D&I Recruitment Ltd does not support child labour and we are committed to this by not employing anyone under the age of 18 years old.

 To ensure this we insist on seeing original identification when a candidate registers with us. This can be a Passport, ID Card or Birth Certificate.

 We also go one step further by using a system called TrustID which scans the ID of everyone that we

register to ensure that the ID provided is genuine and that the person has the right to work in the UK.

 

 

The Agency Workers Regulations came into force on the 1st of October 2011. The Agency Workers Regulations originate from the Agency Workers Directive. The aim of the legislation is for agency workers to be provided with equal treatment in the workplace.

​Upon completion of a 12 week qualifying period in the same job with the same hirer, agency workers will be entitled to the same basic working and payment conditions that they would have received if they had been recruited by the hirer directly.

​Under the regulations there are also ‘day one rights’, which apply from the first day of the assignment. These rights include access to onsite collective amenities (such as car parking and canteen), as well as access to information about permanent job vacancies. It is possible that the hirer may decline to offer certain facilities provided they can show good justification for doing so.

​After you have worked in the same temporary job for the same hirer for 12 weeks, you may well qualify for equal treatment in respect of basic working and employment conditions, including pay. You can accumulate these weeks even if you only work a few days each week; however you must work within 12 separate weeks in order to qualify for equal treatment. Any gap of more than six weeks will mean your qualifying period will start again.

​D&I Recruitment will ask for details of your work history, including work done through other agencies to help establish when you will be (or if you are already) entitled to equal treatment. You will need to disclose to your D&I Recruitment consultant any periods of time during which you worked for the hirer or a group company of the hirer in the preceding months. Failure to do so may mean that you delay the opportunity to receive equal treatment until you have completed a further period of 12 weeks service with the hirer.

​For further information about the Agency Workers Regulations speak to your D&I Recruitment Consultant or visit the gov website.

 

 

Complaints Policy
D&I Recruitment Ltd is committed to providing a high level of service to our customers. If you do not receive satisfaction from us, we need you to tell us about it. This will help us to improve our standards.

Complaints Procedure
If you have a complaint, please contact Maddy Coman Recruitment Manager by phone 0203 744 2211 in the first instance so that we can try to resolve your complaint informally.

At this stage, if you are not satisfied please contact Ioan Maftei, Director. You can write to him at: Suite 3, 12B High View Parade, Woodford Avenue, Ilford, Essex, IG4 5EP.

Next steps

1. We will send you a letter acknowledging your complaint and asking you to confirm or explain the details set out. We will also let you know the name of the person who will be dealing with your complaint. You can expect to receive our letter within 5 days of us receiving your complaint.

2. We will record your complaint in our central register within a day of having received it.

3. We will acknowledge your reply to our acknowledgment letter and confirm what will happen next. You can expect to receive our acknowledgement letter within 5 days of your reply.

4. We will then start to investigate your complaint. This will normally involve the following steps; We may ask the member of staff who dealt with you to reply to your complaint within 5 days of our request; We will then examine the member of staff’s reply and the information you have provided for us. If necessary, we may ask you to speak to them. This will take up to 4 days from receiving their reply.

​5. Ioan Maftei will then invite you to meet him to discuss and hopefully resolve your complaint. He will do this within 5 days of the end of our investigation.

6. Within 2 days of the meeting Ioan Maftei will write to you to confirm what took place and any solutions she has agreed with you. If you do not want a meeting or it is not possible, Ioan Maftei will send you a detailed reply to your complaint. This will include his suggestions for resolving the matter. He will do this within 5 days of completing his investigation.

7. We will let you know of the outcome of this review within 5 days of the end of the review. We will write to you confirming our final position on your complaint and explaining our reasons. If you are still not satisfied, you can contact the Employment Agencies Standards Inspectorate at the Department for Business Innovation and Skills or the REC, the industry trade association, of which we are a member by writing to the Consultancy and Compliance Team, REC, Dorset House, 1st Floor, 27-45 Stamford Street, London, SE1 9NT.

If we have to change any of the time scales above, we will let you know and explain why. NOTE: In any event, we will comply with any statutory procedures that may relate to your complaint.

 

 

 

All organisations that process personal data are required to comply with data protection legislation.  This includes in particular the Data Protection Act 1998 (or its successor) and the EU General Data Protection Regulation (together the ‘Data Protection Laws’).  The Data Protection Laws give individuals (known as ‘data subjects’) certain rights over their personal data whilst imposing certain obligations on the organisations that process their data.

 As a recruitment business the Company collects and processes both personal data and sensitive personal data.  It is required to do so to comply with other legislation.  It is also required to keep this data for different periods depending on the nature of the data.  

 This policy sets out how the Company implements the Data Protection Laws. It should be read in conjunction with the Data Protection Procedure.

 In this policy the following terms have the following meanings:

 ‘consent’ means any freely given, specific, informed and unambiguous indication of an individual’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of persona data relating to him or her;

 ‘data controller’ means an individual or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data;

 ‘data processor’ means an individual or organisation which processes personal data on behalf of the data controller;

 ‘personal data’ means any information relating to an individual who can be identified, such as by a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

 ‘personal data breach’* means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data;

 ‘processing’ means any operation or set of operations performed on personal data, such as collection, recording, organisation, structuring, storage (including archiving), adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

 ‘profiling’ means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements;

 ‘pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to an individual without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable individual;

 ‘sensitive personal data’* means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data, data concerning health, an individual’s sex life or sexual orientation and an individual’s criminal convictions.

 * For the purposes of this policy we use the term ‘personal data’ to include ‘sensitive personal data’ except where we specifically need to refer to sensitive personal data.

 ‘Supervisory authority’ means an independent public authority which is responsible for monitoring the application of data protection. In the UK the supervisory authority is the Information Commissioner’s Office (ICO).

 All of these definitions are italicised throughout this policy to remind the reader that they are defined terms.

 The Company processes personal data in relation to its own staff, work-seekers and individual client contacts and is a data controller for the purposes of the Data Protection Laws. The Company has registered with the ICO and its registration number is Z2453021.

 The Company may hold personal data on individuals for the following purposes:

 Staff administration;

 Advertising, marketing and public relations

 Accounts and records;

 Administration and processing of work-seekers’ personal data for the purposes of providing work-finding services, including processing using software solution providers and back office support.

 Administration and processing of clients’ personal data for the purposes of supplying/introducing work-seekers.

1. The data protection principles

 The Data Protection Laws require the Company acting as either data controller or data processor to process data in accordance with the principles of data protection. These require that personal data is:

 Processed lawfully, fairly and in a transparent manner;

 Collected for specified and legitimate purposes and not further processed in a manner that is incompatible with those purposes;

 Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;

 Accurate and kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;

 Kept for no longer than is necessary for the purposes for which the personal data are processed;

 Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures; and that

 The data controller shall be responsible for, and be able to demonstrate, compliance with the principles.

 2. Legal bases for processing

 The Company will only process personal data where it has a legal basis for doing so. Where the Company does not have a legal reason for processing personal data any processing will be a breach of the Data Protection Laws.

 The Company will review the personal data it holds on a regular basis to ensure it is being lawfully processed and it is accurate, relevant and up to date and those people listed in the Appendix shall be responsible for doing this.

 Before transferring personal data to any third party (such as past, current or prospective employers, suppliers, customers and clients, intermediaries such as umbrella companies, persons making an enquiry or complaint and any other third party (such as software solutions providers and back office support)), the Company will establish that it has a legal reason for making the transfer.

 3. Privacy by design and by default

 The Company has implemented measures and procedures that adequately protect the privacy of individuals and ensures that data protection is integral to all processing activities. This includes implementing measures such as:

 data minimisation (i.e. not keeping data for longer than is necessary);

 pseudonymisation;

 anonymization

 cyber security

 The Company shall provide any information relating to data processing to an individual in a concise, transparent, intelligible and easily accessible form, using clear and plain language. The information shall be provided in writing, or by other means, including, where appropriate, by electronic means. The Company may provide this information orally if requested to do so by the individual.

A. Privacy notices

 Where the Company collects personal data from the individual, the Company will give the individual a privacy notice at the time when it first obtains the personal data.

 Where the Company collects personal data other than from the individual directly, it will give the individual a privacy notice within a reasonable period after obtaining the personal data, but at the latest within one month.  If the Company intends to disclose the personal data to a third party then the privacy notice will be issued when the personal data are first disclosed (if not issued sooner).

 Where the Company intends to further process the personal data for a purpose other than that for which the data was initially collected, the Company will give the individual information on that other purpose and any relevant further information before it does the further processing.

 B. Subject access requests

 The individual is entitled to access their personal data on request from the data controller.

 C. Rectification

 The individual or another data controller at the individual’s request, has the right to ask the Company to rectify any inaccurate or incomplete personal data concerning an individual.

 If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to rectify the personal data unless this proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold – however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred.

 

4. Erasure

 The individual or another data controller at the individual’s request, has the right to ask the Company to erase an individual’s personal data. 

 If the Company receives a request to erase it will ask the individual if s/he wants his personal data to be removed entirely or whether s/he is happy for his or her details to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise).  The Company cannot keep a record of individuals whose data it has erased so the individual may be contacted again by the Company should the Company come into possession of the individual’s personal data at a later date.

 If the Company has made the data public, it shall take reasonable steps to inform other data controllers and data processors processing the personal data to erase the personal data, taking into account available technology and the cost of implementation.

 If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to erase the personal data, unless this proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold – however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred.

 

5. Restriction of processing

 The individual or a data controller at the individual’s request, has the right to ask the Company to restrict its processing of an individual’s personal data where:

 The individual challenges the accuracy of the personal data;

 The processing is unlawful and the individual opposes its erasure;

 The Company no longer needs the personal data for the purposes of the processing, but the personal data is required for the establishment, exercise or defence of legal claims; or

 The individual has objected to processing (on the grounds of a public interest or legitimate interest) pending the verification whether the legitimate grounds of the Company override those of the individual.

 If the Company has given the personal data to any third parties it will tell those third parties that it has received a request to restrict the personal data, unless this proves impossible or involves disproportionate effort. Those third parties should also rectify the personal data they hold – however the Company will not be in a position to audit those third parties to ensure that the rectification has occurred.

 

6. Data portability

 The individual shall have the right to receive personal data concerning him or her, which he or she has provided to the Company, in a structured, commonly used and machine-readable format and have the right to transmit those data to another data controller in circumstances where:

 The processing is based on the individual’s consent or a contract; and

 The processing is carried out by automated means.

 Where feasible, the Company will send the personal data to a named third party on the individual’s request.

 

7. Object to processing

 The individual has the right to object to their personal data being processed based on a public interest or a legitimate interest. The individual will also be able to object to the profiling of their data based on a public interest or a legitimate interest.

 The Company shall cease processing unless it has compelling legitimate grounds to continue to process the personal data which override the individual’s interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

 The individual has the right to object to their personal data for direct marketing.

 

8. Enforcement of rights

 All requests regarding individual rights should be sent to the person whose details are listed in the Appendix.

 The Company shall act upon any subject access request, or any request relating to rectification, erasure, restriction, data portability or objection or automated decision making processes or profiling within one month of receipt of the request. The Company may extend this period for two further months where necessary, taking into account the complexity and the number of requests.

 Where the Company considers that a request under this section is manifestly unfounded or excessive due to the request’s repetitive nature the Company may either refuse to act on the request or may charge a reasonable fee taking into account the administrative costs involved.

 

 

9. Automated decision making

 The Company will not subject individuals to decisions based on automated processing that produce a legal effect or a similarly significant effect on the individual, except where the automated decision:

 Is necessary for the entering into or performance of a contract between the data controller and the individual;

 Is authorised by law; or

 The individual has given their explicit consent.

 The Company will not carry out any automated decision-making or profiling using the personal data of a child.

 Reporting personal data breaches

 All data breaches should be referred to the persons whose details are listed in the Appendix.

 

1. Personal data breaches where the Company is the data controller:

 Where the Company establishes that a personal data breach has taken place, the Company will take steps to contain and recover the breach. Where a personal data breach is likely to result in a risk to the rights and freedoms of any individual the Company will notify the ICO.

 Where the personal data breach happens outside the UK, the Company shall alert the relevant supervisory authority for data breaches in the effected jurisdiction.

 

2. Personal data breaches where the Company is the data processor:

 The Company will alert the relevant data controller as to the personal data breach as soon as they are aware of the breach.

 

3. Communicating personal data breaches to individuals

 Where the Company has identified a personal data breach resulting in a high risk to the rights and freedoms of any individual, the Company shall tell all affected individuals without undue delay.

 The Company will not be required to tell individuals about the personal data breach where:

 The Company has implemented appropriate technical and organisational protection measures to the personal data affected by the breach, in particular to make the personal data unintelligible to any person who is not authorised to access it, such as encryption.

 The Company has taken subsequent measures which ensure that the high risk to the rights and freedoms of the individual is no longer likely to materialise.

 It would involve disproportionate effort to tell all affected individuals. Instead, the Company shall make a public communication or similar measure to tell all affected individuals.

 All individuals have the following rights under the Human Rights Act 1998 (HRA) and in dealing with personal data these should be respected at all times:

 Right to respect for private and family life (Article 8).

 Freedom of thought, belief and religion (Article 9).

 Freedom of expression (Article 10).

 Freedom of assembly and association (Article 11).

 Protection from discrimination in respect of rights and freedoms under the HRA (Article 14).

 If you have a complaint or suggestion about the Company’s handling of personal data then please contact the person whose details are listed in the Appendix to this policy.

 Alternatively, you can contact the ICO directly on 0303 123 1113 or at https://ico.org.uk/global/contact-us/email/

 a) The lawfulness of processing conditions for personal data are:

 Consent of the individual for one or more specific purposes.

 Processing is necessary for the performance of a contract with the individual or in order to take steps at the request of the individual to enter into a contract.

 Processing is necessary for compliance with a legal obligation that the controller is subject to.

 Processing is necessary to protect the vital interests of the individual or another person.

 Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the data controller.

 Processing is necessary for the purposes of legitimate interests pursued by the controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the individual which require protection of personal data, in particular where the individual is a child.

 b) The lawfulness of processing conditions for sensitive personal data are:

 Explicit consent of the individual for one or more specified purposes, unless reliance on consent is prohibited by EU or Member State law.

 Processing is necessary for carrying out data controller’s obligations under employment, social security or social protection law, or a collective agreement, providing for appropriate safeguards for the fundamental rights and interests of the individual.

 Processing is necessary to protect the vital interests of the individual or another individual where the individual is physically or legally incapable of giving consent.

 In the course of its legitimate activities, processing is carried out with appropriate safeguards by a foundation, association or any other not-for-profit body, with a political, philosophical, religious or trade union aim and on condition that the processing relates only to members or former members (or those who have regular contact with it in connection with those purposes) and provided there is no disclosure to a third party without the consent of the individual.

 Processing relates to personal data which are manifestly made public by the individual.

 Processing is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.

 Processing is necessary for reasons of substantial public interest on the basis of EU or Member State law which shall be proportionate to the aim pursued, respects the essence of the right to data protection and provide for suitable and specific measures to safeguard the fundamental rights and interests of the individual.

 Processing is necessary for the purposes of preventative or occupational medicine, for assessing the working capacity of the employee medical diagnosis, the provision of health or social care or treatment or the management of health or social care systems and services on the basis of EU or Member State law or a contract with a health professional and subject to the necessary conditions and safeguards.

 Processing is necessary for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health or ensuring high standards of quality and safety of healthcare and of medicinal products or medical devices, on the basis of EU or Member State law which provides for suitable and specific measures to safeguard the rights and freedoms of the individual, in particular professional secrecy.

 Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes, which shall be proportionate to the aim pursued, respect the essence of the right to data protection and provide for suitable and specific measures to safeguard fundamental rights and interests of the individual.

 

 

1. GENERAL PRINCIPLES

The following general principles will apply to the Disciplinary, Dismissal and Grievance Procedures
– Each step and action will be taken without unreasonable delay. Please be aware that
timelines may vary to those set out in this policy, due to (for example) the volume or
complexity of the allegations being considered, or the availability of appropriate members of
staff to conduct each stage of the process.

– Whenever the employee is invited by the Company to attend a meeting, the employee must
take all reasonable steps to attend.

– At all stages of the procedure (except any investigation meetings) the employee will have
the right to be accompanied by a trade union representative or a work colleague of your
choice. If your choice of companion is unreasonable (e.g. because they are unavailable for a prolonged period of time or because of a conflict of interest) the Company may ask you to chose someone else. If your companion is unable to attend any such meeting you may suggest an alternative date, provided it is within 5 working days of the original date.

– Timing and location of meetings must be reasonable.

– Meetings will be conducted in a manner that enables both the Company and employee to explain their case.

– Meetings may be adjourned so that further investigation can be carried out in light of any new points raised. Any new information obtained will be provided to you for consideration before the meeting is reconvened.

– For appeal hearings following a decision the Company will as far as reasonably practicable, be represented by a more senior manager than attended the first meeting (unless the most senior manager attended that meeting).

– Whenever the company or employee is required to send the other a statement, the original
or a copy will suffice.

– If you have difficulty at any stage of the procedure because of a disability please discuss this as soon as possible with your line manager.

2. DISCIPLINARY, DISMISSAL AND GRIEVANCE PROCEDURES

2.1 PURPOSE

The Disciplinary, Dismissal and Grievance procedures are designed to help and encourage all employees to achieve and maintain appropriate standards of conduct, attendance and job performance. The company rules and these procedures apply to all employees. The aim is to ensure consistent and fair treatment for all in the organisation.

2.2 PRINCIPLES

– No disciplinary action will be taken against an employee until the case has been fully
investigated. The amount of investigation required will depend on the nature of the
allegations and will vary from case to case.

– The Company may suspend an employee with or without pay while an investigation takes place. Such a suspension will be reviewed as soon as possible and will not normally exceed 10 working days. Suspension of this kind is not a disciplinary penalty and does not imply any decision has been made about the allegations.

– An employee will not be dismissed for a first breach of discipline except in the case of gross misconduct (when the penalty may be dismissal without either notice or payment in lieu of notice).

– Misconduct will generally fall into two categories, namely “general” misconduct (in respect of which the general disciplinary action procedure described below applies) and “gross” misconduct, which is of so serious a nature that it justifies instant dismissal for a first offence. Listed below are examples which would normally be considered to be either general misconduct or gross misconduct. However, it should be recognised that neither list can be regarded as complete to meet every case, and also that action described as general misconduct may amount to and be treated as gross misconduct if the circumstances or the manner of the misconduct are such as to warrant serious disciplinary action. These lists
should be regarded therefore as being illustrative rather than exhaustive.

2.2.1 Examples of “gross” misconduct:

Summary dismissal (i.e. dismissal without notice or pay in lieu of notice) may be necessary in cases of gross misconduct. For guidance, the following are examples of the offences which may be regarded as gross misconduct and will normally result in summary dismissal.

 It is emphasised that this is not an exhaustive list:

– Unauthorised use or disclosure of confidential information or business matters relating
to the Company, its clients, temporary workers or applicants.

– Breach of the Data Protection Laws or the Company’s Data Protection Policy.

– Unauthorised amendments to the Company’s profile pages on any networking site or
Networking Site as defined in the Company’s Email, Telephone, Computer Facilities and
Social Media policy or website.

– Any prohibited use of the Company’s internet and email facilities as set out in the
Company’s Email, Telephone, Computer Facilities and Social Media Policy including in
particular any activities set out on sections 3.3, 4 and 5 of that policy.

– Acts of violence, including physical assault, unlawful discrimination, drunkenness, taking of non-prescribed drugs in such a way as to impair the ability to carry out work or conduct of any kind which endangers the health and safety of others.

– Any bullying or harassment of fellow employees, clients, candidates or any other person including via the company’s facilities or any Networking Sites (as defined in the Email, Telephone, Computer Facilities and Social Media Policy).

– A criminal offence committed at work other than a minor road traffic offence committed in the course of the employment, or an offence committed outside work which is incompatible with the employee remaining in the Company’s employment.

– Falsification of information or references on appointment.

– Theft or fraudulent activity.

– Unauthorised absence or gross negligence in the performance of duties.

– Breach of the Company’s Anti-Bribery and Corruption Policy.

– Breach of the Criminal Finances Act 2017.

– Any conduct tending to bring the Company, or the employee into disrepute or which
results in the loss of custom of a client, temporary or applicant or a loss of business.

– Working for or assisting a competitor of the company or seeking to establish a business
which is likely to compete with the company or divulging confidential information
concerning the company and its business.

– Serious insubordination or refusal to obey a lawful instruction in connection with the
employment.

– Deliberate and serious damage to property or causing any loss, damage or injury
through negligence.

– Serious misuse of the Company’s property or name.

2.2.2 Examples of “general” misconduct

The following may be regarded as reasons for disciplinary action in that they deviate from accepted standards and constitute general misconduct. The employee’s first offence will usually result in a written warning.

 

Repetition of offences following a warning could lead to a final written warning as appropriate. Thereafter any repetition will result in dismissal.

 

It is again emphasised that this is not an exhaustive list:

o Poor job performance.
o Poor time-keeping.
o Failure to comply with the conditions of your employment contract.
o Unseemly or disruptive conduct.

2.3 DISCIPLINARY ACTION

The following is the disciplinary action that may be taken against an employee in cases of
misconduct or unsatisfactory performance:

STAGE 1 – FORMAL WRITTEN WARNING

If an employee’s conduct or performance is unsatisfactory, they will be given a formal written warning. This written warning will include the reason for the warning and a note that, if there is no improvement after a specified period, a final written warning will be given. A copy of the written warning will be given to the employee and a copy will be placed on their personnel file. The warning will be disregarded after 6 months satisfactory service.

STAGE 2 – FORMAL FINAL WRITTEN WARNING

If following a written warning, conduct or performance remains unsatisfactory, or if a serious incident occurs, a final written warning will be given making it clear that any recurrence of the offence or other serious misconduct within a specified period will result in dismissal. A copy of the written warning will be given to the employee and a copy will be placed on their personnel file. The warning will then be disregarded after 12 months satisfactory service.

STAGE 3 – DISMISSAL OR OTHER SANCTION

If there is no satisfactory improvement in conduct or performance, or if further serious misconduct occurs within 12 months, the final step in the procedure may be dismissal, either with or without notice or payment in lieu of notice, or some other action short of dismissal such as disciplinary suspension or transfer to another department or job. Stage 3 may also apply to any gross misconduct (even if there are no active warnings on file) or any misconduct during your probationary period.

2.4 DISCIPLINARY PROCEDURE

2.4.1 Informal Discussion

 

1. Minor breaches of discipline, misconduct, poor time-keeping, etc may result in an informal discussion with the employee’s immediate superior.
   2. Although an informal warning will not be formally recorded for the purposes of any future disciplinary hearing, a note of the conversation may be kept on your personnel file.
   3. It is expected that in most cases an informal discussion will resolve most difficulties. Where an employee commits a more serious act of misconduct or fails to improve and maintain that improvement with regard to conduct, behaviour or job performance, the formal steps detailed below may be taken.

2.4.2 Formal Discussion 

Step 1 – Written Statement

The Company will inform the employee in writing of the alleged conduct or characteristics, or other circumstances, which lead the Company to contemplate dismissing or taking disciplinary action against the employee. This shall be done promptly after becoming aware of the circumstances, and the employee shall be invited to attend a meeting to discuss the matter, once any necessary investigations have been conducted to establish the facts of the matter. The Company will provide a
copy of any relevant documents which will be used at the disciplinary meeting to the employee in advance of the meeting.

Step 2 – Meeting

1. The meeting will take place before any action is taken, except in the case where the disciplinary action consists of a suspension on full pay, in order to investigate the allegation.
   2. The meeting will not take place unless:
   – the Company has informed the employee of the ground or grounds for contemplating
   disciplinary action or dismissal; and the employee has had a reasonable opportunity to consider his response to that information.
   3. The employee has the right to be accompanied at the meeting by a work colleague or a Trade Union representative.
2. After the meeting, the Company will inform the employee in writing of its decision as soon as reasonably possible (but normally within one week of the meeting) and notify him of the right to appeal against the decision if he is not satisfied with it.

Step 3 – Appeal

1. If the employee does wish to appeal, s/he must inform the Company within 5 working days of receiving the decision, and on doing so the Company will invite him/her to attend a further meeting.
   2. The appeal meeting may not necessarily take place before the dismissal or disciplinary action takes effect but it will be arranged within a reasonable period of time.
   3. The appeal will be dealt with by a more senior manager than at the Step 2 meeting. Where this is not practicable, the company will hear the appeal and decide the case as impartially as possible.
   4. After the appeal meeting, the Company will inform the employee of its final decision in writing, as soon as reasonably possible (but normally within one week of the meeting). The Company may uphold or revoke the original decision or substitute a different penalty.
   GRIEVANCE PROCEDURE
   If an employee has a problem or concern about their work, working conditions or a relationship with
   a colleague, they should aim to settle their grievance informally with their line manager.
   If an employee’s grievance cannot be settled informally, or a formal approach is preferable, the
   employee should raise it formally with management by following the procedure below.

Step 1 – Written statement

The employee must set out their grievance in writing and send this statement to your line manager unless your grievance concerns your line manager in which case the grievance should be submitted to the Director. Include facts, dates, a chronology and names of individuals, as appropriate. The subject heading should be marked as “Formal Grievance”.

Step 2 – Meeting

1. The company will invite the employee to attend a meeting to discuss the grievance, normally within 5 days, but longer where it is necessary to undertake an investigation to establish the facts or it is otherwise impracticable.

 

2. The meeting will not take place unless:
   – the employee has informed the Company of the basis for the grievance in writing; and
   – the Company has had a reasonable opportunity to consider its response to that information
3. After the meeting the Company will inform the employee of its decision, as soon as reasonably practicable (but normally within one week of the meeting), and the Company will notify the employee of his right to appeal if he is not satisfied with it.

Step 3 – Appeal

If the employee does wish to appeal, he must inform Ioan Maftei within 5 working days of receiving the decision, and on doing so the company will invite him to attend a further meeting.

After the appeal meeting, the Company will inform the employee of its final decision as soon as is reasonably practicable (but normally within one week of the meeting). The Company’s decision is final.

 

 

 

D&I Recruitment Ltd is committed to providing a safe, healthy and secure environment for all our employees, and anyone involved in our operations and activities. The work & reputation of D&I Recruitment Ltd will not be compromised by the presence of individuals who are under the influence of alcohol; non-prescribed drugs or the abuse of prescribed medication or legal highs in the workplace. Therefore we enforce a zero tolerance policy for the use and abuse of drugs, alcohol and any other substance that would compromise safety and affect a person’s fitness for duty and concentration.

This policy is designed to eliminate the risk of drug, alcohol and substance abuse and applies to all our staff including senior managers and directors or anyone who is representing us. Any use of prescribed or “over the counter” medication, which carries any risk of affecting a person’s reactions, ability to take decisions or causes drowsiness MUST be reported to D&I Recruitment Ltd prior to you accepting work with us.
 

Policy Requirements:

 

• Employees must be able to carry out their duties and must not be under the influence of alcohol or any other substance that would impair their ability to work safely and within the law.

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• We have a zero tolerance to drugs and alcohol. Employees are not permitted to work under the influence of drugs and alcohol – anyone suspected of being impaired due to alcohol, drugs legal or illegal or substance will immediately be removed from the position they are working in.

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• Our clients reserve the right to carry out random testing and screening for alcohol and drugs. Testing will automatically be carried out on reasonable suspicion or following an incident or accident.

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• We shall ensure that anyone who is deemed unfit for work in line with our zero-tolerance policy will be dealt with in a fair, consistent and constructive manner.

​The use of illegal drugs will invariably adversely affect a person’s ability to carry out his/ her duties and to make decisions. This causes that person to be a danger to both him/ herself and those around them. Any person found in possession of, or with traces of illegal drugs in a blood or urine sample will be immediately removed from the workplace and at the sole discretion of the company may be subsequently dismissed.

 The Directors endorse this policy to confirm their commitment to maintaining a safe and healthy workplace for all employees, visitors and the public.

 

D&I Recruitment Ltd embraces diversity and aims to promote the benefits of diversity in all of our business activities. We seek to develop a business culture that reflects that belief. We will expand the media in which we recruit to in order to ensure that we have a diverse employee and candidate base. We will also strive to ensure that our clients meet their own diversity targets. 

​D&I Recruitment Ltd is committed to diversity and will promote diversity for all employees, workers and applicants. We will continuously review all aspects of recruitment to avoid unlawful discrimination. D&I Recruitment Ltd will treat everyone equally and will not discriminate on the grounds of an individual’s “protected characteristic” under the Equality Act 2010 (the Act) which are age, disability, gender re-assignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation. We will not discriminate on the grounds of an individual’s membership or non-membership of a Trade Union. All staff have an obligation to respect and comply with this policy. D&I Recruitment Ltd is committed to providing training for its entire staff in equal opportunities and diversity. D&I Recruitment Ltd will avoid stipulating unnecessary requirements which will exclude a higher proportion of a particular group of people and will not prescribe discriminatory requirements for a role.

​D&I Recruitment Ltd will not discriminate unlawfully when deciding which candidate/temporary worker is submitted for a vacancy or assignment, or in any terms of employment or terms of engagement for temporary workers. D&I Recruitment Ltd will ensure that each candidate is assessed in accordance with the candidate’s merits, qualifications and ability to perform the relevant duties for the role. 

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DISCRIMINATION

​Under the Act unlawful discrimination occurs in the following circumstances: 

​Direct discrimination

​Direct discrimination occurs when an individual is treated less favourably because of a protected characteristic. Treating someone less favourably means treating them badly in comparison to others that do not have that protected characteristic.

​It is unlawful for a recruitment consultancy to discriminate against a person on the grounds of a protected characteristic: 

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• in the terms on which the recruitment consultancy offers to provide any of its services; 
• by refusing or deliberately omitting to provide any of its services; 
• in the way it provides any of its services. 

​Direct discrimination can take place even if the individual does not have the protected characteristic but is treated less favourably because it is assumed he or she has the protected characteristic or is associated with someone that has the protected characteristic.

​Direct discrimination would also occur if a recruitment consultancy accepted and acted upon instructions from an employer which states that certain persons are unacceptable due to a protected characteristic, unless an exception applies. The Act contains provisions that permit specifying a requirement that an individual must have a particular protected characteristic in order to undertake a job. These provisions are referred to as occupational requirements.

Where there is an occupational requirement then the client must show that applying the requirement is a proportionate means of achieving a legitimate aim, i.e. the employer must be able to objectively justify applying the requirement. An occupational requirement does not allow an employer to employ someone on less favourable terms or to subject a person to any other detriment. Neither does an occupational requirement provide an excuse against harassment or victimisation of someone who does not have the occupational requirement. 

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Indirect discrimination 

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Indirect discrimination occurs when a provision, criterion or practice (PCP) is applied but this results in people who share a protected characteristic being placed at a disadvantage in comparison to those who do not have the protected characteristic. If the PCP can be objectively justified it will not amount to discrimination.  

Indirect discrimination would also occur if a recruitment consultant accepted and acted upon an indirectly discriminatory instruction from an employer. 

​If the vacancy requires characteristics which amount to an occupational requirement or the instruction is discriminatory but there is an objective justification, D&I Recruitment Ltd will not proceed with the vacancy unless the client provides written confirmation of the occupational requirement, exception or justification. 

​D&I Recruitment Ltd will use best endeavours to comply with the Act and will not accept instructions from clients that will result in unlawful discrimination. 

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Harassment  

​Under the Act, harassment is defined as unwanted conduct that relates to a 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. This includes unwanted conduct of a sexual nature. 

​D&I Recruitment Ltd is committed to providing a work environment free from unlawful harassment. 

D&I Recruitment Ltd will ensure that the consultants do not harass any individual.

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Examples of prohibited harassment are: 

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1. verbal or written conduct containing derogatory jokes or comments; 
2. slurs or unwanted sexual advances; 
3. visual conduct such as derogatory or sexually orientated posters; 
4. photographs, cartoons, drawings or gestures which some may find offensive; 
5. physical conduct such as assault, unwanted touching, or any interference because of sex, race or any other protected characteristic basis;
6. threats and demands to submit to sexual requests as a condition of continued employment or to avoid some other loss, and offers of employment benefits in return for sexual favours; 
7. retaliation for having reported or threatened to report harassment. 

​If an individual believes that they have been unlawfully harassed, they should make an immediate report to Ioan Maftei, Director followed by a written complaint as soon as possible after the incident. The details of the complaint should include:  

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• Details of the incident 
• Name(s) of the individual(s) involved 
• Name(s) of any witness(es) 

​D&I Recruitment Ltd will undertake a thorough investigation of the allegations. If it is concluded that harassment has occurred, remedial action will be taken. 

​All employees and workers will be expected to comply with D&I Recruitment Ltd’s policy on harassment in the workplace. Any breach of such a policy will lead to the appropriate disciplinary action. 

​Any individual who D&I Recruitment Ltd finds to be responsible for harassment will be subject to the disciplinary procedure and the sanction may include termination. 

​Victimisation 

​Under the Act victimisation occurs when an individual is treated unfavourably because he/she has done a ‘protected act’ which is bringing a claim for unlawful discrimination or raising a grievance about discrimination or giving evidence in respect of a complaint about discrimination. 

​D&I Recruitment Ltd will ensure that the consultants do not victimise any individual.

 Disabled Persons

​Discrimination occurs when a person is treated unfavourably as a result of their disability.

​In direct discrimination occurs where a provision, criterion or practice is applied by or on behalf of an employer, or any physical feature of the employer’s premises, places a disabled person at a substantial disadvantage in comparison with persons who are not disabled. 

​In recruitment and selection there may be a requirement to make reasonable adjustments. For example, it might be necessary to have different application procedures for partially sighted or blind applicants that enable them to use Braille. With testing and assessment methods and procedures, tests can only be justified if they are directly related to the skills and competencies required for the job. Even then, it might be appropriate to have different levels of acceptable test results, depending on the disability. For example, an applicant with a learning disability might need more time to complete a test, or not be expected to reach the same standard as other non-disabled applicants. 

​Reasonable adjustments in recruiting could include: 

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• modifying testing and assessment procedures;  
• meeting the candidate at alternative premises which are more easily accessible;  
• having flexibility in the timing of interviews;  
• modifying application procedures and application forms;  
• providing a reader or interpreter.  

​Wherever possible D&I Recruitment Ltd will make reasonable adjustments to hallways, passages and doors in order to provide and improve means of access for disabled employees and workers. However, this may not always be feasible, due to circumstances creating such difficulties as to render such adjustments as being beyond what is reasonable in all the circumstances. 

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D&I Recruitment Ltd will not discriminate against a disabled person:  

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• in the arrangements i.e. application form, interview or arrangements for selection for determining whom a job should be offered; or 
• in the terms on which employment or engagement of temporary workers is offered; or 
• by refusing to offer, or deliberately not offering the disabled person a job for reasons connected with their disability; or 
• in the opportunities afforded to the person for receiving any benefit, or by refusing to afford, or deliberately not affording him or her any such opportunity; or 
• by subjecting the individual to any other detriment (detriment will include refusal of training or transfer, demotion, reduction of wage, or harassment). 

​D&I Recruitment Ltd will make career opportunities available to all people with disabilities and every practical effort will be made to provide for the needs of staff, candidates and clients.  

 Age Discrimination 

 Under the Act, it is unlawful to directly or indirectly discriminate against or to harass or victimise a person because of age.  Age discrimination does not just provide protection for people who are older or younger. People of all ages are protected. 

​A reference to age is a reference to a person’s age group. People who share the protected characteristic of age are people who are in the same age group. 

​Age group can have various references: 

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• Under 21s 
• People in their 40s 
• Adults  

​D&I Recruitment Ltd will not discriminate directly or indirectly, harass or victimise any person on the grounds of their age. We will encourage clients not to include any age criteria in job specifications and every attempt will be made to encourage clients to recruit on the basis of competence and skills and not age. 

​D&I Recruitment Ltd is committed to recruiting and retaining employees whose skills, experience, and attitude are suitable for the requirements of the various positions regardless of age. No age requirements will be stated in any job advertisements on behalf of the company. 

​If D&I Recruitment Ltd requests age as part of its recruitment process such information will not be used as selection, training or promotion criteria or in any detrimental way and is only for compilation of personal data, which the company holds on all employees and workers and as part of its equal opportunities monitoring process. In addition if under age 22 to adhere to Conduct of Employment Agencies and Employment Business Regulations 2003 and other relevant legislation applicable to children or young candidates.

​Where a client requests age or date of birth, this will have to be under an occupational requirement or with an objective justification which should be confirmed in writing.

​Part-time Workers​

​This policy also covers the treatment of those employees and workers who work on a part-time basis, D&I Recruitment UK Ltd recognises that it is an essential part of this policy that part time employees are treated on the same terms, with no detriment, as full time employees (albeit on a pro rata basis) in matters such as rates of pay, holiday entitlement, maternity leave, parental and domestic incident leave and access to our pension scheme. D&I Recruitment UK Ltd also recognises that part time employees must be treated the same as full time employees in relation to training and redundancy situations. 

Gender Reassignment Policy

 D&I Recruitment Ltd recognises that any employee or worker may wish to change their gender during the course of their employment with the Company. 

​D&I Recruitment Ltd will support any employee or worker through the reassignment. 

D&I Recruitment Ltd will make every effort to try to protect an employee or worker who has undergone, is undergoing or intends to undergo gender reassignment, from discrimination or harassment within the workplace.  

Where an employee is engaged in work where the gender change imposes genuine problems D&I Recruitment will make every effort to reassign the employee or worker to an alternative role in the Company, if so desired by the employee. 

​Any employee or worker suffering discrimination on the grounds of gender reassignment should have recourse to the Company’s grievance procedure.   

Recruitment of Ex-Offenders 

 Where D&I Recruitment Ltd has registered with the Disclosure and Barring Service (DBS) and has the authority to apply for criminal records checks on individual because they are working with children or vulnerable adults or both, we will comply with the DBS’s Code of Practice which includes having a policy on the recruitment of ex-offenders.​

Complaints and Monitoring Procedures 

​D&I Recruitment Ltd has in place procedures for monitoring compliance with this policy and for dealing with complaints of discrimination. These are available from Ioan Maftei and will be made available immediately upon request.  Any discrimination complaint will be investigated fully. 

 D&I Recruitment Ltd is committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses.  

 D&I Recruitment Ltd is committed to ensuring that its staff and any workers it supplies (directly or indirectly) are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses.  

 D&I Recruitment Ltd provides appropriate training and awareness information for all of its staff. 
In particular: 

 

• All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.

​Any staff member, worker or other parties are strongly encouraged to report any concerns or suspicions that they might have to Ioan Maftei – Director. 

 Reports surrounding these issues are taken extremely seriously by our board of directors who are committed to ensuring that all investigations shall be prompt and effective. If our investigations reveal any issues, we are committed to taking appropriate action, including but not limited to:

 

• Working with the appropriate organisations to improve standards
• Removing that organisation from our preferred supplier list,
• Passing details to appropriate law enforcement bodies.

 We regularly monitor our risks in this area through the use of relevant key performance indicators, including:

 The percentage of suppliers who sign up to an appropriate code/provide their own modern slavery statements. 

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• The effectiveness of enforcement against supplies who breach policies
• The amount of time spent on audits, re-audits, spot checks and related due diligence
• The level of modern slavery training and awareness amongst staff

 As part of our efforts in this area, we publish a modern slavery statement on an annual basis. 

 

We would also recommend reading this in conjunction with our other policies, including our:

 

• Corporate social responsibility policy,
• Ethical procurement policy,
• Anti-bribery / corruption policy, and
• Whistle-blowing policy.

 This policy was adopted on 1st January 2016 after being agreed by the Business Director.  It is reviewed annually.  

This statement is made as part of D&I Recruitment Ltd’s commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act).  It summarises how D&I Recruitment Ltd operates, the policies and processes in place to minimise the possibility of any problems, any risks we have identified and how we monitor them, and how we train our staff.  

​This statement is published in accordance with section 54 of the Act and relates to the financial year April 2023 to April 2024. It was approved by the director on 29th March 2023.

 Ioan Maftei, Director, our business D&I Recruitment Ltd is a limited company operating in the recruitment sector. We supply temporary workers / act as a neutral vendor / and act as a master vendor] in the Transport & Logistics sectors.

 D&I Recruitment Ltd is an independent business. All of the hirers that we work with, and all of the work-seekers we provide, are known to and identified by our staff.  All of the temporary workers we supply are identified by our staff. Some of these work-seekers operate through their own limited companies.  Some of our work-seekers are supplied via other businesses, who facilitate providing them to the eventual hiring company.

​As a “master vendor”, we work with other businesses to supply workers to hiring companies.  We hire some of the workers directly, who are directly recruited by our staff.  Other workers are hired directly by other businesses. Some of these workers operate through their own limited companies. We facilitate supplying a mix of these workers to the hiring companies.

​The hiring companies that we work with are located in Essex, Herts & London.  The workers we supply live in these areas.

 

Other relationships

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• As part of our business, we also work with the following organisations:
• the Recruitment and Employment Confederation (rec.uk.com) 
• Our Policies
• In addition, D&I Recruitment Ltd has the following policies which incorporate ethical standards for our staff:
• GDPR
• Drugs & Alcohol
• Child Labour
• Disciplinary, dismissal & grievance 
• AWR – Agency Worker Regulations

 

Policy development and review

​D&I Recruitment Ltd ’s policies are established by our directors, based on advice from HR professionals, industry best practice and legal advice. We review our policies on a regular basis, or as needed to adapt to changes.  Our Processes for Managing Risk

In order to assess the risk of modern slavery, we use the following processes with our suppliers:

 

• When engaging with suppliers, we ask for evidence of their processes and policies, including commitments around modern slavery, human trafficking, forced labour, human rights, and whistle-blowing.
• We conduct audits before entering into a commercial relationship with any business where there is the potential for risk.  These audited businesses form the basis of our preferred supplier list.

​We review the potential for risk at regular intervals, including the possibility of re-auditing a supplier or conducting spot checks.

 After due consideration, we have not identified any significant risks of modern slavery, forced labour, or human trafficking in our supply chain. However, we continue to be alert to the potential for problems.  

 Additionally, we have taken the following steps to minimise the possibility of any problems:

 

• We reserve the right to conduct spot-checks of the businesses who supply us, in order to investigate any complaints.
• We require the businesses we work with to address modern slavery concerns in their policies.
• We collaborate with our suppliers in order to improve standards and transparency across our supply chain.
• Only senior members of staff who have undergone appropriate training for assessing modern slavery risks in the supply chain are authorised to sign contracts and establish commercial relationships in any area where we have identified the potential for risk.
• We ensure that all of our suppliers are members of appropriate industry bodies and working groups.
• Our staff are encouraged to bring any concerns they have to the attention of management.

​Our Performance:

 

• Based on the potential risks we have identified, we have also established the following key performance indicators, which are regularly assessed by our board of directors:
• the percentage of suppliers who sign up to an appropriate code / provide their own modern slavery statements
• the percentage of workers and/or candidates supplied from audited businesses
• the effectiveness of enforcement against suppliers who breach policies
• the amount of time spent on audits, re-audits, spot checks, and related due diligence
• the level of modern slavery training and awareness amongst our staff 

• We benchmark our indicators against industry best-practice, in order to ensure that we do not put undue pressure on our suppliers that might increase the potential for risk. 

​Our Training

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• All of our staff receive training and support that is appropriate to their role.  In particular:
• All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.
• As part of this, our staff are encouraged to discuss any concerns that they have.  
• Training is refreshed regularly.