence, and speaking to witnesses if necessary.
3. Resolution: Upon conclusion, appropriate disciplinary action will be taken if the complaint is substantiated, up to and including termination of employment. Unsubstantiated complaints will also be addressed to prevent future issues.
4. Feedback: The complainant will be informed of the outcome of the investigation, while respecting the confidentiality of involved parties.

7. Protection against retaliation

Retaliation against any employee for reporting sexual harassment or participating in an investigation is strictly prohibited. Employees who engage in retaliatory behaviour will face disciplinary action, which may include termination.

8. Disciplinary actions

Any employee found to have engaged in sexual harassment or retaliatory behaviour will be subject to disciplinary action, which may include but is not limited to:

• Verbal or written warnings.
• Mandatory training or counselling.
• Suspension or demotion.
• Termination of employment.

9. Policy review and updates

This policy will be reviewed regularly or as necessary to ensure compliance with relevant laws and best practices. Revisions will be communicated to all employees.

Contact information for reporting harassment:

• HR Department: effie@beva.org.uk or david@beva.org.uk
• Anonymous Reporting: BEVA Reporting Tool

In this policy, "we", "us" and "our" refer to the BEVA Group. The BEVA Group consists of BEVA Ltd, BEVA Enterprises Ltd, British Equine Veterinary Association Trust and Equine Veterinary Journal Ltd.

This privacy notice tells you what to expect us to do with your personal information.

Our contact details

Post: BEVA, Mulberry House, 31 Market Street, Fordham, Ely, Cambridgeshire, CB7 5LQ, GB
Telephone: 01638 723 555
Email: dpo@beva.org.ukh4>What information we collect, use and why

What information we collect, use and why

We collect or use the following information to provide services and goods, including delivery:

• Names and contact details
• Addresses
• Date of birth
• Purchase or account history
• Payment details (including card or bank information for transfers and direct debits)
• Account information
• Information relating to loyalty programme
• Website user information (including user journeys and cookie tracking)
• Information relating to compliments or complaints
• Information relating to sponsorship

We collect or use the following information for the operation of customer accounts and guarantees:

• Names and contact details
• Addresses
• Payment details (including card or bank information for transfers and direct debits)
• Purchase history
• Account information, including registration details
• Marketing preferences

We collect or use the following information for service updates or marketing purposes:

• Names and contact details
• Addresses
• Marketing preferences
• Location data
• IP addresses
• Website and app user journey information
• Information relating to sponsorship
  • Records of consent, where appropriate

We collect or use the following information for research or archiving purposes:

• Names and contact details
• Addresses
• Location data
• Personal information used for administration of research
• Personal information used for the purpose of research
• Records of consent, where appropriate

We also collect or use the following information for research or archiving purposes:

• Racial or ethnic origin
• Political opinions
• Religious or philosophical beliefs
• Health information
• Sexual orientation information

Lawful bases

Our lawful bases for collecting or using personal information to provide services and goods are:

• Contract

Our lawful bases for collecting or using personal information for the operation of customer accounts and guarantees are:

• Contract
• Legitimate interest: Collecting this information allows us to deliver to the Member the benefits associated with membership of the Association.

Our lawful bases for collecting or using personal information for service updates or marketing purposes are:

• Consent
• Legitimate interest: We might use this information to provide Members with details of how to access existing or new benefits of their membership, information regarding new benefits or details regarding the end of term of an existing benefit.

Our lawful bases for collecting or using personal information for research or archiving purposes are:

• Legitimate interest: We use the results of surveys to improve the Members experience, in order to deliver benefits (including representing the profession) or to improve a service to which membership confers a preference (eg. Continuous Professional Development (CPD)).

Where we get personal information from

• People directly

How long we keep information

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
We will retain your personal data as follows:

• Account data will be retained for a maximum period of 4 years following your last membership, or interaction with BEVA.
• Transactional data will be retained for a maximum period of 6 years, in line with current regulations.

Notwithstanding the other provisions of this policy, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Who we share information with

Data processors

John Wiley & Sons Publishing

This data processor does the following activities for us: Publish and ship the BEVA Group Journals using information provided by Members.

FirstSight Media

This data processor does the following activities for us: They assist in managing attendee information for BEVA Congress.

Mice Concierge

This data processor does the following activities for us: They assist in managing accommodation for BEVA run events.

Zoom

This data processor does the following activities for us: Managing attendance for online sessions.

ClearCourse Membership Services (trading as Silverbear)

This data processor does the following activities for us: Process payment information.

BACS

This data processor does the following activities for us: Process payment information for Direct Debit payments to be managed.

HMRC

This data processor does the following activities for us: Process payment, VAT and PAYE information

Royal London

This data processor does the following activities for us: Manages an Employee benefit.

Simply Health

This data processor does the following activities for us: Manages an Employee benefit.

Sage UK Ltd

This data processor does the following activities for us: Process payment information.

Civica

This data processor does the following activities for us: Management of elections.

Dotdigital

This data processor does the following activities for us: Management and storage of email data.

Other organisations

• External auditors or inspectors
• Course Organisers and Venues as necessary for the provision of, and access to, CPD Events
• CPD Sponsors where appropriate
• Partner Associations as necessary to confirm eligibility for membership

Your data protection rights

Under the data protection law, you have rights including:

Your right of access - You have the right to ask us for copies of your personal data.

Your right to rectification - You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal data in certain circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal data in certain circumstances.

Your right to object to processing - You have the right to object to the processing of your personal data in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the personal data you gave us to another organisation, or to you, in certain circumstances.

Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent.

You don’t usually need to pay a fee to exercise your rights. If you make a request, we have one calendar month to respond to you.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

How to complain

If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.

If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

Website: https://www.ico.org.uk/make-a-complaint

Purpose

This policy outlines the BEVA Group’s commitment to safeguarding, its responsibilities, an assessment of potential risks, steps taken to reduce those risks and the steps that should be taken in the event of the group becoming aware of a safeguarding issue.

Policy statement

The group is committed to pro-actively safeguarding children, young people and vulnerable adults* with whom the staff, or anyone acting on our behalf (the representatives), come into contact with, during fundraising, benevolence or outreach activities. Examples of the group’s activities in which staff may encounter children and or vulnerable adults include: work experience students under 18; school visits; welfare clinics; national and regional participation events.

The group must ensure that appropriate due diligence is carried out on any third- party organisations that are working with the group on any events that may result in contact with any representatives, members or beneficiaries of the group,ensuring that they have appropriate systems of control in place, including adequate safeguarding policies and procedures.

The welfare and safety of the person at risk is paramount. All vulnerable people, regardless of age, disability, gender, racial heritage, religious belief, sexual orientation or identity, have a right to equal protection from all types of harm or abuse.

The group takes all reasonable care to protect its beneficiaries and supporters. The group will never exploit vulnerability and will do everything it can to ensure that potential volunteers or beneficiaries are able to make an informed decision about the support they choose to give.

The group is committed to the promotion of equality of opportunity. The group’s Equal Opportunities Policy aims to eliminate all forms of unlawful and unfair discrimination, both direct and indirect, from its employment practices.

We will seek to fulfil our legal obligation and commitment to proactively safeguard and promote the welfare of the group’s beneficiaries and representatives through:

• the production of a policy and procedures with a clear line of accountability, to which all will comply;
• a senior executive level lead – the designated manager - to take leadership responsibility for the group’s safeguarding arrangements; to act as the organisational interface with the Local Authority whenever a situation arises;
• a culture of listening to children and vulnerable adults and taking account of their wishes and feelings, both in individual decisions and the development of any events/services;
• clear whistleblowing procedures and policies as detailed in the guidelines of those from the Local Safeguarding Childrens Board /Local Safeguarding Adults Board for dealing with any allegations; responding without delay to concerns and complaints regarding actual or potential abuse, harm or maltreatment.

This policy applies to all employees, trustees, volunteers and anyone working on behalf of the BEVA Ltd Group.

*For the purpose of this document, by ‘vulnerable’ we are referring to children and young people under 18 years of age or to a person who is 18 years of age or over, and who is or may be in need of community care services by reasons of mental or other disability, age or illness (whether they are receiving such care or not) and who is unable to take care of himself/herself, or unable to protect himself/herself against significant harm or exploitation.

Responsibility and accountability

Trustees are overall responsible for safeguarding, even if certain aspects of the work are delegated to the Chief Executive and staff. They should proactively safeguard and promote the well-being and welfare of the group’s beneficiaries, staff and volunteers and others who come into contact with the group. This is a key governance priority.

The issue of safeguarding is subject to regular reviews at Board level and is reported on by exception at Board of Trustees’ meetings. In addition, ‘Safeguarding’ will be reported upon in the Annual Report and Accounts. Given the nature of the group’s activities, there is no requirement for a lead Safeguarding Trustee to be appointed.

The group’s nominated lead for safeguarding policy and management is the CEO supported by the Board of Management. The Safeguarding Lead will report directly to Trustees.

Risk assessments

Our Trustees have a duty to manage risk and to protect the reputation and assets of the group. It is therefore vital that Trustees assess the risks that arise from the group’s activities and operations involving children and vulnerable people and develop and put in place appropriate safeguarding policies and procedures to protect them. They must also undertake on-going monitoring to ensure that these safeguards are being effectively implemented in practice. This is critically important because on occasion charities may be targeted by people who abuse their position and privileges to gain access to vulnerable people, or their records, for inappropriate or illegal purposes.

Key safeguarding risks for the group are:

• potential abuse of children, young people or vulnerable adults occurring during group
  activities, through failure to safeguard them;
• potential abuse of children, young people or vulnerable adults occurring during organised activities, supported by funding or volunteers from BEVA Ltd;
  ensuring that those who run activities that include vulnerable beneficiaries have the expertise, knowledge and skills to do so properly;
• failure to deal with any incident responsibly, appropriately and in a timely manner;
• failure to ensure that Trustees are clear about their responsibilities for safeguarding;
• failure to ensure that staff, Trustees and volunteers coming into frequent contact with children, young people or vulnerable adults are appropriately vetted;
• the reputational risk of damaging public trust and confidence in the group through the occurrence of any alleged or actual incident.

The group seeks to manage effectively the risks associated with activities and events through departments/teams:

• completing a risk assessment process which involves identifying risks and means of reducing or eliminating them, for any new activities or events
  involving or potentially involving children and or vulnerable adults, and if changes are being made to activities or events involving or potentially involving children and or vulnerable adults;
• requiring that new employees and individuals working with children or vulnerable adults familiarise themselves with the content of this policy and the Code of Safer Working Practice.

Code of Safer Working Practice

The Code (at Annex B) is provided for all those across the group to follow, in working and volunteering with children, young people and vulnerable adults.

The Code represents the behaviours which constitute safe practice. As such it will assist those working with children and vulnerable adults to do so safely and responsibly, enabling each to monitor their own standards of integrity and good practice. The Code sets clear expectations of behaviour and codes of practice which serve to reduce the possibilities of positions of trust being abused or misused, or false accusations being made.

Partnering organisations

We must exercise due diligence with our partnering organisations that deliver welfare services on our behalf and conduct face-to-face, in-person visits to our financially supported beneficiaries.

In engaging with other charities or organisations under contract to deliver service provision/welfare support e.g. BHS, it is the group’s responsibility to ensure that each of these organisations provides assurances to the group that it has adequate safeguarding policies and procedures, that are reviewed regularly, under which the quality of delivery would be subject to routine scrutiny, and that the details of any safeguarding incident which might have an impact on the group or its reputation are advised to us in a timely manner.

Incident reporting

Staff, volunteers and Trustees need to be aware of their responsibilities for reporting concerns in relation to safeguarding matters and the circumstances in which they should make a referral to the Local Authority* or police if necessary.

Safeguarding concerns about children, young people and vulnerable adults and others who come into contact with the group will be diligently and promptly responded to, recognising the sensitivity it may hold for those involved. Where there is a concern, this should be reported to an appropriate person (Chief Executive, President) immediately where possible, but at least within 24 hours, to determine what action, if any, must be taken. This will enable each situation to be investigated thoroughly, whilst treating the parties involved fairly and with sensitivity. It will also ensure that suitable steps are taken as a result of any investigations, which may include contacting the police and/or fulfilling the legal duty to refer information to the DBS and/or the Local Safeguarding Children Board (LSCB) or Local Safeguarding Adults Board (LSAB) as required. Not all concerns justify a notification to the Local Authority but must still be recorded.

• The Trustees acknowledge their duties to make a Serious Incident report to the Charity Commission and a report of a Notifiable Event made to the Office of Scottish Charity Regulator (OSCR) and other relevant bodies if:
• there has been an incident where someone has been abused or mistreated (alleged or actual) and this relates to the activities of the group;
• beneficiaries/representatives of the group have been, or are alleged to have been, abused or mistreated while under the care of the group, or by someone connected with the group, for example a Trustee, staff member or volunteer; or
• there has been a breach of procedures or policies at the group which has put
  beneficiaries/representatives at risk.

*The Local Authority is the focal point for all reports, alerts, concerns or notifications of possible abuse.

Recruitment

Although most of the group’s activities do not involve regular contact with children or working in
‘regulated activity’ with adults at risk, the group has a responsibility to ensure the suitability of those Trustees, employees and volunteers who may work with, or encounter children and adults at risk.

The group’s recruitment process as well as the quality of our employment contracts are critical to our approach to safeguarding; they must be sufficiently rigorous, robust and appropriately reviewed. Given the nature of the group’s activities, there is currently no requirement for a DBS or Enhanced Disclosure.

As part of recruitment good practice, the group will make robust checks; for example, taking up two references for successful candidates and questioning employment gaps, declaring unspent or relevant criminal convictions, as part of our robust recruitment process.

All new members of staff must be made aware of this policy and given the opportunity to read it during their induction period.

Related policies

• This policy should be read in conjunction with the following group policies and procedures:
• GDPR Policy
• Disciplinary policy, grievance and appeals procedure
• Equal Opportunities Policy
• Health and Safety Policy
• Recruitment Policy
• Whistleblowing Policy
• Serious Incident Reporting Policy

Policy review

This policy will be reviewed by the designated lead regularly and the refreshed version presented to the Board for review.

This policy does not form part of any employee’s contract of employment and the group may amend it at any time.

Annex A: BEVA Ltd Group - Safeguarding policy legal framework

The group’s Safeguarding has been drawn up based on law and guidance that seeks to protect children and vulnerable people:

• Children Act 1989
• United Nations Convention on the Rights of the Child 1991
• Data Protection Act 1998
• Sexual Offences Act 2003
• Children Act 2004
• Charities Act 2011
• Safeguarding Vulnerable Groups Act 2006
• Equality Act 2010
• Protection of Freedoms Act 2012
• Care Act 2014
• Statutory Guidance “Working Together to Safeguard Children 2015”
• Charity Commission guidance: ‘how to protect vulnerable people’ and ‘Strategy for dealing with Safeguarding issues in Charities’
• Relevant government information on safeguarding vulnerable people
• Institute of Fundraising - Treating Donors Fairly
• The Code of Fundraising Practice – The Fundraising Regulator

The primary legislation covering safeguarding for adults is the Care Act 2014.

Annex B: BEVA Ltd Group - Safeguarding policy of safer working practice

Members of staff, volunteers and Trustees should:

• consider the wellbeing and safety of event participants in advance through proper planning and development of safe methods of working/activities;
• treat all children, young people and vulnerable adults with respect and dignity, keeping your own language, attitude and body language respectful;
• actively communicate with children, young people and vulnerable adults and where possible involve them in planning and running of activities;
• develop a culture where staff, children and vulnerable adults feel comfortable to point out inappropriate attitudes and behaviour in each other;
• make it plain to whom someone can speak about a personal concern, and be proactive in addressing concerns and allegations;
• keep physical contact specific to the needs of the activity and always seek permission from the person first;
• never use rough play, sexually provocative words and games or any forms of physical punishment;
• never scapegoat, ridicule or reject a child or vulnerable adult, or allow others to do so;
• avoid one-to-one access with children and young people; make sure that others can clearly observe you;
• avoid personal relationships with a child or vulnerable adult;
• obtain consent for any photographs/videos to be taken, shown or displayed;
• remember that inappropriate behaviour can also occur over the telephone, email, social media or internet – communication through social media should only be on public pages and avoid colloquial language/abbreviations which may be misinterpreted e.g. LOL;
• report incidents of alleged abuse.

Key Points

The Whistleblowing Procedure sets out the framework for dealing with allegations of illegal and improper conduct.

The BEVA Group is committed to the highest standards of transparency, probity, integrity and accountability.

This procedure is intended to provide a means of making serious allegations about standards, conduct, financial irregularity or possible unlawful action in a way that will ensure confidentiality and protect those making such allegations in the reasonable belief that it is in the public interest to do so from being victimised, discriminated against or disadvantaged.

This procedure does not replace other policies and procedures such as the complaints procedure, the Grievance and Harassment and Bullying Policies and other specifically laid down statutory reporting procedures.

This procedure is intended to ensure that the BEVA Group complies with its duty under the Public Interest Disclosure Act 1998.

Scope

This procedure applies to all BEVA employees, including associates, volunteers, trustees and contractors.

This procedure does not replace other BEVA Group policies or procedures. For example, if an employee has a grievance about their working conditions they should use the BEVA Grievance Policy or, if they felt that their manager or a colleague was treating them unfavourably, they should use the BEVA Harassment and Bullying Policy. Similarly if an employee has a concern about the conduct of a fellow employee in the working environment (e.g. that they are not treating colleagues with respect) they should raise these with their line manager, or if that is not possible, with the CEO, President or through the Charity Commission’s whistle blowing policy whistleblowing@charitycommission.gsi.gov.uk

This procedure applies to, but is not limited to, allegations about any of the following:

• Conduct which is an offence or breach of the law
• Alleged miscarriage of justice
• Serious Health and Safety risks
• The unauthorised use of public funds
• Possible fraud and corruption
• Sexual, physical or verbal abuse, or bullying or intimidation of employees, customers or service users
• Abuse of authority
• Other unethical conduct

Reporting

The BEVA Group recognises that the decision to make an allegation can be a difficult one to make. However, whistleblowers who make serious allegations in the reasonable belief that it is in the public interest to do so have nothing to fear because they are doing their duty either to the BEVA Group and/or to those for whom the BEVA Group are providing a service.

The BEVA Group will take appropriate action to protect a whistleblower who makes a serious allegation in the reasonable belief that it is in the public interest to do so from any reprisals, harassment or victimisation.

Confidentiality
All allegations will be treated in confidence and every effort will be made not to reveal a whistleblower’s identity unless the whistleblower otherwise requests.

Similarly, if the allegation results in court proceedings then the whistleblower may have to give evidence in open court if the case is to be successful.
The BEVA Group will not, without the whistleblower’s consent, disclose the identity of a whistleblower to anyone other than a person involved in the investigation/allegation.

Anonymous allegations
This procedure encourages whistleblowers to put their name to an allegation wherever possible as anonymous allegations may often be difficult to substantiate/prove. Allegations made anonymously are much less powerful but anonymous allegations will be considered at the discretion of the CEO/President.

In exercising discretion to accept an anonymous allegation the factors to be taken into account:

• The seriousness of the issue raised
• The credibility of the allegation; and
• Whether the allegation can realistically be investigated from factors or sources other than the complainant

Untrue Allegations
No disciplinary or other action will be taken against a whistleblower who makes an allegation in the reasonable belief that it is in the public interest to do so even if the allegation is not substantiated by an investigation. However, disciplinary action may be taken against a whistleblower who makes an allegation without reasonable belief that it is in the public interest to do so (e.g. making an allegation frivolously, maliciously or for personal gain where there is no element of public interest).

Procedure for Making an Allegation
It is preferable for allegations to be made to an employee’s immediate manager to whom they report. However, this may depend on the seriousness and sensitivity of the issues involved and who is suspected of the malpractice. For example, if the whistleblower believes that management is involved it would be inappropriate to raise it directly with them. The whistleblower may then make an allegation direct to any of the following:

• The CEO
• President

If either of the above receive an allegation he/she will consider the allegation and may discuss with either the CEO or other Trustees.

Allegation
Whether a written or oral report is made it is important that relevant information is provided including:

• The name of the person making the allegation and a contact point.
• The background and history of the allegation (giving relevant dates and names and positions of those who may be in a position to have contributed to the allegation);
• The specific reason for the allegation. Although someone making an allegation will not be expected to prove the truth of any allegations, they will need to provide information to the person they have reported to, to establish that that there are reasonable grounds for the allegation.

Someone making an allegation may be accompanied by another person of their choosing during any meetings or interviews in connection with the allegation. However, if the matter is subsequently dealt with through another procedure the right to be accompanied will at that stage be in accordance with the relevant procedure.

Action on receipt of an Allegation
The line manager will record details of the allegation gathering as much information as possible, (within 5 working days of receipt of the allegation) including:

• The record of the allegation:
• The acknowledgement of the allegation;
• Any documents supplied by the whistleblower

The investigator will ask the whistleblower for his/her preferred means of communication and contact details and use these for all communications with the whistleblower in order to preserve confidentiality.

If the allegation relates to fraud, potential fraud or other financial irregularity the Treasurer will be informed within 5 working days of receipt of the allegation. The Treasurer will determine whether the allegation should be investigated and the method of investigation.

If the allegation discloses evidence of a criminal offence it will immediately be reported to the Board of Trustees and a decision will be made as to whether to inform the Police. If the allegation concerns suspected harm to children or vulnerable adults the appropriate authorities will be informed immediately.

Timetable
An acknowledgement of the allegation in writing within 10 working days with:

• An indication of how the BEVA Group propose to deal with the matter
  
• An estimate of how long it will take to provide a final response
• An indication of whether any initial enquiries have been made
• Information on whistleblower support mechanisms
• Indication whether further investigations will take place and if not, why not

Where the allegation has been made internally and anonymously, obviously the BEVA Group will be unable to communicate what action has been taken.

Support
The BEVA Group will take steps to minimise any difficulties which may be experienced as a result of making an allegation.

The BEVA Group accepts that whistleblowers need to be assured that the matter has been properly addressed. Thus, subject to legal constraints, we will inform those making allegations of the outcome of any investigation.

Responsibility for the Procedure
The CEO and President have overall responsibility for the operation of this Procedure and for determining the administrative processes to be followed and the format of the records to be kept.

Monitoring
A Register will record the following details:

• The name and status (e.g. employee) of the whistleblower
• The date on which the allegation was received
• The nature of the allegation
• Details of the person who received the allegation
• Whether the allegation is to be investigated and, if yes, by whom
• The outcome of the investigation
• Any other relevant details

The Register will be confidential and only available for inspection by the Board of Trustees.

The CEO will report annually to the Board of Trustees on the operation of the Procedure and on the whistleblowing allegations made during the period covered by the report. The report will be in a form which does not identify whistleblowers.