Policies

Corporate Social Responsibility Policy

VERSION 2 - WRITTEN [01/11/2021]  REVIEW DATE [01/11/2023] NEXT DOCUMENT REVIEW [02/11/2024] BY Juliet Trapp

Policy brief & purpose

Voncap Recruitment Limited (VC) Corporate Social Responsibility (CSR) company policy refers to our responsibility toward our environment. VC’s existence is not lonely. It’s part of a bigger system of people, values, ethics and nature. The social responsibility of a business is to give back to the world just as it gives to us.

What is corporate social responsibility?

Our Corporate Social Responsibility (CSR) company policy outlines our efforts to give back to the world as it gives to us.

Scope

This policy applies to VC. It may also refer to suppliers, subcontractors and partners.

Policy elements

We want to be a responsible business that meets the highest standards of ethics and professionalism.

VC’s social responsibility falls under two categories: compliance and proactiveness. Compliance refers to VC’s commitment to legality and willingness to observe community values. Proactiveness is every initiative to promote human rights, help communities and protect our natural environment.

Compliance

Legality

VC will:

Business ethics

We’ll always conduct business with integrity and respect to human rights. We’ll promote:

Examples of Corporate Social Responsibility

Policy brief & purpose

VC recognises the need to protect the natural environment. Keeping our environment clean and unpolluted is a benefit to all. We will try where possible to minimise our impact on the environment by:

Protecting people

We’ll ensure that we:

Human rights

VC is dedicated to protecting human rights. We are a committed equal opportunity employer and will abide by all fair labor practices. We’ll ensure that our activities do not directly or indirectly violate human rights in any country (e.g. forced labor).

Proactiveness

Donations and aid

VC may preserve a budget to make monetary donations. These donations will aim to:

Volunteering

VC will encourage its employees to volunteer. They can volunteer through programs organised internally or externally. VC may sponsor volunteering events from other organisations.

Preserving

Apart from legal obligations, VC will proactively protect the environment. Examples of relevant activities include:

Supporting the community

VC may initiate and support community investment and educational programs. It can provide support to nonprofit organisations or movements to promote cultural and economic development of global and local communities.

Learning

We will actively invest in R&D. We will be open to suggestions and listen carefully to ideas. VC will try to continuously improve the way it operates.

VC is committed to the United Nations Global Compact. We’ll readily act to promote our identity as a socially aware and responsible business. Management must communicate this policy on all levels. Managers are also responsible for resolving any CSR issues.


Environmental Sustainability Policy

VERSION 2 - WRITTEN [01/11/2021]  REVIEW DATE [01/11/2023] NEXT DOCUMENT REVIEW [02/11/2024] BY Juliet Trapp

Purpose

The purpose of this policy is to provide direction to Voncap Recruitment Limited (VC) on the promotion, integration, management, review and evaluation of environmental sustainability within all aspects of the organisation.

Definitions

VC identifies environmentally sustainable development as:

“Meeting present needs without compromising the ability of future generations to meet their own needs.”

Sustainability is a process of ensuring the wise use of all resources within a framework in which environmental, social and economic factors are integrated.

Scope

This policy covers all organisational activities of VC and applies to all employees, learners, employers, and sub-contractors of VC whilst indirectly providing direction and awareness to the wider community and partner organisations.

Legal framework

VC is fully aware of its legal obligations within the following legal framework and is committed to meeting its legal requirements which will include, but not limited to:

Policy statement

VC will seek to promote the conservation and sustainable use of natural resources and to minimise environmental pollution in all its activities, and through its influence over others. The organisation will review each of its policies, programmes and services, and act wherever necessary to meet the standards set out in its policy.

The Board of Directors have committed the organisation to the effective implementation and operation of the Environmental Management System (EMS) and as such have committed the necessary resources to permit this. Moreover, the VC Board of Directors commit to a full annual review of the environmental management system, which will be recorded and signed off each year.

The main environmental impacts of the business include general office waste, kitchen waste and energy usage. In recognising these impacts, through demonstration of continuous environmental improvement and a commitment to pollution prevention, VC will:

Waste Management

VC recognises it has a role in furthering and improving the management of all waste via

Sustainable Procurement

VC recognises it has a vital role in furthering sustainable development, through its procurement of offices, goods and services. Procurement decisions have a major socio-economic and environmental implication, both locally and globally, now and for future generations. VC will therefore strive to:-

People, Education & Awareness:

Policy and Communication:

Procurement Processes

Engaging Suppliers of Goods & Services

Energy Management

VC recognises it has a role in furthering and improving energy management via

Travel and Transport

VC recognises it has a role in furthering and improving the efficiency of work based transport and travel and aims to promote the benefits of fuel efficient motoring and increase awareness of alternative modes of transport, in particular for employees via

Strategic aims

VC has developed eight strategic aims which will be monitored on a quarterly basis.

Responsibilities

The Board of Directors have responsibility for:

The senior management team have responsibility for:

Managers have responsibility for:

All employees have a responsibility for:

 All learners have responsibility for:

Implementation

The Strategic Development Director,Lesley Nicholson, will take full responsibility for implementing this strategy using the following methodology:

Organisational Commitment and Leadership – VC is committed to Environmental Sustainability through the adoption of socially responsible business practises and effective governance. These practises will include a robust and accredited Environmental Management System and other related external accreditations.

It is the belief of VC that its employees should act as role models for learners, associates and sub-contractors and take every opportunity to positively promote the benefits of Environmental Sustainability.

Stakeholder and Community Partnerships – VC is committed to improving the work-based learning sector with regards to Environmental Sustainability. The organisation will seek to lead groups of providers and stakeholder organisations in best practices sharing, dialogue initiation, promotional activities, partnership working and employer awareness.

Opportunities are sought to engage with local community, public and private sector organisations to maximise knowledge sharing and efficient resource utilisation within the sector. Effective engagement will be sought with other providers and stakeholders with a view to overall sector improvement  to the  benefit of learners in Wales.

Appropriate training and development activities will be provided to ensure employees are equipped with the skills and knowledge to fully implement this strategy.

Communication

This strategy will be made available in hard copy in every branch and in an electronic format on the company servers.

Training activities will be introduced to ensure all employees are fully conversant with the content of this strategy.

Employers and learners will be provided with access to this strategy in electronic and hard copy formats at the start of the training programme.

Complaints

Any complaints will be taken seriously and dealt with in a timely and sensitive manner, in accordance with the company disciplinary and grievance procedures.

A copy of the complaints procedure can be obtained by contacting info@voncaprecruitment.co.uk

Monitoring and review processes

This strategy will be reviewed, via the senior management team, on an annual basis to ensure it continues to meet the needs of the business.

Data and performance targets associated with this strategy will be reviewed on an annual basis by the Board of Director

Equality & Diversity Policy

VERSION 2 - WRITTEN [01/11/2021]  REVIEW DATE [01/11/2023] NEXT DOCUMENT REVIEW [02/11/2024] BY Juliet Trapp

Policy statement

Voncap Recruitment Ltd (VC) is committed to developing, maintaining and supporting a culture of equality and diversity in employment in which staff are treated equitably, and where they can realise their potential whatever their age, race, colour, nationality, ethnic origin, creed, disability, sexual orientation, sex, gender identity, marital or civil partnership status, parental status, religion, belief or non-belief, social or economic class, employment status, or any other criteria that cannot be shown to be properly justifiable.

Similarly, VC is committed to developing, maintaining and supporting a culture of equality and diversity in service and learning provision in which learners feel free from harassment and bullying of any description, or any other form of unwanted behaviour, and are also treated equitably and can realise their potential. 

Equality of opportunity and inclusivity is fundamental to the vision and values of VC. The principles of equality and diversity are at the very heart of every operational aspect from selection and recruitment through to teaching and learning, and are supported by appropriate policies, procedures and good practice. VC will not tolerate any form of unlawful discrimination, bullying, harassment or victimisation and aims to promote a culture in which staff and learners feel supported and encouraged to challenge discriminatory and/or unacceptable behaviour at all levels.  

Scope

This policy applies to all VC offices, operations, activities anda services, without exception, and to all VC employees at all levels of the organisational structure. The Aims of this policy will equally apply to all VC operations and activities conducted on sites beyond VC control wherever its employees are designated to perform their contractual duties.  

Aims

Equality is not about treating everyone the same, it is about ensuring that access to opportunities is available to all by taking account of differing needs and capabilities. Diversity is about recognising and valuing differences through inclusion, regardless of age, disability, gender, racial origin, religion, belief, sexual orientation, perspectives, opinions and personal values. 

Definitions

The Equality Act 2010 makes it unlawful for employers to discriminate on the grounds of race, religion or belief, disability, gender or gender reassignment, age, sexual orientation, marriage or civil partnership, pregnancy or maternity; all of which are referred to as individuals or groups with ‘protected characteristics’. VC and this policy aims to protect all employees and all individuals who use VC services, such as learners, in relation to the following aspects. 

Discrimination

The Equality Act (2010) expands upon previous definitions of Discrimination and circumstances in which this may arise as follows:  

Harassment

The Equality Act (2010) defines harassment as “unwanted conduct related to a relevant protected characteristic, which has the purpose or effect of violating an individual’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that individual”. It expands upon previous definitions of harassment and circumstances in which this may arise as follows:  

Age

The Act protects people of all ages. However, different treatment because of age is not unlawful direct or indirect discrimination if it can be justified i.e. if it can be demonstrated that it is a proportionate means of meeting a legitimate aim. Age is the only protected characteristic that allows employers to justify direct discrimination. 

Disability

The Act has made it easier for a person to show that they are disabled and protected from disability discrimination. Under the Act, a person is disabled if they have a physical or mental impairment which has a substantial and long-term adverse effect on their ability to carry out normal day-to-day activities, which would include things like using a telephone, reading a book or using public transport.  

As before, the Act puts a duty on an employer to make reasonable adjustments for employees or service users to help them overcome disadvantage resulting from an impairment (e.g. by providing assistive technologies to help visually impaired staff use computers effectively). The Act includes a new protection from discrimination arising from disability. This states that it is discrimination to treat a disabled person unfavourably because of something connected with their disability (e.g. a tendency to make spelling mistakes arising from dyslexia). This type of discrimination is unlawful where the employer or other person acting for the employer knows, or could reasonably be expected to know, that the person has a disability. This type of discrimination is only justifiable if an employer can show that it is a proportionate means of achieving a legitimate aim. Additionally, indirect discrimination now covers disabled people. This means that a job applicant or employee could claim that a particular rule or requirement that an employer has in place disadvantages people with the same disability. Unless this could be justified, it would be unlawful. The Act also includes a new provision which makes it unlawful, except in certain circumstances, for employers to ask about a candidate’s health before offering them work. 

Gender reassignment

The Act provides protection for individuals who propose to, starts or has completed a process to change his or her gender. The Act no longer requires a person to be under medical supervision to be protected – so a woman who decides to live as a man but does not undergo any medical procedures would be protected. It is discrimination to treat people less favourably for being absent from work because they propose to undergo, are undergoing or have undergone gender reassignment than they would be treated if they were absent because they were ill or injured. 

Marriage and Civil Partnership

The Act protects individuals who are married or in a civil partnership against discrimination. Single people are not protected. 

Pregnancy and Maternity

A woman is protected against discrimination on the grounds of pregnancy and maternity during the period of her pregnancy and any statutory maternity leave to which she is entitled. During this period, pregnancy and maternity discrimination cannot be treated as sex discrimination. An employer must not take into account an employee’s period of absence due to pregnancy-related illness when making a decision about her employment. 

Race

For the purposes of the Act ‘race’ includes colour, nationality and ethnic or national origins. 

Religion and Belief

In the Equality Act, religion includes any religion. It also includes a lack of religion, in other words individuals are protected if they have no religion at all. Additionally, a religion need not be mainstream or well known to gain protection but must have a clear structure and belief system. Denominations or sects within a religion can be considered a protected religion or religious belief. Belief means any religious or philosophical belief or a lack of such belief. To be protected under the Act, a belief must satisfy various criteria, including that it is a weighty and substantial aspect of human life and behaviour, and not just an opinion. Discrimination because of religion or belief can occur even where both the discriminator and recipient are of the same religion or belief. 

Gender

Applies to both men and women, and both are equally protected under the Act. 

Sexual orientation

Sexual orientation is a protected characteristic. It means a person’s sexual orientation towards: 

Gender reassignment is a separate protected characteristic and unrelated to sexual orientation – despite a common misunderstanding that the two characteristics are related. 

Complaints

All complaints of discrimination, harassment or bullying will be treated seriously and dealt with promptly, efficiently and where possible in confidence. The aim of the procedure is to resolve complaints of discrimination, harassment or bullying swiftly and confidentially.  

Any employee or learner may use the complaints procedure if they believe they have:  

Any employee or learner who believes they have been the victim of discriminatory treatment, or who has witnessed discrimination or harassment, may choose to take informal or formal action. 

Informal action

Where possible the employee or learner should talk directly and informally to the person they believe has discriminated against them and explain their objection to their actions or conduct. It may be that the person whose conduct is causing offence is genuinely unaware that their behaviour is unwelcome or objectionable.  

If the employee or learner feels unable to approach the person or if they have already done so without any resolution, they may elect to raise a formal complaint with the VC Safeguarding Team.

Formal action

The employee or learner may raise the complaint with the Safeguarding Team by emailing juliet@voncaprecruitment.co.uk. The complainant must identify the person who is alleged to have perpetrated discriminatory treatment and give specific examples of actions or conduct that the learner believes constitutes discrimination.  

In the event of serious allegations, it may be necessary to consider whether to suspend the alleged perpetrator to prevent any further contact between parties until the matter can be fully dealt with.  

An investigation will be conducted and will be handled with due respect to the rights of the complainant and alleged perpetrator. Both parties will be interviewed separately where they will be provided with the opportunity to state their side of events and explain any conduct that forms the basis of the employee’s or learner’s complaint. 

If, following the investigation, the complaint is founded, suitable and proportionate action will be taken promptly to remedy the discrimination and prevent any recurrence.  

The organisation regards all forms of discrimination as gross misconduct (except unintentional behaviour of a mild nature) and any employee or learner found guilty of this behaviour will be liable to proportionate disciplinary measures up to and including summary dismissal. Disciplinary measures will also be taken against any learner or employee who is found to have made a deliberately false or malicious complaint of discrimination. 

Responsibilities

The Governance Board is responsible for ensuring that VC complies with equalities legislation and promotes equality of opportunity and diversity throughout the organisation. Overall responsibility for implementation and overseeing this Policy rests with the Safeguarding Team.

All VC managers are responsible for developing an open and inclusive culture in which employees and learners feel able and encouraged to report any incidents of discrimination, harassment and bullying in the workplace. Managers are expected to actively support employees and learners making a complaint, ensuring that any such allegations are fully and thoroughly investigated and dealt with appropriately. 

Managers will be responsible for ensuring that awareness is raised with third parties that harassment will not be tolerated, complaints of discrimination and harassment will be investigated, and action taken against offenders found guilty of such as appropriate to protect employees and learners from further occurrences.  

Managers will also be responsible for setting high standards for equality and diversity in VC workplaces, and for ensuring that all employees and learners are aware of the requirements of this policy and that it is applied fairly, rigorously and consistently.  

Every member of staff carries personal responsibility for their own behaviour at work and for ensuring that this policy is translated into practice in all areas of employment and service provision.  

All staff have a duty to report any incidents of discrimination, harassment or bullying that come to their attention, and to take part in any investigation into such allegations, to support VC in the development of a culture in which employees and learners feel able and supported to report such concerns and have them fairly and robustly addressed.  

VC gives an assurance that there will be no victimisation against an employee or learner making a genuine complaint in good faith or against employees or learners who assist or support colleagues or peers in making such a complaint.  

The contents of this policy will be communicated to all employees and learners during induction to their role or their qualification and thereafter at each subsequent policy review. Absolute compliance with this Equality and Diversity Policy is a condition of employment. 


Health and Safety Policy

VERSION 2 - WRITTEN [01/11/2021]  REVIEW DATE [01/11/2023] NEXT DOCUMENT REVIEW [02/11/2024] BY Juliet Trapp


1.0 Policy statement

1.1 The Directors and staff of Voncap Recruitment Limited (VC)  are committed to providing a safe, secure and pleasant working environment in which learners, trainers and employees are able to maximise their full potential, irrespective of their gender, age, race, disability, marital status or other. 

1.2 We are all committed to identifying and eliminating discriminatory practices, procedures, attitudes and behaviour throughout our organisation. We will extend this philosophy to ensure that our learners, trainers and employees, external suppliers, understand this policy and its implications.

1.3 We believe that all learners, trainers, employees are entitled to be treated with dignity, respect and fairness while at work and when representing the organisation in any outside capacity.

1.4 The clear and unambiguous aim of this policy is to provide guidance to the learner should he or she wish to challenge the outcome of an assessment or training decision if they consider the assessment or training has not been carried out correctly.

2.0 Health and Safety Policy Statement

2.1. It is policy of VC to meet all statutory requirements relating to health and safety and to apply the appropriate standards to ensure the health, safety and welfare of all learners, trainers and employees of VC. 

2.2. The Directors of VC bear the legal responsibility for all matters of health, safety and welfare within our assessment and training activities and to ensure that statutory requirements are met and appropriate standards applied. The management responsibility for the development and implementation of the health and safety policy is Juliet Trapp.

2.3. The management of Health and Safety is an integral part of good management at all levels of our organisation. This includes the provision of:

2.4. Internal Quality Assurers and Trainers are accountable for the proper implementation of health and safety policies and procedures in their respective areas and compliance with VC and statutory requirements.

2.5. Those supervising work, assessment or training of any kind are responsible for ensuring that all companies, learners, trainers and employees under their direction do not jeopardise the Company’s compliance with the law.

2.6. It is incumbent on all members of VC and visitors to the Company to recognise their own individual responsibility to be aware of, and to comply with, all health and safety requirements relevant to their activities.

2.7. This policy statement is issued to all learners, trainers and employees and will be subject to periodic review in the light of experience and developments in national health and safety legislation.

Summary of Company Health and Safety Policy Statements and Codes of Practice

3.1 Health Protection

VC require that the health of learners, trainers and employees affected by our activities should be protected by avoiding, as far as is reasonably practical, exposure to hazardous substances, dangerous tasks, working conditions or environments. The associated code of practice covers the health protection measures, which require medical advice or interventions, [e.g. health monitoring and vaccinations] to reduce risks, which cannot be avoided by procedural controls. It describes the arrangements designed to:

3.2 Risk Assessment and Risk Control

VC require that the risks of all activities, on and off site, which may affect the health and safety of its learners, trainers, staff and others be assessed. The risk control measures that are implemented should be what is reasonably practicable in the circumstances and should be regularly monitored and reviewed. The way assessments are undertaken will depend on the nature of the activity and the type and extent of its hazards and risks. The process described in the associated code of practice is a practical one and should include managers and representative learners, trainers and employees.

3.3 Representations, Communication and Consultation.

VC require that arrangements are made for representation, consultation and communication with learners, trainers and employees affected by our activities The arrangements, as described in the associated code of practice, should be open, responsive and timely and should reflect the range of Company activities and working situations, including off site working.

3.4 Training, Competence and Supervision.

VC require that learners, trainers and staff are provided with appropriate information, instruction, training, and supervision to ensure they can achieve the level of competence they need to work in a safe and healthy manner. The associated code of practice covers the general arrangements and refers to specific statutory and VC requirements.

 

VC requires learners, trainers and employees to meet the performance standards set. These standards will be quantifiable, specific, achievable, relevant, and realistic. Their achievement should be monitored and action taken on the results of the monitoring. The setting, publishing, achievement and measurement of these standards will underpin Company health and safety arrangements. The associated code of practice describes the process of standard setting, measurement and follow up action.

3.6 Document Management

VC requires documentation to demonstrate compliance with Statutory and Company Policies. Proper documentation is critical to the VC Quality Assurance for the control of all activities that might affect health and safety. All levels of documentation should form a coherent entity that makes it possible to trace or audit from one level to the next. The associated code of practice describes the documentation necessary for effective communication and monitoring change. The code recognises that documentation supports the system, does not drive it and should be kept to the minimum necessary for compliance.

3.7 Audit Inspection and Review

VC requires Internal Quality Assurers and Trainers to undertake regular self-inspections in order to assess their own performance and take any necessary remedial action. The associated code of practice describes the arrangements for: audit, inspection and review, and the consequential actions taken, which are the basis for self-regulation and confirming compliance with VC and statutory requirements. VC is committed to establishing audit systems to compliment its existing inspection and review arrangements.

3.8 Workplace Safety

VC require all offices, classrooms and other workplaces to be suitable for the work activities which take place in them so as to protect the health and safety of learners, trainers and others who work there. All operations that involve a risk of injury or harm should be avoided as far as is reasonably possible and all work and activities will be expected to comply with statutory and Company requirements. Learning delivery must ensure they comply with on-site Health & Safety practices.

Non Standard Working Environments

VC requires learners, trainers and employees to ensure that as far as is reasonably practicable individuals should not undertake any work/activity in non standard work environments which present unusual hazards. The associated code of practice describes the requirement for safety plans to be prepared in advance, where work / activities involves lone working, work, travel or stays in exposed, hostile or potentially hostile environments. Internal Quality Assurers and Trainers should confirm, through their hazard identification and risk assessment procedures, what comes within this definition and their safety plans which should include supervisory and communication arrangements and should be regularly monitored and reviewed.

4.0 Off Site Working

VC requires:

All offsite work to be organised so as to minimise the risks to the health and safety of learners, trainers and employees. 

If you have any queries about the contents of the policy, please contact Juliet Trapp,, VC Managing Director


Modern Slavery Policy

VERSION 2 - WRITTEN [01/11/2021]  REVIEW DATE [01/11/2023] NEXT DOCUMENT REVIEW [02/11/2024] BY Juliet Trapp


POLICY PURPOSE

Modern slavery is a crime and a violation of fundamental human rights. It takes various forms, such as slavery, servitude, forced and compulsory labour and human trafficking, all of which have in common the deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain.

Voncap Recruitment Limited (VC) has a zero-tolerance approach to modern slavery and we are committed to acting ethically and with integrity in all our business dealings and relationships and to implementing and enforcing effective systems and controls to ensure modern slavery is not taking place anywhere in our own business or in any of our supply chains.

VC Limited is also committed to ensuring there is transparency in our own business and in our approach to tackling modern slavery throughout our supply chains, consistent with our disclosure obligations under the Modern Slavery Act 2015. We expect the same high standards from all of our contractors, suppliers and other business partners. As part of our contracting processes, we include specific prohibitions against the use of forced, compulsory or trafficked labour, or anyone held in slavery or servitude, whether adults or children, and we expect that our suppliers will hold their own suppliers to the same high standards.

SCOPE/TO WHOM THIS POLICY APPLIES

This policy applies to all persons working for VC Limited or on our behalf in any capacity, including employees at all levels, directors, officers, agency workers, interns, agents, contractors, external consultants, third-party representatives, and business partners. This policy does not form part of any employee’s contract of employment and VC Limited may amend it at any time.

RELATED POLICIES AND PROCEDURES

This Modern Slavery (Anti-Slavery and Human Trafficking) Policy interacts with the Whistleblowing Policy which can be found in Policies and Procedures folder. You are encouraged to familiarise yourself with the policies detailed in the folder. If you have any queries about this policy please contact the Managing Director, Juliet Trapp.

RESPONSIBILITY FOR POLICY

VC Limited Governors have overall responsibility for ensuring this policy with senior management; and managers have day to day responsibility to ensure compliance with our legal and ethical obligation.

The Managing Director, Juliet Trapp has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it, and auditing internal control systems and procedures to ensure they are effective in countering modern slavery.

Management at all levels are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it and the issue of modern slavery in supply chains.

COMPLIANCE WITH THIS POLICY

You must ensure that you read, understand, and comply with this policy. The prevention, detection, and reporting of modern slavery in any part of our business or supply chains is the responsibility of all those working for us or under our control. You are required to avoid any activity that might lead to, or suggest, a breach of this policy. You must notify your manager OR the Managing Director, Juliet Trapp as soon as possible if you believe or suspect that a conflict with this policy has occurred or may occur in the future. You are encouraged to raise concerns about any issue or suspicion of modern slavery in any parts of our business or supply chains of any supplier tier at the earliest possible stage.

If you believe or suspect a breach of this policy has occurred or that it may occur you must notify your manager or the Managing Director, Juliet Trapp or you may report it in accordance with our Whistleblowing Policy as soon as possible. If you are unsure about whether a particular act, the treatment of workers more generally, or their working conditions within any tier of our supply chains constitutes any of the various forms of modern slavery, raise it with your manager or the Managing Director, Juliet Trapp.

We aim to encourage openness and will support anyone who raises genuine concerns in good faith under this policy, even if they turn out to be mistaken. VC Limited is committed to ensuring no one suffers any detrimental treatment as a result of reporting in good faith their suspicion that modern slavery of whatever form is or may be taking place in any part of our own business or in any of our supply chains. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the compliance manager immediately. If the matter is not remedied, and you are an employee, you should raise it formally using the Grievance Procedure which can be found in Policies and Procedures folder.

COMMUNICATION AND AWARENESS OF THIS POLICY

Training on this policy, and on the risk our business faces from modern slavery in its supply chains, will be provided as necessary. Our zero-tolerance approach to modern slavery must be communicated to all suppliers, contractors and business partners at the outset of our business relationship with them and reinforced as appropriate thereafter.

BREACHES OF THIS POLICY

Any employee who breaches this policy will face disciplinary action, which could result in dismissal for misconduct or gross misconduct. VC Limited may terminate our relationship with other individuals and organisations working on our behalf if they breach this policy.


Anti Bribery Policy

VERSION 2 - WRITTEN [01/11/2021]  REVIEW DATE [01/11/2023] NEXT DOCUMENT REVIEW [02/11/2024] BY Juliet Trapp


Voncap Recruitment Limited (VC) is committed to applying the highest standards of ethical conduct and integrity in its business activities in the UK and overseas. Every employee and individual acting on the organisation’s behalf is responsible for maintaining the organisation’s reputation and for conducting company business honestly and professionally.

VC considers that bribery and corruption have a detrimental impact on business by undermining good governance and distorting free markets.

VC benefits from carrying out business in a transparent and ethical way and helping to ensure that there is honest, open and fair competition in all matters. Where there is a level playing field, VC can lead the market through being creative and innovative in key business activities that differentiate VC from competitors and by delivering excellent services to its stakeholders.

Transparent, fair conduct helps to foster deeper relationships of trust between VC and its business partners and stakeholders. It is vital for VC’ reputation and future growth.

VC does not tolerate any form of bribery, whether direct or indirect, by, or of, its employees, officers, agents or consultants or any persons or companies acting for it or on its behalf. The board and senior management are committed to implementing and enforcing effective systems throughout VC to prevent, monitor and eliminate bribery, in accordance with the Bribery Act 2010.

This anti-bribery policy (which forms part of your Contract of Employment) outlines the organisation’s position on preventing and prohibiting bribery. The anti-bribery policy applies to all employees, including those of any subsidiary] as well as agency workers, consultants and contractors All employees and other individuals acting for VC are required to familiarise themselves and comply with the organisation’s anti-bribery policy with immediate effect.

Employees and others acting for or on behalf of VC are strictly prohibited from making, soliciting or receiving any bribes or unauthorised payments.

As part of its anti-bribery measures, VC is committed to transparent, proportionate, reasonable and bona fide hospitality and promotional expenditure. Such expenditure must be authorised in advance, in accordance with the procedures set out in the organisation’s [anti­ bribery policy].

A breach of the organisation’s anti-bribery policy by an employee will be treated as grounds for disciplinary action, which may result in a finding of gross misconduct, and immediate dismissal. Employees and other individuals acting for VC should note that bribery is a criminal offence that may result in up to 10 years’ imprisonment and/or an unlimited fine for the individual and an unlimited fine for the organisation.

The success of the organisation’s anti-bribery measures depends on all employees, and those acting for the organisation, playing their part in helping to detect and eradicate bribery. Therefore, all employees and others acting for, or on behalf of, VC are encouraged to report any suspected bribery in accordance with the procedures set out in the anti-bribery policy. VC will support any individuals who make such a report, provided that it is made in good faith.

This Anti Bribery policy is not contractual and may be varied by the organisation at any time.


Privacy & GDPR Policy

VERSION 3 - WRITTEN [01/11/2021]  REVIEW DATE [01/11/2023] NEXT DOCUMENT REVIEW [02/11/2024] BY Juliet Trapp


Policy Statement

This policy statement is effective immediately for all users, provided that the enhanced date protection rights include within the policy required under the EU General Data Protection Regulations (GDPR) come into effect on May 25, 2018.

Scope

This policy applies to Voncap Recruitment Ltd (VC). This privacy policy describes how we use the personal information that we collect from you, or that you provide, when you visit any of our websites (the ‘website) or use our products and services that we provide or otherwise contact us.

Personal Data

Personal data relates to any information about a natural person that makes you identifiable which may include but is not limited to:

Sensitive Personal Data

Sensitive personal data refers to the above but includes genetic data and biometric data for example:

A Data Controller

For GDPR purposes, the “data controller” means the person or organisation who decides the purposes for which and the way in which any personal data is processed. The data controller is Juliet Trapp who can be contacted at  juliet@voncaprecruitment.co.u

A Data Processor

A “data processor” is a person or organisation which processes personal data for the controller.

Data Processing

Data processing is any operation or set of operations performed upon personal data, or sets of it, be it by automated systems or not. Examples of data processing explicitly listed in the text of the GDPR are collection, recording, organising, structuring, storing, adapting, altering, retrieving, consulting, using, disclosing by transmission, disseminating or making available, aligning or combining, restricting, erasure or destruction.

Information we collect about you and how

We collect a range of personal information about you in a variety of ways. This could be, but not limited to, the use of forms, paper or electronic from our websites, when you sign up to receive our newsletters, register for information or engage in the services that we offer. If you are progressing your career through VC, we may need to collect additional personal information from you in order to secure funding or satisfy legal or governmental scheme requirements. Further information on the requirements for learners can found within the Apprenticeship Funding and Performance Management Rules www.gov.uk/government/publications/apprenticeship-funding-and-performance-management-rules-2017-to-2018

We also collect personal information from you when you communicate with us for any reas

In addition, we will automatically collect information from you when you visit our websites i.e. sending an enquiry, signing up for an event, filing in a survey or giving feedback. Website usage information is collected using cookies.

We may record and store telephone conversation you may have with us for the purposes of quality improvement, staff training and or to prevent/detect crime. You will always be notified if your call is being recorded.

If you chose to provide us with your information this processing of personal data is based on consent.

Information for Apprentices

Some of the information provided by you will be used by the Education and Skills Funding Agency (ESFA) in order to fulfil its statutory duties and functions, issue/verify your Unique Learner Number (ULN) in order to maintain your Personal Learning Record. The ESFA may share your ULN and Personal Learning Record with other education related organisations. Further details of how your information is processed and shared can be found at the following website www.gov.uk/government/publications/lrs-privacy-notices 

Use of Cookies

We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer and accesses each time you visit so we can understand how you use our site and serve you content based on preferences you have specified. For more information visit www.aboutcookies.org  or www.allaboutcookies.org  

You have the right to choose whether or not to accept cookies and to set your own cookie preferences on your computer. If you do not wish to accept cookies from us, you should instruct your browser to refuse cookies from our website, with the understanding that we may be unable to provide you with some of your desired service without them. This policy covers only the use of cookies between your computer and our website; it does not cover the use of cookies by any advertisers.

Analytics

We use Google Analytics to store information about how visitors use our website so that may make improvements and give visitors a better user experience.

Google Analytics is a third party information storage system that records information about the pages that you visit, the length of time you were on specific pages and the website in general, how you arrived at the site and what you clicked on when you were there. These cookies do not store any personal information about you e.g. your name, address etc and we do not share the data. You can view their privacy policy at policies.google.com/privacy     

IP Addresses

An IP or Internet Protocol Address is a unique numerical address assigned to a computer as it logs onto the internet. Your IP address is logged when you visit our website and in addition VC use Lead Forensics, a third-party software that reveals the identity of your anonymous website traffic and turns them into actionable leads within a business to business environment. You can view their privacy policy at www.leadforensics.com/privacy-and-cookies 

Internet Based Advertising

We use LinkedIn, Facebook and Twitter advertising services and as such there are tracking codes installed on our website so that we can manage the effectiveness of these campaigns. We do not store any personal data within this type of tracking.

Using the Information about you and why

The information that we collect and store relating to you is primarily used to enable us to provide our services to you. In addition, we may use the information for the following purposes:

If you do not want us to use your data for any marketing purposes, you will have the opportunity to withhold your consent to this when you provide your details to us. Should you wish to withdraw your consent for such purposes please contact  juliet@voncaprecruitment.co.u

For Business to Business Clients and Contacts our lawful reason for processing your personal information will be “legitimate interests”. Under “legitimate interests” we can process your personal information if: we have a genuine and legitimate reason and we are not harming any of your rights and interests.

For Business to Consumer Clients and Contacts our lawful reason for processing your personal information will be “A contract with the individual”, for example to supply goods and services you have requested, or to fulfil obligations under an employment contract or an Apprenticeship Agreement. This also includes steps taken at your request before entering into a contract.

Our work for you may require us to pass your information to our third-party service providers, agents, subcontractors and other associated organisations for the purposes of completing tasks and providing the Services to you on our behalf. However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the Services and we have contracts in place that requires them to keep your information secure and not to use it for their own direct marketing purposes.

We collect information on our website to process your enquiry, deal with your event registration, give advice based on survey data and improve our services. If you agree, we will also use this information to share updates with you about our services which we believe may be of interest to you.

We will not share your information for marketing purposes with companies so that they may offer you their products and services.

We may disclosure your personal information to any company within our group, third parties that we contract to provide services on our behalf or where third-party funding is required within Apprenticeships. In addition, we may be required to provide information to government agencies, where required by the learner and any third part that purchases all or substantially all of our assets and business.

In accordance with legal and regulatory requirements we may be required to disclose your personal information to any law enforcement agency, court, regulator, government authority or other third party where we believe this is necessary in order to comply with our obligations or otherwise to protect our rights or the rights of any third party.

Transferring your information outside Europe

As part of the services offered to you through this website, the information which you give to us may be transferred to countries outside the European Union (“EU”). For example, some of our third-party providers may be located outside of the EU. Where this is the case, we will take steps to make sure the right security measures are taken so that your privacy rights continue to be protected as outlined in this policy. By submitting your personal data, you’re agreeing to this transfer, storing or processing. 

If you use our services while you are outside the EU, your information may be transferred outside the EU to give you those services.

Security Precautions in place about Data collected

When you give us personal information, we take steps to make sure that it’s treated securely. Any personal information you supply to us is stored within secure servers. When you are on a secure page, a lock icon will appear on the bottom of web browsers such as Microsoft Internet Explorer.

Non-sensitive details (your email address etc.) are sent normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Profiling

We may analyse your personal information to create a profile of your interests and preferences so that we can contact you with information relevant to you. We may make use of extra information about you when it is available from external sources to help us do this effectively. We may also use your personal information to detect and cut fraud and credit risk.

3.4 Training, Competence and Supervision.

VC requires learners, trainers and employees to meet the performance standards set. These standards will be quantifiable, specific, achievable, relevant, and realistic. Their achievement should be monitored and action taken on the results of the monitoring. The setting, publishing, achievement and measurement of these standards will underpin Company health and safety arrangements. The associated code of practice describes the process of standard setting, measurement and follow up action.

Marketing

We would like to send you information about our services which may be of interest to you. If you have consented to receive marketing, you may opt out at any point as set out below.

You have a right at any time to stop us from contacting you for marketing purposes. To opt out please email: juliet@voncaprecruitment.co.uk

Holding your Data

Marketing: We will hold your data for a period of 6 years with a review every 3 years. You will have the opportunity to opt out or update or delete data at any point should you need to do so, and details are set out in this policy as to how to do that.

Contracted Services: We will hold your data for 7 years in line with our regulatory requirements.

Access to your Information, Correction, Portability and Deletion

Subject Access Request

If you would like a copy of some or all your personal information, please email or write to us at the following address with the correct fee. VC currently requires a fee of £10 (the statutory maximum) with all SARs. VC, . We will respond to your request within one month of receipt of the request.

We want to make sure your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate by writing to the above address or emailing  juliet@voncaprecruitment.co.u

Objections to processing of personal data

It is your right to lodge an objection to the processing of your personal data if you feel the “ground relating to your particular situation” applies. The only reasons we will be able to deny your request is if we can show compelling legitimate grounds for the processing, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defence of a legal claims.

Data Portability

It is also your right to receive the personal data which you have given to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without delay from the current controller if:

All offsite work to be organised so as to minimise the risks to the health and safety of learners, trainers and employees. 

(a) The processing is based on consent or on a contract, and

(b) The processing is carried out by automated means.

Your Right to be Forgotten

Should you wish for us to completely delete all information that we hold about you for:

Email: juliet@voncaprecruitment.co.uk or

Other Websites

Our website may contain links to other websites. This privacy policy is only applicable to this website so when you link to other websites should read their own privacy policies.

Complaints

The organisation is dedicated to being compliant with the Act and, from 25 May 2018, the GDPR. Individuals, any member of staff, applicant or a student wishing to report concerns should, in the first instance, contact the Data Protection Officer who will aim to resolve any issue:

Data Protection Officer 

Email: juliet@voncaprecruitment.co.uk

If the individual, member of staff or student feels the complaint has not been dealt with to their satisfaction, he/she can formally complain to the Registrar.

Information Commissioner’s Office

Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF.

Internet: www.ico.org.uk   

Changes to Privacy Policy

We reserve the right to update this privacy notice at any time to take account of changes in our business and legal requirements. We will place updates on our website. Please refer to the ‘last updated’ date at the top of this Privacy Policy to see when it was last revised.